ML22242A001
| ML22242A001 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/2022 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Tyree C | |
| References | |
| NRC-2048 | |
| Download: ML22242A001 (92) | |
Text
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting on the Development of Risk-Informed License Renewal
Docket Number: (n/a)
Location: teleconference
Date: Thursday, August 4, 2022
Work Order No.: NRC-2048 Pages 1-92
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234 -4433 1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
+ + + ++
PUBLIC MEETING ON THE DEVELOPMENT OF RISK-INFORMED
+ + + + +
THURSDAY,
AUGUST 4, 2022
+ + + + +
The meeting convened via Video
Teleconference, at 1:00 p.m. EDT, Christopher Tyree,
NRR, presiding.
PRESENT:
CHRISTOPHER TYREE, Division of New and Renewed
Licenses
WENDY BROST, South Texas Project
LAUREN GIBSON, Division of New and Renewed Licenses
ALLEN HISER, Division of New and Renewed Licenses
EDWIN LYMAN, Union of Concerned Scientists
BRETT TITUS, Nuclear Energy Institute
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 2
TABLE OF CONTENTS
Page
Opening Remarks....................................4
Opportunities to Risk Inform in License Renewal
(10 CFR Part 54)...................................5
Presentations
Union of Concerned Scientists...................39
NEI.............................................41
South Texas Project.............................57
Open Discussion/Public Comments...................86
Closing Remarks...................................90
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 3
P-R-O-C-E-E-D-I-N-G-S
1:00 p.m.
MR. TYREE: Good afternoon. This is the
public meeting on risk-informing subsequent license
renewal. Today's meeting is a comment-gathering
public meeting where we are looking for feedback and
comments on areas where we can risk-inform various
aspects of thelicense renewal process.
My name is Chris Tyree, I am project
manager in the License Renewal Branch in the Division
of New and Renewed Licenses here at the NRC.
The agenda for today's meeting includes
four presentations, and/or remarks, that will be
provided by Dr. Allen Hiser and Lauren Gibson from the
NRC in the division of new and renewed licenses. Dr.
Lyman will be joining us shortly from the Union of
Concerned Scientists to give some remarks. Brett
Titus from the Nuclear Energy Institute. And Wendy
Brost from the South Texas Project.
So, let me provide a quick agenda for
everyone to see.
So we will be having a pretty large chunk
of time to go and provide, you know, for open discussion
and comments at the end. So we want to get everyone's
feedback.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 4
In the room with me we have Brian Harris
and Lauren Gibson. And we have a few housekeeping type
items. So we are having a court reporter transcribe
this meeting. So please, whenever you speak, state
your name first. And if you are with an organization,
that's up to you.
And just speak clearly and loudly. Don't
speak over one another. Use the hand raise function
in Teams chat. And also, if you're not speaking,
please have your line muted.
And with that, we will get started with
opening remarks from Lauren.
MS. GIBSON: Good afternoon. We're
having this meeting as a follow-up to the RIC session
that happened earlier this year. We're really
interested in hearing from a broader range of
stakeholders about how they would like us to move
forward with risk-informing license renewal.
We do have the risk-informed AMPs that NEI
sent in. But is there something else? Where else
should we be looking?
So we're really looking forward to the
discussion. Thank you for participating today.
MR. TYREE: Thank you, Lauren. With
that, we will begin with the first presentation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 5
DR. HISER: Okay. Thank you, Chris.
This is Allen Hiser with the NRC Staff, Division of
New and Renewed Licenses. And the presentation that
I will provide is very similar to what Lauren Gibson
provided at the RIC session in March, that she
mentioned, but there is a lot more detail so that we
can maybe have a little more in-depth discussion
overall.
Next slide, Chris. So why are we here
today? NRC is working to become a modern risk-informed
regulator.
As has been mentioned, we're currently
evaluating industry proposed risk-informed aging
management programs. At this point this is the only
thing that we really have on the table related to
license renewal. So we are looking at the potential
for risk-informing other aspects of the license renewal
process.
So what we want to come out of this meeting
today, is to understand industry perspectives on areas
that they think may be right for risk-informing. Gain
understanding of public perspectives. We do have Dr.
Lyman of UCS so we're looking forward to his comments.
And in combination with this, we will develop a path
forward that we would then look to implement.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 6
Next slide. Now to layout what I will talk
about. The main thing I want to do is to try to achieve
a common understanding of how risk is treated in the
regulatory framework overall.
Assessment of how risk is currently used
in license renewal. Looking at the rule and the
current process. How they deal with risk. Looking
at some of the discussion, the statements of
consideration from the rulemakings that have led to
Part 54.
Look at some possibilities within the
current rule. Then speak a little bit about use of
risk and program implementation. And then some
overall approaches that could be used to risk-inform
Next slide, Chris. Now, in terms of
defining risk, risk from a regulatory perspective is
a combined answer to three questions.
This represents what we at NRC call the
risk triplet. First of all, what can go wrong, second
of all, how likely is it, and thirdly, what would be
the consequences if things went wrong.
So these three questions allow the NRC to
understand likely outcomes, sensitivities, areas of
importance, system interactions and areas of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 7
uncertainty. Which can be used to identify
risk-significant scenarios.
Next slide. Then in terms of some related
concepts that mention risk. And this really came off
the NRC web page, pretty much word-for-word.
The items that I've highlighted in green
are things that we endorse as being a risk-informed
regulatory. So risk-informed decision making uses
insights from probabilistic risk assessment, which are
considered with other engineering insights to make
decisions.
Risk-based decision making is a little bit
different in that that would only consider the results
of a PRA. And NRC does not ascribe to risk-based
decision making. We are a risk-informed regulatory.
Risk-informed regulation incorporates
assessment of safety significance or relative risks.
Ensures that the regulatory burden is appropriate to
its importance in protecting health and safety of the
public and the environment.
Performance-based regulation is somewhat
related. This focuses on desired outcomes rather than
prescriptive processes, procedures, et cetera. So its
performance-based regulation is looking at the
results, not necessarily providing a detailed list of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 8
things to do. We're concerned more with the outcomes.
In all of these cases that we deal with,
the risk-informed decision making regulation and
performance-based regulation. The objective is to
maintain adequate levels of plant safety. The intent
is not to reduce plant safety.
Next slide, Chris. Now, in terms of the
outline, the next thing I'll discuss is rule and current
process on using risk assessment in license renewal.
Next slide. So how does risk relate to
license? I mean, there are potential uses of risk in
For example, Part 54 license renewal rule,
which governs the issuance of renewed operating
licenses. Two aspects could relate to submittal of
the application and contents of the application. And
secondly, the NRC review of the application. Those
are potential areas.
In terms of plant implementation of
license renewal activities, this could be, from the
perspective of aging management programs, of how they
would be implemented at plants. Could also relate to
implementing changes to aging management programs.
So the focus of the next section that I
will discuss is on how risk information can be used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 9
consistent with the current license renewal rule.
Next slide, Chris. So how does license
renewal rule address risk?
First of all, Part 54 does not directly
mention risk. If you do a word search, it's not there.
So what I will do is provide a description of the Part
54 license renewal process as it's implemented today
and summarize some of the part 54 rulemaking statements
of consideration to see how the Commission envisioned,
30 years ago, how risk could be used within license
renewal.
Next slide. Now, in terms of license
renewal process, the thing that I'll focus on is the
integrated plant assessment. And this includes
identification of system, structures and components
that are in the scope of Part 54. And I'll talk about
that on the next slide, what the scope is.
And for the in-scope SSCs, the next step
in the process would be to identify the structures and
components that require aging management review. And
then for each structure and component that's been
identified in the second bullet there, the applicant
is required to demonstrate that the effects of aging
will be adequately managed so that the intended
functions of the structure or component will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 10
maintained.
Next slide. Now in terms of the scoping,
it's laid out in Paragraph 54.4(a). The scope includes
system structures and components that are safety
related, things that are non-safety related whose
failure could prevent accomplishment of safety related
functions.
Those that are relied on for compliance
with certain NRC regulations. A few that I have listed
there. Fire protection and station blackout. There
are three others as well.
Now, in terms of safety-related SSCs,
those would have functions that would achieve one of
the following three purposes. Either to maintain
integrity of the reactor coolant pressure boundary,
to shut down the reactor and maintain it in a safe
shutdown, or to prevent or mitigate the consequences
of accidents which could result in potential offsite
exposures.
The one commonality, really in the way that
SSCs, if you will, system, structures and components,
are scoped in for license renewal, is an emphasis on
the intended function of the SSC. And in Part 54 its
described that the intended functions are those
functions that are the bases for including the SSC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 11
within the scope of a license renewal.
So as you'll see we go through the next
few slides, intended function is really what's
preserved by the license renewal rule. And that's what
brings things into the scope of license renewal.
Next slide. Now for in-scope SSCs, they
have to meet one of those criteria on the previous page.
The applicant is required to identify those structures
and components that require aging management review.
And these SCs are those that are described
as colloquially as passive and long-lived. And
passive is actually provided in a few more words in
the license renewal rule. It says those, the SCs that
are passive are those that perform their intended
function without moving parts or without a change in
configuration or properties.
I guess just of sort to restate, passive
is not in the rule. But the context of this performing
intended function without moving parts or changing
configuration we have sort of summarized as the one
using the term passive.
Similarly, the rule says that SCs that are
not subject to replacement based on a qualified life
or specified time period would become subject to an
aging management review. And again, our phrase for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 12
that is long-lived. So that long-lived is not within
the rule but that refers to SCs that are not subject
to replacement.
Next slide, Chris. Now, the purpose of
the aging management review is to demonstrate that the
effects of aging will be adequately managed so that
the intended functions will be maintained consistent
with the CLB for the period of extended operation.
So again, you see the word intended
functions there. That's what the purpose is of what
we do within license renewal.
Now, generally this is achieved in two
steps. The first is described, for those structures
and components that are subject to aging management
review, you identify the aging effects that could
prevent intended functions from being performed.
So these aging effects could be cracking,
loss of fractured toughness, loss of material, things
like that. There are many more intended functions that
are described in the standard review plan for license
renewal and for subsequent license renewal.
Once you've identified the aging effects
they could prevent intended functions. And you
identify aging management programs that will be used
to manage the effects of aging so that the intended NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 13
functions can be preserved for the structure or
component.
Next slide. Now, in terms of approving
a renewed license, 54.29(a) has the following
statements. First, the Staff has to be able to
demonstrate that there is reasonable assurance that
the activities authorized by the renewed license will
continue to be conducted in accordance with the CLB.
One of the things that must be addressed
is that the applicant will be able to manage the effects
of aging during the period of extended operation on
the functionality of structures and components that
have been identified to require review. So again, we
come back to functionality being one of the main
standards that we have to be able to demonstrate in
our review.
Next slide. Now to summarize Part 54 as
it's written, and as it has been implemented at this
point, scoping is deterministic. All SSCs that meet
the scoping criteria are included. And that's based
on the SSC intended functions.
The screening term, which is identifying
the passive, long -live components that are subject to
aging management review, the rule says, all SCs that
are in effect passive and long-lived are subject to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 14
screening.
Aging management review is deterministic.
The rule states, for each SC you have to demonstrate
thatthe effects of aging will be adequately managed
so that the intended functions will be maintained.
So all three aspects of this, clearly as
written, are deterministic. All SSCs, all SCs and for
each SC. So there is no ability to exclude structures
and components or systems based on any other criteria.
Next slide, Chris. Now jumping down to
discussion and rulemaking statements of
considerations.
Next slide. The license renewal rule has
had two rulemakings associated with it. One was in
1991 and the other is 1995.
Looking at some of the language from 1991,
I tried to highlight the important piece. Tried to
paraphrase, you know, extract their statements in to tal
so that you can understand the context.
But the first piece there, the Commission
acknowledges that PRA techniques could be used as a
supplemental tool, and the renewal applicants
integrated plant assessment. And further the
Commission states that PRA can be effective, an
effective tool to provide added assurance that all SSCs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 15
important to license renewal have been evaluated.
One reading of this would indicate that
the focus is on ensuring that you've included all
important SSCs so that the risk information could be
used to bolster the list of SSCs that have to be
considered for aging management review.
The next bullet there says that the
screening methods, as well as aging management
approaches, may also include use of PRA techniques as
a supplement to the primary, primarily deterministic
methods. No real additional discussion onthat, but
I think there was a recognition that there could be
a role for PRA, but at least in 1991, 31 years ago,
the Commission was not able to provide any additional
light on that.
Next slide, Chris. So again, looking
further in that statement of consideration for 1991,
the Commission, another statement was the Commission
considers that at the present time, 1991, appropriate
aging data and models had not been developed for many
SSCs for inclusion in the PRAs and uniformed criteria
did not exist for evaluating the PRA results.
As we talk a little bit later I think the
models and data for aging have been significantly
improved over the last 31 years. But how well those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 16
have been integrated in the PRAs is, I think, not clear
to us. And so, how well the PRA results can be used
at face value is something that I think we would have
a lot of questions on and want to have discussion on.
The Commission goes on. Nevertheless at
the present time, probabilistic assessments can be
helpful to help draw attention to specific
vulnerabilities and help guard against significant
oversights in the screening process.
Again, to me this indicates that the
Commission was, had intended at least that PRA would
be used to ensure that there weren't additional
vulnerabilities that could be missed otherwise. And
so that could be used to potentially enlarge the scope,
if you will, of license renewal. And the list of
structures and components that are subject to aging
management review.
The Commission continues. Probabilistic
assessment alone is not an acceptable basis for the
exclusion of SSCs to be evaluated as part of an IPA.
I think this is probably the most definitive statement
that the Commission makes about PRA.
And to go on. It may be useful to identify
additional SSCs to be evaluated as a part of the
independent plant assessment. Or integrated plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 17
assessment.
Next slide, Chris. Now, in 1995 the
Commission had put out the rule, revised rule, for
public comment. And had received comments, obviously
from the public.
And there were some statements that, or
some comments that the Commission received that the
Commission should require that plants implement PRAs
to supplement what's in the license renewal rule. And
the Commission declined to do that.
But they did say that, again, this is 1995,
within the construct of the final rule, PRA techniques
are a very limited use for license renewal scoping.
A little bit further into the SOC, the statements made
that PRA may be useful on a plant specific basis by
helping to draw attention to specific vulnerabilities.
So again, the Commission's emphasis seemed
to be on ensuring the adequacy of the scoping that's
used for license renewal.
Probabilistic arguments may assist in
developing an approach for aging management adequacy.
However, probabilistic arguments alone will not be
an acceptable basis for concluded that the effects of
aging will be adequately managed in the period of
extended operation.
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So PRA alone was considered in 1995 not
to be adequate by the Commission.
Next slide, Chris. And my summary of
what's in the statements of considerations for the two
rule versions, or the two final rule designations, PRA
can be an effective tool to provided added assurance.
All SSCs important to license renewal and
then evaluated, and may be useful to identify
additional SSCs that should be evaluated as a part of
a IPA. PRA techniques could be used as a supplemental
tool in the applicants IPA. And as a supplement to
the primarily deterministic methods for the screening
methods and aging management approaches that are in
the rule.
Again, dating from 1991, appropriate aging
data and models had not been developed for many SSCs
for inclusion in the PRAs. And I wouldsay, at this
point, talking with our PRA experts, it's not clear
how well or even if these models had been incorporated
into PRAs.
And finally, PRA techniques are not an
acceptable basis for the exclusion of SSCs to be
evaluated as part of an IPA. And are a very limited
use for license renewal scoping.
Next slide, Chris. Now from our standard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 19
review plan for subsequent license renewal. And I hope
this is, comes across large enough.
There's a couple of statements on use of
risk. And oneof them, at the top here, is that the
reviewer should focus on IPE, individual plant
examination information, pertaining to plant changes
or modifications that are initiated by the licensee
in accordance with 50.59 or 10 CFR 50.90. Again, I
think this is mainly looking at whether any structure
or component that is important from a risk perspective
should be included in the scope.
Many of the AMPs include statements
similar to that second bullet where potential augmented
requirements for aging management could include, it's
highlighted in green, additional locations that are
based on risk-insights based on susceptibility to aging
effect and consequences failure.
So this is seen by many of the answers a
way to, if you will, focus the inspections on certain
locations based on their risk profile. Including both
the susceptibility and the consequences.
And in the third bullet there, use of
probabilistic arguments alone is not an acceptable
basis for concluding that for those SSCs subject to
an again management review, the effects of aging will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 20
be adequately managed in the subsequent period of
extended operation.
And finally, risk significance may not be
used to conclude that no AMP is necessary for SOR for
any structure or component that is subject to aging
management review.
Next slide, Chris. Then we'll jump to
maybe certain possibilities that could be implemented
within the current rule to incorporate risk
information.
Next slide. So several opportunities for
use that I think would be consistent with the current
rule.
One is a development of risk-informed
aging management programs that could be included in
the GALL-SLR. As I believe Lauren mentioned earlier,
we did receive a letter from the Nuclear Energy
Institute about almost seven months ago, the proposed
two risk-informed AMPs.
I expect from Brett Titus later we'll hear
more about these AMPs and industry's plans to maybe
expand the list of AMPs that are risk-informed.
There's a potential that the NRC level of
review of aging management review line items could be
risk-informed. And also our review of enhancements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 21
or exceptions within the aging management programs.
Next slide, Chris. And on terms of the
aging management review line items, regarding using
information from 10 CFR 50.69, or similar risk
categorizations, questions that we would have would
be, how could this information be used to adjust the
NRC review effort. And are the PRAs sufficiently
detailed to be useful for the relevant SSCs that are
within the scope and subject to aging management
review.
We don't have clear ideas on how to do this.
And hopefully we could stimulate some discussion today
if some of the other presenters, or any of the other
folks on the line have ideas on how to do that.
I guess really the bottom line for us is,
exactly how applicable is PRA to the subsequent period
of extended operation with the potential for degraded
components, how is that considered? And in the end,
is aging appropriately modeled in the PRA that would
be used to impact the aging management review line
items?
Next slide, Chris. In terms of aging
management programs. You know, how can risk
information, specifically risk categorization or PRA
results, be used to support enhancements or exceptions?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 22
And how could the risk information be used
to modify the way that an aging effect is managed, e.g.,
more or fewer inspections? Which would that go, would
you need to do more or fewer inspections?
Now, this piece on aging management
programs, we do have an ongoing activity looking at
the NEI proposed AMPs. So, I'm not expecting that we
would have a lot of discussion at this point because
we have had separate public meetings, and I will expect
that we will have more public meetings on
risk-informing AMPs.
So hopefully we'll have more discussion
though on the aging management review. And maybe
scoping and screening were other areas where maybe we
can risk inform the rule.
Next slide. And now looking at use or risk
and really aging program implementation.
Next slide, Chris. And this is directly
from Lauren's presentation at the RIC. What if the
renewed license has already been issued?
Well, 50.59 governs the approach to
changing aging management program commitments. If a
plant is unable to justify the criteria in 50.59, then
there would be a potential for license amendment in
accordance with 50.90.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 23
The possibilities for risk-informing AMPs
is potential, and particular on a plant-specific basis
is much broader than we can possibly discuss in any
presentation. But I expect that maybe we'll have some
more discussion later in this meeting or in the future,
on a plant-specific basis.
Next slide. And looking finally at
overall approaches, if you go to the next slide, Chris,
there are things to implement risk-informed license
renewal. There are things that we believe can be done
right now, consistent with Part 54.
And this could include risk-informed AMPs
that could be added to the GALL-SLR report. Could be
plant-specific AMP implementation.
I think we'll hear a little bit later from
a representative of South Texas project on their, what
their thoughts are on risk-informing AMP
implementation.
To do other things within license renewal
likely would involve rulemaking to change Part 54.
At this point we have no plans or ongoing activities
to do that. Clearly that is something the Commission
could take on as an action if there was sufficient
interests for that.
And in terms of application specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 24
exemptions, in going back, Part 54 has regulations,
has requirements. The things they talk about, all
SSCs, all SCs, et cetera. Plants on an application
specific basis could request exemptions from that to
use risk-informed techniques.
We have had no requests for exemptions like
that, but that would be an individual applicant
decision. But that would be another way that an
applicant could risk-inform license renewal.
Next page please, Chris. In terms of our
next steps, we will evaluate information that we gather
from the presentations today and from the Q&A and
comment periods. And based on that, we'll develop a
path forward.
And I think, Chris, the last slide is just
some of the initialisms that were used in my
presentation. And with that, I am finished, Chris.
MR. TYREE: Okay, thank you, Allen. Dr.
Lyman, are you online now?
MS. GIBSON: I think there was a question
in the chat.
MR. TYREE: Oh, sure. Oh, there was a
question.
MS. GIBSON: Yes.
MR. TYREE: Okay. Let's see. Okay.
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MS. GIBSON: Allen, could you take a look
at the question?
MR. TYREE: Yes.
DR. HISER: Yes. Do you want me to read
it?
MR. TYREE: I can read the question.
DR. HISER: Okay. Why don't you do that
while I think.
(Laughter.)
MR. TYREE: The IPEs and the IPEEEs are
about 30 years old. These models were not built to
industry PRA standards as they did not exist at the
time. All of these models have been supplanted by
modern more advance PRA models that are maintained
consistently and based on industry ASME/ANS standards.
These new models are maintained by the
licensees with comparisons to the independent SBA SPAR
models used by the NRC, consistent with the stated
policy of being modern, why aren't these current models
being used?
DR. HISER: They could be. The NRC
doesn't, I don't think that we feel the need to dictate
or require that people use these models. But clearly
an applicant could propose to use the results from these
PRA analyses. And again, I think we'll hear from South NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 26
Texas on their thoughts on doing that.
As Jim Medoff wrote a response in the chat.
There are some AMPs that are risk-informed. One of
those being the PRA vessel internals AMP called SLRA
AMP XI.M16A, which does use the risk-informed
methodology for sampling, that has been approved by
the Staff.
MR. TYREE: Sorry, I forgot to mention
that that question was from Jeff Mitman. And he also
had another question that was up above.
In other regulatory areas the industry and
the NRC define the scope of risk, i.e. PRA, somewhat
different than what is presented in this presentation.
Included are non-safety related equipment that reduce
risk. An example would be non-safety related
condensate and feedwater systems. Are these not
included in license renewal? If not, why not?
DR. HISER: Well, the screening, or the
scoping for license renewal is real clear. I mean,
it's deterministic. If it's non-safety component or
structure whose failure could affect safety functions,
that it's included in the scope. So I think the
non-safety equipment is already including within the
scoping. I hope that answered your questions, Jeff?
MR. TYREE: I guess we'll go to Jeff, since NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 27
you raised your hand. We'll get to the rest of you
in a second. Jeff, if you would like to unmute.
MR. MITMAN: So I have unmuted. Can you
hear me?
MR. TYREE: Yes, sir.
MR. MITMAN: So, the scope that you laid
out was non-safety equipment that's included, it's
failure could effect safety related. So I'll just give
you an example.
A non-safety related wall falls on the ECCS
component. That would be included. The wall would
be included.
The PRA models have a much broader scope.
As the illustration I had was condensate and
feedwater, in most plants are non-safety related. And
so they're, but they could have very significant impact
on risk. Usually lower, as there is another mitigation
system that could be clarified to go over the systems.
So by your definition that those systems
would be excluded from license renewal. And it seems
short-sided for it not to. If they supply a positive
benefit by lowering the risk, they should be analyzed
and see what kind of aging effects there are.
And likewise in the unlikely event that
they would raise the risk with the failure then they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 28
should be included. I understand it's deterministic
rules in those where the rules that you given by
Commission direction. But nonetheless, it's not
covering non-safety related equipment that can impact
risk to the public.
DR. HISER: Okay.
MR. MITMAN: It's not a question there,
maybe it's more of a comment.
DR. HISER: Yes, thanks for the comment,
Jeff. I don't know if one of our PRA folks online,
maybe Michelle or maybe Angie? Or maybe scoping and
screening folks could add some information to that.
Okay. I think, Jeff, we have that
recorded in the transcript and we will consider that
as one of the comments coming out of this meeting.
MS. BUFORD: Yes, I was going to, sorry,
Allen, I was -- this is Angie Buford, the branch chief
of the vessels and internals branch. I said yes, we
can take that back. I'm not sure if there is a lot
more that we can talk to at this point.
DR. HISER: Thank you, Angie.
MR. MEDOFF: This is Jim Medoff, Staff.
I had my hand up on this. But it really depends on
how the plant-specific scoping analysis for the license
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on that.
For example, if you're talking about a
boiler where you don't have any steam generators to,
you know, that are used for the generating of steam,
they're going to be reactor coolant pressure boundary
portions and probably non-safety, non-Class 1 portions
of those feedwater and condensate systems. So you're
in different parts of the system.
Some parts may be scoped in because they
serve a reactor coolant pressure bounding safety
related intended function. And others, they would
have to see whether, you know, if it's not safety
related portions of those systems, they would have to
see whether their potential failure could impact a
component that's serving one of the safety related
intended functions in the Part 54.4 portion of the rule.
So it really depends on the plant specific
scoping analysis that you want to play out for those
systems. I think in the PWRs it's a little bit
different because they're not linked to the reactor
coolant pressure boundary.
DR. HISER: Yes. I've had some feedback
from a Staff Member who says that there is two systems
that you mentioned, Jeff. The condensate and
feedwater would be scoped in as either A2 or A3. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 30
they may be in there already, but we'll go back and
take a look at those two systems in particular.
MR. TYREE: Okay, thank you. So we have
one more question, hand raised, from Mr. Grantom.
MR. GRANTOM: Yes, thank you. This is
Rick Grantom. I am the current co-chair of the ASME
and ANS Joint Committee on Nuclear Risk Management,
which is responsible for the development of the PRA
standards that are endorsed by the NRC in Regulatory
Guide 1.200.
First of all, let me say that nothing that
I am saying right now is meant to reflect the opinion
of ASME, this is strictly my own personal opinion.
With regard to current day PRAs, as I just
mentioned, there are standards that have greatly
improved the quality and scope of the PRAs. There is
an independent peer review process that all domestic
PRAs have gone through. So all PRAs out there for
existing nuclear plants meet Reg Guide 1.200 and
therefore are much more improved than 31 years ago.
So, the question about, are PRAs adequate
now to evaluate this, I think that that's definitely
the case. The discussions that you're having on
non-safety related components is basically resolved
by PRA that goes and vets all of that stuff and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 31
determines which non-safety related components are
risk significant or included in the model. And again,
that's endorsed by the NRC and Reg Guide 1.200.
So I think the discussions about PRAs and
IPE and IPEEEs basically go off into the past because
that does not reflect today's PRAs. And does not
reflect the PRA processes.
All the PRAs go through an independent peer
review process. There is a set of facts and
observations, or findings and observations, that are
developed and have to be resolved. There is a closure
process for this.
I'm certain most people in the PRA branch
are aware of this as well.So I just want to make that
one point about the current status of PRAs being
significantly much improved over the period of time.
As far as aging being modeled in PRAs, PRAs
are living models that are updated periodically, so
they reflect the ongoing time dependent failures that
may occur in components and equipment. This is handled
by PRA configuration and control. It's a requirement
to be able to update PRAs as well.
So there is, a lot of this has already been
addressed. It's not so far been acknowledged in this
discussion so I just wanted to bring that point up about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 32
PRA standards, Reg Guide 1.200 peer review process,
closure process for issues and the use of these PRAs
in many new risk-informed applications. Thanks.
DR. HISER: Thanks. I guess just a little
bit of feedback I've gotten from our risk folks. One
is that the, I think it's maybe not the quality of the
PRAs but it's really the detail of the PRAs. And
whether there is sufficient detail down to the
structure component level.
It would be a question, I mean, and it's
not, it's just a question.
MR. GRANTOM: Well --
DR. HISER: Okay. Go ahead.
MR. GRANTOM: I was going to say, well,
PRAs currently go down to the failure mode level. And
in processes like 50.69, you even pair it down to the
characteristics of the component.
So the level of detail I think is more than
sufficient to be able to handle these items. You're
getting down to not only components, but as we know,
many components have multiple failure modes that are
included in PRA as well.
So, there is a level of granularity that
is produced in PRAs that exceeds anything else that
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withstanding the value of the deterministic and the
design basis processes here, but PRA, and PRA does go
down to component level. And human action levels as
well.
DR. HISER: Yes. And I think this would
be the kind of discussion that we would want to have
as PRAs became incorporated more in the license
renewal.
And I guess the only other thing I would
say, in terms of the aging, using experience, aging
experiences is one thing, but if you're projecting 20
years into the future, it's very, I'm not sure that
the modeling is there to not so much go based on what
happened thelast 20 years, 40 years, but what would
be the condition, say at year 80, and how that would
ripple through the PRA.
MR. GRANTOM: Well the good thing though,
the good thing about the PRA is it's going to identify
the important equipment. The ones that you have to
watch, the ones that you have to look at.
So in that regard the PRA, and it's not
just used in the PRA. We don't espouse in any of the
areas that we don't use a risk-informed process. 50.69
is a risk-informed process, risk-informed completion
time. They're all risk-informed processes.
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So in regard to that, the PRA is going to
identify the equipment that is the most important to
prevent core damaging events and predict large release
events, which is protection of public health and
safety. So in that regard it does. And it also
identifies, as I said earlier, the non-safety related
components that would be important to that as well.
So based on previous regulatory approvals
for programs like risk-informed completion time
programs and others, 50.69 included, PRAs are robust
enough to be able to identify the important equipment
that does need to be protected to protect public health
and safety.
DR. HISER: Chris, could we go to Michelle
Kichline for some additional discussion?
MR.TYREE: Sure.
MS. KICHLINE: Hi. This is Michelle
Kichline. I just wanted to comment on what Rick was
saying.
And I completely agree that between the
IPEs and the PRAs that we have available now, there
has been significant changes. And I do think that the
PRAs that we have now are, we do have the tools that
we need to identify risk-significant components down
to a detailed level.
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But I do think that there are still some
concerns that we would probably need to flesh out for
license renewal. Such as the fact that a lot of the
stuff that's going to be scoped in for license renewal,
like piping or tanks or passive equipment, in general
is the stuff that's in a PRA and is very low risk.
Because it has low failure probabilities.
You know, a tank is going to have a much
lower failure probability than a pump. And so, that's
part of the reason that this stuff that's within the
scope of license renewal is within the scope of license
renewal because it's the stuff that's not active.
And we don't want to lose the fact that
the, you know, that we have a rule that specifically
says that we need to look at the passive components
and then try to use just risk. Then we would be
risk-based.
So I definitely see where we can use risk
to help us identify aging management programs. What
we should be looking at, stuff like that. But there
is still some concerns that I would have regarding too
much use of risk.
MR. GRANTOM: If I could address a little
bit of that real quick?
In the 50.69 process there is a passive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 36
categorization process which goes to exactly what you
said. Those are very good comments that you just made
on that.
So in the passive categorization, part of
that process is assuming a pipe break up to, you know,
a double-ended guillotine break of the pipe. So there
isn't a sense, another risk-informed pass, that goes
through 50.69 that looks strictly at passive equipment.
Tanks, pipe, piping supports. You have to assume a
break. You look at conditional core damage
probabilities as a result ofthat.
So I just wanted to bring up the fact that
passive categorization is in fact included and
considered in the NRC's approved 50.69 process. And
so, it's not that the passive components have been
forgotten, there definitely is an approved process for
looking at those types of components for exactly the
reasons that you just talked about.
MS. KICHLINE: And that's a great point
as well, that one of the things that we'll have to flesh
out here is, what's going to be, how are we going to,
if we're using risk information, how are we going to
ensure the PRA acceptability? What's going to be the
process by which that risk information, when it's used,
what pedigree of PRAs are we using for them as well?
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So that's something that has to get fleshed out.
MR. GRANTOM: Yes, exactly. Now again,
that's why I pointed to the PRA standard in Reg Guide
1.200. The independent PRA peer reviews that are
performed and the F&O closure process.
Which is the method right now for
determining acceptability of the PRA. That's the
current NRC method right now. Or NRC endorsement that
we use to do that type of thing.
MR. MITMAN: This is Jeff Mitman again.
And I hate to bog down this meeting on this, but I
can't exactly agree with Rick more or with Michelle
more.
The modern models are worlds beyond the
IPE and the IPEEE. They are so much better in every
way. Okay?
But the citations in this presentation,
we're back to the IPE and the IPEEE in talking about
using those models. And in one subsequent license
renewal that I have been involved in, the licensee did
use the IPE and the IPEEE results from three decades
ago. And that's my point.
Not that the modern models aren't better,
they are better and they should be used. But in the
industry, in my opinion, should not be relying upon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 38
30 year models to make these very important decisions.
And so, I think the process should be
modernized and the current model should be utilized
to get the best insights. That's my point.
MR. GRANTOM: Yes. I would agree with
that, Mr. Mitman.
MR. TYREE: I appreciate the great
dialogue and discussion here. I'd like to try keep
moving forward with the agenda, and then obviously
we'll have more time to talk about it a little bit more
later on.
So next on the agenda is Dr. Lyman. Dr.
Lyman, are you on line now?
DR. LYMAN: I am. Can you hear me?
MR. TYREE: Yes, sir.
DR. LYMAN: Yes. So thanks. I missed
the beginning a little, but the previous discussion
I think pretty much covered all the issues that I wanted
to highlight.
I don't have a presentation today, but the
only point I really wanted to make is that we do share
the concerns about the use of PRA in this application
without an appropriate understanding of how to
incorporate the age in those models.
And the fact that we don't think the use NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 39
of PRAs is conservative enough today because it doesn't
systematically incorporate anything into those models,
despite what a previous speaker said. I'm not aware
of how that's systematically being done and if there
is enough known as what's pointed out about the
evolution of failure rates that could actually inform
updating those models.
I understand there are ways of dynamic PRA
methods that are being developed, but it just seems
that the gain, the PRA gain has to be up to some extent
to address those aging concerns. Because the
categorization that you do based on today's PRA would
not be the same. You know, some component or SSCs may
change their categorization based on aging phenomenal,
who knows.
So it seems to base those decisions
essentially a lot on symptoms still today based on
today's PRA would not be appropriate. So unless they
align also a facility management program that would
require that updating a PRA is not, the evaluation of
categorization of the components, I don't see how this
would work.
Just stepping back, what is actually being
proposed here is essentially reducing the frequency
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really knowing what the impact of those routine
inspections are on the increased failure rates. So,
it seems that the quantitative basis may not have the
data to do this in a meaningful way.
So that's --and I would point in 50.69,
to the requirements, PRA should support keeping a
sufficient quality to support to categorization. And
I think that's the standard that you would focus on
to allow this type of thing to go forward. So that's
my comment. Thank you.
MR. TYREE: Thank you so much. We will
keep moving on. So we'll move on to the next
presentation by Brett Titus from the Nuclear Energy
Institute.
MR. TITUS: Yes, thank you very much,
Chris. If you can share the slides that I provided
in advance, I think it will help us walk through this
particular conversation. I've heard a lot of good
elements and things that are very consistent with what
I'm about to present on.
Once again, my name is Brett Titus and I
am the licensing director at NEI. And I happen to sit
on our license renewal taskforce.
So, if you can move on to the first slide.
What you'll hear today, we really appreciate the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 41
opportunity to continue this dialogue that we started
back at the RIC session.
And even before that you've heard mention
of our submittal with the two risk-informed, or the
two AMPs that leverage risk insights. That's kind of
the terminology that we're using. Because we feel
like, as alluded to in Allen's presentation, we don't
want this to be labeled a risk-based proposal or a
risk-based approach.
But as I mentioned at the RIC in
particular, I think we need to take a step back and
figure out, what is the purpose of leveraging these
risk insights in aging management. Why are we doing
this? Why are we looking for these opportunities for
efficiency?
And really it is to continue on providing
reasonable assurance of adequate protection. The
licensees, and in particular, the NEI membership that
supports the license renewal taskforce is focused on
safety.
But we have a finite amount of resources
and we want to keep the operating plants at their peak
performance of both safety and efficiency as we look
to the next generation. Which is actually what this
slide is about.
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So, the light water reactor sustainability
program from the DOE has actually got this statement
that I'm just going to read briefly because I think
it really captures why we're looking at this as another
opportunity to more efficiently operate the existing
fleet.
It says, nuclear power has reliable and
economically contributed approximately 20 percent of
electrical generation in the United States over the
past two decades. It remains the single largest
contributor, approximately 56 percent, of
non-greenhouse gas emitting electric power generation
in the United States.
Operation of the existing plants, excuse
me, yes, to 60 years, extending the operation of those
plants beyond 60 years, and where practical, making
-- excuse me, I lost my place. I apologize. And
making further improvements in their productivity are
essential to support the nation's energy needs, supply,
reliability and diversity.
So what does that all mean? It means, that
as we await the next generation of small module
reactors, advance reactors, we need to continue
operating our existing fleet in the most efficient way
possible.
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Maintaining safety, maintaining those
intended functions and adequately managing our aging
management programs. But we need to do it in an
efficient manner so that we can continue to meet the
carbon goals that the United States and our individual
fleets have set out in front of us.
So that's kind of the big picture of why
we are investing our resources into pursuing risk
insights for aging management.
Next slide please. So we've had a really
good conversation around this already so I won't
belabor these.
But since 1995, obviously the NRC and the
industry have significantly expanded their use of PRA
and risk insights. We've talked about the granularity
of their models, the fidelity of their models. The
peer checks that have been done on each one of the PRA
aspects that have been advanced since the rules were
originally written.
And just here on this slide there is a
number of activities where we do use risk insights to
inform the oversight and the decision making that we
make in the licensing space and in oversight space.
In particular we did spend some time talking about
50.69.
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And I think you will find that the STP
presentation that's coming up from Wendy here in a
little bit will talk about that aspect and how it can
be leveraged. And what is the adequate treatment in
accordance with that.
Our particular approach, as you may know
from following along with the presentations that were
done over the course of this year is that, I'm going
to go ahead and skip to the bottom bullet that says,
while the focus of each risk-informed application may
be different, there are insights that can be leveraged
to inform aging management effects. All right.
That's what we're talking about right now.
Making a holistic integrated decision that we've shown
that this framework that was developed by EPRI can be
used to efficiently implement these aging management
programs.
So, I'm going to go on to the next slide
please. So in January what we did, as mentioned, we
submitted a couple of pilot plants that implemented
this particular framework. And for the selective
leaching aging management program and for inaccessible
cables of medium voltage ones.
And we've had a couple of really good
dialogues on those topics. Both at the RIC session NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 45
and later on, just last June, we had an extensive public
meeting where we really dove in a little bit deeper
on those topics in looking for opportunities to move
that review forward. Because ultimately that review
will inform a larger initiative that we have to develop
this technical report on a generic process that can
be used for any aging management programs.
I think one of the reasons that the
industry is focused on this is, we are very aligned
with Allen's presentation and the interpretation of
sort of the boundary conditions that exist within the
rule and the statements and considerations. It's
comforting to know that we interpret them kind of the
same way.
Which is why the industry is focused on
the implementation phase of license renewal to leverage
this risk insights. We think a rulemaking would be
necessary to touch on things like scoping or some of
the other aspects that were brought up earlier.
And I think there is an opportunity for
us to realize some of the benefits of risk informing
again management in the near term, as opposed to putting
more effort into something longer term, like a
rulemaking.
So you hear, you know, essentially the key NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 46
messages going forward is that we're looking at near
term implementation that focus on these pilot
evaluations to inform our more generic document that
can be used on any aging management program.
Next slide please. So again, our number
one priority, what are we interested in the NRC focusing
on, where do we want to see the resources dedicated
to moving risk insights into aging management and
license renewal space. We are ready and willing to
support the review of those particular pilot markups
that we sent in, in January.
We think that the path looking forward of
a potential audit and more discussions on the technical
details of how this framework can be used is the best
use of our time right now.
In the future we want to take those same
insights from the review of those pilot AMP markups.
And we want to continue the development of this
technical report that we plan to submit to the NRC for
endorsement by the end of this calendar year.
And then as was alluded to, or mentioned
before, that will be able to be expanded to use that
framework on multiple AMPs once the methodology, as
a whole, is kind of endorsed and seeing it's benefit.
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presentation. Again, a lot of these are the same key
elements and key messages that we have been presenting
on behalf of the NEI membership and the license renewal
taskforce since of the beginning of the year.
I think other opportunities, which was
part of the scope of this meeting. We did ask about
the GALL update and the SRP for SLR update at the project
during the June 1st meeting.
If there are any opportunities to use risk
insights in the drafting of those new sections. And
I think one of the responses that we've heard was,
essentially that that project, at this point in time,
is not budgeted for that type of a deep dive into how
the NRC could leverage risk insights into the GALL
update. So I understand that. That makes sense to
us.
But moving forward we're going to keep our
emphasis on the implementation phase. And we really
look forward to more conversations around these
particular AMPs for the pilot plants. Happy to take
any questions from the NRC.
DR. HISER: Brett, this is Allen Hiser.
I guess my only comment would be I appreciate the
information and I guess, you know, we'll continue to
go forward with the risk-informed AMPs. I don't see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 48
that as being a problem. I don't know, Lauren, if you
had anything else to add on that schedule wise or
anything?
MS. GIBSON: No, I understand that this
is NEI's focus right now.
MR. PAIGE: Hey, Brett, this is Jason
Paige with the NRC. I have one question on slide five.
Do you have a schedule of when you plan on submitting
that technical report to the NRC?
MR. TITUS: So, our soft date is going to
be about the fourth quarter or by the end of the calendar
year. That's the space that we're in. Again, we are
trying to inform that document based on the review of
the pilot AMPs.
I think that will give us a lot of insights
into areas where there are gaps in the staff's
understanding, and so we look forward to those audits
kind of helping us to refine that document and move
it forward, but the end of the calendar year is our
target right now, Jason.
MR. PAIGE: Okay, thank you.
MR. TYREE: Are there any other questions?
If not --
MR. MEDOFF: Before you go on, I'd just
like to know if we're going to have just a general NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 49
discussion section after the presentations?
MR. TYREE: Yes, yes, we are.
MR. MEDOFF: Okay, thank you.
MR. TYREE: Mr. Gunter, do you have a
question?
MR. GUNTER: Yes, thank you. Paul
Gunter, Beyond Nuclear. My question has to do with,
you know, the whole idea of risk-informing age
management programs, can that be performed without
requiring the harvesting of real world samples from
particularly through the decommissioning process?
MR. TYREE: Is that a question for the
staff? I think the questions are intended --
MR. GUNTER: I would be interested in
hearing from NEI as well.
MS. GIBSON: Well, from the staff
perspective, I think there are things that we can do.
Allen, go ahead.
DR. HISER: Yeah, thanks for the question,
Paul. I think there are things, I mean, from the
perspective that use of PRA would bring in the risk
significance and maybe enable us to stratify or focus
on the things that have high susceptibility and high
consequence, I think, would be independent of
harvesting.
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It's not clear to me at this point how
harvesting would factor in other than it would provide
the potential for additional operating experience data
that we could use to either, you know, depending on
whether the aging it's identified, you know, validates
models that we have or if it's a little more severe
than we expected.
I mean, there would be some recalibration,
but I'm not sure that it would be, how significant the
impact would be on the PRA results overall.
MR. TITUS: So, I'll go aheadand answer
in a generality. Once again, this is Brett Titus.
The method that we have for leveraging risk insights
in aging management considers the fidelity of the
information that we have at that point in time.
I think you heard at the RIC session, in
particular when we were talking about the medium
voltage cables pilot experience, there were some gaps
essentially in the knowledge base that precluded some
of those samples from moving to the longer frequency
of testing, right?
So, those are still safety decisions that
are being left in the hands of the experts that
developed the risk insight models and that are looked
at on kind of a holistic basis.
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So, I know I didn't answer specifically
about harvesting and gathering that data, but I think
it's important to know that as these aging management
programs are being implemented, that they're being done
so, you know, with an appropriate and scrutable process
that considers what we know today and there's also a
feedback loop for the things that we don't know or would
come across, so I'll just kind of leave it at that.
MR. TYREE: Okay, thank you, Brett. Are
there any other questions at this time? If not, we
will move onto our next and last presentation from
Wendy. Oh, Jeff?
MR. MITMAN: Yeah, before we leave the
aging management issue, you know, there was a situation
at Oyster Creek, I don't know, ten, maybe 12 years ago
where they had rather significant, you know, I'll say
significant in regulatory space, drywell wall thinning
due to corrosion.
And if my memory is correct, there was a
lot of inspections done and maybe there was some wall
overlay or well reinforcement that was done to thicken
the wall where they knew they were getting corrosion.
So, I think that's a classic example of
what was being put forward was, hey, you know, Oyster
Creek is shut down. There is a harvesting opportunity.
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You know, what insights can we go, can we, as an
industry, gain from going in and looking to see how
bad that damage really was and whether there was any
kind of applicability to other plants, specifically
the Mark I containment plants?
I think it's a real lost opportunity to
say, well, you know, they're shut down. We don't need
to worry about them, and just not look. You know, your
risk insights, you only can use risk information if
you go and you explore. If you don't expand and think
about what's not currently covered, you lose that
opportunity.
So, I'm sure with a little bit of thought,
I could come up with other examples, but you get the
gist of the comment. There's insights and risk
information that can be gleaned from harvesting, and
that could be used to make the license renewal process
better and either streamline it more or to make it more
robust if it needs to be.
DR. HISER: Yeah, Chris, I can speak to
that a little bit about Oyster Creek. I mean, the plant
did many measurements of the wall thickness, so I don't
know that there's any additional information that could
be gained by harvesting from Oyster Creek, and that's
all, I think, documented in some of the hearing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 53
documents related to the license renewal for Oyster
Creek.
MR. MITMAN: Cutting out a piece of the
drywell wall gives you more insights than, you know,
doing the UT thickness measurements on it. You know,
likewise, if you want to confirm that everything you
know is right, you know, Duane Arnold, another Mark
I containment, shut down a couple of years ago. You
can go look at that containment to confirm that the
insights from Oyster Creek are valid.
I mean, risk needs to be used both ways,
not just to justify doing less, but going out, and when
you're finding areas that there might be some
additional insights, go look at them and see what you
can learn from them.
This perspective by the industry and by
the NRC of we can only use risk to do away with the
weaken, the current regulatory perspective is
inappropriate. You use it to find vulnerabilities,
and if you don't look for vulnerabilities, you won't
find them. I'm going to stop now.
MR. TYREE: Thank you for that. Mr.
Gunter, do you have another comment or question?
MR. GUNTER: Well, with regard to the
Oyster Creek license renewal, I was involved in that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 54
and, you know, one of the things, again, that would
have supported the whole idea of not, you know, not
relying on the operator to volunteer information, but
in that particular case, the operator had submitted
conflicting information.
If you go back and look at the record, at
that time it was Jersey Power and Light had even
submitted information that showed that the drywell
liner had healed itself and had actually gotten thicker
in areas of corrosion.
So, there was an active dispute on that
particular aging component, and yet there was no
impetus on the part of the Nuclear Regulatory
Commission to actually intervene to gather the
observable and measurable science from that particular
event that came about during a license renewal review,
but certainly could have played a stronger role in the
license renewals if that component had been served up
as samples and, you know, closer analysis.
But that seems to be the dilemma that we're
stuck in right now is that the -- you know, there's
not a demonstrated eagerness on the part of the industry
to comply or to cooperate, and I think that my concern
is that this recalcitrance only gets worse when you
become more reliant on risk informing license renewal.
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MR. GRANTOM: This is Rick Grantom. I
would like to respond to that. The idea that we're
doing less instead of doing something more efficient,
that's not true.
We're applying the proper resources
commensurate with the risk significance of it.
There's no recalcitrance. There's no anything along
that line. That's just presuming a bunch of stuff
that's not true.
So, the fact that we're using
risk-informed methods over here, in addition to
deterministic and other types of information, makes
these programs much better than that.
So, we are emphasizing the equipment
that's really important. We've got hundreds and
hundreds of reactor years of experience that's told
us a lot of things about how components have failed.
Wehave corrective action programs.
So, I totally reject that we're somehow
doing less than what we're doing, other than
maintaining these plants very well, performing a vital
service to our country, and continuing to do this on
an ongoing basis.
These programs using risk information only
helps us to do this more effectively and efficiently NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 56
and with better safety because we're focusing on the
things that are absolutely important.
MR. GUNTER: I would just add, again, this
is Paul Gunter, not that we need to go back and forth
on this, but the drywell liner on a Mark I is a
significant safety-critical component and we did miss
an opportunity there, and it does have a role to play
in terms of particularly in the subsequent license
renewal reviews.
MR. TYREE: I appreciate that comment.
So, we are about at the point in the agenda where we
were going to take a break, so let's take a ten-minute
break and we will reconvene at 2:30 to do our last
presentation.
(Whereupon, the above-entitled matter
went off the record at 2:19 p.m. and resumed at 2:30
p.m.)
MR. TYREE: Okay, it is 2:30, so we will
get started again. Just a quick reminder that if you
have a comment or a question, please provide your
affiliation if you have one. If you're just, you know,
a private citizen, you can just say you're a private
citizen.
With that, we will move to our next
presentation from Wendy Brost with the South Texas NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 57
Project. Wendy, are you -- I guess I should check to
make sure you're back.
MS. BROST: I'm back. Thank you. Thank
you. And would you mind sharing the presentation?
MR. TYREE: Yes, give me one second.
MS. BROST: All right.
MR. TYREE: Okay.
MS. BROST: Great, thank you. Okay, so
as it says there, my name is Wendy Brost and I'm the
licensing supervisor here at the South Texas Project.
So, certainly some pros and cons for
presenting last. On one hand, I get to build on some
of the things you all have been speaking about. On
the other hand, there may be some repetition here, but
you know what? Some of these things are worth
repeating, so let's get into it.
So, my purpose today is to talk a bit about
a project effort that STP is working on and that is
using our risk information as an input for evaluating
changes to ouraging management programs, and really
it's using these risk insights to enhance our overall
aging management strategy and developing alternate
treatments for some components. So, if you could go
onto the next slide?
So, a bit of relevant background here on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 58
STP. So, of note, STP is not a 50.69 plant. We're
really the predecessor. We're the proof-of-concept
pilot for risk significance categorization, so the NRC
granted us some exemptions from the special treatment
requirements for low safety significant components
over 20 years ago.
So, here at STP, we have categorized over
100 plant systems in terms of both nuclear safety risk
and plant generation risk so that the categorization
data has been fully integrated into our station
processes, including databases such as our master
equipment database. The point there is that STP's
program is quite robust. It's thoroughly integrated
and well established.
So, this component risk categorization
provides us with a technical basis for treatment of
components commensurate with their safety and
operational significance, which what that does is it
better allows us to focus the most effort on the most
safety significant equipment, which is what we're
trying to do here.
So, the project we're working on now is
we're planning to apply alternate treatment for low
and non-risk significant components in 50.59 space
known as RISC-3 and RISC-4, as well as doing some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 59
engineering evaluations on RISC-2 type components to
determine if alternate treatment can be provided for
those as well.
And lastly on this slide, so we are looking
at each aging management program for evaluation, and
due to our established categorization process and our
experience, we can use our existing processes to
alternatively treat many of these components is what
we concluded. So, we want to go to the next slide?
And the point we wanted to make there is
we're not excluding anything from the license renewal
scope here. It is all being evaluated, so we're not
changing the scope applying alternate treatments to
what's already there.
So, the goals here, the goals and benefits,
a bit of repetition, but what we're doing is applying
the appropriate resources to components commensurate
with their nuclear safety significance. This
certainly doesn't reduce safety. From our
perspective, it actually improves it.
So, the benefits here is it focuses those
resources on the items that are most safety
significant, results in increased availability of
those components by removing the prescriptive special
treatment requirements.
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In some cases, it also results in improved
ALARA performance due to the dose associated with
certain repair, inspection, and replacement activities
which may not be needed to be performed as frequently,
as well as reduced overall station burden, again
focusing most resources where they should be, and that
is on the most safety significant components. All
right, if you want to move onto the next slide?
All right, so what we're doing right now,
and just like any other change, we're going through
this deliberately and with a focus on evaluation,
documentation, and transparency.
So, one of the aspects of this is weare
creating a procedure for performing these AMP
evaluations. So, the procedure is still in draft form,
so discussions like these are particularly helpful for
us to help see if there's something that should also
be included or considered.
So, the purpose of our procedure is to give
guidance for tracking, implementation, and
documentation of all of these alternate treatment
actions.
Also noted there is the procedure will
ensure that we also evaluate industry and station OE
pertaining to age-related degradation, and we factored NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 61
that into the evaluations as well.
So, just to echo something, we use the risk
information to inform our decisions about potential
AMP changes, but it's certainly not the only input.
There are other things that are looked at there.
The procedure also outlines the guidance
and responsibilities for these alternate treatment
implementation and maintenance, so it just clearly
lines out the who, the what, and the how. Okay, move
onto the next slide there.
So, another thing we've worked on, and
again, in the interests of documentation and
transparency is in case our basis is questioned in the
future is we've created and documented our position
for why we believe that this is allowable in an internal
white paper. So, our conclusions relied on, in this
white paper, on the interpretation and information that
was already provided in the statements of consideration
for 50.69.
So, of note, 10 CFR Part 54 was identified
as a candidate as a special treatment requirement, and
in those statements of consideration, it says that no
changes are necessary to Part 54 to implement the 50.69,
or in STP's case, our equivalent before renewing or
after license renewal, so that was a key point in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 62
white paper.
So, a few other points to point out, so
license renewal is considered and aging management are
considered special treatment requirements, so our
exemption from special treatment would apply in those
cases.
Further, risk insights can be used to
evaluate aging management programs, and noting risk
information being one input to the change evaluation
process.
So, the conclusion that we came to was that
STP can risk inform procedures and processes to
implement the exemption allowances for all station
programs where appropriate, and further, that what we
are planning is consistent with current regulation is
what we concluded there. We're going to move onto the
last slide.
You know, as we're going through these
evaluations and looking into applying risk insights
to additional parts of license renewal, you know, we
have come across a few questions and one of those is
in the area of equipment qualification.
So, equipment qualification was
specifically mentioned in our license renewal
correspondence and there was some discussion of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 63
replacing these components at the dates designated in
the original qualification maintenance database.
So, we are evaluating applying alternate
treatments to the life of these components as well.
So, as an example, we have about 80 of these Rosemount
transmitters, approximately half of which are ranked
as low or non-risk significant.
So, alternate treatment evaluations
considering risk would allow us the opportunity to
extend the lives of these components and focus on the
more risk significant and safety significant
components.
Additionally, in this case, there is
certainly an ALARA aspect of the replacements due to
the dose that would be accumulated by replacing the
transmitters as they're located in containment.
So, again, we believe this approach is
consistent with current regulations and our existing
exemption from special requirements, but what we came
across and brought up some questions is there really
isn't crystal clear guidance, right?
So, the guidance is out there, but it's
not crystal clear and specific. So, what we found is
what we're doing, we believe, is justifiable, just a
little different.
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And really, we want to be transparent in
all of our actions and what we're doing here, so we
started asking ourselves what's the appropriate
vehicle for communicating this change?
And I saw in the first presentation, you
mentioned that 50.59 is the appropriate vehicle and
we came to a similar conclusion, but again, that wasn't
crystal clear as far as we could see. It's not
explicitly spelled out anywhere that that's the change
method for these type of things.
So, with that, I might just say that, you
know, that would be a recommendation for future
discussion in a public forum, you know, specifically
calling out how these changes related to license
renewal should be evaluated and documented just to make
sure the process is more widely and better understood,
eliminating any kind of misunderstandings in the
future.
But that's just a status report on where
we're at, the types of things we're looking at, and
a couple of questions. That's about all we have.
MR. TYREE: Thank you, Wendy. With that,
we can open the floor for an open discussion. Oh,
Seung?
DR. MIN: Yes, thank you. This is Seung NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 65
Min with the NRC staff. Thank you for the
presentation. I have a very basic question here. So,
my understanding, you know, for typical sampling
approaches using risk insight, you know, sometimes the
terms like high consequence items, or high consequence
locations, high priority items, or something like that
are utilized, but when you go back to the kind of
framework, when we use or your programs use high
consequence or something like that, is that related
to intended function or kind of system level core damage
frequency or something like that, or both of them?
That's my very basic question at this point.
MR. GRANTOM: This is Rick Grantom
talking. Let me introduce myself again. As I
mentioned, I am the co-chair of the ASME, excuse me,
of the ASME/ANS Joint Committee on Nuclear Risk
Management. I'm also an independent consultant
retired from the South Texas Project. I consult with
a number of utilities about risk-informed
applications, South Texas being one of them as well.
With regard to the question of what we're
looking at, there are two figures of merit for
risk-informed applications that the NRC has approved,
core damage frequency and large early release.
So, what you're seeing here in the results NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 66
are you're seeing the components' risk significance
relative to core damaging events and/or large early
release events in here.
So, we build from the component level,
which is, you know, the lowest level in PRA basic events
that are failure modes in the PRA components, to system
functions, all the way up to plant level functions to
be able to do this, and culminating into importance
to core damage frequency using traditional PRA
importance measures as an input, all of that together,
to other deterministic, operating experience,
engineering experience to make these final decisions.
I hope that answers your question.
DR. MIN: I think pretty much, but so, once
again, as you previously discussed, that type of
degradation due to aging effects are kind of modeled
or considered in your PRA or PSA approaches, so that's
core damage frequency or system level make like a
pattern so a matrix can be calculated, but I'm feeling
that if that's the case, then the so-called intended
function, maintaining intended function in the aging
management maybe, you know, probably still well needed
there, but thank youfor the discussion.
MR. GRANTOM: Oh, one other thing that
hasn't been mentioned yet that I'll bring up real quick NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 67
is, yeah, I did mention that in a sense, when you look
at the number of times that PRAs have been updated,
they're covering, you know, decades of plant
performance where, you know, some aging mechanisms have
occurred or may have occurred, and that performance
is being updated.
One other item that was brought up is let's
assume, you know, you don't do everything that the
special treatment requirement tells you to do. You're
going to use an alternative treatment that's more
effective or more efficient commensurate with the
component.
Components that are low in the 50.69
process, there is a sensitivity study in the PRA that
assumes that, well, let's just assume that the failure
rate's increased, and so we multiply the failure rates
of all of the low safety significant components by a
factor of three to say, well, are they still low and
would utilities be able to detect an increasing failure
rate in this regard? And this would be seeing
components fail three times their current rate and
corrective action programs somehow not picking that
up.
And generally what we find, that
components that go through the 50.69 process, through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 68
the qualitative assessment, the PRA assessment, the
passive assessment, and they go through a final
defense-in-depth assessment, if they pass through all
of that and they're low, you have high confidence they
really are low and it confirms itself when we multiply
their failure rates, all of their failure rates by a
factor of three, it still ends up being below Reg Guide
1.174 risk assessment criteria.
So, those things continue to point to the
fact that you ought to be able to focus more on the
high risk stuff, you know, do something more
appropriate for the low risk stuff, while still
maintaining that they're able to perform their
functions under normal and design basis consideration
conditions.
DR. MIN: Thank you. Just a quick
follow-up question, in the kind of PRA/PSA framework
considering aging effects, then aging effects on
different systems are kind of getting rated or
considered in an integrated manner or just whenever
you look at the system aging effects will be considered
so that kind of isolated consideration of the aging
effect should be the matrix like core damage frequency
is considered.
I mean, you know, hypothetically speaking, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 69
as plants are getting aged, you know, different systems
can go through different aging effects and degradation,
so they may work together to generate combined effects.
I mean, once again, I'm not an expert in
that field, but just for my curiosity, I mean, that's
my problem, my last question for discussion at this
point.
MR. GRANTOM: Well, I mean, there's other
probably who can speak to this as well too, but, you
know, PRAs are integrated models in terms of, you know,
the sequencing and the identification of equipment and
systems that have to play together in order to bring
a plant to a stable condition or mechanistically fail
things until you reach a core damaging and plant damage
state of some sort.
So, they are all considered, systems
considered together in the role, but as I mentioned
before, you know, there's typically not a basing event,
you know, that says this particular aging mechanism
grows at this level for this point, and that point,
and that point.
PRAs usually look at failures at the
component levels or the structural piping levels that
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included in updates.
So, in a sense, it's included in that
regard, but if you're going to do a focus-specific look
at an aging mechanism and try to determine what the
increase in failure rate is, that's something for
research in that regard.
We're reflecting actual component history
and actual mechanism history in that regard. So, I
think the answer to your question is, yeah, it is all
included in there. All of the things are updated, but
DR. MIN: Okay, sounds good. Thank you
very much.
MR. TYREE: Thank you. Allen?
DR. HISER: Yeah, this is Allen Hiser of
the NRC. Wendy, I've got a couple of questions. I
think you mentioned that Part 54 is included in the
scope of, within the scope of regulations that 50.69
can modify and I don't see that within 50.69. Was that
in the SOC or where was that? Where is that addressed?
MS. BROST: And if I misspoke, I
apologize. I'm looking at -- so we were looking at
the statements of consideration for 50.69 and --
DR. HISER: Okay.
MS. BROST: -- the specific statement was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 71
that, it says the NRC staff suggested that no changes
are necessary to Part 54 to implement 50.69 either
before renewing a license or after license renewal,
so that's one of the things that we had keyed in on.
Should we interpret that differently? Is that the
question?
DR. HISER: I guess I'm not sure because
I look at the special treatment sections that 50.69
applies to and Part 54 is not listed is all.
MR. GRANTOM: I think one of the things
is we didn't change the scope of equipment that Part
54 identifies.
DR. HISER: Yeah, okay.
MR. GRANTOM: So, that was the part -- the
scope has not changed. All of that scope of equipment
goes into the license renewal. The only thing that
STP is doing in this regard is applying an alternative
treatment to those items that are low safety
significant. All of the equipment that's identified
in Part 54 is included in the scope.
DR. HISER: Okay, and I guess one other
question, Wendy, I was sort of hoping that you would
have used one of the slides that Drew Richards used
at the RIC, and it was a schematic that showed license
renewal scope, and then a screen and a big red box, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 72
and then, you know, risk-informed AMP and aging
management review.
And at first when I went back and looked
at the slides, I thought this indicated that one of
your applications was to actually license renewal
applications, you know, so that you would incorporate
the 50.69, or your special treatment exemption within
the screening process in effect for license renewal.
Can you comment on that or are you really
just looking at AMP implementation? And I don't know,
maybe, Chris, I can show the slide if that would be
MS. BROST: Okay, yeah, that's what I was
trying to do, find it, but, yeah, if you have it, that
might help.
MR. GRANTOM: It's AMP implementation.
MR. TYREE: Allen, if you have the slide,
do you want to put it up there?
DR. HISER: Is that -- can you see it?
Okay.
MR. TYREE: Yeah.
DR. HISER: Yeah, I guess the way this was
laid out, it was like a license renewal application
sort of process, and so it was confusing to me to see
that within the screening step. So, this would not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 73
be something that you would intend to use, say, for
SLR, for STP at this point in time? I mean, that's
not what you're proposing, just AMP implementation?
MR. GRANTOM: The intent of what we're
doing is on the AMP implementation. You can see in
the LRI scope, there's no changes to the scoping.
The only question it's asked is if it is
low safety significant, then we're determining an
alternative treatment for it, and then that alternative
treatment is going to, that will include aging
considerations in the alternative treatment, but it
may not be prescriptively what's in the GALL.
DR. HISER: So, for example, the part that
says is the SSC GQA low or NRS? That actually should
come out of the screen -- I mean, scoping and screening
has been done for STP, so it actually is somewhere on
the implementation piece.
I guess a concern I would have, you know,
the rule lays out screening, and it's basically, you
know, active, passive, periodic replacement, and long
lived. Those are the only two criteria that enable
you to not do aging management review of in-scope SSCs.
So, okay, I think I understand better now.
This is just a little bit misleading, I guess, would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 74
be the only thing. You might want to amend that --
MR. GRANTOM: Yeah.
DR. HISER: -- a little bit to reflect
where the risk significance really plays into your
implementation of your aging management programs.
Okay, thank you.
MR. GRANTOM: Okay, yeah, that's good
feedback.
MS. BROST: More clearly call that out.
Thank you.
MR. TYREE: Matt McConnell?
MR. McCONNELL: Yes, good afternoon,
everyone. My name is Matthew McConnell. I'm with the
NRC. My question is directed at Wendy and her
presentation. One of the slides, Wendy, that you
mentioned discussed about equipment qualification and
how you are, how STP is using, I believe you said 50.69
in order to extend the qualification. Can you -- I'm
not sure if you meant 50.69 or 50.49, but could you
maybe go into that a little bit more on how you're
applying that if it is 50.69?
MS. BROST: So, I meant 50.59, so if I
mixed that up, I apologize. Did that clear up your
question or --
MR. McCONNELL: It did. It leads to other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 75
questions.
MS. BROST: Okay.
MR. McCONNELL: I mean, and how are you
using 50.59 as far as extending the qualification then
which, you know, are you still using the 50.49 process
or --I'm just trying to understand how you're using
risk insights in order to extend the qualification of
equipment.
MR. GRANTOM: This is Rick if I could add
something in here. So, first of all, just like with
50.69, STP has an exemption that preceded 50.69, but
the more 50.69 components that go through the process
and are categorized as low safety significant are
exempted from something like 12 special treatment
requirements.
50.49 is one of the special treatment
requirements for which LSS or low safety significant
components are exempted from. In other words, they're
removed from the scope of those programs and that's
the approved process.
Now, once you remove it from the scope,
you still have to have some alternative treatment to
ensure that that component performs adequately in that
regard.
So, you may borrow an element of an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 76
equipment qualification program or you may do some
other mechanism by which to ensure that you have
reasonable confidence, not reasonable assurance,
reasonable confidence that the component will continue
to perform its intended function under normal design
basis conditions, but they're removed from the scope,
as is all LSS components from the special treatment
programs.
MR. McCONNELL: Understood, thank you.
Yeah, I'm aware that the 50.49, certain equipment could
reach the threshold for special treatment and
exemptions of 50.49, and I'm glad you pointed out that
the equipment still needs to be shown that it can
perform its function under accident conditions, let
alone day to day operations and design basis events.
So, is STP then categorizing then and
cataloging that in some sort of documentation under
some other program? Is that how you're using 50.59
in that context or is 50.69 being used as another
documentation bin?
MR. GRANTOM: So, basically, you know, as
I mentioned, STP doesn't have 50.69. They have an
exemption. However, we're using the same criteria
that's in 50.69 for alternative treatment, which means
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some sort, there has to be an inspection element of
some sort, and there has to be corrective action
associated with it.
So, all of the alternative treatments are
handled in a separate procedure, implementing
procedure that defines, you know, for these components,
it's not going to be the prescriptive special treatment
requirement for this low safety significant. It's
going to have a different treatment associated.
Here is the inspection element of that
alternative treatment. Here is the pressing element
of that alternative treatment that is going to be used
for this component. And that's consistent with 50.69,
although STP is borrowing that.
MR. McCONNELL: Okay, I understand that.
I'm tracking along. I think then my next question
is how does this play out in license renewal space?
Because you have a TLAA for 50.49 equipment
specifically and taking credit for the EQ program, and
then you have other requirements of the Part 54.
It seems like there's a purgatory
environment, so to speak, for where does that new
equipment that is being treated differently and taking
credit for an existing program fit in the license
renewal process?
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MR. GRANTOM: Well, so in regard to that,
the fact that it's exempted from 50.49 means it's out
of the 50.49 process, so it's basically not. Now,
there isstill discussion about that in the industry
and with the regulator about that.
This is why I say you may borrow an element
or you may borrow something from a qualification
program of some sort, or you may do other types of
relaxations and maybe use better information in order
to extend qualified lives of equipment, maybe not only
for high safety significant equipment, but also for
low safety significant equipment as well.
But the important point being is under the
50.69 and under STP's exemption process, those
components are removed from the scope. It's as if they
never should have been in the scope of 50.49 to begin
with.
So, basically the answer to your question
is they're going into an alternative treatment, but
the alternative treatment requires that they have a
testing and inspection element that ensures that they
perform their intended purposes even under accident
conditions.
MR. McCONNELL: Okay, and that still
leaves my open-ended question out there of how that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 79
fits within the GALL and GALL-SLR?
Whenever you pull it out of that, you know,
even though it may have elements of 50.49 that it's
exempted from those specific requirements and GALL and
GALL-SLR, it still addresses equipment qualification,
but if it's not in the bound or scope of 50.49 or that
TLAA, how does the staff address --
MR. GRANTOM: That would be the point.
The aging management program is a special treatment
requirement, so it's exempted from that just like it's
exempted from 50.49. It's out of the scope of it.
Now, I said out of the scope. It's not
out of the scope of LRI, but it's available or a
candidate for an alternative treatment, which is
exactly what STP is doing. They don't remove it from
the scope. They just say this is a candidate for an
alternative treatment.
MR. McCONNELL: Okay, I think this is
something I'm going to talk back or take back as a
follow-up item and maybe discuss internally with the
staff and decide on a path forward for this, but I
appreciate your information.
MR. TYREE: Thank you. Do we have any
other comments or questions? Yes, Brad Dolan?
MR. DOLAN: Hi, this is Brad Dolan. I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 80
the Chairman of the Risk Management Committee with the
PWR Owners Group. I just wanted to say I thank you
for your efforts in this area. I think it's very
valuable to help us focus our resources on the things
that really matter.
And I heard a number of questions during
the presentations, things like how can we use 50.69
to adjust NRC reviews and how can we use risk
information to support enhancements or exceptions?
I'm going to take those back and discuss
them with my industry colleagues and with my peers,
and I hope that we'll have a chance to engage further,
but I just wanted to thank you.
MR. TYREE: Thank you for your comment.
Do we have anyone else? Oh, Mr. Gunter?
MR. GUNTER: Thank you. I want to, let's
see, I'm going to try to frame a question that came
out of the RIC session with regard to the scope of
risk-informed relicensing and particularly around how
the agency and industry treat single failure events
versus multiple failure events.
And I'm just curious if you could help me
understand the idea that you can, for example, risk
inform cable failure based on single failure of a cable
when, you know, the examples out there are of the Browns NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 81
Ferry fire where you had, you know, a cable spreading
room caught fire and there were over 1,600 cables
involved in that fire and almost half of them were
safety related.
So, I'm just curious in terms of how you
determine the scope of risk. The pilot program that
was raised in that particular presentation was on a
single failure of a cable, and I believe it was a
submerged cable that was the subject of the pilot, but
fire raises some, you know, bigger consequences.
So, I'm just -- if you can help me
understand how you can fairly treat risk in risk
informing things like fire and submergence of
electrical cables. Is that clear what I'm trying to
ask?
DR. HISER: Paul, this is Allen Hiser.
Let me take the first crack at it. I mean, things like
fire would not be affected by aging of the component,
so I'm not sure if that really would fit in. I mean,
we normally --
MR. GUNTER: Aging, you know, doesn't
aging involve initiation of fire?
DR. HISER: I'm not familiar with that.
MR. GUNTER: You know, cracked cable
jacketing, I mean, can't -- you know, again, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 82
age-related initiation of a failure event could have
much broader consequences than a single cable. I guess
that's my --how do you limit the scope of something
like that to a single failure when the outcome is
multiple failures?
DR. HISER: Let me just take half a step
back. We have not approved anything like this using
risk, so that probably would be one of the things that
we would need to tackle, and that's not, I know that's
not a satisfactory answer, but --
MR. GUNTER: Well, I may not be making my
question clear enough. You know, again, if you look
at age-related degradation for submerged cable, you
know, it would imply that, again, looking at single
failure for a single cable, you know, you're qualifying
the risk on a single failure when multiple cables could
be involved in that.
I'm just -- you know, to be blunt, can you
-- you know, how do you check fixing the result by
narrowing the scope, you know, making the risk
acceptable by narrowing the scope of the aging event?
That's a concern, you know, that I think
is broadly felt in terms of public confidence, that
you can manipulate the scope, particularly when there
are, you know --
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MS. KICHLINE: Can I try to answer this
question? This is Michelle Kichline from the NRC.
I think we're maybe confusing different types of PRA
here. So, you talked about fire PRA and that's an
external event. It would be modeled a little
differently than when we perhaps model, you know,
submerged cables.
So, in a fire PRA, you would definitely
look at how does that cable and the fire that could
occur in a cable tray impact all of the cables in the
area? That would -- a fire PRA would look at the
spatial analysis for everything in the area and all
of the cables in the area.
But for internal events' PRA where you're
looking at the cable failure degradation due to the
submerged cable, you're not looking at fire as what
is initiating. You're looking at the cable becoming
degraded.
Now, if there was a failure mechanism in
which the cable were to -- I don't know that the
submerged cable is going to catch fire, but there are
some situations where we do have cables that are in
underground chases and they can cause, some say, high
energy arching faults.
Then the scope of, you know, where does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 84
that arching fault go would be included in the failure
mechanism. When the cable fails, what it takes with
it would be also failed, so it just depends on what
type of PRA you're looking at.
And I think you're specifically calling
out the one pilot AMP which I'm not completely up to
speed on exactly how they did the risk analysis. I
think you're right that it was for a single cable that
was submerged. What would occur if that cable were
to fail?
MR. GRANTOM: Yeah, this is Rick. Let me
add something about the fire PRA. So, fire PRA does
include multiple spurious operation. It does include
multiple cables failing as a result of a fire. So,
those things are in the PRA standards. They're peer
reviewed. So, that type of thing is included.
Single failure is one thing as a
deterministic criteria, but PRA goes well beyond that
and looks at multiple failures, and failures upon
failures. That's how we get to core damaging events
and PRA sequences to do that.
So, to answer part of the question, do we
look at multiple failures? Yes, we do. PRAs are
explicitly structured to do that. Fire PRA is included
in that as well also.
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The risk-informed aging management
program on cabling looking at primarily, I believe,
like sampling rates and different types of things.
I don't believe it did anything relative to the scope
of cables that were included.
It looked at different ways to do sampling
rates, do changing intervals for inspections and that
type of thing from what I recall, but again, going back
to that, fire PRAs are structured to do just in fact
that, as are seismic PRAs.
MR. GUNTER: Thank you.
MS. GIBSON: I believe that the concern
is that the questions get to the heart of how the
risk-informed decision making and the risk-informed
format is working with these AMPs, the pilot AMPs that
we've seen, and we have some open questions on that
from the NRC side, and that's what we're hoping to dig
into with the audit and with future interactions with
NEI as well. Thank you.
MR. TYREE: Are there any other questions
or comments? One last housekeeping item to go over
real quick is for any members of the public who have
called in, if you could email me, I'm going to put my
email up on the screen here in a second, to just let
me, you know, give me your name and if there's any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 86
affiliation just for our meeting notice that we will
be putting out just to include the attendee's list.
MS. GIBSON: I know we've already had
plenty of opportunities for public comment, but I think
we need to formally say this is an opportunity for
public comment. So, are there any other public
comments or questions for the NRC?
(Pause.)
MR. TYREE: Okay, if there are none, I
appreciate everyone's time for today.
MS. GIBSON: So, I have a few closing
comments. I'd like to reiterate some of the things
that I heard here today. I heard that there were
concerns about the applicability of PRA, and there's
concerns about how it would be implemented in the pilot
AMPs, even though the pilot AMPs were not the subject
of this meeting.
I understand that there are concerns that
risk needs to go both ways, that it's not just about
relaxing. The AMP implementation seems to be the area
of most interest across these stakeholders, and it
would be helpful to have more specific guidance on 50.59
implementation.
It is stated in all of the license
conditions for the individual plants that it is a change NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 87
mechanism, but there is no further explanation for
that, so I think that that would be helpful.
And I also heard concerns about the
environmental qualification, TLAA, and the special
treatment, and that is something that the NRC staff
is going to follow up on. And I see that we have a
hand up. Paul?
MR. GUNTER: Yeah, just a quick question
about, so the meeting summary out of this, will we be
looking for the ML number for the transcript in that
summary?
MS. GIBSON: We can do that. Sure, let's
talk about that, but that's a possibility.
MR. GUNTER: Thank you.
MR. GRANTOM: With regard to your
takeaways on this, you know, also as a member of the
public, I'd say I'd have concerns on not using risk
information to perform this, so will the counterpart
of what you just said also be included in that? Because
you said the concern for this, or the concern for this,
concern for this. Well, the counterpart is also a
concern of not doing these things.
MS. GIBSON: It will be now. Thank you.
MR. GRANTOM: Thank you.
DR. HISER: Lauren, can I just ask one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 88
follow-up tothat?
MS. GIBSON: Sure.
DR. HISER: This is Allen Hiser again.
Rick, what do you mean of not -- I don't remember your
exact words.
MR. GRANTOM: If you don't use the
technologies that we have -- we had PRAs that meet
standards that have been peer reviewed, that the
method's endorsed by the regulator, and using, you
know, what has been already in a sense agreed upon,
to deviate from that, to say all of a sudden that, well,
we have concerns on using risk, well, we use risk for
risk-informed completion times. We use risk for lots
of things. The reactor oversight processes use risk.
So, if you'regoing to say that I have a
concern about using risk, I'm going to probably also
say on the counterpart I have a concern about you not
using risk as an input. That's what I mean.
DR. HISER: Okay, yeah, I think when we
say concerns about using it, I think how it will be
used and what the -- you know, how it really fits in.
MR. GRANTOM: Okay.
MS. GIBSON: My first bullet of concerns
about the applicability of PRA was meant to state that
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management concerns, not in general the use of risk.
DR. HISER: Right.
MR. GRANTOM: Okay.
MS. GIBSON: Noted, Rick. We have your
concern. We have your concern about our concern.
MR. GRANTOM: We have a nested concern,
okay, very good.
MS. GIBSON: All right, anything else?
MR. MITMAN: This is Jeff Mitman. I'm a
retired NRC risk analyst. I hope you also capture the
concern with using outdated PRAs, that the industry
and the NRC should be using the most current versions
of the PRA, not the archaic 30-year-old versions of
MS. GIBSON: So noted. Thank you.
MR. MITMAN: Thank you.
MR. TYREE: Thank you. Do we have one
last chance if anyone else has any comments or a
question?
MR. TITUS: Lauren, this is Brett Titus,
and Chris, is this the time for our closing remarks
as well or are these just comments?
MR. TYREE: We can do closing remarks at
this point since no one --
MS. GIBSON: This was meant to be my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 90
closing remarks and then we got some comments, so we
can have it all at once.
MR. TITUS: Well, I'll go ahead and take
this opportunity to thank the staff for continuing this
conversation. I think you've heard a lot of good
perspectives and some places where we can fill in with
some additional guidance.
I do think, to Rick's point, there is a
lot of information to be gleaned and some efficiencies
to be gained, and we're looking to do that in the near
term, so we look forward to more conversations about
the AMPs, the pilot AMPs that we set forward, and we're
looking forward to moving towards a more generic
endorsement of the methodology and the framework that's
been laid out in front of us.
So, we do applaud the NRC on this meeting
and all of the great information that was supplied in
Allen's presentation, which was an extension of your
presentation from the RIC, and we think we're
definitely in line with all of the boundary conditions,
et cetera.
And if the NRC does feel the need to, you
know, pursue a policy clarification from the Commission
or embark on some kind of rulemaking, that's something
that we would certainly support, but as our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 91
presentation alluded to, our top priority right now
is at the implementation stage. So, thanks again for
this opportunity.
MR. TYREE: Thank you.
MS. GIBSON: Thank you. Would anyone
else like to make any closing comments?
MR. TYREE: Okay, seeing none, we will
conclude this meeting for today. Thank you, everyone,
for participating. Have a good rest of your day.
(Whereupon, the above-entitled matter
went off the record at 3:18 p.m.)
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