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L i
DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JULY 16, 1998 b
l The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
- Committee on Reactor Safeguards, taken on July 16, 1998,-as reported herein, is a record of the discussions recorded at the meeting held'on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
t c
F
 
1 i
1 UNITED STATES NUCLEAR REGULATORY COMMISSION j
2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
l l
3 l
4 PLANT LICENSE RENEWAL 5
l 6
1 7
U.S. Nuclear Regulatory Commission i
8 Two White Flint North, Room 2B-3 9
11545 Rockville Pike 10 Rockville, Maryland
]
l 11 q
12 Thursday, July 16, 1998 13 14 The committee met, pursuant to notice, at 8:30 15 a.m.
16 17 MEMBERS PRESENT:
18 MARIO FONTANA, Chairman, ACRS 19 GEORGE APOSTOLAKIS, Member, ACRS I
20 DON MILLER, Member, ACRS 1
21 ROBERT SEALE, Member, ACRS 22 WILLIAM SEACK, Member, ACRS i
23 DANA POWERS, Member, ACRS 24 ROBERT UHRIG, Member, ACRS l
25 i
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2 1
PROCEEDINGS 2
(8:30 a.m.]
3 CHAIRMAN FONTANA:
The meeting will now come to 4
order.
5 This is a meeting of the ACRS Subcommittee on 6
Plant License Renewal.
I'm Mario Fontana, Chairman of the 7
Subcommittee on Plant License Renewal.
8 The ACRS members in attendance are George
.9 Apostolakis, Don Miller, Robert Seale, William Shack, who 10 will be here in a minute, Dana Powers and Robert Uhrig.
11 The purpose of this meeting is to discuss the 12 NRC's staff's activities associated with license renewal, 13 proposed staff plans and schedule for reviewing the license 14 renewal application, and related safety issues.
15 The Subcommittee will also discuss the ACRS 16 involvement in reviewing the license renewal submittal and 17 related matters.
18 The Subcommittee will gather information, analyze 19 relevant issues and facts, and formulate proposed positions 20 and actions as appropriate.
l 21 Our experience has been that interactions with the 22 ACRS at appropriate times have led to a much smoother 23 process and final agreement than has been the case in 24
-instances where the ACRS reviews were delayed until the very 25 end, and we hope to identify natural points in the process ANN RILEY & ASSOCIATES, LTD.
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whora mastings bstwacn tha license renewal participants and 2
the ACRS would be beneficial.
3 Medhat El-Zeftawy is a cognizant ACRS Staff 4
Engineer for this meeting.
5 The rules for participation in today's meeting has 6
been announced as part of the notice of this meeting 7
previously published in the Federal Register on June 29th, 8
1998.
A transcript of the meeting is being kept and will be 9
made available as stated in the Federal Register notice.
10 It is requested that the speakers first identify 11 themselves and speak with sufficient clarity and volume so 12 that they can be readily heard.
13 We have received no written comments or requests 14 for time to make oral statements from members of the public.
15 We will proceed with the meeting, and I call upon Mr. Frank t
16 Miraglia of the Office of Nuclear Reactor Regulation to 17 begin.
18 MR. MIRAGLIA:
Can you hear me now?
19 CHAIRMAN FONTANA:
Yes.
20 MR. MIRAGLIA:
Okay.
Thank you, sir.
21 Thank you, Dr. Fontana.
22 My name is Frank Miraglia.
I'm Deputy Director of 23 the Office for Nuclear Reactor Regulation.
24 I'm here with two objectives today:
First as the 25 Deputy Director of the program office responsible for the ANN RILEY & ASSOCIATES, LTD.
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4 1
implementation of the license renewal program for power 2
reactors, and second, I have an additional role of being 3
Chairman of the License Renewal Steering Committee, and I'll 4
be presenting-to you what that role of that committee is.
5 Subsequent to my remarks, Chris Grimes, the 6
Project Director for License Renewal, will be putting the 7
context -- in context the agenda for today, which is shown 8
on this slide, which is in your handout.
9 My primary purpose is to talk about the Steering i
10 Committee.
11 License Renewal, as a program, has been receiving 12 elevated interest in the industry.
The Chairman made 13 License Renewal the centerpiece of her remarks at the Reg 14 Information Conference that was sponsored by the Office of l
15 Reactor Regulation in May of this year, and the Commission j
16 has expressed an interest in orderly conduct and -- of that 17 program.
18 In that regard, the Chairman chartered the 19 Executive Council, which is the CFO, CIO and EDO to monitor 20 the progress of the program to assure that it's proceeding i
21 apace and has the right type of attention in terms of policy 22 issues and resources, i
23 In line with that interest from above and from l
l 24 outside the Agency, from an office perspective, there is 25 that same sort of interest.
And Sam Collins commissioned a ANN RILEY & ASSOCIATES, LTD.
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Steering Committee -- Licenso Renewal Steering Committee.
2 I believe you have in your packages an April 29th memo which 3
was the charter for this Steering Committee.
4 The membership of the Committee is the NRR 5
Executive Team.
These are the principal directors that will 6
be participating in the review of the program to assure that 7
there is management attention from within NRR.
8 The membership also includes a representative from 9
the Office of General Counsel, a member from the region, and 10 a member from the Office of Research.
11 The purpose of the Steering Committee is to advise 12 the Director of Regulation on the progress of the review and 13 issues in terms of the status of review for the specific 14 applications.
15 As you are probably aware, we do have two 16 applications for review.
One is Calvert Cliffs Baltimore.
17 Gas & Electric, which was proffered in May -- April.
And 18 then last week, Duke Power submitted an application for the 19 Oconee Units for renewal.
So there are two specific 20 applications under review.
21 In addition, there is an industry steering group 22 and working group following generic issues and generic 23 reports, and the staff is working through NEI to coordinate 24 those reviews.
And so there will be generic issues and 25 technical issues from that venue.
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DR. UHRIG:
Those applications, do they include l
2 all units, the three units at Oconee --
3 MR. MIRAGLIA:
That's right.
4 DR. UHRIG:
-- and two at Baltimore?
5 MR. MIRAGLIA:
Yes, sir.
Yes, sir.
And the staff 6
is prepared to give you more details on the current 7-schedules.
8 Dr. Fontana, you asked and indicated points at 9
which interaction with the ACRS might be appropriate, and I 10 think when the milestones are described, I think there will 11 be some natural points where the staff would -- and the 12 applicant would find those interactions useful.
4 13 DR. UHRIG:
Will those renewals be individually 14 for the individual plants, or will they be sort of a group i
15 of three there?
16 MR. MIRAGLIA:
The review would be a review for 17 the three units.
It would have to have three specific --
18 DR. UHRIG:
Licenses?
19 MR. MIRAGLIA:
-- licenses.
20 DR. UHRIG:
Okay.
21 MR. MIRAGLIA:
Because each license --
l 22 DR. UHRIG:
Is separate.
23 MR. MIRAGLIA:
-- is separate.
24 DR. UHRIG:
That's right.
25 MR. MIRAGLIA:
Yes, sir.
I l
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DR. UERIG:
Thank you.
2 MR. MIRAGLIA:
So the primary purpose of the 3
steering group is to monitor the staff review on these 4
principal applications and the generic issues, to follow the 5
resolution of the technical issues in the process, and make 6
sure that we're following the goals and objectives in our 7
operating plan.
8 What we're going to be using as a Steering 9
Committee are the same indicators that the line organization 10 is going to be using.
11 Are we meeting schedules?
12 Are we meeting the resource expenditures that had 13 been planned?
14 The specific applications will have specific 15 milestones.
The generic reviews -- we're working with the 16 industry to identify what the issues are in terms of 17 priorities, and then to schedule the top priority. items so 18 we would have milestones as to the importance of the issues 19 and the path for resolution.
20 So our Steering Committee is going to be monitoring the p' ogress on that to assure that there is 21 r
22 orderly resolution of these issues.
23 The second role that we play is to recommend to i
4 24 Sam Collins, based upon our interaction with the staff and 25 the industry any recommended actions to approve the process l
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8 1
or to resolvo issues.
2 We're also going to act as the communication from l
3-the program office to the Executive Council.
As I said, the l
l 4
Chairman has charged the Executive Council to monitor our l
l 5
progress.
I 6
We-have the staff, as well as I as the Chairman of 7
the Steering Committee, and have been having periodic 8
meetings with the Executive Council to indicate the status 9
to date and where we stand with respect to our goals and 10 objectives.
11 In addition, the Steering Committee will be l
12 interacting with the industry.
We've had one meeting with 13 NEI and working groups.
We have a meeting planned next -- I 14 think it's the 22nd.
Steve, is that the right date?
i 15 And then there is a meeting about a month 16 subsequent to that in August already planned to provide a 17 forum to say, "How are we progressing?"
18 The focus of next week's meeting -- the previous 19 meeting with the industry is to get from them what are their 20 views and priorities of the issues so we can foc.us on the 21 issues of importance, schedule a path to resolve those 22 issues so we -- they don't wind up being a bar to progress 23 with respect to the reviews.
24 There is in the next chart --
25 DR. SEALE:
Frank, can I --
l l
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MR. MIRAGLIA:
Yes, sir.
2 DR. SEALE:
-- make a comment?
3 In the June meeting, we went through the 4
application for the upgrading of the power level on the 5
Monticello Plant, and toward the end of the meeting, we were 6
suddenly made aware of the fact that there were three issues 7
that were in the generic power upgrading process that 8
referenced -- that were referenced in the Monticello 9
~ application, and for us to be able to get -- pull -- to 10 write a closecut letter on that issue, we would have to 11 finish up the resolution of those three issues, as well, and 12 we were able to do that in our just previous meeting.
13 But we were in the rather awkward position of 14 being on the critical' path, as it were -- potentially on the 15 critical path for the review of that particular item.
16 And you're really in charge of the schedule, and 17 our schedule included -- and I just want to express our 18 desire to not be on the critical path on any of the things j
19 having to do with license renewal, and we'll have to rely on 20 you to make sure that we're not.
So that if there are any i
21 generic things that happen to be a problem, we want to be 22 able to see them early entitled so that we don't get 23 ourselves in that position.
24 MR. MIRAGLIA:
I'd like to amplify on the "you,"
l 25 that you used.
You as a plural pronoun --
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DR. SEALE:
Suro.
2 MR. MIRAGLIA:
-- and as it applies to me, not 3-only because of my size.
I am wearing two hats.
i.
l-4 DR. SEALE:
I understand.
5
[ Laughter.)
6 MR. MIRAGLIA:
And in terms of -- in terms of 7
that, you -- the primary you in terms of the schedule, it's 8
'the staff and it's the line organization.
9 What this chart is to depict for this process to 10 work --
11-DR. SEALE:
Okay.
the industry and the staff and 12 MR. MIRAGLIA:
13 the line have to work anc make it happen.
14-The Steering Committee, now, including switching 15 my hat as the Chairman of the Steering Committee, I have an 16 additional role, not only as --
17 DR. SEALE:
Yeah.
from the program office, but 18 MR. MIRAGLIA:
19 from the perspective of oversight.
20 Are we moving on the right --
21 DR. SEALE:
Yes.
22 MR. MIRAGLIA:
-- kind of issues?
23 Are we identifying them --
24 DR. SEALE:
Yes.
25 MR. MIRAGLIA:
-- and to get those bars.
I i
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1 11 1
Our goal is not to have that happen --
i, 2
DR. SEALE:
Okay.
3 MR. MIRAGLIA:
-- Dr. Seale.
4 DR. SEALE:
Okay.
5 MR. MIRAGLIA:
Our success will depend on not 6
having that happen at all.
7 It remains to be seen where the --
i 8
DR. SEALE:
Sure.
9 MR. MIRAGLIA:
-- issues are.
Is it how they go 10 is -- but that is certainly the intent.
11 And the levels of oversight predominantly is 12 within the staff and the staff organization, with oversight l
13 by the Steering Committee, and further oversight by the 14-Executive Council and the Commission.
15 There's very high interest in this program.
Your 16 comments are well taken, and I think --
17 DR. SEALE:
Let us know --
18 MR. MIRAGLIA:
-- the program office, the Steering 19 Committee and the staff clearly understand --
20 DR. SEALE:
Let us know if there is a problem, and 21 we'll -- we can't promise that we won't be, but we will i
22 certainly try --
23 MR. MIRAGLIA:
And from -- as the Chairman of the 4
l 1
24 Steering Committee, if there are issues that the Committee 25 would like to raise through the Steering Committee, we're I
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certcinly receptiva to doing that and briefing you --
2 DR. SEALE:
Fine.
3 MR. MIRAGLIA:
-- if that would be useful to the 4
Committee, as well.
5 DR. SEALE:
Thank'you.
6 MR. MIRAGLIA:
So I think I've completed n/
7 primary role here today and met the two objectives to talk 8
about the Steering Committee.
9 Chris Grimes is going to discuss the rest of the 10
-agenda and where we stand with the program to date.
11 I want to apologize to the Committee, because my 12 initial intent was to spend the morning with you.
I'm going 13 to spend at least another hour with you, and I apologize for 14 having to leave.
15 DR. APOSTOLAKIS:
I have a question.
16 MR. MIRAGLIA:
Yes, sir.
17 DR..APOSTOLAKIS:
I read some of the documents 18 that were forwarded to unit s.
19 Is there a regulatory guide now that tells the 20 world what you think they should do?
21 MR. MIRAGLIA:
Yes.
Let me -- the staff will be 22 talking more to that, but let me just indicate that there 23 has been interaction with the ACRS on license renewal in l
24 terms of the Part 54 rulemaking, and there was interactions l
25 with the committees when the rule was promulgated.
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there was a rule and an amended rule.
That rule er.cabli.shes 2
the process.
3 There is a draft reg guide that has been out for 4
comment.
I believe that reg guide was discussed with the 5
Committee, and it may be sometime back.
6 DR. MILLER:
Yes.
7 MR. MIRAGLIA:
There i s a draf t SRP that I don't 8
believe we've brought to the Committee.
Those documents are 9
points of departure.
10 The application of those principles and these 11 first two plants are going to be a learning process for us 12 to defer, to modify, consider the comments from the 13 industry, in terms of the issues that the industry is going 14 to prioritize, Dr. Apostolakis.
15 There are a nunber of issues that they have raised 16 in context to the comments on the reg guides.
So those are 17 going to be prioritized with all the issues there to get an 18 orderly resolution to those so the review could progress.
19 The outcome being, at some point after the 20 completion of the initial reviews, a modified reg guide and 21 standard review plan that's consistent with the experiences 22 gained on the first two facility surveys.
23 DR. APOSTOLAKIS:
On the applications from Calvert 24 Cliffs and Oconee, I looked at the applications.
Nothing --
25 MR. MIRAGLIA:
We have not used -- these are ANN RILEY & ASSOCIATES, LTD.
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honest to goodnnss --
l2 DR. APOSTOLAKIS:
Okay.
3 MR. MIRAGLIA:
-- real applications for.a license.
4 DR. APOSTOLAKIS:
But we expect to learn a lot 5
from these?
6 MR. MIRAGLIA:
Absolutely, and I think we and the 7
staff have articulated that to the Commission and the 8
industry what our intent is.
9 There are questions out there, and the details --
10.
you know, the devil is always in the details of 11 implementation.
12 DR. APOSTOLAKIS:
Right.
13 MR. MIRAGLIA:
And we, in the industry, expect to 14 learn by this process.
We've had dialogue with the industry 15 on how we're going to proceed and how changes will be made 16 in the future.
17 DR. APOSTOLAKIS:
But have the rules of the game 18 been determined already, established --
19 MR. MIRAGLIA:
In terms of process, Part 54 20 DR. APOSTOLAKIS:
Yeah.
21 MR. MIRAGLIA:
-- establishes that.
22 DR. APOSTOLAKIS:
Okay.
23 MR. MIRAGLIA:
And then the staff and the Steering I
24 Committee, working with industry, will monitor the 25 implementation of that process.
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DR. UHRIG:
Are there a significant number of 2
plants that are sort of sitting, waiting, watching this 3
process, anticipating the submission of renewals --
4 MR. MIRAGLIA:
Yes.
5 DR.-UHRIG:
-- or --
6 MR. MIRAGLIA:
Yes, sir.
I think the indication 7
we have, most of it, is informal.
This is -- I mean if one 8
just takes a step back, 20 percent of the electrical supply 9
in the country is nuclear.
10 The decisions for renewal are economic by the 11 utilities.
A lot of that depends upon what's going on in 12 their own service areas with respect to deregulation, but 13 there is a number of utilities who feel that it is -- the
-14 economics are going to support renewal.
And so I think it
(
15 is important to show progress.
16 I think that's what's spurring the external 17 interest from the industry, from the Congress, from --
18 internal from the Commission, all the way down, to make sure 19 that the process does work.
20 It's an important process and the outcome of the 21 process is going to be important, as well.
j 22
-DR. MILLER:
Is there a fairly detailed schedule 23 for the'-- for, say, Calvert Cliffs --
24 MR. MIRAGLIA:
Yes, hopefully --
25_
DR. MILLER:
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have to see that today?
2 MR. MIRAGLIA:
There should -- it should have been 3
provided --
4 DR. MILLER:
We saw --
5 MR. MIRAGLIA:
-- in the background papers for the
'6 Committee.
7 DR. MILLER:
We saw the list of milestoner.
8 MR. MIRAGLIA:
Yes, those -- those --
9 DR. MILLER:
What I'm looking at, is there more 10 than just a list of milestones?
11
-MR. MIRAGLIA:
There's probably intermediate 12 milestones from those in terms of where individual branches
~13 stand, but I think it goes down to when the RAI's have to go 14 out and things of that nature, i
15 But the staff could dialogue more with you on 16 that, Dr. Miller.
17 We haven't put the schedule out on Oconee yet, but 18 it would be very, very similar to that, and the Committee 19 will be provided with that information, as well.
20 As soon as we have prioritization from the 21 industry and schedules for those issues, we'll provide that.
22 That could be potential agenda issues on some of 23 those issues, as well.
24' DR. MILLER:
There's also a mention of a number of 25 technical issues in one of the memoranda like I think the l
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one -- are those issues being resolved, or is that -- what 2
are we going to learn about that today?
3 MR. MIRAGLIA:
That's -- and what I'm talking 4
about the issues, you'll hear more about that, but there are 5
issues that the industry has raised with respect to process, 6
technical issues, and then issues that resulted from 7
comments on the draft Regulatory Guide.
8 All of those issues have been collected.
The I
9 industry is prioritizing those and grouping those, and then 10 we'll work those off and priority schedule to make sure that j
11 those issues are on a path to resolution, and what the goals 12 and objectives are.
13 And we can share that with the Committee as soon 14 as we have input from the Committee and establish what those 15
' schedule -- the Working Group of the industry and they'll 16-set a potential agenda for interaction on issues, as well, l
17 with this Committee.
18 MR. GRIMES:
My name is Chris Grimes.
I'm the 19 Director of the License Renewal, Project Director.
20 As Frank mentioned, we met with the ACRS in l
21 January of this year, and we talked about part -- the 22 contents of Part 54 and Part 51 that provide the 23 requirements for license renewal technical and environmental 24 reviews.
And we talked about the contents of the draft 25 standard review plans and our efforts to try and organize ANN RILEY & ASSOCIATES, LTD.
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and prepare to review license renewal applications.
lj 2
Since that time, there has been a tremendous 3
amount of focus on the license renewal process.
Starting in o
4 about February, as Frank mentioned, the Chairman directed 5
the Executive Council to provide s'.'ewardship and oversight 6
of the license renewal process.
We've met with the 7
Executive Council 12 times.
8 Also, as Frank mentioned, the formation of the 9
Steering Committee and a focus on schedules and resources l
10 has caused us to spend a considerable amount of time looking 11 at plans, resources and appropriate milestones fer these 12 reviews.
13 We had not planned on going back over the contents 14 of Part 54 or Part 51 today, but instead, we were going to l'
15 stem from that and talk more in terms of the implementation 16 plans and the kinds of preparations that we're making for l
l 17 the conduct of the reviews.
l 18 Bob Prato of my staff is going to talk about the 19 guidance that's being developed to assist the staff in the 20 conduct of the reviews, and he's going to go back over those l
21 issues that we described in January in terms of how we're 22 going to approach those issues in a process way.
23 And then I will -- I will go through and talk 24 about the particular status of all of those activities.
And 25 I will describe, as best I can, where we stand with our ANN RILEY & ASSOCIATES, LTD.
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plans and schedules so that then we can have a meaningful 2-dialogue with you in terms of what are the most efficient j
3 and appropriate ways for the staff to interact with the 4
ACRS.
5 And with that, I -- unless you have any general 6
questions for me, I'll have Bob Prato start in with the 7
presentations.
8 CHAIRMAN FONTANA:
Okay.
Thanks.
Thank you.
9 MR. PRATO:
Good morning.
I'm Bob Prato.
10 Can you hear me okay?
11 Everybody can hear me back there?
12 I'm Bob Prato.
I'm currently the Acting Section l
13 Chief in the PDLR Engineering Section, and I'm also a 14 mechanical engineer responsible for the inspection program 15 in the implementation program for license renewal.
16 I'm going to be covering the inspection program 17 and the office letter, and if you remember, in January, we 18 gave pretty much the same presentation, so my primary 19 objective is to review what we basically told you in January
.20
'and tell you what has changed.since January, and where we're 21 going in the next few months.
22 Based on our presentation last January, we told 23 you that the license renewal application -- the license l
24 renewal inspection program is broken down into two basic 25 applications.
The first applications is the pre-renewal i
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application approval inspection activities, and the second 2
application is the post-renewal inspection activities.
3 During that period of time, we discussed the 4
program documentation, the aging management program 5
implementation, and the aging management program 6
effectiveness as the objectives of the license renewal 7
pre-application approval inspection activities.
8 As for the objectives, the program documentation 9
is intended to review the document -- the on site 10 documentation associated with an applicant's license renewal 11 inspection program.
12 The intent is to verify that the documentation is 13 being maintained consistent with the requirements of the 14 rule and site procedures.
t 15 The second one, the aging management program 16 implementation, our objective in that objective in that 17 phase of the inspection process is to verify that the 18 applicant did, indeed, implement the program as it was 19 described in their application, as well as the changes as a 20 result of the staff's safety evaluation.
21 And, finally,,as the third objective of the 22 inspection program is to verify that the aging management 23 programs are being implemented effectively.
24 As for the post-license renewal application 25 approval, the intent of the inspection program is to verify ANN RILEY & ASSOCIATES, LTD.
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that license conditions have been met, license commitments 2
have been met, as well, and that the aging management 3
programs continue to be effective.
4 This portion of the inspection program we expect 5
will fall in direct line with the current operating reactor 6
inspection activities.
There are no new activities expected 7
as a result of this.
Maybe some additional actions.
8 The regions and the residents are used to dealing 9
with license conditions and license commitments, and as far 10 as aging management effectiveness, it's routine inspection 11 type of activities.
12 MR. GRIMES:
Bob, if I could, I'd like to 13 interject at this point and focus specifically on recent 14 lessons learned from Millstone, a Maine Yankee, in terms of
(
15 process improvements for operating reactors.
And one of --
16 embedded in this objective is the recognition that we can do 17 a better job in our safety evaluations and in the license 18 content of identifying those particular licensee features --
19 the features of their programs that we rely on for our 20 reasonable assurance findings.
And so we expect to -- as j
21 Bob pointed out, we want to see the end result blend in 22 seamlessly with the routine, but at the same time, reflect 23 on lessons learned and better ways to do this.
24 So when we present our safety evaluation, when we 25 present the final license, we hope that you will find that ANN RILEY & ASSOCIATES, LTD.
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we've donn a batter job of articulating what the licensing L,:
2 basis is and what commitments the license -- we've relied on 3
in our findings so that the inspection program is better 4
focused.
5 DR. SEALE:
That seamlessness in the process is, 6
as I recall, certainly an aspiration of the discussions that 7
have gone on'in the implementation of the maintenance rule.
8 And, in fact, the aging management program itself is really 9.
a part of the main -- of the maintenance rule 10 implementation.
11 Now at the same time, a lot of people are just now 12 getting through the transition, if you will, to compliance 13 with the modern maintenance rule, and I would -- I would l
14 hazard a guess that perhaps Oconee or Calvert Cliffs might li 15 not be in as good a position in terms of a history of i
16 maintenance rule, just because of the calendar that you 17 might expect five years from now from an applicant that 18 might come in.
l 19 But I would -- I would guess, if you would -- you 20 would want to at least see the traces there that shows that, p
.21 you know, where the ganglia will connect back to the 22 maintenance rule at -- in the full maturity of that 23 transition.
~
j 24 I'd be interested, as you go along, if you can 12 5 maybe make some of those connections.
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MR. PRATO:
There are a lot of activities where 2
license renewal and the main people are interacting, and 3
we're trying to glean as much of the lessons learned from 4
the -- from the maintenance rule as we possibly can.
And I 5
believe that we're doing that.
We work with them an awful 6
lot.
7 DR. SEALE:
So anything you can tell us --
8 MR. PRATO:
A lot of our activities are being 9
integrated.
10 MR. GRIMES:
Okay.
11 MR. PRATO:
And we will be covering that.
12 MR. GRIMES:
Bob, are you going to talk a little 13 bit about the -- how you and the maintenance rule folks have 14 worked together to identify inspection procedures?
15 DR. SEALE:
Yes, sir.
16 MR. GRIMES:
Okay.
17 MR. PRATO:
That will be covered on our next 18 slide.
19 DR. SEALE:
Good.
20 MR. PRATO:
As far as the status of the inspection 21 program, the license renewal manual Chapter 2516, okay, has 22 been issued -- was issued last month.
It's taking a little 23 while to get onto the Web, but nonetheless, it's been 24 officially issued.
And the regions have been part of the 25 review process.
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The maintenance rule people have been part of the i
2 review process.
They've been on review for all of our 3
documentation, and we will receive quite a few comments, and 4
we've integrated all those comments.
5 The license renewal inspection procedure IP71002 6-has also been issued.
It's in the same status as the manual 7
chapter that was issued about the same time.
As a matter of 8
fact, it was issued in the same revision package.
: But, 9
again, it hasn't made it to the Web yet, but we expect it l'0 any day.
11 There's a lot more information going on the Web 12 than has been in the past, and it's just taking longer for 13 revisions to get incorporated.
14.
As far as for the aging management program 15 inspection procedures, initially -- and we looked at this on 16 two levels.
We looked at it as the pre-approval phase and 17 the post-approval phase.
18 And what we had intended to do for the l
19 pre-approval phase was to develop separate inspection 20 procedures for the major aging management programs.
And for l
21 the post-approval phase, we were going to go through the 22 current 2515 program and make revisions to the existing 23 procedures, as they exist today, to make sure that license l
24 renewal was adequately covered.
i 25 In recent months, we've started working with the ANN RILEY & ASSOCIATES, LTD.
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maintenance rule people.
They're going through a major 2
revision of the 2516 IP procedures.
We are starting to get 3
together and incorporating --
4 What we found was, especially with the 5
erosion-corrosion procedure -- this is what initiated these 6
actions -- is that the maintenance rule people had a draft 7
erosion-corrosion special procedure, license renewal 8
pre-approval.
We had developed a procedure for verifying 9
erosion-corrosion aging management programs.
They looked 10 significantly different than what exists today in 2515.
11 But the bottom line is, all three procedures had 12 the same end results.
We were trying to verify that they 13 had effective aging management programs in place.
14 So what we've done is, we've decided that we're 15 going to coordinate all our revisions into one.
We are 16 working directly with the maintenance rule group.
The 17 intent is to develop one procedure that takes care of all 18 three items, the maintenance rule requirements, the current 19 2515 inspection requirements, and the aging management 20 review requirements, not'only for the post-approval, but for 21 the pre-approval stage.
22 And we believe that in 90 percent of the cases, 1
23 we're going to be able to do this.
There may be some 24 individual procedures that need to be developed, 25 specifically for license renewal.
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A lot of the licensees are taking credit for j
i 2
engineering walkdowns, for example, in the area of license I
3 renewals to verify that aging is being handled 4
appropriately, and right now, that's one area where we may j
l 5
have to develop a separate procedure, although the industry, 6
as a whole, is trying to integrate their -- these efforts 7
that they're doing, this routine walkdowns that are -- now 8
that~are proceduralized, that are part of their 9
requirements, that are integrated in -- into, not only their 10 maintenance program, but also into their engineering 11 program.
12 So it may, in the long run, end up that even those 13 that we suspect are going to be focused on license renewals 14 may, again, end up being part of the 2515 program, t
15 The other reason we started doing this is because 16 we found out that, through presentations from BG&E and 17 Oconee, that the major of their aging management programs 18 are existing.
19 And just for rough numbers, and I'm not sure about 20 the specifics, I believe BG&E claimed that they have 330 21 aging management programs.
280 of them -- approximately 280 22 of them are existing programs without any changes, and 23 approximately another 30 or 40 are existing programs with 24 minor changes.
25 That means about five percent of their aging 1
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27 1
managtment programs are new programs', okay.
And because we 2
do inspect the current programs, it makes a lot of sense 3
that we integrate it in the current inspection activities.
4 As far as the feedback process, I'm going to cover 5
most of that under office letter 805, but we do have a 6
process in place.
That process doesn't apply to the 7
inspection program.
We expect lessons learned, especially 8
after we start implementing for BG&E and Oconee, the license 9
renewal inspection activities.
10 Our intent is to try and track all the lessons 11 learned to completion.
One of the things that we've -- one 12 of the guides that we've implement with respect to the 13 feedback process, the lessons learned process, is that the 14 documentation that provides the guidance, documentation like 15 the SRP, office letter 805, the inspection program, will all 16 feed through this lessons learned process that I'll be 17 covering shortly.
18 And, finally, training.
We had a meeting with 19 regional representatives just recently -- actually, we've 20 had two recently.
We've given the presentation which was 21 more like a training session to our DRS counterparts.
And 22 recently, we met with the working level, and we've given 23 them a present -- a whole day's worth of training on --
24 actually, it was a half a day's worth of training on license 25 renewal to get them prepared to get involved in the l
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implementation process.
2 We are also expecting to have a counterpart 1
3 meeting with the residents.
This is a clear opportunity for l
4 us to begin training the residents.
That decision hasn't --
5 isn't final, but right now, I'm preparing the training 6
session for the residents, as well.
7 In addition, one of the items that we decide 8
during our meetings with the regions on the implementation l
9 process was that PDLR will be prepared to begin training 1
10 inspectors November 1, and those schedules will be based on 11 region availability.
But we will have a training session in 12 place at that time.
13 Bob, I would like to add at this point that the 14 focus on the inspection program is primarily because we are I
15 looking at the end state, that is, where do we want to get 16 to in this process?
What kind of inspection verification is 17 appropriate for the Regions to be able to make a 18 recommendation to the Commission like they did in their 19 94300 procedure for the operating license?
20 And we are concentrating on what -- a vision of 21 what the safety evaluation basis would be to comply with 22 Part 54 and what the attendant inspection finding would look 23 like.
And so that's why we believe it's appropriate at this 24 time, even Lhough the staff doesn't have a draft safety 25 evaluation yet, but to envision that safety evaluation and ANN RILEY & ASSOCIATES, LTD.
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start planning around how will the inspectors verify the l
2 conclusions of the staff's safety evaluation so that our 3
plans for the future are better focused.
4 DR. PRATO:
The whole license renewal inspection 5
process is a little different than we have been doing 6
business routinely.
We are planning to develop an 7
inspection plan that would require a review of the 8
licensee's application, as well as the safety evaluations 9
that are produced from that.
And also any recommendations, 10 we are asking DE to provide us with recommendations on what 11 they would like verified.
12 Now, obviously, the inspection program is going to 13 be a sample program, and where those recommendations are 14 applicable, we will implement those recommendations.
: Also, 15 if there are any required verification that comes out of the 16 safety evaluation review process, we intend to implement 17 those as well.
18 DR. SEALE:
Just a couple of thoughts on the 19 comments you made.
It strikes me that recognizing that the 20 bottom line is the important issue in these inspection 21 programs and that there is very real value in coming to a 22 common template, if you will, recognizing that the bottom 23 line is the important product is the kind of resource 24 conservation that not only the Commission itself, with its 25 budget problems and so forth, but the industry should really l
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appreciate and -- because it will save significant 2
resources.
That's very important.
3 But the other thing that I I don't know how you 4
do it, but it seems to me that somewhere along --
5 particularly in these formative stages, you need to have my 6
colleagues at the university in the remote sensing area cal 7
ground truth.
Every once in a while you need to check and 8
make sure what you think you are looking is telling you what 9
you think it is telling you, because sometimes reality is 10 not -- the reality is not what you think you see, or what 11 you thought you saw.
12 And it strikes me that you would be very -- you 13 could make some very real use of the input of good 14 inspectors who know the plants, the two plants or the two l'5 groups of plants you are talking about, to tell you whether 16 or not you are blowing smoke.
Because they really know the 17 plant.
And you really -- those are the inspectors -- I know 18 they are going to be busy, but they could sure give you some 19 input that would keep you from running down false trails 20 early on, if you --
]
21 DR. PRATO:
Well, the Regionb and the people who l
22 were active in the maintenance rule implementation, and the 23 field inspectors are an integral part of our process.
We 24 are going to be talking on the next slide a lot about 25 resource conservation.
If we keep in mind the fact that the ANN RILEY & ASSOCIATES, LTD.
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maintenance rule is performance-based, license renewal is l
2 performance-based, the current 2515 program is basically 3
performance-based.
Most of our effort is focused on the 4
effectiveness'of their aging management program.
We can't 5
get into that aspect without reviewing the documentation and 6
the implementation aspect, and we are hoping to get that 7
done in the pre-approval phase.
8 DR. SEALE:
Okay.
9 DR. PRATO:
And that's, to us, where is the most 10 applicable place to do that?
Once we get that done, once we 11 verify that the programs have been implemented as we have 12 written our safety evaluations on, then we can get into the 13 primary objective, which is performance-based and whether or 14 not the aging management programs and the inspection 15 procedures are being effective in what the applicants say 16 that they will do.
17 MR. GRIMES:
Speaking --
18 DR. APOSTOLAKIS:
Sorry.
4 19 MR. GRIMES:
And I would like to add to that that I
I 20 Bob -- excuse me.
Bob mentioned before that we have already 21 started to get some useful feedback just in terms of trying 22 to design the inspection procedures and finding the common 23 ground between the current inspection practices and our 24 desire to formalize a feedback process that constantly 25 collects this knowledge and experience from the residents, l
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from ths Regions, from the review staff, from the utilities.
f I
2 Everybody has got good ideas.
The major hurdle that we face 3
is trying to assimilate, digest and act on those -- that 4
feedback.
5 And so when Bob describes the way that we intend 6
on managing that feedback process, I hope you will find that 7
we have established an environment that both stimulates and 8
makes use of that kind of, knowledge, that kind of ground 9
truth.
10 DR. APOSTOLAKIS:
You mentioned that the 11 inspection program is performance-based, and that cries for 12 the first two words, risk-informed.
13 DR. PRATO:
Okay.
14 DR. APOSTOLAKIS:
And the comma.
15 DR. PRATO:
I heard your comment before the 16 meeting and I thought about it, I had time to thing about 17 it.
18 DR. APOSTOLAKIS:
Let me complete my thought 19 first.
20 DR. PRATO:
Okay.
21 DR. APOSTOLAKIS:
The Commission -- the staff is 22 working on a regulatory guide and the appropriate SOP 23 chapter, corresponding SOP chapter on risk-informed 24 in-service inspection.
And that has a lot of good stuff, 25 and I was wondering whether that, the thoughts of the l
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approach that is described there, has had any impact on what 2
you are planning to do, or will have any impact on what you 3
are planning to do.
4 Because I mean I realize that'these guides are 5
optional.
But, on the other hand, we can't really go in two 6
separate paths and not be consistent.
7 MR. MIRAGLIA:
Dr. Apostolakis, may I try to j
l 8
address?
j l
9 DR. APOSTOLAKIS:
Sure.
{
i 10 MR. MIRAGLIA:
What you are saying is the extent 11 that risk-informed inspections, risk-informed licensing 12 processes become part of that facility's current licensing 13 basis, they become potentially an existing program within 14 that current licensing basis.
So to the extent that they 15 incorporate those things, that automatically -- it just 16 flows right over into the license renewal, in that kind of 17 context.
18 In addition, the staff is looking at the 19 inspection program, it is looking at its licensing process, 20 it is 1.ooking at its performance assessment processes to 21 make all of those risk-informed.
So I think, to the extent 22 that the staff moves in that direction, to the extent that 23 industiy and these specific licensees adopt those things and 24 make it part of their current life, for example, in-service 25 test and inspection, if that becomes an amendment, that l
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1-becomas partLof their licensing basis.
And if that is tl, 2
important to demonstrate some control of an aging mechanism, I
3
.therefore, that is a credit for, quote, "an existing l
'4
; program."
5-So I think-that is.the process'by which 6
risk-informed.is,two ways, in terms of implementation of the 7
' things that'we have offered and put out there that become 8
part-of the licensing basis for those facilities and then-9 risk-informed approaches, to the extent that the staff j
10 changes'its processes.in terms of licensing, inspection and 11'
: performance assessment, also get reflected.
So I see it as 12 a continuum.
13-DR. APOSTOLAKIS:
Well, that is why I asked you 14
: earlier a question.whether the rules of the game have been j
15 established.
Because I see this -- there are two 16
' conflicting, perhaps, processes or goals here.
One is we 17 are working on these regulatory guides, as you know, and ISI 18 Guide, I think is about to be completed.
The others have l
1 19 already been-forwarded to the Commission, as I understand l
I 120 it, and 1.174 has-been approved.
So there is a lot of
]
'21
. activity on that front.
22 At the same time we are doing this.
And, of 23' course, you don't do this in a week, so you have already 24 invested a lot'of time and so.on, especially the licensee.
25 I mean'if we decide now that the risk-informed processes I
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that are described in these new guides make eminent sense to 2
be used here, can we really do that?
Can we go back to the 3
applicant and say, well, gee, the volumes you submitted, 4
they are kind of incomplete, the rules of the game have i
5 changed?
Is that possible?
6 MR. MIRAGLIA:
No.
7 DR. APOSTOLAKIS:
On the other hand, wouldn't we 8
have a logical problem there, when we are coming out with a 9
guide that says it is correcting all sorts of problems from 10 the past and this is a great way of doing it, but we are 11 going to ignore it because of logistical reasons?
I don't 12 what the resolution of that is, but it seems to me there is 13 a slight problem there.
14 MR. GRIMES:
Dr. Apostolakis, if I may, I would 15
.like to -- I believe that baak in January I made a statement 16 that the license renewal review is' founded on a 17 deterministic basis and that our expectations are that we 18 will eventually be able to find a way to fit it in the pilot 19 activity stemming from the risk-informed decision-making 20 process.
And I want to reinforce that now in a way that 21 we are still struggling in order -- you characterized it as l
22 pilot applications.
We still have a lot of soft spots just 23 in the basic design evaluation process, but we see a vision l
24 in the future where there is a natural integration, for l
25 example, in scoping required for Part 54.
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What are the appropriate system, structures and 2
components that should be subject to an aging management 3
review?
The graded QA approach I think will naturally fit 4
into that at some point in the future and, certainly, 5
risk-informed ISI is going to have a profound effect on the 6
evaluation basis for aging management programs.
7 But at this peint we see that those activities are 8
being conducted both in parallel, and being supported by the 9
same staff.
Those staff that are working on the 10 risk-informed guide applications are the same staff that are 11 going to be reviewing the license renewal applications.
And 12 so we expect to get feedback from them on how to develop 13 what has been referred to in the past, and will be referred 14 to in the future as risk-informed license renewal.
15 But at this point we don't want to go back and 16 cause concerns about the stability of the review proces's by 17 telling BG&E and Oconee that we are going to have them do 18 something different.
As a matter of fact, when we get into 19 talk about the status, we are going to explain how we 20 acknowledge their difference but we will continue the 21 feedback process to improve it in the future.
22 So I am not -- I am not trying to say that -- what 23 I want to say is I see the conflict as opportunity.
I see 24 that there is a natural blending that will occur as the 25 standard review plans and as the experience identifies good ANN RILEY & ASSOCIATES, LTD.
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ways to integrate these two processes.
2 MR. MIRAGLIA:
I just would like to make the 3
following observations in terms of what we see.
I think, 4
Dr. Apostolakis, you made the comment that we are taking 5
different approaches.
I think if you go back to one of the
)
6 fundamental principles of Part 54 that the Commission 7
articulated when it promulgated the rule is that the current 8
licensing basis for the plants that are operating now is 9
--provides the basis for renewal except for those things 10 that raise unique issues in terms of function of important 11 equipment in the renewal period.
12 And so it is a process kind of thing.
To the 13 extent that the current licensing basis for the existing 14 facilities change for its operating life, and those 15 risk-informed approaches are made part of that licensing 1
16 basis, it should flow.
So in terms of process, I don't 17 think the processes are in conflict, I think they are 18 married.
19 Now, the question I think Chris was trying to say 20 is, to the extent that there's new things that have to be 21 considered, and there are risk-informed approaches to 22 address some of those issues, certainly, those kinds of 23 insights would be used for those kinds of things as well.
i 24 So I don't see it as a conflict, I think it's a continuum, 25 as I tried to express initially.
)
I 1
l
(
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DR. APOSTOLAKIS:
No, I apprecicto your commants.
2 And when I said conflict, I think it is a built-in conflict.
3
-In other words, 4
MR. MIRAGLIA:
It's complex.
5 DR. APOSTOLAKIS:
You are absolutely right that we l
6 have to have a stable process.
We can't change the process 7
all the time.
But at the same time, this new set of 8
regulatory guides is not just another thing.
I mean it is 9
. attempting to change the way we are approaching things.
For 10 example, the 1.174 guide that has been approved gives the 11 general guidelines for evaluating requests for changes in i
12.
the current licensing basis.
I mean if there is a big 13 request, it is this one.
You are extending the license by 14
'50 percent, right.
I 15 DR. PRATO:
Right.
Major license --
16 DR. APOSTOLAKIS:
So how can the question of what 17 happens to the core damage frequency and LERF and whether 18 they fall on Figure 3 or Figure 4 of that guide will come 19 up, even if we don't want it to come up.
20 So the question is now, how can it come up in a 21 way that will not surprise people?
And is there any way 22 that, in the process that you have, the milestones, for 23
. example, or maybe another title, but to have some allowance 24 there for some interaction so the applicant will know that, 25 and everybody will know that?
There may be this feedback or l
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interaction because -- I don't know whether one way of doing 2
it is to do it through a request for additional information, 3
but it seems to me that is not the best way to do it.
4 Now, let me give you an example.
Last week we 5
were writing the letter on the Monticello request for power 6
upgrade, and the question of 1.174 came up again.
Now, the 7
applicant there had managed to get some viewgraphs from here 8-and there, ACRS meetings, because they were at a 9
disadvantage, of course, the guide had not been published, 10 and they did some quick calculations to show that delta CDF 11 was within the limits.
But then we debated among ourselves 12 whether it was really -- I don't know whether the right word 13 is fair, but I think it applies here, to say that that is 14 the way they should have done it when they didn't have 3
15 access to the guide.
16 Now, are we going to find ourselves in the same 17 situation at the ACRS meeting scheduled for February 14th, 18 the year 2000, where we are going to be asked to evaluate 19 the staff's SSER and FES, and we will say, gee, it would 20 have been nice for them to have used 1.174 for?
And if that 21 will be the case, why don't we do something now?
Can we do 22 something now?
I don't know.
23 MR. MIRAGLIA:
That's -- what you are saying is 24 you are arranging -- 1.174 is guidance out there if l
25 licensees choose to take that approach.
It is a voluntary.
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What you are talking about, Dr. Apostolakis, is a broad 2
question of implementation of 1.174 as a new basis for 3
licensing.
That is a major policy kind of issue and that's 4
-- that, if you go back to the Part 54, the basic, 5
fundamental principles of the process to be used by license 6
renewal, the Commission spoke to those, although it was 7
several years ago, and most notably, it was a different 8
Commission.
And they talked to -- it's a process rule in 9
terms of current licensing basis.
10 It is not our intent to impose that requirement in 11 terms of the license renewal process.
That is not 12 consistent with where the staff -- we think the fundamental 13 principles of the rule are in the process to date.
To the 14 extent that those guides are used and implemented by i
15 licensees, in conformance with the guidance, for those 16 issues that they feel that they need to make those changes 17 to their licensing basis, and they are incorporated into the 18 licensing basis, they would flow with the license renewal 19 decision.
20 DR. APOSTOLAKIS:
I am not really --
21 MR. MIRAGLIA:
I am talking process.
22 DR. APOSTOLAKIS:
I understaed what you are 23 saying.
24 MR. MIRAGLIA:
I understand the issue you raise.
25 DR. APOSTOLAKIS:
I am not proposing to make 1.174 l
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41 '
1 the basis for decision-making.
You are absolutely right, 2
it's optional, or in this case, the word optional really has 3
to be stretched, the meaning of the word.
4 I mean it is optional, but that does not mean, I 5
think, again, de facto, real life, that if the licensee I
'6 chooses not to use it, the questions will not come up.
I 7
can't imagine that the NRC staff will approve a license I
8 renewal application without ever asking the question, what 9
happened to the core damage frequency?
10 So what I am saying is maybe we ought to think 11 about bringing that kind of thinking into this process, 12 without changing it fundamentally, because I fully 13 appreciate that this cannot be done for many reasons.
But 14 the question will be asked, and it will not be me, okay.
15 there will be other people who will be curious, what 16 happened to the CDF?
I mean --
17 DR. SEALE:
Well, George, I think we have to all 18 recognize that, in essence, what we said with that letter, 19 and we shouldn't waste these people's time talking about 20 that letter, except that it is quite relevant in this case.
21 What happened with that letter is that we said --
22 DR. APOSTOLAKIS:
The Monticello letter?
23 DR. SEALE:
Yeah.
That, hey, the process is a lot 24 more convenient, a lot more straightforward, a lot less a 25 matter of faith if we have the kind of evaluation that was l
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made.
And now it is not an 1.174 evaluation, it was the l,
2 kind of evaluation of risk difference that they had in that 3
particular submittal.
And that kind of letter from the 4
ACRS, I think has impact.
I think a lot of licensees are j
5 going to see that, hey, that is not a bad way to make the 6
: argument, l
l 7
DR. APOSTOLAKIS:
But what I am saying is I don't 8
want to find ourselves in a situation in the year 2000 q
9 saying again the same thing.
And I do appreciate -- don't 10 think that I want to change everything -- but I do -- but I 11 mean --
12 (Laughter.)
13 DR. APOSTOLAKIS:
I realize there are limitations.
14 MR. MIRAGLIA:
Glad you finally --
15 DR. APOSTOLAKIS:
I fully appreciate what you said 16 about stability and so on.
But it seems to me that it would I
17 make everybody much happier if somewhere along the line you 18 show them the milestones that this whole activity on the 19 other side will be brought into this process as appropriate, i
20 in some way, without imposing it.
Because, de facto, it l
i 21 will happen.
I just don't see how -- I mean what are we l
22 going to talk about?
Changing periodic inspection by three 23 hours and go to 1.174.
This is that big.
If you don't I
i l
24 apply it here, I don't ktow why we developed it.
Now, it is 25 optional, I realize that, it is optional.
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MR. MIRAGLIA:
I think, in terms of process, and j
2 how you impose it into process is very important.
I think 3
the Commission, in establishing the fundamental principles, 4
renewal in Part 54, did not consider that in the context of 5
the process.
I understand your question and --
6 DR. APOSTOLAKIS:
When was this approved, by the 7
way?
Part 54.
8 MR. MIRAGLIA:
Part 54, there was two approvals I 9
think the first year.
10 DR. PRATO:
Ninety-one.
11 MR. MIRAGLIA:
Ninety-one was the first Part 54.
12 DR. PRATO:
And then May 8th of
'95.
13 MR. MIRAGLIA:
And then it was revised in '95.
14 DR. APOSTOLAKIS:
That's the reason.
But 15 everything that I am talking about happened after that time.
16 MR. MIRAGLIA:
The thought processes that you are 17 talking about, and the implications of implementing that 18 kind of change in the processes we are talking about, have 19 to be fully understand and evaluated.
20 DR. APOSTOLAKIS:
And I fully appreciate that.
21 MR. MIRAGLIA:
And I think they were looked at in 22 the past time.
If the Committee is of a view that they need 23 to be re-examined in this time, that's a choice the 24 Committee can make through the Commission.
25 MR. GRIMES:
I would like to add to that, we have i
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44 l
1 asked the question of ourselves, and we have been talking 2
about the plant-specific IPE and IPEEE results, and we have 3
been struggling with the extent to which some of the basic 4
questions about the quality of PRA --
l 5
DR. APOSTOLAKIS:
Yes.
6 MR. GRIMES:
come into play in terms of how 7
well a PRA can be used to look at aging management or life 8
extension questions.
And so at this point, as Frank points 9
out, because of the concern about the stability and ensuring l
10 that the milestones have clearly defined and established
{
11 objectives, we know the question is on the table, we have an i
12 interest in it, and as the opportunity presents itself to 13 raise the policy issues associate with that, I am sure l
14 Frank, in his role as Steering Committee, and also the i
15 Executive Council, they understand that we know that that
)
16 question is on the table, and now it is up to us to figure 17 out what the right -- where the right place is to pursue l
18 that answer.
I 19 DR. APOSTOLAKIS:
What is the current CDF for 20 Calvert Cliffs?
21 DR. PRATO:
I don't know the answer to that, but I 22 know it is relative high for Calvert Cliffs.
And the reason 23
-- the reason I understand it is that way is because they 24 have got a very intricate IPE that goes beyond what the 25 typical standard is.
I have heard a lot of this information l
l l
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through the maintenance rule implementation program.
Okay.
2 They also have a living database, if I understand correctly.
3 And if I understand, because now we are looking at three 4
levels.
Do they have an IPE that is accurate?
Do they have 5
a living one that they can implement changes adequately?
6 And are they doing those changes?
And apparently, BG&E has 7
a very good process and they are very conservative in the 8
numbers that they use.
So --
9 DR. APOSTOLAKIS:
Met, can we get a copy of the 10 IPE and have it here?
11 DR. EL-ZEFTAWY:
For Calvert Cliffs?
12 MR. MIRAGLIA:
Yeah, we can provide that to the 13 Committee.
From a point of view of process, the requirement 14 for the IPE, there was a Generic Letter that said there was
(
15 a requirement, or a request for a probabilistic analysis to 16 be submitted.
So that is available for both facilities.
17 Now, how updated the one we have is, you know, of course, 18 the licensees do make changes in their facilities, but that 19 can certainly be provided.
20 The licensees also were to submit a response to 21 that request also.
An IPEEE with respect to external 22 events, so that could be shared with the Committee.
23 DR. APOSTOLAKIS:
You say the CDF is pretty high.
l h
24 Is it above the goal of 10 to the minus 4?
25 MR. MIRAGLIA:
My understanding is it is, Dr.
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'Apostolakis.
It is some number times 10 to the minus 4 and 2-that number is not 1, and I don't want to speculate what it 3
is, but that is my recollection as well.
4 DR. APOSTOLAKIS:
It seems to me that 1.174 will 5
be used here, no matter what we call it, because it says 1
6 explicitly that if the current CDF is above 10 to the minus 7
4, you can do very things to the plant.
So --
8 DR. SEALE:
To raise it.
i 9
DR. APOSTOLAKIS:
To raise it, yeah.
So what we l
l 10 are doing here, I mean I don't know, I mean somebody will l
l 11 bring it up.
You are in that region now where there is 12 increased management attention, according to 1.174.
i 13 MR. MIRAGLIA:
To make changes to that license.
14 DR. APOSTOLAKIS:
That's right.
I 15 MR. MIRAGLIA:
It's the premise in the process 16 rule and the premise in the fundamental principle for -- is 17 that that current licensing basis established the 18 Commission's determination of reasonable assurance of 19 adequate protection and it, therefore, as long as it is not 20 being increased, it can continue.
And so I think that's --
21 that's where we are in terms of --
22 DR. MILLER:
The renewal process is not meant to i
l 23 change the current licensing basis.
24 MR. MIRAGLIA:
That's correct.
25 DR. MILLER:
But if there tre changes, then l
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risk-inform:d methods --
2 MR. MIRAGLIA:
Then those --
l 3
DR. MILLER:
-- might be used to analyze those 4
changes.
j 5
MR. MIRAGLIA:
Yes, sir.
6 DR. APOSTOLAKIS:
How do you know unless you look?
l 7
DR. MILLER:
What's that?
8 DR. APOSTOLAKIS:
How do you know unless you look?
9 That there is no delta CDF that is positive.
That's the 10 point.
11 DR. MILLER:
No, what I am really saying is the 12 licensing -- the relicensing process is not meant to change 13 the current licensing --
14 DR. APOSTOLAKIS:
I understand that.
But how do 15 you know that you have accomplished that?
I mean you have 16 to look at the requests and somehow make that determination.
17 DR. MILLER:
I think that's part of the process, 18 you are going to make that determination.
19 MR. MIRAGLIA:
The current licensing basis is 20 being maintained.
21 DR. APOSTOLAKIS:
I think we have to close this 22 discussion because it goes on forever.
But all I am saying 23-is there ought to be some allowance somewhere in their 24 schedule for bringing into the process these other ideas, or i
l 25 a w:y or considering them.
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DR. MILLER:
It seems to m3 you can --
2 DR. APOSTOLAKIS:
You don't necessarily have to 3
-bring them in.
But the question will --
4 DR. MILLER:
No, George, it will come in 5
naturally, I think.
6 DR. APOSTOLAKIS:
That's what I am saying.
7 DR. MILLER:
Chris explained that earlier.
He 8
said if they are going to make changes in the plant, you 9
might want to use risk-informed methods to evaluate those 10 changes, and that will flow in that.
11 DR. APOSTOLAKIS:
You mean this is not a change in 12 the plant?
13 DR. MILLER:
No.
That's the whole intent.
It is 14 not meant to change the plant.
15 MR. MIRAGLIA:
The intent is to demonstrate that 16 this is the plant, the current licensing basis is 17 articulated, and they have processes in place tc.aake sure 18 that that current licensing basis is being maintained.
19 Fundamental principles of the Part 54.
20 They are not proposing to amend or modify the 21 facility.
What this is is a demonstration, is that we had 22
-- we were licensed under this basis and we demonstrated and j
23 we have processes and principles in place to demonstrate we 24 could operate this plant for 40 years.
We want to extend 25 for 20, and we are demonstrating that the adequacy of those l
(
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procedures and processes would maintain that same licensing 2
basis for --
3 DR. MILLER:
For another 20 years.
4 MR. MIRAGLIA:
-- an additional period of renewal, 5
up to 20 years.
So that's -- it's a process rule.
6 DR. MILLER:
It seems to me an ideal license 7
renewal, if everything is perfect, you would never use 8
risk-informed methods, you don't need to.
9 CHAIRMAN FONTANA:
Of course, one of the question 10 is --
11 DR. MILLER:
If it is not perfect --
12 CHAIRMAN FONTANA:
One of the questions is, as 13 things age, --
14 DR. MILLER:
Right.
15 CHAIRMAN FONTANA:
-- what is the effect?
16 DR. MILLER:
That's right.
17 CHAIRMAN FONTANA:
Yes.
18 DR. MILLER:
So if the aging management indicates 19 there is going to be a degradation in the licensing basis, 20 then maybe risk-informed methods would be very valuable.
21 DR. APOSTOLAKIS:
Well, so what you are saying is 22 that if I were to apply 1.174, I would find that delta CDF 23 is zero.
24 DR. MILLER:
Ideally.
25 MR. MIRAGLIA:
Ideally.
i l
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1 DR. APOSTOLAKIS:
So maybe --
2 MR. MIRAGLIA:
And the programs and the monitoring 3
programs are such that they either are controlling it and 4
can adequate demonstrate that it is good for 20 years, or 5
that they have enough controls to understand and identify 6
the degradation before it gets to the point where it is 7
going to impact.
8 DR. MILLER:
1.174 only applies to a delta, only a 9
change, right?
10 DR. APOSTOLAKIS:
Twenty years extension, it seems l
11 to me it is a hugh capital Greek Delta.
12 DR. MILLER:
The ideal thing is they are trying to 13 demonstrate it is not a delta.
14 DR. APOSTOLAKIS:
Well, anyway, let me repeat my i
15 point.
I think these questions will come up naturally and 16 there has to be a way of anticipating them.
Okay.
That's 17 all I am saying.
18 DR. SEALE:
At the risk of diluting or i
I 19 sidetracking a little bit longer, I think the real point, 20 though, is that if you really do look at something like the 21 use of the maintenance rule and the implications of the kind 22 of focused in-service inspection and so forth that is 23 involved in that, putting your resources where they count, 24 in the inspection process and so forth, that using a 1.174 25 process, if you have done that job right, you are going to 1
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have a decrease in CDF because now you are putting things 2
where they count most.
So it won't be quite the same plant 3
as you initiated, or you got the license for in the first 4
place using the old prescriptive rules on in-serve 5
inspection and so forth.
6 So if you do the whole job, you are going to have 7
to a 1.174 evaluation', or you will have done it, in effect, 8
when you put your maintenance rule implementation in effect.
9 And that is subsequent to the IPE or the IPEEE.
10 CHAIRMAN FONTANA:
So the question is, it is going 11 to happen, it is going to happen naturally, the question is 12 how much allowance ought to be in the schedule that we see 13 now to cover --
14 DR. APOSTOLAKIS:
To formalize.
I 15 CHAIRMAN FONTANA:
-- or will it happen after the 16 schedule that we are looking at.
17 DR. PRATO:
That's right, 1
18 CHAIRMAN FONTANA:
Proceed.
19 MR. GRIMES:
We currently don't have any 20 provisions to address delta CDF in the review and so there 21 is no attendant milestone associated with it, but we clearly 22 understand the question.
23 DR. SEALE:
It's embedded in there.
24 MR. GRIMES:
Yeah.
25' CHAIRMAN FONTANA:
Thanks.
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DR. PRATO:
Just let m3 add one more point from 2
the inspection program aspect.
Because risk-informed is a 3
big question that we deal with on a daily basis, we 1
4 considered that when we developed the inspection program.
5 And I am not sure if it is in the menu chapter or the IP, 6
but because the inspection program is a sampling program, 7
one of the criteria that need to be considered when you are 8
developing that sample is safety significance.
So from the 9
inspection process, we try to keep that -- be mindful of the 10 fact that risk-informed is a big part of our daily routine 11 here and we are trying to make sure it is being addressed 12 from the inspection process perspective.
13 This slide we just put up, this is the same exact 14 slide we showed you last time for the implementation.
We 15 talked about the different areas that we feel that need to 16 be inspected from the license renewal pre-approval and 17 post-approval inspection activities.
If there's one area 18 that I believe we have made significant progress in it's in 19 the implementation of the inspection program.
20 With respect to the progress that has been made in l
21 the inspection program, a letter went out from Sam Collins 22 to the Regional Administrators telling them it is time to I
23 get involved.
We have had a meeting with the Regions 24 earlier this month.
The Regions are on board, they have 25 been trained to some extent, as much as you can train l
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53 1
somebody in this rule without some practical experience in 2
applying it.
Okay.
3 And we have set some initial activities.
We 4
presented them with an information binder.
That information 5
binder has all the guidance documents.
It includes the 6
rule, the SOC, the previous rule, Reg. Guide 1047, which is 7
the Implementation Guide, NEI 9510, which is the industry's 8
Implementation Guide.
This SRP, all we provided them was 9
with an outline of the SRP, there's no reason for the i
10 inspector -- the Regions to get involved in the safety 11 review process other than to know what is being reviewed, 12 okay, and how we are going to apply that in the inspection 13 process.
14 We gave them copies of the office letter.
We also 15 gave them copies of Part 51, they needed to be aware of.Part 16 51.
There's almost no inspection activities on the Region's 17 part with Part 51, that is all being handled by consultants 18 here out of general office.
We also gave them final copies l
19 of the manual chapter and the inspection procedure itself.
20
.Again, the manual chapter and the inspection procedures are 21 large steps in the progress we have made over the last 22 couple of months since our last presentation to you.
23 They went back with the objective of reviewing and 24 getting themselves familiar with a lot of this information 25 beyond what we spoke to them about.
Our presentation was ANN RILEY & ASSOCIATES, LTD.
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54 1
l 1
mostly focused on what is important to help thsm, to help 2
guide,them and to help them focus their time more i
i 3
efficiently.
4 As a result of that, one of their primary i
i 5
objectives is to -- for them to define what they feel the 6
scope of the inspection process is supposed to be for f
1 7
license renewal, for the pre-application period.
Then I
8 they're also to overlay 2515 on these inspection objectives,
)
9 okay, what is required.
10' We are expecting to gain a lot of benefits with 11 respect to efficient use of resources.
We are very 12 confident that a lot of our activities are going to be 13 covered by the core program and most of the remaining stuff 14 are typical activities that we do on the regional i
15 initiatives, and we expect a minimum amount of activities 16 required for the pre-inspection activities to be beyond what 17 the Regions normally do.
i 18 Now, I say that with tongue in cheek, because 19 there's going to have to be a focus effort.
One of the 20 questions we are asking ourselves, do we implement the 21 license renewal inspection program and take credit for it 22 under the core program or do we implement the core program 23 and take credit for it under the license renewal inspection 1
24 program?
25 CHAIRMAN FONTANA:
Well, it raises a question of i
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are you going to use the same people, the same number of 2
people, or are you going to have to add some people to do 3
this?
4 DR. PRATO:
If a lot of the core program and a lot 5
of the regional initiatives can be applied, it would be a 6
lot of the same people doing what they would normally do as 7
part of their routine annual inspection activities.
To me, 8
it's just a change in focus.
And I believe that we should 9
do a license renewal inspection and apply it to the core 10 program.
That may change.
I mean that's what my hope is.
11 Because it is a lot easier because license renewal is such a 12 significant licensing action, it would be a lot easier for 13 us to focus the inspection reports on license renewal and 14 allow them to take credit for it in the core program area.
j ii 15 CHAIRMAN FONTANA:
But you are going to find out?
16 DR. PRATO:
Excuse me, sir?
17 CHAIRMAN FONTANA:
You are going to find out?
18 DR. PRATO:
Oh, yes.
That's what really this 19 activity is right here, this overlay.
We are going to be l
l 20 able to identify the delta on what additional resources are 21 needed.
Okay.
We are also going to take credit for this 22 year's core program and maybe even next year's, and there 23 may be justification for taking it back three years.
We are 24 going to review on what -- as to what we have looked at and 25 try to assess how big a sample we need based on that.
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i 56 l
1 what we plan to look at next year and the year after.
2 So we are really looking at a three-dimensional 3
effort here.
We expect to be able to document and justify i
4 what we have inspected and the basis for our reasonable 5
assurance that we verified is adequate for either approval t
6 or disapproval, depending on how it turns out.
7 The culmination of these activities will result in 8
developing an inspection plan.
The way we typically have I
9 done things in the past, including in the maintenance l
10 program, is we would either write a mannal chapter, but for 11 the maintenance program 2515 applied.
We have an inspection 12 procedure and we implement that inspection procedure in one 13 specific inspection.
Okay.
14 We are doing it a little different than license f
15 renewal.
I don't know if I can pull this out.
We have INC 16 2516 we have IP 71002.
This is the basic license renewal 17 inspection procedure.
And instead of going into a single 18 inspection activity like they normally do, we are going to 19 break off into several inspection activities.
Okay.
Some 20 of them are going to be during refueling outages.
Okay.
21 Others of them are going to be during normal plant 22 operation.
Okay.
23 What we are doing to tie all of this together, 1
24 because inspections are usually very well documented and i
l 25 very specific on activities that need to be done, is we are l
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inserting an inspection plan here.
Okay.
That inspection l,
2 plan will define the scope, will define the number of 3
inspections, okay, at least the initial number of 4
inspections planned.
It may result in addition, but right 5
now identify the scope, the number of inspections.
The 6
scope of each inspection, okay.
And the resources that will i
7 be required.
Okay.
And then that will allow us to -- and j
we expect these inspections to be implemented anywhere from 8
9 12 to 16, 18 months -- month period.
So we will get four 10 separate inspection procedures that, hopefully, will address 11 everything under IP 71002, 12 CHAIRMAN FONTANA:
Now, you'll have -- this says 13 there's going to be an SER on November '99.
14 DR. PRATO:
That's correct.
'i 15 CHAIRMAN FONTANA:
These procedures would be in 16 place by then.
Would there actually be actual inspections i
17 done in this two-year period?
Or are you just --
l 18 DR. PRATO:
I can talk about schedule.
Right now 19 with the manual chapter in place, with the IP in place, they 20 are done, along with those two procedures, we expect aging l
21 management program inspection procedures to be developed.
l l
22 We are in the process of doing that.
Our goal is to try to 23 get these done by the end of the year.
We are looking at 24 about eight or nine of them, okay, for the major aging 25 management programs that the industry seems to be taking l
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58 1
credit for.
Okay.
2 We expect to have the IP for Oconee and Calvert 3
Cliffs done by January 1.
We were hoping to start 4
inspections in March and April time frame.
On Calvert, the 5
Region says no, let's do it sooner, let's get going as soon 6
as we can.
So we have given ourselves a target date that we 7
can begin implementation of the inspection process January 8
1, that's our target date.
9 CHAIRMAN FONTANA:
This actually involves going 10 out there and climbing over hardware and things like that?
11 DR. PRATO:
Yes, sir.
It includes the 12 administrative review, the implementation review and the 13 aging management review.
14 CHAIRMAN FONTANA:
Thank you.
'i 15 DR. PRATO:
As far as the renewed licensing 16 inspection, we mentioned that we intend to make it part of 17 the core program.
But when you talk about the post-renewed 18 licensing inspection, three things come to mind, is what we 19 have to do to the core program, what we will have to do
)
20 under regional initiatives and resources.
21 And we are in the process or working that out.
A 22 large part of what we find out for the pre-inspection 23 activities will directly relate to the post-approval phase.
l 24 And we are relatively confident, especially with the 25 activities that are going on with the maintenance rule ANN RILEY & ASSOCIATES, LTD.
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pnople who cro doing bnsically c revamp of the inspection f
2 procedures for maintenance programs.
We are confident that 3
we are going to be ready for the post-approval period 4
without any problems.
5 DR. UHRIG:
What do you mean by regional 6
initiatives?
7 DR. PRATO:
What they do right now is, basically, 8
they set up a plan for inspections for each applicant on a 9
yearly basis.
10 DR. UHRIG:
Isn't that part of the core program?
11 DR. PRATO:
It's --
12 DR. UHRIG:
Incorporates the --
13 DR. PRATO:
It is and it isn't.
The core program 14 are minimum requirements that they have to do and they have 15 absolutely no choice to get it done.
There are some 16 regional. initiatives that they go out and look at things.
17 For instance, if there is an erosion, corrosion break at 18-Oconee, Region 4, it may raise the rest of the Regions' 19 sensitivity to erosion, corrosion and they add inspections 20 on erosion, corrosicn.
That's what is meant by regional 21 initiatives.
Okay.
It lets them focus on areas that are 22 not tied to the SALP, which really is the --
23 DR. UHRIG:
They are really unique to that 24 particular plant, in other words.
25 DR. PRATO:
Right.
Well, it may be unique to the l
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60 1
plant.
It may be a generic concern, like erosion, 2
corrosion.
It may be unique to the NSSS' vendor.
It could j
3 be a BWR issue, the core shroud cracking issue, that type of 4-thing.
Those are what is covered under the regional 5
initiatives.
6 Chris.
7 MR. GRIMES:
If I might, there's -- the term core 8
program and regional initiatives really stem from the way 9
that the program office establishes the budget for the 10 Regions.
And the systematic assessment of licensee 11 performance also comes into play in terms of there are 12 resources that are set aside to make sure that there is a 13 minimum amount of inspections that occur at every plant.
14 But then beyond that, the Regional Administrator has the 15 discretion to take these regional initiative resources and 16 allocate them on a plant basis or between plants.
17 And you see the end result if you look at the l
18 Director's monthly report and see the number of hours that 19 are spent at each site in a given period of time.
And the 20 problem that we face is that license renewal will likely --
21 is not likely going to apply to plants that are problem 22 plants.
23 So the Region is probably going to have their i
24 resources on the problem plants and we need resources to 25 work license renewal, so there are resource-competing l
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effects.
And that's why Bob emphasized that the Regions are 2
overlaying this 2515 program in order to see where they are 3
certain they are going to have time that could be modified l
4 to suit both their needs and the license renewal finding.
5 And then where have they got discretion with their resources 6
that they could use and where do we need to contribute more 1
7 resources in order to support the. renewal finding?
8 DR. SEALE:
At the same time, there is some murmur 9
out there that says that if you have a non-problem plant 10 that has a good SALP rating and all of these other things, 11 it doesn't necessarily require the same level of attention 12 as a problem plant does.
13 And it seems that an inspector who knows something 14 about the reality of that plant can probably be more helpful 15 in doing some of the things associated with renewal, says 16 that maybe you aren't as -- let's say, not dollar-wise 17 resource, but now bodies with the brains that are in their 18 heads resources, limited as you would be otherwise.
l 19 I mean you've got people who know the plant.
It's 1
20 a good plant, and here is something that they can do that's I
21 constructive to supporting the program as it moves along.
22 So it's not all bad.
23 MR. GRIMES:
No, it -- and that was the point in 24 terms of taking advantage of the core program, recognizing 25 the talent that is being applied, even to the very good --
I 1
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DR. SEALE:
Yeah.
2 MR. GRIMES:
-- performers, although it's less 3
than the level of attention and resources that are applied 4
to other plants, it's still a very useful resource.
5 DR. SEALE:
Yeah.
6 MR. GRIMES:
That we don't -- we don't want to 7
hamper the value that that resource plays in maintaining the 8
confidence level in the current operation.
9 And that's part of the debate that continues in 4
I
(
10 terms of the senior management process and the allocation of i
l 11 resources in terms of what value is added by being a I
12 regulated entity, and I don't want to go there.
13 DR. UHRIG:
You made a remark -- you made a remark 14 a minute ago about not expecting the problem plants -- I
(
15 believe the same ones that were -- had license renewal.
16 Is that what you really meant to say?
17 MR. GRIMES:
Yes.
That's what I really meant to 18
: say, i
l 19 DR. UHRIG:
And you don't expect a plant on the 20 problem list, what you want to call it, the watch list, to 21 be applying for renewal?
22 MR. GRIMES:
Not while they're on the watch list.
23 It's my expectation that a utility will not want 24 to expose itself to litigation while they're on the watch 25 list, but that's my personal opinion.
That does not mean ANN RILEY & ASSOCIATES, LTD.
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that th'ny would not ba interested in license renewal, it f
2 would meant -- it would affect the timing.
3 DR. UHRIG: 'The timing issue, not --
'4 MR. GRIMES:
Right.
5 DR. UHRIG:
Not a work list?
6 MR. GRIMES:
Right.
They would -- a licensee is, I
7
'you know, as concerne'd about allocating resources, as I just 8
explained, the regions are.
They're not going to want to 1
9 spread themselves so thin that they're fighting being on the l
l t
I 10 watch list at the same time that they're trying to devote 11 resources, 12 And these are not insignificant resources, j
13 although I will say, I've been pleased to see that the cost 14' estimates for license renewal have come down from a value of 15 200 million that was quoted just a little over a year ago, 16 and now we're seeing numbers in the range of ten to --
17 through $30 million to complete a license renewal 18 application.
And we'll be pleased to see if that estimate 19 comes down a little bit further, although I don't want it to l
20 go below the cost of an IPE.
l 21
[ Laughter.)
22 MR. PRATO:
Okay.
Again, in summary, a lot of the 23 implementation documentation is in place.
Training is 24 ongoing, and our next major milestone is the inspection 25' plans, and we expect to have those done by the beginning of ANN RILEY & ASSOCIATES, LTD.
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64 l
1
'the year '99..
2 That completes the inspection program 3
presentation.
If you'd like, I'll go on straight to 805.
4 That's up to you.
We can take a short break if you want.
5 It's --
6 CHAIRMAN FONTANA:
Is this a good time to take a 7
break?
8 DR. APOSTOLAKIS:
Yes.
9 CHAIRMAN FONTANA:
It's scheduled for ten, so --
10 MR. PRATO:
Does anybody have any more questions 11 on the inspection program?
12' CHAIRMAN FONTANA:
Pardon?
13 MR. PRATO:
On the inspection --
14 DR. APOSTOLAKIS:
Any more questions that they
[ (
15 want to ask at this time?
16 MR. PRATO:
Yes, sir.
I'm sorry, i
17 CHAIRMAN FONTANA:
I guess -- let's take a break 18 until 10:15?
19 MR. PRATO:
Yes, sir.
20
[ Recess.)
21 CHAIRMAN FONTANA:
The meeting will reconvene and 22 pick up wherever you want to.
23
[ Discussion off the record.)
24 MR. PRATO:
Just one other point.
This team of 25 regional people and PDLR staff, their final objective will I
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l 65 1
be to revise the manual chapter in the IP, which hopefully, i,
2 will glean all the lessons learned after the first couple of 3
inspections and be able to develop a procedure that can be 4
used generically and be as effeccive as we hope the overall 5
process will be.
)
t 6
The next portion of my presentation is on NRC 7
office letter -- NRR office letter 805.
And if you'll 8
remember from my last presentation in January, the office 9
letter is really broken down into four separate sections.
10 You have the office letter itself, which provides the 11 guidance and the controls and the basic outline for the 12 review -- technical review process.
It defines the roles 13 and the responsibilities under branch level and above, okay.
14 And within that office letter, there are four 15 separate guides, four separate attachments, okay.
I'm 16 sorry.
Three separate attachments, okay.
17 The first attachment is the guide for reviewing 18 license renewal applications.
Okay.
That guide provides 19 the guidance on the staff level.
It defines the roles and 20 responsibilities of the different organizations, and it 21 provides the staff with the basic process of developing a 22 safety evaluation.
23 The second guide, the guide for processing renewed i
24 licensing action items, this is sort of a unique guide.
The I
25 intent is to -- the overall intent for the license renewal ANN RILEY & ASSOCIATES, LTD.
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process is to make it modular, okay, if you will.
Not to 2
have a lot of renewal activities bleed in -- over into the 3
operating reactor space, and not forcing operator reactors 4
to have to backtrack through the license renewal process.
5 Once the application is approved, we want 2515 and
)
6 routine reactor operations programs to be able to handle the 7
-- the approved licenses as they would for the 40-year 8
license -- the 60-year license as they would for the 40-year 9
license.
10 I think this guide accomplishes that, and I'll get 11 into details on that in just a moment.
13 DR. UHRIG:
In other words, what you're saying is 13 that there is no additional requirements likely to be 14 imposed as a condition for extending the license?
15 MR. PRATO:
No, not at all.
What we're saying is 16 that the process that's being used for regulating and 17 monitoring and control and operating reactors for 40 years 18 would be the same process for 60 years.
19 It doesn't mean that there won't be additional 20 actions.
For instance, if there are license conditions, we 21 have to verify that the license conditions are implemented 22 correctly.
23 DR. UHRIG:
When would those be effective?
At the l
24 end of 40 years?
25 MR. PRATO:
The license conditions?
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DR. UHRIG:
Would it be -- that is, if you 2
approved Calvert Cliffs or Oconee right now, two years from 3
now, two and a half years from now, you approved it, would 4
they become effective immediately if there were license 5
conditions, or would they be implemented at the end of.the 6
40 years?
7 MR. PRATO:
Well, the license conditions, okay, 8
would become effective at the time of signing the license, 9
but the target dates may be down the road somewhat.
10 For instance, if EQ is an issue, okay, and they --
11 the licensee's promise to do some actions prior to the end 12 of the 40-year cycle, the due date may be in the year 38, 13 for instance, okay?
14 As long as these requirements are documented that 15 the licensee has to meet these commitments, okay, as long as 16 they're documented and they have target dates, the license 17 condition -- we just have to verify that the license j
l 18 conditions are met at the time they're supposed to, based on l
19 what's documented in the license.
l 20 DR. UHRIG:
So it's no different than any other I
21 commitment?
22 MR. PRATO:
No, sir.
No, sir.
23 Finally, the guide for the technical and process 24 list for license renewal, I'll get into this in a lot more 25 detail.
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This affects all the activities oriented around 2
license renewal.
The intent is to have a formalized 3
documented process that tracks not only the issues that are 4
identified to completion, but through implementation and 5
verification, that the implementation is complete and 6
accurate.
7 DR. SEALE:
You reminded me of something, Mr.
1 8
Grimes.
I think at this last full Committee meeting, we 9
agreed to send you folks a Larkins gram regarding the review 10 of the environment-reports.
I think it was -- it had to 11 do with license renewal, and indicated we didn't want to 12 talk about things much right now.
13 But I was wondering, toward the end of the day, if 14 you could give us a thumbnail capsule of any changes that 15 you might be able to highlight for us on that process so 16 that we can sort of do a double check, do some ground truth, 17 if you will, on our decision not to look at that in detail.
18 MR. GRIMES:
When I go over the schedules, I'll 19 talk about where the --
20 DR. SEALE:
Fine.
21 MR. GRIMES:
-- the environmental review --
j l
22 DR. SEALE:
Okay.
]
23 MR. GRIMES:
-- milestones are.
24 DR. SEALE:
Okay.
Fine.
Thank you.
25 MR. PRATO:
Okay.
And the next slide, this next ANN RILEY & ASSOCIATES, LTD.
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slids, it's a slido under the first attachment to letter 2
805.
It basically shows the process for reviewing an 3
application.
It identifies the submittal and the acceptance I
i 4
review.
5 It talks about the work planning process.
Work 6
planning process is really the heart of an effective review, 7
okay.
And a lot of activities in that area, not only to 8
plan the work, but to improve the planning process and to 9
improve the overall safety evaluation review.
10 It talks about the review, the request for 11 additional information, the response for request for 12 additional information.
13 It identifies the public hearing process.
I 14 believe that that's either just been resolved or is still in
(
15 final resolution.
I'm not active in that area, but Mr.
16 Grimes, I'm sure, will address that specifically.
17 And it talks about developing the final safety 18 evaluation, the ACIS review and reporting activities, and 19 the granting or the rejecting of a renewed license.
20 DR. UHRIG:
What are the arrows going to the left?
21 MR. PRATO:
The IP is the issue points.
That 22 falls under the feedback process, okay.
These are the areas 23 where we expect to identify feedback and --
24 DR. UHRIG:
From whom?
Feedback from?
25 MR. PRATO:
From everybody.
From the public, from l.
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our technical reviewers, from the industry.
2 i,
We're very active with the industry right now, and 3
I'll get in -- a little bit more into that in a few minutes
)
4
-- from ACRS.
Basically everybody that has any input to the 5
process.
6 CHAIRMAN FONTANA:
Do you have the issue points?
7 Are you going to get into how you -- how you're 8
going to reach closure on these --
9 MR. PRATO:
Yes, sir.
10 CHAIRMAN FONTANA:
-- points?
11 MR. PRATO:
Yes, sir.
12 CHAIRMAN FONTANA:
Okay.
13 MR. PRATO:
Yes, sir.
14 One of the major issues that we're facing today is i
15 level of detail, not only in the application, but in the 16 FSAR supplement, okay.
17 The other question that comes to mind is that this 18 is su~ch a significant licensing action, okay.
We absolutely 19.
need a means to verify that the questions and answers were 20 complete and adequate.
So what -- and on top of that, we're 21 trying to develop a process that, again, is modularized, 22 that the operating reactor people don't have to -- five or 23 ten years after the license is approved, when they're 24 checking on a license condition, they really don't have to 25 backtrack to the license application review process.
And so ANN RILEY & ASSOCIATES, LTD.
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that the license renewal review activities don't bleed over
(
2 into the operating reactor space, that these people have to 3
continue to be involved, and they can concentrate on the I
4 application review and the application review alone, okay?
5 So what we did was we developed a process, and 6
what we're asking the safety evaluation people, basically, 7
as well the inspections -- inspection people to do is to 8
document the findings, okay.
9 What did they need to make their finding under 10 5429, okay?
11 As they go through the FSAR review, there's the 12 documents specifically.
Those issues that they identify as 13 critical to their findings will be put in a database.
That 14 database will come down to the final review process.
i 15 Also, it will be documented in the safety 16 evaluation, okay, and it will provide input to the FSAR 17 supplement, the license conditions tech spec requirements 18 and-the inspection program, okay.
19 At the time of final review, the database will 20 identify the item, where in the renewed licensing package, 21 which includes the license itself, tech spec changes, and 22 the FSAR supplement, okay, and the inspection reports where 23 these issues were addressed and resolved.
24 So we have a database that's tracking each 25 individual issue, okay, and where the -- where these issues ANN RILEY & ASSOCIATES, LTD.
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72 1
have been resolved or entered or documented in the process.
(
2
-Based on this, we do a verification and that 3
verification will provide us with a high-level of confidence 4
that the process has been completed, okay?
5 Our intent from there is to forward this 6
information to the regions to allow them to keep track of 7
any open items that they have to track, any license 8
conditions, okay, and to keep a well-documented history of 9
what was done for the renewed application.
10 DR. SEALE:
You've got an interesting mix here.
I 11 When you talk about things you send to the regions and so 12
-forth of a generic nature, you're talking about the ground 13-
-rules under which tha process will proceed, and there are 14 certain calculations.that will need to be done to support i
15 that.
16 But for many of the reactors, these reactors were 17 licensed under the -- on the basis of margins.
18 MR. PRATO:
Right.
19 DR. SEALE:
They were based on -- their license 20
-was based-on margin-type calculations, rather than best 21 estimate calculations, and some recent experience we have i
22 suggests that, in some cases, the codes that were used to 23 make those initial margin calculations 20 years ago may not i
24 be too husky right now; that is, just in terms of the 25 availability of a machine to run them on.
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And I think our position is going to be that we 2
want these kinds of analyses, when they're done, to be very 3
scrutable.
If, indeed, this is a continuation of the 4
initial license, clearly, we have to accept the idea that it 5
is based on a margin calculation, but it's going to have to 6
be a margin calculation that has some robustness.
7 And so I'm just telling you, we're going to look 8
hard.
9 MR. PRATO:
Those calculation reviews are a part 10 of the technical review.
I don't see that having an impact 11 on -- after the license is approved.
That certainly should 12 be addressed before the --
13 DR. SEALE:
Yes.
14 MR. PRATO:
-- approval process.
15 DR. SEALE:
Yeah.
16 MR. PRATO:
Okay.
It sounds like you're talking 17 basically about time and aging analyses?
18 DR. SEALE:
Well, that and'--
19 MR. PRATO:
How that --
20 DR. SEALE:
-- and some of the -- yeah.
That kind I
i I
21 of thing.
Yeah.
1 l
22 MR. PRATO:
Okay.
Chris, do you have -- want to 23 add something?
24 MR. GRIMES:
Yeah.
I -- I hesitate because part 25 of the rules of the game, in terms of carrying over the I
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current licensing basis is we will accept the design 2
analysis as it exists today.
3 MR. PRATO:
Okay.
4 MR. GRIMES:
In order to demonstrate aging 5
management, for example, there's a minimum law for erosion 6
analysis.
Some of those analysis, as you point out, aren't 7
all that robust.
They.-- they may be better than when the 8
plant was originally constructed, but they clearly are not 9
going to satisfy the standards for a new license application 10 today.
11 And I think we're going to run into a lot of 12 circumstances where we're going to have to make some rather 13' pithy backfitting decisions about whether we want them to go l
14 back and reanalyze the design basis in order to get a better 15 handle on what they're using as thresholds for making 16 corrective action decisions, like. minimum wall is the only 17 one that really springs to mind right now.
But maybe when J
18 we get into the, you know, vessel embrittlement issues.
]
19 DR. SEALE:
And I think those are some of the s
.20 issues that we may be wishing that you would bring to our 21 attention whenever you get to that point.
22 MR. PRATO:
Chris, correct me if I'm wrong.
Will 23 we find issues like this?
I don't believe that it will be i
12 4 addressed under license renewal.
It will be referred back
^
25 to current operating concerns.
l l
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MR. GRIMES:
Yeah.
If there's a question about 2
the adequacy of the margin at all --
3 MR. PRATO:
Yeah.
4 MR. GRIMES:
-- then we'll have to face it in 5
terms of what does it mean to continue plant operation.
)
6 But in terms of the way that you posed the 7'
question, the generic nature of some of these questions, f
8 rather than plant specific things that will probably be 9
revealed through a request for additional information or 10 possibly open items in a safety evaluation report, we're --
11 Bob's going to go over the broad generic issues associated 12 with license renewal implementation, and you'll see a few 13 choice ones in there that will interest you.
14 And I'll tell you right now that our intent is 15 that as we address these issues formally and communicate 16 them with the Nuclear Energy Institute, you'll be on 17 distribution as we reveal how those issues are unfolding.
18 And it would probably be appropriate for us to talk about 19 whether or not there are just some points in time where we 20' will stop -- or will pause and discuss the status of those 21 things with the ACRS in a general way.
22 DR. SEALE:
Okay.
23 MR. PRATO:
Okay?
Before I go on to the next 24 slide, I pointed out the IP's, okay.
We also have another 25 code, the licensing issues for license renewal.
Those j
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76 1
licensing issues for license renewal are the input to the c
2 renewed licensing item process.
And here is the input for 3
the IP's.
4 All those issue points end up being dumped to the 5
IC Coordinator, which right now, I'm acting as the IC 6
Coordinator.
Is assigned specifically to somebody right now 7
within License Renewal.
That's our intent.
8 If it's a process type of question, typically, 9
we'll resolve it internally to license renewal.
10 If it's technical, okay, or legal oriented, it 11 will -- we will involve whoever we need to involve, from 12 design engineering to OGC.
Okay.
13 Regardless of how we decide to resolve it, whether 14 it's going to be a team effort or an individual effort, the i-15 objective is to either identify resolutions or options, 16 okay.
17 If we take the path of identifying options, it 18 gets kicked up to the Steering Committee, basically.
Gets 19 sent up the chain of command to the Steering Committee.
The 20 Steering Committee decides whether it's Commission level, 21 okay, or whether or not -- or selects the option themselves.
22 From there, it gets into the review and approval 23 process.
The industry is part of that review and -- it's 24 not part of the review and approval process.
I apologize.
25 The responsible organizations are part of that j.
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77 1
review and approval process.
When that decision has been 2
resolved, if it affects the development and implementation 3
aspects of it, it gets sent to the industry for their 4
comments.
5 And we've done that on a number of issues.
Some 6
of them have been kicked back, and they get kicked right 7
back into the process again at the top, okay.
8 From there, we make any appropriate changes to the 9
office letter, to the SRP, to the rate guide, and to the 10 manual chapter in IP's for the inspection program, okay.
11 From there, we verify that the documents have been 12 revised appropriately before the item gets closed.
13 MR. GRIMES:
I'd like to add a clarification about 14 the resolution.
i 15 The first step in the resolution process, at the 16 top of that box to the left, is management involvement, 17 which is a very important feature.
I get a first crack at 18 these things in terms of establishing whether or not the.
19 particular -- whether or how a particular issue is going to 20 get addressed and resolved.
21 My primary role is going to be to test the issues 22 in terms of reasonableness and fairness, and also to look at 23 it from a priority standpoint.
24 Line management gets the first opportunity to l
25' resolve an issue.
Bob said to go to the Steering Committee.
l.
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78 1
I don't expsct that wa're going to go to the Stenring 2
Committee with two or 300 solutions, but if'this is anything 3
like improved tech specs, where we had literally thousands 4
of issues --
5 We went to senior management on a half a dozen 6
occasions with particular issues, and maybe came out with 7
one or two policy issues that stem from that.
8 I expect to see the same kind of thing in license 9
renewal where we're going to have several hundred questions.
10 Some of these questions are going to break down into dozens 11 of other questions.
12 This process is a means of maintaining an 13 inventory and a control and a focus, and making sure that 14 good ideas don't get lost or questions don't get lost so 15 that we -- that we're assured that this evolution is going 16 to be a growing process and a learning process.
l 17 MR. PRATO:
Okay.
As for the status, the office 18 letter was approved on June 19th.
It's in effect.
In 19 reality, it's been in effect for quite some time prior to 20 that.
21 The guide for reviewing license renewal 22 applications has been in the implementation phase for --
23 since March 18th, was it, when BG&E came in with their 24 original application.
25 It seems to be working well.
We've got a number ANN RILEY & ASSOCIATES, LTD.
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79 1
of itcms fed back to us.
They're in the lessons learned 2
process, and they're being worked through the process as it 3
was designed.
4 The second guide, the guide for processing renewed 5
licensing action items, is a little bit premature right now.
6 We're only in the RAI phase for the BG&E application and we 7
just received the Oconee application.
8 But we do have a database in place.
We do have 9
forms that.need to be filled out, and they -- we -- since 10 PDR -- PDLR is the focal point and responsible for this 11 database, we're going to ensure that that gets done.
12 And I believe we have one item in that database, 13 okay, and what it is, off the top of my head, I don't 14 remember.
But, nonetheless, it's active and it's moving 15 along.
16 As for the guide for technical and process lessons 17 learned, that has also been in place for some time.
It was 18 put in place prior to June 19th.
It probably began in --
19 probably in January of this year, we started working in that 20 database.
21 We've got some 50 plus items in there.
Those 22 items include the 13 NEI items, the 17 EPRI items, plus a 23 number of proceasing items, plus some technical issues that 24 our design folks have raised, okay.
25 Along with that, we're expecting to meet with NEI l
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nsxt week to gain anywhere from 150 to 170 other additional 2
items, more focused on the guidance documents, okay.
We 3
have a meeting planned for next week to do that.
4 Once again, during our January meeting -- I'm 5
going to try to overlay both of these slides so we can have 6
them up there at the same time.
7 It's difficult.
I don't think I can do that.
8 But, nonetheless, these are the license renewal 9
items, the 13 Jicense renewal items that were basically 10 initiated by NEI.
We talked about these briefly last time.
11 Along with that, here it is, 17 issues from 2PRI.
12 There is some overlap, but none of those questions 13 where there's overlap, have they been asked the same exact 14 way.
We may come up with a single resolution to both of 15 them, but we did not want to take a chance on missing some 16 of the fine points, so we -- we put both lists directly into 17 the database.
18 DR. MILLER:
And that's the list of issues where 19 there is disagreement?
Is that the --
20 MR. PRATO:
Some of theme, disagreements.
Some of 21 them, I think, are basically resolved.
It's just a matter 22 of insuring that the process is well documented.
But for 1
23 the large part, yeah.
We're still doing a typical 24 evaluation.
i 25' I wouldn't say that disagreement.
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DR. MILLER:
Yeah.
Disagreement is too strong.
2 MR. PRATO:
Yeah.
3' DR. MILLER:
There's a difference of opinion on 4
the --
5 MR. PRATO:
There may not even be that.
There may 6
be new information that EPRI provided us that we're still 7
evaluating.
Fatigue is a perfect example, and I'll talk 8
about that in just a minute, okay?
9 DR. APOSTOLAKIS:
Now are you -- would you put up 10 the NEI 11 MR. PRATO:
Sure.
12 DR. APOSTOLAKIS:
What exactly did they think was 13 a issue with item 7?
14 MR. PRATO:
Item 7, Risk Conformed License 15 Renewal.
I believe and let me see if I have my responses 16 here.
17 MR. HOFFMAN:
Bob?
Bob?
My name is Steve 18 Hoffman.
I'm with the License Renewal Branch.
19 Is part of the development of the draft reg guide 20 and the review of the NEI 9510 implementation guidance, we 21 got some comments that they wanted a little more guidance on 22 exactly how risk would be used in the application for 23 renewal.
j 24 DR. APOSTOLAKIS:
This is what we were discussing 25 earlier.
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MR. HOFFMAN:
Tes.
2 DR. APOSTOLAKIS:
They would like to know more 3
about how you plan to use the risk dimension.
4 MR. PRATO:
I think -- I think the gist of this 5
more is in the direction of what the SOC says we're going to 6
use with respect to --
7 DR. APOSTOLAKIS:
Right.
8 MR. PRATO:
-- risk information.
9 There is statements in the SOC that says exactly 10 what the Commission had intended, if you will.
I don't 11 think it goes to the depth that your question raised.
But 12 13 MR. HOFFMAN:
That's correct.
The SOC talks about 14 if you have a structure component that's within the scope of 15 a license renewal that you need to evaluate, that risk can 16 be considered in establishing the level of aging management 17 in more or less the robustness of the program required.
And 18 so it was just an area that they wanted to just, you know, 19 somebody requested that a little more guidance be provided 20 as to how would you go about using it in that context.
21 But Bob is right.
It's more along the lines of 22 what the SOC statements address.
23 MR. GRIMES:
And this is Chris Grimes.
24 I'd like to add to that.
I want to clarify the 25-scope of these issues.
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83 1
This is a condensed list of a lot of questions and 2
comments that evolved from the time that the staff attempted i
l 3
to endorse NEI guideline 9510 for implementation and license I
4 renewal.
And as Bob pointed out, in some cases, we --
5 you'll find that these are very broad -- too broad, in fact 6
-- very broad issues that lack -- that need some clarity put 7
to them, and are very controversial, all the way down to 8
some relatively minor questions like item 13, degradation 9
induced by human activity.
10 That's to what extent do you account for how 11 humans constitute aging effects?
And the staff's position 12 is, "We're not going to attempt to try and define aging 13 effects caused by human activity?"
That's a -- that's a 14 natural part of the processes for maintaining a plant.
15 MR. PRATO:
That's one of the issues I'm going to 16 be going over --
17 DR. APOSTOLAKIS:
We're not --
18 MR. PRATO:
-- a little bit more.
19 DR. APOSTOLAKIS:
-- extending the life of humans.
20 MR. GRIMES:
I know.
We're not --
l 21 (Laughter.)
22 MR. GRIMES:
We're not going to attempt to explain 23 how to extend the life of a human.
24 DR. SHACK:
Just renew their license.
25 DR. APOSTOLAKIS:
Why won't you?
l l
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84 1
MR. GRIMES:
And it gets to th@ purpose for this 2
process.
We want to make sure that we -- that the question 3
is clearly defined in a way.
4 First of all, it's within the scope of the job 5
that we've been asked to do, and then secondly, so that the 6
answer is meaningful.
7 And so some of the -- their -- there's a broad 8
range of issue on here.
This is issue with a little I.
And 9
a lot of these need to be framed in terms of questions for 10 which we can reasonably expect to find answers.
11 DR. APOSTOLAKIS:
Can we get a description of 12 these?
13 MR. PRATO:
I believe I have a brief description 14 of those issues.
Isn't that what --
15 MR. HOFFMAN:
We have some.
We can get it for 16 him.
17 DR. UHRIG:
For issue number 12, I haven't the 18 foggiest idea what it is.
19 MR. PRATO:
If you -- consumables.
If you look at 20 the rule, it says for it to be long-term, okay, it needs --
l 21 it cannot -- it's long-term if it's -- it's short-term if 22 it's not in a specific replacement program that specifically 23 identifies the frequency of replacement.
24 And you take a look at consumables.
Typically, i
I 25 they don't have a specific frequency of replacement.
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They're replaced as you enter a system.
l 1
2 If you break a seal, you replace gaskets, okay?
3 But they certainly don't meet what we initially felt was the 4
intent of the rule as long-term.
They don't -- typically, 5
consumables, you won't keep into the system for 40 years.
6 On top of that, the codes really don't take credit 7
for many of the consumables.
But since they didn't fit the 8
guideline of what's long-term and what's short-term, and 9
based on the rule they fit into the long-term, they would 10 end.up within the scope of the rule.
11 So we are trying to deal with this so that we can 12 document what the final decision is on that, how the rule 13 applies to these items, okay?
14 That is not a final resolution yet.
15 MR. HOFFMAN:
The term, "consumables," may not 16 accurately describe it.
We are talking about like gaskets, 17 packing seals.
Like you may have a gasket on a manway.
18 DR. UHRIG:
Consumables would not be gasoline or 19 diesel fuels?
20 MR. HOFFMAN:
No.
But this is more -- it -- in 21 particular, it's gaskets, packing and seals.
22 DR. UHRIG:
Seals.
23 MR. HOFFMAN:
And you may have a gasket on a 24 manway that you're not going to routinely replace that.
25 You're going to replace it when you go in.
And so the l
l l
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question was, is how do you address that gasket for license 2
renewal?
3 Some of these items are actually just items that 4
we identified at the time we were developing the guidance 5
that needed further clarification in the future.
They 6
weren't reactors issues.
It's just something we needed --
7 we wanted to develop more fully in the future.
8 MR. PRATO:
I'm going to go over a couple of these
.I 9
items.
Certainly these are dispersed among the staff, and a 10 lot of the specifics are no one person knows all the 11 specifics.
But I'll do the best I can on describing them.
12 I have some supporting documentation, and I'll do what I can 13 to help you.
14 GSI letter -- GSI safety issues.
In one of our i
15 earliest presentations to the ACRS, you gave us some j
16 guidance on how we should hand GSI's and made some 17 recommendations to us.
18 We issued a letter in January of '98 that I
19 basically told the industry that the staff has -- the staff 20 developed criteria for which GSI's applied to license 21 renewal that may potentially have application to license 22 renewal -- not applies, but potentially has application to 23 license renewal.
So we gave them criteria.
24 And we also did a review of NUREG 933, based on 25 supplement 21, which was issued in 12-96, and gave them a ANN RILEY & ASSOCIATES, LTD.
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87 1
snapshot of which ones we thought were potentially 2
applicable to license renewal.
This was based on guidance 3
that we received from you folks in one of our earliest 4
presentations on license renewal.
5 DR. UHRIG:
Is this the issue that was -- that had j
l 6
lines of the paper a week or so ago about specifically fuel I
7 storage, spent fuel storage?
8 MR. PRATO:
Chris?
j l
9 MR. GRIMES:
No.
Actually, that's in a Part 51 1
10 arena, the environmental impact issues.
The -- when we 11 described the process to the public, they were most annoyed 12 that the Commission has chosen to exclude from a license 13 renewal finding things like a high-level waste repository l
l 14 for the nation.
l l
15 Essentially, what Part 51 refers to is the
)
16 category 1 issues, i
17 These are -- this is more classically described as l
18 the ALAB 444, the Atomic Safety and Licensing Board, back 20 19 years ago or so ago, said that the Commission can make 20 decisions on licensing actions, even though there may be 21 some germane generic safety issues that remain unresolved.
22 And there is a -- the process that we go through l
23 is to look at pending generic safety issues and say, "Which 24 ones of these relate to the licensing action, and then 25 address them in terms of why it's okay to permit them to i
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88 1
continuo to be unresolved since we -- since the process has 2
been developed for 0933 that now provides us with a point of 3
departure to do it a little bit more efficiently.
4 But there's still some room for further 5
improvements in terms of explaining in some more detail how 6
to address generic safety issues in an efficient way.
7 MR. PRATO:
Okay.
As a follow up to the GSI 8
question, if you take a look at number 2, the volume on 9
qualification of tabling, the staff, on June 2nd, issued a 10 letter to NEI that basically told them how to address GSI 11 168.
Okay.
12 GSI 168 is the GSI on environmental qualification, 13 and basically the staff told them that they did not have to 14 address 168 for license renewal until it's been resolved by 15 the staff.
16 However, okay, EQ is still within the scope of 17 license renewal.
They still have to address EQ as an aging 18
-- as an aging effect.
19 MR. GRIMES:
Bob, if I --
20 MR. PRATO:
Sure.
21 MR. GRIMES:
We have to address EQ because it is a 22 time limited aging analysis.
23 As far as EQ --
24 DR. UHRIG:
I'm not sure I understand that 25 statement.
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Could you elaborate?
2 MR. GRIMES:
Part 54 provides that there are two i
3 components to aging management.
One is identifying passive j
I 4
structure systems and components that age, and describing 5
how the aging effects will be managed.
3 i
6 But there's a second part to the license renewal 7
decision, and that's'a recognition that the design includes 8
some design analysis that have time dependent features.
9 If you had to -- if you had to use 40 years in 10 your design calculation, that's a time limited aging 11 analysis.
All of the environmental qualification packages 12 include analysis that demonstrate that the qualification is 13 suitable for 40 years or more, and depending on whether or 14 not the EQ package has a particular time constraint in it, 15 it fits within a scope of stuff that's called " time limited
]
16 aging analysis," as opposed --
17 So we address it there as a design analysis.
We 18 address the other stuff in terms of managing aging effects 19 in a process way.
20 CHAIRMAN FONTANA:
Is it pretty clear cut?
Is it 21 going to be pretty clear cut on what is involved in a TLAA, 22 or is there going to be a lot of kind of decisionmaking as 23 you kind of go along?
24 MR. PRATO:
With our experience in the 25 demonstration program?
l I
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CHAIRMAN FONTANA:
Yeah.
2 MR. PRATO:
I don't believe that there's any 3
problem with that.
I think TLAA's are a lot more specific 4
and a lot easier to define than aging management, in 5
general.
But that's just a -- a general observation that we 6
identified during the demonstration program.
7 MR. HOFFMAN:
The Commission --
8 CHAIRMAN FONTANA:
But there could be differences 9
of opinion?
10 MR. HOFFMAN:
Well, the Commission offered, in the 11 SSC for the rule --
12 MR. PRATO:
I've got that --
13 MR. HOFFMAN:
-- provided three approaches.
14 One, you know, your analysis already may be 15 adequate for the 60 years.
So all you do is you go back and 16 verify your analysis is good.
17 The second approach would be to revise your 18 analysis to show it's good out to 60 years.
19 And then the final way to be is to, more or less, 20 manage the effects of aging.
You know, if you can't revise 21 the analysis, you might decide to replace it periodically or 22 something like that.
23 So there are three approaches, and so far, we 24 haven't seen any.
25 MR. GRIMES:
I understood your question to be more l
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1 towards is there going to be any controversy about what is 2
the time limit or ging analysis.
3 CHAIRMAN FONTANA:
That was my question.
And then 4
the next question is, once you decided -- and I guess that's 5
a technical question about how is the analysis performed 6
with respect to anticipated lifetime, and things like that.
7 MR. GRIMES:
And the reason that I hesitated is 8
because I was about to say time limited aging analysis are 9
almost self-evident.
You ought to be able to spot one a 10 mile away.
l 11 But then it occurred to me that there may be some 12 left-handed thinker and comes in and says that the vessel is 1
13 a time limited aging analysis and -- and I don't need to --
14 I don't need to address aging effects or embrittlement or 15 anything else.
I'm just -- you know, it's a TLAA, and I'm 16 going to, you know, do a reanalysis, which I don't think was 17 the concept.
It was more towards EQ and fatigue cycles and 18 it's in what we consider to be classical time dependent 19 design analysis.
20 I -- my suspicion is that it's not going to be 21 tremendously controversial.
There's a general understanding 22 of.what a time limited aging analysis is.
1 23 CHAIRMAN FONTANA:
Okay.
j 24 MR. PRATO:
Okay.
And a follow up to Chris' i
25.
original discussion on time limited aging analysis and aging l
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92 1
management, the SOC -- there's a statement in the SOC that 2
i'll read to you very quickly:
"A resolution of a USI and 3
GSI generically for the set of applicable plants is not 4
necessary for the issuance of a renewed licensa.
GSI's and 5
USI's that did not contain issues related to license renewal 6
aging management review and time limited aging evaluations 7
are not a subject of review or finding for license renewal.
8 "However, designation of an issue as a GSI or USI 9
does not include -- does not exclude the issue from the 10 scope of aging management review or time limited aging 11 analysis."
12 As a follow up to the discussion on 168, we have 13 another item that's active right now on EQ, and that is --
14 partially addresses Steve's comments that the rule under 10 15 CFR 5421(c) gives them three options on how to address a 16 time limited aging analysis.
17 One is to have an evaluation that's already good 18 for 60 years.
Another one is to go in there and reevaluate.
19 And the third one is is to develop an aging management 20 program.
21 And the licensee has all three options to choose 22 from for any TLAA.
And we're trying to figure out how this 23 applies in the EQ area, specifically as an example to apply 24 to the rest of the time limited aging analyses as they may 25 come in.
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1 With respect to passive and active determination, 2
ongoing items probably is going to be open for many, many 3
years.
The reason is is as we go through the scoping 4
process at the different plants, there are going to be new 5
. questions that come up -- come about as with respect to 6
which components are passive and active.
7 One example of this was on September 19, 1997.
8 The staff issued a position stating the active and passive 9
state of six different electrical components, okay.
Based 10 on this letter which went out to the industry, the industry 11 came back with concerns on one of the determinations, that 12 is the active or passive nature of fuses.
The staff said 13 that the continuity function of a fuse is passive.
The 14 industry took exception to that.
They didn't recognize the 15 continuity as a function for fuses.
And right now, we're in 16
-- we're evaluating their comments and preparing a response 17 to that.
18 It's just an example of how the system works.
19 When the staff identifies a position, they document it.
20 They send it out to the industry.
The industry reviews it i
21 and provides comments back to us, and it pucs us right back l
22 into the top of that flow chart, which, of course, is to 23 reevaluate it.
I 24 CHAIRMAN FONTANA:
Yes.
Well, along those lines, 25 I don't know if my memory serves me right here, but at one ANN RILEY & ASSOCIATES, LTD.
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. time, I thought I read somewhere that instrumentation was 2
basically active.
Instrumentation was not involved.
3 MR. PRATO:
That's correct, sir.
4 CHAIRMAN FONTANA:
In thumbing through the BG&E 5
report, I see that -- I think that involves some 6
instrumentation on the course brace -- on the containment 7
brace system, or something like that.
I think.
8 Now, are they --
9 MR. PRATO:
Okay.
10 CHAIRMAN FONTANA:
-- are marching to a little 7.1 different set of rules here.
12 MR. PRATO:
We have to take a step back from that.
13 The electronics, in general, are active, and I think what 14 the rule says is, " transmitters," which referred to the 15 electronic portion of instrumentation.
16 Copper tubing, whether or not you're talking about 17 a flow orifice or a venturi, all those components, okay, can 18 fall within the scope of license renewal --
19 CHAIRMAN FONTANA:
Okay.
if they're determined to be passive 20 MR. PRATO:
21 and long-lived.
22 CHAIRMAN FONTANA:
Okay.
23 MR. PRATO:
It's like the rule --
24 CHAIRMAN FONTANA:
I understand.
25 MR. PRATO:
-- what you're referring to in the ANN RILEY & ASSOCIATES, LTD.
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95 1
rulo is tha tran:mitters and the transmitters as, I believe, 2
it was defined and discussed in the SOC.
We're talking I
3 about the electronic portions, okay?
4 Circuit boards, transistors, those type of things, l
5 are considered active by the rule.
6 CHAIRMAN FONTANA:
Okay.
7 MR. PRATO:
Okay?
8 This brings us down to the famous question of 9
degradation induced by human activity.
10 On June 5, 1998, the staff issued a position 11 stating that the degradation induced by. human activity, 12 including abuse, accidents, or specific.-- and specific or 13 unexpected events, are not considered an aging management 14 an aging'effect, f
15 Let me also bring out something really quick.
16 This was in the response which we sent to NEI.
It says 17 that, "The staff believes that degradation induced by human 18 activity, including abuse, accidents, and specific or 19 unexpected events, is not an aging effect that needs to be 20 subject to an aging management review."
21 Then we go down a little bit further, and we see, 22 "Similarly, human activities might influence degradation or J
23 the rate of degradation by increased air and water-borne 1
24 contaminants.
For instance, acid rain.
25 "However, this influence would be considered l
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l 96 1 -
through the evaluation of a specific aging effect, such as
!j 2
chemical attack, and therefore, do not need to be addressed 3
as a separate aging effect."
4 So, in other words, we didn't say that conditions 5
initiated by human activities are completely out of the 6-scope of the rule.
We're saying that they're not specific 7
aging effects, and that if they do effect a specific aging 8
effect, they need to be considered under your evaluation for 9
that aging effect.
10' And another example we give in here is terminals 11
-- electrical terminals.
If manipulation of electrical
'12 terminals under Appendix B, they're covered automatically, 13 and therefore, we didn't -- we really didn't need to address 14 them specifically for license renewal.
f-15 Those type of activities that result in specific 16 degradation, they should be picked up under the current 17.
licensing basis programs, which is Appendix B.
18-Finally, fatigue.
19 CHAIRMAN FONTANA:
They aren't -- an example came 20 to mind, though.
A few years back where a coal plant a 21 short distance upstream from some external equipment, which 22 was stainless steel, over a period of about 30 years, really 23
-corroded.
The thing almost came apart.
l 24 That was a totally different thing.
It was a
_25 human activity upstream that ended up affecting something ANN RILEY & ASSOCIATES, LTD.
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97 1
downstream.
2 MR. PRATO:
Again, I think this falls under the 3
difference between aging -- aging effect and degradation 4
mechanism.
5 If the aging effect is reduced -- reduction of 6
wall thickness, loss of materials, okay, if there is 7
something that's affecting that, okay, like emissions from a 8
coal. plant, okay, they have to address that aging effect and 9
the cause of that aging effect, and how they manage it would 10 bring in the emissions from the coal plant.
11' CHAIRMAN FONTANA:
Pretty straightforward.
12 MR. PRATO:
Yes, sir.
13 CHAIRMAN FONTANA:
Yeah.
14 MR. PRATO:
Okay.
Finally, fatigue.
The industry 15 has been in a number of times to talk to us about fatigue.
16 Their basic opinion is that fatigue from the industry's 17 level is resolved.
'18 The staff is considering their resolution.
We're 19 evaluating it right now.
However, we do not want to impede 20' the Oconee and Calvert Cliffs applications.
21 So what -- what we're trying to do right now, 22 we're trying to address fatigue for Oconee and specifically 23 for BG&E right now, and Oconee in the very near future.
24 As a result of the way we address fatigue for 25 those specific applications, we may find the final ANN RILEY & ASSOCIATES, LTD.
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98 1
resolution for the generic concerns relating to fatigue.
2 The staff has met on these issues, discussed them, j
1 3
and they're taking actions to try and resolve them l
4 specifically for Calvert Cliffs and to keep in mind, the 5
generic concerns, at the same time, and see if we can't 6
resolve both of them at the same time.
7 MR. GRIMES:
Let me add to that.
The fatigue 8
action plan offered us a rather unique opportunity to 9
experience a horse race.
The schedule that the research 10 folks are currently working on hopes to come to a resolution 11 on generic safety issue number 190, which is fatigue for 12 license renewal, which is unique in itself.
It's the only 13 generic safety issue that applies specifically to this 14 program.
15 And at the same time, we're trying to develop an 16 understanding of what requirements are necessary and 17 sufficient to address fatigue for these first two 18 applications.
And I'm probably a pretty good gambling man, 19 but I'm not going to gamble on having the critical path for 20 this review depend on the generic safety issue being 21 resolved.
22 So we're running this in parallel paths.
We're 23 going to continue t3 probe into the how is fatigue managed 24 on Calvert Cliffs and Oconee to see whether or not we can 25 define some standard of requirements to put in the SRP.
L 1
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And at the same time, we're going to let the 2
research folks see what they can do to understand how fast 3
new data is going to come out, and how it's going to be 4
addressed to come up with a generic resolution.
5 Their timing is to complete their evaluation in 6
March of
'99, and when we get to the schedule for BG&E, 7
you'll notice that that's also about the time that we're 8
going to try and complete an SER.
And that's why I say this 9
is an interesting horse race, because the two of these 10 things are going to occur, you know, almost on top of each 11 other.
12 CHAIRMAN FONTANA:
I was wondering, could you put 13 the EPRI issues slide back -- I don't guess we really need 14 the slide, but it's --
15 Now is each one of these basically generic?
16 Do these have to be resolved specifically for the 17 application that you have in hand?
18 DR. UHRIG:
Are there more questions?
19 MR. PRATO:
Actually, these are issues that either 20 constitute questions or industry positions on certain 21 technical matters.
22 On the first set were questions that evolved from 23 the implementation requirements that came out of the NEI 24 guide and the reg guide and the initial formulation of the 25 standard review plan.
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100 1
This-is a set of stLff from APRI that represents 2
both industry positions on the resolution of generic issues 3
-- let me pause here and say this is all generic.
4 CHAIRMAN FONTANA:
Yeah.
5 MR. PRATO:
Okay.
But the -- and the question is 6
to what extent do these things either answer requirements 7
for license renewal for all plants or constitute better ways 8
to address issues technically that might have an effect, not 9
only for license renewal, but also current operating reactor 10 requirements in the future.
11 And part of our prioritization process will be to 12 go through and say, "Well, to what extent do we have to 13 address these issues now and in the context of a license 14 renewal decision?"
(
15 So that aspect of fatigue is we have an industry 16 position that says, "It's resolved.
Just keep doing what 17 you're doing."
18 And we have to decide whether or not that's 19 sufficient and it constitutes the basis to resolve the GSI 20 and establish it.
Nothing more need be done than current 21 Section 11 practices or whether or not there is a delta of l
22 requirement that goes along with managing fatigue for a 23 period of extended operation.
24 But then if you go down to -- I'm looking for one 25
-- stress relaxation number 5.
Stress relaxation of l
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101 1
pressurized water reactor and terminal components.
(
2 But since I'm not quite sure yet how the staff is l
3 going to address baffle barrel bolts for pressurized water l
4 reactors and its current operating reactor kind of issue, I 5
don't know to what extent I need to resolve that right now.
6 That would depend, in part, on whac the staff concludes is 7
necessary and sufficient to manage aging effects for reactor 8
internals.
9 And in some of those things, it may be that they 10 go into GSI space because they don't have a clear 11 resolution.
They don't have a clear technical requirement 12 that can be imposed as an aging management condition.
13 CHAIRMAN FONTANA:
Do you have a process by which 14 every one of these will come to some conclusion or other?
15 MR. PRATO:
Yes, sir.
Yes.
16-CHAIRMAN FONTANA:
That's either been to GSI --
17 MR. PRATO:
Yes.
18 CHAIRMAN FONTANA:
-- or about or what are they?
19 MR. PRATO:
In scme of these cases, we may -- in 20' some cases, if it's clear that there's not going to be a 21 generic resolution, we may still have to make a decision on 22 the. plant specific application.
23 And fatigue is an example of that.
If it turns i
24 out that the generic resolution isn't -- you know, it 25 doesn't -- isn't coming to fruition, we still have to decide l
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l 102 l
l 1
what we consider to be an appropriate aging management for 2
fatigue for Calvert Cliffs and Oconee.
And they may resolve 3
it their own way.
That's still an option, too.
4 And I -- this is probably an appropriate point to 5
say that we're going to continue to work towards generic l
6 resolutions of these issues, but given that the applications 7
have already been received from Duke -- from BG&E and Duke 8
on Calvert Cliffs and Oconee, they'll be offered an 9
opportunity to do something different because they have 10 already made their application and they can either adopt 11 generic resolutions or they can negotiate for plant specific 12 solutions.
13 They dLaerve that for the sake of being where they 14 are.
And so it's -- it's not a foregoing conclusion that as 15 we come to generic solutions for these issues that we're 16 simply going to impose those on Calvert Cliffs and Oconee.
17 They'll be offered an opportunity to argue to do something 18 different because they've always submitted an application.
19 DR. SHACK:
Well, presumably, their application 20 didn't refer to any generic solution, so they've addressed 21 it for their plants.
22 MR. GRIMES:
That's correct.
23 DR. SHACK:
You have to review it and decide 24 whether it's acceptable.
I 25 MR. GRIMES:
That's correct.
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103 1
MR. PRATO:
Fatigue has been a longstanding issue, j
2 and most plants have programs in place to address fatigue, j
3 So generic resolution may not be necessary for all plants to 4
satisfy the requirements of license renewal.
5 DR. SHACK:
It would just make life simple?
6 MR. PRATO:
It would help the licensees in their 7.
application -- in developing their application more so than 8
it would help in the evaluation, because regardless of what 9
the generic resolution is, we still have to evaluate that it i
10 meets the requirements of the rule.
11 Okay.
Are there any other questions?
12 We've --
13 CHAIRMAN FONTANA:
The reason I asked is that I 14 did look through them and a lot of times, the industry 15 position was just change some of the wording in a standard 16 review plan or something like'that.
17 MR. PRATO:
We have a number of process type of 18 items and we're working through them a lot quicker than some 19 of these generic issues.
20 We -- only one has been through the entire system, 21 and we believe that that one will remain resolved, which is 22 the human impact.
23 But there are three or four more in final 24 resolution.
There are a couple of more that are really 25 being processed through as quickly as possible.
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104 1
The EQ question is one of them.
Management wants l
2 a resolution to that.
It's significant.
3 We're trying to focus our resources on priorities.
1 4
CHAIRMAN FONTANA:
Okay.
l 5
MR. PRATO:
Okay.
{
6 CHAIRMAN FONTANA:
Yeah.
I 7
MR. PRATO:
By the way, just as an added side bar 8
to that comment is, we're working with NEI diligently on 9
setting those priorities, j
l 10 DR. MILLER:
So six months from now, that list 11 will be quite a bit shorter?
12 MR. PRATO:
I hope.
13 DR. UHRIG:
I was going to say, longer.
14 MR. PRATO:
Well, it's certainly going to be 15 longer because we're going to be adding about another 170 j
1 16 over the next couple of weeks.
But, hopefully, the list of l
17 resolved ones will be getting longer.
Correct.
18 DR. MILLER:
The 170 or --
19 MR. PRATO:
The 170 are the NEI comments on the 20 industry guidance documents.
21 MR. GRIMES:
On the standard review plan?
22 MR. PRATO:
I'm sorry.
On the standard review 23 plan.
24 DR. MILLER:
You list those issues --
25 MR. PRATO:
That's correct.
I'm sorry.
l i
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105 1
DR. MZLLER:
You list those issues, then?
2 MR. PRATO:
Right.
j 3
DR. MILLER:
You list those then as issues?
4 MR. PRATO:
They will because we're trying to 5
control not only the issues themselves, but the revision 6
process, as well.
7 It doesn't mean that the revision process is 8
solely tied to the feedback process, but we're trying to 9
control both aspects, both ends of that process.
10 Any other questions?
I 11 Okay.
Thank you very much for your time.
I 12 CHAIRMAN FONTANA:
Well, thank you.
13 DR. SEALE:
Mr. Chairman, are we going to hear 14 anything from anyone from the industry today?
I 15 CHAIRMAN FONTANA:
We have not I
16 DR. EL-ZEFTAWY:
I don't think so.
I mean they 17 know about the meeting but there's no volunteer.
We hadn't 18 heard ahead of time at least.
19 DR. SEALE:
Okay.
l 20 MR. GRIMES:
We had not intended -- we provided 21 for this meeting in order to come -- er.'.ain to you where we 22 are and what our plans are, but we did not ask the industry 1
23 to come speak but I am sure that when they want to, we can i
24 make those arrangements too, but at the conclusion of 25 today's meeting I want to make sure that we do talk about l
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106 1
what schedule and what content you would like for future 2
meetings.
l 3
DR. SEALE:
Well, I wasn't trying to imply that I 4
did not appreciate or had any reason to suspect anything you 5
said, but on the other hand we are always interested to hear 6
about these things in the evolutionary stage because among l
7 other things we think it is a very efficient time to get 8
industry input and for them to have the opportunity to get 9
your perspective as well, so just curious.
10 MR. GRIMES:
I had expected that when we get a 11 group of the generic issues that is a convenient size for an 12 ACRS presentation --
13 DR. SEALE:
Great.
14 MR. GRIMES:
-- that we would have the industry 15 come and speak to their positions --
16.
DR. SEALE:
Very good.
17 MR. GRIMES:
-,or any positions of controversy.
18 CHAIRMAN FONTANA:
I was going to say as we were 19 discussing the function of this meeting it was mostly 20 process, procedures and direction we're likely to go to.
i 21 MR. GRIMES:
And at this point in the presentation 22 I would like to explain to you where we stand with respect 23 to the license renewal activities, specifically I think that 24 Bob mentioned that we got the Calvert Cliffs application in 25
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107 1
The application was dated April the 8th and it was 2
received on April the 10th and from that we have developed a 3
review schedule that was negotiated at the highest levels of 4
the agency.
I said that somewhat facetiously.
We went 5
through a series of scheduling exercises trying to explain 6
to NRR management, to the Executive Council and to the
~
?
Commissioners exactly how fast we could do a review and 8
exactly why does it take so long, and you may have noticed 9
in some of the trade journals the controversy that was 10 created when Corbin McNeil said that there is no reason that 11 the NRC can't do this license renewal decision in six 12 months, and I can tell you that created a consternation for 13 me for several weeks, explaining exactly how long it takes 14 to process a licensing application.
15 But we have boiled it down to our most aggressive 16 schedule, which is 585 days, and I have used that figure 17 publicly too.
It represents the time from the receipt --
4 18 not the date of the letter but the actual when it comes 19 through the door of the application to the point where we 20 would complete a safety evaluation supplement that is 21 resolution of any open items in a safety evaluation and the 22 final environmental impact statement, and for Calvert Cliffs I
23 that date is November the 16th, 1999.
24 You will notice on the schedule, which I think was 25 referred to earlier, was published in a letter to BG&E dated l
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June the 17th.
Now the difficulty with that schedule is we 2
carved out just the piece associated with doing the re*iew 3
of the -- pursuant to Part 54 and Part 51, the technical and 4
environmental aspects -- and we did not include in that the 5
hearing process, and that is because the Commission has only 6
recently decided on how the hearing process should proceed 7
and the Commission will be issuing a policy statement, a 8
general policy statement related to the conduct of 9
adjudicatory proceedings 10 You have noticed that -- you should notice that 11 the General Counsel's Office has trained me very well in how 12 to explain these terms and they will be addressing the 13 schedule for the overall Commission decision in a 14 case-specific order.
15 DR. SEALE:
We'll still give you the benefit of 16 the doubt.
17 MR. GRIMES:
Thank you.
)
18
[ Laughter.]
I 19 MR. GRIMES:
So at this point in time all I can 20 tell you is we are continuing to work to this overall 21 schedule as it was published to BG&E and we will monitor 22 resources and accomplishments towards the major milestones 23 in the review for both Calvert Cliffs and Oconee.
12 4 Now that Oconee has been received I'll give you a 25 little preview and say that with a receipt date of July the l
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109 l
1 7th, 1998, we are expecting to complete the safety 2
evaluation supplement and the final environmental impact 3
statement in February, year 2000, which means that your ACRS 4
meeting would be in May of the year 2000.
It delays exactly 5
by the three month difference between the submittal dates of 6
the applications, but in the middle of those schedules are 7
major milestone dates for completing all of the questions.
8 We get one shot at asking questions and then we go right 9
into writing the safety evaluation.
10 Then there is a safety evaluation and whether you 11 call it a draft safety evaluation or a safety evaluation 12 with open items, the next major milestone is to collect 13 together all that we know and all that we don't know in much 14 the same way as we used to do operating license reviews.
15 We issue a safety evaluation and whatever is 16 missing or unresolved gets identified as an open item.
Then 17 we can track the resolution of open items to the completion 18 of the safety evaluation supplement.
19 A similar process occurs for the environmental 20 review.
We issue -- we held a public scoping meeting last 21 week on the Calvert Cliffs application and you noticed what 22 kind of media coverage that we got.
Mr. Riccio from 23 Critical Mass was quite adept at saying that the process 24 that provides for Category I environmental issues and 25 Category II basically takes all the Category I issues off ANN RILEY & ASSOCIATES, LTD.
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the table and so we don't get to address the things that we 2
want to address.
3 What the media coverage did not focus on is the 4
fact that we went through a very public process to get to l
5 that point when Part 51 was revised in 1996 to categorize 6
the environmental impacts into those that are generic and 7
chose that are appropriate to be addressed on a 8
plant-specific basis, so I am sure that we will hear some 9
more about that and that there will continue to be public 10 concern about the extent to which they can debate their 11 particular areas of interest.
12 We are also proceeding with rulemaking to change 13 Part 51 again to make transportation of high level waste a 14 Category I issue and now that we have these pending license 15 renewal applications, I expect there may be a little more 16 public attention the next time we revise Part 51 than there 17 was in 1995 when we went through the first exercise to 18 categorize the environmental impacts for license renewal.
19 But getting back to the question you asked earlier 20 about the schedule, the milestones that we are going to 21 monitor are, first, completion of the Request for Additional 22 Information, or RAIs, which for BG&E is September the 7th, 23 1998.
From there we will complete environmental RAIs on 24 October the 7th, about a month behind.
We will complete 25 the -- I'm sorry, the applicant will complete the response I
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111 1
to the technical RAIs by November the 21st and they said i
2 that they expect that 60 days is sufficient or about 60 days 3
is sufficient for them to complete their responses and their 4
response to the environmental RAIs will be completed by 5
December the 6th.
6 The draft environmental impact statement would be 7
issued in March of 1999.
The Staff's safety evaluation with 8
open items would be issued on March 21st, 1999.
The public 9
meeting on the draft environmental impact statement is April 10 the 5th, 1999.
The resolution of the draft environmental 11 impact statement comments is May 20th, 1999.
Applicant's 12 response to the open items in the safety evaluation is July 13 19th, 1999, and as I mentioned before, the safety evaluation 14 supplement final environmental impact statement would be 15 completed by November, 1999.
16 That is about as fast as we think we can do it and 17 we would apply the same template to the review process for 18 Oconee and we'll be publishing that schedule, but at the 19 same time now we have to see how the milestones for the
)
20 adjudicatory proceeding will fit into this and I have just l
21 this morning started to fit in what the General Counsel has 22 identified as all those points where the Staff and the 23 applicant have to respond to interrogatories and do other I
24 things, and it looks like the Commission decision is going l
l 25 to be about September-October, year 2000.
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We are continuing to be pressed to see whether or 2
not we can compress that part of the schedule to get it down 3
closer to two years than three years and so we will be -- we 4
will share with you the adjudicatory milestones as soon as
)
i 5
the Commission completes its scheduling for that proceeding.
6 DR. UHRIG:
Do you expect that the hearing process I
7 will be similar to those held for an operating license or 1
8 what is the nature, the guidance you have so far?
Did the 9
Commission indicate the nature of what the adjudicatory J
10 process would be?
11 MR. GRIMES:
It would probably be easier for you 12 to see that in the Commission's policy statement where they 13 talk about the fairness of this process to the interested 14 parties, but I can tell you that the Commission is focusing 15 very heavily on the narrow focus -- that is, the specific 16 focus of this proceeding is making a decision pursuant to 17 Part 54, which is aging management for passive long-lived 18 components and time-limited aging analysis.
That is a very 19 specific box, and Part 51 gets to environmental impacts that 20 are only associated with extending the license period, and 21 my suspicion is that unlike the proceedings for the 22 operating license, which were much broader and pretty well 23 covered the whole of the plant design and operation, that we 24 are going to see the adjudicatory proceeding now spending a 25 lot more time talking about whether or not the contention is l
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i 113 1
within bounds.
2 DR. UHRIG:
There will be a licensing board 3
appointed?
4 MR. GRIMES:
If a hearing is requested.
5 DR. UHRIG:
If a hearing is requested?
6 MR. GRIMES:
Yes and the clock is now running for 7
BG&E.
8 The notice for hearing -- hearing opportunity 9
notice, whatever -- I can never remember exactly how they 10 set that up, but the hearing notice was published on July 11 the 8th and it expires or it ends on August the 7th, so by 12 August the 7th we will see whether anyone is interested in 13 litigating particular contentions on the Calvert Cliffs 14 application.
15 DR. MILLER:
Has anybody applied yet?
16 MR. GRIMES:
Not that I know of.
17 DR. UHRIG:
They always come in the last day.
18 DR. SEALE:
Oh -- how robust is that short a 19 window?
Namely --
20 DR. UHRIG:
30 days.
21 DR. SEALE:
You said 30 days.
I can imagine 22 someone might come in and say that doesn't give the 23 potential Intervenor the window that they would need in 24 order to make a reasonable evaluation of whether or not they 25 want to intervene.
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How successful have those kinds of contentions 2
been?
Do you have any feel for that?
g 3
MR. GRIMES:
Oh - 'my experience is limited to 4
only a few cases.
5 DR. SEALE:
Yes.
6 MR. GRIMES:
Fortunately they were relatively high 7
profile -- Diablo Canyon, Comanche Peak -- and I can tell 8
you that there is more to it than just that initial hearing 9
opportunity to request, and so my suspicion is that that 10 window will probably be fairly successful in terms of j
11 identifying whoever the interested parties then who want to 12 intervene, but then they will argue for some time on whether 13
'or not the contention, the issues, the particular issues of l
14 interest are within bounds or not and that is the scariest 15 part about the litigation is how much time is it going to 16 take before they focus on what the questions are that are 17 appropriate and how they are going to be addressed and that 18 is why there's been so much attention to the hearing process 19 improvements but there is a provision to notice the hearing 20 now but then go back at the completion of the staff 21 evaluation on the final environmental impact statement and 22 address the issue of late-filed contentions -- that is, new 23 issues -- and then the schedule also takes advantage of the 24 fact that we don't have to do this thing with couriers 25 anymore.
They will take advantage of electronic exchange l
{
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115 1
and other things in order to try and shorten the timeframe.
2 The General Counsel's office has spent a 3
tremendous amount of time looking at the back end of the 4
schedule and the Commission's policy statement will 5
encourage everything to make sure that there is amply 6
opportunities but at the same time expedited service.
7 DR. UHRIG:
Well, literally all a person has to do 8
is to say before the deadline that they want to intervene or 9
want to adjudicate this --
10 MR. GRIMES:
That's correct.
,11 DR. UHRIG:
You can give the flimsiest of reasons 12 to start with and then it gets expanded.
13 MR. GRIMES:
That's correct and then the 14 opportunity to clarify the contentions into particular 15
' issues in the prehearing conference and the whole rest of 16 that schedule now is just being made clear to me since we 17 now have noticed the hearing opportunity and how that fits 18 into our 585 day review schedule will be the next challenge, 19 plus Bob mentioned before that we are meeting next week with 20 NEI and the industry to talk about the priority of the 21 generic issues and so what you will see is we have got the 22 Calvert Cliffs review schedule and we will put the hearing 23 piece on that, and now we have just got the Oconee 24 application.
We will put that review schedule and its 25 hearing piece -- and its hearing opportunity will be noticed l
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1 a little bit sooner within the usual -- I think it is within 2
60 days -- and then on top of that we will have a schedule s
3 for addressing specific generic issues and so the milestone 4
tracking now has become an extremely large challenge at the 5
same time that the Commission has asked us to update our 6
operating plan to put in measurable goals and GPRA --
7 Government Performance and Resultti Act -- measures into the 8
process improvements, so we are getting re-engineered like 9
crazy, on the fly, as we try and proceed with these license 10 renewal applications.
11 Another feature that I want to point out l
12 specifically is Calvert Cliffs and Oconee probably won't
{
13-look much like the next applications.
Oconee may look 14 closer, but you'll find Calvert Cliffs is broken into 37 15 chapters organized more along how they carved the plant up, 16 systems, like commodities, and so forth.
17 Oconea packaged their license renewal application 18 more in terms of environments because the environment 19 relates back to the aging effects and so they found it 20 better to cut the matrix a different way and at the same 21 time our safety evaluation won't look like either one of 22 them because we are organizing our safety evaluation along 23 the lines of organization responsibilities and efficiencies.
24 I don't want three different branches responsible 25 for addressing the same aging management program, so I ask ANN RILEY & ASSOCIATES, LTD.
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for your indulgence.
You are going to have to take some 2
time to understand that the contents of the application and 3
the safety evaluations and the ultimate guidance that we put 4
into the standard review plan are all moving targets, but 5
they are going to be on stable ground.
6 Stability is going to be important from the 7
standpoint of planning and executing the schedules, so BG&E 8
has been told that they get -- there is a fairness 9
associated with their package is packaged the way it is and 10 we are not going to criticize them for packaging it that 11 way.
We'll respect the template that the Staff approved.
12 We'll respect the methodology that the Staff approved, but 13 we are going to use the standard review plan as best we can, 14 So you may have noticed that we haven't asked a 15 lot of questions so far.
We issued one set of RAI then we 16 spent four days in meetings talking about what BG&E had 17 supporting their application and why the Staff was asking 18 questions, and at the same time we recognized that we had 19 these generic issues that we had to maneuver around and so 20 that is why the interleaving of these things is now of 21 greatest importance to us, and you heard a lot about process 22 controls, the steering committee oversight, the executive 23 council oversight -- all of those things have put us in a 24 bright spotlight and now if I could just get the resources i
1 25 commensurate with that spotlight we would be home free, but t
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we are getting there.
t 2
We have gotten a lot more support over the last l
3 few months now that this has turned into a real live 4
program, and also I am pleased to report that despite the 5
threats of what is going to happen to our budget and the 6
debate that resulted from the Domenici proposal to the 7
Senate and subsequently Mr. McCabe -- no -- I'm sorry, I 8
can't remember now the Chairman of the House Appropriations 9
Committee, but despite those budget cuts we are seeing 10 substantially increased resources allocated for license j
11 renewal in the outer years now, so we have got management 12 support for the program.
)
i 13 Along those lines I would also like to mention 14 Hatch has come in and like Baltimore Gas & Electric they are
't 15 approaching us with a methodology in an attempt to try and 16 address some of these generic issues on a plant-specific 17 basis.
18 At this point we have looked over their proposed 19 methodology and we will begin a dialogue with them because 20 they are active in their interest -- interested -- but 21 suddenly other utilities have noticed that the Commission is 22 allocating resources on the basis of announced intent and so 23 when they said that we were cutting off the support for the 24 Westinghouse Owners Group topicals because we had no 25 announced intent, suddenly there's a rumbling in the bushes ANN RILEY & ASSOCIATES, LTD.
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1 and you can expect to see that there's going to be more 2
licensees coming in with letter of intent'in order to make 3
sure that they get their piece of the resources.
{
4 DR. SEALE:
The rhinoceros will charge out of the 5
brush.
6 MR. GRIMES:
That's correct.
7 DR. MILLER:
Question on BG&E, of course a 8
combustion plant, and if say another combustion plant came 9
in, would we still have the 585 days or would live generic 10 issues, generic to the CE plants, be resolved and the 11 schedule would be somewhat compressed or at least the 12 allocation of resources would be less.
13 MR. GRIMES:
Well, I would prefer to answer that 14 question in this way.
The 585 days was basically cut from
(
15 wholecloth that didn't take into account the contents of the 16 application.
It was simply how fast is as fast as we can 17 go, and with reasonable periods of time to breathe and 18 recognizing that there is more than just one of these -- we 19 probably could have done it faster than 585 days if we only 20 expected to do one application and then stop -- but we put 21 that schedule together recognizing that we were going to l
22
'have to interleave these milestones.
23 The next application will not likely come in until J
24 mid to late 1999.
By then we will have had enough 25-experience with the review schedules that it may be that 585 l-I ANN RILEY & ASSOCIATES, LTD.
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days ends up becoming a long, stretched out in time, because l,
2 of the numbers of applications that are anticipated or maybe 3
it will get shorter based on experience that shows that we 4
were able to manage more work in parallel activity so that l
5 you can compress some of the milestones.
6 Quite frankly, at this point I think it is just 7
too early to tell which will happen in terms of the 1
8 schedules.
Also we need to have at least a little bit of 9
experience fitting in these adjudicatory proceedings 10 schedules because that is what really tied us in knots on 11 the operating reactor reviews.
12 l
13 14 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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121 1
Was that we didn't account for the fact that the staff was 2
going to be distracted framing or responding to contentions, 3
preparing testimony, and doing some of those other things.
I 4
And that experience that I have tells me that I 5
need to make sure that that continues to be monitored in the 6
planning processes in terms of it's not as simple as just 7
assume that you can do legal activities in your spare time.
8 It needs to be fully integrated in the planning.
9 DR. MILLER:
Probably a better question I should 10 have-asked is, the time analysis of 585 days, did you also l
11 do a research analysis of --
12 MR. GRIMES:
Yes.
13 DR. MILLER:
-- people years or --
14 MR. GRIMES:
We have a matrix model that shows l
l-15 disciplines.
We attempt to try and keep it away from the l
16 organization and focus primarily on what kinds of talent do 1
l 17 we need.
18 But we've got a model that shows that, including 19 support for the hearing, that there's approximately 20 FTE 20 of effort over -- over this period, which is on the range of 21 30 to 35 months, and we expect to refine that model so that l
22 it can be used for future resource planning as we get 23 through the first few applications.
24 CHAIRMAN FONTANA:
But with regard to the public 25 hearings, some will -- some will be in parallel with the IJRJ RILEY & ASSOCIATES, LTD.
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122 1
schedule that we have here?
2 MR. GRIMES:
Yes.
3 CHAIRMAN FONTANA:
Interleave there.
4 Will any occur after the FES and SER's and will 5
they --
6 MR. GRIMES:
Yes, they --
7 CHAIRMAN FONTANA:
-- occur after what you've got 8
here --
9 MR. GRIMES:
The hearing is actually going to be 10 scheduled after the completion of the safety evaluation 11 supplement and the final environmental impact statement.
12 The schedule will take advantage of the technical 13 review time for the -- to identify standing of interveners 14 to scope the contentions, to focus on the issues and 15 controversy.
16 But then as soon as the staff completes its 17 finding, then there's another step that the interveners will 18 be offered an opportunity to see whether or not new 19 information has been revealed by the staff review that's 20 called, " late file contentions."
21 Then they focus what's going to be addressed in a 22 hearing, and then you schedule the hearing.
23 And so, hopefully, within the next few weeks, 24 you'll see the Commission's policy statement, and will also 25 have -- I don't know --
f 1
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Let's see.
Shortly after the hearing opportunity l
2 period closes, I expect to see a specific hearing schedule l
3 set forth.
But if nobody asks for a hearing, then we'll 4
just keep on marching to 500, maybe five days.
And we'll 5
see you in February.
6 DR. UHRIG:
Not likely.
7 DR. SHACK:
Is the BG&E application somewhat 8
anomalous because they've been at this for such a long time, 9
and did they have things that they started under the old 10 rule that somehow got recycled?
11 MR. GRIMES:
Yes, as a matter of fact, you'll find 12 the BG&E application was actually constructed to the 1991 13 rule and then repackaged, and you'll find a number of 14 references in the BG&E application aging mechanisms.
And 15 aging mechanisms was at the heart of the downfall of the 16 1991 rule, and we -- the 1995 rule focuses on aging effects.
17 There is no appreciable difference in the end, but 18 you will find that the packaging, the methodology and the 19 template, you know, all preceded the resolution of the 20 approach for the NEI 9510 implementation and --
21 DR. SHACK:
It just goes to the fact, again, it 22 won't be a particularly typical application.
23 MR. GRIMES:
It will be very atypical.
24 Like I said, Oconee will be closer to what we 25 think the -- you know, what we think the application content l
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124 i
1-will look like in the future.
But even there, as we learn 4
2 lessons and as we find better ways to' package the 3
information.
4 It's conceivable that after the industry sees our 5
safety evaluation report and the way that it has been 6
organized, because we're so sensitive to both being able to 7
identify responsible groups to support the safety 8
evaluation, and also because of the resource efficiencies, 9
-it's conceivable that they may want to reformat the 10 application to look more like the way we organize the safety 11 evaluation.
12 DR. UHRIG:
But doesn't the safety evaluation 13 basically follows the standard review plan?
14 MR. GRIMES:
No.
I 15 DR. UHRIG:
It does not?
16 MR. GRIMES:
The safety evaluation, right now, is 17 being organized more in terms of how the workload has been 18 distributed.
19 The standard review plan is organized more towards 20 the contents of'Part 54.
So -- and there are so many 21 different ways to package.
22 You know, you could have a whole section that just 23 does scoping, and then another one that does aging effects, 24 and then another one that it does aging management programs, l
25 which is sort of the way that Oconee has it.
And then you l
l l
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125 1
can go through, you know, and follow a particular system 2
structure or component across all of those things.
3 But we found that we addressed aging management 4
programs that apply to everything separate, and then 5
particular systems in terms of scoping age -- applicable 6
aging effects and aging management programs.
7 So it -- a lot of it has to do with just being 8
able to know who's responsible for what end state, and 9
that's workload management, primarily.
10 And speaking of workload management, I also want 11 to mention that we still have owner's group activities.
The 12 BWR owner's group, in addition to having an interest in 13 trying to pursue generic issues for boiling water reactors, 14 there is a lot of effort involved in a vessel internals i
15 program and what the staff refers to as the BWR VIP.
16 The vessel internals program for the BWR 17 stimulated -- stemmed from the core shroud cracking 18 incident, and now it's extending into managing aging effects 19 for vessel internals.
20 And the BWR owners have similar efforts, but i
21 that's the major renewal area for the BWR owners right now.
\\
22 And then we've completed two safety evaluations 23 for the B&W owners in support of the Oconee application that 24 we expected, and we have two more under review.
25 Now the two that have been completed, I would not i
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cay that those are typical of what we expect to do in the 2
future, either because of some of the lessons that we've 3
been learning on how to develop the model safety evaluation 4
for the application reviews.
5 But they are completed.
They have been 6
distributed to the ACRS, and they do represent the first 7
attempts of the staff to make findings under Part 54.
8 We have the other two B&W topical safety 9
evaluations nearing completion, and when those are l
10
. completed, we'll forward them to the ACRS, as well, and we 11 can talk about to what extent you want us to come over and 12 explain those topical report evaluations as representative 13 of generic work done by the staff.
14 And at the same time, as we mentioned before, we 15 expect that we will -- by that time, we'll also have shown
-16 you several resolution of generic issues, as well, which 17 will be documented in correspondence to NEI.
18 And so the nature of the way that we interact with 19 the Committee on generic matters is sort of, you know, 20 whatever you want.
21 The NEI task group that we mentioned before is --
22 I believe that they're meeting on like a monthly basis or 23 so.
I expect that that's about the frequency of interaction 24 that we'll have.
And we will, you know, start next week by 25 trying to establish priorities for the particular issues.
L Y
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The issue that's most important to the industry f
2 right now is credit for existing programs.
And as Mr. Prato 3
explained, that's our top priority, too, because the staff 4
wants credit for existing programs as much as the industry 5
wants credit for existing programs.
6 The difficulty is, what is the -- how do you take 7
that credit in the form of the contents of an application or 8
the contents of a safety evaluation?
9 They don't let us off the hook in safety l
10 evaluation content simply because we've got a maintenance 11 rule.
We don't let the utilities off the hook on content of 12 the application simply because they do comport -- conform 13 with 10 CFR 50.55(a), and therefore, have appropriate 14 in-service inspection activities.
15 But the way that those -- that that credit can be 16 articulated, either in the form of staff positions that say 17 it's sufficient for this aging management technique to 18 reference Section 11 of the Code, or it's sufficient for 19 this scoping activity to rely on this part of the 20 maintenance rule that categorizes certain stuff.
21 Those details need to be worked out in terms of 22 framing that credit for existing programs, and to very 23 discreet questions about which program, how much credit, 24 what does it ?.cok like?
25 And similarly, with some of the other issues like ANN RILEY & ASSOCIATES, LTD.
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operating experience.
Well, how much do you have to 2
explain?
3 Yes.
I know you've had operating experience, but 4
you're going to have to say a little bit more than, "I've 5
had operating experience."
And how germane is that either 6
to identifying the scope of aging effects, or taking credit 7
for aging management?
8 And the way that we want to address those issues 9
is to more clearly focus, "Well, what is the question you're 10 really asking?
What do you want to know?
What does the 11 application content look like?
What is the staff's 12 evaluation finding look like?"
13 And that will help us then to frame staff 14 positions that we can feed back into the standard review 15 plan.
16 And that 17 DR. UHRIG:
Well --
18 MR. GRIMES:
-- pretty well covers --
19 DR. UHRIG:
-- along that line, what does this 20 impending change on getting rid of the present evaluation 21 system for plants and going to the more general assessment 22 going to do to part of your program based -- the operating 23 experience part?
24 MR. GRIMES:
Are you referring to the alleged 25 dismantlement of the AEOD office?
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DR. UHRIG:
No.
I'm referring to going -- the
-2 SALP --
3 MR. GRIMES:
Oh, from SALP.
4 DR. UHRIG:
-- senior management.
5 MR. GRIMES:
-- senior management 6
DR. UHRIG:
Yes.
7 MR.' GRIMES:
-- process?
8 I don't -- I don't expect that the changes to that 9
system are going to have a dramatic effect on this program.
10 As I mentioned before, it comes -- it's more --
11 that's more oriented towards working very closely with the 12 regions to make sure that the competing effects on the 13 resources are clearly understood.
14 DR. UHRIG:
But it also gets rid of all the good
?
15 points that are pointed out, and it's almost a, "Yes, it's 16 satisfactory," and, "No.
It's not satisfactory," level of 17 decision here, as far as the plant.
18 Either you're satisfactory, and you continue 19 operating, or you're not, and you shut down.
That's what it 20 looks to me like it's getting to.
21 MR. GRIMES:
I'd hate to speculate --
22 DR. UHRIG:
That it have any effect at all?
23 MR. GRIMES:
Right.
Because, for one thing, I 24 know that there's -- that the Commission is in the midst now 25 of explaining to Congress exactly how we're going to improve I
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]
130 1
1 this process.
l 1
2 Reactor oversight will always be our
)
3 responsibility.
How we go about doing that and how we 4
manage the resources to do that, I'm sure will continue to 5
evolve over time.
6 But I don't -- and I don't foresee that the senior 7
management process is going to evolve to a point where we 8
just -- the resident says that the plant's either okay or 9
not.
10 There's going to be some inspection -- there's 11 going to be an inspection verification associated with a 12 license renewal --
13 DR. UHRIG:
I overstated the --
14 MR. GRIMES:
-- and --
1 15 DR. UHRIG:
-- situation.
16 MR. GRIMES:
Well, and I exaggerated your 17 overstn 4/>nt.
18 (Laughter.]
19 MR. GRIMES:
I don't -- but I don't think that 20 there are going to be changes that are so dramatic in the 21 senior management process that it's going to have -- that 22 it's going to have a profound effect on the region's 23 responsibility to make a -- to do their job of oversight and 24 provide us with a piece on a license renewal decision.
25 They will need to do some inspection verification.
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1 And at this poi"t, we're taking advantage of having to 2
understand how to do that with a minimal impact on resources 3
to help us focus what the technical review findings should 4
be that will make it easier for them.
l 5
So any other questions?
l 6
I have -- I briefly went back and enumerated the 7
milestones as we intend to monitor them for the application 8
reviews.
We've got complete RAI's, technical and 9
environmental, draft safety evaluation and environmental 10 impact statement, and then the final, which for BG&E, the 11 safety evaluation and the safety evaluation supplement, 12
: November,
'99.
13 There's a lot of time between now and November of 14 1999.
And we would like to come back and tell you about how i
15 we've progressed at appropriate points.
16 I think as a minimum, we could make a presentation 17 to the ACRS after we've had a draft safety evaluation --
18 actually, we call that the safety evaluation report with 19
-open items, the traditional, you know, first issuance of the 20 safety evaluation, which is the way that we did it for the 21 operating license.
22 But between now and then, I expect that we 23 probably should come back and talk some more about the 24 generic issues so that you're not -- so that you see the 25 first staff product in context.
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And I think, suffice it to say at this point, just 2
explaining the schedule to you and the process, that we can 3
work out particular schedule details with -- with Med on 4
what works for you.
5 You probably should wait to see what the 5
adjudicatory schedule is, as well, so that you -- you know,
~
where the milestone might fit.
And also, we'll be 8
publishing the Oconee schedule.
9 So with those -- armed with that information, I'm 10 sure that we could pick a few dates, you know, tr art of 11 work this along.
12 We're not. going to wait until February the 14th, 13 year 2000 and come in and say, "Okay.
We're ready.
Give me 14 a letter."
15 DR. MILLER:
You know, I think it's good that we 16 l discuss the ACRS involvement because I done a little i
17 !
thinking about this and I think the Committee can play a l
18 multiple of roles that help facilitate this process.
19 One, of course, we are a public meeting, so it 20 does give us a public forum.
And, of course, anybody that's 21 ;
in the public can appear and make comments.
22 '
The second, I think, historically -- recent l
23 !
history I've been on, I think the Committee has been l
24 valuable in providing a sounding board for problem areas and l
helping to resolve -- if there is differences between the 25 I
l l
[
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133 1
industry's perspective and your perspective, I think we can
; t-2 help'in that -- that arena.
l-
'3 And the third is, hopefully, we'll provide a 4
1 valuable technical input'and feedback to you.
L l
5 So I think with all those issues where we can
'6 play, I think it's a very important process that we can be a 7
; valuable -- have a valuable input to this process.
And
:8 maybe that will help decide when we should be involved and I
9 when we shouldn't, and so forth.
10 MR. GRIMES:
No.
I agree completely.
I've always 11 found that the ACRS meetings, the Subcommittee meetings and 12 the full Committee meetings both give us an opportunity to 13 stop and,.as you say, we can do a -- we can do a ground 14 check,. because just in the nature of trying to come -- to 5
15 organize our thoughts and come down and explain to you what 16 we're doing, we get a chance to get a fresh focus on what's 17-happening?
What are we doing and why are we doing it this 18 way?
19-Mut, also, as I mentioned, there are -- there is a 20
. lot of different perspectives on'this thing.
We can come 21:
talk-to.you about particular sets of generic issues.
- 22 As I mentioned before, the -- for some of these 23 issues, we can just tell you that there is sort of work in 24 progress because line. management wants, you know, first 25
' crack at what.the staff should -- position'should be, and 1
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also, I want line management held accountable for supporting 2
decisions on what action should be taken so that 3
So that the Steering Committee's advisory role 4
functions properly, but beyond that, at any point in time we 5
are always prepared to come tell you where we stand and 6
which issues are resolved and which aren't.
And at this 7
point I think it is -- what I would, the feedback that I 8
would like from the Committee is in terms of, we will give 9
you these schedules, we will identify the priority of 10 workload, and do you -- how do you want for us to bring the 11 information to you, and how can we package it?
12 We don't want -- I don't want to be down -- I 13 don't want you to be down here every week, because this week 14 I will come to you with this B&W topical SER.
Next week I 15 will be back with the fatigue position, week after that.
We 16 can create a monster, as a matter of fact, and we have 17 learned how to create a scheduling monster in terms of 18 breaking the work down into two fine a detail.
That's why 19 we are focusing now on these major program milestones rather l
l 20 than the detailed PERT charts.
And as far as I am 21 concerned, whatever is convenient for you.
I 22 CHAIRMAN FONTANA:
Okay.
1 I
23 MR. GRIMES:
That's why you will find there is no 24 last slide on future activities.
We are now prepared to go l
l 25 into a listening mode.
I l
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CHAIRMAN FONTANA:
Yes.
The timing that you 2
discussed seem to match what I had in mind from looking at 3
this.
So it looks like we are on the same page here.
4 Have you reached the end of the agenda?
5 MR. GRIMES:
Yes, I have.
6 CHAIRMAN FONTANA:
Okay.
7 MR. GRIMES:
We are now -- the last point on the 8
agenda is future activities and I am now --
9 DR. UHRIG:
And it's 4:15.
10 MR. GRIMES:
And it's 4:15.
11 CHAIRMAN FONTANA:
Well, great.
Maybe we can all 12 do them this way.
13 Do you have comments, George?
14 DR. APOSTOLAKIS:
No.
15 CHAIRMAN FONTANA:
No.
Do we have comments from 16 the Subcommittee?
17 DR. MILLER:
Well, one could ask -- be very 18 optimistic.
You are talking resource planning.
What would 19 happen -- this blue sky, we had -- everybody got excited i
1 20 about license renewal and within the next five years, 80 21 units came in with renewal applications with that.
22 MR. GRIMES:
Fifteen, actually, I think is --
23 DR. MILLER:
Well, let's just say 80.
24 MR. GRIMES:
Now, there's a window, you can't 1
25 submit more than 20 years prior to expiration.
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DR. MILLER:
Okay.
You probably have that.
2 MR. GRIMES:
Yeah, we crunch these numbers like 3
crazy.
You have to submit five years before and we have 4
struck the announced plants that are going to decommission.
5 And there's like 56 units that could be here by the end of 6
the year.
Practically speaking, it will take them 12 to-18 7
months to prepare an application, even if they had perfect 8
knowledge about the contents of the application.
9 So, but we are -- the Executive Council looked 10 long and hard at that budget assumption that said that we 11 will get two applications in '98, two applications in '99 12 and then it was, well, are we going to say for the year 13 2000? 'Because it could be two more if you are stable, or it 14 could go to 50.
And so at that point they said the year i
15 2000, and they looked at the -- you know, they looked at the 16 feedback they are getting from Congress and they said, two 17 in the year 2000, four in 2001.
So they show this spike 18 coming up in 2001.
19 I have a personal opinion that by next year they I
20 will change that budget assumption for the year 2000.
l 21 DR. MILLER:
It'll go up?
j 22 MR. GRIMES:
It'll go way up.
23 DR. UHRIG:
The applications are usually for all 24 the units?
25 MR. GRIMES:
Yes.
They normally make the ANN RILEY & ASSOCIATES, LTD.
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137
?
1 application in the same way that they applied for an 2
operating license.
So if they --
l 3
DR. UHRIG:
Well, it depends on the individual L
4 situation.
The St. Lucie had two separate.
)
5 MR. GRIMES:
Right.
1 i
6 DR. UHRIG:
For instance, I am thinking of Brown's i
7 Ferry.
I would never envision Brown's Ferry Unit 1 coming
)
8 in for a license renewal.
It would be 2 and 3.
9 MR. GRIMES:
But they may submit an application 10 for 2 and 3.
11 DR. UHRIG:
Yeah.
12 MR. GRIMES:
At the same time they submit their 13 decommissioning plan for Unit 1.
14 Now, we have spent a lot of time, you know, 15.
looking at the table.
As a matter of fact, that table of 16 license expirations is in the NRC Information Digest.
And 17 we frequently go back to that to show the groupings of 18 plants by years.
And it is not going to be just the 19 expiration date.
Because of things like, well, if they --
20 you know, they postponed a unit for construction completion,
]
21 they may very well come back and apply for, you know, a two 1
I 22 unit license renewal.
23 DR. UHRIG:
There is also the issue that keeps I
24 coming up about a plant that needs major expenditures, steam 25 generators.
You literally have to make a decision at that l-ANN RILEY & ASSOCIATES, LTD.
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138 l'
point whether to come in for license renewal or to shut it 2
'down early.
.3 MR. GRIMES:
Yes.
1 l
4 DR. UHRIG:
And it may be 30 years or 35, or
'I 5-something of this sort, not 40.
l 6
MR. GRIMES:
That's correct.
And that was one of 7
the public criticisms last. week.
You know, it did not go 8
unnoticed that BG&E announced that they were pursuing their 9
license renewal application at the same time that they 10 funded their new steam generators, which caused Mr. Riccio 11 from Critical Mass to say the only thing that is green about 12 this issue is the color of money.
License renewal doesn't 13 have a thing to do with it.
They are just looking for a way 14 to hoodwink their ratepayers.
15 Now,-that's not -- that is probably one good 16 reason why the NRC and the PUCs do not integrate.
Because I 17 don't think that -- you know, we have got a tough enough job 18 trying to figure out what it is going to take to make a 19 license. renewal decision without getting into what all those 20 economic environment influences are.
21 DR. UHRIG:
But that's management's decision.
22 MR. GRIMES:
That's correct.
I 23 DR. UHRIG:
It's a utility management decision.
l l
24 MR. GRIMES:
Right.
And in the face of 25 deregulation, the utility managers have clearly said that 1
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l 139 l
1 license renewal is a factor and how to make that decision,
(-
2 and how to project what it means to them economically, in 3
the face of deregulation, is more complicated than resolving 4
fatigue, I can tell you.
I 5
DR. UHRIG:
Well, I think when a utility has to l
I 6
pay $4 for a kilowatt hour of electricity --
1 I
7 DR. MILLER:
Seven.
)
l 8
DR. UHRIG:
Is it $7?
J 9
DR. MILLER:
Seven.
I 10 DR. UHRIG:
I have heard various numbers.
: But, j
l 11 anyhow, whatever it is, it has got a dollar sign on it.
12 That's a shocker.
And it has a tremendous impact on the 13 bottom line.
14 MR. GRIMES:
Yes.
But, we -- you know, we get 15 into that only insofar as the Commission has established a 16 policy on their regulation effects, and trying to guess what 17 plants might come in when.
I 18 But I can tell you that utilities -- part of the l
l 19 reluctance about making an announcement about license l
20 renewal is because of the impact it has on Wall Street.
And 21 they are -- you know, the utilities are spending money on 22 license renewal work.
We know that they are doing it.
But 23 they haven't announced, made a formal announcement of when 24 they expect to make a submittal.
25 DR. UHRIG:
That's just there's usually an 4
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140 1
evaluation of what they are doing.
2 MR. GRIMES:
Yeah.
3 DR. UHRIG:
Scoping it out, what is it going to 4
cost us to go ahead with license renewal, and what are we i
l-5 going to have to do after we have got this, in terms of 6
major components?
7 MR. GRIMES:
I expect Southern Company found that 8
when the scoping study reached $6 million for Hatch, that 9
they thought they might as well just confess they were going 10 for it.
11 But that part of the budgeting process about how 12 many applications are going to occur and when, we don't see 13 that as a problem that is going to affect our fiscal '99 l
14 situation, because we expect that we are going to be working 15 these two applications until probably next summer, the 16 summer of
'99, before we see the next applicant.
But by 17 then we may have lots of announced intents and folks coming 18 in wanting to pursue issues on a plant-specific basis.
And 19 I can tell you that I'll be trying to deflect them to the 20 industry task force and say, to the extent that we can 21 resolve these issues generically, we want to do that, so 22 that we can conserve our resources to make sure that we 23 fulfill the application milestones.
Because that is our l
l 24 primary -- the primary success measure is going to be 25 meeting those milestones.
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141 1
And then our secondary measure, success measure, l
2 that you might as well start thinking about now, is with a l
3 quality safety evaluation finding, if you have any 4
suggestions on how we measure the quality of the safety 5
evaluation finding, I would be pleased to put those in our 6
operating plan.
7 DR. SEALE:
We referred earlier to the -- I think 8
I called it the rhinoceros that was charging out of the 9
bush.
Certainly, the Westinghouse Owners Group has had some 10 discussions about license renewal and I would -- and they 11 have been talking to you, that is my recollection.
12 MR. GRIMES:
That's correct.
l 13 DR. SEALE:
In this budget, with the budget 1
14 limitations you have and so forth, you are continuing your 15 discussions with Westinghouse on generic issue resolution 16 and so forth.
So it is not as if the Westinghouse PWR 17 status was on hold.
18 MR. GRIMES:
No, but it's about as close as you 19 can get.
20 DR. SEALE:
Okay.
So --
21 MR. GRIMES:
And the reason being because right 22 now about the only feedback that Westinghouse is getting is 23 through their representation on the industry task force.
24 All of their topical report reviews, the review schedules 25 are suspended until we are sure that we have all the l
l i
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142 1
resources we need to support Calvert Cliffs, Oconee, the B&W i
2 topicals, the BWR VIP, and then whatever time it takes us to 3
comment on Hatch methodology.
So that makes the 4
Westinghouse topicals No. 6 on the list of things to do.
5 DR. SEALE:
Sure.
Sure.
6 MR. GRIMES:
So if I have run out of everything 7
.else to de, and I skip lunch today and I have an extra 15 8
minutes, a Westinghouse topical will get worked on.
It 9
might be a mild exaggeration, but that's about the 10 situation.
11 DR. SEALE:
So you would have something, either a 12 conundrum or a piece of paper in hand real quickly to go to 13 the Commission and say I need some relief, if Westinghouse 14 suddenly made that a priority issue.
l 15 MR. GRIMES:
Actually, it works the other way 16 around.
It's not so much that we ask for relief, it's we 17 ask them what do you want us to kick off the plate --
18 DR. SEALE:
Okay.
Sure.
to, you know, to start providing 19 MR. GRIMES:
20 staff time to address these things.
21 DR. SEALE:
It gets nudged out.
22 MR. GRIMES:
Right.
23 DR. SEALE:
Okay.
24 CHAIRMAN FONTANA:
Any additional comments?
25 DR. POWERS:
It must be nice to be so popular.
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143 1
CHAIRMAN FONTANA:
Any comments from the floor?
2
[No response.]
3 CHAIRMAN FONTANA:
Well, thank you very much.
I 4
think this has gone very well.
And if you can go through 5
your schedule here as quickly as you went through the 6
meeting today, you shouldn't have any problem.
But my 7
experience is, in looking in projects in the past, is that 8
that often the best you can do is a factor of pi over two.
9 MR. GRIMES:
That's the best?
10 CHAIRMAN FONTANA:
You would be amazed how often
-11 that pops up.
12 MR. GRIMES:
As soon as we get the rest of the 13 milestones stuck into the computer, I'll make sure to put a 14 pi over two factor on each of the milestones, see how close il 15 this --
16 DR. UHRIG:
What's the basis for that pi over two?
17 CHAIRMAN FONTANA:
I'll explain it to you later.
18 There is a basis for it.
You lay out a program the best you i
19 know how.
'20 DR. POWERS:
We can let these guys 90.
21 CHAIRMAN FONTANA:
And then you'll find that more 22 often that not, it'll take about 50 percent more, and 23 there's a real good reason for that.
i 2 41
.But, anyway -- nell, thank you very much.
25 MR. GRIMES:
You're welcome.
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144 1
DR. UERIG:
.57, huh?
2 CHAIRMAN FONTANA:
Yes.
q 3
MR. GOT.MES:
As I mentioned before, you will 4
continue to see materiala from us, letters to NEI, the 5
questions that go out to the -- Steve, is the ACRS on the 6
RAI letter list distribution?
7 MR. HOFFMAN:
I would have to go back and look.
8 DR. EL-ZEFTAWY:
I don't think so, not on RAI.
9 DR. POWERS:
Not. typically do we get -- we do not 10 typically get RAIs.
Sometimes RAIs are pretty challenging 11 to interpret.
12 MR. GRIMES:
They can be, if they are taken out of 13 context.
Yeah, if you just look at one set of requests for 14 additional information, then you won't understand.
But to 15 the extent that we can share information in context that is
)
16 useful for you, and also continue to work with Med to 17 schedule periodic sessions like this to tell you where we 18 are and where we are going.
19 DR. POWERS:
On the subject of RAIs, I would 20 suggest that if you find something that you think would be 21 significant to share with the Committee, that you maybe 22 bounce it off Med.
23 MR. GRIMES:
Okay.
24 DR. POWERS:
And whatnot, and he might be able to 25 give you some idea of the contextual material that better ANN RILEY & ASSOCIATES, LTD.
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l 145 1
accompany it, - or otherwise, we look at it -- What in the-2 world is this!
4_
3 DR. SEALE:
Uhere did this thing come from?
4 MR. GRIMES:.Sure.
5 DR. UHRIG:
Furthermore, we don't need any more 6-paper at home.
7
-DR.
POWERS:
Well, the problem -- the problem they 8
will get into is either they are wasting the paper and their 9
. time, or they prompt a confusion, and we thi'nk you are doing 10 something that you didn't really think you were doing.
And 11 that usually results in spending a lot of time explaining 12 things two or three times.
13 MR. GRIMES:
I understand.
So we will be very 14 careful about sharing information with you, but at the same 15 time schedule something, 11 6 DR. POWERS:
It's just that the RAIs are in a 17 context of-documents that aren't right with them, and the 18 documents.-- you and who you are writing to are very 19 familiar with, and we won't'have that facile familiarity.
20 CHAIRMAN FONTANA:
Well, you'll be in day to day 21 contact with Med on the work that needs to be done.
22 MR. GRIMES:
Yes.
23 CHAIRMAN FONTANA:
Well, thank you very much.
And 24 I appreciate your time, effort and cooperation, and this is 25~
the end of the meeting..
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-___-______-_Q
 
146 I
1 MR. GRIMES:
Thank you.
l I,
2
[Whereupon, at 12:17 p.m.,
the meeting was 3
concluded.)
4
.5 6
7 8
)
9 l
10 11 12 13 14 I
15 16 17 18
.19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
PLANT LICENSE RENEWAL DOCKET NUMBER:
PLACE OF PROCEEDING:
Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a ' rue and accurate record of the foregoing proceedings.
I h bN 4 td l
Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
l l
l k
1 i
 
1 INTRODUCTORY STATEMENT BY THE CHAIRMAN OF THE PLANT LICENSE RENEWAL SUBCOMMITTEE 11545 ROCKVILLE PlKE, ROOM: T-2B3 ROCKVILLE, MARYLAND JULY 16,1998 The meeting will now come to order. This is a meeting of the ACRS Subcommittee on Plant License Renewal.
I am Mario Fontana, Chairman of the Subcommittee for Plant License Renewal.
l l
The ACRS Members in attendance are:
George Apostolakis, Don Miller, Robert Seale, William Shack, Dana Powers, and Robert Uhrig.
The purpose of this meeting is to discuss the NRC staffs activities associated with license renewal, proposed staffs plans and schedule for reviewing the license renewal application and related safety issues. The Subcommittee will also discuss the ACRS involvement in reviewing the license renewal submittal and related matters. The Subcommittee will gather information, analyze relevant issues and facts, and formulate proposed positions and actions as appropriate, for deliberation by the full Committee.
Medhat El-Zeftawy is the Cognizant ACRS Staff Engineer for this meeting.
l The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the Federal Register on June 29,1998.
A transcript of the meeting is being kept and will be made available as stated in the Federal l
Register Notice. It is requested that the speakers first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.
We have received no written comments or requests for time to mike oral statements from members of the public.
(Chairman's Comments-if any)
We will proceed with the meeting and I call upon Mr. Frank Miraalia of the Office of Nuclear Reactor Regulation to begin.
4
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NRC STAFF PRESENTATION l
TO THE ACRS LICENSE RENEWAL SUBCOMMITTEE I
JULY 16,1998 STATUS OF LICENSE RENEWAL L
 
1 l
1 i
ACRS LICENSE RENEWAL SUBCOMMITTEE BRIEFING STATUS OF LICENSE RENEWAL JULY 16.1998 1.
Introduction Dr. Fontana ll.
License Renewal Steering Committee Frank Miraglia Ill.
Implementation Guidance Development Bob Prato A.
Inspection Program B.
Office Letter IV.
Resolution of issues Bob Prato V.
Staff Renewal Activities Chris Grimes A.
Baltimore Gas & Electric - Calvert Cliffs B.
Duke Energy - Oconee C.
Southern Nuclear - Hatch D.
Owners Groups E.
NEl VI.
Future Activities Chris Grimes t
 
LICENSE RENEWAL STEERING COMMITTEE Membership Responsibilities Review:
(1)
Status of staff's review of applications and generic technical reports (2)
Status of the resolution of technical and process issues identified by the applicants, industry, public, and staff (3)
Effort expended relative to the planned i
accomplishments in NRR Operating Plan 1
Recommend actions to improve processes and resolve related issues Identify topics to be conveyed to Executive Council and Commission Meet with applicants and NEl
 
1 t
e, The Commission 9;
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Chairman U-Executive councli 6
6A.W 2A4 wad Executive Director for Operations Deputy Executive Director Regulatory Programs License Renewal Director Nuclear Reactor Regulation Steering committee Division of Reactor Associate Director.
inspection &
Program Technical Review Support Programs Management l
l Generic issues &
License Renewat Environmental Project Directorate Projects Branch IE_-----_--
 
i NRC INSPECTION PROGRAM FOR LICENSE RENEWAL (LRIP) l PROGRAM STRUCTURE 1
)
PROGRAM STATUS I
PROGRAM IMPLEMENTATION l
 
1 l
l LRIP STRUCTURE LICENSE RENEWAL APPLICATION INSPECTIONS i
PROGRAM DOCUMENTATION l
AGING MANAGEMENT PROGRAM IMPLEMENTATION l
AGING MANAGEMENT PROGRAM EFFECTIVENESS i
l l
RENEWED LICENSE INSPECTIONS LICENSE CONDITIONS LICENSEE COMMITMENTS l
AGING MANAGEMENT PROGRAM EFFECTIVENESS
 
LRIP STATUS LICENSE RENEWAL MANUAL CHAPTER LICENSE RENEWAL INSPECTION PROCEDURE AGING MANAGEMENT PROGRAM INSPECTION PROCEDURES FEEDBACK PROCESS l
i TRAINING PROGRAM l
l l
 
LRIP IMPLEMENTATION l
LICENSE RENEWAL APPLICATION !NSPECTIONS SCOPING SCREENING IDENTIFYING AGING EFFECTS i
AGING MANAGEMENT PROGRAM DOCUMENTATION AGING MANAGEMENT PROGRAM IMPLEMENTATION OTHER AGING EFFECTS TLAA/ EXEMPTION DOCUMENTATION REVIEW DEMONSTRATION RENEWED APPLICATION INSPECTIONS LICENSE CONDITIONS LICENSE COMMITMENTS CONTINUED EFFECTIVENESS OF AGING MANAGEMENT
{
j.
PROGRAMS j
i l
1
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i
 
l LRIP IMPLEMENTATION LICENSE RENEWAL APPLICATION INSPECTIONS LETTER TO ras MEETING WITH REGIONS TRAINING IMPLEMENTATION ACTIVITIES o
REVIEW o
SCOPE OF INSPECTION o
OVERLAY OF IMC 2515 o
DEVELOP INSPECTION PLANS FOR CALVER CLIFF
)
AND OCONEE j
o IMPLEMENTATION SCHEDULE
]
o FUTURE MEETINGS I
RENEWED LICENSE INSPECTIONS CORE PROGRAM REGIONAL INITIATIVES RESOURCES l
i
)
 
NRR OFFICE LETTER 805 OFFICE LETTER -
LICENSE RENEWAL APPLICATIONS REVIEW PROCESS GUIDE FOR REVIEWING LICENSE RENEWAL APPLICATIONS GUIDE FOR PROCESSING RENEWED LICENSE ACTION ITEMS I
GUIDE FOR TECHNICAL AND PROCESS LESSONS LEARNED FOR LICENSE RENEWAL 1
1
 
I Figure 1. LRA Review Process i
Industry / Applicant Applicant: Tender
,p m
m l
Activities Application j
1r
'Obtain TAC (s) i I'
IP <
Acceptance Review
; Return to Applicant
;,3 Accept Notification &
l iP Environmental Review Opportunity for l
Public Hearing 1
P 1r Develop Contractor W rk Planning Scope, j
Schedule, and Public Hearing j
S0W Resources j
i 1
1r l
1r 1r l
1 DSSA IPA /TLAA DE lPA/TLAA Review 1
DR Support ',
Review (SRP-LR)
(SRP LR)
+
contractor SUDDort IP 1r RAls l
3r IP Response to RAls
:l 3r IP SER Development
,.)
3r Final SER f:
LtLR l
)
issue Points IP 4 ACRS Review / Report
{
IP Q
\\
License Renewal Action LILR Renewed License items ti tg
*1
.e lad I
 
Figure 1. License Renewal Action item Process LRA Review &
Verification 1r
/
\\
i LlLR 1
\\
h i
ir w'
1r Originator Fills Out Ll-l Documented in SER LR Tracking Form l
l J
u PM Input LI LR into RLID FSAR Supplement Input License Condition PM Reviews Final Licensing Documents to Verify All LI LR are TS Requirement IP LR inspection
, input m
Report 1 r PM Forward Renewed f
Verified License for Final Approva!
l Ll LR Tracking Forms l
m Sent to File l
l 1
Copies of RLID Sent to Input into Operating m
PM and Regions Reactor Program 2
 
Figure 1 - LR Less@ns Learned Issue Documented &
IP Forwarded to issue
..J Coordinator (IC) 1r i
IC Enters issue in Tracking System &
Assign to issues Responsible individual (IRI) i r IRI Plans & Schedules PD/ Branch Assignment Resolve Priorities ir Management involvement Pro osed Branch Level t Options Evaluation Process:
Division Level to Determine Options /
Executive Team Level Resolution As Needed to Resolve issue Resolution
~
1r ir Commission Level issue Resolution issues Review & Approval 1
Approval 3r
,y IRI Coordinates Policy /Rulemaking Changes / Process Positions I
k I
l SRP LR Coordinator:
RG Coordinator:
IP LR Coordinator:
PDLR Rev.ise OL 805 l
Revise SRP LR as Revise DG 1047 & NEl Revise MC & IPs as as Necenary Necessary 9510 as Necessary Necessary l
l l
l Y
Revision (s) Verified by IRI t
IC Closes issue u
I 4
l l
i.
_______________-___A
 
\\
NRR OFFICE LETTER 805 STATUS OFFICE LETTER 805 - APPROVE JUNE 19,1998.
GUIDE FOR REVIEWING LICENSE RENEWAL APPLICATIONS IS IN PLACE AND BEING IMPLEMENTED GUIDE FOR PROCESSING RENEWED LICENSE ACTION ITEMS -
A DATABASE IS IN PLACE AND FORMS HAVE BEEN DEVELOPED GUIDE FOR TECHNICAL AND PROCESS LESSONS LEARNED FOR LICENSE RENEWAL IS VERY ACTIVE
 
1 License Renewal Issues 1.
Credit for Existing Programs 2.
Demonstration Detail 1
3.
Operating Experience 4.
Component Failure / intended Functions 5.
App!icable Aging Effects 6.
Generic Safety issues 7.
Risk-Informed License Renewal i
8.
Component Lists l
9.
FSAR Content l
10.
Time-Limited Aging Analysis Timing 11.
Passive / Active Determinations 12.
Consumables l
l 13.
Degradation Induced by Human Activity I
 
l t
EPRI Issues 1.
Fatigue of metal components 2.
Environmental qualification of low-voltage, in-containment cables -
l 3.
Thermal embrittlement of cast austenitic stainless steel components 4.
' Irradiation-assisted stress corrosion cracking of reactor internals 5.
Stress relaxation of pressurized water reactor internals components i
6.
Primary water stress corrosion cracking of high-nickel alioy components 7.
Stress corrosion cracking of PWR reactor coolant system components 8.
Degradation of Class i small bore piping 9.
Neutron irradiation embrittlement c' reactor vessel beltline materials l
10.
Ultrasonic inspection of pressure vessels and components l
11.
Visual examination of components and structures l
12.
One-time inspections of concrete and steel structures l
L 13.
Freeze-thaw damage in concrete containment structures 14.
Alkali-aggregate reactions in concrete containment structures 15.
Differential settlement in PWR containments and Class 1 structures 16.
Reinforcement corrosion in PWR containments 17.
Void swelling of reactor internals i
 
f STAFF RENEWAL ACTIVITIES l
BALTIMORE GAS AND ELECTRIC - CALVERT CLIFFS I
l DUKE ENERGY - OCONEE SOUTHERN NUCLEAR - HATCH OWNERS GROUPS NEl i
I I
i
)
i l
I f
!}}

Latest revision as of 22:09, 22 May 2025

Transcript of 980716 Plant License Renewal Meeting in Rockville,Md.Pp 1-146.Certificate & Supporting Documentation Encl
ML20236T087
Person / Time
Issue date: 07/16/1998
From:
Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-3047, NUDOCS 9807270426
Download: ML20236T087 (167)
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DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JULY 16, 1998 b

l The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory

- Committee on Reactor Safeguards, taken on July 16, 1998,-as reported herein, is a record of the discussions recorded at the meeting held'on the above date.

This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.

t c

F

1 i

1 UNITED STATES NUCLEAR REGULATORY COMMISSION j

2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l

l l

3 l

4 PLANT LICENSE RENEWAL 5

l 6

1 7

U.S. Nuclear Regulatory Commission i

8 Two White Flint North, Room 2B-3 9

11545 Rockville Pike 10 Rockville, Maryland

]

l 11 q

12 Thursday, July 16, 1998 13 14 The committee met, pursuant to notice, at 8:30 15 a.m.

16 17 MEMBERS PRESENT:

18 MARIO FONTANA, Chairman, ACRS 19 GEORGE APOSTOLAKIS, Member, ACRS I

20 DON MILLER, Member, ACRS 1

21 ROBERT SEALE, Member, ACRS 22 WILLIAM SEACK, Member, ACRS i

23 DANA POWERS, Member, ACRS 24 ROBERT UHRIG, Member, ACRS l

25 i

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PROCEEDINGS 2

(8:30 a.m.]

3 CHAIRMAN FONTANA:

The meeting will now come to 4

order.

5 This is a meeting of the ACRS Subcommittee on 6

Plant License Renewal.

I'm Mario Fontana, Chairman of the 7

Subcommittee on Plant License Renewal.

8 The ACRS members in attendance are George

.9 Apostolakis, Don Miller, Robert Seale, William Shack, who 10 will be here in a minute, Dana Powers and Robert Uhrig.

11 The purpose of this meeting is to discuss the 12 NRC's staff's activities associated with license renewal, 13 proposed staff plans and schedule for reviewing the license 14 renewal application, and related safety issues.

15 The Subcommittee will also discuss the ACRS 16 involvement in reviewing the license renewal submittal and 17 related matters.

18 The Subcommittee will gather information, analyze 19 relevant issues and facts, and formulate proposed positions 20 and actions as appropriate.

l 21 Our experience has been that interactions with the 22 ACRS at appropriate times have led to a much smoother 23 process and final agreement than has been the case in 24

-instances where the ACRS reviews were delayed until the very 25 end, and we hope to identify natural points in the process ANN RILEY & ASSOCIATES, LTD.

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3 1

whora mastings bstwacn tha license renewal participants and 2

the ACRS would be beneficial.

3 Medhat El-Zeftawy is a cognizant ACRS Staff 4

Engineer for this meeting.

5 The rules for participation in today's meeting has 6

been announced as part of the notice of this meeting 7

previously published in the Federal Register on June 29th, 8

1998.

A transcript of the meeting is being kept and will be 9

made available as stated in the Federal Register notice.

10 It is requested that the speakers first identify 11 themselves and speak with sufficient clarity and volume so 12 that they can be readily heard.

13 We have received no written comments or requests 14 for time to make oral statements from members of the public.

15 We will proceed with the meeting, and I call upon Mr. Frank t

16 Miraglia of the Office of Nuclear Reactor Regulation to 17 begin.

18 MR. MIRAGLIA:

Can you hear me now?

19 CHAIRMAN FONTANA:

Yes.

20 MR. MIRAGLIA:

Okay.

Thank you, sir.

21 Thank you, Dr. Fontana.

22 My name is Frank Miraglia.

I'm Deputy Director of 23 the Office for Nuclear Reactor Regulation.

24 I'm here with two objectives today:

First as the 25 Deputy Director of the program office responsible for the ANN RILEY & ASSOCIATES, LTD.

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4 1

implementation of the license renewal program for power 2

reactors, and second, I have an additional role of being 3

Chairman of the License Renewal Steering Committee, and I'll 4

be presenting-to you what that role of that committee is.

5 Subsequent to my remarks, Chris Grimes, the 6

Project Director for License Renewal, will be putting the 7

context -- in context the agenda for today, which is shown 8

on this slide, which is in your handout.

9 My primary purpose is to talk about the Steering i

10 Committee.

11 License Renewal, as a program, has been receiving 12 elevated interest in the industry.

The Chairman made 13 License Renewal the centerpiece of her remarks at the Reg 14 Information Conference that was sponsored by the Office of l

15 Reactor Regulation in May of this year, and the Commission j

16 has expressed an interest in orderly conduct and -- of that 17 program.

18 In that regard, the Chairman chartered the 19 Executive Council, which is the CFO, CIO and EDO to monitor 20 the progress of the program to assure that it's proceeding i

21 apace and has the right type of attention in terms of policy 22 issues and resources, i

23 In line with that interest from above and from l

l 24 outside the Agency, from an office perspective, there is 25 that same sort of interest.

And Sam Collins commissioned a ANN RILEY & ASSOCIATES, LTD.

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5 1

Steering Committee -- Licenso Renewal Steering Committee.

2 I believe you have in your packages an April 29th memo which 3

was the charter for this Steering Committee.

4 The membership of the Committee is the NRR 5

Executive Team.

These are the principal directors that will 6

be participating in the review of the program to assure that 7

there is management attention from within NRR.

8 The membership also includes a representative from 9

the Office of General Counsel, a member from the region, and 10 a member from the Office of Research.

11 The purpose of the Steering Committee is to advise 12 the Director of Regulation on the progress of the review and 13 issues in terms of the status of review for the specific 14 applications.

15 As you are probably aware, we do have two 16 applications for review.

One is Calvert Cliffs Baltimore.

17 Gas & Electric, which was proffered in May -- April.

And 18 then last week, Duke Power submitted an application for the 19 Oconee Units for renewal.

So there are two specific 20 applications under review.

21 In addition, there is an industry steering group 22 and working group following generic issues and generic 23 reports, and the staff is working through NEI to coordinate 24 those reviews.

And so there will be generic issues and 25 technical issues from that venue.

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DR. UHRIG:

Those applications, do they include l

2 all units, the three units at Oconee --

3 MR. MIRAGLIA:

That's right.

4 DR. UHRIG:

-- and two at Baltimore?

5 MR. MIRAGLIA:

Yes, sir.

Yes, sir.

And the staff 6

is prepared to give you more details on the current 7-schedules.

8 Dr. Fontana, you asked and indicated points at 9

which interaction with the ACRS might be appropriate, and I 10 think when the milestones are described, I think there will 11 be some natural points where the staff would -- and the 12 applicant would find those interactions useful.

4 13 DR. UHRIG:

Will those renewals be individually 14 for the individual plants, or will they be sort of a group i

15 of three there?

16 MR. MIRAGLIA:

The review would be a review for 17 the three units.

It would have to have three specific --

18 DR. UHRIG:

Licenses?

19 MR. MIRAGLIA:

-- licenses.

20 DR. UHRIG:

Okay.

21 MR. MIRAGLIA:

Because each license --

l 22 DR. UHRIG:

Is separate.

23 MR. MIRAGLIA:

-- is separate.

24 DR. UHRIG:

That's right.

25 MR. MIRAGLIA:

Yes, sir.

I l

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DR. UERIG:

Thank you.

2 MR. MIRAGLIA:

So the primary purpose of the 3

steering group is to monitor the staff review on these 4

principal applications and the generic issues, to follow the 5

resolution of the technical issues in the process, and make 6

sure that we're following the goals and objectives in our 7

operating plan.

8 What we're going to be using as a Steering 9

Committee are the same indicators that the line organization 10 is going to be using.

11 Are we meeting schedules?

12 Are we meeting the resource expenditures that had 13 been planned?

14 The specific applications will have specific 15 milestones.

The generic reviews -- we're working with the 16 industry to identify what the issues are in terms of 17 priorities, and then to schedule the top priority. items so 18 we would have milestones as to the importance of the issues 19 and the path for resolution.

20 So our Steering Committee is going to be monitoring the p' ogress on that to assure that there is 21 r

22 orderly resolution of these issues.

23 The second role that we play is to recommend to i

4 24 Sam Collins, based upon our interaction with the staff and 25 the industry any recommended actions to approve the process l

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or to resolvo issues.

2 We're also going to act as the communication from l

3-the program office to the Executive Council.

As I said, the l

l 4

Chairman has charged the Executive Council to monitor our l

l 5

progress.

I 6

We-have the staff, as well as I as the Chairman of 7

the Steering Committee, and have been having periodic 8

meetings with the Executive Council to indicate the status 9

to date and where we stand with respect to our goals and 10 objectives.

11 In addition, the Steering Committee will be l

12 interacting with the industry.

We've had one meeting with 13 NEI and working groups.

We have a meeting planned next -- I 14 think it's the 22nd.

Steve, is that the right date?

i 15 And then there is a meeting about a month 16 subsequent to that in August already planned to provide a 17 forum to say, "How are we progressing?"

18 The focus of next week's meeting -- the previous 19 meeting with the industry is to get from them what are their 20 views and priorities of the issues so we can foc.us on the 21 issues of importance, schedule a path to resolve those 22 issues so we -- they don't wind up being a bar to progress 23 with respect to the reviews.

24 There is in the next chart --

25 DR. SEALE:

Frank, can I --

l l

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MR. MIRAGLIA:

Yes, sir.

2 DR. SEALE:

-- make a comment?

3 In the June meeting, we went through the 4

application for the upgrading of the power level on the 5

Monticello Plant, and toward the end of the meeting, we were 6

suddenly made aware of the fact that there were three issues 7

that were in the generic power upgrading process that 8

referenced -- that were referenced in the Monticello 9

~ application, and for us to be able to get -- pull -- to 10 write a closecut letter on that issue, we would have to 11 finish up the resolution of those three issues, as well, and 12 we were able to do that in our just previous meeting.

13 But we were in the rather awkward position of 14 being on the critical' path, as it were -- potentially on the 15 critical path for the review of that particular item.

16 And you're really in charge of the schedule, and 17 our schedule included -- and I just want to express our 18 desire to not be on the critical path on any of the things j

19 having to do with license renewal, and we'll have to rely on 20 you to make sure that we're not.

So that if there are any i

21 generic things that happen to be a problem, we want to be 22 able to see them early entitled so that we don't get 23 ourselves in that position.

24 MR. MIRAGLIA:

I'd like to amplify on the "you,"

l 25 that you used.

You as a plural pronoun --

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DR. SEALE:

Suro.

2 MR. MIRAGLIA:

-- and as it applies to me, not 3-only because of my size.

I am wearing two hats.

i.

l-4 DR. SEALE:

I understand.

5

[ Laughter.)

6 MR. MIRAGLIA:

And in terms of -- in terms of 7

that, you -- the primary you in terms of the schedule, it's 8

'the staff and it's the line organization.

9 What this chart is to depict for this process to 10 work --

11-DR. SEALE:

Okay.

the industry and the staff and 12 MR. MIRAGLIA:

13 the line have to work anc make it happen.

14-The Steering Committee, now, including switching 15 my hat as the Chairman of the Steering Committee, I have an 16 additional role, not only as --

17 DR. SEALE:

Yeah.

from the program office, but 18 MR. MIRAGLIA:

19 from the perspective of oversight.

20 Are we moving on the right --

21 DR. SEALE:

Yes.

22 MR. MIRAGLIA:

-- kind of issues?

23 Are we identifying them --

24 DR. SEALE:

Yes.

25 MR. MIRAGLIA:

-- and to get those bars.

I i

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Our goal is not to have that happen --

i, 2

DR. SEALE:

Okay.

3 MR. MIRAGLIA:

-- Dr. Seale.

4 DR. SEALE:

Okay.

5 MR. MIRAGLIA:

Our success will depend on not 6

having that happen at all.

7 It remains to be seen where the --

i 8

DR. SEALE:

Sure.

9 MR. MIRAGLIA:

-- issues are.

Is it how they go 10 is -- but that is certainly the intent.

11 And the levels of oversight predominantly is 12 within the staff and the staff organization, with oversight l

13 by the Steering Committee, and further oversight by the 14-Executive Council and the Commission.

15 There's very high interest in this program.

Your 16 comments are well taken, and I think --

17 DR. SEALE:

Let us know --

18 MR. MIRAGLIA:

-- the program office, the Steering 19 Committee and the staff clearly understand --

20 DR. SEALE:

Let us know if there is a problem, and 21 we'll -- we can't promise that we won't be, but we will i

22 certainly try --

23 MR. MIRAGLIA:

And from -- as the Chairman of the 4

l 1

24 Steering Committee, if there are issues that the Committee 25 would like to raise through the Steering Committee, we're I

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certcinly receptiva to doing that and briefing you --

2 DR. SEALE:

Fine.

3 MR. MIRAGLIA:

-- if that would be useful to the 4

Committee, as well.

5 DR. SEALE:

Thank'you.

6 MR. MIRAGLIA:

So I think I've completed n/

7 primary role here today and met the two objectives to talk 8

about the Steering Committee.

9 Chris Grimes is going to discuss the rest of the 10

-agenda and where we stand with the program to date.

11 I want to apologize to the Committee, because my 12 initial intent was to spend the morning with you.

I'm going 13 to spend at least another hour with you, and I apologize for 14 having to leave.

15 DR. APOSTOLAKIS:

I have a question.

16 MR. MIRAGLIA:

Yes, sir.

17 DR..APOSTOLAKIS:

I read some of the documents 18 that were forwarded to unit s.

19 Is there a regulatory guide now that tells the 20 world what you think they should do?

21 MR. MIRAGLIA:

Yes.

Let me -- the staff will be 22 talking more to that, but let me just indicate that there 23 has been interaction with the ACRS on license renewal in l

24 terms of the Part 54 rulemaking, and there was interactions l

25 with the committees when the rule was promulgated.

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there was a rule and an amended rule.

That rule er.cabli.shes 2

the process.

3 There is a draft reg guide that has been out for 4

comment.

I believe that reg guide was discussed with the 5

Committee, and it may be sometime back.

6 DR. MILLER:

Yes.

7 MR. MIRAGLIA:

There i s a draf t SRP that I don't 8

believe we've brought to the Committee.

Those documents are 9

points of departure.

10 The application of those principles and these 11 first two plants are going to be a learning process for us 12 to defer, to modify, consider the comments from the 13 industry, in terms of the issues that the industry is going 14 to prioritize, Dr. Apostolakis.

15 There are a nunber of issues that they have raised 16 in context to the comments on the reg guides.

So those are 17 going to be prioritized with all the issues there to get an 18 orderly resolution to those so the review could progress.

19 The outcome being, at some point after the 20 completion of the initial reviews, a modified reg guide and 21 standard review plan that's consistent with the experiences 22 gained on the first two facility surveys.

23 DR. APOSTOLAKIS:

On the applications from Calvert 24 Cliffs and Oconee, I looked at the applications.

Nothing --

25 MR. MIRAGLIA:

We have not used -- these are ANN RILEY & ASSOCIATES, LTD.

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honest to goodnnss --

l2 DR. APOSTOLAKIS:

Okay.

3 MR. MIRAGLIA:

-- real applications for.a license.

4 DR. APOSTOLAKIS:

But we expect to learn a lot 5

from these?

6 MR. MIRAGLIA:

Absolutely, and I think we and the 7

staff have articulated that to the Commission and the 8

industry what our intent is.

9 There are questions out there, and the details --

10.

you know, the devil is always in the details of 11 implementation.

12 DR. APOSTOLAKIS:

Right.

13 MR. MIRAGLIA:

And we, in the industry, expect to 14 learn by this process.

We've had dialogue with the industry 15 on how we're going to proceed and how changes will be made 16 in the future.

17 DR. APOSTOLAKIS:

But have the rules of the game 18 been determined already, established --

19 MR. MIRAGLIA:

In terms of process, Part 54 20 DR. APOSTOLAKIS:

Yeah.

21 MR. MIRAGLIA:

-- establishes that.

22 DR. APOSTOLAKIS:

Okay.

23 MR. MIRAGLIA:

And then the staff and the Steering I

24 Committee, working with industry, will monitor the 25 implementation of that process.

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DR. UHRIG:

Are there a significant number of 2

plants that are sort of sitting, waiting, watching this 3

process, anticipating the submission of renewals --

4 MR. MIRAGLIA:

Yes.

5 DR.-UHRIG:

-- or --

6 MR. MIRAGLIA:

Yes, sir.

I think the indication 7

we have, most of it, is informal.

This is -- I mean if one 8

just takes a step back, 20 percent of the electrical supply 9

in the country is nuclear.

10 The decisions for renewal are economic by the 11 utilities.

A lot of that depends upon what's going on in 12 their own service areas with respect to deregulation, but 13 there is a number of utilities who feel that it is -- the

-14 economics are going to support renewal.

And so I think it

(

15 is important to show progress.

16 I think that's what's spurring the external 17 interest from the industry, from the Congress, from --

18 internal from the Commission, all the way down, to make sure 19 that the process does work.

20 It's an important process and the outcome of the 21 process is going to be important, as well.

j 22

-DR. MILLER:

Is there a fairly detailed schedule 23 for the'-- for, say, Calvert Cliffs --

24 MR. MIRAGLIA:

Yes, hopefully --

25_

DR. MILLER:

-- a list of -- that we're going to ANN RILEY & ASSOCIATES, LTD.

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have to see that today?

2 MR. MIRAGLIA:

There should -- it should have been 3

provided --

4 DR. MILLER:

We saw --

5 MR. MIRAGLIA:

-- in the background papers for the

'6 Committee.

7 DR. MILLER:

We saw the list of milestoner.

8 MR. MIRAGLIA:

Yes, those -- those --

9 DR. MILLER:

What I'm looking at, is there more 10 than just a list of milestones?

11

-MR. MIRAGLIA:

There's probably intermediate 12 milestones from those in terms of where individual branches

~13 stand, but I think it goes down to when the RAI's have to go 14 out and things of that nature, i

15 But the staff could dialogue more with you on 16 that, Dr. Miller.

17 We haven't put the schedule out on Oconee yet, but 18 it would be very, very similar to that, and the Committee 19 will be provided with that information, as well.

20 As soon as we have prioritization from the 21 industry and schedules for those issues, we'll provide that.

22 That could be potential agenda issues on some of 23 those issues, as well.

24' DR. MILLER:

There's also a mention of a number of 25 technical issues in one of the memoranda like I think the l

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one -- are those issues being resolved, or is that -- what 2

are we going to learn about that today?

3 MR. MIRAGLIA:

That's -- and what I'm talking 4

about the issues, you'll hear more about that, but there are 5

issues that the industry has raised with respect to process, 6

technical issues, and then issues that resulted from 7

comments on the draft Regulatory Guide.

8 All of those issues have been collected.

The I

9 industry is prioritizing those and grouping those, and then 10 we'll work those off and priority schedule to make sure that j

11 those issues are on a path to resolution, and what the goals 12 and objectives are.

13 And we can share that with the Committee as soon 14 as we have input from the Committee and establish what those 15

' schedule -- the Working Group of the industry and they'll 16-set a potential agenda for interaction on issues, as well, l

17 with this Committee.

18 MR. GRIMES:

My name is Chris Grimes.

I'm the 19 Director of the License Renewal, Project Director.

20 As Frank mentioned, we met with the ACRS in l

21 January of this year, and we talked about part -- the 22 contents of Part 54 and Part 51 that provide the 23 requirements for license renewal technical and environmental 24 reviews.

And we talked about the contents of the draft 25 standard review plans and our efforts to try and organize ANN RILEY & ASSOCIATES, LTD.

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and prepare to review license renewal applications.

lj 2

Since that time, there has been a tremendous 3

amount of focus on the license renewal process.

Starting in o

4 about February, as Frank mentioned, the Chairman directed 5

the Executive Council to provide s'.'ewardship and oversight 6

of the license renewal process.

We've met with the 7

Executive Council 12 times.

8 Also, as Frank mentioned, the formation of the 9

Steering Committee and a focus on schedules and resources l

10 has caused us to spend a considerable amount of time looking 11 at plans, resources and appropriate milestones fer these 12 reviews.

13 We had not planned on going back over the contents 14 of Part 54 or Part 51 today, but instead, we were going to l'

15 stem from that and talk more in terms of the implementation 16 plans and the kinds of preparations that we're making for l

l 17 the conduct of the reviews.

l 18 Bob Prato of my staff is going to talk about the 19 guidance that's being developed to assist the staff in the 20 conduct of the reviews, and he's going to go back over those l

21 issues that we described in January in terms of how we're 22 going to approach those issues in a process way.

23 And then I will -- I will go through and talk 24 about the particular status of all of those activities.

And 25 I will describe, as best I can, where we stand with our ANN RILEY & ASSOCIATES, LTD.

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plans and schedules so that then we can have a meaningful 2-dialogue with you in terms of what are the most efficient j

3 and appropriate ways for the staff to interact with the 4

ACRS.

5 And with that, I -- unless you have any general 6

questions for me, I'll have Bob Prato start in with the 7

presentations.

8 CHAIRMAN FONTANA:

Okay.

Thanks.

Thank you.

9 MR. PRATO:

Good morning.

I'm Bob Prato.

10 Can you hear me okay?

11 Everybody can hear me back there?

12 I'm Bob Prato.

I'm currently the Acting Section l

13 Chief in the PDLR Engineering Section, and I'm also a 14 mechanical engineer responsible for the inspection program 15 in the implementation program for license renewal.

16 I'm going to be covering the inspection program 17 and the office letter, and if you remember, in January, we 18 gave pretty much the same presentation, so my primary 19 objective is to review what we basically told you in January

.20

'and tell you what has changed.since January, and where we're 21 going in the next few months.

22 Based on our presentation last January, we told 23 you that the license renewal application -- the license l

24 renewal inspection program is broken down into two basic 25 applications.

The first applications is the pre-renewal i

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application approval inspection activities, and the second 2

application is the post-renewal inspection activities.

3 During that period of time, we discussed the 4

program documentation, the aging management program 5

implementation, and the aging management program 6

effectiveness as the objectives of the license renewal 7

pre-application approval inspection activities.

8 As for the objectives, the program documentation 9

is intended to review the document -- the on site 10 documentation associated with an applicant's license renewal 11 inspection program.

12 The intent is to verify that the documentation is 13 being maintained consistent with the requirements of the 14 rule and site procedures.

t 15 The second one, the aging management program 16 implementation, our objective in that objective in that 17 phase of the inspection process is to verify that the 18 applicant did, indeed, implement the program as it was 19 described in their application, as well as the changes as a 20 result of the staff's safety evaluation.

21 And, finally,,as the third objective of the 22 inspection program is to verify that the aging management 23 programs are being implemented effectively.

24 As for the post-license renewal application 25 approval, the intent of the inspection program is to verify ANN RILEY & ASSOCIATES, LTD.

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that license conditions have been met, license commitments 2

have been met, as well, and that the aging management 3

programs continue to be effective.

4 This portion of the inspection program we expect 5

will fall in direct line with the current operating reactor 6

inspection activities.

There are no new activities expected 7

as a result of this.

Maybe some additional actions.

8 The regions and the residents are used to dealing 9

with license conditions and license commitments, and as far 10 as aging management effectiveness, it's routine inspection 11 type of activities.

12 MR. GRIMES:

Bob, if I could, I'd like to 13 interject at this point and focus specifically on recent 14 lessons learned from Millstone, a Maine Yankee, in terms of

(

15 process improvements for operating reactors.

And one of --

16 embedded in this objective is the recognition that we can do 17 a better job in our safety evaluations and in the license 18 content of identifying those particular licensee features --

19 the features of their programs that we rely on for our 20 reasonable assurance findings.

And so we expect to -- as j

21 Bob pointed out, we want to see the end result blend in 22 seamlessly with the routine, but at the same time, reflect 23 on lessons learned and better ways to do this.

24 So when we present our safety evaluation, when we 25 present the final license, we hope that you will find that ANN RILEY & ASSOCIATES, LTD.

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we've donn a batter job of articulating what the licensing L,:

2 basis is and what commitments the license -- we've relied on 3

in our findings so that the inspection program is better 4

focused.

5 DR. SEALE:

That seamlessness in the process is, 6

as I recall, certainly an aspiration of the discussions that 7

have gone on'in the implementation of the maintenance rule.

8 And, in fact, the aging management program itself is really 9.

a part of the main -- of the maintenance rule 10 implementation.

11 Now at the same time, a lot of people are just now 12 getting through the transition, if you will, to compliance 13 with the modern maintenance rule, and I would -- I would l

14 hazard a guess that perhaps Oconee or Calvert Cliffs might li 15 not be in as good a position in terms of a history of i

16 maintenance rule, just because of the calendar that you 17 might expect five years from now from an applicant that 18 might come in.

l 19 But I would -- I would guess, if you would -- you 20 would want to at least see the traces there that shows that, p

.21 you know, where the ganglia will connect back to the 22 maintenance rule at -- in the full maturity of that 23 transition.

~

j 24 I'd be interested, as you go along, if you can 12 5 maybe make some of those connections.

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MR. PRATO:

There are a lot of activities where 2

license renewal and the main people are interacting, and 3

we're trying to glean as much of the lessons learned from 4

the -- from the maintenance rule as we possibly can.

And I 5

believe that we're doing that.

We work with them an awful 6

lot.

7 DR. SEALE:

So anything you can tell us --

8 MR. PRATO:

A lot of our activities are being 9

integrated.

10 MR. GRIMES:

Okay.

11 MR. PRATO:

And we will be covering that.

12 MR. GRIMES:

Bob, are you going to talk a little 13 bit about the -- how you and the maintenance rule folks have 14 worked together to identify inspection procedures?

15 DR. SEALE:

Yes, sir.

16 MR. GRIMES:

Okay.

17 MR. PRATO:

That will be covered on our next 18 slide.

19 DR. SEALE:

Good.

20 MR. PRATO:

As far as the status of the inspection 21 program, the license renewal manual Chapter 2516, okay, has 22 been issued -- was issued last month.

It's taking a little 23 while to get onto the Web, but nonetheless, it's been 24 officially issued.

And the regions have been part of the 25 review process.

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The maintenance rule people have been part of the i

2 review process.

They've been on review for all of our 3

documentation, and we will receive quite a few comments, and 4

we've integrated all those comments.

5 The license renewal inspection procedure IP71002 6-has also been issued.

It's in the same status as the manual 7

chapter that was issued about the same time.

As a matter of 8

fact, it was issued in the same revision package.

But, 9

again, it hasn't made it to the Web yet, but we expect it l'0 any day.

11 There's a lot more information going on the Web 12 than has been in the past, and it's just taking longer for 13 revisions to get incorporated.

14.

As far as for the aging management program 15 inspection procedures, initially -- and we looked at this on 16 two levels.

We looked at it as the pre-approval phase and 17 the post-approval phase.

18 And what we had intended to do for the l

19 pre-approval phase was to develop separate inspection 20 procedures for the major aging management programs.

And for l

21 the post-approval phase, we were going to go through the 22 current 2515 program and make revisions to the existing 23 procedures, as they exist today, to make sure that license l

24 renewal was adequately covered.

i 25 In recent months, we've started working with the ANN RILEY & ASSOCIATES, LTD.

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maintenance rule people.

They're going through a major 2

revision of the 2516 IP procedures.

We are starting to get 3

together and incorporating --

4 What we found was, especially with the 5

erosion-corrosion procedure -- this is what initiated these 6

actions -- is that the maintenance rule people had a draft 7

erosion-corrosion special procedure, license renewal 8

pre-approval.

We had developed a procedure for verifying 9

erosion-corrosion aging management programs.

They looked 10 significantly different than what exists today in 2515.

11 But the bottom line is, all three procedures had 12 the same end results.

We were trying to verify that they 13 had effective aging management programs in place.

14 So what we've done is, we've decided that we're 15 going to coordinate all our revisions into one.

We are 16 working directly with the maintenance rule group.

The 17 intent is to develop one procedure that takes care of all 18 three items, the maintenance rule requirements, the current 19 2515 inspection requirements, and the aging management 20 review requirements, not'only for the post-approval, but for 21 the pre-approval stage.

22 And we believe that in 90 percent of the cases, 1

23 we're going to be able to do this.

There may be some 24 individual procedures that need to be developed, 25 specifically for license renewal.

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A lot of the licensees are taking credit for j

i 2

engineering walkdowns, for example, in the area of license I

3 renewals to verify that aging is being handled 4

appropriately, and right now, that's one area where we may j

l 5

have to develop a separate procedure, although the industry, 6

as a whole, is trying to integrate their -- these efforts 7

that they're doing, this routine walkdowns that are -- now 8

that~are proceduralized, that are part of their 9

requirements, that are integrated in -- into, not only their 10 maintenance program, but also into their engineering 11 program.

12 So it may, in the long run, end up that even those 13 that we suspect are going to be focused on license renewals 14 may, again, end up being part of the 2515 program, t

15 The other reason we started doing this is because 16 we found out that, through presentations from BG&E and 17 Oconee, that the major of their aging management programs 18 are existing.

19 And just for rough numbers, and I'm not sure about 20 the specifics, I believe BG&E claimed that they have 330 21 aging management programs.

280 of them -- approximately 280 22 of them are existing programs without any changes, and 23 approximately another 30 or 40 are existing programs with 24 minor changes.

25 That means about five percent of their aging 1

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27 1

managtment programs are new programs', okay.

And because we 2

do inspect the current programs, it makes a lot of sense 3

that we integrate it in the current inspection activities.

4 As far as the feedback process, I'm going to cover 5

most of that under office letter 805, but we do have a 6

process in place.

That process doesn't apply to the 7

inspection program.

We expect lessons learned, especially 8

after we start implementing for BG&E and Oconee, the license 9

renewal inspection activities.

10 Our intent is to try and track all the lessons 11 learned to completion.

One of the things that we've -- one 12 of the guides that we've implement with respect to the 13 feedback process, the lessons learned process, is that the 14 documentation that provides the guidance, documentation like 15 the SRP, office letter 805, the inspection program, will all 16 feed through this lessons learned process that I'll be 17 covering shortly.

18 And, finally, training.

We had a meeting with 19 regional representatives just recently -- actually, we've 20 had two recently.

We've given the presentation which was 21 more like a training session to our DRS counterparts.

And 22 recently, we met with the working level, and we've given 23 them a present -- a whole day's worth of training on --

24 actually, it was a half a day's worth of training on license 25 renewal to get them prepared to get involved in the l

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implementation process.

2 We are also expecting to have a counterpart 1

3 meeting with the residents.

This is a clear opportunity for l

4 us to begin training the residents.

That decision hasn't --

5 isn't final, but right now, I'm preparing the training 6

session for the residents, as well.

7 In addition, one of the items that we decide 8

during our meetings with the regions on the implementation l

9 process was that PDLR will be prepared to begin training 1

10 inspectors November 1, and those schedules will be based on 11 region availability.

But we will have a training session in 12 place at that time.

13 Bob, I would like to add at this point that the 14 focus on the inspection program is primarily because we are I

15 looking at the end state, that is, where do we want to get 16 to in this process?

What kind of inspection verification is 17 appropriate for the Regions to be able to make a 18 recommendation to the Commission like they did in their 19 94300 procedure for the operating license?

20 And we are concentrating on what -- a vision of 21 what the safety evaluation basis would be to comply with 22 Part 54 and what the attendant inspection finding would look 23 like.

And so that's why we believe it's appropriate at this 24 time, even Lhough the staff doesn't have a draft safety 25 evaluation yet, but to envision that safety evaluation and ANN RILEY & ASSOCIATES, LTD.

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start planning around how will the inspectors verify the l

2 conclusions of the staff's safety evaluation so that our 3

plans for the future are better focused.

4 DR. PRATO:

The whole license renewal inspection 5

process is a little different than we have been doing 6

business routinely.

We are planning to develop an 7

inspection plan that would require a review of the 8

licensee's application, as well as the safety evaluations 9

that are produced from that.

And also any recommendations, 10 we are asking DE to provide us with recommendations on what 11 they would like verified.

12 Now, obviously, the inspection program is going to 13 be a sample program, and where those recommendations are 14 applicable, we will implement those recommendations.

Also, 15 if there are any required verification that comes out of the 16 safety evaluation review process, we intend to implement 17 those as well.

18 DR. SEALE:

Just a couple of thoughts on the 19 comments you made.

It strikes me that recognizing that the 20 bottom line is the important issue in these inspection 21 programs and that there is very real value in coming to a 22 common template, if you will, recognizing that the bottom 23 line is the important product is the kind of resource 24 conservation that not only the Commission itself, with its 25 budget problems and so forth, but the industry should really l

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appreciate and -- because it will save significant 2

resources.

That's very important.

3 But the other thing that I I don't know how you 4

do it, but it seems to me that somewhere along --

5 particularly in these formative stages, you need to have my 6

colleagues at the university in the remote sensing area cal 7

ground truth.

Every once in a while you need to check and 8

make sure what you think you are looking is telling you what 9

you think it is telling you, because sometimes reality is 10 not -- the reality is not what you think you see, or what 11 you thought you saw.

12 And it strikes me that you would be very -- you 13 could make some very real use of the input of good 14 inspectors who know the plants, the two plants or the two l'5 groups of plants you are talking about, to tell you whether 16 or not you are blowing smoke.

Because they really know the 17 plant.

And you really -- those are the inspectors -- I know 18 they are going to be busy, but they could sure give you some 19 input that would keep you from running down false trails 20 early on, if you --

]

21 DR. PRATO:

Well, the Regionb and the people who l

22 were active in the maintenance rule implementation, and the 23 field inspectors are an integral part of our process.

We 24 are going to be talking on the next slide a lot about 25 resource conservation.

If we keep in mind the fact that the ANN RILEY & ASSOCIATES, LTD.

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maintenance rule is performance-based, license renewal is l

2 performance-based, the current 2515 program is basically 3

performance-based.

Most of our effort is focused on the 4

effectiveness'of their aging management program.

We can't 5

get into that aspect without reviewing the documentation and 6

the implementation aspect, and we are hoping to get that 7

done in the pre-approval phase.

8 DR. SEALE:

Okay.

9 DR. PRATO:

And that's, to us, where is the most 10 applicable place to do that?

Once we get that done, once we 11 verify that the programs have been implemented as we have 12 written our safety evaluations on, then we can get into the 13 primary objective, which is performance-based and whether or 14 not the aging management programs and the inspection 15 procedures are being effective in what the applicants say 16 that they will do.

17 MR. GRIMES:

Speaking --

18 DR. APOSTOLAKIS:

Sorry.

4 19 MR. GRIMES:

And I would like to add to that that I

I 20 Bob -- excuse me.

Bob mentioned before that we have already 21 started to get some useful feedback just in terms of trying 22 to design the inspection procedures and finding the common 23 ground between the current inspection practices and our 24 desire to formalize a feedback process that constantly 25 collects this knowledge and experience from the residents, l

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32 1

from ths Regions, from the review staff, from the utilities.

f I

2 Everybody has got good ideas.

The major hurdle that we face 3

is trying to assimilate, digest and act on those -- that 4

feedback.

5 And so when Bob describes the way that we intend 6

on managing that feedback process, I hope you will find that 7

we have established an environment that both stimulates and 8

makes use of that kind of, knowledge, that kind of ground 9

truth.

10 DR. APOSTOLAKIS:

You mentioned that the 11 inspection program is performance-based, and that cries for 12 the first two words, risk-informed.

13 DR. PRATO:

Okay.

14 DR. APOSTOLAKIS:

And the comma.

15 DR. PRATO:

I heard your comment before the 16 meeting and I thought about it, I had time to thing about 17 it.

18 DR. APOSTOLAKIS:

Let me complete my thought 19 first.

20 DR. PRATO:

Okay.

21 DR. APOSTOLAKIS:

The Commission -- the staff is 22 working on a regulatory guide and the appropriate SOP 23 chapter, corresponding SOP chapter on risk-informed 24 in-service inspection.

And that has a lot of good stuff, 25 and I was wondering whether that, the thoughts of the l

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approach that is described there, has had any impact on what 2

you are planning to do, or will have any impact on what you 3

are planning to do.

4 Because I mean I realize that'these guides are 5

optional.

But, on the other hand, we can't really go in two 6

separate paths and not be consistent.

7 MR. MIRAGLIA:

Dr. Apostolakis, may I try to j

l 8

address?

j l

9 DR. APOSTOLAKIS:

Sure.

{

i 10 MR. MIRAGLIA:

What you are saying is the extent 11 that risk-informed inspections, risk-informed licensing 12 processes become part of that facility's current licensing 13 basis, they become potentially an existing program within 14 that current licensing basis.

So to the extent that they 15 incorporate those things, that automatically -- it just 16 flows right over into the license renewal, in that kind of 17 context.

18 In addition, the staff is looking at the 19 inspection program, it is looking at its licensing process, 20 it is 1.ooking at its performance assessment processes to 21 make all of those risk-informed.

So I think, to the extent 22 that the staff moves in that direction, to the extent that 23 industiy and these specific licensees adopt those things and 24 make it part of their current life, for example, in-service 25 test and inspection, if that becomes an amendment, that l

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34 I

1-becomas partLof their licensing basis.

And if that is tl, 2

important to demonstrate some control of an aging mechanism, I

3

.therefore, that is a credit for, quote, "an existing l

'4

program."

5-So I think-that is.the process'by which 6

risk-informed.is,two ways, in terms of implementation of the 7

' things that'we have offered and put out there that become 8

part-of the licensing basis for those facilities and then-9 risk-informed approaches, to the extent that the staff j

10 changes'its processes.in terms of licensing, inspection and 11'

performance assessment, also get reflected.

So I see it as 12 a continuum.

13-DR. APOSTOLAKIS:

Well, that is why I asked you 14

earlier a question.whether the rules of the game have been j

15 established.

Because I see this -- there are two 16

' conflicting, perhaps, processes or goals here.

One is we 17 are working on these regulatory guides, as you know, and ISI 18 Guide, I think is about to be completed.

The others have l

1 19 already been-forwarded to the Commission, as I understand l

I 120 it, and 1.174 has-been approved.

So there is a lot of

]

'21

. activity on that front.

22 At the same time we are doing this.

And, of 23' course, you don't do this in a week, so you have already 24 invested a lot'of time and so.on, especially the licensee.

25 I mean'if we decide now that the risk-informed processes I

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that are described in these new guides make eminent sense to 2

be used here, can we really do that?

Can we go back to the 3

applicant and say, well, gee, the volumes you submitted, 4

they are kind of incomplete, the rules of the game have i

5 changed?

Is that possible?

6 MR. MIRAGLIA:

No.

7 DR. APOSTOLAKIS:

On the other hand, wouldn't we 8

have a logical problem there, when we are coming out with a 9

guide that says it is correcting all sorts of problems from 10 the past and this is a great way of doing it, but we are 11 going to ignore it because of logistical reasons?

I don't 12 what the resolution of that is, but it seems to me there is 13 a slight problem there.

14 MR. GRIMES:

Dr. Apostolakis, if I may, I would 15

.like to -- I believe that baak in January I made a statement 16 that the license renewal review is' founded on a 17 deterministic basis and that our expectations are that we 18 will eventually be able to find a way to fit it in the pilot 19 activity stemming from the risk-informed decision-making 20 process.

And I want to reinforce that now in a way that 21 we are still struggling in order -- you characterized it as l

22 pilot applications.

We still have a lot of soft spots just 23 in the basic design evaluation process, but we see a vision l

24 in the future where there is a natural integration, for l

25 example, in scoping required for Part 54.

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What are the appropriate system, structures and 2

components that should be subject to an aging management 3

review?

The graded QA approach I think will naturally fit 4

into that at some point in the future and, certainly, 5

risk-informed ISI is going to have a profound effect on the 6

evaluation basis for aging management programs.

7 But at this peint we see that those activities are 8

being conducted both in parallel, and being supported by the 9

same staff.

Those staff that are working on the 10 risk-informed guide applications are the same staff that are 11 going to be reviewing the license renewal applications.

And 12 so we expect to get feedback from them on how to develop 13 what has been referred to in the past, and will be referred 14 to in the future as risk-informed license renewal.

15 But at this point we don't want to go back and 16 cause concerns about the stability of the review proces's by 17 telling BG&E and Oconee that we are going to have them do 18 something different.

As a matter of fact, when we get into 19 talk about the status, we are going to explain how we 20 acknowledge their difference but we will continue the 21 feedback process to improve it in the future.

22 So I am not -- I am not trying to say that -- what 23 I want to say is I see the conflict as opportunity.

I see 24 that there is a natural blending that will occur as the 25 standard review plans and as the experience identifies good ANN RILEY & ASSOCIATES, LTD.

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ways to integrate these two processes.

2 MR. MIRAGLIA:

I just would like to make the 3

following observations in terms of what we see.

I think, 4

Dr. Apostolakis, you made the comment that we are taking 5

different approaches.

I think if you go back to one of the

)

6 fundamental principles of Part 54 that the Commission 7

articulated when it promulgated the rule is that the current 8

licensing basis for the plants that are operating now is 9

--provides the basis for renewal except for those things 10 that raise unique issues in terms of function of important 11 equipment in the renewal period.

12 And so it is a process kind of thing.

To the 13 extent that the current licensing basis for the existing 14 facilities change for its operating life, and those 15 risk-informed approaches are made part of that licensing 1

16 basis, it should flow.

So in terms of process, I don't 17 think the processes are in conflict, I think they are 18 married.

19 Now, the question I think Chris was trying to say 20 is, to the extent that there's new things that have to be 21 considered, and there are risk-informed approaches to 22 address some of those issues, certainly, those kinds of 23 insights would be used for those kinds of things as well.

i 24 So I don't see it as a conflict, I think it's a continuum, 25 as I tried to express initially.

)

I 1

l

(

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DR. APOSTOLAKIS:

No, I apprecicto your commants.

2 And when I said conflict, I think it is a built-in conflict.

3

-In other words, 4

MR. MIRAGLIA:

It's complex.

5 DR. APOSTOLAKIS:

You are absolutely right that we l

6 have to have a stable process.

We can't change the process 7

all the time.

But at the same time, this new set of 8

regulatory guides is not just another thing.

I mean it is 9

. attempting to change the way we are approaching things.

For 10 example, the 1.174 guide that has been approved gives the 11 general guidelines for evaluating requests for changes in i

12.

the current licensing basis.

I mean if there is a big 13 request, it is this one.

You are extending the license by 14

'50 percent, right.

I 15 DR. PRATO:

Right.

Major license --

16 DR. APOSTOLAKIS:

So how can the question of what 17 happens to the core damage frequency and LERF and whether 18 they fall on Figure 3 or Figure 4 of that guide will come 19 up, even if we don't want it to come up.

20 So the question is now, how can it come up in a 21 way that will not surprise people?

And is there any way 22 that, in the process that you have, the milestones, for 23

. example, or maybe another title, but to have some allowance 24 there for some interaction so the applicant will know that, 25 and everybody will know that?

There may be this feedback or l

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interaction because -- I don't know whether one way of doing 2

it is to do it through a request for additional information, 3

but it seems to me that is not the best way to do it.

4 Now, let me give you an example.

Last week we 5

were writing the letter on the Monticello request for power 6

upgrade, and the question of 1.174 came up again.

Now, the 7

applicant there had managed to get some viewgraphs from here 8-and there, ACRS meetings, because they were at a 9

disadvantage, of course, the guide had not been published, 10 and they did some quick calculations to show that delta CDF 11 was within the limits.

But then we debated among ourselves 12 whether it was really -- I don't know whether the right word 13 is fair, but I think it applies here, to say that that is 14 the way they should have done it when they didn't have 3

15 access to the guide.

16 Now, are we going to find ourselves in the same 17 situation at the ACRS meeting scheduled for February 14th, 18 the year 2000, where we are going to be asked to evaluate 19 the staff's SSER and FES, and we will say, gee, it would 20 have been nice for them to have used 1.174 for?

And if that 21 will be the case, why don't we do something now?

Can we do 22 something now?

I don't know.

23 MR. MIRAGLIA:

That's -- what you are saying is 24 you are arranging -- 1.174 is guidance out there if l

25 licensees choose to take that approach.

It is a voluntary.

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What you are talking about, Dr. Apostolakis, is a broad 2

question of implementation of 1.174 as a new basis for 3

licensing.

That is a major policy kind of issue and that's 4

-- that, if you go back to the Part 54, the basic, 5

fundamental principles of the process to be used by license 6

renewal, the Commission spoke to those, although it was 7

several years ago, and most notably, it was a different 8

Commission.

And they talked to -- it's a process rule in 9

terms of current licensing basis.

10 It is not our intent to impose that requirement in 11 terms of the license renewal process.

That is not 12 consistent with where the staff -- we think the fundamental 13 principles of the rule are in the process to date.

To the 14 extent that those guides are used and implemented by i

15 licensees, in conformance with the guidance, for those 16 issues that they feel that they need to make those changes 17 to their licensing basis, and they are incorporated into the 18 licensing basis, they would flow with the license renewal 19 decision.

20 DR. APOSTOLAKIS:

I am not really --

21 MR. MIRAGLIA:

I am talking process.

22 DR. APOSTOLAKIS:

I understaed what you are 23 saying.

24 MR. MIRAGLIA:

I understand the issue you raise.

25 DR. APOSTOLAKIS:

I am not proposing to make 1.174 l

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41 '

1 the basis for decision-making.

You are absolutely right, 2

it's optional, or in this case, the word optional really has 3

to be stretched, the meaning of the word.

4 I mean it is optional, but that does not mean, I 5

think, again, de facto, real life, that if the licensee I

'6 chooses not to use it, the questions will not come up.

I 7

can't imagine that the NRC staff will approve a license I

8 renewal application without ever asking the question, what 9

happened to the core damage frequency?

10 So what I am saying is maybe we ought to think 11 about bringing that kind of thinking into this process, 12 without changing it fundamentally, because I fully 13 appreciate that this cannot be done for many reasons.

But 14 the question will be asked, and it will not be me, okay.

15 there will be other people who will be curious, what 16 happened to the CDF?

I mean --

17 DR. SEALE:

Well, George, I think we have to all 18 recognize that, in essence, what we said with that letter, 19 and we shouldn't waste these people's time talking about 20 that letter, except that it is quite relevant in this case.

21 What happened with that letter is that we said --

22 DR. APOSTOLAKIS:

The Monticello letter?

23 DR. SEALE:

Yeah.

That, hey, the process is a lot 24 more convenient, a lot more straightforward, a lot less a 25 matter of faith if we have the kind of evaluation that was l

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made.

And now it is not an 1.174 evaluation, it was the l,

2 kind of evaluation of risk difference that they had in that 3

particular submittal.

And that kind of letter from the 4

ACRS, I think has impact.

I think a lot of licensees are j

5 going to see that, hey, that is not a bad way to make the 6

argument, l

l 7

DR. APOSTOLAKIS:

But what I am saying is I don't 8

want to find ourselves in a situation in the year 2000 q

9 saying again the same thing.

And I do appreciate -- don't 10 think that I want to change everything -- but I do -- but I 11 mean --

12 (Laughter.)

13 DR. APOSTOLAKIS:

I realize there are limitations.

14 MR. MIRAGLIA:

Glad you finally --

15 DR. APOSTOLAKIS:

I fully appreciate what you said 16 about stability and so on.

But it seems to me that it would I

17 make everybody much happier if somewhere along the line you 18 show them the milestones that this whole activity on the 19 other side will be brought into this process as appropriate, i

20 in some way, without imposing it.

Because, de facto, it l

i 21 will happen.

I just don't see how -- I mean what are we l

22 going to talk about?

Changing periodic inspection by three 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> and go to 1.174.

This is that big.

If you don't I

i l

24 apply it here, I don't ktow why we developed it.

Now, it is 25 optional, I realize that, it is optional.

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MR. MIRAGLIA:

I think, in terms of process, and j

2 how you impose it into process is very important.

I think 3

the Commission, in establishing the fundamental principles, 4

renewal in Part 54, did not consider that in the context of 5

the process.

I understand your question and --

6 DR. APOSTOLAKIS:

When was this approved, by the 7

way?

Part 54.

8 MR. MIRAGLIA:

Part 54, there was two approvals I 9

think the first year.

10 DR. PRATO:

Ninety-one.

11 MR. MIRAGLIA:

Ninety-one was the first Part 54.

12 DR. PRATO:

And then May 8th of

'95.

13 MR. MIRAGLIA:

And then it was revised in '95.

14 DR. APOSTOLAKIS:

That's the reason.

But 15 everything that I am talking about happened after that time.

16 MR. MIRAGLIA:

The thought processes that you are 17 talking about, and the implications of implementing that 18 kind of change in the processes we are talking about, have 19 to be fully understand and evaluated.

20 DR. APOSTOLAKIS:

And I fully appreciate that.

21 MR. MIRAGLIA:

And I think they were looked at in 22 the past time.

If the Committee is of a view that they need 23 to be re-examined in this time, that's a choice the 24 Committee can make through the Commission.

25 MR. GRIMES:

I would like to add to that, we have i

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44 l

1 asked the question of ourselves, and we have been talking 2

about the plant-specific IPE and IPEEE results, and we have 3

been struggling with the extent to which some of the basic 4

questions about the quality of PRA --

l 5

DR. APOSTOLAKIS:

Yes.

6 MR. GRIMES:

come into play in terms of how 7

well a PRA can be used to look at aging management or life 8

extension questions.

And so at this point, as Frank points 9

out, because of the concern about the stability and ensuring l

10 that the milestones have clearly defined and established

{

11 objectives, we know the question is on the table, we have an i

12 interest in it, and as the opportunity presents itself to 13 raise the policy issues associate with that, I am sure l

14 Frank, in his role as Steering Committee, and also the i

15 Executive Council, they understand that we know that that

)

16 question is on the table, and now it is up to us to figure 17 out what the right -- where the right place is to pursue l

18 that answer.

I 19 DR. APOSTOLAKIS:

What is the current CDF for 20 Calvert Cliffs?

21 DR. PRATO:

I don't know the answer to that, but I 22 know it is relative high for Calvert Cliffs.

And the reason 23

-- the reason I understand it is that way is because they 24 have got a very intricate IPE that goes beyond what the 25 typical standard is.

I have heard a lot of this information l

l l

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through the maintenance rule implementation program.

Okay.

2 They also have a living database, if I understand correctly.

3 And if I understand, because now we are looking at three 4

levels.

Do they have an IPE that is accurate?

Do they have 5

a living one that they can implement changes adequately?

6 And are they doing those changes?

And apparently, BG&E has 7

a very good process and they are very conservative in the 8

numbers that they use.

So --

9 DR. APOSTOLAKIS:

Met, can we get a copy of the 10 IPE and have it here?

11 DR. EL-ZEFTAWY:

For Calvert Cliffs?

12 MR. MIRAGLIA:

Yeah, we can provide that to the 13 Committee.

From a point of view of process, the requirement 14 for the IPE, there was a Generic Letter that said there was

(

15 a requirement, or a request for a probabilistic analysis to 16 be submitted.

So that is available for both facilities.

17 Now, how updated the one we have is, you know, of course, 18 the licensees do make changes in their facilities, but that 19 can certainly be provided.

20 The licensees also were to submit a response to 21 that request also.

An IPEEE with respect to external 22 events, so that could be shared with the Committee.

23 DR. APOSTOLAKIS:

You say the CDF is pretty high.

l h

24 Is it above the goal of 10 to the minus 4?

25 MR. MIRAGLIA:

My understanding is it is, Dr.

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'Apostolakis.

It is some number times 10 to the minus 4 and 2-that number is not 1, and I don't want to speculate what it 3

is, but that is my recollection as well.

4 DR. APOSTOLAKIS:

It seems to me that 1.174 will 5

be used here, no matter what we call it, because it says 1

6 explicitly that if the current CDF is above 10 to the minus 7

4, you can do very things to the plant.

So --

8 DR. SEALE:

To raise it.

i 9

DR. APOSTOLAKIS:

To raise it, yeah.

So what we l

l 10 are doing here, I mean I don't know, I mean somebody will l

l 11 bring it up.

You are in that region now where there is 12 increased management attention, according to 1.174.

i 13 MR. MIRAGLIA:

To make changes to that license.

14 DR. APOSTOLAKIS:

That's right.

I 15 MR. MIRAGLIA:

It's the premise in the process 16 rule and the premise in the fundamental principle for -- is 17 that that current licensing basis established the 18 Commission's determination of reasonable assurance of 19 adequate protection and it, therefore, as long as it is not 20 being increased, it can continue.

And so I think that's --

21 that's where we are in terms of --

22 DR. MILLER:

The renewal process is not meant to i

l 23 change the current licensing basis.

24 MR. MIRAGLIA:

That's correct.

25 DR. MILLER:

But if there tre changes, then l

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risk-inform:d methods --

2 MR. MIRAGLIA:

Then those --

l 3

DR. MILLER:

-- might be used to analyze those 4

changes.

j 5

MR. MIRAGLIA:

Yes, sir.

6 DR. APOSTOLAKIS:

How do you know unless you look?

l 7

DR. MILLER:

What's that?

8 DR. APOSTOLAKIS:

How do you know unless you look?

9 That there is no delta CDF that is positive.

That's the 10 point.

11 DR. MILLER:

No, what I am really saying is the 12 licensing -- the relicensing process is not meant to change 13 the current licensing --

14 DR. APOSTOLAKIS:

I understand that.

But how do 15 you know that you have accomplished that?

I mean you have 16 to look at the requests and somehow make that determination.

17 DR. MILLER:

I think that's part of the process, 18 you are going to make that determination.

19 MR. MIRAGLIA:

The current licensing basis is 20 being maintained.

21 DR. APOSTOLAKIS:

I think we have to close this 22 discussion because it goes on forever.

But all I am saying 23-is there ought to be some allowance somewhere in their 24 schedule for bringing into the process these other ideas, or i

l 25 a w:y or considering them.

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DR. MILLER:

It seems to m3 you can --

2 DR. APOSTOLAKIS:

You don't necessarily have to 3

-bring them in.

But the question will --

4 DR. MILLER:

No, George, it will come in 5

naturally, I think.

6 DR. APOSTOLAKIS:

That's what I am saying.

7 DR. MILLER:

Chris explained that earlier.

He 8

said if they are going to make changes in the plant, you 9

might want to use risk-informed methods to evaluate those 10 changes, and that will flow in that.

11 DR. APOSTOLAKIS:

You mean this is not a change in 12 the plant?

13 DR. MILLER:

No.

That's the whole intent.

It is 14 not meant to change the plant.

15 MR. MIRAGLIA:

The intent is to demonstrate that 16 this is the plant, the current licensing basis is 17 articulated, and they have processes in place tc.aake sure 18 that that current licensing basis is being maintained.

19 Fundamental principles of the Part 54.

20 They are not proposing to amend or modify the 21 facility.

What this is is a demonstration, is that we had 22

-- we were licensed under this basis and we demonstrated and j

23 we have processes and principles in place to demonstrate we 24 could operate this plant for 40 years.

We want to extend 25 for 20, and we are demonstrating that the adequacy of those l

(

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49 1

procedures and processes would maintain that same licensing 2

basis for --

3 DR. MILLER:

For another 20 years.

4 MR. MIRAGLIA:

-- an additional period of renewal, 5

up to 20 years.

So that's -- it's a process rule.

6 DR. MILLER:

It seems to me an ideal license 7

renewal, if everything is perfect, you would never use 8

risk-informed methods, you don't need to.

9 CHAIRMAN FONTANA:

Of course, one of the question 10 is --

11 DR. MILLER:

If it is not perfect --

12 CHAIRMAN FONTANA:

One of the questions is, as 13 things age, --

14 DR. MILLER:

Right.

15 CHAIRMAN FONTANA:

-- what is the effect?

16 DR. MILLER:

That's right.

17 CHAIRMAN FONTANA:

Yes.

18 DR. MILLER:

So if the aging management indicates 19 there is going to be a degradation in the licensing basis, 20 then maybe risk-informed methods would be very valuable.

21 DR. APOSTOLAKIS:

Well, so what you are saying is 22 that if I were to apply 1.174, I would find that delta CDF 23 is zero.

24 DR. MILLER:

Ideally.

25 MR. MIRAGLIA:

Ideally.

i l

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1 DR. APOSTOLAKIS:

So maybe --

2 MR. MIRAGLIA:

And the programs and the monitoring 3

programs are such that they either are controlling it and 4

can adequate demonstrate that it is good for 20 years, or 5

that they have enough controls to understand and identify 6

the degradation before it gets to the point where it is 7

going to impact.

8 DR. MILLER:

1.174 only applies to a delta, only a 9

change, right?

10 DR. APOSTOLAKIS:

Twenty years extension, it seems l

11 to me it is a hugh capital Greek Delta.

12 DR. MILLER:

The ideal thing is they are trying to 13 demonstrate it is not a delta.

14 DR. APOSTOLAKIS:

Well, anyway, let me repeat my i

15 point.

I think these questions will come up naturally and 16 there has to be a way of anticipating them.

Okay.

That's 17 all I am saying.

18 DR. SEALE:

At the risk of diluting or i

I 19 sidetracking a little bit longer, I think the real point, 20 though, is that if you really do look at something like the 21 use of the maintenance rule and the implications of the kind 22 of focused in-service inspection and so forth that is 23 involved in that, putting your resources where they count, 24 in the inspection process and so forth, that using a 1.174 25 process, if you have done that job right, you are going to 1

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have a decrease in CDF because now you are putting things 2

where they count most.

So it won't be quite the same plant 3

as you initiated, or you got the license for in the first 4

place using the old prescriptive rules on in-serve 5

inspection and so forth.

6 So if you do the whole job, you are going to have 7

to a 1.174 evaluation', or you will have done it, in effect, 8

when you put your maintenance rule implementation in effect.

9 And that is subsequent to the IPE or the IPEEE.

10 CHAIRMAN FONTANA:

So the question is, it is going 11 to happen, it is going to happen naturally, the question is 12 how much allowance ought to be in the schedule that we see 13 now to cover --

14 DR. APOSTOLAKIS:

To formalize.

I 15 CHAIRMAN FONTANA:

-- or will it happen after the 16 schedule that we are looking at.

17 DR. PRATO:

That's right, 1

18 CHAIRMAN FONTANA:

Proceed.

19 MR. GRIMES:

We currently don't have any 20 provisions to address delta CDF in the review and so there 21 is no attendant milestone associated with it, but we clearly 22 understand the question.

23 DR. SEALE:

It's embedded in there.

24 MR. GRIMES:

Yeah.

25' CHAIRMAN FONTANA:

Thanks.

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DR. PRATO:

Just let m3 add one more point from 2

the inspection program aspect.

Because risk-informed is a 3

big question that we deal with on a daily basis, we 1

4 considered that when we developed the inspection program.

5 And I am not sure if it is in the menu chapter or the IP, 6

but because the inspection program is a sampling program, 7

one of the criteria that need to be considered when you are 8

developing that sample is safety significance.

So from the 9

inspection process, we try to keep that -- be mindful of the 10 fact that risk-informed is a big part of our daily routine 11 here and we are trying to make sure it is being addressed 12 from the inspection process perspective.

13 This slide we just put up, this is the same exact 14 slide we showed you last time for the implementation.

We 15 talked about the different areas that we feel that need to 16 be inspected from the license renewal pre-approval and 17 post-approval inspection activities.

If there's one area 18 that I believe we have made significant progress in it's in 19 the implementation of the inspection program.

20 With respect to the progress that has been made in l

21 the inspection program, a letter went out from Sam Collins 22 to the Regional Administrators telling them it is time to I

23 get involved.

We have had a meeting with the Regions 24 earlier this month.

The Regions are on board, they have 25 been trained to some extent, as much as you can train l

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53 1

somebody in this rule without some practical experience in 2

applying it.

Okay.

3 And we have set some initial activities.

We 4

presented them with an information binder.

That information 5

binder has all the guidance documents.

It includes the 6

rule, the SOC, the previous rule, Reg. Guide 1047, which is 7

the Implementation Guide, NEI 9510, which is the industry's 8

Implementation Guide.

This SRP, all we provided them was 9

with an outline of the SRP, there's no reason for the i

10 inspector -- the Regions to get involved in the safety 11 review process other than to know what is being reviewed, 12 okay, and how we are going to apply that in the inspection 13 process.

14 We gave them copies of the office letter.

We also 15 gave them copies of Part 51, they needed to be aware of.Part 16 51.

There's almost no inspection activities on the Region's 17 part with Part 51, that is all being handled by consultants 18 here out of general office.

We also gave them final copies l

19 of the manual chapter and the inspection procedure itself.

20

.Again, the manual chapter and the inspection procedures are 21 large steps in the progress we have made over the last 22 couple of months since our last presentation to you.

23 They went back with the objective of reviewing and 24 getting themselves familiar with a lot of this information 25 beyond what we spoke to them about.

Our presentation was ANN RILEY & ASSOCIATES, LTD.

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54 1

l 1

mostly focused on what is important to help thsm, to help 2

guide,them and to help them focus their time more i

i 3

efficiently.

4 As a result of that, one of their primary i

i 5

objectives is to -- for them to define what they feel the 6

scope of the inspection process is supposed to be for f

1 7

license renewal, for the pre-application period.

Then I

8 they're also to overlay 2515 on these inspection objectives,

)

9 okay, what is required.

10' We are expecting to gain a lot of benefits with 11 respect to efficient use of resources.

We are very 12 confident that a lot of our activities are going to be 13 covered by the core program and most of the remaining stuff 14 are typical activities that we do on the regional i

15 initiatives, and we expect a minimum amount of activities 16 required for the pre-inspection activities to be beyond what 17 the Regions normally do.

i 18 Now, I say that with tongue in cheek, because 19 there's going to have to be a focus effort.

One of the 20 questions we are asking ourselves, do we implement the 21 license renewal inspection program and take credit for it 22 under the core program or do we implement the core program 23 and take credit for it under the license renewal inspection 1

24 program?

25 CHAIRMAN FONTANA:

Well, it raises a question of i

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55 1

are you going to use the same people, the same number of 2

people, or are you going to have to add some people to do 3

this?

4 DR. PRATO:

If a lot of the core program and a lot 5

of the regional initiatives can be applied, it would be a 6

lot of the same people doing what they would normally do as 7

part of their routine annual inspection activities.

To me, 8

it's just a change in focus.

And I believe that we should 9

do a license renewal inspection and apply it to the core 10 program.

That may change.

I mean that's what my hope is.

11 Because it is a lot easier because license renewal is such a 12 significant licensing action, it would be a lot easier for 13 us to focus the inspection reports on license renewal and 14 allow them to take credit for it in the core program area.

j ii 15 CHAIRMAN FONTANA:

But you are going to find out?

16 DR. PRATO:

Excuse me, sir?

17 CHAIRMAN FONTANA:

You are going to find out?

18 DR. PRATO:

Oh, yes.

That's what really this 19 activity is right here, this overlay.

We are going to be l

l 20 able to identify the delta on what additional resources are 21 needed.

Okay.

We are also going to take credit for this 22 year's core program and maybe even next year's, and there 23 may be justification for taking it back three years.

We are 24 going to review on what -- as to what we have looked at and 25 try to assess how big a sample we need based on that.

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i 56 l

1 what we plan to look at next year and the year after.

2 So we are really looking at a three-dimensional 3

effort here.

We expect to be able to document and justify i

4 what we have inspected and the basis for our reasonable 5

assurance that we verified is adequate for either approval t

6 or disapproval, depending on how it turns out.

7 The culmination of these activities will result in 8

developing an inspection plan.

The way we typically have I

9 done things in the past, including in the maintenance l

10 program, is we would either write a mannal chapter, but for 11 the maintenance program 2515 applied.

We have an inspection 12 procedure and we implement that inspection procedure in one 13 specific inspection.

Okay.

14 We are doing it a little different than license f

15 renewal.

I don't know if I can pull this out.

We have INC 16 2516 we have IP 71002.

This is the basic license renewal 17 inspection procedure.

And instead of going into a single 18 inspection activity like they normally do, we are going to 19 break off into several inspection activities.

Okay.

Some 20 of them are going to be during refueling outages.

Okay.

21 Others of them are going to be during normal plant 22 operation.

Okay.

23 What we are doing to tie all of this together, 1

24 because inspections are usually very well documented and i

l 25 very specific on activities that need to be done, is we are l

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inserting an inspection plan here.

Okay.

That inspection l,

2 plan will define the scope, will define the number of 3

inspections, okay, at least the initial number of 4

inspections planned.

It may result in addition, but right 5

now identify the scope, the number of inspections.

The 6

scope of each inspection, okay.

And the resources that will i

7 be required.

Okay.

And then that will allow us to -- and j

we expect these inspections to be implemented anywhere from 8

9 12 to 16, 18 months -- month period.

So we will get four 10 separate inspection procedures that, hopefully, will address 11 everything under IP 71002, 12 CHAIRMAN FONTANA:

Now, you'll have -- this says 13 there's going to be an SER on November '99.

14 DR. PRATO:

That's correct.

'i 15 CHAIRMAN FONTANA:

These procedures would be in 16 place by then.

Would there actually be actual inspections i

17 done in this two-year period?

Or are you just --

l 18 DR. PRATO:

I can talk about schedule.

Right now 19 with the manual chapter in place, with the IP in place, they 20 are done, along with those two procedures, we expect aging l

21 management program inspection procedures to be developed.

l l

22 We are in the process of doing that.

Our goal is to try to 23 get these done by the end of the year.

We are looking at 24 about eight or nine of them, okay, for the major aging 25 management programs that the industry seems to be taking l

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credit for.

Okay.

2 We expect to have the IP for Oconee and Calvert 3

Cliffs done by January 1.

We were hoping to start 4

inspections in March and April time frame.

On Calvert, the 5

Region says no, let's do it sooner, let's get going as soon 6

as we can.

So we have given ourselves a target date that we 7

can begin implementation of the inspection process January 8

1, that's our target date.

9 CHAIRMAN FONTANA:

This actually involves going 10 out there and climbing over hardware and things like that?

11 DR. PRATO:

Yes, sir.

It includes the 12 administrative review, the implementation review and the 13 aging management review.

14 CHAIRMAN FONTANA:

Thank you.

'i 15 DR. PRATO:

As far as the renewed licensing 16 inspection, we mentioned that we intend to make it part of 17 the core program.

But when you talk about the post-renewed 18 licensing inspection, three things come to mind, is what we 19 have to do to the core program, what we will have to do

)

20 under regional initiatives and resources.

21 And we are in the process or working that out.

A 22 large part of what we find out for the pre-inspection 23 activities will directly relate to the post-approval phase.

l 24 And we are relatively confident, especially with the 25 activities that are going on with the maintenance rule ANN RILEY & ASSOCIATES, LTD.

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pnople who cro doing bnsically c revamp of the inspection f

2 procedures for maintenance programs.

We are confident that 3

we are going to be ready for the post-approval period 4

without any problems.

5 DR. UHRIG:

What do you mean by regional 6

initiatives?

7 DR. PRATO:

What they do right now is, basically, 8

they set up a plan for inspections for each applicant on a 9

yearly basis.

10 DR. UHRIG:

Isn't that part of the core program?

11 DR. PRATO:

It's --

12 DR. UHRIG:

Incorporates the --

13 DR. PRATO:

It is and it isn't.

The core program 14 are minimum requirements that they have to do and they have 15 absolutely no choice to get it done.

There are some 16 regional. initiatives that they go out and look at things.

17 For instance, if there is an erosion, corrosion break at 18-Oconee, Region 4, it may raise the rest of the Regions' 19 sensitivity to erosion, corrosion and they add inspections 20 on erosion, corrosicn.

That's what is meant by regional 21 initiatives.

Okay.

It lets them focus on areas that are 22 not tied to the SALP, which really is the --

23 DR. UHRIG:

They are really unique to that 24 particular plant, in other words.

25 DR. PRATO:

Right.

Well, it may be unique to the l

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plant.

It may be a generic concern, like erosion, 2

corrosion.

It may be unique to the NSSS' vendor.

It could j

3 be a BWR issue, the core shroud cracking issue, that type of 4-thing.

Those are what is covered under the regional 5

initiatives.

6 Chris.

7 MR. GRIMES:

If I might, there's -- the term core 8

program and regional initiatives really stem from the way 9

that the program office establishes the budget for the 10 Regions.

And the systematic assessment of licensee 11 performance also comes into play in terms of there are 12 resources that are set aside to make sure that there is a 13 minimum amount of inspections that occur at every plant.

14 But then beyond that, the Regional Administrator has the 15 discretion to take these regional initiative resources and 16 allocate them on a plant basis or between plants.

17 And you see the end result if you look at the l

18 Director's monthly report and see the number of hours that 19 are spent at each site in a given period of time.

And the 20 problem that we face is that license renewal will likely --

21 is not likely going to apply to plants that are problem 22 plants.

23 So the Region is probably going to have their i

24 resources on the problem plants and we need resources to 25 work license renewal, so there are resource-competing l

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effects.

And that's why Bob emphasized that the Regions are 2

overlaying this 2515 program in order to see where they are 3

certain they are going to have time that could be modified l

4 to suit both their needs and the license renewal finding.

5 And then where have they got discretion with their resources 6

that they could use and where do we need to contribute more 1

7 resources in order to support the. renewal finding?

8 DR. SEALE:

At the same time, there is some murmur 9

out there that says that if you have a non-problem plant 10 that has a good SALP rating and all of these other things, 11 it doesn't necessarily require the same level of attention 12 as a problem plant does.

13 And it seems that an inspector who knows something 14 about the reality of that plant can probably be more helpful 15 in doing some of the things associated with renewal, says 16 that maybe you aren't as -- let's say, not dollar-wise 17 resource, but now bodies with the brains that are in their 18 heads resources, limited as you would be otherwise.

l 19 I mean you've got people who know the plant.

It's 1

20 a good plant, and here is something that they can do that's I

21 constructive to supporting the program as it moves along.

22 So it's not all bad.

23 MR. GRIMES:

No, it -- and that was the point in 24 terms of taking advantage of the core program, recognizing 25 the talent that is being applied, even to the very good --

I 1

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DR. SEALE:

Yeah.

2 MR. GRIMES:

-- performers, although it's less 3

than the level of attention and resources that are applied 4

to other plants, it's still a very useful resource.

5 DR. SEALE:

Yeah.

6 MR. GRIMES:

That we don't -- we don't want to 7

hamper the value that that resource plays in maintaining the 8

confidence level in the current operation.

9 And that's part of the debate that continues in 4

I

(

10 terms of the senior management process and the allocation of i

l 11 resources in terms of what value is added by being a I

12 regulated entity, and I don't want to go there.

13 DR. UHRIG:

You made a remark -- you made a remark 14 a minute ago about not expecting the problem plants -- I

(

15 believe the same ones that were -- had license renewal.

16 Is that what you really meant to say?

17 MR. GRIMES:

Yes.

That's what I really meant to 18

say, i

l 19 DR. UHRIG:

And you don't expect a plant on the 20 problem list, what you want to call it, the watch list, to 21 be applying for renewal?

22 MR. GRIMES:

Not while they're on the watch list.

23 It's my expectation that a utility will not want 24 to expose itself to litigation while they're on the watch 25 list, but that's my personal opinion.

That does not mean ANN RILEY & ASSOCIATES, LTD.

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that th'ny would not ba interested in license renewal, it f

2 would meant -- it would affect the timing.

3 DR. UHRIG: 'The timing issue, not --

'4 MR. GRIMES:

Right.

5 DR. UHRIG:

Not a work list?

6 MR. GRIMES:

Right.

They would -- a licensee is, I

7

'you know, as concerne'd about allocating resources, as I just 8

explained, the regions are.

They're not going to want to 1

9 spread themselves so thin that they're fighting being on the l

l t

I 10 watch list at the same time that they're trying to devote 11 resources, 12 And these are not insignificant resources, j

13 although I will say, I've been pleased to see that the cost 14' estimates for license renewal have come down from a value of 15 200 million that was quoted just a little over a year ago, 16 and now we're seeing numbers in the range of ten to --

17 through $30 million to complete a license renewal 18 application.

And we'll be pleased to see if that estimate 19 comes down a little bit further, although I don't want it to l

20 go below the cost of an IPE.

l 21

[ Laughter.)

22 MR. PRATO:

Okay.

Again, in summary, a lot of the 23 implementation documentation is in place.

Training is 24 ongoing, and our next major milestone is the inspection 25' plans, and we expect to have those done by the beginning of ANN RILEY & ASSOCIATES, LTD.

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64 l

1

'the year '99..

2 That completes the inspection program 3

presentation.

If you'd like, I'll go on straight to 805.

4 That's up to you.

We can take a short break if you want.

5 It's --

6 CHAIRMAN FONTANA:

Is this a good time to take a 7

break?

8 DR. APOSTOLAKIS:

Yes.

9 CHAIRMAN FONTANA:

It's scheduled for ten, so --

10 MR. PRATO:

Does anybody have any more questions 11 on the inspection program?

12' CHAIRMAN FONTANA:

Pardon?

13 MR. PRATO:

On the inspection --

14 DR. APOSTOLAKIS:

Any more questions that they

[ (

15 want to ask at this time?

16 MR. PRATO:

Yes, sir.

I'm sorry, i

17 CHAIRMAN FONTANA:

I guess -- let's take a break 18 until 10:15?

19 MR. PRATO:

Yes, sir.

20

[ Recess.)

21 CHAIRMAN FONTANA:

The meeting will reconvene and 22 pick up wherever you want to.

23

[ Discussion off the record.)

24 MR. PRATO:

Just one other point.

This team of 25 regional people and PDLR staff, their final objective will I

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be to revise the manual chapter in the IP, which hopefully, i,

2 will glean all the lessons learned after the first couple of 3

inspections and be able to develop a procedure that can be 4

used generically and be as effeccive as we hope the overall 5

process will be.

)

t 6

The next portion of my presentation is on NRC 7

office letter -- NRR office letter 805.

And if you'll 8

remember from my last presentation in January, the office 9

letter is really broken down into four separate sections.

10 You have the office letter itself, which provides the 11 guidance and the controls and the basic outline for the 12 review -- technical review process.

It defines the roles 13 and the responsibilities under branch level and above, okay.

14 And within that office letter, there are four 15 separate guides, four separate attachments, okay.

I'm 16 sorry.

Three separate attachments, okay.

17 The first attachment is the guide for reviewing 18 license renewal applications.

Okay.

That guide provides 19 the guidance on the staff level.

It defines the roles and 20 responsibilities of the different organizations, and it 21 provides the staff with the basic process of developing a 22 safety evaluation.

23 The second guide, the guide for processing renewed i

24 licensing action items, this is sort of a unique guide.

The I

25 intent is to -- the overall intent for the license renewal ANN RILEY & ASSOCIATES, LTD.

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process is to make it modular, okay, if you will.

Not to 2

have a lot of renewal activities bleed in -- over into the 3

operating reactor space, and not forcing operator reactors 4

to have to backtrack through the license renewal process.

5 Once the application is approved, we want 2515 and

)

6 routine reactor operations programs to be able to handle the 7

-- the approved licenses as they would for the 40-year 8

license -- the 60-year license as they would for the 40-year 9

license.

10 I think this guide accomplishes that, and I'll get 11 into details on that in just a moment.

13 DR. UHRIG:

In other words, what you're saying is 13 that there is no additional requirements likely to be 14 imposed as a condition for extending the license?

15 MR. PRATO:

No, not at all.

What we're saying is 16 that the process that's being used for regulating and 17 monitoring and control and operating reactors for 40 years 18 would be the same process for 60 years.

19 It doesn't mean that there won't be additional 20 actions.

For instance, if there are license conditions, we 21 have to verify that the license conditions are implemented 22 correctly.

23 DR. UHRIG:

When would those be effective?

At the l

24 end of 40 years?

25 MR. PRATO:

The license conditions?

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DR. UHRIG:

Would it be -- that is, if you 2

approved Calvert Cliffs or Oconee right now, two years from 3

now, two and a half years from now, you approved it, would 4

they become effective immediately if there were license 5

conditions, or would they be implemented at the end of.the 6

40 years?

7 MR. PRATO:

Well, the license conditions, okay, 8

would become effective at the time of signing the license, 9

but the target dates may be down the road somewhat.

10 For instance, if EQ is an issue, okay, and they --

11 the licensee's promise to do some actions prior to the end 12 of the 40-year cycle, the due date may be in the year 38, 13 for instance, okay?

14 As long as these requirements are documented that 15 the licensee has to meet these commitments, okay, as long as 16 they're documented and they have target dates, the license 17 condition -- we just have to verify that the license j

l 18 conditions are met at the time they're supposed to, based on l

19 what's documented in the license.

l 20 DR. UHRIG:

So it's no different than any other I

21 commitment?

22 MR. PRATO:

No, sir.

No, sir.

23 Finally, the guide for the technical and process 24 list for license renewal, I'll get into this in a lot more 25 detail.

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This affects all the activities oriented around 2

license renewal.

The intent is to have a formalized 3

documented process that tracks not only the issues that are 4

identified to completion, but through implementation and 5

verification, that the implementation is complete and 6

accurate.

7 DR. SEALE:

You reminded me of something, Mr.

1 8

Grimes.

I think at this last full Committee meeting, we 9

agreed to send you folks a Larkins gram regarding the review 10 of the environment-reports.

I think it was -- it had to 11 do with license renewal, and indicated we didn't want to 12 talk about things much right now.

13 But I was wondering, toward the end of the day, if 14 you could give us a thumbnail capsule of any changes that 15 you might be able to highlight for us on that process so 16 that we can sort of do a double check, do some ground truth, 17 if you will, on our decision not to look at that in detail.

18 MR. GRIMES:

When I go over the schedules, I'll 19 talk about where the --

20 DR. SEALE:

Fine.

21 MR. GRIMES:

-- the environmental review --

j l

22 DR. SEALE:

Okay.

]

23 MR. GRIMES:

-- milestones are.

24 DR. SEALE:

Okay.

Fine.

Thank you.

25 MR. PRATO:

Okay.

And the next slide, this next ANN RILEY & ASSOCIATES, LTD.

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slids, it's a slido under the first attachment to letter 2

805.

It basically shows the process for reviewing an 3

application.

It identifies the submittal and the acceptance I

i 4

review.

5 It talks about the work planning process.

Work 6

planning process is really the heart of an effective review, 7

okay.

And a lot of activities in that area, not only to 8

plan the work, but to improve the planning process and to 9

improve the overall safety evaluation review.

10 It talks about the review, the request for 11 additional information, the response for request for 12 additional information.

13 It identifies the public hearing process.

I 14 believe that that's either just been resolved or is still in

(

15 final resolution.

I'm not active in that area, but Mr.

16 Grimes, I'm sure, will address that specifically.

17 And it talks about developing the final safety 18 evaluation, the ACIS review and reporting activities, and 19 the granting or the rejecting of a renewed license.

20 DR. UHRIG:

What are the arrows going to the left?

21 MR. PRATO:

The IP is the issue points.

That 22 falls under the feedback process, okay.

These are the areas 23 where we expect to identify feedback and --

24 DR. UHRIG:

From whom?

Feedback from?

25 MR. PRATO:

From everybody.

From the public, from l.

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70 1

our technical reviewers, from the industry.

2 i,

We're very active with the industry right now, and 3

I'll get in -- a little bit more into that in a few minutes

)

4

-- from ACRS.

Basically everybody that has any input to the 5

process.

6 CHAIRMAN FONTANA:

Do you have the issue points?

7 Are you going to get into how you -- how you're 8

going to reach closure on these --

9 MR. PRATO:

Yes, sir.

10 CHAIRMAN FONTANA:

-- points?

11 MR. PRATO:

Yes, sir.

12 CHAIRMAN FONTANA:

Okay.

13 MR. PRATO:

Yes, sir.

14 One of the major issues that we're facing today is i

15 level of detail, not only in the application, but in the 16 FSAR supplement, okay.

17 The other question that comes to mind is that this 18 is su~ch a significant licensing action, okay.

We absolutely 19.

need a means to verify that the questions and answers were 20 complete and adequate.

So what -- and on top of that, we're 21 trying to develop a process that, again, is modularized, 22 that the operating reactor people don't have to -- five or 23 ten years after the license is approved, when they're 24 checking on a license condition, they really don't have to 25 backtrack to the license application review process.

And so ANN RILEY & ASSOCIATES, LTD.

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that the license renewal review activities don't bleed over

(

2 into the operating reactor space, that these people have to 3

continue to be involved, and they can concentrate on the I

4 application review and the application review alone, okay?

5 So what we did was we developed a process, and 6

what we're asking the safety evaluation people, basically, 7

as well the inspections -- inspection people to do is to 8

document the findings, okay.

9 What did they need to make their finding under 10 5429, okay?

11 As they go through the FSAR review, there's the 12 documents specifically.

Those issues that they identify as 13 critical to their findings will be put in a database.

That 14 database will come down to the final review process.

i 15 Also, it will be documented in the safety 16 evaluation, okay, and it will provide input to the FSAR 17 supplement, the license conditions tech spec requirements 18 and-the inspection program, okay.

19 At the time of final review, the database will 20 identify the item, where in the renewed licensing package, 21 which includes the license itself, tech spec changes, and 22 the FSAR supplement, okay, and the inspection reports where 23 these issues were addressed and resolved.

24 So we have a database that's tracking each 25 individual issue, okay, and where the -- where these issues ANN RILEY & ASSOCIATES, LTD.

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have been resolved or entered or documented in the process.

(

2

-Based on this, we do a verification and that 3

verification will provide us with a high-level of confidence 4

that the process has been completed, okay?

5 Our intent from there is to forward this 6

information to the regions to allow them to keep track of 7

any open items that they have to track, any license 8

conditions, okay, and to keep a well-documented history of 9

what was done for the renewed application.

10 DR. SEALE:

You've got an interesting mix here.

I 11 When you talk about things you send to the regions and so 12

-forth of a generic nature, you're talking about the ground 13-

-rules under which tha process will proceed, and there are 14 certain calculations.that will need to be done to support i

15 that.

16 But for many of the reactors, these reactors were 17 licensed under the -- on the basis of margins.

18 MR. PRATO:

Right.

19 DR. SEALE:

They were based on -- their license 20

-was based-on margin-type calculations, rather than best 21 estimate calculations, and some recent experience we have i

22 suggests that, in some cases, the codes that were used to 23 make those initial margin calculations 20 years ago may not i

24 be too husky right now; that is, just in terms of the 25 availability of a machine to run them on.

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And I think our position is going to be that we 2

want these kinds of analyses, when they're done, to be very 3

scrutable.

If, indeed, this is a continuation of the 4

initial license, clearly, we have to accept the idea that it 5

is based on a margin calculation, but it's going to have to 6

be a margin calculation that has some robustness.

7 And so I'm just telling you, we're going to look 8

hard.

9 MR. PRATO:

Those calculation reviews are a part 10 of the technical review.

I don't see that having an impact 11 on -- after the license is approved.

That certainly should 12 be addressed before the --

13 DR. SEALE:

Yes.

14 MR. PRATO:

-- approval process.

15 DR. SEALE:

Yeah.

16 MR. PRATO:

Okay.

It sounds like you're talking 17 basically about time and aging analyses?

18 DR. SEALE:

Well, that and'--

19 MR. PRATO:

How that --

20 DR. SEALE:

-- and some of the -- yeah.

That kind I

i I

21 of thing.

Yeah.

1 l

22 MR. PRATO:

Okay.

Chris, do you have -- want to 23 add something?

24 MR. GRIMES:

Yeah.

I -- I hesitate because part 25 of the rules of the game, in terms of carrying over the I

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current licensing basis is we will accept the design 2

analysis as it exists today.

3 MR. PRATO:

Okay.

4 MR. GRIMES:

In order to demonstrate aging 5

management, for example, there's a minimum law for erosion 6

analysis.

Some of those analysis, as you point out, aren't 7

all that robust.

They.-- they may be better than when the 8

plant was originally constructed, but they clearly are not 9

going to satisfy the standards for a new license application 10 today.

11 And I think we're going to run into a lot of 12 circumstances where we're going to have to make some rather 13' pithy backfitting decisions about whether we want them to go l

14 back and reanalyze the design basis in order to get a better 15 handle on what they're using as thresholds for making 16 corrective action decisions, like. minimum wall is the only 17 one that really springs to mind right now.

But maybe when J

18 we get into the, you know, vessel embrittlement issues.

]

19 DR. SEALE:

And I think those are some of the s

.20 issues that we may be wishing that you would bring to our 21 attention whenever you get to that point.

22 MR. PRATO:

Chris, correct me if I'm wrong.

Will 23 we find issues like this?

I don't believe that it will be i

12 4 addressed under license renewal.

It will be referred back

^

25 to current operating concerns.

l l

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MR. GRIMES:

Yeah.

If there's a question about 2

the adequacy of the margin at all --

3 MR. PRATO:

Yeah.

4 MR. GRIMES:

-- then we'll have to face it in 5

terms of what does it mean to continue plant operation.

)

6 But in terms of the way that you posed the 7'

question, the generic nature of some of these questions, f

8 rather than plant specific things that will probably be 9

revealed through a request for additional information or 10 possibly open items in a safety evaluation report, we're --

11 Bob's going to go over the broad generic issues associated 12 with license renewal implementation, and you'll see a few 13 choice ones in there that will interest you.

14 And I'll tell you right now that our intent is 15 that as we address these issues formally and communicate 16 them with the Nuclear Energy Institute, you'll be on 17 distribution as we reveal how those issues are unfolding.

18 And it would probably be appropriate for us to talk about 19 whether or not there are just some points in time where we 20' will stop -- or will pause and discuss the status of those 21 things with the ACRS in a general way.

22 DR. SEALE:

Okay.

23 MR. PRATO:

Okay?

Before I go on to the next 24 slide, I pointed out the IP's, okay.

We also have another 25 code, the licensing issues for license renewal.

Those j

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licensing issues for license renewal are the input to the c

2 renewed licensing item process.

And here is the input for 3

the IP's.

4 All those issue points end up being dumped to the 5

IC Coordinator, which right now, I'm acting as the IC 6

Coordinator.

Is assigned specifically to somebody right now 7

within License Renewal.

That's our intent.

8 If it's a process type of question, typically, 9

we'll resolve it internally to license renewal.

10 If it's technical, okay, or legal oriented, it 11 will -- we will involve whoever we need to involve, from 12 design engineering to OGC.

Okay.

13 Regardless of how we decide to resolve it, whether 14 it's going to be a team effort or an individual effort, the i-15 objective is to either identify resolutions or options, 16 okay.

17 If we take the path of identifying options, it 18 gets kicked up to the Steering Committee, basically.

Gets 19 sent up the chain of command to the Steering Committee.

The 20 Steering Committee decides whether it's Commission level, 21 okay, or whether or not -- or selects the option themselves.

22 From there, it gets into the review and approval 23 process.

The industry is part of that review and -- it's 24 not part of the review and approval process.

I apologize.

25 The responsible organizations are part of that j.

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review and approval process.

When that decision has been 2

resolved, if it affects the development and implementation 3

aspects of it, it gets sent to the industry for their 4

comments.

5 And we've done that on a number of issues.

Some 6

of them have been kicked back, and they get kicked right 7

back into the process again at the top, okay.

8 From there, we make any appropriate changes to the 9

office letter, to the SRP, to the rate guide, and to the 10 manual chapter in IP's for the inspection program, okay.

11 From there, we verify that the documents have been 12 revised appropriately before the item gets closed.

13 MR. GRIMES:

I'd like to add a clarification about 14 the resolution.

i 15 The first step in the resolution process, at the 16 top of that box to the left, is management involvement, 17 which is a very important feature.

I get a first crack at 18 these things in terms of establishing whether or not the.

19 particular -- whether or how a particular issue is going to 20 get addressed and resolved.

21 My primary role is going to be to test the issues 22 in terms of reasonableness and fairness, and also to look at 23 it from a priority standpoint.

24 Line management gets the first opportunity to l

25' resolve an issue.

Bob said to go to the Steering Committee.

l.

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I don't expsct that wa're going to go to the Stenring 2

Committee with two or 300 solutions, but if'this is anything 3

like improved tech specs, where we had literally thousands 4

of issues --

5 We went to senior management on a half a dozen 6

occasions with particular issues, and maybe came out with 7

one or two policy issues that stem from that.

8 I expect to see the same kind of thing in license 9

renewal where we're going to have several hundred questions.

10 Some of these questions are going to break down into dozens 11 of other questions.

12 This process is a means of maintaining an 13 inventory and a control and a focus, and making sure that 14 good ideas don't get lost or questions don't get lost so 15 that we -- that we're assured that this evolution is going 16 to be a growing process and a learning process.

l 17 MR. PRATO:

Okay.

As for the status, the office 18 letter was approved on June 19th.

It's in effect.

In 19 reality, it's been in effect for quite some time prior to 20 that.

21 The guide for reviewing license renewal 22 applications has been in the implementation phase for --

23 since March 18th, was it, when BG&E came in with their 24 original application.

25 It seems to be working well.

We've got a number ANN RILEY & ASSOCIATES, LTD.

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of itcms fed back to us.

They're in the lessons learned 2

process, and they're being worked through the process as it 3

was designed.

4 The second guide, the guide for processing renewed 5

licensing action items, is a little bit premature right now.

6 We're only in the RAI phase for the BG&E application and we 7

just received the Oconee application.

8 But we do have a database in place.

We do have 9

forms that.need to be filled out, and they -- we -- since 10 PDR -- PDLR is the focal point and responsible for this 11 database, we're going to ensure that that gets done.

12 And I believe we have one item in that database, 13 okay, and what it is, off the top of my head, I don't 14 remember.

But, nonetheless, it's active and it's moving 15 along.

16 As for the guide for technical and process lessons 17 learned, that has also been in place for some time.

It was 18 put in place prior to June 19th.

It probably began in --

19 probably in January of this year, we started working in that 20 database.

21 We've got some 50 plus items in there.

Those 22 items include the 13 NEI items, the 17 EPRI items, plus a 23 number of proceasing items, plus some technical issues that 24 our design folks have raised, okay.

25 Along with that, we're expecting to meet with NEI l

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nsxt week to gain anywhere from 150 to 170 other additional 2

items, more focused on the guidance documents, okay.

We 3

have a meeting planned for next week to do that.

4 Once again, during our January meeting -- I'm 5

going to try to overlay both of these slides so we can have 6

them up there at the same time.

7 It's difficult.

I don't think I can do that.

8 But, nonetheless, these are the license renewal 9

items, the 13 Jicense renewal items that were basically 10 initiated by NEI.

We talked about these briefly last time.

11 Along with that, here it is, 17 issues from 2PRI.

12 There is some overlap, but none of those questions 13 where there's overlap, have they been asked the same exact 14 way.

We may come up with a single resolution to both of 15 them, but we did not want to take a chance on missing some 16 of the fine points, so we -- we put both lists directly into 17 the database.

18 DR. MILLER:

And that's the list of issues where 19 there is disagreement?

Is that the --

20 MR. PRATO:

Some of theme, disagreements.

Some of 21 them, I think, are basically resolved.

It's just a matter 22 of insuring that the process is well documented.

But for 1

23 the large part, yeah.

We're still doing a typical 24 evaluation.

i 25' I wouldn't say that disagreement.

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DR. MILLER:

Yeah.

Disagreement is too strong.

2 MR. PRATO:

Yeah.

3' DR. MILLER:

There's a difference of opinion on 4

the --

5 MR. PRATO:

There may not even be that.

There may 6

be new information that EPRI provided us that we're still 7

evaluating.

Fatigue is a perfect example, and I'll talk 8

about that in just a minute, okay?

9 DR. APOSTOLAKIS:

Now are you -- would you put up 10 the NEI 11 MR. PRATO:

Sure.

12 DR. APOSTOLAKIS:

What exactly did they think was 13 a issue with item 7?

14 MR. PRATO:

Item 7, Risk Conformed License 15 Renewal.

I believe and let me see if I have my responses 16 here.

17 MR. HOFFMAN:

Bob?

Bob?

My name is Steve 18 Hoffman.

I'm with the License Renewal Branch.

19 Is part of the development of the draft reg guide 20 and the review of the NEI 9510 implementation guidance, we 21 got some comments that they wanted a little more guidance on 22 exactly how risk would be used in the application for 23 renewal.

j 24 DR. APOSTOLAKIS:

This is what we were discussing 25 earlier.

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MR. HOFFMAN:

Tes.

2 DR. APOSTOLAKIS:

They would like to know more 3

about how you plan to use the risk dimension.

4 MR. PRATO:

I think -- I think the gist of this 5

more is in the direction of what the SOC says we're going to 6

use with respect to --

7 DR. APOSTOLAKIS:

Right.

8 MR. PRATO:

-- risk information.

9 There is statements in the SOC that says exactly 10 what the Commission had intended, if you will.

I don't 11 think it goes to the depth that your question raised.

But 12 13 MR. HOFFMAN:

That's correct.

The SOC talks about 14 if you have a structure component that's within the scope of 15 a license renewal that you need to evaluate, that risk can 16 be considered in establishing the level of aging management 17 in more or less the robustness of the program required.

And 18 so it was just an area that they wanted to just, you know, 19 somebody requested that a little more guidance be provided 20 as to how would you go about using it in that context.

21 But Bob is right.

It's more along the lines of 22 what the SOC statements address.

23 MR. GRIMES:

And this is Chris Grimes.

24 I'd like to add to that.

I want to clarify the 25-scope of these issues.

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This is a condensed list of a lot of questions and 2

comments that evolved from the time that the staff attempted i

l 3

to endorse NEI guideline 9510 for implementation and license I

4 renewal.

And as Bob pointed out, in some cases, we --

5 you'll find that these are very broad -- too broad, in fact 6

-- very broad issues that lack -- that need some clarity put 7

to them, and are very controversial, all the way down to 8

some relatively minor questions like item 13, degradation 9

induced by human activity.

10 That's to what extent do you account for how 11 humans constitute aging effects?

And the staff's position 12 is, "We're not going to attempt to try and define aging 13 effects caused by human activity?"

That's a -- that's a 14 natural part of the processes for maintaining a plant.

15 MR. PRATO:

That's one of the issues I'm going to 16 be going over --

17 DR. APOSTOLAKIS:

We're not --

18 MR. PRATO:

-- a little bit more.

19 DR. APOSTOLAKIS:

-- extending the life of humans.

20 MR. GRIMES:

I know.

We're not --

l 21 (Laughter.)

22 MR. GRIMES:

We're not going to attempt to explain 23 how to extend the life of a human.

24 DR. SHACK:

Just renew their license.

25 DR. APOSTOLAKIS:

Why won't you?

l l

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84 1

MR. GRIMES:

And it gets to th@ purpose for this 2

process.

We want to make sure that we -- that the question 3

is clearly defined in a way.

4 First of all, it's within the scope of the job 5

that we've been asked to do, and then secondly, so that the 6

answer is meaningful.

7 And so some of the -- their -- there's a broad 8

range of issue on here.

This is issue with a little I.

And 9

a lot of these need to be framed in terms of questions for 10 which we can reasonably expect to find answers.

11 DR. APOSTOLAKIS:

Can we get a description of 12 these?

13 MR. PRATO:

I believe I have a brief description 14 of those issues.

Isn't that what --

15 MR. HOFFMAN:

We have some.

We can get it for 16 him.

17 DR. UHRIG:

For issue number 12, I haven't the 18 foggiest idea what it is.

19 MR. PRATO:

If you -- consumables.

If you look at 20 the rule, it says for it to be long-term, okay, it needs --

l 21 it cannot -- it's long-term if it's -- it's short-term if 22 it's not in a specific replacement program that specifically 23 identifies the frequency of replacement.

24 And you take a look at consumables.

Typically, i

I 25 they don't have a specific frequency of replacement.

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They're replaced as you enter a system.

l 1

2 If you break a seal, you replace gaskets, okay?

3 But they certainly don't meet what we initially felt was the 4

intent of the rule as long-term.

They don't -- typically, 5

consumables, you won't keep into the system for 40 years.

6 On top of that, the codes really don't take credit 7

for many of the consumables.

But since they didn't fit the 8

guideline of what's long-term and what's short-term, and 9

based on the rule they fit into the long-term, they would 10 end.up within the scope of the rule.

11 So we are trying to deal with this so that we can 12 document what the final decision is on that, how the rule 13 applies to these items, okay?

14 That is not a final resolution yet.

15 MR. HOFFMAN:

The term, "consumables," may not 16 accurately describe it.

We are talking about like gaskets, 17 packing seals.

Like you may have a gasket on a manway.

18 DR. UHRIG:

Consumables would not be gasoline or 19 diesel fuels?

20 MR. HOFFMAN:

No.

But this is more -- it -- in 21 particular, it's gaskets, packing and seals.

22 DR. UHRIG:

Seals.

23 MR. HOFFMAN:

And you may have a gasket on a 24 manway that you're not going to routinely replace that.

25 You're going to replace it when you go in.

And so the l

l l

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question was, is how do you address that gasket for license 2

renewal?

3 Some of these items are actually just items that 4

we identified at the time we were developing the guidance 5

that needed further clarification in the future.

They 6

weren't reactors issues.

It's just something we needed --

7 we wanted to develop more fully in the future.

8 MR. PRATO:

I'm going to go over a couple of these

.I 9

items.

Certainly these are dispersed among the staff, and a 10 lot of the specifics are no one person knows all the 11 specifics.

But I'll do the best I can on describing them.

12 I have some supporting documentation, and I'll do what I can 13 to help you.

14 GSI letter -- GSI safety issues.

In one of our i

15 earliest presentations to the ACRS, you gave us some j

16 guidance on how we should hand GSI's and made some 17 recommendations to us.

18 We issued a letter in January of '98 that I

19 basically told the industry that the staff has -- the staff 20 developed criteria for which GSI's applied to license 21 renewal that may potentially have application to license 22 renewal -- not applies, but potentially has application to 23 license renewal.

So we gave them criteria.

24 And we also did a review of NUREG 933, based on 25 supplement 21, which was issued in 12-96, and gave them a ANN RILEY & ASSOCIATES, LTD.

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87 1

snapshot of which ones we thought were potentially 2

applicable to license renewal.

This was based on guidance 3

that we received from you folks in one of our earliest 4

presentations on license renewal.

5 DR. UHRIG:

Is this the issue that was -- that had j

l 6

lines of the paper a week or so ago about specifically fuel I

7 storage, spent fuel storage?

8 MR. PRATO:

Chris?

j l

9 MR. GRIMES:

No.

Actually, that's in a Part 51 1

10 arena, the environmental impact issues.

The -- when we 11 described the process to the public, they were most annoyed 12 that the Commission has chosen to exclude from a license 13 renewal finding things like a high-level waste repository l

l 14 for the nation.

l l

15 Essentially, what Part 51 refers to is the

)

16 category 1 issues, i

17 These are -- this is more classically described as l

18 the ALAB 444, the Atomic Safety and Licensing Board, back 20 19 years ago or so ago, said that the Commission can make 20 decisions on licensing actions, even though there may be 21 some germane generic safety issues that remain unresolved.

22 And there is a -- the process that we go through l

23 is to look at pending generic safety issues and say, "Which 24 ones of these relate to the licensing action, and then 25 address them in terms of why it's okay to permit them to i

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88 1

continuo to be unresolved since we -- since the process has 2

been developed for 0933 that now provides us with a point of 3

departure to do it a little bit more efficiently.

4 But there's still some room for further 5

improvements in terms of explaining in some more detail how 6

to address generic safety issues in an efficient way.

7 MR. PRATO:

Okay.

As a follow up to the GSI 8

question, if you take a look at number 2, the volume on 9

qualification of tabling, the staff, on June 2nd, issued a 10 letter to NEI that basically told them how to address GSI 11 168.

Okay.

12 GSI 168 is the GSI on environmental qualification, 13 and basically the staff told them that they did not have to 14 address 168 for license renewal until it's been resolved by 15 the staff.

16 However, okay, EQ is still within the scope of 17 license renewal.

They still have to address EQ as an aging 18

-- as an aging effect.

19 MR. GRIMES:

Bob, if I --

20 MR. PRATO:

Sure.

21 MR. GRIMES:

We have to address EQ because it is a 22 time limited aging analysis.

23 As far as EQ --

24 DR. UHRIG:

I'm not sure I understand that 25 statement.

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Could you elaborate?

2 MR. GRIMES:

Part 54 provides that there are two i

3 components to aging management.

One is identifying passive j

I 4

structure systems and components that age, and describing 5

how the aging effects will be managed.

3 i

6 But there's a second part to the license renewal 7

decision, and that's'a recognition that the design includes 8

some design analysis that have time dependent features.

9 If you had to -- if you had to use 40 years in 10 your design calculation, that's a time limited aging 11 analysis.

All of the environmental qualification packages 12 include analysis that demonstrate that the qualification is 13 suitable for 40 years or more, and depending on whether or 14 not the EQ package has a particular time constraint in it, 15 it fits within a scope of stuff that's called " time limited

]

16 aging analysis," as opposed --

17 So we address it there as a design analysis.

We 18 address the other stuff in terms of managing aging effects 19 in a process way.

20 CHAIRMAN FONTANA:

Is it pretty clear cut?

Is it 21 going to be pretty clear cut on what is involved in a TLAA, 22 or is there going to be a lot of kind of decisionmaking as 23 you kind of go along?

24 MR. PRATO:

With our experience in the 25 demonstration program?

l I

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CHAIRMAN FONTANA:

Yeah.

2 MR. PRATO:

I don't believe that there's any 3

problem with that.

I think TLAA's are a lot more specific 4

and a lot easier to define than aging management, in 5

general.

But that's just a -- a general observation that we 6

identified during the demonstration program.

7 MR. HOFFMAN:

The Commission --

8 CHAIRMAN FONTANA:

But there could be differences 9

of opinion?

10 MR. HOFFMAN:

Well, the Commission offered, in the 11 SSC for the rule --

12 MR. PRATO:

I've got that --

13 MR. HOFFMAN:

-- provided three approaches.

14 One, you know, your analysis already may be 15 adequate for the 60 years.

So all you do is you go back and 16 verify your analysis is good.

17 The second approach would be to revise your 18 analysis to show it's good out to 60 years.

19 And then the final way to be is to, more or less, 20 manage the effects of aging.

You know, if you can't revise 21 the analysis, you might decide to replace it periodically or 22 something like that.

23 So there are three approaches, and so far, we 24 haven't seen any.

25 MR. GRIMES:

I understood your question to be more l

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1 towards is there going to be any controversy about what is 2

the time limit or ging analysis.

3 CHAIRMAN FONTANA:

That was my question.

And then 4

the next question is, once you decided -- and I guess that's 5

a technical question about how is the analysis performed 6

with respect to anticipated lifetime, and things like that.

7 MR. GRIMES:

And the reason that I hesitated is 8

because I was about to say time limited aging analysis are 9

almost self-evident.

You ought to be able to spot one a 10 mile away.

l 11 But then it occurred to me that there may be some 12 left-handed thinker and comes in and says that the vessel is 1

13 a time limited aging analysis and -- and I don't need to --

14 I don't need to address aging effects or embrittlement or 15 anything else.

I'm just -- you know, it's a TLAA, and I'm 16 going to, you know, do a reanalysis, which I don't think was 17 the concept.

It was more towards EQ and fatigue cycles and 18 it's in what we consider to be classical time dependent 19 design analysis.

20 I -- my suspicion is that it's not going to be 21 tremendously controversial.

There's a general understanding 22 of.what a time limited aging analysis is.

1 23 CHAIRMAN FONTANA:

Okay.

j 24 MR. PRATO:

Okay.

And a follow up to Chris' i

25.

original discussion on time limited aging analysis and aging l

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management, the SOC -- there's a statement in the SOC that 2

i'll read to you very quickly:

"A resolution of a USI and 3

GSI generically for the set of applicable plants is not 4

necessary for the issuance of a renewed licensa.

GSI's and 5

USI's that did not contain issues related to license renewal 6

aging management review and time limited aging evaluations 7

are not a subject of review or finding for license renewal.

8 "However, designation of an issue as a GSI or USI 9

does not include -- does not exclude the issue from the 10 scope of aging management review or time limited aging 11 analysis."

12 As a follow up to the discussion on 168, we have 13 another item that's active right now on EQ, and that is --

14 partially addresses Steve's comments that the rule under 10 15 CFR 5421(c) gives them three options on how to address a 16 time limited aging analysis.

17 One is to have an evaluation that's already good 18 for 60 years.

Another one is to go in there and reevaluate.

19 And the third one is is to develop an aging management 20 program.

21 And the licensee has all three options to choose 22 from for any TLAA.

And we're trying to figure out how this 23 applies in the EQ area, specifically as an example to apply 24 to the rest of the time limited aging analyses as they may 25 come in.

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1 With respect to passive and active determination, 2

ongoing items probably is going to be open for many, many 3

years.

The reason is is as we go through the scoping 4

process at the different plants, there are going to be new 5

. questions that come up -- come about as with respect to 6

which components are passive and active.

7 One example of this was on September 19, 1997.

8 The staff issued a position stating the active and passive 9

state of six different electrical components, okay.

Based 10 on this letter which went out to the industry, the industry 11 came back with concerns on one of the determinations, that 12 is the active or passive nature of fuses.

The staff said 13 that the continuity function of a fuse is passive.

The 14 industry took exception to that.

They didn't recognize the 15 continuity as a function for fuses.

And right now, we're in 16

-- we're evaluating their comments and preparing a response 17 to that.

18 It's just an example of how the system works.

19 When the staff identifies a position, they document it.

20 They send it out to the industry.

The industry reviews it i

21 and provides comments back to us, and it pucs us right back l

22 into the top of that flow chart, which, of course, is to 23 reevaluate it.

I 24 CHAIRMAN FONTANA:

Yes.

Well, along those lines, 25 I don't know if my memory serves me right here, but at one ANN RILEY & ASSOCIATES, LTD.

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. time, I thought I read somewhere that instrumentation was 2

basically active.

Instrumentation was not involved.

3 MR. PRATO:

That's correct, sir.

4 CHAIRMAN FONTANA:

In thumbing through the BG&E 5

report, I see that -- I think that involves some 6

instrumentation on the course brace -- on the containment 7

brace system, or something like that.

I think.

8 Now, are they --

9 MR. PRATO:

Okay.

10 CHAIRMAN FONTANA:

-- are marching to a little 7.1 different set of rules here.

12 MR. PRATO:

We have to take a step back from that.

13 The electronics, in general, are active, and I think what 14 the rule says is, " transmitters," which referred to the 15 electronic portion of instrumentation.

16 Copper tubing, whether or not you're talking about 17 a flow orifice or a venturi, all those components, okay, can 18 fall within the scope of license renewal --

19 CHAIRMAN FONTANA:

Okay.

if they're determined to be passive 20 MR. PRATO:

21 and long-lived.

22 CHAIRMAN FONTANA:

Okay.

23 MR. PRATO:

It's like the rule --

24 CHAIRMAN FONTANA:

I understand.

25 MR. PRATO:

-- what you're referring to in the ANN RILEY & ASSOCIATES, LTD.

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rulo is tha tran:mitters and the transmitters as, I believe, 2

it was defined and discussed in the SOC.

We're talking I

3 about the electronic portions, okay?

4 Circuit boards, transistors, those type of things, l

5 are considered active by the rule.

6 CHAIRMAN FONTANA:

Okay.

7 MR. PRATO:

Okay?

8 This brings us down to the famous question of 9

degradation induced by human activity.

10 On June 5, 1998, the staff issued a position 11 stating that the degradation induced by. human activity, 12 including abuse, accidents, or specific.-- and specific or 13 unexpected events, are not considered an aging management 14 an aging'effect, f

15 Let me also bring out something really quick.

16 This was in the response which we sent to NEI.

It says 17 that, "The staff believes that degradation induced by human 18 activity, including abuse, accidents, and specific or 19 unexpected events, is not an aging effect that needs to be 20 subject to an aging management review."

21 Then we go down a little bit further, and we see, 22 "Similarly, human activities might influence degradation or J

23 the rate of degradation by increased air and water-borne 1

24 contaminants.

For instance, acid rain.

25 "However, this influence would be considered l

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through the evaluation of a specific aging effect, such as

!j 2

chemical attack, and therefore, do not need to be addressed 3

as a separate aging effect."

4 So, in other words, we didn't say that conditions 5

initiated by human activities are completely out of the 6-scope of the rule.

We're saying that they're not specific 7

aging effects, and that if they do effect a specific aging 8

effect, they need to be considered under your evaluation for 9

that aging effect.

10' And another example we give in here is terminals 11

-- electrical terminals.

If manipulation of electrical

'12 terminals under Appendix B, they're covered automatically, 13 and therefore, we didn't -- we really didn't need to address 14 them specifically for license renewal.

f-15 Those type of activities that result in specific 16 degradation, they should be picked up under the current 17.

licensing basis programs, which is Appendix B.

18-Finally, fatigue.

19 CHAIRMAN FONTANA:

They aren't -- an example came 20 to mind, though.

A few years back where a coal plant a 21 short distance upstream from some external equipment, which 22 was stainless steel, over a period of about 30 years, really 23

-corroded.

The thing almost came apart.

l 24 That was a totally different thing.

It was a

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downstream.

2 MR. PRATO:

Again, I think this falls under the 3

difference between aging -- aging effect and degradation 4

mechanism.

5 If the aging effect is reduced -- reduction of 6

wall thickness, loss of materials, okay, if there is 7

something that's affecting that, okay, like emissions from a 8

coal. plant, okay, they have to address that aging effect and 9

the cause of that aging effect, and how they manage it would 10 bring in the emissions from the coal plant.

11' CHAIRMAN FONTANA:

Pretty straightforward.

12 MR. PRATO:

Yes, sir.

13 CHAIRMAN FONTANA:

Yeah.

14 MR. PRATO:

Okay.

Finally, fatigue.

The industry 15 has been in a number of times to talk to us about fatigue.

16 Their basic opinion is that fatigue from the industry's 17 level is resolved.

'18 The staff is considering their resolution.

We're 19 evaluating it right now.

However, we do not want to impede 20' the Oconee and Calvert Cliffs applications.

21 So what -- what we're trying to do right now, 22 we're trying to address fatigue for Oconee and specifically 23 for BG&E right now, and Oconee in the very near future.

24 As a result of the way we address fatigue for 25 those specific applications, we may find the final ANN RILEY & ASSOCIATES, LTD.

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resolution for the generic concerns relating to fatigue.

2 The staff has met on these issues, discussed them, j

1 3

and they're taking actions to try and resolve them l

4 specifically for Calvert Cliffs and to keep in mind, the 5

generic concerns, at the same time, and see if we can't 6

resolve both of them at the same time.

7 MR. GRIMES:

Let me add to that.

The fatigue 8

action plan offered us a rather unique opportunity to 9

experience a horse race.

The schedule that the research 10 folks are currently working on hopes to come to a resolution 11 on generic safety issue number 190, which is fatigue for 12 license renewal, which is unique in itself.

It's the only 13 generic safety issue that applies specifically to this 14 program.

15 And at the same time, we're trying to develop an 16 understanding of what requirements are necessary and 17 sufficient to address fatigue for these first two 18 applications.

And I'm probably a pretty good gambling man, 19 but I'm not going to gamble on having the critical path for 20 this review depend on the generic safety issue being 21 resolved.

22 So we're running this in parallel paths.

We're 23 going to continue t3 probe into the how is fatigue managed 24 on Calvert Cliffs and Oconee to see whether or not we can 25 define some standard of requirements to put in the SRP.

L 1

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And at the same time, we're going to let the 2

research folks see what they can do to understand how fast 3

new data is going to come out, and how it's going to be 4

addressed to come up with a generic resolution.

5 Their timing is to complete their evaluation in 6

March of

'99, and when we get to the schedule for BG&E, 7

you'll notice that that's also about the time that we're 8

going to try and complete an SER.

And that's why I say this 9

is an interesting horse race, because the two of these 10 things are going to occur, you know, almost on top of each 11 other.

12 CHAIRMAN FONTANA:

I was wondering, could you put 13 the EPRI issues slide back -- I don't guess we really need 14 the slide, but it's --

15 Now is each one of these basically generic?

16 Do these have to be resolved specifically for the 17 application that you have in hand?

18 DR. UHRIG:

Are there more questions?

19 MR. PRATO:

Actually, these are issues that either 20 constitute questions or industry positions on certain 21 technical matters.

22 On the first set were questions that evolved from 23 the implementation requirements that came out of the NEI 24 guide and the reg guide and the initial formulation of the 25 standard review plan.

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This-is a set of stLff from APRI that represents 2

both industry positions on the resolution of generic issues 3

-- let me pause here and say this is all generic.

4 CHAIRMAN FONTANA:

Yeah.

5 MR. PRATO:

Okay.

But the -- and the question is 6

to what extent do these things either answer requirements 7

for license renewal for all plants or constitute better ways 8

to address issues technically that might have an effect, not 9

only for license renewal, but also current operating reactor 10 requirements in the future.

11 And part of our prioritization process will be to 12 go through and say, "Well, to what extent do we have to 13 address these issues now and in the context of a license 14 renewal decision?"

(

15 So that aspect of fatigue is we have an industry 16 position that says, "It's resolved.

Just keep doing what 17 you're doing."

18 And we have to decide whether or not that's 19 sufficient and it constitutes the basis to resolve the GSI 20 and establish it.

Nothing more need be done than current 21 Section 11 practices or whether or not there is a delta of l

22 requirement that goes along with managing fatigue for a 23 period of extended operation.

24 But then if you go down to -- I'm looking for one 25

-- stress relaxation number 5.

Stress relaxation of l

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101 1

pressurized water reactor and terminal components.

(

2 But since I'm not quite sure yet how the staff is l

3 going to address baffle barrel bolts for pressurized water l

4 reactors and its current operating reactor kind of issue, I 5

don't know to what extent I need to resolve that right now.

6 That would depend, in part, on whac the staff concludes is 7

necessary and sufficient to manage aging effects for reactor 8

internals.

9 And in some of those things, it may be that they 10 go into GSI space because they don't have a clear 11 resolution.

They don't have a clear technical requirement 12 that can be imposed as an aging management condition.

13 CHAIRMAN FONTANA:

Do you have a process by which 14 every one of these will come to some conclusion or other?

15 MR. PRATO:

Yes, sir.

Yes.

16-CHAIRMAN FONTANA:

That's either been to GSI --

17 MR. PRATO:

Yes.

18 CHAIRMAN FONTANA:

-- or about or what are they?

19 MR. PRATO:

In scme of these cases, we may -- in 20' some cases, if it's clear that there's not going to be a 21 generic resolution, we may still have to make a decision on 22 the. plant specific application.

23 And fatigue is an example of that.

If it turns i

24 out that the generic resolution isn't -- you know, it 25 doesn't -- isn't coming to fruition, we still have to decide l

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l 1

what we consider to be an appropriate aging management for 2

fatigue for Calvert Cliffs and Oconee.

And they may resolve 3

it their own way.

That's still an option, too.

4 And I -- this is probably an appropriate point to 5

say that we're going to continue to work towards generic l

6 resolutions of these issues, but given that the applications 7

have already been received from Duke -- from BG&E and Duke 8

on Calvert Cliffs and Oconee, they'll be offered an 9

opportunity to do something different because they have 10 already made their application and they can either adopt 11 generic resolutions or they can negotiate for plant specific 12 solutions.

13 They dLaerve that for the sake of being where they 14 are.

And so it's -- it's not a foregoing conclusion that as 15 we come to generic solutions for these issues that we're 16 simply going to impose those on Calvert Cliffs and Oconee.

17 They'll be offered an opportunity to argue to do something 18 different because they've always submitted an application.

19 DR. SHACK:

Well, presumably, their application 20 didn't refer to any generic solution, so they've addressed 21 it for their plants.

22 MR. GRIMES:

That's correct.

23 DR. SHACK:

You have to review it and decide 24 whether it's acceptable.

I 25 MR. GRIMES:

That's correct.

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MR. PRATO:

Fatigue has been a longstanding issue, j

2 and most plants have programs in place to address fatigue, j

3 So generic resolution may not be necessary for all plants to 4

satisfy the requirements of license renewal.

5 DR. SHACK:

It would just make life simple?

6 MR. PRATO:

It would help the licensees in their 7.

application -- in developing their application more so than 8

it would help in the evaluation, because regardless of what 9

the generic resolution is, we still have to evaluate that it i

10 meets the requirements of the rule.

11 Okay.

Are there any other questions?

12 We've --

13 CHAIRMAN FONTANA:

The reason I asked is that I 14 did look through them and a lot of times, the industry 15 position was just change some of the wording in a standard 16 review plan or something like'that.

17 MR. PRATO:

We have a number of process type of 18 items and we're working through them a lot quicker than some 19 of these generic issues.

20 We -- only one has been through the entire system, 21 and we believe that that one will remain resolved, which is 22 the human impact.

23 But there are three or four more in final 24 resolution.

There are a couple of more that are really 25 being processed through as quickly as possible.

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The EQ question is one of them.

Management wants l

2 a resolution to that.

It's significant.

3 We're trying to focus our resources on priorities.

1 4

CHAIRMAN FONTANA:

Okay.

l 5

MR. PRATO:

Okay.

{

6 CHAIRMAN FONTANA:

Yeah.

I 7

MR. PRATO:

By the way, just as an added side bar 8

to that comment is, we're working with NEI diligently on 9

setting those priorities, j

l 10 DR. MILLER:

So six months from now, that list 11 will be quite a bit shorter?

12 MR. PRATO:

I hope.

13 DR. UHRIG:

I was going to say, longer.

14 MR. PRATO:

Well, it's certainly going to be 15 longer because we're going to be adding about another 170 j

1 16 over the next couple of weeks.

But, hopefully, the list of l

17 resolved ones will be getting longer.

Correct.

18 DR. MILLER:

The 170 or --

19 MR. PRATO:

The 170 are the NEI comments on the 20 industry guidance documents.

21 MR. GRIMES:

On the standard review plan?

22 MR. PRATO:

I'm sorry.

On the standard review 23 plan.

24 DR. MILLER:

You list those issues --

25 MR. PRATO:

That's correct.

I'm sorry.

l i

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DR. MZLLER:

You list those issues, then?

2 MR. PRATO:

Right.

j 3

DR. MILLER:

You list those then as issues?

4 MR. PRATO:

They will because we're trying to 5

control not only the issues themselves, but the revision 6

process, as well.

7 It doesn't mean that the revision process is 8

solely tied to the feedback process, but we're trying to 9

control both aspects, both ends of that process.

10 Any other questions?

I 11 Okay.

Thank you very much for your time.

I 12 CHAIRMAN FONTANA:

Well, thank you.

13 DR. SEALE:

Mr. Chairman, are we going to hear 14 anything from anyone from the industry today?

I 15 CHAIRMAN FONTANA:

We have not I

16 DR. EL-ZEFTAWY:

I don't think so.

I mean they 17 know about the meeting but there's no volunteer.

We hadn't 18 heard ahead of time at least.

19 DR. SEALE:

Okay.

l 20 MR. GRIMES:

We had not intended -- we provided 21 for this meeting in order to come -- er.'.ain to you where we 22 are and what our plans are, but we did not ask the industry 1

23 to come speak but I am sure that when they want to, we can i

24 make those arrangements too, but at the conclusion of 25 today's meeting I want to make sure that we do talk about l

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what schedule and what content you would like for future 2

meetings.

l 3

DR. SEALE:

Well, I wasn't trying to imply that I 4

did not appreciate or had any reason to suspect anything you 5

said, but on the other hand we are always interested to hear 6

about these things in the evolutionary stage because among l

7 other things we think it is a very efficient time to get 8

industry input and for them to have the opportunity to get 9

your perspective as well, so just curious.

10 MR. GRIMES:

I had expected that when we get a 11 group of the generic issues that is a convenient size for an 12 ACRS presentation --

13 DR. SEALE:

Great.

14 MR. GRIMES:

-- that we would have the industry 15 come and speak to their positions --

16.

DR. SEALE:

Very good.

17 MR. GRIMES:

-,or any positions of controversy.

18 CHAIRMAN FONTANA:

I was going to say as we were 19 discussing the function of this meeting it was mostly 20 process, procedures and direction we're likely to go to.

i 21 MR. GRIMES:

And at this point in the presentation 22 I would like to explain to you where we stand with respect 23 to the license renewal activities, specifically I think that 24 Bob mentioned that we got the Calvert Cliffs application in 25

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The application was dated April the 8th and it was 2

received on April the 10th and from that we have developed a 3

review schedule that was negotiated at the highest levels of 4

the agency.

I said that somewhat facetiously.

We went 5

through a series of scheduling exercises trying to explain 6

to NRR management, to the Executive Council and to the

~

?

Commissioners exactly how fast we could do a review and 8

exactly why does it take so long, and you may have noticed 9

in some of the trade journals the controversy that was 10 created when Corbin McNeil said that there is no reason that 11 the NRC can't do this license renewal decision in six 12 months, and I can tell you that created a consternation for 13 me for several weeks, explaining exactly how long it takes 14 to process a licensing application.

15 But we have boiled it down to our most aggressive 16 schedule, which is 585 days, and I have used that figure 17 publicly too.

It represents the time from the receipt --

4 18 not the date of the letter but the actual when it comes 19 through the door of the application to the point where we 20 would complete a safety evaluation supplement that is 21 resolution of any open items in a safety evaluation and the 22 final environmental impact statement, and for Calvert Cliffs I

23 that date is November the 16th, 1999.

24 You will notice on the schedule, which I think was 25 referred to earlier, was published in a letter to BG&E dated l

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June the 17th.

Now the difficulty with that schedule is we 2

carved out just the piece associated with doing the re*iew 3

of the -- pursuant to Part 54 and Part 51, the technical and 4

environmental aspects -- and we did not include in that the 5

hearing process, and that is because the Commission has only 6

recently decided on how the hearing process should proceed 7

and the Commission will be issuing a policy statement, a 8

general policy statement related to the conduct of 9

adjudicatory proceedings 10 You have noticed that -- you should notice that 11 the General Counsel's Office has trained me very well in how 12 to explain these terms and they will be addressing the 13 schedule for the overall Commission decision in a 14 case-specific order.

15 DR. SEALE:

We'll still give you the benefit of 16 the doubt.

17 MR. GRIMES:

Thank you.

)

18

[ Laughter.]

I 19 MR. GRIMES:

So at this point in time all I can 20 tell you is we are continuing to work to this overall 21 schedule as it was published to BG&E and we will monitor 22 resources and accomplishments towards the major milestones 23 in the review for both Calvert Cliffs and Oconee.

12 4 Now that Oconee has been received I'll give you a 25 little preview and say that with a receipt date of July the l

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1 7th, 1998, we are expecting to complete the safety 2

evaluation supplement and the final environmental impact 3

statement in February, year 2000, which means that your ACRS 4

meeting would be in May of the year 2000.

It delays exactly 5

by the three month difference between the submittal dates of 6

the applications, but in the middle of those schedules are 7

major milestone dates for completing all of the questions.

8 We get one shot at asking questions and then we go right 9

into writing the safety evaluation.

10 Then there is a safety evaluation and whether you 11 call it a draft safety evaluation or a safety evaluation 12 with open items, the next major milestone is to collect 13 together all that we know and all that we don't know in much 14 the same way as we used to do operating license reviews.

15 We issue a safety evaluation and whatever is 16 missing or unresolved gets identified as an open item.

Then 17 we can track the resolution of open items to the completion 18 of the safety evaluation supplement.

19 A similar process occurs for the environmental 20 review.

We issue -- we held a public scoping meeting last 21 week on the Calvert Cliffs application and you noticed what 22 kind of media coverage that we got.

Mr. Riccio from 23 Critical Mass was quite adept at saying that the process 24 that provides for Category I environmental issues and 25 Category II basically takes all the Category I issues off ANN RILEY & ASSOCIATES, LTD.

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the table and so we don't get to address the things that we 2

want to address.

3 What the media coverage did not focus on is the 4

fact that we went through a very public process to get to l

5 that point when Part 51 was revised in 1996 to categorize 6

the environmental impacts into those that are generic and 7

chose that are appropriate to be addressed on a 8

plant-specific basis, so I am sure that we will hear some 9

more about that and that there will continue to be public 10 concern about the extent to which they can debate their 11 particular areas of interest.

12 We are also proceeding with rulemaking to change 13 Part 51 again to make transportation of high level waste a 14 Category I issue and now that we have these pending license 15 renewal applications, I expect there may be a little more 16 public attention the next time we revise Part 51 than there 17 was in 1995 when we went through the first exercise to 18 categorize the environmental impacts for license renewal.

19 But getting back to the question you asked earlier 20 about the schedule, the milestones that we are going to 21 monitor are, first, completion of the Request for Additional 22 Information, or RAIs, which for BG&E is September the 7th, 23 1998.

From there we will complete environmental RAIs on 24 October the 7th, about a month behind.

We will complete 25 the -- I'm sorry, the applicant will complete the response I

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to the technical RAIs by November the 21st and they said i

2 that they expect that 60 days is sufficient or about 60 days 3

is sufficient for them to complete their responses and their 4

response to the environmental RAIs will be completed by 5

December the 6th.

6 The draft environmental impact statement would be 7

issued in March of 1999.

The Staff's safety evaluation with 8

open items would be issued on March 21st, 1999.

The public 9

meeting on the draft environmental impact statement is April 10 the 5th, 1999.

The resolution of the draft environmental 11 impact statement comments is May 20th, 1999.

Applicant's 12 response to the open items in the safety evaluation is July 13 19th, 1999, and as I mentioned before, the safety evaluation 14 supplement final environmental impact statement would be 15 completed by November, 1999.

16 That is about as fast as we think we can do it and 17 we would apply the same template to the review process for 18 Oconee and we'll be publishing that schedule, but at the 19 same time now we have to see how the milestones for the

)

20 adjudicatory proceeding will fit into this and I have just l

21 this morning started to fit in what the General Counsel has 22 identified as all those points where the Staff and the 23 applicant have to respond to interrogatories and do other I

24 things, and it looks like the Commission decision is going l

l 25 to be about September-October, year 2000.

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We are continuing to be pressed to see whether or 2

not we can compress that part of the schedule to get it down 3

closer to two years than three years and so we will be -- we 4

will share with you the adjudicatory milestones as soon as

)

i 5

the Commission completes its scheduling for that proceeding.

6 DR. UHRIG:

Do you expect that the hearing process I

7 will be similar to those held for an operating license or 1

8 what is the nature, the guidance you have so far?

Did the 9

Commission indicate the nature of what the adjudicatory J

10 process would be?

11 MR. GRIMES:

It would probably be easier for you 12 to see that in the Commission's policy statement where they 13 talk about the fairness of this process to the interested 14 parties, but I can tell you that the Commission is focusing 15 very heavily on the narrow focus -- that is, the specific 16 focus of this proceeding is making a decision pursuant to 17 Part 54, which is aging management for passive long-lived 18 components and time-limited aging analysis.

That is a very 19 specific box, and Part 51 gets to environmental impacts that 20 are only associated with extending the license period, and 21 my suspicion is that unlike the proceedings for the 22 operating license, which were much broader and pretty well 23 covered the whole of the plant design and operation, that we 24 are going to see the adjudicatory proceeding now spending a 25 lot more time talking about whether or not the contention is l

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within bounds.

2 DR. UHRIG:

There will be a licensing board 3

appointed?

4 MR. GRIMES:

If a hearing is requested.

5 DR. UHRIG:

If a hearing is requested?

6 MR. GRIMES:

Yes and the clock is now running for 7

BG&E.

8 The notice for hearing -- hearing opportunity 9

notice, whatever -- I can never remember exactly how they 10 set that up, but the hearing notice was published on July 11 the 8th and it expires or it ends on August the 7th, so by 12 August the 7th we will see whether anyone is interested in 13 litigating particular contentions on the Calvert Cliffs 14 application.

15 DR. MILLER:

Has anybody applied yet?

16 MR. GRIMES:

Not that I know of.

17 DR. UHRIG:

They always come in the last day.

18 DR. SEALE:

Oh -- how robust is that short a 19 window?

Namely --

20 DR. UHRIG:

30 days.

21 DR. SEALE:

You said 30 days.

I can imagine 22 someone might come in and say that doesn't give the 23 potential Intervenor the window that they would need in 24 order to make a reasonable evaluation of whether or not they 25 want to intervene.

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How successful have those kinds of contentions 2

been?

Do you have any feel for that?

g 3

MR. GRIMES:

Oh - 'my experience is limited to 4

only a few cases.

5 DR. SEALE:

Yes.

6 MR. GRIMES:

Fortunately they were relatively high 7

profile -- Diablo Canyon, Comanche Peak -- and I can tell 8

you that there is more to it than just that initial hearing 9

opportunity to request, and so my suspicion is that that 10 window will probably be fairly successful in terms of j

11 identifying whoever the interested parties then who want to 12 intervene, but then they will argue for some time on whether 13

'or not the contention, the issues, the particular issues of l

14 interest are within bounds or not and that is the scariest 15 part about the litigation is how much time is it going to 16 take before they focus on what the questions are that are 17 appropriate and how they are going to be addressed and that 18 is why there's been so much attention to the hearing process 19 improvements but there is a provision to notice the hearing 20 now but then go back at the completion of the staff 21 evaluation on the final environmental impact statement and 22 address the issue of late-filed contentions -- that is, new 23 issues -- and then the schedule also takes advantage of the 24 fact that we don't have to do this thing with couriers 25 anymore.

They will take advantage of electronic exchange l

{

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115 1

and other things in order to try and shorten the timeframe.

2 The General Counsel's office has spent a 3

tremendous amount of time looking at the back end of the 4

schedule and the Commission's policy statement will 5

encourage everything to make sure that there is amply 6

opportunities but at the same time expedited service.

7 DR. UHRIG:

Well, literally all a person has to do 8

is to say before the deadline that they want to intervene or 9

want to adjudicate this --

10 MR. GRIMES:

That's correct.

,11 DR. UHRIG:

You can give the flimsiest of reasons 12 to start with and then it gets expanded.

13 MR. GRIMES:

That's correct and then the 14 opportunity to clarify the contentions into particular 15

' issues in the prehearing conference and the whole rest of 16 that schedule now is just being made clear to me since we 17 now have noticed the hearing opportunity and how that fits 18 into our 585 day review schedule will be the next challenge, 19 plus Bob mentioned before that we are meeting next week with 20 NEI and the industry to talk about the priority of the 21 generic issues and so what you will see is we have got the 22 Calvert Cliffs review schedule and we will put the hearing 23 piece on that, and now we have just got the Oconee 24 application.

We will put that review schedule and its 25 hearing piece -- and its hearing opportunity will be noticed l

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1 a little bit sooner within the usual -- I think it is within 2

60 days -- and then on top of that we will have a schedule s

3 for addressing specific generic issues and so the milestone 4

tracking now has become an extremely large challenge at the 5

same time that the Commission has asked us to update our 6

operating plan to put in measurable goals and GPRA --

7 Government Performance and Resultti Act -- measures into the 8

process improvements, so we are getting re-engineered like 9

crazy, on the fly, as we try and proceed with these license 10 renewal applications.

11 Another feature that I want to point out l

12 specifically is Calvert Cliffs and Oconee probably won't

{

13-look much like the next applications.

Oconee may look 14 closer, but you'll find Calvert Cliffs is broken into 37 15 chapters organized more along how they carved the plant up, 16 systems, like commodities, and so forth.

17 Oconea packaged their license renewal application 18 more in terms of environments because the environment 19 relates back to the aging effects and so they found it 20 better to cut the matrix a different way and at the same 21 time our safety evaluation won't look like either one of 22 them because we are organizing our safety evaluation along 23 the lines of organization responsibilities and efficiencies.

24 I don't want three different branches responsible 25 for addressing the same aging management program, so I ask ANN RILEY & ASSOCIATES, LTD.

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117 1

for your indulgence.

You are going to have to take some 2

time to understand that the contents of the application and 3

the safety evaluations and the ultimate guidance that we put 4

into the standard review plan are all moving targets, but 5

they are going to be on stable ground.

6 Stability is going to be important from the 7

standpoint of planning and executing the schedules, so BG&E 8

has been told that they get -- there is a fairness 9

associated with their package is packaged the way it is and 10 we are not going to criticize them for packaging it that 11 way.

We'll respect the template that the Staff approved.

12 We'll respect the methodology that the Staff approved, but 13 we are going to use the standard review plan as best we can, 14 So you may have noticed that we haven't asked a 15 lot of questions so far.

We issued one set of RAI then we 16 spent four days in meetings talking about what BG&E had 17 supporting their application and why the Staff was asking 18 questions, and at the same time we recognized that we had 19 these generic issues that we had to maneuver around and so 20 that is why the interleaving of these things is now of 21 greatest importance to us, and you heard a lot about process 22 controls, the steering committee oversight, the executive 23 council oversight -- all of those things have put us in a 24 bright spotlight and now if I could just get the resources i

1 25 commensurate with that spotlight we would be home free, but t

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we are getting there.

t 2

We have gotten a lot more support over the last l

3 few months now that this has turned into a real live 4

program, and also I am pleased to report that despite the 5

threats of what is going to happen to our budget and the 6

debate that resulted from the Domenici proposal to the 7

Senate and subsequently Mr. McCabe -- no -- I'm sorry, I 8

can't remember now the Chairman of the House Appropriations 9

Committee, but despite those budget cuts we are seeing 10 substantially increased resources allocated for license j

11 renewal in the outer years now, so we have got management 12 support for the program.

)

i 13 Along those lines I would also like to mention 14 Hatch has come in and like Baltimore Gas & Electric they are

't 15 approaching us with a methodology in an attempt to try and 16 address some of these generic issues on a plant-specific 17 basis.

18 At this point we have looked over their proposed 19 methodology and we will begin a dialogue with them because 20 they are active in their interest -- interested -- but 21 suddenly other utilities have noticed that the Commission is 22 allocating resources on the basis of announced intent and so 23 when they said that we were cutting off the support for the 24 Westinghouse Owners Group topicals because we had no 25 announced intent, suddenly there's a rumbling in the bushes ANN RILEY & ASSOCIATES, LTD.

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1 and you can expect to see that there's going to be more 2

licensees coming in with letter of intent'in order to make 3

sure that they get their piece of the resources.

{

4 DR. SEALE:

The rhinoceros will charge out of the 5

brush.

6 MR. GRIMES:

That's correct.

7 DR. MILLER:

Question on BG&E, of course a 8

combustion plant, and if say another combustion plant came 9

in, would we still have the 585 days or would live generic 10 issues, generic to the CE plants, be resolved and the 11 schedule would be somewhat compressed or at least the 12 allocation of resources would be less.

13 MR. GRIMES:

Well, I would prefer to answer that 14 question in this way.

The 585 days was basically cut from

(

15 wholecloth that didn't take into account the contents of the 16 application.

It was simply how fast is as fast as we can 17 go, and with reasonable periods of time to breathe and 18 recognizing that there is more than just one of these -- we 19 probably could have done it faster than 585 days if we only 20 expected to do one application and then stop -- but we put 21 that schedule together recognizing that we were going to l

22

'have to interleave these milestones.

23 The next application will not likely come in until J

24 mid to late 1999.

By then we will have had enough 25-experience with the review schedules that it may be that 585 l-I ANN RILEY & ASSOCIATES, LTD.

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days ends up becoming a long, stretched out in time, because l,

2 of the numbers of applications that are anticipated or maybe 3

it will get shorter based on experience that shows that we 4

were able to manage more work in parallel activity so that l

5 you can compress some of the milestones.

6 Quite frankly, at this point I think it is just 7

too early to tell which will happen in terms of the 1

8 schedules.

Also we need to have at least a little bit of 9

experience fitting in these adjudicatory proceedings 10 schedules because that is what really tied us in knots on 11 the operating reactor reviews.

12 l

13 14 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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Was that we didn't account for the fact that the staff was 2

going to be distracted framing or responding to contentions, 3

preparing testimony, and doing some of those other things.

I 4

And that experience that I have tells me that I 5

need to make sure that that continues to be monitored in the 6

planning processes in terms of it's not as simple as just 7

assume that you can do legal activities in your spare time.

8 It needs to be fully integrated in the planning.

9 DR. MILLER:

Probably a better question I should 10 have-asked is, the time analysis of 585 days, did you also l

11 do a research analysis of --

12 MR. GRIMES:

Yes.

13 DR. MILLER:

-- people years or --

14 MR. GRIMES:

We have a matrix model that shows l

l-15 disciplines.

We attempt to try and keep it away from the l

16 organization and focus primarily on what kinds of talent do 1

l 17 we need.

18 But we've got a model that shows that, including 19 support for the hearing, that there's approximately 20 FTE 20 of effort over -- over this period, which is on the range of 21 30 to 35 months, and we expect to refine that model so that l

22 it can be used for future resource planning as we get 23 through the first few applications.

24 CHAIRMAN FONTANA:

But with regard to the public 25 hearings, some will -- some will be in parallel with the IJRJ RILEY & ASSOCIATES, LTD.

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schedule that we have here?

2 MR. GRIMES:

Yes.

3 CHAIRMAN FONTANA:

Interleave there.

4 Will any occur after the FES and SER's and will 5

they --

6 MR. GRIMES:

Yes, they --

7 CHAIRMAN FONTANA:

-- occur after what you've got 8

here --

9 MR. GRIMES:

The hearing is actually going to be 10 scheduled after the completion of the safety evaluation 11 supplement and the final environmental impact statement.

12 The schedule will take advantage of the technical 13 review time for the -- to identify standing of interveners 14 to scope the contentions, to focus on the issues and 15 controversy.

16 But then as soon as the staff completes its 17 finding, then there's another step that the interveners will 18 be offered an opportunity to see whether or not new 19 information has been revealed by the staff review that's 20 called, " late file contentions."

21 Then they focus what's going to be addressed in a 22 hearing, and then you schedule the hearing.

23 And so, hopefully, within the next few weeks, 24 you'll see the Commission's policy statement, and will also 25 have -- I don't know --

f 1

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Let's see.

Shortly after the hearing opportunity l

2 period closes, I expect to see a specific hearing schedule l

3 set forth.

But if nobody asks for a hearing, then we'll 4

just keep on marching to 500, maybe five days.

And we'll 5

see you in February.

6 DR. UHRIG:

Not likely.

7 DR. SHACK:

Is the BG&E application somewhat 8

anomalous because they've been at this for such a long time, 9

and did they have things that they started under the old 10 rule that somehow got recycled?

11 MR. GRIMES:

Yes, as a matter of fact, you'll find 12 the BG&E application was actually constructed to the 1991 13 rule and then repackaged, and you'll find a number of 14 references in the BG&E application aging mechanisms.

And 15 aging mechanisms was at the heart of the downfall of the 16 1991 rule, and we -- the 1995 rule focuses on aging effects.

17 There is no appreciable difference in the end, but 18 you will find that the packaging, the methodology and the 19 template, you know, all preceded the resolution of the 20 approach for the NEI 9510 implementation and --

21 DR. SHACK:

It just goes to the fact, again, it 22 won't be a particularly typical application.

23 MR. GRIMES:

It will be very atypical.

24 Like I said, Oconee will be closer to what we 25 think the -- you know, what we think the application content l

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1-will look like in the future.

But even there, as we learn 4

2 lessons and as we find better ways to' package the 3

information.

4 It's conceivable that after the industry sees our 5

safety evaluation report and the way that it has been 6

organized, because we're so sensitive to both being able to 7

identify responsible groups to support the safety 8

evaluation, and also because of the resource efficiencies, 9

-it's conceivable that they may want to reformat the 10 application to look more like the way we organize the safety 11 evaluation.

12 DR. UHRIG:

But doesn't the safety evaluation 13 basically follows the standard review plan?

14 MR. GRIMES:

No.

I 15 DR. UHRIG:

It does not?

16 MR. GRIMES:

The safety evaluation, right now, is 17 being organized more in terms of how the workload has been 18 distributed.

19 The standard review plan is organized more towards 20 the contents of'Part 54.

So -- and there are so many 21 different ways to package.

22 You know, you could have a whole section that just 23 does scoping, and then another one that does aging effects, 24 and then another one that it does aging management programs, l

25 which is sort of the way that Oconee has it.

And then you l

l l

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can go through, you know, and follow a particular system 2

structure or component across all of those things.

3 But we found that we addressed aging management 4

programs that apply to everything separate, and then 5

particular systems in terms of scoping age -- applicable 6

aging effects and aging management programs.

7 So it -- a lot of it has to do with just being 8

able to know who's responsible for what end state, and 9

that's workload management, primarily.

10 And speaking of workload management, I also want 11 to mention that we still have owner's group activities.

The 12 BWR owner's group, in addition to having an interest in 13 trying to pursue generic issues for boiling water reactors, 14 there is a lot of effort involved in a vessel internals i

15 program and what the staff refers to as the BWR VIP.

16 The vessel internals program for the BWR 17 stimulated -- stemmed from the core shroud cracking 18 incident, and now it's extending into managing aging effects 19 for vessel internals.

20 And the BWR owners have similar efforts, but i

21 that's the major renewal area for the BWR owners right now.

\\

22 And then we've completed two safety evaluations 23 for the B&W owners in support of the Oconee application that 24 we expected, and we have two more under review.

25 Now the two that have been completed, I would not i

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cay that those are typical of what we expect to do in the 2

future, either because of some of the lessons that we've 3

been learning on how to develop the model safety evaluation 4

for the application reviews.

5 But they are completed.

They have been 6

distributed to the ACRS, and they do represent the first 7

attempts of the staff to make findings under Part 54.

8 We have the other two B&W topical safety 9

evaluations nearing completion, and when those are l

10

. completed, we'll forward them to the ACRS, as well, and we 11 can talk about to what extent you want us to come over and 12 explain those topical report evaluations as representative 13 of generic work done by the staff.

14 And at the same time, as we mentioned before, we 15 expect that we will -- by that time, we'll also have shown

-16 you several resolution of generic issues, as well, which 17 will be documented in correspondence to NEI.

18 And so the nature of the way that we interact with 19 the Committee on generic matters is sort of, you know, 20 whatever you want.

21 The NEI task group that we mentioned before is --

22 I believe that they're meeting on like a monthly basis or 23 so.

I expect that that's about the frequency of interaction 24 that we'll have.

And we will, you know, start next week by 25 trying to establish priorities for the particular issues.

L Y

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The issue that's most important to the industry f

2 right now is credit for existing programs.

And as Mr. Prato 3

explained, that's our top priority, too, because the staff 4

wants credit for existing programs as much as the industry 5

wants credit for existing programs.

6 The difficulty is, what is the -- how do you take 7

that credit in the form of the contents of an application or 8

the contents of a safety evaluation?

9 They don't let us off the hook in safety l

10 evaluation content simply because we've got a maintenance 11 rule.

We don't let the utilities off the hook on content of 12 the application simply because they do comport -- conform 13 with 10 CFR 50.55(a), and therefore, have appropriate 14 in-service inspection activities.

15 But the way that those -- that that credit can be 16 articulated, either in the form of staff positions that say 17 it's sufficient for this aging management technique to 18 reference Section 11 of the Code, or it's sufficient for 19 this scoping activity to rely on this part of the 20 maintenance rule that categorizes certain stuff.

21 Those details need to be worked out in terms of 22 framing that credit for existing programs, and to very 23 discreet questions about which program, how much credit, 24 what does it ?.cok like?

25 And similarly, with some of the other issues like ANN RILEY & ASSOCIATES, LTD.

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operating experience.

Well, how much do you have to 2

explain?

3 Yes.

I know you've had operating experience, but 4

you're going to have to say a little bit more than, "I've 5

had operating experience."

And how germane is that either 6

to identifying the scope of aging effects, or taking credit 7

for aging management?

8 And the way that we want to address those issues 9

is to more clearly focus, "Well, what is the question you're 10 really asking?

What do you want to know?

What does the 11 application content look like?

What is the staff's 12 evaluation finding look like?"

13 And that will help us then to frame staff 14 positions that we can feed back into the standard review 15 plan.

16 And that 17 DR. UHRIG:

Well --

18 MR. GRIMES:

-- pretty well covers --

19 DR. UHRIG:

-- along that line, what does this 20 impending change on getting rid of the present evaluation 21 system for plants and going to the more general assessment 22 going to do to part of your program based -- the operating 23 experience part?

24 MR. GRIMES:

Are you referring to the alleged 25 dismantlement of the AEOD office?

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DR. UHRIG:

No.

I'm referring to going -- the

-2 SALP --

3 MR. GRIMES:

Oh, from SALP.

4 DR. UHRIG:

-- senior management.

5 MR. GRIMES:

-- senior management 6

DR. UHRIG:

Yes.

7 MR.' GRIMES:

-- process?

8 I don't -- I don't expect that the changes to that 9

system are going to have a dramatic effect on this program.

10 As I mentioned before, it comes -- it's more --

11 that's more oriented towards working very closely with the 12 regions to make sure that the competing effects on the 13 resources are clearly understood.

14 DR. UHRIG:

But it also gets rid of all the good

?

15 points that are pointed out, and it's almost a, "Yes, it's 16 satisfactory," and, "No.

It's not satisfactory," level of 17 decision here, as far as the plant.

18 Either you're satisfactory, and you continue 19 operating, or you're not, and you shut down.

That's what it 20 looks to me like it's getting to.

21 MR. GRIMES:

I'd hate to speculate --

22 DR. UHRIG:

That it have any effect at all?

23 MR. GRIMES:

Right.

Because, for one thing, I 24 know that there's -- that the Commission is in the midst now 25 of explaining to Congress exactly how we're going to improve I

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1 this process.

l 1

2 Reactor oversight will always be our

)

3 responsibility.

How we go about doing that and how we 4

manage the resources to do that, I'm sure will continue to 5

evolve over time.

6 But I don't -- and I don't foresee that the senior 7

management process is going to evolve to a point where we 8

just -- the resident says that the plant's either okay or 9

not.

10 There's going to be some inspection -- there's 11 going to be an inspection verification associated with a 12 license renewal --

13 DR. UHRIG:

I overstated the --

14 MR. GRIMES:

-- and --

1 15 DR. UHRIG:

-- situation.

16 MR. GRIMES:

Well, and I exaggerated your 17 overstn 4/>nt.

18 (Laughter.]

19 MR. GRIMES:

I don't -- but I don't think that 20 there are going to be changes that are so dramatic in the 21 senior management process that it's going to have -- that 22 it's going to have a profound effect on the region's 23 responsibility to make a -- to do their job of oversight and 24 provide us with a piece on a license renewal decision.

25 They will need to do some inspection verification.

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1 And at this poi"t, we're taking advantage of having to 2

understand how to do that with a minimal impact on resources 3

to help us focus what the technical review findings should 4

be that will make it easier for them.

l 5

So any other questions?

l 6

I have -- I briefly went back and enumerated the 7

milestones as we intend to monitor them for the application 8

reviews.

We've got complete RAI's, technical and 9

environmental, draft safety evaluation and environmental 10 impact statement, and then the final, which for BG&E, the 11 safety evaluation and the safety evaluation supplement, 12

November,

'99.

13 There's a lot of time between now and November of 14 1999.

And we would like to come back and tell you about how i

15 we've progressed at appropriate points.

16 I think as a minimum, we could make a presentation 17 to the ACRS after we've had a draft safety evaluation --

18 actually, we call that the safety evaluation report with 19

-open items, the traditional, you know, first issuance of the 20 safety evaluation, which is the way that we did it for the 21 operating license.

22 But between now and then, I expect that we 23 probably should come back and talk some more about the 24 generic issues so that you're not -- so that you see the 25 first staff product in context.

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And I think, suffice it to say at this point, just 2

explaining the schedule to you and the process, that we can 3

work out particular schedule details with -- with Med on 4

what works for you.

5 You probably should wait to see what the 5

adjudicatory schedule is, as well, so that you -- you know,

~

where the milestone might fit.

And also, we'll be 8

publishing the Oconee schedule.

9 So with those -- armed with that information, I'm 10 sure that we could pick a few dates, you know, tr art of 11 work this along.

12 We're not. going to wait until February the 14th, 13 year 2000 and come in and say, "Okay.

We're ready.

Give me 14 a letter."

15 DR. MILLER:

You know, I think it's good that we 16 l discuss the ACRS involvement because I done a little i

17 !

thinking about this and I think the Committee can play a l

18 multiple of roles that help facilitate this process.

19 One, of course, we are a public meeting, so it 20 does give us a public forum.

And, of course, anybody that's 21 ;

in the public can appear and make comments.

22 '

The second, I think, historically -- recent l

23 !

history I've been on, I think the Committee has been l

24 valuable in providing a sounding board for problem areas and l

helping to resolve -- if there is differences between the 25 I

l l

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industry's perspective and your perspective, I think we can

t-2 help'in that -- that arena.

l-

'3 And the third is, hopefully, we'll provide a 4

1 valuable technical input'and feedback to you.

L l

5 So I think with all those issues where we can

'6 play, I think it's a very important process that we can be a 7

valuable -- have a valuable input to this process.

And

8 maybe that will help decide when we should be involved and I

9 when we shouldn't, and so forth.

10 MR. GRIMES:

No.

I agree completely.

I've always 11 found that the ACRS meetings, the Subcommittee meetings and 12 the full Committee meetings both give us an opportunity to 13 stop and,.as you say, we can do a -- we can do a ground 14 check,. because just in the nature of trying to come -- to 5

15 organize our thoughts and come down and explain to you what 16 we're doing, we get a chance to get a fresh focus on what's 17-happening?

What are we doing and why are we doing it this 18 way?

19-Mut, also, as I mentioned, there are -- there is a 20

. lot of different perspectives on'this thing.

We can come 21:

talk-to.you about particular sets of generic issues.

- 22 As I mentioned before, the -- for some of these 23 issues, we can just tell you that there is sort of work in 24 progress because line. management wants, you know, first 25

' crack at what.the staff should -- position'should be, and 1

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also, I want line management held accountable for supporting 2

decisions on what action should be taken so that 3

So that the Steering Committee's advisory role 4

functions properly, but beyond that, at any point in time we 5

are always prepared to come tell you where we stand and 6

which issues are resolved and which aren't.

And at this 7

point I think it is -- what I would, the feedback that I 8

would like from the Committee is in terms of, we will give 9

you these schedules, we will identify the priority of 10 workload, and do you -- how do you want for us to bring the 11 information to you, and how can we package it?

12 We don't want -- I don't want to be down -- I 13 don't want you to be down here every week, because this week 14 I will come to you with this B&W topical SER.

Next week I 15 will be back with the fatigue position, week after that.

We 16 can create a monster, as a matter of fact, and we have 17 learned how to create a scheduling monster in terms of 18 breaking the work down into two fine a detail.

That's why 19 we are focusing now on these major program milestones rather l

l 20 than the detailed PERT charts.

And as far as I am 21 concerned, whatever is convenient for you.

I 22 CHAIRMAN FONTANA:

Okay.

1 I

23 MR. GRIMES:

That's why you will find there is no 24 last slide on future activities.

We are now prepared to go l

l 25 into a listening mode.

I l

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CHAIRMAN FONTANA:

Yes.

The timing that you 2

discussed seem to match what I had in mind from looking at 3

this.

So it looks like we are on the same page here.

4 Have you reached the end of the agenda?

5 MR. GRIMES:

Yes, I have.

6 CHAIRMAN FONTANA:

Okay.

7 MR. GRIMES:

We are now -- the last point on the 8

agenda is future activities and I am now --

9 DR. UHRIG:

And it's 4:15.

10 MR. GRIMES:

And it's 4:15.

11 CHAIRMAN FONTANA:

Well, great.

Maybe we can all 12 do them this way.

13 Do you have comments, George?

14 DR. APOSTOLAKIS:

No.

15 CHAIRMAN FONTANA:

No.

Do we have comments from 16 the Subcommittee?

17 DR. MILLER:

Well, one could ask -- be very 18 optimistic.

You are talking resource planning.

What would 19 happen -- this blue sky, we had -- everybody got excited i

1 20 about license renewal and within the next five years, 80 21 units came in with renewal applications with that.

22 MR. GRIMES:

Fifteen, actually, I think is --

23 DR. MILLER:

Well, let's just say 80.

24 MR. GRIMES:

Now, there's a window, you can't 1

25 submit more than 20 years prior to expiration.

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DR. MILLER:

Okay.

You probably have that.

2 MR. GRIMES:

Yeah, we crunch these numbers like 3

crazy.

You have to submit five years before and we have 4

struck the announced plants that are going to decommission.

5 And there's like 56 units that could be here by the end of 6

the year.

Practically speaking, it will take them 12 to-18 7

months to prepare an application, even if they had perfect 8

knowledge about the contents of the application.

9 So, but we are -- the Executive Council looked 10 long and hard at that budget assumption that said that we 11 will get two applications in '98, two applications in '99 12 and then it was, well, are we going to say for the year 13 2000? 'Because it could be two more if you are stable, or it 14 could go to 50.

And so at that point they said the year i

15 2000, and they looked at the -- you know, they looked at the 16 feedback they are getting from Congress and they said, two 17 in the year 2000, four in 2001.

So they show this spike 18 coming up in 2001.

19 I have a personal opinion that by next year they I

20 will change that budget assumption for the year 2000.

l 21 DR. MILLER:

It'll go up?

j 22 MR. GRIMES:

It'll go way up.

23 DR. UHRIG:

The applications are usually for all 24 the units?

25 MR. GRIMES:

Yes.

They normally make the ANN RILEY & ASSOCIATES, LTD.

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137

?

1 application in the same way that they applied for an 2

operating license.

So if they --

l 3

DR. UHRIG:

Well, it depends on the individual L

4 situation.

The St. Lucie had two separate.

)

5 MR. GRIMES:

Right.

1 i

6 DR. UHRIG:

For instance, I am thinking of Brown's i

7 Ferry.

I would never envision Brown's Ferry Unit 1 coming

)

8 in for a license renewal.

It would be 2 and 3.

9 MR. GRIMES:

But they may submit an application 10 for 2 and 3.

11 DR. UHRIG:

Yeah.

12 MR. GRIMES:

At the same time they submit their 13 decommissioning plan for Unit 1.

14 Now, we have spent a lot of time, you know, 15.

looking at the table.

As a matter of fact, that table of 16 license expirations is in the NRC Information Digest.

And 17 we frequently go back to that to show the groupings of 18 plants by years.

And it is not going to be just the 19 expiration date.

Because of things like, well, if they --

20 you know, they postponed a unit for construction completion,

]

21 they may very well come back and apply for, you know, a two 1

I 22 unit license renewal.

23 DR. UHRIG:

There is also the issue that keeps I

24 coming up about a plant that needs major expenditures, steam 25 generators.

You literally have to make a decision at that l-ANN RILEY & ASSOCIATES, LTD.

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138 l'

point whether to come in for license renewal or to shut it 2

'down early.

.3 MR. GRIMES:

Yes.

1 l

4 DR. UHRIG:

And it may be 30 years or 35, or

'I 5-something of this sort, not 40.

l 6

MR. GRIMES:

That's correct.

And that was one of 7

the public criticisms last. week.

You know, it did not go 8

unnoticed that BG&E announced that they were pursuing their 9

license renewal application at the same time that they 10 funded their new steam generators, which caused Mr. Riccio 11 from Critical Mass to say the only thing that is green about 12 this issue is the color of money.

License renewal doesn't 13 have a thing to do with it.

They are just looking for a way 14 to hoodwink their ratepayers.

15 Now,-that's not -- that is probably one good 16 reason why the NRC and the PUCs do not integrate.

Because I 17 don't think that -- you know, we have got a tough enough job 18 trying to figure out what it is going to take to make a 19 license. renewal decision without getting into what all those 20 economic environment influences are.

21 DR. UHRIG:

But that's management's decision.

22 MR. GRIMES:

That's correct.

I 23 DR. UHRIG:

It's a utility management decision.

l l

24 MR. GRIMES:

Right.

And in the face of 25 deregulation, the utility managers have clearly said that 1

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l 139 l

1 license renewal is a factor and how to make that decision,

(-

2 and how to project what it means to them economically, in 3

the face of deregulation, is more complicated than resolving 4

fatigue, I can tell you.

I 5

DR. UHRIG:

Well, I think when a utility has to l

I 6

pay $4 for a kilowatt hour of electricity --

1 I

7 DR. MILLER:

Seven.

)

l 8

DR. UHRIG:

Is it $7?

J 9

DR. MILLER:

Seven.

I 10 DR. UHRIG:

I have heard various numbers.

But, j

l 11 anyhow, whatever it is, it has got a dollar sign on it.

12 That's a shocker.

And it has a tremendous impact on the 13 bottom line.

14 MR. GRIMES:

Yes.

But, we -- you know, we get 15 into that only insofar as the Commission has established a 16 policy on their regulation effects, and trying to guess what 17 plants might come in when.

I 18 But I can tell you that utilities -- part of the l

l 19 reluctance about making an announcement about license l

20 renewal is because of the impact it has on Wall Street.

And 21 they are -- you know, the utilities are spending money on 22 license renewal work.

We know that they are doing it.

But 23 they haven't announced, made a formal announcement of when 24 they expect to make a submittal.

25 DR. UHRIG:

That's just there's usually an 4

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evaluation of what they are doing.

2 MR. GRIMES:

Yeah.

3 DR. UHRIG:

Scoping it out, what is it going to 4

cost us to go ahead with license renewal, and what are we i

l-5 going to have to do after we have got this, in terms of 6

major components?

7 MR. GRIMES:

I expect Southern Company found that 8

when the scoping study reached $6 million for Hatch, that 9

they thought they might as well just confess they were going 10 for it.

11 But that part of the budgeting process about how 12 many applications are going to occur and when, we don't see 13 that as a problem that is going to affect our fiscal '99 l

14 situation, because we expect that we are going to be working 15 these two applications until probably next summer, the 16 summer of

'99, before we see the next applicant.

But by 17 then we may have lots of announced intents and folks coming 18 in wanting to pursue issues on a plant-specific basis.

And 19 I can tell you that I'll be trying to deflect them to the 20 industry task force and say, to the extent that we can 21 resolve these issues generically, we want to do that, so 22 that we can conserve our resources to make sure that we 23 fulfill the application milestones.

Because that is our l

l 24 primary -- the primary success measure is going to be 25 meeting those milestones.

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141 1

And then our secondary measure, success measure, l

2 that you might as well start thinking about now, is with a l

3 quality safety evaluation finding, if you have any 4

suggestions on how we measure the quality of the safety 5

evaluation finding, I would be pleased to put those in our 6

operating plan.

7 DR. SEALE:

We referred earlier to the -- I think 8

I called it the rhinoceros that was charging out of the 9

bush.

Certainly, the Westinghouse Owners Group has had some 10 discussions about license renewal and I would -- and they 11 have been talking to you, that is my recollection.

12 MR. GRIMES:

That's correct.

l 13 DR. SEALE:

In this budget, with the budget 1

14 limitations you have and so forth, you are continuing your 15 discussions with Westinghouse on generic issue resolution 16 and so forth.

So it is not as if the Westinghouse PWR 17 status was on hold.

18 MR. GRIMES:

No, but it's about as close as you 19 can get.

20 DR. SEALE:

Okay.

So --

21 MR. GRIMES:

And the reason being because right 22 now about the only feedback that Westinghouse is getting is 23 through their representation on the industry task force.

24 All of their topical report reviews, the review schedules 25 are suspended until we are sure that we have all the l

l i

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142 1

resources we need to support Calvert Cliffs, Oconee, the B&W i

2 topicals, the BWR VIP, and then whatever time it takes us to 3

comment on Hatch methodology.

So that makes the 4

Westinghouse topicals No. 6 on the list of things to do.

5 DR. SEALE:

Sure.

Sure.

6 MR. GRIMES:

So if I have run out of everything 7

.else to de, and I skip lunch today and I have an extra 15 8

minutes, a Westinghouse topical will get worked on.

It 9

might be a mild exaggeration, but that's about the 10 situation.

11 DR. SEALE:

So you would have something, either a 12 conundrum or a piece of paper in hand real quickly to go to 13 the Commission and say I need some relief, if Westinghouse 14 suddenly made that a priority issue.

l 15 MR. GRIMES:

Actually, it works the other way 16 around.

It's not so much that we ask for relief, it's we 17 ask them what do you want us to kick off the plate --

18 DR. SEALE:

Okay.

Sure.

to, you know, to start providing 19 MR. GRIMES:

20 staff time to address these things.

21 DR. SEALE:

It gets nudged out.

22 MR. GRIMES:

Right.

23 DR. SEALE:

Okay.

24 CHAIRMAN FONTANA:

Any additional comments?

25 DR. POWERS:

It must be nice to be so popular.

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CHAIRMAN FONTANA:

Any comments from the floor?

2

[No response.]

3 CHAIRMAN FONTANA:

Well, thank you very much.

I 4

think this has gone very well.

And if you can go through 5

your schedule here as quickly as you went through the 6

meeting today, you shouldn't have any problem.

But my 7

experience is, in looking in projects in the past, is that 8

that often the best you can do is a factor of pi over two.

9 MR. GRIMES:

That's the best?

10 CHAIRMAN FONTANA:

You would be amazed how often

-11 that pops up.

12 MR. GRIMES:

As soon as we get the rest of the 13 milestones stuck into the computer, I'll make sure to put a 14 pi over two factor on each of the milestones, see how close il 15 this --

16 DR. UHRIG:

What's the basis for that pi over two?

17 CHAIRMAN FONTANA:

I'll explain it to you later.

18 There is a basis for it.

You lay out a program the best you i

19 know how.

'20 DR. POWERS:

We can let these guys 90.

21 CHAIRMAN FONTANA:

And then you'll find that more 22 often that not, it'll take about 50 percent more, and 23 there's a real good reason for that.

i 2 41

.But, anyway -- nell, thank you very much.

25 MR. GRIMES:

You're welcome.

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DR. UERIG:

.57, huh?

2 CHAIRMAN FONTANA:

Yes.

q 3

MR. GOT.MES:

As I mentioned before, you will 4

continue to see materiala from us, letters to NEI, the 5

questions that go out to the -- Steve, is the ACRS on the 6

RAI letter list distribution?

7 MR. HOFFMAN:

I would have to go back and look.

8 DR. EL-ZEFTAWY:

I don't think so, not on RAI.

9 DR. POWERS:

Not. typically do we get -- we do not 10 typically get RAIs.

Sometimes RAIs are pretty challenging 11 to interpret.

12 MR. GRIMES:

They can be, if they are taken out of 13 context.

Yeah, if you just look at one set of requests for 14 additional information, then you won't understand.

But to 15 the extent that we can share information in context that is

)

16 useful for you, and also continue to work with Med to 17 schedule periodic sessions like this to tell you where we 18 are and where we are going.

19 DR. POWERS:

On the subject of RAIs, I would 20 suggest that if you find something that you think would be 21 significant to share with the Committee, that you maybe 22 bounce it off Med.

23 MR. GRIMES:

Okay.

24 DR. POWERS:

And whatnot, and he might be able to 25 give you some idea of the contextual material that better ANN RILEY & ASSOCIATES, LTD.

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l 145 1

accompany it, - or otherwise, we look at it -- What in the-2 world is this!

4_

3 DR. SEALE:

Uhere did this thing come from?

4 MR. GRIMES:.Sure.

5 DR. UHRIG:

Furthermore, we don't need any more 6-paper at home.

7

-DR.

POWERS:

Well, the problem -- the problem they 8

will get into is either they are wasting the paper and their 9

. time, or they prompt a confusion, and we thi'nk you are doing 10 something that you didn't really think you were doing.

And 11 that usually results in spending a lot of time explaining 12 things two or three times.

13 MR. GRIMES:

I understand.

So we will be very 14 careful about sharing information with you, but at the same 15 time schedule something, 11 6 DR. POWERS:

It's just that the RAIs are in a 17 context of-documents that aren't right with them, and the 18 documents.-- you and who you are writing to are very 19 familiar with, and we won't'have that facile familiarity.

20 CHAIRMAN FONTANA:

Well, you'll be in day to day 21 contact with Med on the work that needs to be done.

22 MR. GRIMES:

Yes.

23 CHAIRMAN FONTANA:

Well, thank you very much.

And 24 I appreciate your time, effort and cooperation, and this is 25~

the end of the meeting..

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-___-______-_Q

146 I

1 MR. GRIMES:

Thank you.

l I,

2

[Whereupon, at 12:17 p.m.,

the meeting was 3

concluded.)

4

.5 6

7 8

)

9 l

10 11 12 13 14 I

15 16 17 18

.19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:

NAME OF PROCEEDING:

PLANT LICENSE RENEWAL DOCKET NUMBER:

PLACE OF PROCEEDING:

Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a ' rue and accurate record of the foregoing proceedings.

I h bN 4 td l

Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.

l l

l k

1 i

1 INTRODUCTORY STATEMENT BY THE CHAIRMAN OF THE PLANT LICENSE RENEWAL SUBCOMMITTEE 11545 ROCKVILLE PlKE, ROOM: T-2B3 ROCKVILLE, MARYLAND JULY 16,1998 The meeting will now come to order. This is a meeting of the ACRS Subcommittee on Plant License Renewal.

I am Mario Fontana, Chairman of the Subcommittee for Plant License Renewal.

l l

The ACRS Members in attendance are:

George Apostolakis, Don Miller, Robert Seale, William Shack, Dana Powers, and Robert Uhrig.

The purpose of this meeting is to discuss the NRC staffs activities associated with license renewal, proposed staffs plans and schedule for reviewing the license renewal application and related safety issues. The Subcommittee will also discuss the ACRS involvement in reviewing the license renewal submittal and related matters. The Subcommittee will gather information, analyze relevant issues and facts, and formulate proposed positions and actions as appropriate, for deliberation by the full Committee.

Medhat El-Zeftawy is the Cognizant ACRS Staff Engineer for this meeting.

l The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the Federal Register on June 29,1998.

A transcript of the meeting is being kept and will be made available as stated in the Federal l

Register Notice. It is requested that the speakers first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.

We have received no written comments or requests for time to mike oral statements from members of the public.

(Chairman's Comments-if any)

We will proceed with the meeting and I call upon Mr. Frank Miraalia of the Office of Nuclear Reactor Regulation to begin.

4

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NRC STAFF PRESENTATION l

TO THE ACRS LICENSE RENEWAL SUBCOMMITTEE I

JULY 16,1998 STATUS OF LICENSE RENEWAL L

1 l

1 i

ACRS LICENSE RENEWAL SUBCOMMITTEE BRIEFING STATUS OF LICENSE RENEWAL JULY 16.1998 1.

Introduction Dr. Fontana ll.

License Renewal Steering Committee Frank Miraglia Ill.

Implementation Guidance Development Bob Prato A.

Inspection Program B.

Office Letter IV.

Resolution of issues Bob Prato V.

Staff Renewal Activities Chris Grimes A.

Baltimore Gas & Electric - Calvert Cliffs B.

Duke Energy - Oconee C.

Southern Nuclear - Hatch D.

Owners Groups E.

NEl VI.

Future Activities Chris Grimes t

LICENSE RENEWAL STEERING COMMITTEE Membership Responsibilities Review:

(1)

Status of staff's review of applications and generic technical reports (2)

Status of the resolution of technical and process issues identified by the applicants, industry, public, and staff (3)

Effort expended relative to the planned i

accomplishments in NRR Operating Plan 1

Recommend actions to improve processes and resolve related issues Identify topics to be conveyed to Executive Council and Commission Meet with applicants and NEl

1 t

e, The Commission 9;

)

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Chairman U-Executive councli 6

6A.W 2A4 wad Executive Director for Operations Deputy Executive Director Regulatory Programs License Renewal Director Nuclear Reactor Regulation Steering committee Division of Reactor Associate Director.

inspection &

Program Technical Review Support Programs Management l

l Generic issues &

License Renewat Environmental Project Directorate Projects Branch IE_-----_--

i NRC INSPECTION PROGRAM FOR LICENSE RENEWAL (LRIP) l PROGRAM STRUCTURE 1

)

PROGRAM STATUS I

PROGRAM IMPLEMENTATION l

1 l

l LRIP STRUCTURE LICENSE RENEWAL APPLICATION INSPECTIONS i

PROGRAM DOCUMENTATION l

AGING MANAGEMENT PROGRAM IMPLEMENTATION l

AGING MANAGEMENT PROGRAM EFFECTIVENESS i

l l

RENEWED LICENSE INSPECTIONS LICENSE CONDITIONS LICENSEE COMMITMENTS l

AGING MANAGEMENT PROGRAM EFFECTIVENESS

LRIP STATUS LICENSE RENEWAL MANUAL CHAPTER LICENSE RENEWAL INSPECTION PROCEDURE AGING MANAGEMENT PROGRAM INSPECTION PROCEDURES FEEDBACK PROCESS l

i TRAINING PROGRAM l

l l

LRIP IMPLEMENTATION l

LICENSE RENEWAL APPLICATION !NSPECTIONS SCOPING SCREENING IDENTIFYING AGING EFFECTS i

AGING MANAGEMENT PROGRAM DOCUMENTATION AGING MANAGEMENT PROGRAM IMPLEMENTATION OTHER AGING EFFECTS TLAA/ EXEMPTION DOCUMENTATION REVIEW DEMONSTRATION RENEWED APPLICATION INSPECTIONS LICENSE CONDITIONS LICENSE COMMITMENTS CONTINUED EFFECTIVENESS OF AGING MANAGEMENT

{

j.

PROGRAMS j

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1

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i

l LRIP IMPLEMENTATION LICENSE RENEWAL APPLICATION INSPECTIONS LETTER TO ras MEETING WITH REGIONS TRAINING IMPLEMENTATION ACTIVITIES o

REVIEW o

SCOPE OF INSPECTION o

OVERLAY OF IMC 2515 o

DEVELOP INSPECTION PLANS FOR CALVER CLIFF

)

AND OCONEE j

o IMPLEMENTATION SCHEDULE

]

o FUTURE MEETINGS I

RENEWED LICENSE INSPECTIONS CORE PROGRAM REGIONAL INITIATIVES RESOURCES l

i

)

NRR OFFICE LETTER 805 OFFICE LETTER -

LICENSE RENEWAL APPLICATIONS REVIEW PROCESS GUIDE FOR REVIEWING LICENSE RENEWAL APPLICATIONS GUIDE FOR PROCESSING RENEWED LICENSE ACTION ITEMS I

GUIDE FOR TECHNICAL AND PROCESS LESSONS LEARNED FOR LICENSE RENEWAL 1

1

I Figure 1. LRA Review Process i

Industry / Applicant Applicant: Tender

,p m

m l

Activities Application j

1r

'Obtain TAC (s) i I'

IP <

Acceptance Review

Return to Applicant
,3 Accept Notification &

l iP Environmental Review Opportunity for l

Public Hearing 1

P 1r Develop Contractor W rk Planning Scope, j

Schedule, and Public Hearing j

S0W Resources j

i 1

1r l

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1 DSSA IPA /TLAA DE lPA/TLAA Review 1

DR Support ',

Review (SRP-LR)

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contractor SUDDort IP 1r RAls l

3r IP Response to RAls

l 3r IP SER Development

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3r Final SER f:

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issue Points IP 4 ACRS Review / Report

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IP Q

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License Renewal Action LILR Renewed License items ti tg

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Figure 1. License Renewal Action item Process LRA Review &

Verification 1r

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i LlLR 1

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ir w'

1r Originator Fills Out Ll-l Documented in SER LR Tracking Form l

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u PM Input LI LR into RLID FSAR Supplement Input License Condition PM Reviews Final Licensing Documents to Verify All LI LR are TS Requirement IP LR inspection

, input m

Report 1 r PM Forward Renewed f

Verified License for Final Approva!

l Ll LR Tracking Forms l

m Sent to File l

l 1

Copies of RLID Sent to Input into Operating m

PM and Regions Reactor Program 2

Figure 1 - LR Less@ns Learned Issue Documented &

IP Forwarded to issue

..J Coordinator (IC) 1r i

IC Enters issue in Tracking System &

Assign to issues Responsible individual (IRI) i r IRI Plans & Schedules PD/ Branch Assignment Resolve Priorities ir Management involvement Pro osed Branch Level t Options Evaluation Process:

Division Level to Determine Options /

Executive Team Level Resolution As Needed to Resolve issue Resolution

~

1r ir Commission Level issue Resolution issues Review & Approval 1

Approval 3r

,y IRI Coordinates Policy /Rulemaking Changes / Process Positions I

k I

l SRP LR Coordinator:

RG Coordinator:

IP LR Coordinator:

PDLR Rev.ise OL 805 l

Revise SRP LR as Revise DG 1047 & NEl Revise MC & IPs as as Necenary Necessary 9510 as Necessary Necessary l

l l

l Y

Revision (s) Verified by IRI t

IC Closes issue u

I 4

l l

i.

_______________-___A

\\

NRR OFFICE LETTER 805 STATUS OFFICE LETTER 805 - APPROVE JUNE 19,1998.

GUIDE FOR REVIEWING LICENSE RENEWAL APPLICATIONS IS IN PLACE AND BEING IMPLEMENTED GUIDE FOR PROCESSING RENEWED LICENSE ACTION ITEMS -

A DATABASE IS IN PLACE AND FORMS HAVE BEEN DEVELOPED GUIDE FOR TECHNICAL AND PROCESS LESSONS LEARNED FOR LICENSE RENEWAL IS VERY ACTIVE

1 License Renewal Issues 1.

Credit for Existing Programs 2.

Demonstration Detail 1

3.

Operating Experience 4.

Component Failure / intended Functions 5.

App!icable Aging Effects 6.

Generic Safety issues 7.

Risk-Informed License Renewal i

8.

Component Lists l

9.

FSAR Content l

10.

Time-Limited Aging Analysis Timing 11.

Passive / Active Determinations 12.

Consumables l

l 13.

Degradation Induced by Human Activity I

l t

EPRI Issues 1.

Fatigue of metal components 2.

Environmental qualification of low-voltage, in-containment cables -

l 3.

Thermal embrittlement of cast austenitic stainless steel components 4.

' Irradiation-assisted stress corrosion cracking of reactor internals 5.

Stress relaxation of pressurized water reactor internals components i

6.

Primary water stress corrosion cracking of high-nickel alioy components 7.

Stress corrosion cracking of PWR reactor coolant system components 8.

Degradation of Class i small bore piping 9.

Neutron irradiation embrittlement c' reactor vessel beltline materials l

10.

Ultrasonic inspection of pressure vessels and components l

11.

Visual examination of components and structures l

12.

One-time inspections of concrete and steel structures l

L 13.

Freeze-thaw damage in concrete containment structures 14.

Alkali-aggregate reactions in concrete containment structures 15.

Differential settlement in PWR containments and Class 1 structures 16.

Reinforcement corrosion in PWR containments 17.

Void swelling of reactor internals i

f STAFF RENEWAL ACTIVITIES l

BALTIMORE GAS AND ELECTRIC - CALVERT CLIFFS I

l DUKE ENERGY - OCONEE SOUTHERN NUCLEAR - HATCH OWNERS GROUPS NEl i

I I

i

)

i l

I f

!

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