Plant License Renewal - April 28, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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MEETING: PLANT LICENSE RENEWAL
U.S. Nuclear Regulatory Commission
11545 Rockville Pike
Room T-2B3
Rockville, Maryland
Wednesday, April 28, 1999
The subcommittee met, pursuant to notice, at 1:01 p.m.
MEMBERS PRESENT:
MARIO H. FONTANA, Chairman, ACRS
MARIO V. BONACA, Member, ACRS
THOMAS KRESS, Member, ACRS
DON W. MILLER, Member, ACRS
ROBERT L. SEALE, Member, ACRS
WILLIAM J. SHACK, Member, ACRS
ROBERT E. UHRIG, Member, ACRS. P R O C E E D I N G S
[1:01 p.m.]
DR. FONTANA: 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 on Plant
License Renewal.
The ACRS members in attendance are Mario Bonaca, Thomas
Kress, Don Miller, Robert Seale, William Shack, and Robert Uhrig.
The purpose of this meeting is for the subcommittee to
review the NRC Staff's Safety Evaluation Report concerning Calvert
Cliffs plant license renewal application 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.
Noel Dudley is the Cognizant ACRS Staff Engineer for this
meeting.
The rules for participation in today's meeting have been
announced as a part of the notice of this meeting previously published
in the Federal Register on April 5, 1999.
A transcript of the meeting is being kept, and will be made
available as stated in the Federal 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
make oral statements from members of the public.
We will proceed through the meeting and we will call upon
Mr. Christopher Grimes, Chief of the License Renewal and Standardization
Branch to begin. Chris?
MR. GRIMES: Thank you, Dr. Fontana. I have the same
difficulty with my title that you do. I stumble through it.
I appreciate the subcommittee taking time, especially at
this juncture in the review. As all of you know, this is the first
license renewal review being conducted by the NRC Staff under 10 CFR,
Part 54 for a license renewal application. In close cooperation with
the ACRS we decided to arrange for meetings to begin after the initial
issuance of the safety evaluation and we are going to describe the
Staff's review as it was conducted, using the draft Standard Review Plan
for license renewal, but I want to emphasize since the receipt of the
license renewal application for Calvert Cliffs in April of 1998 we have
learned quite a bit in terms of how to work out the implementation
details and we have arranged during the next day and a half to have BG&E
describe some of their programs and now they approached the license
renewal application, and then we have arranged for various
representatives from the NRC Staff to describe the contents of the
safety evaluation and the conduct of the review including the status of
open and confirmatory items that were identified as we developed this
initial safety evaluation.
At this point we are in the process of reviewing those open
items and confirmatory items with Baltimore Gas & Electric in order to
define appropriate success paths to complete a final safety evaluation,
which currently is scheduled for November of this year.
With that, I would like to introduce Dave Matthews, who is
the Director of the Division of Regulatory Improvement Programs and is
my direct supervisor.
MR. MATTHEWS: I don't really have anything substantive to
add other than if Chris didn't say I'll say it, that we appreciate the
ACRS subcommittee's willingness to begin early review of this
significant Staff effort and applicant effort in the hopes that we can
work through the Staff work products as they are produced. Our
expectation is that there be hopefully interim review results reported
out by the ACRS as we proceed through this process, so that hopefully we
will be able to meet our desired outcomes both in terms of completeness
and accuracy but also in terms of schedule, with schedule to be one of
the facets of quality in this project, as I hope you have appreciated by
observing the progress to date.
With that, I think the next introduction is to Mr. Solorio.
MR. GRIMES: Are there any general questions that you have
before we begin the Staff's presentation?
[No response.]
MR. GRIMES: If not, then I will introduce David Solorio,
who is the Project Manager for the license renewal application in the
License Renewal and Standardization Branch in NRR.
MR. SOLORIO: Good afternoon. My name is Dave Solorio. I
am the NRC Project Manager here for BG&E's license renewal application
for Calvert Cliffs.
Today and tomorrow the Staff will be presenting the results
of the review of Baltimore Gas & Electric's license renewal application
as documented in the Safety Evaluation Report. Today I plan on
providing you some general information on the Staff's review and then
Sam Lee, also from the License Renewal and Standardization Branch, will
talk about some of the more generic priority one license renewal issues
that were applicable to many sections of the Staff's safety evaluation
and also provide you a road map as to where other priority one license
renewal issues are dispositioned in the Safety Evaluation Report that is
going to be discussed largely tomorrow.
I would also like to add that if you are worried about the
size of the slides here, it is because I have today's and tomorrow's
presentations so Sam and I are essentially the first 12 slides.
Page 2 just provides a quick outline of some of the points I
would like to make today, so I am going to start off with Page 3, which
I put up here.
First, I want to provide you all a little orientation
regarding where we started and what were some of the important steps in
the Staff's review and where we are now in the review timeline.
On April 10th BG&E submitted their LRA, their license
renewal application, to the NRC. It is comprised of three volumes. The
focus of the Staff's safety review is on the material in the first two
volumes, and for that reason for the rest of my presentation I will
focus on the Staff's efforts associated with Volumes 1 and 2.
Starting in February of '98 and up through September of '98,
the Staff issued questions related to the BG&E license renewal
application, and up through December of last year BG&E provided their
responses. There was a lot of intense interaction between those
periods, trying to clarify and reach a common understanding on the areas
that we were not so clear.
Additionally, we held public meetings and site visits were
conducted to address difficult questions or issues that remained
following Staff questions and BG&E responses. These efforts were very
intensive and involved significant resource expenditures by both the
Staff and Baltimore Gas & Electric.
However, looking back, I believe these interactions were
very effective and they were a quick way to reach closure on certain
issues. Overall I considered they were pretty successful.
Additionally, I believe having Calvert Cliffs so close also
helped out the process a lot.
Finally, the Staff issued a safety evaluation with open
items and confirmatory items in March of this year. For your
information there's 28 open items and 20 confirmatory items. It is our
goal in the presentations tomorrow to kind of discuss in each SER
section what are the relevant open items, what are the confirmatory
items and the license renewal issues and when you have a chance, maybe
later tonight, and you are looking through the package you will see
that.
DR. UHRIG: How do you define a confirmatory item?
MR. SOLORIO: A confirmatory item is defined as something
that really is more of an administrative nature. BG&E has agreed to do
the actions Staff has requested and it's more a formality in terms of
BG&E's responding on the docket they have done it or that they plan to
do it.
Before I get into some of the more specifics of the Staff's
review and the SER, I wanted to provide some orientation regarding how
the license renewal rule provided some important principles that really
helped to narrow the focus of the Staff's review.
The first principle here in the first bullet and the point I
wanted to make was the part that really narrows the Staff's review
focuses on the part that starts out with "the possible exception of the
detrimental effects of aging."
This is what directs the Staff to focus its review on the
management of aging effects on passive long-lived components.
The second principle is pretty clear and it is also intended
to assure adequate safety during the period of extended operation by
maintenance of the current licensing basis and to clarify that a
confirmation or a reverification of the current licensing basis is not
necessary for license renewal.
For example, if the current licensing basis is that two
diesels are needed during the first 40 years, that should be good enough
for the renewal period.
DR. KRESS: Were these principles handed to you as policy by
the Commissioners?
MR. SOLORIO: They were handed to us in the statements of
consideration to the '95 rule and I believe they were also in the '91
rule -- statements of consideration, excuse me.
Our next slide summarizes the overall Staff goal in the
review of the license renewal application, which is to determine if a
conclusion can be made to satisfy Part 54.29 which requires the Staff to
determine several things -- first, that the applicant has proposed
adequate methods for managing aging to ensure functionality per
54.21(a)(1), and that the applicant has identified time-limited aging
analyses and either proved they are valid for the period of extended
operation, re-analyzed them to project them to the end of the period of
the extended operation, or provided an adequate program to manage the
effects of aging on the intended functions for the period of extended
operation.
The other requirements of 54.29 are that the applicant has
met the applicable requirements of sub-part (a) to Part 51, the National
Environmental Policy Act, and that matters under 2.758 have been
addressed. However, I want to reiterate that the specifics of the
Staff's presentation to you today and tomorrow focuses on the first two
items, the details of how the applicant meets sub-part (a) of Part 51
and how the matters related to Part 2.758 are addressed in other NRC
processes outside the safety evaluation review.
The specifics by which the Staff performed its review to
make the 54.29 determination are covered in Chapters 2, 3 and 4 of the
SER.
In Chapter 2 the Staff evaluated the implementation of
BG&E'S integrated plant assessment methodology to determine which
components, systems and structures should be within the scope of license
renewal.
The second part of this evaluation involved evaluating BG&E's
determination of which passive, long-lived components, systems and
structures should be subject to aging management.
DR. KRESS: I would like to return to your two principles
again for just a second.
If we were to conceive of a concept that licensees would
come in for license renewal again and again and again and again, would
you consider this principle to still be a valid, the first one, to still
be a valid principle under those circumstances?
MR. SOLORIO: The Atomic Energy Act I guess provides for
that scenario you just went through but I think we would probably have
to re-evaluate it the second time around and see if we could re-conclude
that, but I think Chris Grimes has some comments.
MR. GRIMES: I would say that this process would work in
terms of continuing to go beyond, based on the premise that if there is
a need to address some safety weakness that we would do that in the
context of making backfitting decisions for the current licensing basis,
and the extension period focuses specifically on whether or not there
are adequate aging management effects and so as a principle we believe
that if a utility were to come back, you know, 20 years hence and say I
want to apply for another extension that this principle would continue
to be valid.
Mr. Doroshuk wants to make a comment.
MR. DOROSHUK: Yes, sir. Mr. Kress, my name is Barth
Doroshuk. I am the Project Director of the Calvert Cliffs license
renewal project, and I believe the history of these two principles of
the renewal rule come from the regulatory analysis that was done on the
original rule where the NRC reviewed several options on how to implement
license renewal, ranging from do nothing to full SRP requirements, and
this, given all the considerations that were taken into account in that
regulatory analysis, was the preferred regulatory approach and
fundamental assumptions.
DR. KRESS: Thank you for that.
DR. UHRIG: Where did the 20 year term come from? Is that
inherent in the original licensing legislation or is this something that
came out of the study?
MR. SOLORIO: It was not, it is my understanding it was not
part of the initial licensing. It's my understanding it came out of the
Staff's work in the first rule of '91.
MR. GRIMES: I'm sorry, would you repeat the question,
please?
DR. UHRIG: Basically where did the term of 20 years become
the standard by which you were working here? Is this -- there was some
discussion early on, maybe seven or eight years ago about a 10-year
renewal, I remember.
MR. GRIMES: All I can say is it was a conscious Commission
decision that the period --
DR. UHRIG: It was a Commission decision?
MR. GRIMES: Yes. We have a volunteer to address this
question from NEI.
MR. WALTERS. Doug Walters, NEI.
When we initially looked a license renewal we made some
assumption about replacement facilities and we backed off of the 40
years and said, well, it is probably going to take you five years to
prepare the application, maybe five years for review, and the feedback
at the time was a licensee would need about 10 years to decide if the
renewed license was not issued what would I do as an alternative, so
that gives you the 20 years, and then that fit in nicely with the fact
that the Atomic Energy Act will only allow a license to be valid for 40
years, so that is why the 20 years -- you can't submit before the 20
years.
MR. SOLORIO: In Chapter 3 the Staff evaluated Baltimore Gas
& Electric's identification of aging effects and management of aging
effects to ensure equipment-attended functions in accordance with the
current licensing basis are maintained during the period of extended
operation.
Finally, in Chapter 4 the Staff evaluated Baltimore Gas &
Electric's methods to determine how analyses with time limited aging
assumptions will be extended or managed or evolve for the period of
extended operation.
My next slide provides some specifics of the Staff's review
process. Because of preliminary work done by BG&E and the Staff several
years ago, the Staff was able to narrow its review relating to scoping
and screening to the implementation of BG&E scoping and screening
methodology.
Because the Staff had already previously reviewed BG&E's
integrated plant assessment methodology submitted in '95 and concluded
the methodology was acceptable for meeting the requirements of
54.21(a)(2), which were to justify the methods used in 54.21(a)(1).
Specifically on April 4th, 1996, the Staff issued a final
safety evaluation on BG&E integrated plant assessment methodology. In
that SER the Staff also concluded that the methodology if implemented
provided reasonable assurance that all structures and components subject
to an AMR pursuant to 54.21(a)(1) would be identified.
As a result of this previous work, the Staff focused during
the review of BG&E license renewal application on the implementation of
its methodology and tomorrow Mr. Chris Gratton, from the Division of
Safety Systems and Analysis will make a presentation on how the Staff
tested and evaluated BG&E's implementation in its SER Chapter 2.
Also, it is my understanding that a copy of the draft safety
evaluation was provided to the ACRS member at that time. A letter was
issued on February 7th with no comments at that time.
I would also like to add that the license renewal inspection
program also provides another assessment tool that the Staff uses to
evaluate the implementation of BG&E's IPA methodology. The results from
very recent scoping and screening inspection conducted by Region 1 with
participation by the License Renewal and Standardization Branch staff,
were that BG&E implemented its methodology effectively.
My final slide here lists the resources and guidance
documents used by the Staff to conduct its review of the BG&E license
renewal application. You heard Mr. Grimes earlier mention that the
primary document used by the Staff is the draft Standard Review Plan for
license renewal, which incorporates Staff experience gained from the
review of NUMARC industry reports addressing the management of aging of
specific structures and components for license renewal.
The Staff also used the statements of consideration
accompanying the 1995 rule because it included many examples of
structures and components that require renewal review and how to do
specific aspects of the renewal review.
Also, draft Reg Guide 1047, which proposed to endorse NEI
95-10, industry guideline for implementing the requirements of Part 54,
was also used by the Staff.
Last year the Staff developed NRR Office Letter 805, license
renewal application review process, which was also used as a guidance
document.
A significant resource that really contributed to success
has been the NRC and BG&E management meetings that were held monthly to
talk about the status of the license renewal application and talk about
issues that might be having a potential to slow things up, and also
there are the management meetings between, periodically held between the
NEI working group for license renewal and the NRC License Renewal
Steering Committee to deal with the tougher issues.
Then there was also the license renewal issues, which some
of the Staff will be talking to you all about tomorrow in terms of which
SER sections they addressed. Sam Lee will talk a little bit after me
about some of the more generic license renewal issues that were
addressed in mini-sections by the Staff.
There is also the BG&E license renewal application template
that was developed by BG&E and the Staff cooperatively working to put
together a kind of a guide, a roadmap, for what a LRA should look like
and what it should contain.
In the License Renewal Inspection Program, which I mentioned
to you earlier, we have just completed two site inspections in that
program.
The final two documents I wanted to mention were NUREG-1557,
which was the summary of technical information agreements for NUMARC and
Resources Council, industry reports addressing license renewal as well
as NUREG 69.40, which is nuclear power plant generic aging lessons
learned.
That is really what my presentation was going to cover --
try to give you a flavor for some of the tools that Staff used, how they
went about it, what the status is.
DR. SHACK: Do you have any comments on some of these --
like the draft Standard Review Plan and the draft Reg Guide as far as is
it satisfactory guidance? Do you see changes that need to be made? Did
you get a lessons learned --
MR. SOLORIO: Well, under the NRR Office Letter 805, we have
a lessons learned program that did require us to take whatever lessons
we're learning BG&E and also the Oconee review and try to fill in where
the Standard Review Plan may not have an appropriate level of guidance
for the Staff right now.
I guess there are issues that have come up that we have had
to not necessarily have a Standard Review Plan telling us what to do in
that case, and we have had to work on that, and part of our process is
to factor that information back into the Standard Review Plan.
DR. SHACK: Has that process occurred, or you are in the
middle of that?
MR. SOLORIO: Oh, I would say that process is occurring. We
have some license renewal issues. We have some lessons learned that are
starting to be written up by some of the License Renewal and
Standardization Branch staff. If you are interested we could possibly
come over and talk with you about some of those issues.
MR. GRIMES: We will cover quite a few of those when we
address the generic renewal issues, because many of the generic renewal
issues constituted comments on the draft Standard Review Plan and issues
associated with the industry guide, NEI 95-10, and as we have gone
through -- as we originally planned, we expected to learn lessons during
these initial reviews and then feed them back into improvements in the
Standard Review Plan, and we will be discussing those in the context of
the generic renewal issues.
DR. UHRIG: What do you mean by template?
MR. SOLORIO: Elaborate?
DR. UHRIG: Yes -- a little more than --
MR. SOLORIO: Prior to -- was this in the '96-'97
timeframe -- Baltimore Gas & Electric and NRC decided that in order to
help get the first license renewal application in the door it was a good
idea to try to work on a way to provide a format for Baltimore Gas &
Electric to structure an application so that the Staff could complete
its review, so the Staff -- BG&E provided some sample, well, some
completed documents for real systems and the Staff had some intensive
90-day efforts to come up with a six-page template as to what BG&E was
going to provide for their license renewal application.
DR. UHRIG: Is this essentially the same template that is
used for Oconee or is each plant going to have its own template?
MR. SOLORIO: Well, this was done for BG&E. Oconee I don't
believe has a similar template for the safety side. They might have
one, I believe, for the environmental, something similar was done for
environmental.
DR. UHRIG: Is this to be a pattern for future license
renewal applications?
MR. SOLORIO: I don't believe so. I think the way we will
try to provide a pattern for future license renewal applications is
through our safety evaluations, through the Standard Review Plan and
through the draft Reg Guide 1047.
DR. UHRIG: Okay.
MR. SOLORIO: I think the idea was to get BG&E to be the
first --
DR. UHRIG: So it is unique to them?
MR. SOLORIO: Unique to them.
MR. GRIMES: I would like to add that Calvert Cliffs and
Oconee have very different applications.
Calvert Cliffs is organized more by system. Oconee is
organized more by program. We shared those outlines along with the
Staff's safety evaluation outline with NEI and we recently opened a
dialogue with NEI to see if we could work out a mutually acceptable
standard form and content for license renewal applications that would
provide appropriate flexibility for the utilities but also make it
easier for the Staff to review it but that is consistent with our
organization, so we expect to have a standard that is derived from the
experience with these first two applications.
DR. UHRIG: What you are really aiming at is sort of a
mini-Standard Review Plan?
MR. GRIMES: Yes -- I think it was NUREG 1270 standard form
and content for license applications -- something like that.
DR. SHACK: One of the features that interested me was this
age-related degradation inspection thing. Is that something that is in
these guidance documents or is that a unique thing for Calvert Cliffs?
MR. SOLORIO: I am at a loss here.
DR. SHACK: Well, it is this so-called ARDI, which is used
in the thing. I just wondered if that was their invention or did that
come out of -- well, I think it is BG&E's invention. Maybe I should let
BG&E speak to that. That is a unique feature.
MR. DOROSHUK: I can comment on that. My name is Barth
Doroshuk from Calvert Cliffs again.
In the industry efforts, through NEI, and through the
Electric Power Research Institute -- EPRI, and through the
plant-specific efforts it was realized that there are many common
components within systems across the plant and if you add them all up,
they turn into a large population and the approach that was taken in the
industry, and of course we developed our own plant-specific approach,
was how would we develop a sampling inspection program so that we could
go in and perform the necessary aging inspections on a representative
sample of these large volumes of components.
We happened to develop the program at Calvert Cliffs and we
developed the acronym ARDI, so it is a sampled inspection program that
is used on various types of component types in the plant. It could be
small bore piping. It could be component supports -- other types of
components that are in large quantities.
MR. GRIMES: I would also like to add that we expect other
renewal applicants to do that same thing. They may call it by a
different term. Maybe we can standardize the term at some point in the
future as well.
I will also take this opportunity to correct my reference.
It wasn't NUREG 1270 -- it is Reg Guide 1.70 that is the standard form
and content.
DR. FONTANA: Any additional questions?
[No response.]
DR. FONTANA: Are you ready to go to Sam Lee?
MR. LEE: My name is Sam Lee. I am from the License Renewal
and Standardization Branch and I am going to talk to you about the
license renewal issues.
Between the Staff and NEI we have compiled a list of license
renewal issues which are generic implementation issues, and they mostly
come from NEI's comments on the draft Standard Review Plan for license
renewal.
We have worked with NEI and we have agreed on how to put
priority on these issues.
Priority one issues are those that should be addressed to
support the review of the license renewal applications, such as BG&E and
Oconee and priority issues that are generic issues. That should be
resolved so it can be incorporated into the rule implementation guidance
documents such as the Standard Review Plan, the Reg Guide, or NEI 95-10.
Priority 3 issues are less significance.
We are in the process of addressing some of these issues and
also working with NEI to get some of these issues clarified.
As the Staff identifies issues we also -- like the lessons
learned, we identify a certain issue and put it into this process also
so we can look at it.
The next two slides are the current Priority 1 issues.
The first one is the issue number -- for each one we
identify a number and a description. In the slide we also have how we
considered that in the BG&E review.
This is a roadmap to what you will hear tomorrow.
For example, the issue 98-0014 -- that is the EQ, and
tomorrow you will hear about that regarding Section 2 of the SER so that
is for most of this.
I will talk about this -- for the generic, they have got
color codes, many sections of the SER.
The first item is 98-003. This talks about the -- and the
industry question about the need for wide operating experience
information in the application, to support the applicant's determination
of the applicable aging effects and to demonstrate the adequacy of the
aging management program.
In Baltimore Gas & Electric what we did is, I guess last
year or the year before we developed with BG&E a template, which is the
form and content of the application. In there BG&E agreed to provide
that information to us to review, so that is how we addressed that.
BG&E provided the information.
But the generic issues, they are outstanding in terms of
what the industry should provide generically.
DR. SHACK: What exactly is meant here, Sam? Is this
discussion, for example, on whether there's cracking of the reactor
vessel internals and you look at industry experience with that problem?
Is that the kind of --
MR. LEE: Yes, that's what the cards say. One thing is our
industry experience and another thing is plant specific experience, so
we actually do an evaluation of the vessel internals, okay? In your
application you actually describe industry has seen certain cracking and
my plant has seen certain cracking, therefore I have this cracking and I
am managing this and the industry program "x" has been adequately
managing this kind of cracking and found certain things and repair and
replaced. At my plant we had a program "x" also and it has been
effective.
They need to say all of that in the application for us.
MR. GRIMES: The concern that was originally raised was how
far do you have to go? What if you have not had any experience?
DR. SHACK: What was the issue here?
MR. GRIMES: The way that we approached the resolution of
this issue was we gave guidance to the Staff that said ask questions
about operating experience if you can point to specific experience that
is relevant that you think applies, but don't expect the applicant to
come in and explain every possible experience that anyone possibly has.
It was that open-ended feature that was the larger concern.
I think that ultimately we are going to end up resolving
this by providing guidance to the Staff that says if certain operating
experience that you know of has not been mentioned or pointed to or
described in the application, then inquire about it, but don't ask
questions like tell me about all the operating experience you have ever
had.
The ultimate solution to this thing I think is going to end
up being as we gather more and more evidence of what is the appropriate
operating experience to refer to that we will sharpen up the expectation
in terms of what the appropriate level of detail is.
DR. FONTANA: It is my understanding that Priority 1 issues
are going to need to be resolved before the extended license is issued,
is that correct?
MR. LEE: Right now they are scheduled to be -- actually all
the issues will be scheduled to be resolved before the BG&E SE --
DR. FONTANA: Yes. That is one of the requirements that
makes it a Priority 1 issue as compared to Priority 2 --
MR. LEE: They will be resolved.
DR. FONTANA: What?
MR. LEE: According to the schedule right now, yes, they
will be resolved.
DR. FONTANA: The question relates to, for example, on
operating experience the resolution then is an identification of how
much is going to be required. Let me
MR. GRIMES: Let me clarify. We viewed these issues as
issues that we would have to address during the first two license
renewal applications, but the resolution basically is how did we treat
it?
We treated operating experience in these first two reviews.
Now that does not necessarily mean that as a result of developing this
guidance to the Staff that we won't find a better way or more detailed
guidance to put in the Standard Review Plan.
Similarly, environmental qualification and some of these
other areas, we have dealt with them. We have addressed them but now
there are spin-off issues and so I don't view the ultimate solution of
all of these issues as a prerequisite to completing the licensing for
these first two applications, but we did put them high on our list
because we felt they were things that we would have to confront.
MR. LEE: But we learned from BG&E and Oconee also, so we
can feed back into the generic process. I mean do we still want to do
something like this.
DR. UHRIG: This implies that a Priority 2 or perhaps a
Priority 3 category of issues, those will not be resolved before the
renewal of the license?
MR. GRIMES: Most of the characterization that I would
provide for those other issues are there are questions about the form
and content of the application or particular questions that were raised
about how do we deal with a particular aging effect, and so we put them
down as a lower priority because they basically are things that are more
beneficial for future applicants.
That doesn't mean that we are not working on them. We are
making some progress on the lower priority issues, but we didn't see
them as critical to completing the review for the first two
applications.
DR. UHRIG: Okay, so this really --Priority 1 is the
tentative classification for the first two applications?
MR. GRIMES: That is correct.
DR. FONTANA: I don't have the list in front of me, but when
I looked at Priorities 2 and 3, there appear to be some, particularly in
Priority 2, which seemed to be pretty important.
Is it just a case that these are the ones that relate to the
first two?
MR. GRIMES: Yes, there are some of those that are very
important but the first two applicants just addressed them in whatever
fashion they felt they could address them.
In terms of the Staff providing more guidance, in the
Standard Review Plan or putting more guidance in the NEI 95-10 in terms
of the treatment of those issues in future applications was basically
the issue that we're pursuing.
MR. LEE: Okay. The second issue in here is FSAR content.
The license renewal rule requires an applicant to submit an FSAR
supplement summarizing the aging management program and the timely aging
analysis evaluation.
This is an open item in the BG&E SER. We are waiting for
the final SE in terms of what we rely on for the safety conclusion and
also we are -- the agency is providing improved guidance on updating the
FSAR, which is 50.71(e) and we are consulting with those people and
trying to be consistent with that -- so that's that.
The other ones you'll see tomorrow --
DR. SHACK: Sam, could I just ask you a question about
fatigue.
MR. LEE: Okay.
DR. SHACK: That is an interesting one. I see you had a
meeting yesterday that you discussed that one. Somehow the discussion
here doesn't seem to reflect any of the concerns that are addressed
here -- "here" is in the SER and the BG&E thing. It seems to have gone
on as though all this had never been occurring.
MR. LEE: -- it's an open item in the BG&E SER.
DR. SHACK: And it just sort of is left that way as the open
item with the GSI-190 and --
MR. LEE: Yes. Basically that is what is left open is the
GSI-190. That is what it is, and, yes, we are working with BG&E to try
to resolve that.
DR. UHRIG: Because I am surprised it says "Not Priority 1."
MR. LEE: Okay. What happened in this case is -- like I
said, it is not Priority 1. Initially we assigned priority to those
issues and we did not think those are Priority 1.
The issue really is -- well, there are several parts to the
issue. One part is the GSI-190. Another part is the use of the
non-mandatory Appendix L in Section 11 for inspection for fatigue,
okay? -- and this issue is weighted more towards Appendix L, which BG&E
and Oconee that's not proposed to use in their applications, so we don't
see that affecting BG&E or Oconee. At the time we put priority on these
issues, GSI-190 was close to being resolved.
It is only recently when the schedule gets pushed out, okay,
so now it affects BG&E and Oconee.
DR. SHACK: You mean the guy that volunteers to use the
Appendix gets grilled on it? The guy that ducks it doesn't have to
answer questions?
MR. LEE: They are not proposing Appendix L for the
program -- for the plant for license renewal. NEI wants to use Appendix
L, okay, for the industry, okay, so they don't propose it and that's not
what the program really evaluates for BG&E and Oconee.
MR. GRIMES: I would also like to point out that you see the
difficulty that we have in trying to maintain stability in the process,
because we started off pursuing one question and we thought that -- you
know, we had certain expectations about how the review would proceed on
some of these issues, and because we don't -- we can hardly keep track
of how many open items are we tracking and what is their status. We
move them around but we don't change their designation so much as we
just recognize we now have a couple of issues that have evolved as we
continue with the review.
Now we have to make some decisions about whether or not we
bifurcate the issue or create a new one.
I think -- Sam, are we up to 109?
MR. LEE: Yes.
MR. GRIMES: We are up to 109 issues now as we continue our
learning process, and fatigue as we are approaching it now is not the
same question about how are we going to treat fatigue that we originally
started with.
We thought it would be fairly simple to separate GSI-190
from an assessment of managing fatigue, but it is not as easy as we had
hoped and so we are proceeding to try and find a resolution of that that
will permit us to reach a conclusion for a complete safety evaluation.
DR. FONTANA: You said these are going to be discussed in
more depth tomorrow?
MR. LEE: That is correct, yes, and this is the roadmap, so
say, for example, when you come to this issue tomorrow, when we come to
this Section 2 of the SER presentation, they will actually discuss that.
This actually will be in their slides on the license renewal issues and
you have that and then they will discuss that.
We figure you will get more detail when you get individual
sections.
I will just talk about, there is another one in here, there
is 98-0100. This is not a BG&E issue; this is Oconee's -- and here is
more interesting one.
DR. SHACK: It is truly a plant-specific issue.
MR. LEE: Well, these are effects of Oconee, one of the
first applicants.
There is an issue under heat exchanger function and this is
part of the learning process. We did not have that upfront but now we
learned and then we added this to the database.
For BG&E they managed the aging of the heat exchangers for
the pressure boundary function and it's now written in the SER and that
is acceptable.
However, when Region I goes out to do the license renewal
inspection they had a question about should they also include the heat
exchange function as a function of heat exchanger to be managed, so this
is a question and the Staff now is in action to evaluate this, to see if
any additional aging management is needed for the heat exchange
function, the heat exchanger.
This last slide shows the lessons learned.
That is all the Priority 1 issues I have, so do you have any
questions on that? You will hear more on this in detail tomorrow, by
individual sections.
DR. FONTANA: I know that we have several questions on them,
so we will address them tomorrow.
MR. LEE: That's correct. You can ask the presenter
tomorrow.
DR. MILLER: The level of detail we will hear will be in
some cases more than what is in the SER?
MR. LEE: You will have the reviewers in here, so you can
ask them and they will tell you, you know -- if you have a question, you
can ask them.
MR. GRIMES: But I will bring Sam back, because he is
responsible for helping to answer the questions too.
DR. SHACK: Sam -- I thought when I heard license renewal
inspection program that was really a process inspection for how they
implemented things. It says here that they are going into more -- what
is the scope of this actual license renewal inspection program?
Are we going to hear more about that tomorrow?
MR. GRIMES: We hadn't planned on it. We can --
DR. SHACK: I mean is it basically looking at their
processes or you are actually out looking at -- is it plant walkdowns?
What is it?
MR. GRIMES: Yes, both.
DR. SHACK: Both.
MR. GRIMES: We look at the process and then we look at the
results of the process to see how it worked. We verify the contents of
the application and we verify particular details that the Staff relied
on for its safety evaluation conclusion.
DR. SHACK: So it really inspects the entire scope, of which
you need to do this baby?
MR. GRIMES: That's correct. We want the inspection to
verify the process and the process controls, the results of the process
in terms of scoping and screening, applicable aging effects, the aging
management programs are as described in the application, and then
time-limited aging analysis -- all of those areas are sampled by the
inspection so that when the review is complete the Regional
Administrator will be able to contribute to a license decision with a
full complement of information.
DR. FONTANA: Do these inspections feed into trending
analyses, of trends and extrapolations?
MR. GRIMES: The NRC inspections of the license renewal?
DR. FONTANA: Inspections that you are talking about here.
I mean do they feed into a central trending program of some kind?
MR. GRIMES: I am hesitating to answer that question because
the NRC inspections of the licensees -- or the applicants for license
renewal activities really get to a specific licensing action and that is
separate from the inspection program evolution from SALP into this new
oversight process.
It is theoretically conceivable that we might see something
in the license renewal inspections that will be shared and used in the
oversight process but in terms of trending plant performance, I see that
as unlikely.
DR. FONTANA: I guess I was more concerned with the other
direction, information that came from inspections beyond licensing --
feeding into license renewal decisions?
In other words, say you identify -- say you are inspecting
an existing plant, and this is all hypothetical of course, and you
identify -- by trend you identify an aging effect, and you do an
extrapolation and say, oh, that is going to go to year 42 or something
like that.
The question is, how does this feed into what you are trying
to do?
MR. GRIMES: I will answer that in two ways. The first way
is our normal process for analyzing events and information that leads to
generic communications is now sensitized to looking for aging effects,
and so throughout our normal routine we expect to find feedback, but
then I also mentioned earlier that as part of the Staff's review, if we
have knowledge of or learn about particular plant experience that is
relevant to the effectiveness of an aging management program, then we
pursue that.
Most of it is going to be volunteered in the application.
In the case of Baltimore Gas & Electric there was some experience during
the conduct of the review that we reflected on to see whether or not it
affected aging management. I believe that was a line break in the
secondary system that caused us to reflect on the fatigue issue so we
look at the processes to deal with those things in terms of implications
and trends. Does that answer your question?
DR. FONTANA: The question relates to a question you are
going to be hearing probably over and over again over the years -- is
the -- trying to get away from compartmentalization, this effort with
other efforts, and I am sure you are aware of that. It will be raised.
MR. GRIMES: We are acutely aware of how we need to improve
our overall regulatory processes and so license renewal is in the
spotlight right now because license renewal is a very important aspect
of regulatory improvements, but we are also looking at more effective
work processes and sharing information across the agency, so we are
tuned into that as well.
DR. FONTANA: I thought you were.
Any additional questions?
[No response.]
DR. FONTANA: We were scheduled for a break at 2 o'clock. I
guess we might as well take it and come back with Barth Doroshuk.
MR. DOROSHUK: Yes, sir.
DR. FONTANA: How about 2:15, okay?
[Recess.]
DR. FONTANA: The meeting will come back to order. Are you
ready?
MR. DOROSHUK: Yes, sir. I'll put the microphone on.
DR. FONTANA: Sure. At this point we will hear the
presentation by Barth Doroshuk, Baltimore Gas & Electric.
MR. DOROSHUK: Good afternoon, Mr. Chairman and members of
the ACRS Subcommittee on Plant License Renewal. My name is Barth
Doroshuk and I am the Project Director for the Life Cycle Management
License Renewal Project at Calvert Cliffs, and we appreciate, on behalf
of Baltimore Gas & Electric we appreciate the opportunity to provide you
with our remarks this afternoon.
I'll take a moment to just introduce a few people that we
have brought with us -- Mr. Dick Heibel, at this table, is the Manager
of Nuclear Projects and he is my immediate supervisor at Calvert
Cliffs -- he is also responsible for our steam generator replacement
project and all the other projects that are performed on the plant; John
Rycina, to his left, is the Project Manager of the Integrated Plant
Assessment, which we will be covering today, and I guess the Staff will
be covering tomorrow; to Dick's right is Mr. Marv Bowman -- he is the
Project Manager for the implementation side of the License Renewal
Project -- he interfaces with the plant; Don Shaw, who is assisting me
here, is the Project Manager of the application and review and is the
primary interface with Dave Solorio, our Project Manager at NRC.
I would like to also at least acknowledge Dr. John Carey
from the Electrical Power Research Institute, EPRI. BG&E and EPRI have
had a longstanding technical exchange since the mid-'80s on life
extension and their work and our contributions to their efforts as well
has been a great help here.
Tomorrow we will have a number of other engineers, project
engineers, here. We feel we can field the questions today, but we will
certainly have a large depth tomorrow as we go into the detailed
technical review, and so if we can't answer your questions today or
tomorrow then we'll have to take -- but we think we will be well
prepared for your review today and tomorrow. Next slide, please.
The purpose of my presentation is to provide you with an
overview of the development, the review and the implementation of the
Calvert Cliffs license renewal application. I am going to try to
achieve that by doing four things. I am going to discuss the Calvert
Cliffs Nuclear Plant and its role with Baltimore Gas & Electric in the
state of Maryland, the importance it plays. I am going to discuss the
license renewal application itself, the development, the content, how it
came about, and then focus on the findings, which are the programs that
we are committing to manage aging and how we are implementing those
findings at the plant within the engineering staff and the maintenance
organizations.
I would encourage you to interrupt me and ask questions
along the way. As I said, we will do the best we can to field those.
Next slide, please.
Calvert Cliffs is a twin-unit Combustion Engineering NSSS
station. Bechtel is the AE of record. It is a pressurized water
reactor. The operating licenses were issued in 1976 and 1974 and they
expire in 2014 and 2016. They are full 40-year licenses. Calvert
Cliffs was the first plant to obtain construction period recapture in
1985, which was the shifting of the OL date from the CP point to the OL
issuance date.
The plant is located about 60 miles southwest of Washington,
D.C. on the Chesapeake Bay, as shown here. It sits on a 2300 acre site
of land, of which 180 acres is used approximately for the plant itself.
The rest of the site is farmland. It is a wildlife refuge and it has
marshlands, is the home of 90 percent of the world's population of the
tiger beetle and we also have a Bald Eagle's nest on the site as well
and we host a number of other animals as well, as you might imagine.
DR. FONTANA: Is that a working farm right next to you
there?
MR. DOROSHUK: Yes, sir, it is.
The number one goal for Calvert Cliffs is nuclear safety.
That is the goal for the plant, and if we cannot achieve our number one
goal, then the plant does not operate, period. It is an easy standard
to understand and we meet it on a continuous basis.
The plant must also remain competitive, and as we approach
deregulation we are making efforts to make sure the plant is ready from
a safety, a reliability, and a cost competitive perspective.
We have had an excellent track record over the last 25
years. I would note that in the late 1980s and the early 1990s we were
on the Troubled Plant List. We recognized the areas of improvement. We
made those improvements and since then our record -- the record of the
plant speaks for itself. We continue to hit in the top quartile for
most indicators.
The goals are set up to guide us into the future. We need
to continue to be an asset to the customers of Baltimore Gas & Electric
and we need to continue to be an asset for the residents of Maryland,
the stakeholders, and after achieving all these goals we need to
continue to retain the ability to invest wisely in the plant. You can't
have a plant that is meeting all of these differing goals and not be
able to continue to make improvements and the last goal is equally
important.
We need to continue to evolve. The plant is a learning
plant -- next slide.
The nuclear decision, the decision to operate a facility --
this is our philosophy -- or permanently close it must be based on
several inputs -- sound technical information, safe, reliable production
record, and projections into the future, a knowledge of where you stand
competitively in the evolving marketplace, the ability to continue to
operate the plant and meet those goals must be forged with a vision of
integrity, quality and safety.
DR. KRESS: These are --
MR. DOROSHUK: Inputs into our decision --
DR. KRESS: That is your decision. These would not be
inputs into NRC's decision?
MR. DOROSHUK: No. That's correct. I am a little bit in a
broader topic at this point. I will focus in.
Our decision to relicense Calvert Cliffs and to continue to
operate the plant is based on sound technical information, a safe and
reliable production record, and projections and a knowledge of where we
will stand in the competitive marketplace. Our vision is based on
integrity, quality and safety. Next slide.
Calvert Cliffs is important to Baltimore Gas & Electric, to
Maryland and to all the region. It makes up about 30 percent our energy
supply. It provides on an annual basis 50 percent of our generation
from BG&E, and I guess you can look at it as the backbone of the energy
supply to the state of Maryland. Next slide.
The decisions that are being made these days on nuclear
facilities are complex. I can tell you that since 1989, when the life
cycle management organization was established at Calvert Cliffs that we
have evaluated all aspects of the continued operations of the plant and
we concluded that from all aspects that it just makes sense to continue
to operate Calvert Cliffs and to continue to preserve the license
renewal option in the state of Maryland, and that is what license
renewal is -- it is an option to operate the plant.
Today we will focus primarily on the technical aspect of
these evaluations. Next slide.
DR. SHACK: How recently did you come to the decision to
replace steam generators?
MR. DOROSHUK: We have been evaluating steam generators
intensively since probably 1990 on a continuous basis, knowing that the
rest of the industry has been replacing steam generators. We didn't
experience a significant number of tube plugs until 1995, which was 20
years into, basically into the operation, so I think that speaks well of
the programs we have had to maintain the steam generators on site.
We actually made the decision in 1998 to go ahead with the
steam generator replacement so we looked at the data for about two and a
half -- two consecutive outages to confirm that we were not just seeing
an inspection transient.
DR. SHACK: That is for both units?
MR. DOROSHUK: For both units. The schedule for replacement
of steam generators is 2002 and 2003. Unit 1 will have its steam
generators replaced in 2002 and Unit 2 will be in 2003. It is a
like-for-like exchange where we will have, basically we will replace the
inner bundles inside containment and refurbish the dome inside
containment and perform the welds back together. It will not be a
complete changeout. We are going to preserve the domes, refurbish
inside, but basically manufacture the internals.
We believe that early investigations on nuclear facilities,
both technical and financial, combined with a commitment of excellent
performance are necessary to avoid a bow wave of technical and financial
risks that could be so insurmountable that continued operation is
jeopardized.
These types of bow waves challenge our decision-making
process.
We have taken an approach at Calvert Cliffs that has been
referred to as a life cycle management approach to managing its nuclear
assets. It is the long view. We feel that these early investigations
have allowed us to make responsible decisions regarding the future of
Calvert Cliffs. Without these strategic actions we are not sure that
discrete strategic decisions can be made appropriately. Next slide.
Turning more to the subject at hand regarding plant aging,
again from a life cycle management perspective there are some
undesirable knowns that aging provides us in that plant aging can result
in unanticipated increased costs, both O&M and capital, increased plant
unavailability, and regulatory-driven recovery programs.
Plant age-related failures ignore our planning horizon.
They don't care when our outages are.
We also realize that across the world that it is difficult
to apply the right resources at the right time on the long view to
anticipate every single challenge we are going to have and avoid them.
These unanticipated events bolster our competition's perception of us as
a weak and unlikely contender and weak in our resolve to make
knowledge-based decisions.
In our view of life cycle management, this is what we are
trying to avoid technically.
The elements of our program that we believe make up our
success is a good understanding of the plant historical behavior.
Calvert Cliffs Life Cycle Management Organization has been staffed with
approximately 20 to 25 full-time engineers since 1989 who are located at
the plant inside the Engineering Organization of the plant, working with
the plant people. We feel that this infrastructure, this change, this
organization has build a decent plant historical record and understands
its behavior. The resources I mentioned are being applied
appropriately.
Mitigation measures are appropriate for success. Discovery
techniques, which is the confirmation of what we are studying -- we are
not doing an engineering analysis for the sake of an analysis. Our
philosophy is if you come to a conclusion you basically should go check
it. If you find yourself in analysis space, it's probably better off
that you go walk down the plant or perform the right inspection to
determine what real world activities are occurring.
DR. FONTANA: What is an example of mitigation measures?
MR. DOROSHUK: Chemistry.
DR. FONTANA: Okay.
MR. DOROSHUK: Cathodic protection.
DR. FONTANA: Thank you.
MR. DOROSHUK: Yes, sir -- and then the appropriate
corrective actions follow.
DR. SHACK: What fraction of your aging management program
really follows from your life cycle management and which part did you
implement specifically for the license renewal considerations?
MR. DOROSHUK: We have -- from this particular evaluation,
and I will talk about it later, about 450 plant programs that we have
decided are necessary to manage aging post forty years, to ensure that
the safety is maintained in a reasonable manner.
We have been involved over the last 10 years doing
non-nuclear life cycle evaluations, whether it be do I replace the
rubber-lined carbon steel piping in the salt water system, do I put
titanium in instead, those types of evaluations do occur over time and
are more directed at I have a decision, a long-term decision to make on
a power production part of the plant. How do I rank the options? What
is technically the most feasible, what is the most cost effective --
those occur and have occurred over the years and I don't have a number
of how many of those we have done.
We have been able to make the appropriate recommendations
with the plant on those types of decisions. In fact we stayed with
rubber-lined carbon steel. The premium for titanium wasn't worth it.
There are other areas of the plant where we have made recommendations to
actually make changes to the way the plant is operating or the actual
equipment.
This program can be viewed as change management. We are
changing a culture. Aging is nothing new. We have been managing aging
at the plants through our maintenance inspections, our replacement
activities since the plant went into play -- went into operation.
However, we haven't actually in this total approach looked at it from
the standpoint of, as a dimension of the future operation, so we felt
early-on that in order to change behavior that we needed to do this
using integrated engineering teams. We couldn't do this in the home
office and then deliver the product and have them say I didn't have any
play or part in developing the solution.
These teams have been critical in evaluating the plant
beyond the typical planning horizon.
The solutions? There have been clear expectations set and
because these teams are diverse, the decisions and options have been
challenged and have resulted in better decisions.
The integrated implementation of the customer buy-in has
resulted in good measurements for success. How do we know what we were
going to do or are going to do is going to work? It is a learning
program. It is a change to the way we behave. We are not worried about
us here in 1999 or 1998. We are concerned about the engineering staff
who is at the plant in 2010. They will remember what we did here and
continue to manage the aging.
DR. FONTANA: Do your decision analysis techniques involve,
say, risk-informed prioritization?
MR. DOROSHUK: Yes. They can. Not the license renewal. In
license renewal every system is equally important.
However, when you do the plant prioritization for work, that
does come into effect, which mods should be considered over what modes,
which ones should be done first.
DR. FONTANA: Thank you.
MR. DOROSHUK: Let's look specifically at license renewal
now. We have been involved since the beginning. The NRC published the
rule in 1990. We established ourselves very shortly, before that
actually -- 1989. We began initiating the development of the process
and procedures we could use right after the draft rule. We felt that in
parallel with reviewing the rules and providing the NRC with comments
and working with the Nuclear Energy Institute BG&E felt it was important
to also be testing those rules somewhat in parallel, so we were
developing procedures and trying them out, the rules out on the plant,
in parallel.
In 1991 we did develop a methodology which helped provide
the industry input into the NRC that the original rule perhaps had some
flaws in it that needed to be corrected, primarily the age-related
degradation unique to license renewal was an unworkable concept.
It didn't work, and so the fact that we had tried that
process out on seven systems and had thousands of components to be able
to support the input and provide the NRC for consideration we think was
beneficial. The rule was amended in '95. We amended our process in
'96. We submitted it in '96 and the NRC reviewed it and approved it
through a final safety evaluation on the integrated plant assessment
methodology.
We can probably count hundreds of interactions in the
industry with NRC over this time period. This was a veryt good learning
time period. Next slide.
Over the last several years alone, there have been no less
than 60 public meetings. I have been using the number sixty for several
weeks now. I think I can probably go up to 65 as we continue to click
off the public meetings at a fairly good rate. They have been open at
the plant. They have been held at local establishments. They have been
held here at Headquarters, and the point I am trying to make here is
that this process has been open not only between BG&E, NEI, EPRI and the
NRC. It has been open to the public on a continuous basis.
There have been numerous rounds of available times for them
to comment and participate.
In addition to the several formal public meetings held by
the NRC, we have a Visitors Center and an ongoing outreach program at
the plant to solicit public participation and that has resulted in about
3000 visitors a year and over 150 tours a year, so I guess up until the
time we submitted it and the formal process once it has been submitted I
think the doors have been open for all to review and comment.
The application itself was submitted in 1998. It was three
volumes, as Dave pointed out, about 2000 pages. I guess you have it.
Go to the next slide.
These are the parts of the rule that drove what is required
in the application -- 54.19 talks about the general information that you
need to include in it, 54.21, as the contents of the application with
respect to the technical information, which is the primary topic of this
afternoon and tomorrow. They include the integrated plant assessment
results, the annual changes, the evaluation of the time-limited aging
analysis, the UFSAR is required to be part of that application, the
technical specification changes that you are going to perhaps propose,
and then the environmental report.
These are the parts of the rule that drove what we included
in the documents that you have.
I would like to point out and I think it was discussed
earlier that when we developed the actual application we did go through
a fairly extensive development of a template. We think that was a very
important part -- why don't you go to the next slide, Don -- of this
because this slide tries to give you a picture of what the application
actually is built off of, and I will go through all these acronyms, but
at the very tip you have the application itself. Those are based on the
aging management reviews, which is based on the scoping of the plant,
which is based on the licensing basis of the plant, which relies on the
plant test procedures and inspections, which relied on all the NRC
documents of the current licensing basis for Calvert Cliffs, and generic
information which includes also the external assessments, generic -- as
you get further and further down this pyramid you begin to get into just
the general engineering disciplines that make up your fundamental
engineering decisions.
This is a very high level document. I can say that every --
the importance of the template, both for the technical part and the
environmental part, were critical in being able to communicate the
story, provide the NRC the necessary information so that they could
start their review last summer. Yes, sir?
DR. KRESS: George Apostolakis is not here, but if he were I
am sure he would like to ask the question of does PRA enter into this
process anywhere at all?
MR. DOROSHUK: Yes, sir, it does. In the environmental
report it is required that we perform a severe accident mitigation
analysis for --
DR. KRESS: SAMA report.
MR. DOROSHUK: SAMA report, yes, sir. We had to take our
PRA to a full Level 3 PRA. We looked at over 150 individual SAMAs that
split out into actually more as you got into implementation.
We developed a screening process. We used the NRC
guidelines for performing this, which were based on the Watts Bar SAMA.
It was a very extensive analysis that I guess we are not going to
discuss today or tomorrow.
Out of that we found that there was one severe accident
mitigation analysis, one hardware change that we elected to perform. It
was a particular change that resulted in a significant decrease in the
internal flooding sequences in the PRA and we have initiated the actions
to have that change made in the plant.
There were a number of items that -- I guess there were
three items that came up that had nothing to do with aging that the NRC
and Baltimore Gas & Electric both looked at them and did not make them
part of the application but they are being handled under the IPE
follow-up program, a very extensive analysis.
DR. KRESS: Did you use your IPE?
MR. DOROSHUK: Yes, sir.
DR. KRESS: The IPE and IPEEE. Not only did we take the
guidelines off from the NRC published guidelines in the NUREG but we
looked at the advanced reactor SAMAs, recent SAMAs that were performed
on the operating plants during OL stages as well as held several
meetings with the NRC staff to ensure that this particular analysis was
meeting the expectations of the Staff.
Every single sentence almost, and I will say almost, but
every statement of fact, every single conclusion in the application has
a reference to where it came from, so as you review it or as you have
read it you probably noticed that in the bracketed parts of the
paragraphs you will find that there is an auditability trail all the way
through here, and I would point out at this point that the NRC review,
the regional inspections have been extremely thorough.
They have chased down through vertical slices all the way
down to these textbooks where we had debates on whose textbook was
perhaps more current, so this was a very valuable exercise in
auditability and well done.
I think it goes to saying that the principles of the rule,
which you discussed earlier -- this has tested those principles. It
allowed us to perform the surgery, if you will, on the current licensing
basis with respect to aging, and has showed us that the current rule,
although improvements could be made, does work. It does allow you to
make good decisions with respect to aging.
The way we constructed the application -- next slide -- was
consistent with the way we work, we do the work at the plant. We wanted
to satisfy all the requirements in the template that was created but if
you look at the rule, the rule itself just says give me a list of
components, give me the aging management programs, and give me a roadmap
on how you came up with those list of components.
It doesn't say anything about how did you evaluate operating
experience, how did you divide the plant up? The template process and
the standardization work that NEI will be doing over the next year or so
with NRC would be very important.
We provided a summary of the scoping of the pre-evaluation
of the aging management review activities conducted and we provided a
summary of the relevant operating experience according to the template
for the system as a whole to show the effectiveness of accredited
programs and then of course provided the direct references.
This was applied on a system by system basis. That is the
way we do work primarily at the plant is we have feedwater systems and
we divided it that way. We will talk a little bit more about this
particular approach in a second. Don, next slide?
There are two main sections of each LRA system or commodity
chapter. The sections are scoping and aging management. In the scoping
section we break the system down, basically we reach into the plant, we
pull out the feedwater system and we describe what we pulled out so you
know where all the interfaces are, you know where all the components,
you know what the system was supposed to do, you know what the
components are supposed to do, and you know what components that go into
the formal aging management review, which is required by Part 54.
Then, the second part of that -- each chapter is the formal
aging management review summary which shows -- we discuss how we
evaluated the component groupings, how we determined the methods that we
are going to rely on to manage the aging, so those two sections you will
see consistently in each chapter.
The process is very simple. You have the scoping, which
systems and structures are within scope, what are their intended
functions by the rule, what are the components that were required that
contribute to those functions, and then we go into determining, under
the pre-evaluation, this is our own plant-specific terminology, are the
components, with intended functions that support the system, passive or
active; are they periodically replaced; are they excluded by the rule.
These are screens so that we can get to the right set of
components within each system, so that we can focus the engineering
efforts. Then we look at the aging effects that could affect the
components' functions and determine whether or not they're managed by
existing activities or do we need to modify existing activities or
develop new programs to manage the aging. It's a fairly simple
approach.
DR. KRESS: On that diamond that says manage existing
activities.
MR. DOROSHUK: Right.
DR. KRESS: Is that just asking whether such an activity
existed or did you have some sort of criteria to say whether it was
sufficient and necessary or good enough or adequate?
MR. DOROSHUK: Right. That's exactly what we did. We had a
component or a group of components that were of similar material, et
cetera, with effects, and we went and worked with the plant under Marv's
area and implementation, and said what options -- what are we doing
right now with respect to the aging and if we could take credit for
those programs, they became existing credited programs, existing
activities.
If we went into the plant and we found out that they needed
to be modified a little bit to satisfy our unique focus -- for example,
we've had some PMs that put the inspector in the vicinity of the
component, but doesn't just quite tell him to look for general
corrosion. It says inspect for condition. So we modified that existing
activity to focus the inspector.
DR. KRESS: Will these programs then become part of your
licensing basis or are they already part of it?
MR. DOROSHUK: Some of them are already part, but they
become licensing commitments as part of the renewed license. They
become part of the CLB.
DR. BONACA: Are you going to talk about demonstration at
some point, give us some examples?
MR. DOROSHUK: Yes, I am.
DR. SHACK: Just where do your ARDIs fit into this process?
MR. DOROSHUK: They are under a new program. When -- why
don't we hold off on that just a second and we'll get to how we selected
certain things to do certain things.
Let's go to the next slide, scoping. Again, from a scoping
perspective, we felt the most effective approach was to use two levels,
which was a system level and the component level. That's the way we did
business at Calvert Cliffs. That's the way we have our maintenance
system set up. You'll have another utility that might come in and say
we manage it by programs.
You'll all come to the same answer for the individual
components. To us, it was a logical and manageable piece to fit in.
The active/passive determination was the final step. We call that the
pre-evaluation, prior to going to the formal aging management review.
As I said, for the --
DR. KRESS: Excuse me. Did you have a formal criteria for
deciding whether it was active or passive?
MR. DOROSHUK: Yes. We had formal criteria where it had to
change -- it was a definition that's put in Part 54 for passive, which
is change state --
DR. KRESS: It's the definition that's in the rule.
MR. DOROSHUK: Right. You want to add to that, John?
DR. KRESS: I'm familiar with what's in the rule.
MR. DOROSHUK: That's the criteria we used.
DR. KRESS: Thank you.
MR. DOROSHUK: The system level scoping allowed us to
establish the boundaries. One of the concerns from the NRC in how we
package this information is how do we know that the person reviewing the
feedwater system and the person reviewing the condensate system knew
where the interface was. So this allowed us to at least package that
information for their review.
The tools we developed using the rule and then we applied
these tools of our licensing basis to come up with the results.
The goals -- next slide - of the aging management review are
to demonstrate that the effects of aging of the structures and
components within the scope of licensing renewal and subject to an AMR,
long-lived passive components that were left over are adequately
managed.
We've done this by either recognizing that the particular
component that we were about to do an aging management review was
replaced every five years anyway. There is no need to go through a big
formal aging management review since you're replacing it. Or you come in
and you identify the plausible aging effects, age-related degradation
mechanisms for each component. You evaluate those effects relative to
the functions that we're concerned about, and then you determine the
best manner in which these can be managed.
Next slide. There were certain component types throughout
the plant that existed in every system that we felt would be better off
or were unique to themselves to be evaluated in what we call the
commodity aging review. Each commodity evaluation is documented. It's
slightly different. The scope of evaluation is specified.
So if it was different from the way we did the system, we
laid out the method on how it was a little bit different. The results
were basically the same with respect to presenting the plausible aging
and the program justifications.
There were six groups, electrical commodities, instrument
lines, cranes and the fuel handling, fire protection, component
supports, and cables.
You can see that these are like panels. Cables are
self-explanatory. These are non-EQ. Component supports, and instrument
lines are in every system. Fire protection is a very, very broad plant
set of equipment and we felt it ought to be across-the-board just put in
one chapter, and then cranes and fuel handling were a unique animal all
by themselves and we just felt they just belonged together in one
particular chapter.
So these are what we called our commodities. The rest of
the plant was evaluated in its respective systems.
DR. MILLER: Now, electrical commodities, for example, are
those that have already been deemed to be passive, right? Before they
got into that group.
MR. DOROSHUK: Yes.
DR. MILLER: So you went through the diamonds and said,
okay, these -- like fuses I notice are a big issue. These are now
passive, so we'll put those in commodities.
MR. DOROSHUK: That's right.
DR. MILLER: I notice you also put pressure sensors, and
maybe they could go either way, depending on where they are.
I'm just raising questions of how you came up with a list of
electrical commodities, which is kind of a potpourri of a number of
different issues.
MR. DOROSHUK: Do you want to identify yourself?
MR. RYCYNA: I'm John Rycyna. I'm the Evaluation Project
Manager. Electrical commodities generally consist of panels, the steel
boxes that hold electrical components, as well as plastic supports for
various things inside the panels.
Other electrical things you mentioned, such as pressure
transducers, level transducers, other types of transducers, some of
those are specifically excluded by the wording in the rules. Others,
which were not, which have a pressure boundary function, as well as an
electrical function, we looked at for pressure boundary.
DR. MILLER: So they then went into electrical commodity.
MR. RYCYNA: No, sir, they did not.
DR. MILLER: I was just wanting to get clear on your
process. I'll ask for more details as we go on.
DR. SHACK: Just another. Back on your flow diagram, each
of those diamonds, do those diamonds really represent expert panels? Is
that who is making these decisions and determinations?
MR. DOROSHUK: Those are procedural steps within the
process, that have specific procedures written for them, that the
engineer performing the work uses the plant information, puts it
together, assembles it. It is a hundred percent checked under our QA
program and then it was reviewed by the plant, by the plant safety
committees, and then by the off-site safety review committee, each one
of these, each conclusion, each step.
DR. MILLER: So in a way, you have three expert panels.
MR. DOROSHUK: Yes, and they were sometimes very painful.
They were very healthy, though.
Next slide. I guess I probably should have put this up a
little bit earlier. A couple of key definitions in the way we have
defined the world of aging. We consider an aging effect potential if
the mechanism for a given component, if he concludes that it could
occur, in application of the equipment throughout the plant, with
conducive environmental conditions.
This is a very broad net. This is a piece of steel, in air,
what type of aging effects could be potential. So we throw a very broad
net and the initial pass-through of looking at the individual components
and the materials just to make sure we have a complete list.
We then, through the evaluation, declare an aging mechanism
plausible for a specific component when allowed -- if it's allowed to
continue without any preventive mitigative measures or enhanced
monitoring techniques, we couldn't show that the component would be able
to maintain its capability to perform its intended function.
It's a long sentence, but if the aging effect was considered
to be plausible or necessary to be managed, if we couldn't show that we
could operate without doing anything. So that focused the net down to a
very small -- a smaller one to the final screen in the aging management
review.
The plausibility determination -- next slide -- considered
the materials and the environment, NRC and industry information,
plant-specific information, and the effects on the individual passive
intended functions that we were concerned about for the individual
component.
DR. SHACK: Now, how was this determination made?
MR. DOROSHUK: Through the same type of engineering teams,
where the individual reviewers, mostly disciplined at this point,
mechanical, civil, electrical, would perform the evaluation, have it
second-checked, and brought through the plant, through the materials
groups, et cetera, with the appropriate reviews, through the safety
committees.
We then, once we have determined that, look at what it is we
need to manage the aging effects of the particular component of concern
and our criteria dealt with what were the appropriate methods available,
what was the periodicity of the inspection activity or activity itself,
what was the acceptance criteria, and we were measuring the
acceptability of an aging management program relative to the functions
and the aging effects that we were concerned on, and looking at
operating experience to determine whether or not it had been effective
or would continue to be effective.
That was part of the discussion that Sam Lee had on that
open item and this is the key to operating experience is there needs to
be some substantial evidence, in our minds, that this program has been
effective.
We look at two-pronged approach typically throughout the
application. When we have a component and an aging effect, we look at
is there a mitigative action that's in play, that can slow down or
mitigate, and then we validate it through a discovery activity, such as
a field inspection.
So you take erosion/corrosion of feedwater and we have
secondary water chemistry which creates a less aggressive environment,
but we also recognize we need to continue to monitor that through the
inspection activities.
DR. KRESS: Would that be continued to be monitored for the
rest of the life of the plant?
MR. DOROSHUK: For the areas that we -- yes. These programs
would exist throughout the rest of the life of the plant.
We also look at, from a programmatic standpoint, are these
programs self-correcting, do they teach themselves how to be better
through our corrective action program, what's the foundation of the
program itself, was it based on codes and standards, et cetera, and was
the program administratively controlled so that those people around in
2010 would understand that they weren't allowed to change this with
specific consideration.
DR. FONTANA: That raises an issue that's been in the back
of my mind. It seems that we focus a lot on aging of equipment, system
and that sort of thing, and I don't see too much on aging of the people
and replacement of the people and the people who are retiring and no one
is coming in and keeping the same philosophy throughout this.
MR. DOROSHUK: Go back to the beginning, when I started
talking, I said this is really -- it's important to understand the
technical and do the right things, but you're changing behavior.
DR. FONTANA: Yes.
MR. DOROSHUK: You have to change the culture and add that
dimension on to it, or else you run into problems like that. This
wouldn't be the first time where people forget to do things.
As I said earlier, the types of programs we credited in the
application are three types; existing programs, modified existing, and
new programs. About 456.3 activities, to be exact -- no, I'm kidding --
456 different procedures and activities in the application and that
number can change, depending upon how we actually identify the
commitment, and we'll talk about how that might happen.
The selection of the programs involve, again, the integrated
teaming efforts of the integrated plant assessment engineering group,
John Rycyna's group; Marv Bowman's group, the implementation engineering
group; the plant system engineers and system managers who own the actual
equipment organizationally; and the program experts, whether it be
material, maintenance, et cetera.
Considerations; we need to get these programs selected prior
to the final approval of the aging management review report, so they can
go into the application, and that is the first final approval. We have
found that things change after we implement and things like that, and
we'll talk about that, and the staff has told us to change things.
The method; there is a point, at this point, where we can
begin to group things internally and bring them down from the system
level down to the more programmatic level.
So in our case, we heard earlier the Oconee application
groups things by program. Well, we kept that grouping at the site and
that's the way -- we didn't put that in the application. So that step
for us was just kept on-site as opposed to put in organized that way in
their particular application.
This next slide shows you the breakdown of the 456 programs.
There are 329 existing programs. We'll talk about those. There were
101 programs that required modification and there were 16 new programs.
This gave us a good feeling when we were all done, after
many, many years of work, that plants, at least Calvert Cliffs, and I'm
sure this is representative of the industry, we do manage aging already.
This is not a new phenomena. We do recognize, however, there are areas
of the plant that should be looked at for long-term perspective.
So this breakdown gave us a lot of confidence and gave BG&E
management the confidence that we were doing a good job managing aging
today. So when you look back at the principals, the fundamentals of the
rule that came out of the regulatory analysis, the CLB is adequate, with
the exception of management of aging, this confirms that those
fundamental principals were correct.
This is the breakdown of the existing programs and you can
call these things different things from site to site. 309 of the 430
existing programs were in the preventive maintenance program themselves.
There were ten maintenance programs, chemistry procedures, 15 operating
procedures, four engineering programs, 25 maintenance procedures, and we
can pause here to perhaps talk about examples in each one of these, if
it's not clear what they might be.
Chemistry obviously is a secondary. Primary water chemistry
engineering programs would be like fatigue management. Preventive
maintenance tasks would be the field checklists where they go in and
actually inspect and do the actual inspections on the components.
DR. SHACK: This is still talking about these passive
components, right?
MR. DOROSHUK: Yes.
DR. SHACK: Preventive maintenance on the passive
components.
MR. DOROSHUK: Right.
DR. SHACK: 309 of them.
MR. DOROSHUK: Already -- well, of the -- that's 309 of the
430. If we go back to the previous slide, what this kind of does is
lump the existing and the modified together and even though we had to
make some modifications to the existing programs, 430 of these existed
in a shell form or at least on-site already.
And the modifications can range from, again, like I said
earlier, it may have put the inspector in the vicinity of the component
and maybe looking at the component for one reason and the procedure
itself wasn't clear enough to say "and look for this particular aging
effect."
So we're going to modify that procedure, so that inspector
has that level of detail of instructions to record his observations.
Another modification might be we've added components to a particular
program.
Mark, is there another good example of existing programs
that we're modifying?
MR. BOWMAN: I'm Marvin Bowman. I'm the lead
implementations engineer. Those are the two basic modifications we came
up with. Some modifications to like the engineering programs are a
little bit different from that. The fatigue program is an example.
MR. DOROSHUK: Sure. We may have added components to
monitor or done a special evaluation inside the fatigue monitor. Let's
go back to the detail slide.
DR. FONTANA: With that many programs, how many programs
might one person be required to be responsible for, for example?
MR. DOROSHUK: The fatigue monitoring program, we have a
full-time engineer who implements that program and that -- it works in
the life cycle management project. That's where that responsibility or
function is implemented. They, in turn -- we, in turn, provide that
information to design, who does the semi-annual reviews and the
acceptance and the validation of the fatigue information that's taken
from the plant.
The fatigue engineer relies and works with the plant
engineers and the plant computer to extract the information and to make
sure that transients are counted appropriately, transients as opposed to
data scatter.
So there is a network even around an individual that is used
and built to implement these programs. Down to the individual rover,
who may be assigned to go do the individual inspection, of course, that
preventive maintenance task would be assigned at an appropriate level
for the inspector.
But, again, the program is administered and reviewed by
several layers of supervision and the review of the results.
DR. FONTANA: It seems like a lot of programs. I was just
wondering how much of a load it is to keep up with them for specific
persons.
MR. DOROSHUK: Again, these programs already exist and they
are already part of our infrastructure at the site.
DR. MILLER: So one engineer may have responsibility for 20
or 30 preventive maintenance programs.
MR. DOROSHUK: Could.
DR. MILLER: So one engineer may have responsibility for a
grouping of preventive maintenance programs.
MR. DOROSHUK: Yes.
DR. MILLER: Or surveillance programs.
MR. HEIBEL: My name is Dick Heibel. The preventive
maintenance program is -- there's five engineers/technicians that
provide the management of it. Each PM is assigned to a component in a
system and that system engineer is responsible to review the PMs and
make sure that they're upgraded. And when these PMs were reviewed for
aging management, that was the path they took. They took the path
through the administration part down to the system engineer, got
concurrence that the PM change or the PM adequately covered that.
So an engineer may have in his system maybe 60 PMs, but he
has an awful lot of assistance in tech manual changes and all that from
another group to make sure his PMs are kept up-to-date.
DR. MILLER: So I pick the example of I&C, the chief I&C
engineer may be theoretically responsible for the I&C PMs and he has a
lot of people with him to keep up with it.
MR. DOROSHUK: Theoretically.
MR. HEIBEL: Theoretically, all the I&C PMs would go through
the head I&C engineer, but his staff would be the ones that would
develop them and work them up.
MR. DOROSHUK: Next slide. A breakdown of the new programs,
the modified programs, I guess. We had six that we had to extend the
existing engineering analysis on or perform additional activities. One
was the -- we had some non-pressure boundary alloy 600 components that
we needed to add to the alloy 600 program. We had a time limited aging
analysis on the spent fuel rack neutron absorber. We had fatigue
evaluations, seven fatigue evaluations or seven sections that identified
fatigue evaluations that were necessary.
We had, of course, the LTOP and PT curve time limited aging
analysis that needed to be conducted.
DR. SHACK: I assume you had PTS, also, in there.
MR. DOROSHUK: PTS was already analyzed for 60 years for
Calvert Cliffs Units 1 and 2 and the SER, in 1995, was approved for 60
years and beyond. So PTS is not an issue for either one of the unit's
vessels. So it was previously approved. So that's why it doesn't show
up there.
Three new engineering analyses. We had a leak before break
analysis that we're committing to do on the RWST penetrations, some
stress relaxation of CEA shroud bolts and core shroud tie rods. We have
a -- this is one of the issues that we worked very well with the staff
defining the criteria on, the thermal aging of cast-off synthetic
stainless steel.
So these are the areas where we really had good technical
exchanges, because we're in a new program area and we had engineering
people providing their background from this organization, from EPRI,
from NEI, from consultants that were bringing to bear quite an extensive
amount if information to define the requirements.
This was a particular, I think, good success story, where
everybody came together and did the right -- came up with the right
answers.
New inspection programs. Here you can see the already --
you can see that there was a number of sections in the LRA that relied
on this sampling inspection approach, where we had large numbers of
components, instrument lines, mechanical places, valves, where you had a
system-wide type of aging effect. It might be general corrosion and it
was not subjected to the more focused ISI type of approach, where you're
looking at spot-checking.
So we had to develop these types of inspection sampling
programs so that we were able to, with respect to these aging effects
that were more system-wide, identify the sample points, how we were
going to inspect it, what was the acceptance criteria.
So you can see there were a number of sections in the
application that will be relying on these sampled inspections.
DR. SHACK: That part made sense. What I had a hard time
understanding was the one-time nature of the inspection and how you were
sure that the one-time inspection assured that you were okay for the
next 20 years.
MR. DOROSHUK: Well, that was part of, I think, the
discussions we had with the staff, and that is how do you know you
weren't inspecting too soon, was the incubation period such that you
should be doing it close to year 39, and I believe what we focused in on
was making sure that we had the right samples, doing it -- we were going
to be doing it later in life, and relying on the corrective action
program to appropriately expand the sample.
Our acceptance criteria will also play a very important role
and that is for most of these mechanical items, the acceptance criteria
is any observable condition. So we set the threshold so low that if we
open up a valve and look while inspecting the valve and we see pitting,
we would step back and do the corrective action program at that point.
We weren't going to try to pre-analyze what the pit size that the
inspector would look at, because then there would be too much debate.
So we think we were able to address that by the broad sample
and the very low acceptance criteria.
DR. SHACK: Okay. I'm still having trouble with the one
time. Presumably, we'll get some more discussion of that tomorrow.
MR. BOWMAN: Marvin Bowman, again, lead implementations
engineer. It's only one time if you don't find anything. If you find
anything, then that takes you already to your Appendix B corrective
action program into looking at what are the generic implications, what
are the actions to prevent reoccurrence, and do you need to do
additional inspections not only at this point in time, but with broader
scope, but do you need to do additional inspections down the road,
depending on what the trend is so far.
So they're only time if you don't find anything and we
typically credited ARDI where we -- we had difficulty concluding that
something was not plausible. It was almost not plausible, but we wanted
confirmation. For example, for the chemistry program, we've isolated
parts of the system.
DR. BONACA: This program, the whole thing involves a lot of
monitoring, and I would like to understand better the relationship
between your system engineers, which are responsible for groups of
systems, and the life cycle management engineers, which are responsible
for, I guess, some portion of those activities, of monitoring and
testing.
MR. DOROSHUK: Well, it's primarily the relationship occurs
through the teaming and the analysis, where we go through the aging
evaluation and have different points along the way where we're making
decisions. We would get with the plant responsible groups and then get
them to agree with our decisions.
So each phase in that, so to speak, process, you have that
type of check. Once we get to the conclusions, which is this is the
aging management program, we work exclusively with the system engineer
and the program owner.
So the actual engineering group that's going to implement it
is the one that we sit down with and go through the steps and get their
-- get them to develop the actual steps in these new program areas.
Then that goes into our control system and they take ownership.
I'm not sure if that --
DR. BONACA: I understand that. So for example, if you have
a specific issue that you have to monitor which has to do with a
specific nozzle of a component, the system engineers will, at that
point, once the program is established, maintain tracking of those
activities.
MR. DOROSHUK: That's right. The institutionalization of
these aging management programs we view as our project close-out.
DR. BONACA: So you close out the project that you have.
I'm trying to understand how you maintain the memory of these hundreds
of commitments.
MR. DOROSHUK: Why don't you go to the next slide? That was
a good lead-in.
We recognize that there are going to be changes, I think
there have been changes throughout the review. There have been changes
throughout our implementation and there are going to be changes
subsequent to the receipt of the applications.
Again, I think the interesting thing here is that we're -- I
don't believe we're -- we haven't discovered anything new, this is not a
new technology, but it's that technology mindset that causes us to -- I
guess we're in the behavioral change. So why don't we go into the next
slide.
We recognize that there will be hardware changes that will
need to be managed. If we have rubber-lined carbon steel piping in salt
water and we go to titanium, it may not make any sense to do ultrasonic
testing of it anymore. So we have to be able to implement these aging
programs so that when we make a change to the plant, we recognize the
change coming out.
If the intended functions change, if there is a regulation
that changes and adds a new function or we discover a new function, that
would have to be added to it; what if a component took on a new function
because I changed a system and I had not evaluated that component and
function pair as part of this application, that would have to be
managed.
In order to do that, not only do we maintain the
configuration of the programmatic aspects, but when John was finished
doing all the screening at the component level, and I can't tell you how
many thousands of components there were, I don't have that number, each
one of those components are in the site database and are protected by a
flag that we call long-lived passive.
So when the plant goes to change that long-lived passive
component out and we have put the hooks in the modification process
procedures on-site, there will be a consideration on the hardware side
with respect to the license renewal application. There will be a
consideration with respect to the function and the aging management and
then there will be a loop into the program that manages that particular
set of aging effects we're concerned about.
So it's a number of hooks you have to put in place. We
think we've built the infrastructure at this point appropriately and
that's what we're doing at this point, besides finishing up the work
with NRC, is that type of protection against changes.
We've already had some. We had a complete heat exchanger
change-out and the service water system, where we went from the
tube-type heat exchangers to plate and frame, and those heat exchangers
are in the scope of license renewal, and that invalidated the entire
aging evaluation that was part of the original application. We had to
redo the analysis and make that part of the update.
So we think we've had some run time with this change
management, as well.
Our investigations are complete. As I said, I think the
implementation is well underway. We have found that extended plant
service can be achieved safely. We believe, as well as looking at the
cost of implementing these things, that we can do it and remain
competitive. The impacts of these plant programs to monitor aging are
well within the benefits of the cost of implementing license renewal.
Next slide. The status of the review, Dave hit some of
these high points. I want to point out that for a new process, the
rules, although could be improved, they do work. Part 51 and Part 54,
we think that the NRC is doing an excellent job working through a new
process. We find them to be very thorough. We find the region
inspection teams to be very aggressive, but very open to the new
process, and BG&E management is pleased with the way the review is
going.
That's not to say that everything is rosy. We have hit hard
issues and we do sit around the table in public meetings and exchange
letters, making some very tough decisions on what's the right thing to
do. I think that from BGE's perspective, that's the goal that we see
the staff trying to achieve, and that is what is the right thing to do,
and that ties into the 54.29 finding, which is what is reasonable
assurance.
So for a new process, I think everyone is doing the right
thing.
Next slide. Overall schedule, starting to get to the final
milestones here. Today and tomorrow is your meeting. We have the
comment period on the draft supplemental environmental impact statement
closes the comment period there July 19th.
We have an action to complete the responses to the open
items and the confirmatory items and the accuracy review of the safety
evaluation report. That was issued on March 21st and we're on schedule
to hit that milestone. Again, we have a management meeting
month-to-month, which is not shown here. You can see there were a
couple here, January, February. We did not have one in April, but we'll
have one on May 12th, and those have been very good for facilitating the
review.
Next slide. Yes, sir?
DR. SHACK: Can you be specific on what parts of the rule
you have problems with?
MR. DOROSHUK: Well, I think one of the bigger things we
struggled with was how do you -- you have 430 programs that are
existing, how -- we don't want -- I don't think the staff wants to
review every single one, every single time, especially if they're mirror
images at every facility.
So how can these reviews here and at Oconee and through the
work that's being done through NEI, how we can make that process go
smoother, if it's a "me, too, I have an EQ program." Now, we worked
through EQ. This was a classic example of an existing program. It's
embedded in a rule. It's got, what, almost 15 years of run time. We've
all got SERs on it. It's got a generic safety issue on it. So we've
got that flavor. So this was a really good example for everyone to work
through.
But when we did get through with the reviews and to the SER,
they found that the program was adequate for BGE, for the license
renewal period.
There is a significant amount of generic lessons learned
that everyone should be able to extract from that, so that Turkey Point,
et cetera, et cetera, doesn't have to repeat and that is part of what
you didn't see on the priority one -- on the priority one issues, that
wasn't a priority one issue, but it is an issue at very high levels of
attention that everybody is working to make improvements.
MR. GRIMES: EQ is on the priority one list and right now
the whole issue about how do we get appropriate credit for existing
programs is one that we share, as well, because the NRC staff realizes
that we need to be able to apply our time more effectively and we don't
want to spend time covering the same ground.
And through these first two application reviews, with the
differences in the way that the applications were constructed and, at
the same time, the question about what constitutes an appropriate
measure for technically justifying a demonstrated effectiveness to
manage aging, and, at the same time, only make that finding at a
reasonable assurance level.
That's the challenge before us. We view that challenge as
being one of the implementation details, not a fundamental problem with
the rule, although it could go either way. We could go back and say,
well, let's fine tune the rule and clarify what its purpose is, but at
the present time, we're preparing to go to the Commission the end of May
with a paper that explains the controversy surrounding credit for
existing programs and what would constitute the basis for further
streamlining the review process.
MR. DOROSHUK: I think this will be important when you look
at the next 101 plants that are in line and if they all come in in the
next five to six years, that we probably need to make sure we're
learning, we need to make sure we're improving the process, both from
the industry side and through the NRC review, and if we can make it more
streamlined and still meet your public charter to ensuring safety, then
we ought to do that.
DR. BONACA: You are going to get an SER probably -- I don't
know. You have a question here regarding schedule. It says that
sometime after this year, hopefully you'll get a Commission decision on
application, and there are still about 15 years to go before this plant
reach its 40 year life, right?
MR. DOROSHUK: Yes, sir.
DR. BONACA: So I guess between now and then, you'll have a
lot of changes in this life cycle management, just because your ability
to see problems is going to be improving, particularly if it's been like
this in the past, and also new phenomenon may be new things.
So I guess what I'm trying to understand, this is really
pretty unique as a program, it's a leading problem, where changes are
going to be -- sure, there are going to be other changes coming in and,
again, I'm trying to understand how this configuration management of
this program is going to really support, in the long-haul, how you're
going to incorporate all these new findings or new activities that you
have to perform as you go through.
MR. DOROSHUK: Right now we have about 20 people doing that,
focused on making sure all of the material we have here can get somehow
melded in with the rest of the culture of the site. I can't -- if I
could tell you how it was going to turn out ten years from now, I'd love
to.
DR. BONACA: No, I'm not --
MR. DOROSHUK: But we are learning and it's a very
challenging experience. But the whole plant has recognized that we're
not looking at 2005, we are looking at 2036, and they've got a vision
themselves. So they have adopted that vision and we can see the
attention and that behavior changing.
DR. BONACA: I guess I was more thinking about how do you
link with the rest of the industry, because these issues are
industry-wide.
MR. DOROSHUK: We are a member --
DR. BONACA: Also, EPRI.
MR. DOROSHUK: Right. We are a member of the Life Cycle
Management Subcommittee. EPRI has a full committee, which is made up of
almost 100 percent of the utilities, John, is that right?
MR. RYCYNA: Pretty much.
MR. DOROSHUK: And we have -- this committee has been in
place since 1990, '91. We have -- BG&E has published all of its work
through this committee and it's available to the industry. We've put it
on CD-ROM. We have the memory set coming out pretty soon which will
have that entire pyramid on it that we showed earlier. We hold
workshops.
So we're doing a very extensive job through EPRI and through
the Nuclear Energy Institute to make sure that these things are
transferred.
DR. BONACA: So you're going to get this new experience and
feed it from the industry into your programs and your inspections.
MR. DOROSHUK: Right.
DR. BONACA: How does the NRC maintain its confidence that
the SER that was provided in 1999 is still good in the year 2009, that
kind of issue.
MR. GRIMES: That gets back to the fundamental premise or
principle for license renewal, which is the current licensing basis and
its underlying processes carry over to the period of extended operation.
Upon the conclusion of this review, we have now established a new
licensing basis for 60 years of plant operation, but under-girding that
is the overall regulatory process that is now more sensitive to
operational experience and events that have aging implications.
Up until now, we have looked at things from the standpoint
of managing the facility and now this experience has taught us the
importance of not only the hardware, but the software associated with
these programs that basically maintain the integrity of the overall
plant.
So we rely on that process continuing in the future.
Fifteen or 20 years from now, if a new aging effect becomes evident, we
would expect that the process will protect us to identify that it's a
concern that needs to be addressed and then to provide appropriate means
for establishing the regulatory requirements that should be satisfied.
DR. BONACA: You're not going to revisit this issue the day
before you step into the 41st year.
MR. GRIMES: No, sir. As a matter of fact, the concept of
continuity from year 39 through the period of extended operation is very
important to the principle and the process.
DR. MILLER: So in a way, when the SER is signed off, then
the license is for the next 20-plus X years.
MR. GRIMES: That's correct.
DR. MILLER: So if it's signed off in the year 2006 and
since you have a 30-year life extension, is that the way it is? Of
course, then you have a living document to keep as a kind of check
point.
MR. GRIMES: It ends up being a 60-year life.
DR. MILLER: A total of 60 years, but it's 30 more years.
MR. GRIMES: We give them a new license, so there is no
confusion. It will have a brand new expiration date on it.
DR. MILLER: Which will be 2036.
MR. DOROSHUK: '34 and '36.
DR. MILLER: I had a couple of questions on the process. I
want to go back to those.
MR. DOROSHUK: Okay.
DR. MILLER: Go back to the slide you had on diamonds.
MR. DOROSHUK: The process.
DR. MILLER: When you get all done with, say, one of those
last diamonds and you have yes's, say.
MR. DOROSHUK: And you go down here.
DR. MILLER: Right. Well, what I really want to ask you is
when you get -- each time you go through a diamond, you exclude things.
MR. DOROSHUK: Right.
DR. MILLER: When you get all done --
MR. DOROSHUK: Or include things.
DR. MILLER: Or include things, true. When you're all done
with the pipeline, you have X number of items or systems and so forth.
MR. DOROSHUK: Right.
DR. MILLER: And then the NRC went through and, as you
pointed out, did a very thorough evaluation of this process. My
question is, what percent changes did you make in what you did once the
NRC went through and did their thorough evaluation? Any idea of that
number?
MR. DOROSHUK: Let me give you an example. On the regional
inspection for scoping, when they came down in February --
DR. MILLER: That's the high level.
MR. DOROSHUK: No. This was all the way down.
DR. MILLER: That's all the way down.
MR. DOROSHUK: This is a full-blown scoping inspection, with
a team of about ten inspectors from region and headquarters, and, in
fact, Region II participated as well. They selected certain systems and
structures, ten to 15 that we said were in scope, but then they stepped
back and said, well, in order to fully verify how well you exclude
things, we're going to pick five systems and structures that were not in
the scope of your license renewal, but were high risk according to the
IPE, for example, and we're going to go check and see how well you did
making your decisions and they took those systems independently through
the process themselves.
They used our procedures, our databases, and they found in
every case, except two areas, two specific things that they could not
conclude that they agreed with us, and that was, one was a policy issue.
Was a non-safety-related building around a non-safety-related diesel,
should that be included in scope, and we believed the rule says you
don't, in cascade, in non-safety-related areas at all, and there was a
question on whether or not that was correct.
So that's being reviewed by headquarters as an item that I
think Dave talked about. So BGE says, okay, well, this is an
interpretation of the rule; if you interpret the rule to be that way, I
guess we'll have to put that in. It's not a point of disagreement.
It's a question of is the rule being implemented. So that's very
thorough.
The second item, which was probably the one that really made
me step back and say how thorough this was, was in the fire protection
part of the plant, and it's a broad plan and there's a couple of fire
pumps that are out in the building called a fire pump house.
In between these two pumps is a concrete berm, a curb, that
basically is there so that if the oil from one -- the oil-driven pump
spills and catches fire, it won't drip onto the other pump.
So the question was, was this berm important, and if you
look at fire protection, the fire protection licensing basis at our
plant and other plants, the commitments are all somewhat different,
depending upon how you implemented it.
This particular credit for this berm was in the gray area;
was it truly part of the fire protection licensing basis or was it not.
We couldn't say to ourselves it's not entirely and so we agreed with the
staff and we included that concrete berm. We pulled it out of here and
put it up here.
So for the staff to take those five systems that were high
risk, go through component by component and agree with that level of
investigation, with all except for a concrete berm, gave us confidence
that the inspection team really pulsed the system in this box that
you're questioning.
So it's a long story, but I thought it was a good story to
tell.
DR. MILLER: So you came close to answering the question. I
was looking for kind of a percent. Each one of those steps requires a
lot of judgment. Of course, your judgment as a team might be slightly
different than the NRC's. I'm really questioning what percent number
was the judgment of NRC maybe slightly different or different than
yours. Say, two out of so many --
MR. DOROSHUK: Thousands.
DR. MILLER: Thousands.
MR. DOROSHUK: Thousands of components.
DR. MILLER: We're talking about maybe .1 or .2 percent.
MR. DOROSHUK: Less.
DR. MILLER: Or less. Where the judgment or the collective
judgment of the NRC and the collective judgment of your engineering
staff may have had a gray level disagreement.
MR. DOROSHUK: They probably inspected upwards of, I don't
know, 15 to 20,000 components, if you took a look at all those systems
combined. The license renewal scoping is fairly on-off type of a
decision; it's either credited or it's not credited, and we do not shade
things from a risk perspective. We either credit it in the licensing
basis or we don't.
So in this particular case, it was -- we went, in fact, all
the way through the audit trail of documentation on the docket, NRC
correspondence and we drew the conclusion there wasn't any, but they
didn't agree with that, so we put it in.
MR. GRIMES: I would share that view, although we have a
different perspective. I thought it was six inspectors for four days.
So we don't really have an appreciation for the impact on the utility.
DR. MILLER: That may be perspective.
MR. GRIMES: And we looked at hundreds of things, while they
looked at tens of thousands of things. Out of the hundreds of things,
we ended up with a handful of findings, two of which rose to a level of
significance and we agreed, they took one and we took one. So two out
of hundreds, in our view, constitutes a basis for saying there's
reasonable assurance the process has worked.
We will probably come to similar conclusions when we wash
out the rest of the safety evaluation. We'll find that while there are
still some controversies, as is reflected in the open items and the
generic renewal issues, on implementation details, that on the whole,
we're satisfied that the level of these details is so minute that the
broader finding is that we've got the same conceptual idea about what is
passive and long-lived and what requires an aging management review and
what is an appropriate aging management program.
So that's essentially where we think we're headed based on
what we've presented in this safety evaluation report and our initial
inspection findings.
DR. MILLER: I have another question on the previous, the
big pyramid, it was about two overheads before that.
MR. DOROSHUK: Okay.
DR. MILLER: If I understood what you were saying to me,
that you started at the high system level and went through all these
different procedures and plans and so forth, and you documented
everything, tracked everything down to the real very basics, you felt
the bottom of the generic basics were a set of codes and textbooks and
EPRI reports and standards.
Now, if I go and look at your LRA, which I have in my hand,
and I look at all the references for different chapters, I should find
codes and standards, EPRI reports and so forth.
MR. DOROSHUK: Yes.
DR. MILLER: Now, I did my own spot check in about ten
minutes and I looked at, say, environmental qualification. Now, in the
area of I&C, environmental qualification, the basic standard is
IEEE-323. Yet I didn't find it in your reference.
MR. DOROSHUK: You'll find it in the procedure that's
referenced.
DR. MILLER: So someplace in there, buried within what --
there's a lot of reference to the CCNPP, which is Calvert Cliffs. So
it's buried within those procedures.
MR. DOROSHUK: In these plant procedures, you'll find ties
to --
DR. MILLER: So that's where I'll find them.
MR. DOROSHUK: You can find them there.
DR. MILLER: Because most of the references were CCNPP references and
not basic codes and standards.
MR. DOROSHUK: Right. In fact, when we reference an aging
management review report, if you go in there, you can get down to the
individual component level, the individual aging and then the individual
textbook that we used to make a particular call on an aging effect,
inside this document here, as aging management review report.
DR. MILLER: Right.
MR. DOROSHUK: So that will be separate from a plant
procedure that you'll see referenced, that will also have ties. So
you're right. The string that you'd pull, you would have to come to the
site and pull the string all the way through.
DR. MILLER: So if I called up the site and said I need
CCNPP bla-bla number document, where you reference environmental
qualifications, I'll find IEEE-323.
MR. DOROSHUK: I would say yes.
DR. MILLER: So the audit trail, in a sense, in this
document, is one level above, what I would define as one level above
what you put in that pyramid.
MR. DOROSHUK: Well, there are EPRI reports, there are --
DR. MILLER: There are some textbooks.
MR. DOROSHUK: There are some. You've got a splattering.
But for efficiency, the conclusion, where the conclusion was drawn here,
if it was drawn there, then the reference was put there. Then you'll go
see that conclusion and that reference will put you there and may drive
you there and then it's sort of a cascade type thing, that each decision
should have a supporting reference.
DR. MILLER: There are a number of EPRI documents and
there's a smattering of textbooks.
MR. DOROSHUK: There's an enormous amount of information
on-site. Just at this top area, integrated plant assessment, probably
each system chapter has a series of five to ten -- I don't know -- maybe
not -- two to three manuals itself that's license renewal unique.
DR. MILLER: Maybe I can ask this of the NRC. Did the NRC
look at this pyramid as part of their audit process, in addition to the
set of diamonds?
MR. GRIMES: Yes. As a matter of fact, we stumbled into the
procedures and tried to pull the string to get down to the -- as Barth
mentioned before, we did some reviews that constituted vertical slices
all the way down and, of course, we went in and thrashed around in
environmental qualification and made a big mess and stink and tore it
apart and put it back together again.
So part of our review process is trying to pick smart
samples to go look for what some of the underlying documentation is.
In the review itself, we did that through questions and
dialogue and also as part of the inspection.
MR. DOROSHUK: And in the inspection, they not only went up
and down this pyramid, they went out and they said, okay, now, take me
to that particular component in the plant or let me climb into this
building and let me look at the actual physical structure as exists
today, and that was both in the containment, it was not just take me on
a general tour.
We were in confined spaces, we were in radiation areas, we
took advantage of the fact that we were in an outage and took a good
physical look to supplement the inspection team's evaluation in the
offices.
DR. MILLER: I want to go back to the diamonds. I'm going
to ask a question that maybe my colleague, George Apostolakis, who is
not here, might ask.
In going through all the decision-making, those diamonds,
would it be, had been, or did you use some risk insights in making those
decisions?
MR. DOROSHUK: No, sir.
DR. MILLER: Would it have been of value if you had used
risk insights? Would that have made your decision process more
efficient, more effective, maybe you would have excluded more or
included more? Maybe the NRC can help me out on that question.
MR. DOROSHUK: The way the rule is constructed, it doesn't
allow you take advantage of that type of approach. We used more of a --
in other words, the rule says it's in or out. There is no risk-informed
anything. So you don't get a chance.
It's part of your licensing basis. The maintenance rule,
which tends to sit up on top of the passive parts of the plant, takes
into the -- takes that into account and builds -- includes the rest of
the plant in that monitoring envelope, if you will.
So where the PRA comes in, which is primarily in the active
functions and the execution of sequences, the license renewal rule
doesn't go after it. You don't model a piece of concrete in PRA. So
the compliment of the maintenance rule is really those two regulations
fit very nicely with each other.
Would it have helped us? It would have -- if you go to the
maintenance rule, you'll see -- not only will you see the license
renewal scope, but you'll see all of the active equipment of the plant
there and so that is an ongoing monitoring system, really puts the icing
on the cake, if you'll allow me to use that.
DR. MILLER: Well, I wasn't necessarily implying only the
PRA. I was implying maybe a little higher level risk insight.
MR. DOROSHUK: Well, we do. In the program selection, when
we worked with the teams, we used more -- we used a qualitative type of
approach and that is, how aggressive is the aging, how much is going to
degrade the function.
And for aging that's on the periphery and it's -- we can't
prove that it's not happening, it's not worth us expending the
resources, we used that qualitative risk to say, well, maybe we need
just a one-time inspection somewhere near the end of 40 to confirm that
it's not degrading the function of the component.
So to a certain extent, the risk-informed operating
experience and plant experience is used in the selection of the plant
activity, but it's not a calculated measure.
DR. MILLER: It's just part of your qualitative judgment.
MR. DOROSHUK: Yes, sir.
MR. GRIMES: I'll offer, since Dr. Apostolakis asked the
question before, that --
DR. MILLER: He'll ask it next week.
MR. GRIMES: Well, I'm going to head him off, I hope. Right
now, we're working on implementation details simply to extrapolate and
extend this current licensing fabric into a period of extended operation
for 20 years. And it's tough enough to try and keep sanity using
deterministic techniques to go through a screening process.
But I envision a time in the future when both license
renewal, scoping and screening has matured, and graded QA, and
risk-informed ISI have matured, that they eventually can blend together.
But in the meantime, this is not a risk-informed regulation
and I think it's premature to expect license renewal to be
risk-informed, until some of these other initiatives have matured.
DR. MILLER: So in other words, if we were doing license
renewal on a plant, say, ten years from now, we would presume that there
would be, to use your words, more blending than what we're doing; that
using a risk-informed approach in places might be of value.
MR. GRIMES: That's correct.
DR. MILLER: Certainly I would think many are still going to
be deterministic.
MR. MATTHEWS: Ten years from now, the licensing basis
itself may be more risk-informed. Therefore, the precepts associated
with its continuation into the renewed period would reflect the fact
that it was a more risk-informed licensing basis that we were focusing
our concern on with regard to continuity in maintenance.
So, yes, I think what you said is right.
DR. MILLER: When you use the word maybe, there's a lot of
people whose dead bodies will be -- if it is, will be, not maybe.
MR. MATTHEWS: That's true, except in the instance that the
Commission does persist in making a more risk-informed Part 50 a
voluntary program.
MR. DOROSHUK: Next slide. I wish John Fair hadn't left so
quickly. I wanted him to see this first bullet, based on our
discussions yesterday.
We have not discovered anything, any aging that's unique to
license renewal at Calvert Cliffs.
DR. MILLER: What does that mean?
MR. DOROSHUK: That means we haven't found --
DR. MILLER: The aging things that you had discovered before
you started this process.
MR. DOROSHUK: All the aging that we identified that needed
to be managed was already occurring and it did not uniquely change its
state or rate or effect at year 40.
DR. BONACA: That's because you haven't got to 40 years of
age.
MR. DOROSHUK: It's not to say that there might be emerging
issues, but in 1999, our conclusions are such. The current inspection
activity on-site, plus some additions, we believe, will more than
reasonably assure that aging managed regardless of age of the plant
within reasonable cost estimates.
And we think that from Calvert Cliffs' approach, which is a
life cycle management approach, by applying these resources over the
long-term perspective, we have been able to plan for long-term safety
and reliability.
We have done more than what the rule requires. Our program
was laid out to manage the life cycle of the plant. We believe that
many utilities have strategic engineering assets and resources in place
that are doing similar types of evaluations. They may not be in an
organization called the life cycle management project.
So I don't want to leave you with the impression that this
is the standard and this is what it should look like. We think that
license renewal was a very healthy byproduct of the life cycle approach.
License renewal, in and of itself, is a little bit different than what
we went through. We went through a complete asset evaluation. We
tailored it around Part 54, though.
Next slide. I guess in parting thoughts, is plant aging a
certain -- these types of resources are hard to put in place and
maintain. For a utility to put 25 people in an organization for over
ten years, that's over $35 million is what we've spent on all
activities. The license renewal portion of that activity represents
about $15 million at this point, but we're still getting bills from the
NRC staff for their review. So we think that the appropriate -- if you
were just looking at the types of resources it would take to do an
application, at this time, given the current state of lessons learned,
is around ten to $15 million in resources over a three to four-year
period. Just so you have a mark on the wall on what at least our
opinion is.
The cost of not doing anything, however, is steep and I
think that we have seen some of the unfortunate results, whether it be
from an aging or a strategic planning -- plants, some plants have not
made 40 years, not necessarily because they didn't have a life cycle
management group.
DR. FONTANA: That's where I was going to ask a question
there. What are some of the costs of no action and how -- you probably
can't answer the second part of the question -- what was it that drove
some other utilities to go to an opposite conclusion and shut their
plants down rather than extend the lifetime, as compared to the decision
that you all made?
MR. DOROSHUK: Some of the early plants that shut down were
voted to be shut down by a referendum and the utilities were reimbursed
through the rates, and so there were incentives and there were
agreements made.
So I can't -- but I can't comment on whether a
regulatory-driven recovery program or some of the other, you know, news
stories we hear on some of the plants that recently have shut down.
I can tell you, with respect to Calvert Cliffs, that we
certainly look very hard at the early shutdown scenario and we studied
it. In fact, we were directed to take off our license renewal hats and
stop thinking about the long run. Management said don't be in love with
your project, go look at the right thing to do, and if the right thing
to do is to shut the plant down, then let's shut the plant down in the
most responsible manner.
So we didn't go through these last ten years without that
type of consideration. We looked very hard at it.
DR. BONACA: With this decision in place, even if you get
the license renewal, you still can shut the plant down anytime you want.
MR. DOROSHUK: That's exactly right, and I said in the
beginning, it is an option. If we can't continue to meet the safety
goals and compete, then license renewal and steam generator replacement
and all of this was -- it still didn't get us there.
DR. MILLER: This is a question that may be more difficult
to answer. You've spent 35 million over the last ten years. If there
had been a strategic life cycle management program put in place at the
time you designed the plant, like pay me now or pay me a lot later,
would this cost, integrated over 60 years, have been somewhat less?
MR. DOROSHUK: I guess it would be. I mean, we started
virtually in 1985 when the plant was ten years old. So we actually put
the formal organization. We've had some -- we work costs. We had rule
change. So we had to throw out all that active work we did and so we
had some work that we would not like to see another utility repeat.
But certainly, with the work that NEI is doing with EPRI and
the technology transfer, it doesn't do Calvert Cliffs any good to be the
only plant that renews its license, because the industry and the NRC
will all hang up the signs and go home.
We need to move ahead as -- even in a deregulated market,
continuing to share what we think are unique types of resources and
insights. So we hope it gets cheaper. It should.
Thank you, sir.
DR. FONTANA: You're setting precedence and the question
that comes to mind is that you set this precedent, which is totally
based on today's philosophy. In your mind, do you think that will
inhibit the development of maybe more efficient approaches which may be
more risk-based?
MR. DOROSHUK: Not at all. No. In fact, we've identified a
number of lessons learned already; not from the perspective of changing
the way you scope license renewal, but we're continuing to bring back
what people shouldn't do to the industry organizations to transfer that.
You won't be able to tell until you actually look at plant
number eight, I pull that -- that's just arbitrary -- one through five,
the standardization isn't there, the rule improvements or the process
improvements are still in the consideration stage.
DR. SEALE: Well, you guys have bitten a few bullets in the
past. The environmental protection --
MR. DOROSHUK: Starting from day one, right?
DR. SEALE: -- was a hard way to get your -- to tie your
running shoes on and it's interesting.
MR. GRIMES: I do think that it's important to at least
point, we're cutting them some slack on the fees. We split our time.
DR. MILLER: He didn't mention that. It appears like the
process you have put in place is certainly generic and not unique to,
say, a CE-type plant. What fraction do you think is unique to the
CE-type plant or is it mostly generic, that Westinghouse or GE or
whatever could pick up and --
MR. DOROSHUK: It's not until you get way into the internals
of the plant, reactor internals is a good example. CE's got their own
issues, Westinghouse has got some of their own issues.
We solved one yesterday for the CE fleet, in the fatigue
area, with NRR, based on the Calvert Cliffs work, at least we think we
did. So there are -- it's not until you really get into the analytical
sides and the vendor-unique construction that you find the aging
effects.
MR. GRIMES: I'd like to add that to the extent that this at
least heads in the direction of more of a performance-based review, I
don't think that you're going to see as much of a variation from plant
to plant as you're going to see from utility to utility and the way that
they implement their chemistry programs or their maintenance programs.
At this point, I'm encouraging utilities to look across
their common aging management programs as ways to achieve efficiencies,
as opposed to -- obviously, the boiling water reactors all have a common
theme running with vessel internals, but in terms of IGSCC, you find it
more as program-driven than it is plant design, at least in terms of the
way that we've organized the review, looking at managing aging effects.
That's why I envision a blend of the system approach that
Calvert Cliffs used to present their application and the program
approach and tomorrow when the staff talks about how it reviewed the
thing, you're going to see that we've go teams of people that cover
that.
DR. MILLER: So having, in a sense, Calvert Cliffs, then
followed by Oconee, we change to a different approach. It's going to be
an exercise in kind of the spectrum of approaches.
MR. GRIMES: That is correct.
DR. BONACA: I have a question. This kind of approach
clearly presumes that aging can be and will be managed and I think we
see good programs and et cetera.
I have a question for the NRC. Some of the aging effects
are not going to be managed. For example, the vessel is a good example.
Nobody -- I don't think you'll replace the vessel whenever you get to
the limit. So you simply reduce the margin you have on the vessel to a
still acceptable level, but there is some going into margins as you --
whoever this margin belonged to, as you go into extended life.
Is the NRC considering any assessment of a large number of
plants moving into life extension? And that's really where I would see
some risk information being useful to understand implications of a large
fleet of plants moving into extended life.
MR. GRIMES: Yes. We are planning on -- from the standpoint
of what could the future workload be, we're planning from the standpoint
of most of the plants will want to renew their licenses and it's a
matter of whether or not they'll all come in in a very narrow time or
not.
But I would contend that we're approaching even vessel life as an aging
management issue because we're looking at it from the standpoint of how
does one monitor the fluents conditions, how does one manage the
program.
Last week, I heard a conceptual proposal on how the vessel
could be replaced in plants and that's being considered now, at least in
some foreign countries.
So we're looking at this from a process perspective and if a
plant wants to run its vessel with increasing reductions in power in
order to stay within their PTS limits, that's certainly a management
approach, but we see it as a viable -- from the standpoint of
concentrating on managing aging effects and making sure that the
programs are there, then it's a matter of improving the efficiencies and
shifting as much emphasis onto performance-based regulatory requirements
as is achievable.
MR. DOROSHUK: I'd like to add something to that, Chris.
One thing that I think you said was very important, when you talked
about pressurized thermal shock. You didn't say that the rule was going
to be changed to allow utilities to operate beyond what was already
proved. The standards of regulation and safety regulation have not been
changed.
The programs and the findings you see here have not eaten
into any of the safety margins that have been established. All the
acceptance criteria is geared at taking corrective action before any
safety margin is exceeded. So there is no decrease.
DR. BONACA: Yes. But the vessel is going to be 60 years
old rather than 20 years old. I'm trying to say there is a regulatory
margin and there is an actual margin in the equipment, and I'm not
trying to -- I'm only -- I was asking more a question of use of
risk-based insights in looking at issues of that nature from a
regulatory standpoint to see where we simply direct more focus on those
programs than Mr. Grimes was talking about.
I recognize that you're not proposing to exceed the criteria
that were set by regulation on the margin. I'm only saying that you
have an older vessel, so you have less margin just technically in the
vessel.
DR. MILLER: In the area of vessels, though, in a sense,
aging management started a number of years ago, when they started
looking at reducing flux and so forth, and, in a sense, whenever the PTS
rule and issue came up, we started managing some of the vessels' ages 15
or so years ago.
MR. GRIMES: I'd also like to reiterate a point, and I think
a very important point that Dr. Fontana raised before, and that was that
we're trying to get out of our silo thinking and our compartmental
approach to the regulatory requirements and we're looking at
risk-informing the regulations.
Well, it's starting with risk-informing ISI and I don't see
that there is any boundary by which that can't naturally extend all the
way out into managing vessel risk. It's a matter of time and experience
and more learning.
So to that extent, I see license renewal and aging
management and the principal of carrying over the current licensing
basis and managing it in the future will become more risk-informed and
will continue to be a learning process.
DR. FONTANA: Any additional comments from the committee and
the staff? In particular, is there anything that we want to hear
tomorrow that we should know about today? You're through with your
presentation?
MR. DOROSHUK: Yes, sir. Thank you.
DR. FONTANA: I want to thank you very much. You've been
standing there for a couple hours. It turns out you make a good focus
that we can talk to.
MR. DOROSHUK: I stayed right here, in between. Thank you.
DR. FONTANA: Any comments from the audience?
[No response.]
DR. FONTANA: The committee? Nothing in addition to what
we've already discussed?
[No response.]
DR. FONTANA: Well, thank you very much then. We'll meet
tomorrow. Noel suggested, again, are there any specific items that the
committee wants to have discussed tomorrow, over and above what's
already on the agenda? Are there any specific items that the committee
would like to hear about tomorrow that the staff should know about
today, particularly in addition to what's on the agenda?
[No response.]
DR. FONTANA: Hearing none, it looks pretty good to me.
Well, thank you very much. We'll meet tomorrow at 8:30.
[Whereupon, at 4:06 p.m., the meeting was recessed, to
reconvene at 8:30 a.m., Thursday, April 29, 1999.]
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