United States Nuclear Regulatory Commission - Protecting People and the Environment

470TH Advisory Committee on Reactor Safeguards (ACRS) - March 3, 2000

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                       UNITED STATES OF AMERICA
                     NUCLEAR REGULATORY COMMISSION
               ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
                                  ***
         470TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)

                              U.S. Nuclear Regulatory Commission
                              11545 Rockville Pike
                                                       Room T-2B3
                              White Flint Building 2
                              Rockville, Maryland
                              Friday, March 3, 2000
               The committee met, pursuant to notice, at 8:30
     a.m.
     MEMBERS PRESENT:
               DANA A. POWERS, ACRS Chairman
               GEORGE APOSTOLAKIS, ACRS Vice-Chairman
               THOMAS S. KRESS, ACRS Member
               MARIO V. BONACA, ACRS Member
               JOHN J. BARTON, ACRS Member
               ROBERT E. UHRIG, ACRS Member
               WILLIAM J. SHACK, ACRS Member
               JOHN D. SIEBER, ACRS Member
               ROBERT L. SEALE, ACRS Member
               GRAHAM B. WALLIS, ACRS Member
                         P R O C E E D I N G S
                                                      [8:30 a.m.]
               CHAIRMAN POWERS:  The meeting will now come to
     order.
               The is the third day of the 470th meeting of the
     Advisory Committee on Reactor Safeguards.
               During today's meeting the committee will consider
     the following: phenomenon identification and ranking table
     for the high burnup fuel; proposed resolution of Generic
     Safety Issue B-17, criteria for safety-related operator
     actions; report of the Planning and Procedures Subcommittee;
     future ACRS activities; reconciliation of ACRS comments and
     recommendations; proposed ACRS reports.
               A portion of today's meeting may be closed to
     discuss organizational and personnel matters that relate
     solely to the internal personnel rules and practices of this
     advisory committee and matters the release of which would
     constitute a clearly unwarranted invasion of personal
     privacy.
               The meeting is being conducted in accordance with
     the provisions of the Federal Advisory Committee Act.  Mr.
     Sam Duraiswamy is the Designated Federal Official for the
     initial portion of the meeting.
               We have received no written statement or requests
     for time to make oral statements from members of the public
     regarding today's session.
               A transcript of portions of the meeting is being
     kept and it is requested that speakers use one of the
     microphones, identify themselves, and speak with sufficient
     clarity and volume so that you can be readily heard.
               Do any members have opening statements that they
     want to make for this session?
               I have been informed that Karen Faircloth will be
     leaving us for a promotion in the Chief Financial Officers'
     Office.  Karen, you only got here.
               [Laughter.]
               CHAIRMAN POWERS:  What, is it something we said?
               [Laughter.]
               CHAIRMAN POWERS:  Well, congratulations, Karen.
               MS. FAIRCLOTH:  Thank you very much.
               DR. SEALE:  It's nice to know someone who works
     where they keep all the money.
               CHAIRMAN POWERS:  Well, in that case we will move
     to our first presentation.  I will remind members that the
     issues of high burnup fuel, the last time we heard about
     them I think was about a year ago, wasn't it, Ralph?
               This is this very interesting change in phenomena
     that occurs as fuel gets up to very high burnup that the
     trend in the industry is try to use fuel to ever higher
     burnups.
               The Staff has established a limit on how high a
     burnup they are willing to go pending additional
     information.  They did this based on an engineering
     judgment, an examination of relevant phenomena, the results
     of tests that have been conducted in France and Japan, then
     they instituted a confirmatory research program with the
     Office of Research.
               In the course of discussing that research program
     it became obvious to us that the industry has every
     intention of trying to push to ever higher burnups, perhaps
     going beyond the current limit of 62 gigawatt days per ton
     to as high as 75 gigawatt days per ton, and the questions
     come up what kind of information do we have to present to
     show that using fuel to those very high levels of burnup are
     in fact safe, that it would be safe to do so.
               At the same time, the Office of Research is
     interested in what kinds of investigations it needs to carry
     out as part of its confirmatory work and Dr. Meyer has been
     busy designing a research program and a process for helping
     him direct that research work and so, Ralph, I will turn the
     floor over to you at this point.
               MR. MEYER:  Okay.
               CHAIRMAN POWERS:  I will interject that this is a
     presentation for information to the committee that we are
     not anticipating writing anything on this particular
     presentation, but pay close attention because this
     presentation constitutes background for subsequent
     presentations on this subject where there may well be a need
     to write.
               MR. MEYER:  This morning I'll just briefly go over
     what the PIRT is and why we are doing it, because we had a
     lengthy discussion on this a year ago, and then spend a
     little time talking about the organization and the status of
     the PIRT because there have been some changes along the way
     and we are nearly finished with the first PIRT that we are
     going to do, the one on the rod ejection accident for the
     PWR, so I will give you some results from that and then
     comment on our application of the PIRT results.
               The application is going to be the key to solving
     the problems, and the application itself is not part of the
     PIRT process and I think this will unfold as we go through
     here.
               Just to refresh your memory, you will recall that
     the PIRT that we are doing is a structured way to get some
     technical information from a bunch of experts and PIRTs by
     their nature address a specific scenario and they identify
     phenomena that occur during that scenario and then you rank
     the importance of those phenomena with regard to some
     criteria that you define at the outset of all this.
               The scenarios that we have picked are listed
     herein the first bullet.  The PWR rod ejection accident
     is --
               DR. WALLIS:  I'm sorry, I can't see because you
     are standing in front of the screen.
               MR. MEYER:  I am in the way?  Okay.  Let me --
               CHAIRMAN POWERS:  I think if you just moved back
     to the screen --
               DR. WALLIS:  Or to the side or something.
               MR. MEYER:  If I move back to the screen then I
     can't see my notes.
               [Laughter.]
               DR. WALLIS:  Then you can speak the truth.
               MR. MEYER:  But I want to say what is in my notes.
               [Laughter.]
               MR. MEYER:  Okay.  This one is a rod ejection
     accident in TMI-1.  The second one is a BWR event which
     involves ATWS related power oscillations in the Lasalle
     plant.  The loss of coolant accident PIRT will be a
     combination of the PWR and the BWR scenarios in the same
     PIRT meetings and we haven't yet defined the specific PWR
     and BWR scenario that we will be following, but that will be
     done.
               At a later time, not scheduled in the current
     round of PIRTs, we will come back and address the source
     term.
               Now what I want you to notice here is these three
     scenarios that we have picked are scenarios that have
     regulatory criteria associated with them, fuel damage limits
     in each case.  The fuel damage limits are intended to ensure
     that core coolability is maintained and that damaging
     pressure pulses aren't generated during the event, so these
     are the events for which we have speed limits, so to speak,
     that keep us from getting into severe accident trouble, and
     so these are the design basis accidents which we are
     focusing on in the PIRT.
               DR. KRESS:  Did you have a description of the
     scenario from previous work somewhere, you know, like the
     progression of the accident in time --
               MR. MEYER:  Yes.
               DR. KRESS:  Did you take that out of what, some
     previous work?
               MR. MEYER:  It's done largely from previous work
     and for example the first one that is the most complete,
     during the past two years we have been doing a lot of plant
     transient calculations on the TMI-1 rod ejection accident.
               We had a deck from an international standard
     problem and jointly with the French IPSN and the Russian
     Kurchatov Institute we have gone through a very extensive
     sort of round-robin calculation exercise, and we know a lot
     about that particular transient.
               DR. KRESS:  That makes me feel a lot better.  I
     was afraid you got it out of the FSAR.
               MR. MEYER:  No, no, not at all.
               Okay, phenomena -- what did I want to say about
     phenomena?  Nothing in particular.
               In the exercise you simply identify the phenomena
     and you try to rank them as high, medium or low importance.
     We are not trying to find out which is the most important
     phenomenon and what is the second and list them in that way.
     We just want to know which ones are really important and
     which ones don't matter so much, and you do that with regard
     to something that you have in mind.
               The something that we have in mind is that you
     don't go over this cliff and get into a severe accident.
     That is characterized by this long-term coolability and
     avoiding the pressure pulses that threaten structures, so at
     the outset we had this statement that the ranking criteria
     were going to be related to fuel integrity, fuel dispersal,
     long term coolability, and pressure pulses that threaten
     structures.
               DR. KRESS:  Those don't seem to include anything
     about the source term.
               MR. MEYER:  Not yet, no.
               DR. KRESS:  That is for later?  You'll have
     another criteria later.
               MR. MEYER:  That's correct.
               DR. APOSTOLAKIS:  So let me understand --
               MR. MEYER:  These events, these four events,
     really don't invoke challenges, big challenges to offsite
     doses. That is not really the thrust of analyzing these
     events.
               DR. KRESS:  You are assuming ECCS works in these?
               MR. MEYER:  Yes, right.  The source term itself
     will be considered as a separate issue, because even when
     the source term is applied to the loss of coolant accident
     it is this hybrid analysis where you are analyzing an event
     that is successfully terminated and using a source term for
     a core melt to test the containment integrity and things
     like that.
               These three or four events, however you want to
     count them, we are going to look at them just from the point
     of view of the severity of the behavior of the fuel with
     regard to its long-term cooling and pressure pulse
     generation.
               DR. APOSTOLAKIS:  Now let me understand a little
     bit the criteria there.  You have a number of phenomena.
               MR. MEYER:  Yes.
               DR. APOSTOLAKIS:  Typically what number are we
     talking about?  I mean it's not a fixed number or is it two
     or three --
               MR. MEYER:  No.
               DR. APOSTOLAKIS:  No?
               MR. MADISON:  The number of phenomena that we have
     considered is on the order of 100 and I can see where you
     are going with this question and I am going there.
               DR. APOSTOLAKIS:  I don't know where I am going
     with it.
               [Laughter.]
               MR. MEYER:  Well, then I think you are going to go
     with me.
               DR. APOSTOLAKIS:  Okay.
               [Laughter.]
               MR. MEYER:  And if you can bear with me a
     minute --
               DR. APOSTOLAKIS:  Sure.
               MR. MEYER:  -- I believe I am going to come back
     in more detail to this area that you want to discuss.
               DR. APOSTOLAKIS:  Okay.
               DR. WALLIS:  The only thing that is different now
     is that the fuel has been in there a long time.
               MR. MEYER:  Correct.
               DR. WALLIS:  All the other phenomena are the same
     as when the fuel is young.
               MR. MEYER:  They are not all the same.
               DR. WALLIS:  They are not all the same.  But they
     haven't changed much, have they?  It's really the fuel
     that's changed.
               MR. MEYER:  That is really the nub of the issue, I
     guess.  Some of them have changed sufficiently that, for
     example, in the rod ejection accident we found rather early
     on -- early being in 1994 and -95 -- that the mechanism of
     failure is quite different from the one that we studied with
     fresh fuel.  It is a brittle, cracking pellet cladding
     mechanical pushing interaction mechanism rather than a high
     temperature heatup oxidation.
               DR. WALLIS:  It is the fuel that is different, but
     the actual sort of pressure temperature history and
     everything is still the same?
               MR. MEYER:  Yes, yes.
               This is a list of the kinds of questions that we
     want to address with the PIRT.  You are going to see as I go
     through here that the PIRT itself is not going to answer
     these questions directly but we believe that going through
     the exercise will put us in a lot better position to answer
     them.
               For example, we have now several different
     cladding alloys that are being used.  We used to use only
     zircalloy, which is alloy principally of zirconium and tin,
     with some tin in it.  Now Zirlo and M5 have niobium in them.
     M5 doesn't have any tin, so the question is do the criteria
     which were originally developed from experimental work done
     on zircalloy still apply to these other alloys.  That is a
     big question.
               Can we perform expensive tests with one type of
     cladding and extrapolate the results to the other type with
     perhaps some information from less expensive tests?
               Some more detail questions that come up along the
     way -- pulse width, is it a critical parameter or not?  We
     have seen some evidence of that, and what do we do for the
     BWR power oscillations.  This is an event that we know very
     little about in terms of the fuel response at this point.
               I just want to emphasize as you look at these
     questions the fact that we view PIRT as just a tool.  It is
     not going to answer them directly.
               CHAIRMAN POWERS:  It seems to me when I look at
     this list of questions that there must be some background
     assumptions of things that don't need to be looked at.  What
     I am thinking of, for example, there do not seem to be
     questions that relate to the propagation or damage from
     assembly to assembly or rod to rod?
               MR. MEYER:  Well, those questions just aren't on
     this list.
               CHAIRMAN POWERS:  Okay.a
               MR. MEYER:  But I can assure you that those
     questions are discussed in PIRT panel.
               CHAIRMAN POWERS:  And recriticality?
               MR. MEYER:  Recriticality -- I can't recall that
     that has come up yet.
               Okay, let me go on now and talk about the
     organization and status of the PIRT and begin with a list of
     participants here.
               We have literally two dozen of the world's best
     experts in fuel behavior.
               DR. KRESS:  Give or take one or two.
               MR. MEYER:  Give or take one or two.  You will
     recognize some of the names on the list, like Carl
     Alexander, who -- I have given him an extra A in his name;
     I'm sorry, Carl.
               But I want to talk just a minute about some of
     these.  I have put in bold letters, four of them.  These
     four resulted from the ACRS quadripartite interaction.
               So you had the Japanese, German, and French
     partners in your quadripartite group, and with your
     encouragement, we worked through those, and these are the
     people that we got back from Japan, Germany, and France.
               Now, I think most of you know by now that Franz
     Schmitz, who really was the dean of the group, and was
     responsible for a lot of progress in this area, passed away
     last November.
               And so, he has been replaced by Joell Papin from
     the same laboratory in Caderache, so she is working with us
     now regularly.
               DR. APOSTOLAKIS:  These people are in one room and
     are doing this?
               MR. MEYER:  Yes, yes.
               DR. APOSTOLAKIS:  Wow.
               MR. MEYER:  In fact, I will tell you that we do
     occasionally use two rooms.
               DR. APOSTOLAKIS:  Scheduling those meetings must
     be a nightmare.
               MR. MEYER:  Okay, we have done a little dedication
     of the report to Schmitz and put an inside-the-cover page to
     him, which I think was appropriate.  Everybody was happy
     with that arrangement.
               Okay, a few more comments about the list.  Half of
     the names on the list came from EPRI suggestions.  So we
     have three names that came from NRC, ACRS-related; half of
     them that came from industry suggestions, and the rest of
     them, we also made arrangements for.
               Now, almost everyone on this list who
     participates, pays their own way; the companies pay their
     own way.  There are a few exceptions, a couple of college
     professors and a retired guy, and we've got contracts to
     support those.  But by and large, the industry people who
     come pay their own ways.
               There are no NRC contractors on this list.  That
     was intentional.  We thought there could be some appearance
     of conflict if we put NRC contractors on this list.  I'm not
     sure how that thinks through clearly, but --
               DR. WALLIS:  Well, I know Hochreiter has a
     contract.  I hate to -- that doesn't seem to be a true
     statement.
               MR. MEYER:  Hochreiter?  He does --
               DR. WALLIS:  He has a large project, yes.
               MR. MEYER:  He doesn't have a contract from the
     high-burnup fuels project.
               DR. WALLIS:  No, but he's still an NRC contractor.
               MR. MEYER:  Okay.  We tried to avoid putting the
     people that we worked directly with on this, but we used
     them -- we do use them as resource people.
               DR. KRESS:  Did you try to get Dick Hobbins on
     this at all?
               MR. MEYER:  no.
               DR. KRESS:  Is he retired?
               MR. MEYER:  Yes.
               DR. KRESS:  Okay.
               MR. MEYER:  And resource people, we've reached out
     to our own contractors plus some others.  Typically, the way
     we use a resource person is, at the beginning of the
     activity, they will come in and make a large presentation
     about the scenario that we're talking about.
               So there's rod ejection accident, David Diamond
     from Brookhaven came in and made a big presentation about
     the analysis that had been done in the past couple of years.
               Phil McDonald from INEL came in and made a
     presentation and stayed with us through one of the sessions.
     Phil McDonald was the principal investigator on the PBF work
     and some of the SPIRT work in the other days.  So he's the
     principal author on the classic paper on this subject in the
     early 80s.
               And more recently, when we switched to the BWR
     subject and had our first meeting on the BWR subject, we
     invited a fellow named Martin Zimmerman from the Paul
     Scherer Institute who had done some work on the BWR power
     oscillations, to come over.
               So, we've reached out everywhere that we thought
     we could benefit, and asked people to come in and provide
     information to this group.  And that's worked out well for
     us.
               DR. POWERS:  I think the Committee should really
     be excited about what they've done here, because this was
     our recommendation in this area, that they should reach out
     broadly.  It just looks to me like they've gone a mile
     farther than we even anticipated they would, to reach out to
     get the breadth of opinion.
               MR. MEYER:  Yes, it's hard to imagine reaching any
     further.  I mean, we've got all the U.S. fuel manufacturers
     represented, universities, laboratories, foreign
     governments.
               DR. SHACK:  Don't challenge us, Ralph.
               DR. POWERS:  Come on, the astronomers are
     discovering these new planets all the time.  You just really
     have a narrow focus here.
               [Laughter.]
               MR. MEYER:  Okay, leave it alone.
               [Laughter.]
               DR. SEALE:  And you have a fertile imagination.
               MR. MEYER:  I think when we talked to you last
     Spring, we were committed to this, and we were beginning to
     make our plans, but we hadn't scheduled meetings, and
     certainly hadn't held any meetings.
               The first meeting was held at the end of August.
     And then two more meetings on the PWR were held in the Fall
     of the year, in October and December.
               We have a number of people who travel from
     overseas, and so we're trying real hard to schedule some of
     these meetings close to other events that they'll be
     traveling for anyway.
               And we've also reduced the number of meets per
     PIRT to two in our ambition to try and reduce the amount of
     travel.  So the work activity is pretty intense, and you'll
     see that this is a four-day meeting.  So they prefer to work
     hard for four days, rather than have to come back at another
     time.
               Now, that is a large group, and we found that it
     was difficult to work with everybody in the room at the same
     time.
               You're going to see in the organization of the
     work in just a minute, that we broke it into two types of
     technical activities, the experimental work and the
     analytical work.
               So we, in fact, have divided it into two groups
     that meet in parallel.  This just kind of happened
     spontaneously in the PIRT effort.
               And the two group leaders, who, again, arose
     spontaneously, are Arthur Motta from Penn State in the
     Experimental Group, and Lee Peddicord from Texas A&M, in the
     Analytical Group.
               So now this is kind of a semipermanent, unofficial
     arrangement, that we break into these breakout groups and
     these guys take over and lead the group through its paces.
               Now, we have mentioned the fact that we have a
     website and there is the address for the website.  On the
     website are several documents.
               The concept of the website originally was to hold
     the transcripts from the meetings.  Because we had a large
     group, and we thought it would be difficult for the PIRT
     facilitator to keep detailed notes, we hired these court
     reporters to come in and keep a verbal transcript of the
     meetings.
               So they do that and we get them electronically and
     put them up on the Web.  We also have background
     information, general background, the kind of thing that was
     on my one of my first slides, the list of participants, the
     agendas, and the schedules are put up there as soon as we
     have that information.
               And then we've also found a need to provide some
     more specific background information, almost guidance for
     the PIRT participants, prior to the meetings in the various
     areas.  So there have been two of these background
     information papers put on the Web, one pertaining to the rod
     ejection accident and one for the BWR.
               DR. POWERS:  Ralph, the concept of PIRT is heavily
     exercised in the thermal hydraulics field, and probably
     pretty well known by thermal hydraulics types.
               MR. MEYER:  Yes.
               DR. POWERS:  But you're really taking this in a
     very creative move and applying it to fuel behavior and
     perhaps even the source term issue.  People are not so
     familiar with the ideas behind PIRT.
               Do you find that transition difficult?
               MR. MEYER:  Yes.
               DR. POWERS:  Are there lessons that you've learned
     out of that process?
               MR. MEYER:  Yes.  Let me just go ahead to the very
     next slide which addresses that, because it was difficult.
     It cost us one session.
               The August/September meeting, the three-day
     meeting that we had, I would describe as wandering in the
     desert.  We were trying to work with these high-level
     criteria, and trying to list the phenomena that would occur.
               And we couldn't quite put it all together.  How
     were we going to get anywhere with this monster?
               And we had to make some practical adjustments,
     which probably, for PIRT purists, makes some substantial
     changes to a PIRT activity.
               One of the first things that we had to do was to
     change the definition of phenomena, to broaden it.  You
     could almost just put in the word, "stuff," and it would
     work.  But we have phenomena processes, processes,
     conditions, properties, anything that's related to the
     subject that we're going to discuss, becomes a phenomenon
     for the purpose of the PIRT.
               DR. WALLIS:  It's very interesting, the analysis
     not as a phenomenon.
               MR. MEYER:  What?
               DR. WALLIS:  Analysis may be a phenomenon.  That
     puts it in a new category.
               MR. MEYER:  Well, then in the category area, we
     had to break this down into some practical elements.  We
     were struggling with these four areas, with the plant
     transient analysis, integral testing in big machines that
     cost a lot of money.
               Transient fuel rod codes were being used in this.
     Also, we're trying to measure mechanical properties to
     facilitate the use of transient codes to allow us to
     understand the experimental results to see how these fit
     with the plant transient.
               So at that point, after the first meeting, we
     regrouped, we decided that we would list this generalized
     definition of phenomena in these four categories, and we
     made one other major change.  That was, we backed down a
     notch on our criteria.
               After discussing -- trying to discuss coolability
     and pressure pulse generation, we realized that we really
     didn't have a database, and didn't want to get into those
     areas with design basis accidents.
               So nobody wants to try and talk about debris
     coolability or the efficiency of a fuel/coolant interaction
     in a design basis accident.  So we decided, as a practical
     matter, that we would roll this back to the fuel dispersal
     and flow blockage, where flow blockage here, in our minds,
     is like in a loca, ballooning and reduction of the flow
     channel area.
               So, these became the criteria.  Now you look at
     the plant transient analysis and the experiments, and you
     rank the phenomena with regard to the outcome of the
     analysis or the experiment in relation to dispersing fuel or
     ballooning fuel rods.
               DR. KRESS:  I think that was a good move, Ralph.
     That probably focused a whole lot of attention on that.
               DR. POWERS:  I think the whole enterprise of
     taking this technology that's been so useful in one field
     and applying it in another is, Ralph deserves all the credit
     in the world for making that, and he also deserves credit
     for recognizing that a direct transfer is just never going
     to be possible.  You have to make some accommodations to the
     vicissitudes of the field.
               So I'm not surprised at all, and I think you made
     some good changes.
               MR. MEYER:  It became very apparent after the
     first meeting.  The first meeting was uncomfortable.  I
     mean, you're trying for three days to get somewhere, and
     you're frustrated, and you wander off into these deep areas
     that you can't handle.
               So, we made these adjustments, we wrote the first
     background paper prior to the second meeting.  We put it out
     on the Web, we communicated with e-mail and we came back and
     engaged the group in this revised way of treating a, quote,
     PIRT.
               DR. WALLIS:  Are you going to cover all
     eventualities about the fuel result without blocking and
     still be awkward to deal with, without necessarily
     dispersing?
               MR. MEYER:  Could you say that again?  I just
     didn't hear it.
               DR. WALLIS:  Well, if it distorts efficiency, it
     may be hard to handle, or it may prevent some mechanical
     motion of self or rods or whatever.  But it won't
     necessarily disperse or block flow; it just changes its
     geometry sufficiently so that it would be awkward to deal
     with.
               MR. MEYER:  That's considered, swelling, in
     particular, but also bending, getting in the way of control
     rods.
               DR. WALLIS:  That's included.
               MR. MEYER:  Yes.  Now, let me give you just a few
     sample results.  I don't want to go into a lot of detail on
     this.  In the plant transient analysis category, there were
     probably 25 phenomenon that were ranked.
               I just looked through the table and picked out a
     half dozen that had really, you know, like -- we voted.  Let
     me digress here a second:
               With a smaller group, you might come to a
     consensus rather quickly on high, medium, or low.  But in a
     huge group like this, we decided that we would vote and
     record the tally of votes on high, medium, and low.
               And we asked the PIRT members only to vote if they
     felt that they really had some knowledge and opinion on this
     subject, so that we expected that the plant transient
     analysis experts might not vote when you came to a question
     about the experimental measurement of a mechanical property.
               And so you don't have total votes that total up to
     24.  And, in fact, after doing this for awhile, it became
     clear that half of the room would vote on the analysis
     activities, and half of the room would vote on the
     experimental activities, and so we just got another room for
     them and did the work in parallel.
               But what I did then was to look through the table
     with the final vote tally, and pick out the lopsided votes
     for high-ranked phenomena.  And here are six of them that I
     have on the screen here.
               They're not too surprising, in themselves, but you
     try and get from this, as much as you can.  These last
     three, fuel temperature feedback; delayed neutron fraction;
     and heat capacities of the fuel and cladding, are basic
     properties.
               You can't do much about those, except get them
     right in your codes.  But the first three, the control rod
     worth, the fuel cycle design, and the pin-peaking factors,
     you can actually change those in the core design.
               So I think of these three together as core design.
     Now, this has some practical implications.  Now I'm
     wandering into the application part of this.
               So after this is done, we're sitting back and
     we're looking at this and saying, if you get some limiting
     value that is a little difficult to live with, you can alter
     the control rod worths and bring the deposited energy down.
               Or, conversely, if you have some target fuel
     enthalpy that you want to stay below, we began to see in the
     presentations, that you couldn't get up to that value if the
     control rod worth was not greater than such a value.
               It then suggested that somehow we can use control
     rod worth in combination with some other factors about the
     core design, and perhaps make some equivalence to the peak
     fuel enthalpy and thereby avoid doing a 3-D plant
     calculation for each and every core, and simply look at the
     core design and the control rod worths that you're going to
     have, and reach some judgment about whether or not this is
     going to exceed the fuel design criteria.
               DR. UHRIG:  So your fuel cycle design is -- you're
     talking about 24 months, 18 months, or are you talking about
     the leakage configuration, of all of the above?
               MR. MEYER:  All of the above.  So, here is an
     idea, a new idea that has come out of these discussions,
     which we haven't completely ironed out yet.  And this is one
     of the reasons that we're not quite ready to present the
     application.
               But this is one result of this PIRT activity that
     I think is going to be valuable.
               DR. POWERS:  It looks like it's crucial, because
     this is  the kind of information that line organizations
     would want to have when somebody proposed to go to high
     burnup.
               MR. MEYER:  Yes.  And I also want to mention that
     the insights that we're going to get from the PIRT activity
     are not all going to come from just looking at the ranking
     scores.  But you've got two dozen people engaging in
     discussions for three-day periods, and during those
     discussions, a lot happens, and you sit there and you get
     ideas.
               So, the activity itself is part of the equation.
               DR. KRESS:  Ralph, the delayed neutron fraction,
     it strikes me as a strange one to be in here, because I
     would have thought, number one, it has a one-to-one
     relationship with burnup.  And it seems to me, like there is
     very little uncertainty in what you know about it.
               So that even thought it may have a real impact on
     what you do with the transient, how the transient goes, it
     seems like you know enough about it, and it's only related
     to burnup itself, that I don't know where I'm going, but I
     was surprised to see it ranked as high.
               I guess --
               MR. MEYER:  Which one was that?
               DR. KRESS:  The delayed neutron fraction.
               MR. MEYER:  Oh, the delayed neutron fraction, yes.
               DR. WALLIS:  I'm really surprised that cooling of
     the cladding doesn't come into it.
               DR. KRESS:  Well, I think that fuel temperature
     feedback implies something about how you calculate the
     temperature, too.  But these things go so fast, that --
               DR. WALLIS:  But it's still pretty rapid cooling
     as well.
               DR. KRESS:  I know, but I think these things are
     almost adiabatic, aren't they?
               MR. MEYER:  It is nearly adiabatic.  The transient
     is -- the pulse has a half width of about 30-50
     milliseconds.  And the fuel has a time constant of three to
     five seconds.  So, you don't get a lot of heat transfer but
     you do get some.
               DR. WALLIS:  If you heat up the cladding, then you
     probably heat up some water as well.
               MR. MEYER:  Yes.
               DR. POWERS:  I think that on the delayed neutron
     fraction, I think you're right that if you ask me about a
     specific piece of fuel, that I probably can calculate the
     delayed neutron fraction with a fair degree of accuracy.
               When I use these codes, I don't use that number; I
     use a fudge factor to give me an average.  And at least one
     of the NRC contractors has written on this subject, saying
     that we need to look at it.
               And my recollection is that Dave Diamond was doing
     some uncertainty analyses on that aspect of the calculation.
               MR. MEYER:  Yes.  I think it was his presentation
     that led to this ranking.
               There are also some interesting things that don't
     make the high list, and one of them was rate of reactivity
     insertion.
               I think a lot of us who weren't specialists in
     that area thought at the outset that rate of reactivity
     insertion was going to be a big actor.  And it wasn't.
               As long as you can get the reactivity inserted in
     about a couple hundred milliseconds, it doesn't matter.
               DR. POWERS:  I recall lots of questions in this
     room, exactly about transients in the experiments being too
     short.  And people complained that the experiment were
     prototypic.
               I think what you're saying is that as long as
     they're about right, it doesn't make a lot of difference.
               MR. MEYER:  Yes.  Now, the next group of phenomena
     are the integral experiments.  These are the experiments
     like at Cabris or at NSRR.
               And, you know, at first, these don't look very
     surprising, but burnup of the test rod, there was a lot of
     discussion about burnup of the test rod.  After you
     understand a little bit about the failure mechanism for
     these high burnup rods, and realize that the hydrogen
     embrittlement of the cladding is a major factor, you can
     begin thinking that, well, the actual burnup of the test rod
     may not be so important, as long as I've got the right
     amount of hydrogen in the test rod.
               And you might get that in -- you know there may
     not be a one-to-one coupling between burnup and oxidation,
     which leads to the hydrogen, because the oxidation is also
     affected by how high the temperature is in the plant, and
     the water chemistry.
               But n further probings the group realized that the
     burnup itself is going to lead to fission gas distributions
     on the grain boundaries in the pellet, and these are going
     to perhaps have a big effect on the implied loading on the
     cladding.
               DR. KRESS:  I was going to ask you about that
     particular thing.  Now that you are on it, I will.  I would
     have thought somewhere in there you might have been -- the
     amount of time the fuel sits around after burnup, before you
     put it in, would be an important consideration just because
     you change that distribution of fission gases on the grain
     boundaries and you age the grains themselves and change that
     grain structure a little bit.  Was that one of the
     considerations?  Usually you don't just have the fuel right
     there after burnup -- it sits around.
               MR. MEYER:  I don't think we talked about the time
     that it would sit around at room temperature, but we talked
     about the preconditioning that might take place in the test
     reactor when you are warming up and getting ready for the
     test.
               DR. KRESS:  Yes.
               MR. MEYER:  There the discussion focused more on
     what you might do to the distribution and orientation of
     hydrides in the cladding rather than on the fission
     products, but nevertheless the fission product issue
     promoted the burnup of the test rod to a high ranking and
     what this means in a practical way in our interpretation is
     that if you are going to go from 62 to 75 gigawatt days per
     ton burnup that you need to test rods with burnups up to 75
     gigawatt days per ton and not just stop with rods that have
     62 gigawatt days per ton but a lot of oxide on them, which
     we have in our test programs.
               DR. KRESS:  I think that is a real good insight
     there.
               MR. MEYER:  The coolant heat transfer conditions
     during the tests obviously have implications with regard to
     whether you can be satisfied with tests in a sodium loop or
     whether you need to test in a water environment.  That one
     is pretty transparent.  Pulse width during the test was also
     discussed a lot and thought to be important.
               There are, however, two aspects of the pulse that
     were not high ranked.  They were only medium ranked and
     maybe one of them was low.  I have forgotten, but there have
     been two concerns expressed about the pulse and the power
     histories.
               One was about the shape of the pulse.  In Cabri we
     had one test with a big double humped pulse.  They were
     trying to get a broad pulse and it is very difficult to
     operate the valves in the Helium 3 system fast, and they
     didn't get a good operation of the valves and they got two
     pulses sort of merged together with a clear dip in the
     middle.  I thought that that was bad news, but I was
     probably the only one who thought that was bad news.
     Everybody who discussed it thought no, it doesn't matter so
     much as long as you get the enthalpy in the fuel, right, is
     the integral of that thing more than the shape of it that
     matters.
               The other related parameter that was discussed was
     the power history during burnup accumulation in the power
     plant before the rod is tested.
               DR. KRESS:  I would have thought on the pulse
     width that you were right.  If it is broad pulse width or
     humped like that you have a problem, but I would have
     thought that as you come down in the pulse width you will
     reach a place, a width, beyond which it doesn't matter
     anymore, and that would have been -- so as long as you stay
     within the given pulse width that you'll be all right.  Did
     that come out?
               MR. MEYER:  Well, there is a feeling that for the
     very narrow pulses that there is some -- I don't know if I
     am going to get this right -- coherency in the expansion of
     the gas on the grain boundaries and pushing out fragments,
     grain size fragments of the pellet, into the cladding, which
     might if given a little more time to spread out not
     contribute so significantly to the mechanical --
               DR. KRESS:  That's why I thought it would be
     maximum pulse width beyond which you wouldn't want to go,
     but if you are within that narrow range, it doesn't matter.
               MR. MEYER:  Well, but the thinking is the other
     way around.  If you get too small you get an extra kick from
     the fission gas and as long as you get above a certain
     amount you don't get that kick and then it's just the
     thermal expansion of the pellet which is related to the
     enthalpy that you get into the U02.
               DR. WALLIS:  Well, if it is rapid enough, you have
     to worry about sort of wave-like transient propagation of
     things.  It's more like an explosion than the swelling --
     very short transients.
               MR. SIEBER:  I presume that when you are talking
     about agglomerates in the test run you are talking about
     plutonium particle size?
               MR. MEYER:  Yes.
               MR. SIEBER:  Did you go to the extent to figure
     the effect of the particle being hot enough to burst through
     the cladding during the pulse?
               MR. MEYER:  What we had presented to us was some
     metallagraphic examination from the Cabri test with mixed
     oxide fuel.  Now these have the minus MOX fabrication route,
     which does result in plutonium-rich agglomerates.  I think
     it's 50 percent UPU mixed oxide in those agglomerates.  It's
     not pure PUO2, and from those results they did not see
     melting or gross microstructure change in the vicinity of
     the particles so there was the feeling that the extreme high
     temperature wasn't the main actor in the MOX effect which
     was seen prominently in these Cabri tests but rather that
     the MOX effect was related to a high burnup rim around each
     particulate.
               Sort of like the rim that we talk about around the
     outside of a UO2 fuel pellet at high burnup, you have these
     ultrahigh burnup islands with their own rim around them, so
     this is the current thinking on this, and it is not the high
     temperature part, so I think the melt-through of the
     cladding would not be thought to be an important process at
     the moment based on what they have seen.
               MR. SIEBER:  There were a number of experiments in
     a test program called the Plutonium Utilization Program in
     the '70s.
               MR. MEYER:  Yes.
               MR. SIEBER:  Done by the Battelle at Hanford.  Are
     you familiar with that?
               MR. MEYER:  Yes.
               MR. SIEBER:  Okay.  They did get clad perforation
     on those tests.
               MR. MEYER:  Yes.  Well, when we looked at the
     transient fuel rod codes, and for us the transient fuel rod
     code is FRAPTRAN, you find some conclusions, some high
     ranked phenomena that seem pretty obvious, but they may have
     some not so obvious implications.
               For example, the gap size is obviously going to be
     a high ranked thing because you have the pellet expanding
     and pushing on the cladding to generate the stress that
     leads to the fracture.  If there is a gap between the pellet
     and the cladding, the pellet has some free movement before
     it starts applying the stress, so getting the gap size is
     obviously going to be important.
               It strikes me from just sitting and listening to
     the discussions and putting two and two together that in our
     code the gap size is based largely on temperature validation
     of the code rather than the mechanical part.  Now we do have
     some, because we do look at axial elongation of the
     cladding, which is a result of gap closure and lockup, so we
     have some indirect ways of measuring the interaction between
     the pellet and the cladding which then gives you information
     about the gap closure, but I would want to look back at our
     code and to see if there is any need to tune up the gap size
     modeling such that it not only hits the temperatures right
     but it also hits the mechanical interactions right.
               Now I am not sure that it doesn't do that, but I
     am just saying when you go through this you get these kinds
     of implications that cause you to go back and look at some
     of your models.
               DR. KRESS:  Did you say your code was FRAPTRAN?
               MR. MEYER:  FRAPTRAN is the new incarnation of
     FRAP-T.
               DR. KRESS:  FRAP-T, okay.  I hadn't heard of
     FRAPTRAN.  Are we going to see that code sometime?
               MR. MEYER:  Yes. FRAPTRAN is going through its
     validation assessment now, and we are planning a peer review
     this summer and so we will have the assessment and the
     documentation, the peer review, then revisions and then the
     publication of the documentation.  That is taking place this
     year.
               DR. WALLIS:  Does this code assume things like
     cylindrical symmetry to make things simple but maybe miss
     some real phenomena that way?
               MR. MEYER:  Yes.  It does.
               One other thing -- here is one that was not ranked
     high and that was the mechanical properties of the pellet,
     because in the equations you have got a pellet that can give
     and the cladding that can give, and you have got the model
     on both.  Well, pellets are a lot stiffer than the cladding
     is and so getting the pellet model accurately is not as
     important as getting the cladding model accurately.
               We currently have a rigid pellet model in our code
     and we are not sure yet that that is not sufficient.
               DR. WALLIS:  As long as it is intact.
               MR. MEYER:  As long as what?
               DR. WALLIS:  As long as it is intact.
               MR. MEYER:  Yes.
               And then finally we looked at things important in
     making mechanical property measurements.  There is really
     not a whole lot that jumps out here that would be of
     interest to talk about.
               We were looking at such things as the way you
     select specimens and design specimens, and it was clear to
     everyone that the detailed shape of these ring tensile
     specimens, for example, is extremely important.
               And we have been working on this for a couple of
     years now, and this work has spread around to other
     laboratories.  We've been working with cooperating with
     them.
               So it's really not a surprise when you reach out
     and get the experts, and you've been working with them
     already on this subject, that you find out that you're on
     the right track and you really need to do those things.
               DR. WALLIS:  The thing that concerns me about
     PIRTs is when there is a lot of extrapolation of experience.
     It seems to me that the actual base of knowledge for really
     high burnups is very skimpy.
               MR. MEYER:  Yes.
               DR. WALLIS:  So all of these experts are
     extrapolating their experience.
               MR. MEYER:  Yes.
               DR. WALLIS:  And it becomes more and more
     guesswork, the further out they get.
               MR. MEYER:  Yes.  But we don't have an empty
     slate.  We do have a lot of data for the reactivity
     transient, but much of that was obtained under conditions
     that weren't ideal.
               But you still learn from those things.  And also
     in the loca transient, there is preliminary information in
     France, and we're on the verge of getting these data
     ourselves now in our program at Argonne.
               So the one where we really have the least to go on
     is the BWR transient.
               DR. POWERS:  I noticed that on your previous
     slide, you had a MOX callout on that.  How much is MOX
     figuring into these PIRT activities?
               MR. MEYER:  Not a lot, but let me tell you the way
     that we do this, and you can see exactly how it's done.
               We look at the specific sequence, and it's
     specific right down to the fuel type.  So, in the case of
     TMI-1, it's a 15 x 15; it's zircalloy four; it's UO2
     pellets.  And it's got a certain enrichment and oxide
     thickness, and everything is assumed.
               And then we go through the exercise.  At the end
     of the exercise, we ask ourselves several extra questions.
     And we go back through each phenomenon, and the question is,
     would the ranking, high, medium and low, change if you now
     went from a UO2 fuel to a mixed oxide fuel?
               And you can go through large lists of phenomena
     and say, no change; and then you find one that would change.
     And we do the same -- if you change the cladding type from
     zircalloy to zirlo or M-5, would the high, medium, and low
     ranking change?
               Was there another one that we did, Harold?
               MR. SCOTT:  Burnup.
               MR. MEYER:  Yes, burnup.  We did this for 62
     gigawatt days per ton, because 62 gigawatt days per ton is
     the burnup limit for which the NRC has said we will provide
     the confirmatory work.  Going from 62 to 75 is the
     industry's responsibility.
               So we did the basic exercise at 62, and then we
     asked the question, if you went from 62 to 75, would the
     ranking change.  And you go through each and every one of
     them.  And those are tabulated in the report.
               This is what the report looks like in paper.  The
     report is on the website in its entirety, and it's kept up
     to date.  We use it as a working draft, and it's in a
     near-final condition, but there will be some more changes on
     this one, even though we've moved on now to the ATWS PIRT.
               DR. POWERS:  So by the time you're done with this
     particular item, you'll have a pretty good idea?  I mean,
     somebody could look at this and have a pretty good idea that
     it says if I want to go to 75 gigawatt days per ton, the
     kind of information I need to have available for the NRC
     with respect to rod ejection accidents is here.  I mean,
     it's listed down for you.
               I would really like to just say, yes, to your
     question, but I think there is an interpretive step in
     between.
               DR. POWERS:  Okay.
               MR. MEYER:  I can't tell you for sure that our
     conclusions and our applications of the PIRT will match up
     with what the industry does with it.  I hope so, but --
               DR. POWERS:  I wouldn't presume to say that the
     industry would follow it blindly, but with the purposes -- a
     hypothetical industry guy comes in and asks, what do I need
     to bring, that you're happy with my arguments on 75 and has
     something to point to.
               MR. MEYER:  Yes, yes.
               DR. POWERS:  What he actually brings may be up to
     him.
               MR. MEYER:  Yes.  Okay, this is my last slide and
     there's not much on it.  It just say that we're now working
     on an application for the PWR rod ejection case.  I think we
     cannot only see light at the end of the tunnel; I think we
     can see the tunnel clearly enough that we can get out
     without bruising ourselves too much.
               There will be some additional work required, in my
     opinion, to get there, but it's not endless; it's finite.
     And we have a draft document with this written down.  It
     simply hasn't been reviewed.  It will be changed and
     adjusted, and that's the document that I would have really
     liked to have discussed with the Committee, but it was
     clearly not ready for discussion.
               But I do want to leave the impression that we
     think we know what to do with this, with regard to the first
     event type, the PWR rod ejection accident.  And when we work
     out the details of our plan for resolution, then we'll be
     able to discuss that with you.
               MR. SIEBER:  When do you think the report will be
     ready in paper form as a final, not necessarily approved?
               MR. MEYER:  Well, we're probably not going to make
     a large paper distribution of this report.  The whole agency
     is moving towards a paperless existence.
               DR. SEALE:  Well, will it be on the Web?
               MR. MEYER:  It's no the Web right now; it's there
     right now.
               MR. SIEBER:  Reading a couple hundred pages off
     the screen is tough.
               MR. MEYER:  Well, you need to get Matt to print it
     for you.  He's got a good printer.
               DR. POWERS:  We've got at least a draft of the
     document.
               MR. EL-ZEFTAWY:  Yes, I'll print it from the Web
     and distribute it to all the members.
               MR. MEYER:  We have made one decision relevant to
     this question, though, and that is, we're not going to
     finalize the first PIRT report until we finish all of them.
               DR. POWERS:  All right.
               MR. MEYER:  As we move into the subject of the BWR
     ATWS, we remember, oh, we forgot something on the PWR.  And
     we have to go back and make that adjustment.
               They're all sitting on the Web.  They're available
     to anyone.  I don't expect the changes to be major, but
     we're not going to issue them with publication dates until
     we're finished with the last one.
               DR. POWERS:  Okay.
               MR. MEYER:  That's all.
               DR. KRESS:  Ralph, what I heard so far and see so
     far just validates my original impression that this was a
     stroke of genius to go this route for this particular issue.
     I think you're on the right track, and it looks very
     exciting.
               MR. SIEBER:  Yes, it is.
               MR. MEYER:  I really have to give credit for
     Farouk Eltawila for the idea of pushing us into the PIRT
     activity.
               DR. KRESS:  It certainly is an application that
     has a lot of excitement.
               DR. POWERS:  I think it makes us seriously think
     about lessons learned.
               DR. KRESS:  Yes.  I agree, that that might be a
     really good addition to this, lessons learned from applying
     a PIRT to this particular application.  It might be a real
     good little thing to put out, some sort of document on that.
               DR. POWERS:  For your brethren who are going to
     have similar problems of reaching out.  When the Committee
     has written before that we think especially in these areas
     where you're going into something new, it's useful to reach
     out and try to find out what the world knows about these
     things.
               But it would stun and appall me if we could take
     what the thermal hydraulicists have said is and use it
     exactly.
               MR. MEYER:  Yes.
               DR. POWERS:  I think what you found is, no, you
     can't do that.
               MR. MEYER:  It's just very different.  I mean,
     with a thermal hydraulic code, you're modeling the
     phenomenon, so you go down the phenomena one-by-one, but
     here we're trying to resolve a regulatory issue.
               And it involves more than just a code with
     phenomena.
               DR. BONACA:  I have a question regarding the
     scenario where you discuss the PWR for the ejection
     accident.  You're looking at a classic reactivity insertion
     resulting from the ejection.
               MR. MEYER:  Yes.
               DR. BONACA:  And are looking at how likely the
     event is going to happen.  I mean, one issue that was
     debated for a long time was, typically what you postulated
     is the extreme event, which is rod ejection at zero power
     with all the rods inserted, et cetera.
               MR. MEYER:  Yes.
               DR. BONACA:  It's an extremely unlikely event
     because of what you have to assume, I mean, including the
     rupture of a nozzle and the ejection.  And then you have, of
     course, hardware up there that will prevent the ejection.
               MR. MEYER:  Right.
               DR. BONACA:  So you're not looking at all to the
     risk-informed credibility?
               MR. MEYER:  No.  I would say, to the contrary.  We
     did, and you have to go back two years to the time when we
     were developing the agency's high burnup program plan.
               At that time, we did an explicit, albeit very
     simple, risk assessment of each of the issues in the program
     plan.
               And there was no question that all of the design
     basis accidents have low frequencies of occurrence.  But
     when you're talking risk, you obviously have to have
     consequence, so you can't just hone in on a higher
     probability even that can't lead to a consequence.
               And consequence means essentially melting fuel and
     getting big fission product releases.  So, the PWR rod
     ejection accident that had been the traditional design basis
     accident, stayed on the plate after that little examination.
               But the corresponding rod-drop accident for the
     boiling water reactor didn't, because what we found is that
     there is this other reactivity-related event, the power
     oscillations related to an ATWS, that are higher probability
     and probably -- although we're unable to do a real risk
     analysis, we can see that the type of damage to the fuel
     could be serious enough to lead you into consequences.
               And so our conclusion was that the power
     oscillation for the BWR was a higher risk event than the
     rod-drop for the BWR, and so we have turned our attention to
     that.
               DR. BONACA:  Okay.
               DR. KRESS:  There is in the plans, you said, some
     time to repeat this exercise for the source term?
               MR. MEYER:  Yes.  We don't have it schedule.
               DR. KRESS:  That's down the road some time?
               MR. MEYER:  The reactivity-related events and the
     loss of coolant accidents will be finished up this year.
     And I would expect that we would try and schedule the source
     term one in 2001, but it is not scheduled at this time.
               DR. KRESS:  It will probably concentrate on locas
     for that?
               MR. MEYER:  I would think you would have to take
     several severe accident sequences.
               DR. KRESS:  Okay, you may want to take some.
               MR. MEYER:  For the source term, you're probably
     going to have to take three or four sequences.
               DR. KRESS:  It's probably sufficient to just take
     a low-pressure accident these days.
               MR. MEYER:  Okay, it might be.
               DR. KRESS:  You can look into it.
               DR. POWERS:  Well, good.  Do members have any
     further questions?
               [No response.]
               DR. POWERS:  Dr. Meyer, that was just an excellent
     background briefing.  That was very helpful to the
     Committee.
               DR. SEALE:  Yes, super.
               DR. POWERS:  And we look forward to a presentation
     on final interpretations and whatnot.  Just keep us informed
     on your progress.
               MR. MEYER:  Okay.
               DR. POWERS:  Thank you a lot.  I am going to
     recess till 10:30.
               [Recess.]
               CHAIRMAN POWERS:  Okay, let's come back into
     session.  We turn now to the topic of the proposed
     resolution of Generic Safety Issue B-17, criteria for
     safely-related operator actions.  I think this is a subject
     that has been before this committee a couple times in the
     past.
               Professor Seale, I think you will lead us on this
     process.
               DR. SEALE:  Okay.  As you all know, we have been
     trying to encourage our way through the resolution,
     disposition of all the -- as many of the generic issues as
     possible.  We have two of them here, closely related --
     B-17, which is old enough to drink --
               [Laughter.]
               DR. SEALE:  -- and B-27, which is old enough to
     vote.
               [Laughter.]
               DR. SEALE:  And hopefully we will hear from the
     Staff to dispose of these.
               Now there is a record of prior committee
     consideration of these two issues.  Back in November of '95
     we had a proposal from the Staff to close this issue out on
     the basis of the endorsement of an proposed ANSI ANS
     Standard 58-8, 1994, time response design criteria for
     safety-related operator actions.
               The committee reviewed this proposal and took
     sharp exception to it on the basis primarily that the times
     that were identified for operator action in the standard
     were based on information which was not readily available to
     either the -- well, to the public -- and that there were
     proprietary restrictions on the availability of that data
     that made it inappropriate for a standard of this type.
               So as a result of that, why that proposal was
     withdrawn and now the Staff is coming forward with an
     alternative approach to this, a different tack.  We also
     understand that there is a possibility of reconsideration
     action on the standard, and basically what we want to do
     today is to, first of all, look at the proposal from the
     Staff as to how they propose to resolve these issues, and
     then secondly to hear a little bit about any plans they have
     for this standard to see whether or not there is going to be
     any effort to address the concerns we had earlier when we
     looked at that.
               Jay Persensky is going to be giving us our
     presentation and you have a couple of your colleagues, Rossi
     and --
               MR. ROSSI:  I am Ernie Rossi.  I am the Director
     of the Division of Systems Analysis and Regulatory
     Effectiveness and we have Jack Rosenthal, who is the Branch
     Chief of the Regulatory Effectiveness and Human Factors
     Branch here with us, and we have Harold Vandermolen, who is
     the person who is basically in charging of closing out and
     prioritizing and all the other actions associated with
     generic safety issues in the Office of Research, but Jay
     Persensky is going to be the person who gives the
     presentation today and --
               DR. SEALE:  -- the guy in the barrel.
               MR. ROSSI:  -- and Harold Vandermolen will pull
     him out of the barrel if necessary, and I'll watch, okay?
               DR. SEALE:  Very good.
               MR. ROSSI:  Thank you.
               DR. SEALE:  All right, well, Jay, why don't you go
     ahead?
               MR. PERSENSKY:  Good morning.  Actually Bob stole
     a lot of the first couple of slides here by going over a
     very detailed history of where we were a while ago.  As
     indicated, I will be making the bulk of the presentation.
     Harold is here particularly to answer any questions on the
     cost benefit issue, and Paul Lewis is also here, who helped
     to develop this approach and gather the information for it.
               We did send a memo on February 17th with our
     approach described in that, which would close out both
     Generic Issue B-17 and GI-27 with no new or revised
     regulatory activities.
               As Bob indicated, there is a long history -- B-17
     was first identified, the best we can make out, in about
     1978, which is pre-TMI, which is an important element in our
     approach to closing this out.
               B-17 basically says that in some cases plants
     required operator action and that in fact operators may not
     be able to take the appropriate action in time, therefore
     they have to do a study and determine whether or not it
     should be automated.  That was the basic intent -- should we
     automate something or should we leave it as an operator
     action, and they have to take credit in their FSAR for that.
               GI-27 is very similar.  It came up later on, but I
     will get into that in a minute.  The proposed solution was
     set up some time in the mid-'80s and we are not even sure
     who came up with the issue or the idea of closing it out
     using 58.8.  It just seemed because of the title and
     everything else that it would be an appropriate way of
     closing out this issue, since it was to set up criteria for
     operator action.
               We monitored the development of that standard.  We
     had either contractors whom we were involved with actually
     in the development of that standard through about 1994, when
     it was published.  In 1995 the Staff proposed to endorse it
     with Reg Guide 1.164 and at that point we felt that we could
     close out the issue.  ACRS did not support the endorsement
     and they had very strong words and very strong opinions with
     regard to the use of the information in 58.8.  I won't go
     into that again.
               So we were sent back to the drawing boards and it
     probably was a good thing.
               DR. WALLIS:  I'd like to ask that the emphasis
     seems to be here on time rather than the operator's taking
     the wrong action.
               MR. PERSENSKY:  The emphasis was that it could be
     done correctly in the amount of time available.  That was
     assumed and that was the basis of a lot of the data
     collection.
               DR. WALLIS:  After TMI was there a concern with
     inappropriate action?
               MR. PERSENSKY:  There was concern with
     inappropriate action all the way along as far as I know.  I
     mean that was always there was time to do it correctly.
               CHAIRMAN POWERS:  I think it is fair to say that
     the standard in the Staff thinking was a pretty disciplined
     examination of the kinds of things that you take into
     account on operator action -- does the operator diagnose the
     problem, does it accurately diagnose it --
               MR. PERSENSKY:  Yes, and there were, if you go
     back to 58.8 there was essentially a timeline formula that
     would get into questions of diagnosis action time.  The
     action time was important.  There was the whole series of
     things within that and it was based on collection of
     simulator data.
               In any event, after your clear statements, we went
     back and took off our blinders.  We said we have been
     following this one path for a long time but we took off our
     blinders and said, okay, what other ways can we look at
     this?  How can we look at this differently?
               Again, remember this was written pre-TMI, the GI.
               After TMI there were a lot of things that
     happened, particularly with regard to operators.  There was
     improved training.  Simulators were now -- well, every plant
     has its own simulator now a site-specific simulator.  EOPs
     were changed.  In fact, that was part of the problem with
     the original data for ANS 58.8 was that there was a change
     in procedures during that time, so there were a lot of other
     activities that were going on that we feel now actually meet
     the intent of B-17 and that is why we think we don't need
     anything else to do the same thing that is already been
     done.
               We feel it can be closed with no new or revised
     regulatory activities.
               MR. ROSSI:  Let me just follow up with what he
     just said about closing it with no new or revised regulatory
     activities.  I think as we go through this we need to keep
     in mind that the major purpose of the effort on this Generic
     Safety Issue is to make a decision on whether we need to
     impose new actions on the part of licensees as a result of
     this issue and in order to close it out.
               In order to impose new requirements on licensees
     we have to have a disciplined and good reason for doing
     that, and so we have to keep that in mind as we are doing
     it.  That is the real question.  Do we have a basis and need
     for imposing new criteria on licensees or do we have a need
     to ask the Staff to do additional things in this area to
     ensure that where manual actions are required by the
     operators that there is a reasonable assurance that they
     will perform them within the time limits allowed and they
     are available and that they will do it accurately, so I just
     want to have you keep that in mind.
               MR. PERSENSKY:  Okay.  As I said, B-17 was based
     on the fact that plants did require certain actions.  In
     some cases they could be done manually.  If they could not
     be done accurately in the time, then the plant was to make a
     decision to automate that action.
               In 0933, which the Generic Issue Management
     System, there was some work done -- again this would have
     been in the mid-'80s -- indicating that it would include
     requiring plants to perform task analysis, simulator
     studies, analysis and evaluation of operational data, and it
     was the approach that proposed and because 58.8 has some of
     that already built into it, that was one of the reasons they
     suggested at that time to move in that direction.
               Around 1993 Issue 27 came up, and that was just
     titled manual versus automated actions.  It was based on the
     fact that they had been doing some reviews of plant design
     and emergency procedure reviews and said maybe we should
     look at this again.  In that issue, though, it was said to
     be subsumed under B-17 -- if we dealt with B-17, we dealt
     then with Generic Issue 27 as well.
               I think formerly if it is stated to be subsumed,
     it's already closed or listed on the closed list, but we put
     it in here just so you are clear that we are addressing it
     as well.
               DR. WALLIS:  But it's not closed until B-17 is
     closed.
               MR. PERSENSKY:  Right -- well, no.  It is listed
     on our list of things as closed.  Once it is subsumed under
     something else we count it in terms of our bean count, but
     the scope is still covered.  The intent of it is not covered
     until B-17 is closed.
               The justification that we are proposing for the
     closeout again is really a series of other regulatory
     actions that have taken place since B-17 was identified and
     primarily those things that happened after TMI.
               There are a number of requirements, training,
     simulators, operator licensing, EOPs, increased staff that
     are all basically thing things that have changed.  As you
     might remember, I just mentioned that they talked about task
     analysis, simulator studies, review of operational
     experience.
               If you look at the training rule which is in 10
     CFR 51.20 and for the operators in Part 55 they both
     indicate that training programs are supposed to be based on
     systems approach to training.
               Well, a systems approach to training specifically
     talks about doing task analyses to identify what are
     learning objectives and performance objectives.  From those
     then developing tests to make sure that people have
     accommodated through the training to be able to do the tasks
     that are called for in task analysis.  So here is part of it
     that has already been identified through that process and if
     they can't perform the objectives then there is a problem.
               If they can't perform it because there just isn't
     enough time, then the plant would have already made the
     decision to go ahead and automate --
               DR. APOSTOLAKIS:  Yes.  I had a question on this,
     as I looked at the slide.  This, if I just read the slide
     without listening to you, it looks like the emphasis is on
     how to make sure the operators will actually be able to
     perform a function within a given amount of time -- training
     and so on -- but this amount of time comes from physics,
     thermal hydraulic calculations and so on.  I mean this is
     the timed window you have, right --
               MR. PERSENSKY:  Correct.
               DR. APOSTOLAKIS:  -- on the system.  So my
     question was, and I guess you answered it partly, is there
     may be some situations where it is nearly impossible for the
     operators to actually or with reasonable assurance to
     perform that function because the time is simply too short.
     I mean you can't train people to do the impossible, but you
     just said that if that's the case we take care of it
     somewhere else?
               MR. PERSENSKY:  Yes -- well, it would have to be
     taken -- if they cannot meet the performance objectives, and
     this is also true if we take the issue of operator
     licensing, that is where we really get into the picture,
     because with operator action operator licensing we have them
     using plant-specific simulators that have all those physics
     in them and thermal hydraulics in them.  If they can't pass
     their operator licensing examination, so they can't perform
     the operations necessary to pass a licensing examination,
     then there is evidence there that something has to be fixed
     and it can't be trained in, it can't proceduralized in, then
     we have a reasonable assurance that they can do it, that the
     plant would have done something else in order for us to
     license their operators.
               It's sort of an indirect approach to it, but
     nonetheless it's what we consider a performance based
     approach, because we are looking at it in terms of the
     performance of the operators -- can they perform the tasks
     within the time required based on the simulator examinations
     and that builds in those thermal hydraulics and physics.
               DR. APOSTOLAKIS:  There is a mechanism, formal
     mechanism, for handling these things, these situations?
               MR. PERSENSKY:  Yes.
               DR. WALLIS:  Now if I applied defense-in-depth, I
     would say, well, I have to look at the contingency that the
     operator doesn't do the right thing and therefore I put in
     some other thing to back up in case the operator screws up.
               MR. PERSENSKY:  Correct.
               DR. WALLIS:  And you are saying we don't need
     anything like that?
               MR. PERSENSKY:  That is part of the analysis that
     they have to do in their FSAR in terms of do they have
     defense-in-depth.  That is all part of building up --
               DR. WALLIS:  Yes, but this wonderful
     defense-in-depth that we invoke is there because you are
     uncertain whether something will really happen the way you
     thought it would.
               DR. APOSTOLAKIS:  Well, if you are a
     structuralist, you don't need any analysis.
               DR. WALLIS:  I am not an anything.  I am just an
     independent thinker on defense-in-depth.  I have been told
     it's a good thing to think about.
               DR. BONACA:  Many of these transients are --
               DR. WALLIS:  So you are going to tell us that you
     have enough assurance that the operators will do the right
     thing, you don't need a backup system of any sort?
               MR. PERSENSKY:  No.  This is not addressing a
     backup system.  This is addressing the system that would
     replace operator action.
               DR. WALLIS:  Well, you could have a backup --
               MR. PERSENSKY:  And in the backup systems --
               DR. WALLIS:  -- if they haven't done it by a
     certain time it happens by itself, sort of.
               MR. ROSSI:  Let me just try something here and see
     if this helps.  The nuclear power plant is designed and in
     the design they automate some things and they make some
     things require operator action when they do the initial
     design, so the design is done and then they have to do a
     series of analyses of that design to show what happens
     during various transients and accidents.
               We have a deterministic way now which we are going
     to change to a risk informed way of doing that, but we go
     through the analyses and we take single failures and we
     assume various things and we assume that the operator will
     do the actions that are required to be done by operators in
     the analyses and we show that given all of that the plant is
     safe.
               The next thing that happens is the plant gets
     built.  They build a simulator that is very, very similar
     and there are requirements on how similar and good the
     simulator has to be that simulates the actual operation of
     the plant, and then we have the operators who are going to
     run this plant and they get run through the simulator, they
     get run through the testing program.  Well, first they get
     trained on what they are supposed to do, and then they get
     tested on the simulator and they have to pass that test in
     order to get their license.
               As a matter of fact, I guess we take other actions
     if we find that a large number of the operators can't pass
     the test during a period of time -- then the utility is on
     the spot for looking at their training program, so the point
     is that they get tested and then they get retested and
     retrained from time to time.
               MR. PERSENSKY:  It is a continuous process.
               MR. ROSSI:  Right.
               MR. PERSENSKY:  The requalification process,
     especially for the operators, requires that they go through
     certain testing -- training and testing continuously, most
     of them on a six week basis, and each one of those includes
     some time in the simulator, and at each -- they may not get
     tested on every one of the scenarios every time, but there
     is a sample of scenarios that they go through so that there
     is -- again, what we are looking at is are we confident,
     reasonably assured, that the operators can handle the tasks.
               That, the plant requires of them.  And if they
     can't, if none of the operators can, the we're going to shut
     down the plant until they can make that happen.
               MR. ROSSI:  Or even a large percentage or a
     moderate percentage.  If they are having difficulty getting
     their --
               MR. PERSENSKY:  If they don't have enough people
     to staff the plant because they can't accomplish the task.
     Let's face it, this happened in 1978, and we have yet to
     shut down plants because of that.
               DR. WALLIS:  I understand all of that.  It just
     seems to me that one could still realize that human mistakes
     are one of the major causes of a screwup at a plant.  Do you
     have any backup system if they do this?
               And that would be the idea of defense-in-depth.
     You're saying that they're so well trained, nothing is going
     to go wrong.
               MR. PERSENSKY:  No, there are things, and I'm not
     saying that.
               MR. ROSSI:  I was going to say one other thing,
     and that is that along the road, the emergency operating
     procedures have been designed.  We've got a philosophy on
     how they ought to be designed, and that philosophy is
     basically symptom-based emergency operating procedures.
               And they have a lot of the things that you're
     talking about, built into them.  The operators are supposed
     to look for the symptoms, and they're supposed to do certain
     things.
               And those are basically built into the emergency
     operating procedures, including, I believe, the use of
     backup systems where something doesn't work.
               And they get trained on those, again, and they get
     tested on them.
               MR. SIEBER:  I think it's important to think a
     little bit about what happens during an accident scenario in
     the control room, you know.  The plant is designed to
     respond automatically to the Chapter 15 design basis
     accidents.
               And the operator does very little except verify
     that all these functions have taken place.  And if they
     don't, then they try to restore that function.
               And the backup systems, however, come into play in
     a PWR, all the way down to the switch from ejection to
     recirc, which should -- at times can take an hour or so.
               And so the job of the operator is to monitor
     what's going on by looking at his control board, analyze and
     diagnose the accidents and know which branch he is on,
     depending on what his instruments tell us.
               So, if everything works in the plant, the
     operator's job is little more than reading instruments,
     verifying settings, flows, temperatures, pressures, and so
     forth.
               If you try to go beyond that and automate the
     backups when a failure occurs, that process becomes very
     complex.  And somebody would have to be knowledgeable, be
     there to intervene in case the actuation of some backup
     would interfere with the primary recovery of the plant.
               So I don't think that automation to a second,
     third, or fourth level is totally advisable, given the kind
     of training and the way the plants are automated now.
     Perhaps you can comment on that, but that's my experience,
     anyway.
               MR. PERSENSKY:  Well, generally that's the case,
     and that's where we get into some things that are happening
     now, though, in a sense, that some automated systems are
     being turned off.
               MR. SIEBER:  Okay.
               MR. PERSENSKY:  That's just not the purpose of
     this generic issue.  It's another step.
               MR. SIEBER:  Okay.
               MR. PERSENSKY:  But, again, the whole purpose of
     this generic issue was for the plant in the design process,
     to make a decision as to whether or not something should be
     automated.
               MR. SIEBER:  Right.
               MR. PERSENSKY:  And a basis for it was time, but
     it was time to do the work correctly.
               MR. SIEBER:  Right.
               MR. PERSENSKY:  And all we're trying to say here
     is that we have regulations or regulatory actions in place
     that allow us to know whether or not the plant and the
     operators are doing that, performing the job properly.  It's
     really, like I said, a performance-based approach.
               DR. WALLIS:  And you have a measure of those?  All
     you've said so far is qualitative, but you have a measure
     which is through some PRA technique that the system now in
     place --
               MR. PERSENSKY:  Can I get to that?  We're going to
     look at that in a minute.
               DR. WALLIS:  You need some quantitative criteria,
     I think, eventually.
               MR. PERSENSKY:  Well, we have a quantitative
     criterion in the sense, as we said, that operators have to
     be able to accomplish the tasks that come out of the task
     analysis.  It's a one or a zero from that standpoint.
               And that task analysis is a function-based, based
     on the functions of the entire system.
               DR. WALLIS:  But will they do it?  That's the real
     question.
               MR. PERSENSKY:  That's the basis of HRA, you know,
     what people will do when they're faced with different
     situations.  And that may be -- that's a topic, I think, of
     some other discussions where you have coming up next month.
               DR. BONACA:  But I am interested, however, in this
     criteria, in part because, although a lot of things have
     happened since TMI -- and I totally agree with your point
     here -- still at other plants, you have conditions
     occasionally where you have a new situation, and you're
     evaluating whether or not you can dedicate an operator to go
     somewhere, do something in 20 minutes, and would it be
     enough?
               Decisions are being made and criteria being used
     for licensing those, so I would be interested in hearing how
     you go about doing that.
               MR. PERSENSKY:  I think we covered a lot of things
     already.  What I've got on here is operator licensing, the
     licensing program, plant-specific simulators.  These are all
     things that have happened, again, since TMI, since this
     thing was initiated.
               Before B-17 was initiated, there may have been
     four or five simulators in the country, if that.  Now, every
     plant has its own simulator, people are trained on it,
     people are examined on it.
               It includes the functions that the operators have
     to deal with.  And we are involved with that process.  If
     they don't have enough people to do the exams or to carry
     out operations after exams, they may not operate.
               Ernie mentioned emergency operating procedures.
     Prior to TMI, we did not have the symptom-based emergency
     operating procedures; the symptom-based operating procedures
     were put into place after TMI.
               Back in the late 80s and early 90s, the agency
     actually went through and did a detailed inspection of
     emergency operating procedures at every plant.  I know in
     some cases, not all of them, this included -- well, it
     always included actions outside the control room, not just
     actions inside the control room.  So it's not just the
     things that are in the simulator.
               But we walked-down the procedures with them to
     make sure that, again, those actions could be accomplished
     in accordance with the procedures.  The procedures, again,
     are based on task and function analysis.
               These are the same kinds of things that we've
     talked about before:  The function task analysis, operating
     experience; these are all things that are built into the
     development of those procedures.
               And the staffing rule was put into effect in the
     early 80s, which, in fact increased the number of people in
     the control room so that you have more people to do the
     task, so that it increased the minimum requirements of
     people, if necessary.
               With regard to the PRA aspect of it, the IPE
     program, part of the IPE program was to go out and to
     identify vulnerabilities through the use of PRA techniques.
     Are there vulnerabilities out there that have to be dealt
     with?
               Licensees did identify and considered the
     time-critical safety-related operator actions as part of
     that process.  If, in that process, they found that there
     were problems, again, they were to go out and fix those
     problems.  And they could fix it with automation or some
     other way that would satisfy the Agency.
               There's a list of important human actions in NUREG
     1560, which is the lessons-learned report, so those are
     things that we are particularly concerned with.
               The primary scenarios are the switchover, which
     was mentioned in B-17; feed and bleed, and depressurization
     and cooldown.  These are the more important of the human
     actions with regard to the PWRs.
               DR. POWERS:  There is a lot of controversy about
     switchover of suction from the flow into the core.
               MR. PERSENSKY:  Yes.
               DR. POWERS:  Some of them are automatic and some
     of them are --
               MR. PERSENSKY:  Yes, in fact, I think all the CE
     plants are automated.  And there's a certain amount of other
     plants that are.  The issue -- and if we can step on to the
     next slide, really -- as you know, the burden is on the
     staff to demonstrate that the implementation of the generic
     issue meets the requirements of the backfit rule.
               We feel that, in fact, through this deterministic
     or performance-based process, we already have done that by
     saying we've got things in place; we don't need new
     regulations to deal with it.
               So we did not initially do our own cost/benefit
     analysis for B-17, and this was one that was specific to
     B-17.  But we did find that there was a cost/benefit
     analysis done for automatic ECCS switchover to
     recirculation, which was Generic Issue 24.
               DR. POWERS:  ACRS signed off on it.
               MR. PERSENSKY:  ACRS reviewed and signed of on
     that document, and it essentially said that backfitting from
     manual to semiautomatic system or fully automatic system is
     not justified under cost/benefit basis.
               So we're using that, since -- in fact, it's
     probably the most risk-significant of the scenarios that we
     talked about.  Now, Harold is here if you have any questions
     on that particular issue.
               Finally, on our conclusion slide, we find that
     there is both a technical and regulatory basis, because
     these are already regulations or requirements in place that
     we can close the issue.
               Most of these things have taken place since the
     promulgation of -- all of them have taken place since the
     promulgation of the GIs.  Plant-specific vulnerabilities
     have been identified in the IPEs, and part of that whole
     program was to then, based on those PRAs and IPEs, to
     address those vulnerabilities.
               I think this is a more performance-based approach
     rather than a deterministic approach to closing the issue
     and therefore we request a letter from the ACRS supporting
     closure of B-17.  Questions?
               DR. WALLIS:  You sounded to me pretty persuasive.
     The thing that gives me a little uncertainty is the human
     error part of it, of course.  Human error has been assessed.
     I just don't know with what sort of certainty it can really
     be assessed in a quantitative way.
               DR. UHRIG:  But isn't there some evidence that
     training has sort of reached a saturation point where the
     error rate doesn't go down any further?
               MR. PERSENSKY:  There is some evidence of that.  I
     think there is also a question of what to focus on in the
     training.  I mean we have been looking at that through the
     accreditation program with the industry, but there is some
     baseline human error probability.  What that is --
               DR. UHRIG:  So you may be getting there with your
     training.
               MR. PERSENSKY:  The contribution of training to
     that.  There may be other ways of reducing error or reducing
     the probability of error that aren't covered, depending on
     how effective is the --
               DR. UHRIG:  That is the question, yes.
               MR. PERSENSKY:  Yes, how effective are they, but
     human error is considered as part of the IPEs.  It was
     considered in the cost benefit analysis that was done for
     Generic Issue 24.  There are techniques out there that we
     are looking as an agency at improving techniques, coming up
     with better techniques -- as well as the industry as a
     whole, both internationally and here in the U.S. as to how
     to address that kind of problem.
               DR. BONACA:  I'm sorry, go ahead.
               MR. SIEBER:  That's specifically why the STA was
     put on shift.
               MR. PERSENSKY:  I forgot to add that one.  STA
     isn't on there.
               MR. SIEBER:  The shift supervisor or the SRO in
     charge is telling operators what to do following EOPs and
     the STA is supposed to be standing back to say is the
     diagnosis right, did they fail to do something that they
     should have done, or did they do something that they
     shouldn't have done, and so that becomes the second view or
     the defense-in-depth or the human error portion of the
     operating curve and, you know, what else can you do?
               DR. BONACA:  My question was to do with
     irrespective of the GSI and the closure, and I personally
     believe that the situation has changed today and you have a
     good position there, but there are still circumstances where
     people are dealing with having to make a decision on whether
     or not an operator action is adequate.
               If I can think about it, a recent example
     concerned with inadvertent actuation of safety-injection on
     PWRs where people have tried to resolve the issue of
     bleeding PORVs by isolating block valves, and now the issue
     is how do you deal with inadvertent actuation.  Do you have
     enough time to deal with it should you resolve the issue
     that way, and I know some utilities have proposed, in fact,
     that you have -- you can keep your block valve closed and
     with inadvertent actuation they are trying to demonstrate
     they have enough time.
               You are talking about maybe eight minutes or five
     minutes or whatever, and there is an issue of what
     information do the licensees and the Staff use to propose in
     fact a solution of that type and to accept on the part of
     the Staff a solution of that type.
               I would like to know what kind of information and
     I will tell you where I am going.  In absence of other
     information, they are going to still rely on this ANSI
     standard irrespective of the GSI closure, okay?  I just am
     interested in knowing what do they rely on, because they
     have to make these tough decisions.
               MR. PERSENSKY:  There are some NRR Staff here that
     may be able to address it more fully than I can at this
     point.  There is a Generic Letter 97-78 that went out that
     talked about just that kind of issue --
               MR. GALLETTI:  Information Notice.
               MR. PERSENSKY:  I'm sorry, Information Notice --
     the author is here, Greg Galletti -- and in that there were
     options, ways of doing it, in terms of describing it and in
     that document they in fact refer to ANS 58.8.
               What we are doing in addition to that -- this is
     the backup slide -- is that since we do have to review
     license amendments for this type of issue -- we have the
     Information Notice.  NRR has also asked RES to develop risk
     informed guidance for review of these license amendments.
               We have a draft inhouse.  It is under review at
     this point for that guidance, and it addresses a number of
     ways to approach it.  It essentially requires a
     site-specific as opposed to a generic analysis.
               MR. BOEHNERT:  Jay, can you move the slide over a
     little bit?  We can't see the whole thing.  Thank you.
               MR. PERSENSKY:  I'm sorry -- what are the actions,
     what is it that has to be done and it goes into various
     steps of how you would make a presentation or make a
     decision on that and how we would make a decision.
               For your information, because I know there's some
     concern about 58.8, at this point it cites 58.8 as a source
     for checking your plant-specific information, that you have
     to go through a process of determining the appropriate
     times.  The appropriate actions and to test them out on the
     simulator -- 58.8 is in this document, only as a way of
     looking at it as a sanity check or something like that or
     possible check, so that is the current status.  Again, this
     is still in review.  We have not necessarily agreed with
     that guidance.  When it comes to the point where I think it
     is ready for review we would be glad to bring it down to the
     ACRS for you review, but that is where we are on it.
               CHAIRMAN POWERS:  Okay.  I think it is unavoidable
     to not be interested in this because the history of ANS
     58.8, I mean in 1995 the database, the proprietary database
     that underlay 58.8 was old then --
               DR. SEALE:  Yes.
               CHAIRMAN POWERS:  -- has not gotten younger since.
     It was developed with older simulators.  It was developed
     with older sets -- I wonder how useful it is, though I guess
     I agree with you, Jay, it provides a pretty good framework
     for looking and saying how I did it and how other people did
     it, did I do it -- is there any validity.
               MR. PERSENSKY:  Well, it's how you do it and as
     far as the actual numbers -- I think the important part of
     58.8 was the formula or that timeline type of formula they
     established in there.  Here are the different parts of
     the --
               CHAIRMAN POWERS:  Breaking it down into cognition
     and action and things like that.
               DR. SEALE:  Yes, there is the question of the
     specifics of 58.8 and then there is also the question of
     what pedigree do we expect of something that has the status
     of a standard.
               CHAIRMAN POWERS:  They are two different things.
               DR. SEALE:  Yes, they are two different issues and
     we are interested in both.
               MR. PERSENSKY:  And it may be that ANS needs to go
     back and look at --
               CHAIRMAN POWERS:  Yes, ANS definition needs to go
     back.
               MR. PERSENSKY:  -- at anything new that has come
     up that we can use and improve the actual criteria that are
     in that standard.
               DR. SEALE:  Well, the thing before us now is even
     a third issue, and that is the resolution of B-17.
               You have given us your presentation.
               CHAIRMAN POWERS:  In summary, it seems to me what
     they have said is it's taken care of by all the other things
     that have gone on and if there is a plant out there that has
     some deficiencies in it, it is a plant-specific issue now
     and not a generic issue.
               DR. SEALE:  More than that, I think it is
     noteworthy that we have here an example of an issue that is
     now resolved on the basis of a legitimately made claim.
               That it's a performance-based resolution, and it's
     interesting, really, interesting, as opposed to a formula
     like AMS 58.8 suggested.
               Are there any other questions from any of the
     members of the Committee?
               DR. POWERS:  I guess the question that comes up
     immediately mind, though it doesn't have anything to do with
     this question, but it does have to do with operator action
     times and databases for those:  I assume those things still
     exist, and the issues still exist and questions and things
     like the ATHEANA code and like that.
               Are we doing anything to gather data in that area,
     or is that still a troublesome point?
               MR. PERSENSKY:  Well, we don't have a dedicated
     program to go out and gather that data.  We have been
     talking, for instance, with Halden about a lot of the data
     that they have from their simulator studies, and that they
     will be collecting in the future from their simulator
     studies, as to how we can best mine that data.
               DR. POWERS:  Yes.
               MR. PERSENSKY:  So that is one place.  As we get
     submittals for changes, if people are providing simulator
     data in those submittals that we can review, that can start
     building up further information.
               DR. POWERS:  I have always wondered, especially on
     the identification of a problem, how transferable data are
     from one culture to another.  The actual physical act of
     carrying something out, I bet is very transferable.
               But the problem diagnostic process, cognitive part
     of the process, it's not obvious to me that information from
     Finland is transferable to Japan.
               MR. PERSENSKY:  I think some of that data is.
     Whether it's all or not, we have not done a study in that
     way.
               With the -- you mentioned bringing up Halden is
     the fact that they have been doing everything in the past on
     the Finnish simulator with the Finnish operators, but they
     now have a PWR that's based on the Fessenheim plant in
     France, and they have access to French operators.  They will
     soon have a BWR simulator that will be based on the -- I
     think it's Barsebeck.  It's one of the --
               DR. UHRIG:  Forsmarc.
               MR. PERSENSKY:  Forsmarc, yes, in Sweden, which is
     very similar to a lot of other BWRs in Sweden.  They would
     have a lot of access then to Swedish operators.
               We have been making a concentrated effort to get
     more involvement of our U.S. utilities.  In that last EPRI
     meeting in Charlotte, the Halden people came to make some
     presentations, and there was a lot of interest in more
     participation from the utilities in that effort.
               But that is, again, one source of data.  It's one
     that we have probably more control over or more access to
     than the utility simulators.
               DR. UHRIG:  There have been some attempts to make
     this type of thing independent of cultures.  Specifically
     there is the EPRI work with the BWR in Formosa.
               The essence of what they did was to put in an
     expert system.  They found that the use of that really
     didn't help their best operators very much, but it did take
     the new operators and the average operators and bring their
     performance up to the best level.
               So, I think that type of thing is almost
     independent of a culture.
               MR. PERSENSKY:  The other aspect of it is that
     there are certain things that we can look at in other
     applications.  If we got data from FAA, though it may be a
     different situation, that there are still some things in
     terms of time to do something, whatever that action might
     be.
               And we are looking at cooperation with other
     agencies in those areas.
               DR. POWERS:  I would think that issues of
     complexity and things like that might have some
     transferability there.
               MR. PERSENSKY:  Yes, and it's interesting.
               DR. SEALE:  Okay, any other comments or questions?
               [No response.]
               DR. SEALE:  Does staff have anything else they'd
     like to ask?
               MR. ROSSI:  I don't think so, thank you.
               DR. SEALE:  Well, thank you.  I guess we'll have a
     draft of a letter here for folks to comment on shortly.
               MR. BORCHERT:  Jay, I need that last slide for the
     record, if you could give me a copy.  Thank you.
               MR. PERSENSKY:  Yes.
               DR. SEALE:  Mr. Chairman, I give it back to you.
               DR. POWERS:  We will recess till 11:30, and we can
     dispense with the transcript.
               [Whereupon, at 11:18, the recorded portion of the
     meeting was concluded.]
Page Last Reviewed/Updated Wednesday, February 12, 2014