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ACRS Meeting on the Ad Hoc Subcommittee on Differing Professional Opinion Issues - October 11, 2000


                             UNITED STATES
                     NUCLEAR REGULATORY COMMISSION
                                  ***
               ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
                                  ***
                  MEETING ON THE AD HOC SUBCOMMITTEE
               ON DIFFERING PROFESSIONAL OPINION ISSUES
     
                              Room T2-B3
                              Two White Flint North
                              11545 Rockville Pike
                              Rockville, Maryland
     
     
                              Wednesday, October 11, 2000
     
               The above-entitled meeting commenced, pursuant to
     notice, at 8:30 a.m..     MEMBERS PRESENT:
     
               DR. DANA POWERS, Chairman
               DR. MARIO FONTANA, ACRS
               MR. TOM KRESS, ACRS
               MR. JACK SIEBER, ACRS
     
     OTHERS PRESENT:
     
               MR. RON BALLINGER, Consultant
               PROFESSOR IVAN CATTON, Consultant
               MR. JAMES HIGGINS, Consultant
               DR. JOE HOPENFELD
               MR. ROBERT SPENCE
               MR. SAM DURAISWAMY
               MS. UNDINE SHOOP
               MR. JACK STROSNIDER
               MR. JACK HAYES
               MR. KEN KARWOSKI
               MR. JOE MUSCARA
               MR. STEVE ARNDT
               MR. JOE DONOGHUE
               MR. STEVE LONG
               MS. ANN RAMEY-SMITH
               MR. GARETH PARRY
               MR. CHARLIE TINKLER
               .                         P R O C E E D I N G S
                                                      [8:30 a.m.]
               DR. POWERS:  The meeting will now come to order. 
     This is the second day of the meeting of the Ad Hoc ACRS
     Subcommittee on Differing Professional Opinion Issues.
               I'm Dana Powers, Chairman of the Subcommittee. 
     ACRS members in attendance are Dr. Mario Fontana, Tom Kress,
     Jack Sieber.  Additionally, we will have Ron Ballinger in
     attendance as a consultant and a member of this
     subcommittee.  We also have Professor Ivan Catton, Mr. James
     Higgins, as invited independent consultants to the
     subcommittee.
               Welcome, gentlemen.
               The purpose of the meeting is for the subcommittee
     to review the technical issues contained in the differing
     professional opinion on steam generator tube integrity. 
     This review was requested by the Executive Director for
     Operations to assist him with the DPO resolution path.
               The subcommittee will gather information, analyze
     relevant issues and facts, and formulate proposed
     recommendations for the disposition of the technical issues
     contained in the DPO, as appropriate, for deliberation by
     the full Advisory Committee on Reactor Safeguards.
     The subcommittee will hear from Dr. Joe Hopenfeld and Mr.
     Robert Spence today.
               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 this
     meeting.
               Ms. Undine Shoop, a staff member who is assisting
     the panel, is also present.  We have received no written
     comments or requests for time to make oral statements from
     members of the public.
               A transcript of this 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 they can be readily heard.
               Do members of the panel have any comments they'd
     like to make before we start on the session today?     
               DR. CATTON:  Just one, Dana, particularly for us,
     too, because we won't be at your deliberations.  What sort
     of format do you want the report in?  This is something we
     talked about Friday.
               DR. POWERS:  Well, what I wanted to do, Professor
     Catton, is that before you leave on Friday, I would like to
     get an oral presentation of your initial thoughts, comments
     and whatnot.  I don't think we'll hold you to those, but at
     least what you think at that time.
               Then I'd like to get something in writing from you
     and I pretty much leave that to your discretion.  What we're
     interested in is understanding the contentions that exist,
     the data and analyses that exist to support those
     contentions from the staff and the author of the DPO.
               Certainly, the extent that you can put it in a
     here's the issue, here's one position, here's the other
     position, and here's what is available to support each side
     of this, especially when the data and analyses are not
     definitive, are the ones that are going to be the ones that
     are the most difficult for us to handle.
               Some of the issues, I think, will emerge that the
     case is relatively clear.  There is either no data, no
     applicable analyses, or there are data and applicable
     analyses in sufficient magnitude that the point is really
     resolved.
               I think those will manifest themselves very
     clearly.  I think the ones where especially decisions have
     to be made with a heavy does of engineering judgment is the
     ones that we're going to be most interested in what your
     comments are.
               Any other questions before we start?
               [No response.]
               DR. POWERS:  At that point, I think I'll turn the
     floor to Dr. Hopenfeld.  The agenda has various breaks
     listed in it, but since you're going to be doing the heavy
     lifting today, at any time you think you need to take a
     break or think it would be useful to take a break, just sing
     out and we'll declare one.
               DR. HOPENFELD:  Thanks a lot.  Good morning.  I
     would like to thank the members of the panel and their
     consultants for agreeing to resolve this differing
     professional opinion, also known as DPO.
               This DPO has gone unresolved for almost ten years
     and it is high time for it to be resolved now.
               I would also like to welcome the public for coming
     to this meeting to listen to my safety concerns regarding
     steam generators.  This is the first time that the NRC opens
     the door to the DPO process.  I welcome this change and hope
     that it will become permanent.
               I would also like to thank Dr. John Larkins, I
     don't see him here, for allowing me six hours for today's
     presentation.  I requested this much time because there are
     many subjects to cover, as Dr. Powers just indicated, and I
     want to make absolutely sure that all my concerns are
     clearly understood.
               Tomorrow, you will be able to judge whether the
     NRC staff addresses my concerns adequately.
               I believe that the likelihood for a catastrophic
     accident from defective steam generators is significantly
     higher; as a matter of fact, a hundred times larger than
     what the NRC predicts.
               This is the crux of the DPO.  That's all what I'll
     be talking today about.
               Ten years ago, several plants started exhibiting
     severe cases of stress corrosion cracking.  This type of
     corrosion is nasty, because it's unpredictable.
               Standard engineering practice is to select
     materials and environments that are not susceptible to
     stress corrosion.  Nevertheless, when an improper material
     selection is made, delaying the proper response is not the
     viable option, especially when the component degradation
     bears serious safety consequences.
               Instead of repairing defective steam generators,
     the NRC allowed these units to continue to operate without
     adequate safeguards.  The recent incident in Indian Point 2
     demonstrates that this policy is ill advised.
               Safety is very subjective.  At one time, I thought
     that it was safe to drive over a hundred miles an hour.  I
     do not believe so now.  Maybe a bad example, probably to my
     reflexes, but nevertheless.
               Because of this, the NRC set a standard which is
     based on the proposition that risk to the public must not
     exceed ten-to-the-minus-five core melts per reactor year,
     roughly once every thousand years.
               Since we cannot sense an impeding core melt, we
     must rely on inspection and engineering analysis to prevent
     such catastrophic events.  To be credible, such analysis
     must be based on a solid foundation.  Unfortunately, in the
     past decade, this principle has been replaced at the NRC by
     arbitrary judgments.
               My purpose today is to convince the NRC, with your
     help, that plants should not be allowed to operate with
     defective steam generators, as prescribed by the so-called
     alternate repair criteria, ARC.
               I recommend that all plants that currently operate
     under this rule be shut down and the standard 40 percent
     plugging rule be strictly enforced.
               These plants obtained their license to operate
     under the conditions that tube deterioration would not
     exceed 40 percent of weld thickness.  This must remain so.
               Toward this end, my job today is to pierce the
     veil that masks the alternate repair criteria to show you
     that it has no technical merit.
               I will be talking for the first hour about the
     process and the process, to a large degree, is related to
     the technical issues.  However, most of the day I will spend
     on the technical issues.
               In the fall of 1991 -- do you have a pointer, sir? 
     Thank you.  In the fall of 1991, the ACRS sent a letter to
     the Commission indicating that the 40 percent criteria for
     plugging tubes should be revised.  That 40 percent
     originally came from waste studies and the committee, ACRS
     committee indicated to the Commission that the kind of
     phenomena that we see now and that we saw then is different. 
     It's very shallow, very tight, through the wall or partially
     through the wall cracks, and those cracks are so tight that
     there is no -- one shouldn't worry about a tube burst
     because it really doesn't affect the strength of the
     material.
               Well, I thought that the ACRS overlooked one
     important factor and that was that under accident
     conditions, these very tight cracks can open up because of
     the various loads that will act on the tube.
               So under normal conditions, they're absolutely
     right.  There's nothing going to happen.  That tube is going
     to be safe and probably not going to leak.
               But these plants were designed for certain what we
     call design basis accidents and it became very clear to me
     that the load that you're going to have under these
     accidents are going to be such that all those little cracks
     or partially through the wall cracks are going to open up
     and you start losing inventory.
               Now, what I mean inventory, for those people who
     are not that familiar with the lingo, a reactor is really no
     different than a teapot.  As long as you've got water in
     there, it's not going to burn.
               But you start losing water and you uncover the
     core, then you get to a more severe situation, you melt the
     core.  The difference between the teapot and a reactor is
     that when the core melts, you can also burn the city.
               There's another subtle difference.  In the case of
     a teapot, you can hear the steam whistling.  In the case of
     a reactor, you may not, or when you hear the -- when you see
     the steam outside the building, it may be too late and the
     instrumentation that we have to warn you about the possible
     inventory loss is frequently not accurate enough or it could
     provide you misleading information.
               So I felt that you can have all these cracks
     opening up and you may have many, many pinholes or a lot of
     -- hundreds of cracks opening up and the total amount of
     inventory loss would be equivalent to more than one tube.
               Those that have some sea time or have been at sea
     heard stories about the chief engineer walking next to old
     pipelines with a cane, these little cracks, little jets
     emanating from small cracks could be very, very small, you
     can't see them, they could be very abrasive.  They could cut
     your leg.
               So it wasn't only the issue of losing inventory. 
     It's propagating that accident, and that was my concern at
     the time.
               There was another issue and it was really brought
     out by Professor Lewis that the instruments that we have
     have a certain limitation.  They can detect certain things,
     but there are limitations, and I do not think that the ACRS
     really emphasized that point.  They basically said go on and
     reevaluate that 40 percent and come up with something
     better, and they were absolutely right, but I thought it was
     an appropriate time at this to bring the point that it's not
     only the tube burst that is of concern, it's the total
     leakage and the other mechanisms to cause that.
               So we have, the NRC, a process called the DPV, DPO
     process.  It's a two-step process.  The first part of it,
     you bring your concern to the division level and if you are
     not satisfied with the reply, then you take it to higher
     authorities, the EDO.
               Just before I came down here, I read the Inside
     NRC, where the EDO is being quoted as saying "Well, that DPO
     process is not a resolution, it's sort of a consensus thing. 
     It's a disclosure."
               Well, when I wrote that DPV, my purpose wasn't to
     come and just raise flags.  I just expected a dialogue.  I
     was really concerned.  I thought we should look at it.  I
     didn't expect anyone to accept my views.  I expected, I
     think, really to approach it in a professional manner, take
     a look at the issue, and see what -- if the guy is crazy,
     just tell him so.
               Well, that's not what happened and now I can see
     what the EDO says, and I strongly disagree with what he
     says.  He says all you got to do is just tell us that you
     have -- that there is something there and then we'll decide
     what happens.
               Now, imagine yourself, you're on the assembly line
     somewhere in Akron, Ohio and working on the Firestone tires,
     and you find that the epoxy mix is wrong.  So you tell your
     supervisor and all the supervisor listen to you and you go
     back to the assembly line and that's about all that happens.
               And that's what the EDO tells you.  He tells you
     really you just tell us what happens and we'll take care of
     it.
               Now, I don't know of one case, of my own
     knowledge, that a serious safety issue has been resolved to
     the satisfaction of the submitter at the NRC.  What that
     really tells me that what he is saying, well, you just tell
     us and that really gives an appearance to the public that
     we're taking care of it or we consider what our employees'
     concerns are.
               Well, most professional people, when they have a
     differing professional opinion, they're driven by more than
     just presenting it.  They're looking for resolution, and
     it's a normal thing to do.  And what he is saying,
     basically, is I want dummies and so they want -- just tell
     us what the issue is and go away.
               I disagree with that kind of an approach.  I hope
     we can make it more effective than what the EDO claims.
               
               Well, anyway, going back to this, I wrote the DPV
     and submitted it through the channel and the next thing that
     happened was that the NRC came back to me and they told me,
     look, don't submit a DPO.  We ought to make a generic safety
     issue out of it.
               Well, during that time, though, before the meeting
     that we had regarding the DPO, there was another meeting
     with Congressman DeFazio, where the NRC management went to
     him and told him that we have done a lot of studies and we
     are ready to get -- at that time, Trojan was down because of
     these cracks and they told him we have evaluated the thing,
     there is no problem, we can get it up to power.
               Well, what they didn't tell him, they didn't tell
     him there was a DPV on the subject.  They didn't tell him
     there were allegation within Westinghouse that Westinghouse
     is providing misleading information to the NRC.
               The reactor went on-line, I think, somewhere in
     February, beginning of February.  When the Research
     Division, I think, at that time, the Director was Mr.
     Beckjord, he told me come up with a GSI.
               Well, as soon as he told me the GSI, my antennas
     went up.  The GSI is the program that was mandated by
     Congress in 1978 up at TMI and the purpose there was to
     address safety issues and resolve them promptly.
               But that's not what happened.  That program turned
     out to be entirely different.  It's being used, not to solve
     problems, to delay problems.
               If you look at your appendix, the last page there
     has a summary of all the generic safety issues since '83, I
     believe it is, where Congress mandated that we should keep
     track of them before, but we didn't have to keep track of
     those.
               What you see here is that it takes four and a half
     years to resolve a safety issue.  Four and a half years. 
     Some of those safety issues, which are really high priority,
     takes all the way to like 17 years to resolve them.
               Now, what does it say?  What does it state?  It
     states really that safety issues are not a priority item at
     the NRC, when you can work four and a half years on the
     issue.
               And another thing, and I can't give you the
     specifics on that, but you can get it, that many, many of
     these issues, the technical work was completed way before
     the closure date.
               And what does that mean?  That means it is being
     delayed by management.  There's just no other way to read
     it.
               So what you have, you have this GSI that is not
     doing what it was intended to do and if I were a
     Congressman, I would really like to know where my money
     goes.
               To summarize this table, this is a reflection of
     the safety culture at the NRC.  Anyway, being a good
     soldier, I went back and I wrote another report summarizing
     the various issues as I saw them at the time to get a
     generic safety issue initiated.
               The issues that I highlighted at that point were
     basically that under certain conditions, you will deplete
     the inventory or the refueling tank of water if the leakage
     from the primary to the secondary is large enough and that
     would lead to a core melt.
               And I have pointed out various mechanisms.  There
     was jet corrosion/erosion there.  There were vibrations,
     there was MSOB loads.  Basically, it didn't go in a very
     detailed analysis, but highlighted most of the main points.
               And I sent this thing to the Division of Research. 
     Well, they took that document and they set up a committee to
     prioritize this activity.
               By the way, John, you weren't here.  I would like
     to thank you for giving me six hours, because I am going and
     going and if I'm rambling too much, you are more than
     welcome to stop me.
               So I went back to the Research people and I gave
     them that package and they set up a committee to study this.
               The number, the risk that I came up with
     originally was ten-to-the-minus-four core melts per reactor
     year.
               Well, this committee had done a much more thorough
     study.  It was chaired by a very competent man, I believe
     the name was Dr. Burda, and he's not with us anymore, but I
     remember that there were a lot of serious discussions. 
     There was help from PNNL on this.  There were additional
     calculations.  They came up with a number like
     3.4-times-ten-to-the-minus-four.
               I think it's important, I'm pointing this out
     because I'm going to come back to this number later on.  So
     please try to remember this number.  Anyway, they also
     prioritized this as a high priority.
               In September 1992, I provided additional
     information.  I just didn't have enough time and I started
     it and that really relates primarily to severe accidents.  I
     never thought the severe accidents are as important as the
     design basis accidents, but, nevertheless, for completeness,
     I have provided that information.
               And, again, please, try to remember this, because
     I'm going to come back to that September 1992 later on and
     it becomes very, very important.
               Well, on November 9, Trojan shut down due to a
     tube leak.  Well, what happened, at that time, the press got
     a hold -- and I don't know how, but they got a hold of the
     DPV and some additional material, and they really went after
     the NRC for not disclosing that information before.
               So what happened, at this point, the generic
     safety issue, which was already identified as a high
     priority, went to NRR and Research asked NRR for comments.
               Now, Research doesn't have to go and usually are
     not required to get NRR's blessing on this, but they went
     and they sent it to NRR and NRR told them drop it.
               Now, at this point, for those people who are not
     familiar with how the organization or the NRC, I'll be
     referring to NRR and RES many times.  So I might as well
     tell you my perspective of who they are.
               NRR is very, very simple.  It's the regulatory arm
     of the NRC.  They basically think of as somebody has a
     licensing action, a relaxation or something else, they would
     come to NRR and they'll act on it.
               They are like the MVA.  I mean, say, if you want
     to change your license or you're blind in one eye and you
     want to still drive, you go to NRR and that's their
     function.
               Now, Research is a little bit different and the
     reason it's different is because the name research is very,
     very misleading.  You do research in industry to stay ahead
     of your competition, and in academia, you do research to do
     basic studies and produce Ph.D.s.
               Research here doesn't do any of that.  Originally,
     26 years ago, when it split from the AEC, the intent there
     was that they will do independent research.  In other words,
     when they develop all these computer codes, somebody will
     have an opportunity to take a look at the code and say this
     is an independent assessment of what the licensee is
     submitting to us.
               But that's not what happened over the years.  Some
     of these computer codes that NRC has developed were taken by
     the industry and modified here and there and they came back
     and resubmitted them and the action was taken appropriately.
               So it's not -- the independent assessment becomes
     very, very fuzzy.  Five or six years ago, in a constant
     surge to find the mission, the NRC management dictated the
     various divisions at Research that they should produce
     papers for review at high, good quality journals and they
     have to be peer reviewed.
               I don't know how many peer reviewed papers were
     produced.  I suspect not very many.  You can't dictate
     overnight and make people world class researchers.  Most of
     the people that came in have a different background.  They
     may be expert in many areas.
               So the point here is that the function of Research
     is really a support group to NRR.  Basically, that's what it
     is, and I just want to make somebody, especially from the
     public, who may feel -- or may get the impression that this
     is an independent research group.  It is not.
               Now, going back to January '93, remember, Trojan
     was down.  There was a lot of pressure on NRC to explain,
     provide justification for getting that plant back on-line,
     and I remember the Research Division produced several memos
     and none of them really went very far.
               Then Mr. Beckjord pulled Mike Mayfield, Mr.
     Mayfield from Christmas vacation and, in two weeks, asked
     him basically to put an assessment on the Trojan to justify
     operation, future operations.
               So we have -- here is somebody from the public. 
     I've been referring to the public several times.  I didn't
     know how many people were from the public, but we've got
     another one there.
               Anyway, so Mike came in and in two weeks produced
     a very, very impressive package about the analysis of the
     cracks in Trojan, and he had concluded that the leakage
     would be between 33 to 1350.  The risk was acceptable and
     the mean here was about 145 gpm.
               Now, that went out on the street and one thing
     that I think the Research people forgot is that if you have
     a mean leakage of 135, there may be no risk to the public,
     but you cannot meet Part 100.  There is just no way that a
     plant can meet a 145.  You need maybe somewhere between one
     to ten gpm, depending on the site.  You may meet Part 100. 
     But there is no way that you could be within the law and
     meet 145 gpm.
               The people, at that time, were very, very -- at
     NRR -- were very, very concerned about this, but it became,
     to some degree, academic, because the Trojan management
     decided -- and there were several reasons, because of the
     cost of electricity and they were able to buy electricity
     from Canada, they decided that NRC poses too many problems
     here, there are just too many letters, memos running back
     and forth, and there was just too much uncertainty that
     businessmen cannot be exposed to, so they shut down the
     plant.
               It wasn't really a technical issue as much as a
     straightforward business, and I think these memos going back
     and forth didn't help it.
               The reason I'm showing you this is because later
     on I'm going to come back to this.  I'm going to come back
     to this number, because as you see, this two-week effort
     became later on an advance study.
               In February of 1993, we find additional plants are
     being allowed to operate with degraded tubes.  In April,
     Congressman DeFazio was very much upset with NRC that they
     didn't tell him originally that there were disagreements. 
     So he wanted to know what was going on here.
               They just misled him, that's basically what he
     said.  You come in here and tell us that we don't have any
     problems.  Then I find out that you do have problems.  He
     didn't think that he looked very good in front of his
     constituents.
               So NRC made a presentation and basically told him,
     look, we're going to be very tough on the industry.  And one
     thing I remember Congressman DeFazio said, look, you're
     taking everything what Westinghouse tells you, they are
     being sued.  These steam generators are defective.  They're
     being sued and all that you're telling me is that you're
     doing what Westinghouse tells you to do.
               That did bother me.  But nevertheless, we walked
     away, I happened to be at that meeting and when we got out,
     NRC indicated to him that we're going to be very, very rough
     on this thing here.  We have a lot of uncertainties.  One
     limit that we're going to set, we're not going to let
     anybody exceed one volt, and I'll come back to that one volt
     later on.
               Between February and May, there was a task force
     at the NRC and basically what the task force did was really
     trying to come up with -- explain away basically the
     voltage-based plugging criteria, which was really invented
     by Westinghouse.
               It was a rationale to allow people to operate
     steam generators with defective tubes.  That's all it was.
               Somewhere around mid-June, that activity was
     summarized in a NUREG report, NUREG-1477, which is still,
     however, in a draft form.  But all that work that was done,
     the purpose here was to set the foundation for rulemaking on
     defective steam generators.
               Now, this is very important, that NUREG report is
     very important because I'll be coming back to this, because
     it's continuously being used as a justification to indicate
     that there is no risk.
               So we'll go back to that NUREG-1477 and we'll take
     it apart in a technical way.
               In 1993, NRR management goes to the Commission and
     tells them that we have had hearings with ACRS, we are very
     much concerned about the -- so in November 1993, the NRC/NRR
     management went to the Commission and told them, look, we
     cannot -- we don't have the time, we don't have the
     personnel to deal with these steam generator issues on a
     case-by-case basis.  We want to make a rule and we want to
     set a rule on -- we have done our homework and we'll finish
     it within a year or year and a half, and the Commission said
     go ahead.
               And this was a major activity.  It was not a
     little thing on the side.  It was a major activity at the
     NRC.
               In 1994, before the rule -- during the rule
     activities, NRR decided that we need something as an interim
     and as an interim, they took the findings from NUREG-1477
     and basically translated it into a generic letter, which
     was, at that time, called Generic Letter 95-05, and one
     thing that was bothersome about that letter, bothersome to
     me, was that suddenly we find more relaxation.
               Remember back when they talked to Congressman
     DeFazio, they said we're going to go on one vote.  Suddenly
     we find ourselves two votes, and it looked like the door was
     open beyond that.
               And there were other technical issues with the
     NUREG and with the whole approach, especially in connection
     of dose releases to the public violating Part 100.
               So I wrote a DPO and the reason is remember when
     they originally told me to go and write the generic safety
     issue and forget about the DPV, they didn't know how to
     dispose of that DPV.  So that DPV was still active.
               The standard procedures are that when you submit
     the DPV, they are supposed to take an action within 30 days
     and give you a response.  All they told me was go and write
     a GSI and you don't know what that meant.  That meant let's
     not do anything, and that table says that.
               So I felt that I should submit a DPO, take it a
     notch above the division level, take it to the EDO, and
     hopefully that would be addressed.
               Well, before the DPO was going to deliberate on
     it, he thought that I ought to present this thing to the
     ACRS, and let's see what the ACRS has to do -- has to say
     about that.
               So ACRS had a meeting, I believe it was September
     1 or somewhere around there, and they had endorsed that GL
     95-05 as an interim measure and recommended that the SG,
     steam generator issue be addressed via rulemaking.
               I'd like to take a little bit of time about this. 
     Now, the Commission takes very seriously what the ACRS
     recommends.  They should.  They are highly knowledgeable,
     but they are limited in the time that they can spend on
     these issues.
               So they rely on what the NRR people or Research
     people tell them.  They take it on face value many times. 
     They just can't go and look at what's underneath it.
               Well, let me just go, just to refresh -- I hope I
     can get it right.  I think it is right.  Can you see it
     well?  If you can't, I'll have to tell you what it is. 
               You remember I told you that we spent a month,
     Research spent a month coming up with a risk assessment back
     in March and they came up with a number like
     3.4-times-ten-to-the-minus-four.  I came up with
     ten-to-the-minus-four.
               This number really concerned the ACRS very much. 
     I remember they were really shaking their heads and trying
     to find an explanation, what happened here, how do you
     justify this.  You have a generic safety issue with a high
     -- this is more, this is orders of magnitude, order and a
     half magnitude, from what the Commission guidelines,
     although the Commission guidelines at that time were not
     definitive.  They were still thinking about it.
               Nevertheless, it bothered them.  It really --
     another thing that bothered them, and I'll show you on the
     next page, was how the staff calculates how they meet Part
     100.  That really concerned them.
               Well, so when I'm making this presentation, and I
     had only five minutes basically, Mr. Mayfield interrupted
     me, Mr. Wong interrupted me and they came in and they said
     now, hey, we have done advanced studies.  You see, we have
     done advanced studies here for 1477, which we'll go back,
     again, we'll take those advanced studies into pieces and
     we'll show you what advanced studies they mean, and we have
     done also very serious studies for Trojan and all those show
     that these numbers are way too conservative.
               We also believe, and if you can read over the
     wording here, it's kind of difficult to exactly understand
     what they mean, but you get the impression here that the
     ACRS believed that those tubes, also this discussion related
     to the outer diameter stress corrosion cracking in the
     support plates, and those support -- the cracking is
     confined to that region, and they felt that the fact that
     those tubes are confined to that support plate, it gives you
     additional safety.
               In other words, they gave you the impression that
     these tubes are really constrained by that support plate. 
     There is nothing further from the truth.  These tubes are
     going to go all over the place.  The support plates and the
     tubes are going to get divulged very fast when you've got
     this big blow-down, and we'll discuss that later on.
               But nevertheless, that's what the ACRS -- that's
     what the impression that, oh, this study was just like done,
     some kind of a second cousin kind of approach; well, you
     know, did some scoping studies.  We've done some very
     serious studies here.
               Now, why am I telling you all this?  I'm telling
     you all this because later on, the NRR went to the
     Commission and probably to the public, and to the public,
     using the ACRS as the justification to operate these
     defective steam generators.
               In other words, ACRS was the rationale and the
     ACRS did provide the rationale, that's true, but I'd like to
     remind you -- I'd like to provide you -- I hope I've got
     these things right.
               I'd like to remind you that the ACRS just did tell
     them go ahead and tell the Commission that everything is
     okay, go ahead and justify some of these things.
               One of the things that really bothered them, and I
     believe that Dr. Powers remembered that very well, because
     he brought up that point, justified the dose -- how you
     calculate the dose releases and he even submitted an
     analysis by himself, and I thought it was a good start.
               And another thing that you see here, the word
     interim, interim approach.  It was just not permanent.  It
     was an interim.  I don't know what the word interim means. 
     It could be between now and eternity, but what it really
     meant behind, I believe it meant within the context of what
     happened there, context of that time, what it really meant
     was that we are working on the rulemaking and we're talking
     about a year or two or three.
               Well, I'd like to tell you, this thing is a
     permanent feature now.  There is agreement about to be
     signed with NEI and this is part of it.  You don't hear any
     interim, but you do hear from NRC management that we went
     through the public, we got public approval on this.
               Yes, what they got public approval on was on an
     interim basis, because that's the only thing the public
     knows, that there was an interim approach here and they were
     working on it.
               Well, I'd like to -- since I brought this issue of
     the advanced studies that Research has done, and that was
     the reason, partially the reason for the ACRS agreeing or
     going along with this, this is a memo or a letter from one
     of the participants, basically, I believe, it's
     Westinghouse, one of the participants of the task force
     during the preparation of NUREG-1477, and what the expert
     says here, he says that the model or the way the 32, the
     thousand gpm was calculated and the risk, this is -- here is
     the key word -- an arbitrary estimate.
               So here we have an expert, not Hopenfeld, but an
     expert tells them that this is not an advanced study.  This
     is very important, because I feel that the ACRS is, to some
     degree, being used here as a tool to go to the public and
     say, yeah, we've got ACRS looked at it, but they never tell
     you what were the caveats behind it.
               Okay.  Now, on May 20, 1997, we are jumping three
     years. Remember that DPO is still there and the NRR
     continuously tells the Commission that we're working on it
     as part of that rulemaking activity.
               DR. CATTON:  Joe?
               DR. HOPENFELD:  Yes, sir.
               DR. CATTON:  That excerpt from a letter you put up
     there, that was a letter from Westinghouse to who?
               DR. HOPENFELD:  This was not a -- okay.  During
     the -- we spent three months preparing that NUREG-1477. 
     During that time, Westinghouse was making a lot of
     presentations regarding what should be or shouldn't be in
     that NUREG.  One thing, they wanted to keep the voltage very
     high, but basically everything what they said was included
     in the NUREG.  
               That letter -- well, as part of this deliberation,
     there was discussion regarding the research model and
     evidently the Westinghouse people felt very strongly that
     that model was just an arbitrary thing.
               And my point in bringing this model here was only
     to show you that what was referred to in the ACRS letter is
     an advanced, a better study compared to what was there on
     the record, really wasn't really that, because their own
     experts or some other experts really indicated the same.
               MR. BALLINGER:  Excuse me.  Is that Emmett Murphy?
               DR. HOPENFELD:  Emmett Murphy, yes.  It was just
     an informal note and my point here really, it's not any
     formality of anything, but my point here is just to indicate
     to you that I wasn't the only one questioning it. 
     Westinghouse questioned that, too, that this was not some
     kind of an advanced study.
               But nevertheless, on the record, and that's why
     the ACRS agreed that this was one advanced study and there
     was another advanced study that's in the NUREG-1477, and Mr.
     Wong was talking about and we'll talk about that later.
               So somewhere in 1977, mid-1977, the -- well.  I
     believe that you have the -- I believe that one of my
     transparencies disappeared here, so I'll just talk off the
     top of my -- what I remember.  I probably misplaced it or
     something.
               But before -- I'm terribly sorry about this.  Let
     me go back and I'll go by memory.  Oh, thank you very much. 
     I think page five here.  Yes.
               Page five, for some reason, came out in my
     transparency.  On break, I could take it, but you can look
     on your page five and we'll go through this.  I'm terribly
     sorry about that.
               On May 20, 1977, the NRR informs the Commission
     that they have discovered potential failures during severe
     accidents and, therefore, they would like to drop the
     rulemaking activities and, instead, go and resort to a
     generic safety issue, GL-95.
               Before they informed the Commission that they had
     problems with the rulemaking, six months earlier, the NRR
     management went to the Commission, and I thought I had
     another viewgraph to highlight that, maybe I didn't, they
     informed the Commission that they are just about to get the
     rulemaking out and this is going to be a precedent-setting
     rule, it's going to be a backfit.
               However, six months later, they go to the
     Commission and they said there is no cost-benefit in doing
     so.
               Now, imagine yourself being a CEO, you're going to
     the board and you said I have a new product here and I need
     some money to work on it.  You work on it for three years
     and just about when you finish, you say everything is okay,
     the trucks are ready to deliver.  Four months later, you're
     telling I just found out that the bottom line is not there
     and, therefore, I've got to drop all the rule.
               In between, while the activities under rulemaking
     were going on, there was a resentment on the part of the
     industry that they felt that the rulemaking was too -- the
     rule itself was too complicated and there was an indication
     that they didn't like it.
               So we now find that suddenly the rulemaking is
     dropped and the rationale that's provided, the rationale is
     that we found some new problems with severe accidents.  One
     of the problems that was alluded to was this jet that I told
     you before affecting the adjacent tubes.
               So now we find an excuse.  Now, mind you, that
     back in September 1992, there was -- on that DPO, there was
     a discussion on the severe accidents, where I have very
     clearly indicted there is a potential problem there.
               So here NRR is working for three years on this
     major activity and telling the Commission everything is
     okay, but then six months later, suddenly disappears.  Now
     we've got to work on something else.  We're going to start
     on a generic letter, which is a much lower -- has a much
     lower hierarchy in terms of its importance.
               So they get an okay to work on the generic letter
     and there's a year of activity on that letter and it went
     through -- it was so complicated, nobody could understand
     and NRR people couldn't figure out what it was.
               So finally they decided, well, we're going to drop
     that and we're going to a regulatory guide.  Now, in June
     1999, this regulatory guide, by the way, went for public
     comments in the summer of '99 and in June, the industry
     requested -- they had a whole list of comments and rationale
     that NRC dropped the regulatory guide and the NRC did.
               So we have, since 1993 to June 1999, activities
     going on relating to all kinds of safety issues regarding
     steam generators and what do we have, what's the bottom
     line?  Nothing.  Nothing comes out of all these studies.
               Now, we start working together with the industry
     to come up with an agreement.  Well, the industry didn't
     want any of that stuff to begin with.
               So in June 1999, we, again, repeating it, we, the
     regulatory guide is dropped out and you have a whole new set
     of regulations that are being discussed with NEI and I
     understand that the resolution or the agreement is planned
     for the beginning of next year.
               Meanwhile, while all these activities are going
     on, nothing really says much about the DPO, except it went
     for public comments and when it came back from public
     comments, the NRR people made further changes in their
     assessment of it and basically that's where it stands today.
               Meanwhile, while all these activities go on, we
     see there are another 17 reactors, as of June 1999, allowed
     to operate with degraded tubes.  We've got all these
     assessments going on, but the bottom line is 17 reactors
     operating not in accordance to the safety rules or the
     safety guidelines that the Commission had set.    
               At this point, where nothing was happening --
     well, there was one thing happening which I thought was
     very, very significant.  Farley came in here for a
     relaxation.  I think it was to allow them to operate without
     a mid-term inspection or mid-cycle inspection.
               Now, Farley was very, very significant.  It was
     the first time, it was the first time that the proposition
     was that if they come in for a relaxation, they would have
     to do it on the risk -- under the new policy of risk-based
     regulation.  So they would have to use some kind of a risk
     justification. 
               One comment that came from the industry in June
     1999 was that we do not want to or we do not know how to
     assess severe accidents.  Take it out.  We don't know how to
     handle that.
               Well, the NRR feared very strongly that they
     should assess the severe accidents.  So they told them if
     you want relaxation, you better come back and address the
     issue of severe accidents.
     So suddenly, three months later, Farley comes back and makes
     an assessment regarding the -- or talks about the severe
     accidents, and the staff writes a report and says we believe
     that there are no problems.
               Well, one problem that came up was going back to
     this jet issue, the staff found out that if you have very
     small cracks, which you cannot detect, they still could
     cause you a potential accident propagation during severe
     accidents.  They neglected that aspect of design basis.
               And Farley evidently had a potential for small
     cracks.  So they said, well, we believe that there is no
     problem.
               Now, think about this for one second.  Just think. 
     The severe accident is a very complex scenario.  It's
     extremely complex.  Most people cannot -- it's being used to
     analyze things.  You don't design for it.    
               Well, here the staff tells you that they believe
     that there is no problem, and they have experience.  They
     understand it.  But what is your experience to tell somebody
     that certain cracks are not going to be there during this
     very, very complex scenario?
               My answer is none.  And this is important, because
     we're getting into this phase of risk-informed regulation
     which can be very, very subjective and it can be abused, and
     I think this is a very good example where you have a
     problem, you identify the problem, the people identify a
     problem and then when you have to take an action, say, well,
     we believe that there is no problem and that's enough, and
     that's sufficient to pass and get that plant operational.
               Now, I am not arguing about severe accidents.  I
     personally am not sure that it should be there.  But if the
     policy is to include severe accidents, then this is a
     concoction of a story.  This is just -- so I write a letter
     to the EDO and the only reason I wrote a letter to the EDO
     at this point was because it set the precedent for how we
     deal with risk-informed regulation.
               If there is no seriousness behind it, then
     risk-informed regulation is just a joke.  That's all it is,
     and that's the reason I thought I would just voice my
     opinion.
               The reply I got from the EDO basically said, well,
     just we believe that the staff knows what they're doing. 
     And as the EDO knows, they have the insight and experience
     about severe accidents, and I don't know, we haven't had
     many, but they know what's going to happen there.
               Now, as we go along, I will show you why this is
     complete nonsense, because these reactors were not designed
     for these conditions.
               Okay.  I would like to give you my own perspective
     on this.  I realize that at 40 percent through the wall
     criteria, which has been around from day one, imposes heavy
     financial burden and we have tried now for ten years to come
     up with something better or something different and we
     haven't been able to.
               So you must conclude that if we haven't come up
     with anything better, that we should still go back, that we
     should go and retain that 40 percent.  It does have some
     theoretical basis to it, maybe very little, because we don't
     experience -- this is for corrosion, but the probe, the eddy
     current probe has a limited sensitivity and some studies
     show that it's really limited to 40 percent.
               So there is some rationale, whether it's -- it has
     served us well.  That doesn't mean that it solved the
     problem, but it served us well and we cannot go now and
     experiment with something that we don't know what we're
     doing.
               So the other thing that you get from this several
     years of experience, what you get is that what the industry
     wants is that they would like to have an infinite -- not
     infinite -- wide margin of freedom as to decide which tubes
     to plug, which tubes not to plug, but, at the same time,
     they want the NRC approving it.
               So when Con Edison got stuck recently, the first
     thing, they went and said, well, you know, we were right,
     NRC approved it.
               So there is an interest on their part to have the
     NRC ultimate say-so, yet they want to run the whole thing
     and they are.
               Now, if you look back, again, the decision of
     leaving these degraded tubes in place, allowing these steam
     units to operate, continue operating with degraded tubes was
     made back in 1992, early 1992.
               We didn't have any data at that time.  I'll take
     it back.  There was very little meager data that came from
     Westinghouse, very, very little.  But there weren't any
     different -- I'll give you analogy.
               If you're taking Firestone tires and putting them
     on a tricycle and look at the data, that's what we had.  So
     now the management, they grabbed that.  It was there.  They
     took that and they said, okay, we believe this is safe
     enough and we'll just let it operate.
               And they built a machine, put in place a machine
     and they hired people that shared that vision.  Most of
     those people are not here anymore, but some of them are
     here.  So the thing is still moving, but there's no
     difference as far as this belief that we can operate safely
     with those cracks.
               Now, again, safety is a very subjective issue and
     it could be very well that you can operate this for a
     thousand years, but that's not what are our guidelines.  We
     operate on the basis of risk, and my purpose here today, and
     I'll go to the nuts and bolts of this to show you where the
     risk is.
               Okay.  You have to have some kind of a rationale
     when you replace something.  You have to say, well, I've got
     a better mousetrap.  So going back to early '92,
     Westinghouse invented what's called voltage-based plugging
     criteria.  In other words, we're not going to measure the
     thickness or not going to base our plugging based on that 40
     percent wall thickness indication or degradation.
               We are going to base this thing on the basis of a
     model.  But if you trip down everything what they say, it's
     a strictly unproven theoretical model.  That's all it is. 
     There is nothing else behind that.  It's an unproven
     theoretical model.
               So you look into that now, what's behind it. 
     First, it's very nonscientific.  This is very easy to --
               DR. KRESS:  Joe, is it all right to interrupt you?
               DR. HOPENFELD:  Yes, sir.  Please, interrupt me
     anytime, because it's easier for me if we talk and if I lost
     one slide, I'll go and look for it.
               DR. KRESS:  When the ACRS reviewed the
     voltage-based plugging criteria, I think their view was that
     it was strictly an empirical model, without any real
     technical basis behind it.
               Although they didn't -- the ACRS, as I recall,
     didn't have real problems with the empirical model.  Their
     problem was do you have enough data to support an empirical
     model and is that data covering the ranges of things of
     interest, such as the pressure difference, the crack size
     and the crack characteristics.
               So I wouldn't call that a nonscientific model.  I
     would just call it an empirical model.
               DR. HOPENFELD:  Let me amplify that, because I
     understand that's -- going back to the letter you wrote to
     the Commission, that was your view.  My view, and I'll
     elaborate on that, I'll going detail and elaborate why I
     think it is nonscientific and why I don't think it's
     empirical.
               DR. KRESS:  Okay.
               DR. HOPENFELD:  It is not empirical.  It's purely
     theoretical.  Now, I'll tell you, to be more exact, you can
     -- some people refer to something like in the literature,
     you find references to this as semi-empirical.  Now, I don't
     know what semi-empirical means.  It's not -- let me put --
     I'll give you -- I'll go back.
               Sir, please notice this is my perspective and I
     call it analytical and I'm going to back -- I'm going to
     tell you why I think it's analytical.  It goes back to the
     crux of this voltage measurement.  Until we get there, it's
     difficult, but I understand that was your perspective and I
     disagree with that letter.
               DR. CATTON:  Joe, just to make a comment on this. 
     A very complicated area is interaction of fields with
     heterogeneous media.  As soon as this thing has cracks in
     it, it's a heterogeneous media, and a real simple example of
     how badly you can conclude what's going on is a simple
     device, a little heat exchanger.
               If you look at the literature on these kinds of
     devices for a heat transfer problem, which there it's the
     interaction of a temperature field with in-flow and so
     forth, you find, in the friction side of it, you'll find
     several decades difference, and the primary reason is you
     don't have the right variables in the equation.
               So what people put on paper is not really an
     empirical relationship that's any good for anything other
     than where the test was.
               So if you don't describe everything, and this
     means geometry, what the interfaces look like, everything,
     small changes can make huge differences in what you measure.
               And I think this is the same.
               DR. HOPENFELD:  Ivan, I'm really bringing you --
     I'll get to the equations of this, so we can see the
     parameters that play there, exactly what you're talking
     about and any feedback would be greatly appreciated, but
     that's exactly the bottom line.
               This thing is too complex to call it -- it's not
     semi-empirical, but we'll go back.  I'll grant you, there is
     some empiricism in there, there is some.
               I'm sure that you have gone through all the
     volumes of material, backup information, and you have to
     agree with me that there is a lot of statements there,
     assumptions that you don't know where they come from.
               The main -- another problem is that all these
     things can be easy -- the answer can be easily adjusted and
     I will show you that as we go along.  And the bothersome
     thing, extremely bothersome and makes constraints on us, is
     that a lot of that stuff is being stamped proprietary.
               Some of that is so obvious.  Obviously, there is
     no competitor that sits there and they're going to re-derive
     F equals MA.  But it is stamped proprietary and then you go
     back and you're trying to find what the references are and
     then you have these agreements and the stuff goes out for
     public comments.
               If I was in the public, if I had the time, there
     is no way I could follow what it is, because it's all
     proprietary.
               I am, to some degree, restricted in talking about
     some stuff, because I don't want to get in trouble with any
     of the lawyers.  So I'm restricted on giving you any
     numbers, but you have all the information in front of you
     and I will try to point out where the problems are.
               But some of the things, it's ridiculous to call
     this proprietary.
               Now, at this point, I think I'm going to start
     with the technical issue.  I mean, enough with the process,
     I think.  Unless you want to break, that's fine with me.
               DR. POWERS:  We are scheduled for a break.  Maybe
     looking ahead at the slides, this would be a good one to
     complete and then it looks like there is a nice place for a
     break on the next slide.
               I think, incidentally, that the committee is
     persuaded of your qualifications to address this issue.
               DR. HOPENFELD:  I'm sorry?
               DR. POWERS:  The committee is persuaded of your
     qualifications.
               DR. HOPENFELD:  I brought it for a different
     reason.  I brought it for two reasons.  Basically, one, I
     listed some in my statements.  I forgot to list here that
     I'm also on the ten most wanted at the NRC.  But that's not
     really --
               DR. CATTON:  The most important is the fourth
     bullet.
               DR. HOPENFELD:  Yes, that is kind of important. 
     We're about the same time we got out.
               DR. POWERS:  I think there's a conflict of
     interest here somewhere.
               DR. KRESS:  What does the UCLA stand for?
               DR. POWERS:  I thought USBC was getting all the
     Nobel Prizes now.
               DR. HOPENFELD:  I don't know about Nobel Prizes,
     but we had a pretty good football team when I was there.  I
     don't know what they're doing now.
               But anyway, going back to that, what I really
     wanted to -- the reason I'm really showing this is that I
     was personally involved in three different steam generators. 
     One was the element, the R steam generator, and there was --
     you had sodium on one side and you had water on the other
     side, and then I was involved in advanced fossil power plant
     for many years in the design for a program that I want to
     mention.
               But anyway, it's high temperature, high corrosion
     environment, and I was involved in several PWR testing for
     steam -- under steam line break and feed line break for the
     MB-2 program, which was really a prototypic -- the first
     time anybody took a prototypic steam generator, basically,
     and sliced from a steam generator and took a look at it.
               What I'm trying to tell you here is that these
     various steam generators have certain things in common, even
     though their operating conditions are entirely different.
               One thing, I remember spending years really
     arguing what should be the design basis for the LMFBR.  It
     was a hockey stick type of a steam generator, what should be
     the design; should we use one tube, should we use three
     tubes, should we use four tubes, and it was going on and on.
               You had all kinds of rationale for it and we
     finally came up with, I believe, it was like five, there was
     one in the center and the forest around it.
               About eight years ago, there was an accident in
     Dounray, Scotland, and you know what the -- the steam
     generator went.  Do you know how many tubes ruptured or got
     deteriorated?  Forty-eight of 50.  And now I can take the
     slide off, because that really was my main point here.
               What I'm trying to say is that when you do the
     design stage, you come up with your best estimate.  I hope
     that later on, I'll ask Mr. Spence to talk about that.  He
     may mention it.  We have a steam line break as a design
     basis accident.  That doesn't mean that a full steam line
     guillotine type break is the worst case.  It may not be.
               What I'm saying is there are uncertainties here
     and we shouldn't worship this.  And is that time to take a
     break?
               DR. POWERS:  Yes.  We'll recess till five after
     the hour.
               [Recess.]
               DR. POWERS:  Let's come back into session, and I
     will turn the floor back to Dr. Hopenfeld.
               DR. HOPENFELD:  Thank you.  I would like -- while
     I was flipping the pages before, one slide came out and I
     didn't notice that.  I'm not going to harp on this for too
     long.  I just want to make one point here.
               That there was a meeting of the ACRS in November
     1996, and the ACRS was echoing really industry concerns
     about this whole rulemaking thing.  The industry said we've
     got this ASME code that already takes care of it, and they
     were concerned about it.
               But as far as the DPO, I came back and indicated
     to you -- in fact, I even said that what was presented to
     you previously was really misleading.
               And at that time, I believe you stated to the
     Commission, the ACRS stated to the Commission that the NRR
     should resolve the DPO and the generic safety issue before
     they issue any rulemaking.  These should be resolved before
     anything else takes place.
               And that was the commitment that NRR, the EDO, at
     the time, made, that he is going to resolve the DPO and the
     GSI and this is going back to 1996.  We are four years
     later, where do you think the GSI is?  We'll tell you later.
               DR. POWERS:  It goes without saying, the committee
     has commented frequently on the pace of resolution of GSIs.
               DR. HOPENFELD:  Thank you.  Yes.  That is true.  I
     was trying to give you that data and I think there is much
     more to that data to extract for it and I think we can make
     it positive, but I really just wanted to highlight that four
     and a half years and the 17 years, which hits everybody,
     anybody that looks at it.  What's going on here?
               I'd like to give you a little bit of feel for the
     background, mostly for the public, and I may be boring you a
     little bit.  But the importance of this accident is really
     that you have a heat exchangers, with acres and acres of
     land, so there's a lot of surface area.  So there's a lot of
     problems -- there's a high probability that if you operated
     those with a lot of cracks, that something will go wrong.
               It's a very important component.  It's a
     safety-related component, because it -- remember, we have
     three barriers there for safety, cladding, coolant and a
     containment.  In this case, there's no containment.  You
     bypass the containment.  So you're losing a major barrier
     for safety.
               And there was an earlier study, I believe it was
     in the mid '80s, NUREG-0844, which concluded that really the
     steam generator is primarily -- it's a financial concern if
     you have -- it's not a safety-related component.
               It's primarily what drives the inspection and the
     maintenance of that is -- it has no really major safety
     implications.
               The thinking behind that was that if you operate
     with good steam generator tubes, there is justification.  If
     the unit operates all the time, you don't expect it's not --
     it wasn't designed to have major disasters, and that was
     correct.
               So the main difference in opinion between myself
     and NRR is that they believe that if you operate with
     degraded tubes, the risk is acceptable and the DPO position
     is not acceptable, as I said before.  It's the crux of the
     issue here.
               Now, what is this accident?  Most of you probably
     know.  You have, at a given time, at any given time during
     the operation, you may have a steam line break and if you
     have a steam line break, you depressurize the system.  Just
     like when you drive your car and the hose breaks and all the
     steam is going to come out.  You just depressurize all that
     inventory.
               And other accidents, we have two separate
     accidents which these plants originally were designed to. 
     They were designed for a steam line break or they were
     designed for a tube rupture, but not the two at the same
     time.
               So you could have a steam line break and you --
     there's no radioactivity escaping, except a minor amount,
     because the safety valves will isolate, but basically it's a
     -- the system is designed for.
               You also have a tube rupture, and, again, this is
     sealed, so you don't have an accident.  It's not part of the
     design basis.
               Now, when you operate with thousands of cracks,
     what happens to that design accident?  Originally, you
     assumed that those tubes are perfect just the way they came
     from the mill.  Well, they're not the same anymore.
               So now what happens is when you have that accident
     occurring, you depressurize the system and you put different
     loads on those tubes and suddenly you have all those cracks
     that you think that they are tight and sitting there opening
     up, and when they open up and if the operator cannot control
     that accident or cannot depressurize the system, then
     eventually you run out of water.
               This is your refueling tanks which keeps the --
     it's a storage tank.  Well, you can say, well, so what, big
     deal, you know, I ran out of water, I'll just go and get
     some few helicopters, I'll pump some more water in there and
     eventually I'll do something.
               It's not that simple and the reason it's not that
     simple is because this water has to be borated and if it's
     not borated, you run the chance of recriticality in the
     core.  So you can't just get any old water.  There are
     procedures you have to go and make sure it's borated
     properly.
               So that was the issue.  You see, it's a risk
     issue.  And that's what we'll be talking today in more
     specifics.
               So basically, originally, we had -- the plants
     were designed for a steam line break, main steam line break. 
     Okay.  That's what you design.  You don't worry about a tube
     rupture or anything happening at the same time.
               And these are basically the criteria for what you
     designed it to.  Then you design the plant to withstand a
     tube rupture, and, again, these are the conditions that you
     design to.  You can withstand a 600 gpm.
               However, there are differences.  Notice there are
     differences in what occurs during the transient.  In the
     steam line break, the depressurization is fast and,
     relatively speaking, the steam generator tube rupture, it is
     slow.
               For one parameter that comes into calculating
     off-site doses under requirements of Part 100 is to know
     what the iodine spike data is.  It's available for SDTR.  It
     is not available for a main steam line break.
               So my first presentation on the subject back in
     '92 or whatever it was, '94 maybe, I have indicated to you
     that if now we are allowing these plants to operate with all
     these cracks, we are not talking about steam line break
     anymore, nor are we talking about steam generator tube
     rupture.  We're talking about a different material.  We're
     talking about a different accident.
               DR. CATTON:  What is the MSLB/L?
               DR. HOPENFELD:  Main steam line break with
     leakage.  The L stands for leakage.  I'm sorry, I didn't
     make it clear.
               DR. CATTON:  You did, I just didn't look at the
     slide properly.
               DR. HOPENFELD:  And I outlined that, I circled
     that leakage.  So that is really the difference.  You have a
     fast depressurization and now you have more than 30 gpm
     coming out from the primary, and that depends on how many
     cracks open up.
               I claim I don't know how many.  Maybe none.  But
     there is a strong support for the proposition there would be
     many opening up.
               But, again, the point here is if the leakage is
     fairly small, the operator can take care of it.  There is no
     problem.  I don't want to scare anybody.
               But if the leakage is large, there are so many
     things happening, and we'll have an operator talking to you
     today, so many things happening here that you will -- there
     is a high probability that you'll melt the core, and it's a
     question of risk, because there is no way of absolutely
     saying that this will happen or not happen.
               Now, I have relatively an easier job than my
     friends at NRR, because I take the position when I don't
     know something and public safety is my main concern, I'm
     going to be conservative.  I'm going to err on the side of
     safety.
               Well, if they don't want to take that position,
     which is fine, I think the burden on them to come and
     explain to you all their beliefs, all their judgments, where
     they come from, who are those people, what's their
     background.  I think you're entitled to know that, because
     it's judgment.
               Okay.  The procedure to justify operation with
     degraded tubes is as follows.  The main assumption is that
     you are safe to operate if the voltage that the probe reads
     during the refueling outage, if the voltage reads, the probe
     reads voltages less than two volts, one or two volts, or --
     and here is the caveat that they have -- or higher, by
     special approval, and you know what that means.  It can run
     to anything, although they have been limiting themselves to
     three volts.
               Originally, they started with one, then it went to
     two, and now we're at three, but it can be more.
               Now, how do you decide what happens next is
     because these are the voltages during the outage.  Now, you
     really want to know what happens during the cycle, so you
     have to figure out what is going to be the voltage during
     the 18 months period that the steam generator is going to be
     in service.  That's called end-of-cycle voltage.
               Then you have the requirements or the
     specification says that you should be limited to 150 gpd,
     gallons per day, for operational leakage.  You're allowed,
     per steam generator, 150 gpd.  It used to be 500, now I
     believe it's 150.   
               But all that really says, and that 150 has been
     around for many years, it really has nothing to do with
     operating defective steam generators.  It's something that
     you can measure whether you exceed 150 or not.
               So it's an operational limit.  But then you have a
     limit of one gpm under steam line break conditions.  What it
     says is during a steam line break, you cannot exceed one
     gpm.  Now, you ask yourself, what kind -- can you measure
     that when you have a steam line break?  You can't do
     anything.
               I mean, you don't impose on somebody a condition
     where you can't measure, you can't control, you can't do
     anything with it.
               DR. BONACA:  Excuse me, a question.  So the one
     gpm is the one in the tech specs, right?
               DR. HOPENFELD:  That's correct.  But this is
     derived for the steam line break.
               DR. BONACA:  I understand.
               DR. HOPENFELD:  At that time, going back to my
     table, they were thinking in terms of good tubes.  They
     didn't have these degraded tubes.  So that one gpm, you
     could say, yes, it's a reasonable number.  But now we have
     all these thousands of different cracks and how are you
     going to dictate to them that they're going to stay with one
     gpm just because you want to.  That's exactly what they do.
               So the bottom line here is that -- now, the one
     gpm can even exceed it if the tubes are confined.  Remember,
     those support plates, the NRC believed -- or the NRR people
     who designed this believed these act like O-rings that will
     hold the thing.  Anybody with any design, has experience
     with O-rings, you know that that is not a -- even for a very
     simple component, it's not an easy thing to design.
               Dirt gets in there and motion, so they believed
     they're going to be so tight that the leak is not going to
     get out of the support plate region.
               So basically, if you look at this, if you really
     look at this and please think about this, before we had
     degraded tubes, we had basically the same specification as
     we have now after a degraded tube, after we allow them to
     operate with degraded tubes.
               Another thing that's very interesting is note that
     in the steam line break, there was one gpm, and I'm not
     going to argue whether it's one gpm, ten gpm, whatever that
     is, we had one gpm.
               Well, let's take a look at what happened at IP-2
     or other reactors that had experience with large leakage. 
     Well, the reactor -- the NRC said they shouldn't exceed one
     gpm and that wasn't under steam line break.
               If there was a steam line break, obviously, it
     would be much more.  So this, in a sense, this thing here
     has no meaning.  You can't measure it.  You can't do
     anything about it.  When that steam line breaks, we're going
     to have any leakage that the plant decides is going to
     happen.
               It depends on what the forces are going to act on
     the tubes and not some dictation by a regulation.
               But anyway, that goes back to this, to the risk
     that we're talking about.  NRC assumes that if they follow
     this procedure, this procedure will keep them from putting
     the public at risk at a higher than ten-to-the-minus-five
     per reactor year, which is the Commission guidelines for
     safety.  That's what says it's safe or not safe.
               Now, whether it's safe or not safe, I don't know,
     but that's the standard we have to live to.
               DR. BONACA:  Let me just ask a question, Joe.  At
     one gpm, however, it was -- it is a number which is tied to
     the dose at the site boundary.  It implies also one percent
     failed fuel, I believe, in the reactor.
               DR. HOPENFELD:  Right.
               DR. BONACA:  So I'm only saying that I don't think
     the goal was just the one gpm.  The one gpm is an assumption
     made in the tech specs that goes with the assumption of one
     percent failed fuel, and typically plants run with one
     percent failed fuel.
               DR. HOPENFELD:  I understand that and I'm going to
     discuss this.  But this is working, you want to make sure
     that you stay within Part 100, and that is true.  But so
     what?  It's still -- what drives this thing is not what you
     want, what the SRP wants.  What drives this thing is what
     nature wants.
               DR. BONACA:  I understand.
               DR. HOPENFELD:  So you can say, well, I've got
     this Part 100 and it says that I shouldn't exceed five gpm
     or whatever, but I'm just showing you that evidently the
     system is not interested what the NRC tells them, because if
     it was, each time you have a steam generator tube rupture,
     you wouldn't see 150 or 200 or I think they've gone as high
     as 600 gpm.  You wouldn't see that, because this thing
     doesn't allow that.
               DR. BONACA:  That's the question, because thinking
     about the --
               DR. HOPENFELD:  I understand where it comes from.
               DR. BONACA:  The actual limit is there.  So in our
     estimating that, we have to take account of leakage,
     whatever that is.  I agree with you.  The one gpm just was
     an assumption there.
               DR. HOPENFELD:  But I understand the assumption
     and I think it's okay if you stay within what we were
     talking originally, a steam line break.  But that's why I
     put the thing in the third column there.  We are not talking
     about steam line break.
               Unless you can show that these cracks are going to
     stay within that region, and that's probably what they're
     trying to say and that's what's going to be -- we can argue
     it.  That's why I'm bringing all this at this point, so
     we'll focus in on that issue.
               So there is a need to fix this.  If you want to
     operate with cracked tubes, you fix this one, because either
     you can measure it -- if you can predict it, fine, but the
     issue is can you really predict it.
               DR. BONACA:  I don't want to belabor it, but, for
     example, I could say, okay, I am going to fix the amount of
     allowable failed fuel not to one percent, but to one per
     thousand and then I allow a larger leakage.
               DR. HOPENFELD:  Right.
               DR. BONACA:  I'm trying to point out that that
     number was part of a product that ended up with the dose
     leakage.
               DR. HOPENFELD:  You're absolutely right.  Look, if
     you can have perfect fuel with no cladding cracking, it
     doesn't matter. But that's not the real world.  There is
     some cracking.
               It probably, and I don't know, it probably -- the
     lawyers probably got in there and it's probably in the
     warranties going between the fuel manufacturer and the
     supplier and the utility.  There's probably some verbiage
     there that the lawyers put in, but I'm not looking at it
     from that perspective.  I'm telling you this number doesn't
     mean a thing.
               DR. KRESS:  I'm not quite sure, Joe, I understand
     your last bullet on that slide.
               DR. HOPENFELD:  Which one, sir?
               DR. KRESS:  The last one.
               DR. HOPENFELD:  This one?
               DR. KRESS:  Yes.
               DR. HOPENFELD:  Okay.  The reason you have all
     this procedure of controlling how much leakage you're going
     to have or the rationale behind this is you don't want to
     exceed the ten-to-the-minus-five core melt per reactor year.
               
               If you were to say, well, if this is going to be,
     say, a thousand gpm, it could very well be that you will
     exceed the ten-to-the-minus-five, because the operator is
     not going to be able to handle it.
               DR. KRESS:  Okay.  There's more to it than just
     that procedure.
               DR. HOPENFELD:  Correct.
               DR. KRESS:  There's operational procedures and
     frequencies.
               DR. HOPENFELD:  That's correct.
               DR. KRESS:  So you're making --
               DR. HOPENFELD:  What frequencies?
               DR. KRESS:  The frequencies at which this main
     steam line break could initiate.
               DR. HOPENFELD:  Correct.  I'll go into that.  Yes,
     sure.
               DR. KRESS:  So you're saying there's a lot more to
     it than just those procedures.
               DR. HOPENFELD:  Yes, yes, yes.  Absolutely,
     there's a lot more to it.  This is ten-to-the-minus-five. 
     That's what they are saying.  That's their -- you see, the
     NRR people said we -- by doing this, we will guarantee the
     public that we are going to exceed that ten-to-the-minus
     five; we're going to have ten-to-the-minus-seven or whatever
     they said, six-times-ten-to-the-minus-six, and we're going
     to guarantee that.
               Now, how are they going to do that is going to be
     a subject we're going to be discussing this.  But this is --
     I'm trying to focus on the issue.  This is the issue of
     going back to what's safe is safe and the
     ten-to-the-minus-five is a number.
               In order to meet that number, they'll give you a
     rationale tomorrow why they meet it.  And I will give you a
     rationale today why they not meet it.
               Now, I have an easier job, because I can err on
     the side of safety and they don't want to err on the side of
     safety.  But don't let them out of here and tell them, well,
     we believe, because that's what they told you previously.
               DR. KRESS:  I was assuming that there were two
     relatively --
               DR. HOPENFELD:  Sir?
               DR. KRESS:  I was assuming that there were two
     relatively independent objectives.  One was to assure you
     didn't exceed the 10 CFR 100 doses and then there was
     another objective of not exceeding that value of risk, which
     has a lot of other things associated with it.
               DR. HOPENFELD:  Right.  I do have that in the next
     slide, we'll be talking about that.
               DR. KRESS:  Okay.
               DR. HOPENFELD:  I don't know whether you can
     divorce them.  In real life, I don't know how you divorce
     them.
               DR. KRESS:  They are related, of course.
               DR. HOPENFELD:  They are related.  I don't know if
     you can say, well, today, we're not going to exceed this,
     we'll stop as soon as we -- yes, if I had such a mechanism
     there, a shutoff mechanism that cuts me off as soon as I go
     over that one gpm, yeah, I'm okay, but I don't think we have
     anything like that, because nobody ever invented one yet.
               DR. BONACA:  I had just one more question, which
     is more to help me in the review.  You pointed out that
     clearly if you have large leakage rates, the success of the
     operator is much more questionable.
               DR. HOPENFELD:  Correct.
               DR. BONACA:  And it becomes even more questionable
     the larger is the leakage rate.
               DR. HOPENFELD:  Correct.
               DR. BONACA:  And I've been looking at some of the
     sensitivities, again, to make my judgment on, and I've been
     looking at this INEL report, that's the 1996 INEL report
     with the sensitivities.
               DR. HOPENFELD:  Right.
               DR. BONACA:  Is that the right document?
               DR. HOPENFELD:  I believe it's one, but we're
     going to spend a lot of time on the operator action today. 
     As a matter of fact, since I am not an operator, I asked Mr.
     Robert Spence to talk about that aspect of it and he will
     answer your question.
               I really didn't prepare myself too much about the
     operator --
               DR. BONACA:  No, just I'm trying to understand
     what --
               DR. HOPENFELD:  Yes.  I'll be glad to -- I'm
     familiar with the report, but the detail of operation, I
     will just give you just an overview of it.   
               The main point is, focus their attention, again,
     they say, well, we are about ten-to-the-minus-five, and I
     say, no, ten-to-the-minus-four and the other research report
     also says around ten-to-the-minus-four, and that's what
     we're going to be trying to --
               DR. KRESS:  Joe, not to belabor this too much.
               DR. HOPENFELD:  Sure.  We've got plenty of time,
     sir.
               DR. KRESS:  Okay.  I understand.  What would you
     say to a condition where the leakage was such that you
     exceeded 10 CFR 100, but the risk was still actually below
     ten-to-the-minus-five?  I can conceive of that happening,
     depending on how --
               DR. HOPENFELD:  Sure.  Sure.
               DR. KRESS:  Is that acceptable or is it --
               DR. HOPENFELD:  Okay.  I'll answer the question to
     you, because I used to drive very fast when I was younger. 
     But I think all of us drive 80 miles an hour, okay, and
     nobody is going to really worry about it.  When you go 200,
     you start worrying.
               So if you go -- and I think the cutoff number,
     depending on how you do this, is something like five gpm,
     depending on the site, it's a site-specific kind of thing.
               DR. KRESS:  It doesn't take much leakage.
               DR. HOPENFELD:  So if we're talking about five or
     ten or 50, we go to 145, 150, that's what the Research
     people came out with, remember back to '92, Trojan, they
     told him it's going to be -- the mean is going to be 144,
     and they probably thought, hey, how am I going to meet Part
     100 on that.
               We will have to do a lot of nobbing to get the
     thing down somehow.  So to answer the question, yes, but I
     -- yes.  Maybe you should look into the relative risk of
     these two, I don't know.  I haven't looked at it.
     Just to make it clear as to -- I verbally described to you
     what they're doing.  It may be easier to describe here. 
     What they do, they have -- they're getting readings from the
     field as to what the voltage distribution is on all the
     tubes or sample or sample of the tubes, and then they adjust
     the thing by voltage growth to the cycle.
               Now, I got to -- I'm going to spend some time
     about this, because this is a major assumption and those
     people who are stress corrosion experts probably would know
     that stress corrosion, there are two parameters that operate
     in stress corrosion.  One is initiation, another is
     propagation.
               And you, as a rule, really cannot say that the
     historical data can be projected into the future.  You can
     maybe say that in fatigue cracks, where you can count the
     number of cycles, but when you talk about stress corrosion,
     which is a much more complex phenomenon, it depends on the
     environment, it depends on the stresses, it depends on the
     chemistry, it depends on the material, you have --
               The process is so complicated that you cannot say
     what happened in the past is going to happen in the future,
     but that's exactly what they say, with something that they
     cannot even measure.
               So the next thing, what you have is you take all
     this thing here and you put some uncertainties in it and you
     come up with a distribution at the end of the cycle.  And
     then after you do all that, you still have to tell somebody
     what the leakage is.  So you take and you say I'll take my
     end of the cycle distribution of defects and I will multiply
     by something, some factor to say -- to determine whether I
     will or will not have a leakage, and you see these are two
     points.
               And I see one member here from Research that's in
     there and maybe he can help me, if he wants to, is that
     basically you can provide -- put any distribution between
     these points.  You can draw anything you want to. 
               The NRC, and we'll go to this, claims that they
     have a distribution log logistic, and I'm not a
     statistician, but he can tell you, one of his contentions
     was that the log logistic distribution is not conservative.
               
               What does that mean really?  If you wish, he can
     tell you later on.
               The next thing, what is being done, they take this
     -- all this distribution, multiplying by that probability of
     leakage, and they put -- go to the data from the laboratory
     and they come up with some kind of a leakage rate during a
     steam line break, and that goes to calculate that Part 100
     and that goes to calculate and they put additional
     uncertainties on it to come up with and tell you what the
     risk is.
               But that, in a nutshell, is illogical.  You have
     to go item by item and start probing into really what this
     means, but that's just the overview of the whole picture,
     the way I understand it.
               DR. KRESS:  Excuse me, Joe.  What's the little
     dots on the middle curve?
               DR. HOPENFELD:  Those?
               DR. KRESS:  Yes.  The ones on the --
               DR. HOPENFELD:  This is the data.  This is whether
     you leak or not.
               DR. KRESS:  It's your scale.  Okay.
               DR. HOPENFELD:  This one, yes, this is the
     voltage.  They take specimens and --
               DR. KRESS:  That's not a data point.
               DR. HOPENFELD:  Yes, it is.
               DR. KRESS:  It's a data point.
               DR. HOPENFELD:  Could you please it explain it
     better?  It's a yes or no thing.  It's a fail or not fail.
               DR. KRESS:  So you have a bunch of data points
     down there and a bunch of data points here.
               DR. HOPENFELD:  Right.  And this is a logarithmic
     scale, so they drive all kind of -- would you like to very
     briefly say something about the logistics thing?
               DR. POWERS:  You need to use a microphone and
     identify yourself.  It's kind of selfish, but I'd give you a
     little break here on my throat.
               MR. BUSLICK:  Okay.  There is no theoretical basis
     for using a log logistic curve for this response problem. 
     So a logical thing to do would be to try to use different
     curves, different families of curves, like a Kochi and a lot
     Kochi, normal, loss normal, and see how the goodness of fit
     for these different curves, families of curves are, when you
     use the maximum likelihood estimate of the parameters for
     each case.
               You want to see how good and see what the
     differences of results are.  I found that, if I recall
     correctly, I could give you a reference, it's in the PDR,
     that the log logistic was one of the least conservative,
     underestimated the leakage.
               That all of the families of curves fit about the
     same, the goodness of fit characteristics were about the
     same.
               In the cases that I examined, if I recall
     correctly, the changes in the leak -- in the estimated leak
     rate for a typical case, typical set of voltages that were
     measured in the plant, may have changed the leak rate by a
     factor of four or so between a more conservative one, maybe
     not the most conservative, and the log logistic.
               I have the details, I just don't have them with
     me, and that's basically what was done.
               DR. HOPENFELD:  Thank you.
               DR. KRESS:  I still would like to have you clarify
     that middle curve for me.
               DR. HOPENFELD:  This curve?
               DR. KRESS:  How were the data obtained?
               DR. HOPENFELD:  You mean this curve?
               DR. KRESS:  Yes.
               DR. HOPENFELD:  I'll tell you how I think, what I
     believe, you take a specimen, you subject it to the
     pressure, to whatever the steam line pressure differential
     would be.
               DR. KRESS:  The specimen has only the one bobbin
     voltage indicator in it.
               DR. HOPENFELD:  No, I think those -- if I
     understand correctly, you take some tubes, which were in the
     plant, and you take and you pressurize them.
               DR. KRESS:  So that tube has a distribution of
     readings to it.
               DR. HOPENFELD:  Yes.  The certain -- let's see. 
     You see whether they leak or not.  Go ahead.
               DR. POWERS:  And please use the microphone and
     identify yourself.
               MR. MUSCARA:  Joe Muscara, with NRC Research.  It
     essentially comes from what Westinghouse conducted to
     develop the voltage-based criterion.  Many of those points
     are from tubes removed from service.  There are some data
     points developed in an autoclave in the laboratory.
               What they've done -- there are two aspects of
     this.  One, is there is a probability that a cracked tube
     will leak and, secondly, if it does leak, how much does it
     leak.
               The middle curve has to do with the probability of
     the tube leaking.  So they've taken a number of tubes from
     the field, they have different voltage response, and tested
     it.
               And what that graphs shows is whether a tube at a
     given voltage responds, leak or doesn't leak.
               DR. HOPENFELD:  That's what I thought.
               MR. MUSCARA:  So you have a number of data points
     at the bottom, those tubes that did not leak --
               DR. KRESS:  Let me ask you a question about that. 
     Does this curve say that a tube with all voltage responses
     below that level?
               MR. MUSCARA:  There's data for the specific tube. 
     I'm assuming -- I assume they took the highest voltage for
     that flaw.
               DR. KRESS:  That's the highest voltage on the
     tube.
               DR. SHACK:  It's the voltage you measure according
     to your specification for how you measure the voltage for a
     tube.  You have a procedure for doing that.
               DR. HOPENFELD:  One tube, one defect, one
     measurement.
               MR. MUSCARA:  But there are many voltages along
     that crack.  So you have to select a voltage from that
     crack.
               DR. KRESS:  But that's the point I was trying to
     get at.  So one tube, one voltage, one crack.
               MR. MUSCARA:  Right, and I suspect that that's the
     highest voltage noticed for that particular crack.
               I think that's -- from what I've read, that's what
     they do.  They take the highest voltage for a given crack.
               DR. KRESS:  But the point I wanted, wasn't clear
     to me, is if one tube, one crack that you're looking at.
               MR. MUSCARA:  Or a cracked zone.
               DR. KRESS:  Or a cracked zone.  That clarifies it.
               MR. MUSCARA:  Some tubes at a given voltage leak,
     other tubes at the same voltage don't leak.
               DR. KRESS:  Yes.  Okay.  Except that almost looks
     like a --
               DR. CATTON:  And these voltages measured in the
     steam generator and then the tube is tested later or are
     these voltages measured on the pulled tube or what?
               MR. MUSCARA:  Yes.  That's the voltage that was
     measured in situ during operation, the in-service
     inspection.
               DR. CATTON:  So that's what that voltage is.
               MR. MUSCARA:  That's what that number is.  Of
     course, they do measure the voltage after the tube is
     pulled, but the number that they're providing here is the
     voltage response of the tube in-service.
               DR. HOPENFELD:  Well, let me make a couple of
     comments on that.  Thank you very much for straightening me
     out on this.  This is not -- my point here is really there
     is a disagreement whether this distribution could or
     couldn't be, but the point that I just want to make now,
     just in case I forget, you ask yourself what causes
     something to leak.
               Not the voltage, what causes something to leak is
     how deep is the crack and that voltage has nothing to do
     with how deep that crack is and what loads are going to be
     on the crack.
     That goes back to what you said.  When they say it's
     empirical, it's empirical, but it really doesn't relate to
     real world conditions.  It's empirical of something, but
     that's really was the point.
               But exactly how -- there's another point that
     wasn't mentioned here.  When you -- if you measure that
     voltage in the plant and you pull those tubes, many times,
     those tubes get damaged, and I don't know whether you tear
     ligaments or you fix ligaments or whatever, and when you put
     this thing in the test conditions, I don't know what these
     points -- what they really represent.
               I did go back to the database, I couldn't figure
     it out.  But it's not really very essential to my points
     anyway.
               MR. BALLINGER:  As a point of clarification,
     you're going to, I'm sure, explain to us your issues with
     respect to making the jump to the next step.
               DR. HOPENFELD:  Right.
               MR. BALLINGER:  That is to say, voltage to leak
     rate.
               DR. HOPENFELD:  I'm going to spend a lot of time,
     probably most of the day today on this.
               MR. BALLINGER:  Sure.  But with respect to the
     choice of the curve fitting technique that you use to fit
     the --
               DR. HOPENFELD:  First of all, this is not me. 
     This is NRC.  These are these people.
               MR. BALLINGER:  I'm using the generic you.
               DR. HOPENFELD:  Okay.  Sorry.
               MR. BALLINGER:  That's based on the so-called
     engineering judgment part and there are statistical
     techniques which identify the goodness of fit.
               DR. HOPENFELD:  Right.
               MR. BALLINGER:  And at some point, it's your
     choice, the generic you.
               DR. HOPENFELD:  Right.
               MR. BALLINGER:  Of which to use.
               DR. HOPENFELD:  Right.
               MR. BALLINGER:  So there may indeed be an
     empirical correlation between the parameter that you measure
     and the depth of the crack.
               DR. HOPENFELD:  It could very well be.
               MR. BALLINGER:  It then becomes your choice.
               DR. HOPENFELD:  Right.
               MR. BALLINGER:  On how you fit that data and what
     relationship that you use, and that relationship may have
     absolutely no connection with -- it's just a strictly
     mathematical construct.
               DR. HOPENFELD:  I did talk a lot to our
     statisticians and I forgot all my statistics, but I remember
     the basic concept, and I understand what you're saying, sir.
               The point really is that maybe all that thing is
     okay within this laboratory that they're testing all these
     things, but, now, what that really means later on, a month
     and a half, a year and a half later in the plant are two
     different things.
               MR. BALLINGER:  But that's a different question. 
     I mean, in --
               DR. HOPENFELD:  But there is a different question,
     but, you see, that's really what I'm after.
               MR. BALLINGER:  But there is nothing inherently
     bad about making a choice of what you use to fit the data.
               DR. HOPENFELD:  No.
               MR. BALLINGER:  It could be empirical.  The
     relationship is empirical and can't be derived.
               DR. HOPENFELD:  I'm not questioning that.
               DR. KRESS:  But I'm presuming that's not the full
     database that goes into establishing that particular curve,
     because I would have never chosen that one for that
     database.
               MR. BALLINGER:  Nor would I, based on the cartoon.
               DR. KRESS:  It's just a cartoon, I'm assuming.
               DR. HOPENFELD:  I'm not questioning this.  Go
     ahead.  I'm getting a break here.
               MR. BUSLICK:  The point is if there is no
     theoretical basis for one curve and for probably a family of
     curves for probability of leakage or another, then if you
     have several families which have equal goodness of fit, the
     real question is why choose the log logistic if it tends to
     give one of the lower leakages.
               MR. BALLINGER:  That's exactly correct.  Then you
     have to have some other piece of information which may or
     may not -- which may be relevant.
               DR. HOPENFELD:  Really, my main point here was
     that -- and I brought it in here really to show you even the
     experts, there is disagreement.  And it could make a
     difference, up to a factor of four, you know, it makes -- it
     probably has no meaning as far as the overall risk is
     concerned, but when you talk about this legalistic aspect of
     Part 100, it may.
               DR. CATTON:  When you look at this last figure,
     what is the range?  You don't have any numbers on here from
     the bottom of the data to the top of the data.  Is that a
     factor of four?
               DR. HOPENFELD:  No.  I think what I'm talking
     about, if you pick up this distribution --
               DR. CATTON:  Well, I understand --
               DR. HOPENFELD:  -- or pick up a different
     distribution and multiply by this, you can come up with a
     definition factor, a definition leakage.
               DR. CATTON:  But just on that last figure, where
     you have leakage rate is a function of voltage.
               DR. HOPENFELD:  Right.
               DR. CATTON:  If you just blindly plot all the data
     that you can find, what is the scatter?
               DR. HOPENFELD:  I'll tell you, I'm glad you're
     bringing it.  I think you have to go back to this
     proprietary information, and that's -- you have all that
     data in there.
               DR. CATTON:  Is it decades?
               DR. HOPENFELD:  It's several orders magnitude, but
     I don't know exactly.  To answer your question, okay, can I
     come back to this?
               DR. CATTON:  Sure.
               DR. HOPENFELD:  I would like to come back to that,
     because it will become clear.
               DR. CATTON:  I just want to raise that issue
     because this is a problem of a heterogeneous media and
     unless you relate to the proper parameters, you never get it
     right.
               DR. HOPENFELD:  Correct.  That's my next slide.
               MR. HIGGINS:  Could you indicate on there, if it's
     possible, the one volt, two volts, three volts that you
     talked about before?
               DR. HOPENFELD:  In here?
               MR. HIGGINS:  Right.
               DR. HOPENFELD:  I'll tell you, all the data is in
     that proprietary stuff and I -- this came in from many years
     ago and since then, they have generated a lot more data over
     the years, and I really don't want to quote numbers without
     really going back.  But all that information is in your
     hands and it's all stamped proprietary.
               MR. BALLINGER:  One last thing, and then I'll drop
     the statistical thing.
               DR. HOPENFELD:  Sure.
               MR. BALLINGER:  That is, as long as you're doing
     interpolation, the goodness of fit works okay.  But the
     choice of distribution that you use, the choice of
     relationship you use makes a big difference when you start
     extrapolating.
               DR. HOPENFELD:  Okay.
               MR. BALLINGER:  That's where it makes a
     difference.
               DR. HOPENFELD:  But what makes a difference to us,
     really, from my perspective, is whether the number they came
     up with to calculate their dose releases, what kind of
     uncertainty do you have; do you have a factor of four or are
     you conservative, what are you, and that's really why I'm
     bringing it out.
               We'll have an opportunity to talk about this a
     little bit more.
               Let me go and, again, outline the differences here
     between the NRC approach and what my concerns are.
               Basically, the whole philosophy is that we have
     this laboratory data which was obtained in simulated
     environments under certain conditions and then we have a
     specimen, I think these were a tubular specimen.  
               Anyway, you have some tubes, degraded tubes that
     were pulled out from the plant and they were tested at
     different pressure rates.  When they got up to 2,500, they
     observed what the leakage was.  Basically, that's all it is.
               What my claim is, that the database or all the
     database that the industry has generated is irrelevant to
     the steam line break accident, because, for one, there is no
     physical relation between the voltage and the leakage.  And
     therefore, laboratory data cannot be used in a different
     environment.
               There is no reason, physical reason or scientific
     reason why there should be any relation between the voltage
     and the leakage.  These are completely two different
     phenomena.  Let me say why.
               That voltage probe that produces the voltage
     reading, I don't remember the rule there, but you run a
     current through the coil and it produces magnetic field and
     you have secondary currents in the material and then you get
     a feedback and you read different voltage, that's what you
     read, I think.
               But that voltage that that probe reads depends on
     the volume of the cracks.  Really, that's what it depends
     on.  It depends on the crack orientation.  If you have
     various different cracks, oriented and the spacing between
     the cracks, they're going to affect the voltage that you
     read.
               The geometry of the probe or the field of view of
     the probe and the environment, you have impurities in there
     and you have a support plate and you have deposits in there
     and their physical characteristics is going to affect what
     that probe does, and then that probe, you can get away from
     some of that by running the probe at different frequencies,
     but you see this is not a straightforward kind of thing.
               It's not something that I take a voltmeter and
     measure voltage of a clean system.  It's not.  But now, when
     I need leakage, the physical parameters that drive leakage
     are different.  Okay.
               What drives leakage is the loads.  If you're a
     tube, sitting there, and you have some cracks partially
     through the wall, what is going to decide whether that crack
     is going to open up is the loads on that act on that crack.
               All they simulate in these tests are internal
     loads or pressure and nobody has shown me that these
     internal loads are really the main loads on that specimen. 
     But that's all you have.
               Implied in this, to do the steam line break, all
     you have acting on those tubes are the internal loads. 
     There are no other phenomena.  There's no erosion from these
     jets.  There is no vibration.  There is no bending.  All we
     have is a nice clean environment where we're testing these. 
     So that's what the database is.
               Plus, and that's another plus, these tests are
     conducted in an environment which is entirely different than
     the plant environment.  They're not testing those
     necessarily under the same pressure, same delta P, same
     temperature.  So what do we have?
               We have some conditions that we're simulating,
     some, and now we're going to argue whether it's a lot and
     semi or part-semi, and we're taking those conditions and
     have theoretical models, untested theoretical models.  We
     apply all that and we come up with a regulatory position. 
     We say this is safe, and that's what the difference is.
               The procedure, practically going back, makes
     really no distinction.  There is no allotment in here
     anywhere in the entire process of this voltage-based
     approach, there is nothing in here that really makes a
     distinction whether you have a degraded tube or you have a
     perfectly good tube.     
               All you have is some model that tells you, okay,
     this model tells you that you're okay, so everything -- it
     depends here on the validity of that model.
               Again, I'm repeating this, it's the one gpm here
     that you really have no control over.  You cannot assure
     somebody that under steam line break, you can have hundreds
     and hundreds of times more flow, more leakage, if the
     mechanism is there, than the one gpm.
               So if the industry had come with some kind of a
     mechanism, some kind of a shut-off valve, that as soon as
     you exceed that one gpm, it shuts off the system, then,
     yeah, we can operate with any cracks you want.    
               But furthermore, even if you don't -- you can
     operate in any leakage if you have a genius operator that
     will control anything you have.  So if you have this perfect
     operator somewhere that can control no matter what the
     reactor does, then it's fine.
               MR. HIGGINS:  Joe, does the previous curves that
     you showed us, with the leak rate derivation, does that
     ensure -- the calculations using that ensure that you stay
     below the one gpm?
               DR. HOPENFELD:  Which one, the -- no, it does not. 
     Absolutely not.  No, it doesn't, because that curve, by
     itself, is just -- again, it's a theoretical thing obtained
     for certain data within a certain environment.
               Now, if it stays within that environment, that
     curve, it would be okay, but we're not we're not interested
     in that environment.
               MR. HIGGINS:  I mean if you do your analyses with
     that assumption that that is the leakage rate, will that
     keep you under the one gpm?  Because you didn't put any
     values on it.
               DR. HOPENFELD:  If you do -- well, let me -- give
     me one second and I'll address that, because I'm going to
     break the thing item by item.  So come back to me and hit me
     with this, because I will come back to this.
               DR. BONACA:  Before you leave it, because you --
     you know, there was a correlation of voltage measurements
     and leakage.  And the point I'm making is that for a steam
     line break, what you should measure is the residual tube
     strength to withstand the steam line break.
               DR. HOPENFELD:  That's correct.
               DR. BONACA:  That would be --
               DR. HOPENFELD:  Under steam line break conditions,
     under those loads, not loads in the laboratory.
               DR. BONACA:  That's right.  So if you could
     measure, by some metrics, the residual tube strength to a
     standard steam line break or, let's say --
               DR. HOPENFELD:  You're correct.
               DR. BONACA:  -- the damage that would not allow a
     tube to withstand a steam line break, that would be a
     credible metrics.
               DR. HOPENFELD:  Right.
               DR. BONACA:  But you're saying that going from
     voltage to leakage, you cannot infer an intermediate step --
               DR. HOPENFELD:  Right.
               DR. BONACA:  -- that says --
               DR. HOPENFELD:  Let me put it the other way
     around.  If you were to take a tube and, say, hundreds of
     tubes, they all had some cracks in them.  And you put them
     in the laboratory and you run tests under bending, you run
     tests under torsion, you run tests under vibrations, and you
     run tests on all these conditions that you can think that
     represent real life, and then you see on all these, I didn't
     have any of these things, these are super-duper tubes, that
     material is unbelievable, it never breaks.
               And then you don't have any leakage and I say,
     yeah, that's fine, but that is not what's being done.  All
     they do is take these samples and they internally pressurize
     it and then pressurize it under different pressures,
     different temperatures that you have in the plant, and then
     they generate this data that I was showing you before, and
     that's what's being applied.
               And what I'm saying, in all the statistics and all
     the methodology is fine, as long as you stay within that
     laboratory.  You go back to your laboratory, all the
     statistical things and all the correlations, that's fine. 
     But it's an entirely different situation when you're talking
     about an environment that really has nothing to do with
     this, and that's what I will give you the physics of it, why
     it has nothing to do with it.
               Okay.  To summarize this in a pictorial way, I
     realize this is an important thing, so I put a lot of stuff
     in here, so we can focus a little bit better on all these
     things.
               You start, you go to the laboratory and you run a
     whole bunch of specimens.  Some of them came from U-bends,
     some of them may have come from tubes, some may come from
     the plant, and from that laboratory, you generate a leakage
     versus voltage data.
               Now, if you go back to the proprietary
     information, it is difficult to understand what's really
     behind how the data was generated, because some of those
     specimens, especially those that came from the plant, they
     were plugged.
               See, there's a lot of crud in the system,
     especially when you go to shutdown, so some of these things
     are plugged.  The cracks plug and obviously you don't pull
     it at full temperature and full power, so you don't really
     know which one is plugged and which one is not.
               Many years ago, there were some tests at PNL about
     plugging these cracks and the idea there was they were going
     to come up with some rationale for leak before break, and
     what they found, it was very interesting, you look in one of
     those PNL reports, indicating very clearly that this
     plugging and non-plugging is a very random, unpredictable
     situation.
               So you don't really know how to interpret that and
     whether, looking at the database, and I spent a lot of time
     looking to figure out which specimen they're talking about,
     and they say this was in there, this wasn't in there, and
     you don't know what was included and what wasn't included.
               So there's room here to make all kinds of
     adjustments about plugging of these specimens.
               Then, as I already said before, and Dr. Busnick
     discussed it, there is a statistical distribution adjustment
     that's to -- which is, again, within this boundary here. 
     And then you have, which I think is probably more difficult
     to interpret, is when you pull those tubes, a lot of them
     get damaged.  You damage the ligaments.
               And I don't know, please go back to the database
     and see if you can figure out which was included and which
     wasn't included, and, more importantly, if NRC has to have
     an audit function, how do you go and audit that stuff?
               If a utility comes in here and says, well, here is
     our database, we -- how do you know?  I mean, you can't
     characterize the condition of the tube.  You don't even know
     whether it's representing the time that you're talking
     about, how long it was there, you don't know.  You don't
     know anything about those cracks, except you know there are
     a lot of cracks, but you don't -- can't characterize them.
               
               So what you do, you get a statistical relation or
     some kind of regression curve for the leakage versus
     voltage, and that's okay.  If you are running these reactors
     in these environment, that's fine, as long as you do that.
               Now, when you go -- and this was the first thing I
     learned at school, that if you go to a different environment
     and you know that there is no mechanistic explanation to the
     phenomenon that you have, you can show, as I did before,
     that the parameters that control leakage are different than
     the parameters that control -- the parameters that control
     leakage is the length to diameter ratio of the crack.
               It's the opening area and the pressure drop.  And
     that's not what controls what the voltage is read by the
     probe.  These are two different things.
               Now, I'm not saying that you couldn't possibly
     have some kind of a correlation.  You can always get a
     statistical correlation, anything you want, and that's fine,
     there's nothing wrong with that.
               But you have to stick to that environment and
     don't go beyond that point.
               DR. BONACA:  I have a question.
               DR. HOPENFELD:  Yes.
               DR. BONACA:  The question I'm asking is, are they
     isolated and pressurized internally?
               DR. HOPENFELD:  From what I understand, and I
     don't know the exact setup, the experimental setup, I did at
     some time, they take the specimen and they apply pressure at
     a certain rate.  And recently, somebody brought up the issue
     of that even the rate makes a difference on the rupture, but
     then it was brought out that that difference only occurs
     when the crack is very, very deep, and it's a secondary
     effect.
               In other words, that's not important.  What is
     important here is that up to ten years of running these, the
     industry constantly finds some new phenomena, and you would
     expect it.  When you run something, you don't know what
     you're running.
               You're taking some specimen, you test them, and
     then you say that's what we've got.  So it's not something
     that I would --
               DR. BONACA:  But I'm saying so, therefore,
     although you do not simulate at this location, that the main
     steam line break may bring about in the tubes, they do
     simulate the delta pressure that the wall may see in a steam
     line break.
               DR. HOPENFELD:  Some of them do, some of them
     don't.  Some of them have to operate on the different
     pressure.
               DR. BONACA:  Okay.
               DR. HOPENFELD:  So this is the next thing.  So
     what you have, you go with this data.  You also have, as you
     saw before, and that's the reason I brought this procedure
     that they use, you have this measured voltage distribution
     and then you go -- so all this gives you incorrect leakage. 
     So far, yes, this is all experimental.  But now it's all on
     the local beyond that point and, obviously, where is the
     weight of this thing, what weighs more, the analytical here
     or on the experimental, and I'll show you I believe it's
     this part -- the analytical part over-weighs those little
     laboratory tests they've been doing.
               This is not little, I mean, this is many years of
     hard work and I'm not trying to minimize it, it's great and
     it's good to have this database, but don't worship it.
               If industry wants to use it around those steam
     generators, they should give you a little bit more
     justification than they've been giving you so far.
               So the next thing, and I like to call these knobs,
     you have pressure and temperature adjustment, because the
     pressure may not be the same and the temperature may not be
     the same.  Some of these were run at room temperature.  Some
     were run at different pressures.
               So you have pressure and temperature adjustment. 
     Then you have crack growth adjustment.  In other words,
     remember, we had these voltage things, you can make a lot of
     adjustment there in order because you don't know what the
     growth is.  So you go into the histogram of the plant and
     you adjust it in the adjustment.   
               Then you have, as we already mentioned before, you
     had this probability of leakage adjustment that -- no, I'm
     sorry.  Then the probability of leakage was already -- then
     you have the POD adjustment.  So what's the probability
     that, since the whole concept is statistical, what is the
     probability that you're going to miss some of those cracks?
               Well, that is a little bit bothersome and I'm a
     little out of my field on this, but if I remember correctly,
     the POD, the concept of probability of detection of cracks
     really came from single cracks or maybe even from fatigue,
     when you were really worried about what the threshold that
     you can withstand.
               Now, what you have, you don't have a single crack,
     really.  You have a network of cracks.  You have cracks
     growing, coalescing, they're linking, they're doing all
     kinds of things all together, and I'm not so sure --
     eventually you do have one crack that starts, but that
     doesn't mean that you don't have the next one.
               I'm not absolutely sure that the statistical
     concept that was originally intended and was developed over
     the many, many years, and nuclear is not the only industry
     this is being used.  It's being used in the oil industry. 
     Very common.
               So I'm not so sure that this is strictly
     applicable.  But having said that, we do have some data in
     thereabout you'll really have to look at it, and I'll come
     back with some numbers later on.
               Now, the main one here is then you have damage
     adjustment.  As I already mentioned before, you have tubes
     that are going to be exposed to different loads.  They're
     going to be exposed to erosion.
               What adjustment is there?  It's being ignored. 
     It's not there.  It's just completely forgotten.  It's not
     coming in.  So the adjustment, the knob goes from zero.
               
               And then the adjustment in the chemistry of the
     iodine spiking.  What you do there, you make an adjustment
     to come up with what you want.  Well, they finally -- you
     meet two criteria here, and I don't know whether they're
     independent, how they're being used.
               One says I'm going to meet Part 100 and another
     says my risk is going to be such that it will stay within
     the ten-to-the-minus-five core melts per year.
               So you see what the methodology is, is that you
     take a very small database and you apply all these little
     knobs that you have and you come up with any answer you
     want.  That's really what it boils down.
               MR. HIGGINS:  Joe?
               DR. HOPENFELD:  Yes, sir.
               MR. HIGGINS:  The adjustments that -- theoretical
     adjustments that you're describing there, are you talking
     about industry calculations or NRC or both?
               DR. HOPENFELD:  Okay.  I'm going to go through
     this.  This is just the purpose of this slide, is exactly to
     address that issue.
               The industry -- and this is proprietary
     information -- has developed computer codes to make pressure
     and temperature adjustments which are to take that data from
     the laboratory and adjust this thing to plant operation, in
     other words, that data is being corrected.
               Some of those are analytical equations, kind of
     straightforward.  But if you go back, and I'm going to
     discuss that, the validity of them is very questionable.
               And the analytical equation, I can't go to that,
     because it's in your proprietary information, but there is a
     computer code, and I don't know if I'm even allowed to say
     what the name is, but talks about flow through cracks and
     what it does, there are some basic flaws in that computer
     code.
               Now, how that computer code is used, it's used to
     -- it's used to show the analytical equations that they have
     derived agreeable with a more sophisticated tool.
               But then you ask yourself the question, that tool,
     let's call it computer X, that tool, in order for it to show
     that your analytical tools are correct, and in order to
     calculate leakage on a computer -- on a real flow model, you
     have to know the length of the crack.
               You have to know the L-over-D of the crack,
     because that determines the nature of the flow.  Now, how do
     you get that information from the voltage data?  And I think
     you ought to go back, I was going to spend some time, but
     we'll have to close the doors, if you go back to your
     proprietary information, there is a description as to how
     they're doing all that stuff.
               DR. CATTON:  This proprietary information you're
     talking about, I don't know about the rest of you, but what
     I have is just figure titles.  So I really don't know
     anything about this proprietary data.
               DR. HOPENFELD:  Well, you may-- I don't know if
     they have given you all those -- the database that discusses
     how the data is being --
               DR. CATTON:  They gave me a lot of stuff, but
     wherever it referred to proprietary, all I had is a figure
     title.
               DR. HOPENFELD:  I don't know how they're handling
     this, but the description of the computer code and the
     thermal hydraulics through those cracks is in that code, and
     I just don't want to go into that, even though I think it
     shouldn't be classified as proprietary, but I thought it was
     proprietary and I'm not ready to go into the details of
     this.
               But I'll tell you one thing, though.
               DR. CATTON:  Is that the code called Crack Flow or
     something?
               DR. HOPENFELD:  Yes.  Well, you said it.  I don't
     even want to mention it.
               DR. CATTON:  You mean even the name is
     proprietary?
               DR. HOPENFELD:  No, it's not, but I am -- I am
     under tremendous pressure in this area, so I'm trying not to
     -- I don't know what -- I'm not a lawyer and I don't know
     what proprietary or what's not proprietary.
               I wanted to have this meeting open to the public
     so I can go through to a more -- be free to explain the
     general things that I am going into, the minute two-phase
     flow, but although I did mention it.
               It's flawed, the model is flawed, and later on,
     you will see there is some recently data or another model
     developed at Argonne and it's completely different and I
     will talk about this a little bit later.
               So the point here is that when they tell you that
     we have all these computer codes, we have all these tools to
     extrapolate, it's not really -- there are a lot of flaws in
     them.
               One thin that I found was missing there, and I
     couldn't find any description of these, is that when you
     deal with flow at high pressure, high velocities, it takes
     time -- take this again.
               See, it takes time for the fluids to flush into
     steam.  Again, those -- we have liquid under water at 2,500
     pounds and you have, on the secondary side, the atmosphere. 
     So now you have that 2,500 pounds, up to 2,500 pounds,
     water, getting out of the tube and flushes into steam.
               Now, these are very thin tubes.  It's 40 mils.  To
     give you a feel for mils, a mil is your hair.  One hair is
     one mil.  So 40 mils.  These are not big, huge, one-inch
     tubes.  They're very thin tubes.
               So you have residence time.  It takes time to
     become -- to turn into steam.  So the order of magnitude for
     this is ten-to-the-minus-four, and for these kind of
     experiments, you see the liquid comes out of the pressurized
     nozzle and then the two-phased region really develops
     further, depending on what the L-over-D on that tube is.
               But it's on the order of ten-to-the-minus-four. 
     So now if we have all these complicated situations you
     mentioned, the computer code Crack Flow has a two-phase flow
     model in it.  They flow -- they have characteristics for the
     distinction between flows and an equilibrium flaw, but
     there's no distinction between what the stability of the
     thing, whether you're going to -- you will have -- depending
     on the thickness or the tightness of the crack, the flow in
     there is going to be different.
               Now, the answer is different, too.
               DR. CATTON:  What gives you the highest flow rate?
               DR. HOPENFELD:  I think it gives you one-phase
     when you have liquid.
               DR. CATTON:  Frozen form.
               DR. HOPENFELD:  Yes, but frozen would be
     two-phased.
               DR. CATTON:  It would go all the way through.
               DR. HOPENFELD:  But they have it two-phased in
     both cases.  That's not the way they defined it.  They
     defined the frozen flow, it's either two-phase.  In either
     case, it's two-phase, it's not liquid.
               DR. CATTON:  It's liquid inside the tube, isn't
     it?
               DR. HOPENFELD:  It's liquid inside the tube, yes,
     but when they say frozen, they don't mean that you have --
               DR. CATTON:  Frozen, you maintain --
               DR. HOPENFELD:  I think frozen --
               DR. CATTON:  -- the state through the crack.
               DR. HOPENFELD:  No.  I think what they mean in
     there, I've tried to figure that out, I think what they
     mean, frozen, is you have -- it's just like in a chemical
     equation.  You can either have equilibrium, if you're
     freezing by that composition, but the basic assumption is
     the Henry model, using frozen in terms of a two-phase or
     it's an equilibrium between the phases.
               That's what they're discussing.  What I'm saying,
     there is no where in there that this criteria of stability
     of the thing appears in the code, and you can go look for
     yourself.  I was looking for it and it's not there.
               DR. CATTON:  What role does this play?
               DR. HOPENFELD:  It plays the role --
               DR. CATTON:  You showed a previous diagram that
     says we go from the laboratory test and then some things
     that should be done, but a lot are not, to a conclusion.
               DR. HOPENFELD:  Right.
               DR. CATTON:  No where in there did I see anything
     about the modeling.
               DR. HOPENFELD:  Right.  What roles this play is in
     there, when they -- remember back, I told you that there is
     a pressure and temperature adjustment.  They have a
     theoretical model and I'm questioning the validity of the
     theoretical model.
               DR. CATTON:  Okay.
               DR. HOPENFELD:  And what I'm saying, if you have a
     theoretical model, that's fine.  But first tell somebody
     what you have and all they have is a two-phased flow in
     those cracks.
               Now, then Argonne comes the other day and if you
     look in the very recent ones, they just completely don't
     have any two-phase flow.  They just use -- they don't even
     have an LED over there.  They're just using plain orifice
     flow equation, and they called it a new -- I'll go back to
     that.
               Anyway, the point is here that there is -- it
     takes time to nucleate, although there are probably plenty
     of nucleation sites there, it takes time to flush into steam
     and that depends on what kind of crack you have.
               So if you have a very, very tight crack, it could
     very well be that you have a two-phased flow and the
     equation, the Henry equation that he developed in 1971, are
     applicable.
               But you can't say whether they are applicable or
     not unless you can characterize what you have, what kind of
     crack you have.
               So now, my antennas, my warning signal, hey, why
     am I telling you all that.
               This is maybe a factor of four and they tell us in
     the proprietary information that they have validated all
     these theoretical equations and codes, okay.  I'm showing
     you right now, they didn't validate them according to
     physics.  There's something somewhere wrong.  What they've
     validated is questionable.
               That goes back into the physics of flow through
     cracks and it's a very complicated thing.  Again, I'll come
     back to it, but Dr. Shrock at Berkeley studied that for many
     years and he came up with a correlation showing L-over-D is
     an important factor.
               Argonne, after two or three months, recently came
     up with a model that basically is very similar to what they
     did when they designed the aqueducts.  They just neglected
     all that, they just say that the leakage is simply --
               DR. CATTON:  Yes, but there's a difference.  The
     work that Trough did was for thick wall and this is thin
     wall.
               DR. HOPENFELD:  It's not the thickness input. 
     It's the L-over-D.  These are very, very tight cracks. 
     Okay.  It's L-over-D that determines it.
               DR. CATTON:  Residence time is really what --
               DR. HOPENFELD:  Residence time, right, and the
     L-over-D comes into the pressure drop thing.  Remember,
     these are very, very tight cracks.  They may not even leak
     under certain conditions.
               So unless you can characterize what you have, you
     really don't know what you have, and that's fine, too.  But
     don't go and advertise that we've got all these things,
     we're applying all these corrections, and we've got an
     answer and it goes back to all these adjustments that they
     have.
               DR. CATTON:  So there are two parts to what you're
     telling me.  One, you use the laboratory characterization of
     the crack.
               DR. HOPENFELD:  Right.  Not characterization. 
     Just voltage.  They don't characterize the thing.
               DR. CATTON:  They don't try to relate the --
               DR. HOPENFELD:  No.
               DR. CATTON:  They don't.
               DR. HOPENFELD:  There is no characterization
     whatsoever.  There is voltage.  They may have did some
     metallography, but I don't think they've done -- they've
     correlated with the voltage.
               DR. CATTON:  So it's an inadequate
     characterization of the relationship between voltage and
     cracks.
               DR. HOPENFELD:  I would say it's less than
     inadequate.
               DR. CATTON:  Plus leakage measurements and then
     some adjustment that's based on what could be a deficient
     model.
               DR. HOPENFELD:  Correct.  Not applicable.  It
     probably is applicable under certain -- it may be -- I don't
     want to say deficient.  I'm sure that those two-phased flow
     equations, they have been used in nozzle -- in industrial
     equipment.  It was developed by Henry and Fosky in '71.  I
     think they're applicable in certain areas.
               But now that code that you named applied that
     thing all over the place and our friends at NRC/NRR don't
     question that, say, well, we've gotten this code that's been
     proven analytically.
               And that's the point here.  So they've got this,
     they have to make -- all those tests were run at pressure,
     at 2,500 pounds, and at temperature, which they didn't. 
     Then you wouldn't have to -- at least that aspect of it, you
     don't have to worry about it.
               But this is just the first one.  Now, the next
     thing is the crack growth -- to summarize what I said
     before, this is strictly a theoretical model so far.
               Now, what number that came in there is a
     probability of detection and that came from NUREG-1477. 
     They have used point six.  Again, as I mentioned before, the
     POD concept may or may not apply here, but the database --
     all the amplitude of the cracks depends on -- I mean, the
     voltage depends on the separation, conductivity, the
     permeability, the crack volume, the frequency, and the coil
     design.
               These are the parameters that measure the
     amplitude of the voltage that you measure, and I think,
     Ivan, isn't that what you are talking about?  That the
     system would be much more complicated.
               DR. CATTON:  That's right.
               DR. HOPENFELD:  That's what you were talking
     about, those two phases.  I'm sure there is an analogy.
               DR. CATTON:  You probably don't have all the
     variables either.
               DR. HOPENFELD:  I'm sure I don't, but those are
     the parameters that come in.  The frequency is a very
     important one and the permeability is very -- and the
     conductivity, because if you have some -- like in the case
     of Indian Point 2, there was copper got into the system and
     they got wrong readings.
               All these things sitting here.
               DR. CATTON:  The crack morphology, surface
     morphology is probably --
               DR. HOPENFELD:  Right, correct.
               DR. CATTON:  -- a key.
               DR. HOPENFELD:  Right.  This crack volume,
     morphology goes into the separation between those cracks.
               DR. CATTON:  There is another piece of it.  Often,
     you can pick it up with the permeability, but there are
     multiple ways to get the same permeability.
               DR. HOPENFELD:  Okay.
               DR. CATTON:  And the behavior may not be the same
     as reflected by the voltage.
               DR. HOPENFELD:  There is probably another
     parameter that has to do with -- if I remember my physics,
     but it probably has to do with the thickness of the tube,
     too.  The skin thickness probably affects it, too.  It can't
     be an infinite thick material and get reading.
               So there are a lot of parameters, I think, but the
     bottom line of all this, again, I don't know, I'm not sure
     about the POD concept, whether it's applicable at all, but
     let's assume it is.
               The NUREG-2336 indicated the laboratory tests
     showing that .27 to .5 is a number that you get from other
     tests and from laboratory tests.
               And another thing is that that POD concept really
     has, in the .6, hasn't been really verified against actual
     plant data.
               You can do it in a laboratory, but if it was
     verified, I'm not familiar with it.
               So there is a question about that .6, whether
     that's --
               DR. POWERS:  Joe, I've seen quite an inventory of
     data.
               DR. HOPENFELD:  I'm sorry?
               DR. POWERS:  I've seen quite an inventory of data
     taken from the -- I believe it was a steam generator that
     was from Surry.
               DR. HOPENFELD:  Yes, PNL.
               DR. POWERS:  And they quote POD plots as a
     function of crack size and you see if a particular size, .6
     kind of works.
               DR. HOPENFELD:  Yes, but there is also data to
     show from that NUREG, there's .27 to .5 at the intersection.
               So all I'm pointing out is that that number is
     still hasn't been verified on an actual plant.
               DR. POWERS:  What I'm asking, I guess, is that
     these were data that they collected from tubes in a steam
     generator that has seen about six years wroth of service.
               DR. HOPENFELD:  Correct.  Right.
               DR. POWERS:  Had a substantial amount of flaws and
     whatnot on the tubes.
               DR. HOPENFELD:  Correct.
               DR. POWERS:  Is there any reason to discount that
     as not actual plant --
               DR. HOPENFELD:  No, I'm not discounting.  I'll
     tell you what I am discounting, you see, that's one part of
     the equation of getting the crack system, but it takes a lot
     of expertise.
               This is not something that you go in there.  It
     takes a group of people who are expert in this type of data
     and this kind of inspection, NDE inspection, to have them
     come up with what they detect.
               So I don't know, I'm not worried about the Surry
     equipment, it's still is not done at the plant to verify
     versus an operating plant.  That's what you want to check it
     with.
               DR. POWERS:  But I guess it seems like they take a
     steam generator that's been pulled from a plant.  They had
     multiple teams, round-robin kinds of things.
               DR. HOPENFELD:  Right.
               DR. POWERS:  Used a variety of techniques, which
     escape my mind right now, and they show these plots --
               DR. HOPENFELD:  I'm familiar with what you say.
               DR. POWERS:  It seems like a pretty decent applied
     data there.
               DR. HOPENFELD:  Yes, it is.  But what I am saying,
     you still have to verify -- I mean, there is uncertainty in
     it because you see there is an uncertainty in this NUREG
     showing that the numbers are different.  Tomorrow.  So these
     numbers are definition.
               DR. CATTON:  What is a tube-to-tube intersection?
               DR. HOPENFELD:  Okay.  You have -- let me see if I
     have it.  Okay.  The U tubes go to the support plates every
     40 inches that hold the tubes together, to prevent the tubes
     from -- in view of things like, what was it, 40 feet high or
     whatever it is.
               So you have support every 40 inches and that's
     what the tube-to-tube support plate is.
               DR. CATTON:  Also, tube support.  Tube-to-tube
     intersection is this.
               DR. HOPENFELD:  It's the tube support, I'm sorry.
               DR. CATTON:  I understand.
               DR. HOPENFELD:  Let's see.  Yes.  It's about an
     inch and where the tube goes into that support, it's just a
     crate basically, that's what I'm calling a tube support
     plate, TSP.
               Again, this basically talks about as mini-robin
     coil test and it talks about the .25 to .5 and gives you a
     reference for this, and provides you, if anybody wants to
     look more into that, fine.  It gives you more thing that you
     can follow.
               That's as much -- then there's a --
               MR. SIEBER:  Just to clarify this for myself.
               DR. HOPENFELD:  Yes.
               MR. SIEBER:  The probability of detection of .6 is
     really for characterized flaws that are equivalent to about
     40 percent through wall and the larger the flaw, the greater
     the probability of detection, as I recall it.
               So that if you're 80 percent through wall, .8 and
     so forth.  So even if you can't detect anything below 40
     percent, does it make a big difference?
               DR. HOPENFELD:  No, it probably doesn't.
               MR. SIEBER:  Okay.
               DR. HOPENFELD:  All I'm saying, that the data
     that's available and you may want to go back and look into
     the validity of it, that the .6 that was picked up from
     NUREG-1477, it may or may not be representative to other
     data.
               Would you like to say something?  Mr. Spence has
     looked into that and maybe he can make comments on that.
               MR. SPENCE:  The intersection between the tube and
     the tube support plate has metal around it and that's a
     solid plate.  It is not an egg crate.  And the GL-9505 one. 
     And it also has magnetite and all kinds of metal oxides in
     there and that's giving the coils trouble seeing the flaw.
               And that's why -- I think that's why you're
     getting -- I did the numbers, as a matter of fact, to come
     up with the .2 and the .5, and that's only for the crack
     area.
               I think the rest of the testing, the .6 is
     basically free span.  But that was, again, a very small
     sample of the round-robin data.
               DR. HOPENFELD:  That's a very good point and my
     point is, and I haven't gone as much in detail as I probably
     should to all the data at PNL, but there's volumes for that
     thing.
               All I want to point out here that there is
     discrepancy and what the reason for those discrepancies, I
     don't know, but I strongly feel that there's a lot of human
     factors involved, and what you're doing there in the plant
     is not exactly what you're doing at PNL.  It may be close,
     but it's not exactly the same.
               MR. SIEBER:  Just one final question.  The whole
     voltage scheme is only for cracks that are at the tube
     support plates.
               DR. HOPENFELD:  Correct.
               MR. SIEBER:  So the free span value of probability
     of detection of .6 really doesn't apply.
               DR. HOPENFELD:  That is what was put into 1477. 
     That's what they are required to do.
               MR. SIEBER:  Okay.
               MR. SPENCE:  Could I make one other point?  And
     that is, the original setup for the coil eddy current
     testing was to find dish shapes, wall thinning, corrosion
     type things, and for that, it does a little bit better job
     than finding the crack itself.
               And there is no correlation between crack size and
     voltage that I've been able to determine, even between crack
     size and dishing.
               DR. HOPENFELD:  Thank you, Bob.
               MR. SPENCE:  Yes, sir.
               DR. HOPENFELD:  And this one is not very clear to
     me, but this relates to severe accidents.  Originally, the
     preparation for NUREG-1477, the NRC didn't say anything
     about cracks and erosion of cracks from jets, although that
     information was already in that DPO, going back to '92. 
     They completely ignored that.
               Later on, they found that there is a potential for
     cracks to cause jet erosion of adjacent tubes and they only
     focused their attention on severe accidents.  Now, the
     condition for a severe accident and design basis are not
     that different with respect to that aspect of corrosion, but
     I don't know, they, for some reason, they said that it
     doesn't exist in the design basis.  The erosion only exists
     in the severe accident, and maybe tomorrow you will get the
     explanation of why.
               I don't quite understand, but I did talk about it
     in that -- in discussing the various -- what do you call --
     differing -- DPO consideration document, because they were
     talking about these.
               And for some reason, they said that cracks which
     are larger than .125, they're going to be written off like
     the tube is gone.
               But based on data, and I don't know exactly which
     data, they haven't shown that, based on data, most of the
     cracks are not going to be below .125.
               In other words, there will be no through the wall
     cracks which are smaller than .125 and presumably, I don't
     know how they can show that -- how they can prevent, because
     the voltage doesn't tell you what the crack size is, how
     they can prevent the larger cracks are not going to be there
     and maybe you want to ask them to explain this.
               But nevertheless, they said that less than .125,
     cracks are not going to exist.
               Now, if you look into the basic theories of how a
     crack grows and you look into these networks of cracks and
     the intensity factor, there is nothing in there that tells
     you that you are going to limit how -- what kind of size of
     crack is going to get to through the wall.  You can have
     cracks growing on the order of several grain sizes.
               So I don't quite understand that, but what the
     practical application was, the summaries in the case of
     Farley, there was an indication that you could have small
     cracks, but they say, well, we believe it's not there and
     there's no problem.
               Now, I really don't understand the whole
     methodology.  I'm just repeating what they say.  You may
     want to ask them, but evidently .125.  As far as I'm
     concerned, any crack, if the velocity of the jet is
     sufficiently high, will damage the next tube.     
               The next adjustment, and that goes back to crack
     propagation at growth, which, in a classical fracture
     mechanics, it's controlled by a K factor and even there, you
     can see this is not a simple thing that you can go and you
     see various researchers have a spectrum of orders of
     magnitude, depending on the pH of these cracks, how they
     behave and how they grow, and most of them, I don't know all
     of them, but probably a lot of them are single cracks.
               Usually you study, in laboratories, single cracks. 
     Whether there have been studies on network of cracks.  When
     you have a network of cracks, that crack -- the K factor,
     the intensity factor is much more complex because these
     cracks get together and they grow or they stop growing.
               
               The propagation of the crack changes and what you
     have is entirely different.  It's a dynamic thing.  It
     depends on the pressure, it depends on the load that -- on
     the stresses that operate on the tube.
               MR. BALLINGER:  Excuse me.
               DR. HOPENFELD:  Yes.
               MR. BALLINGER:  As a point of clarification.
               DR. HOPENFELD:  Yes.
               MR. BALLINGER:  That data was derived from a lot
     of different tests, very few of which were actually cracked
     tubes, very, very few.
               DR. HOPENFELD:  Okay.
               MR. BALLINGER:  In the actual geometry.  In fact,
     none, effectively.
               DR. HOPENFELD:  Good.
               MR. BALLINGER:  When you do look at actually
     cracked tubes, real cracked tubes, you get a little bit of a
     -- you get much better -- you don't get the scatter that you
     got there.  That scatter is due not to the inherent -- well,
     in large extent, not to the inherent problem of an
     individual stress corrosion crack growth.  It's the test
     method itself.
               DR. HOPENFELD:  That's exactly what my point is.
               MR. BALLINGER:  In the attempt to simulate the
     environment.
               DR. HOPENFELD:  That was exactly my point.
               MR. BALLINGER:  And most of those were -- okay. 
     We can --
               DR. HOPENFELD:  Really, I brought it in for that
     very reason.  It's not a study in fracture mechanics.
               MR. BALLINGER:  What I'm getting at, though, is
     that when you actually use actual tubes, real tubes with
     real cracks and real geometries, the scatter is a lot
     different.
               DR. HOPENFELD:  But my point here was really that
     what I was trying to say is that there is an uncertainty
     when you go from one test to another because the environment
     is different and that probably is responsible for all of
     this variation, orders of magnitude in the crack growth
     rates.
               So even though the pH is the same, there are large
     variations.
               And the next thought that I was going to inject
     at, that you have those variations within those ten
     thousands of tubes sitting there in support plates with
     having pH all over the map and you have all kinds of
     stresses.  Some of them are being stressed because of the
     U-tube moving.  Some of them you have the stresses because
     you have flow induced vibration.
               So you have an entire spectrum of environments. 
     And all I was saying, if you look at the literature, yes,
     there's a range you see for the same condition, for the same
     environment, you have a large scatter, who knows, and maybe
     -- I haven't looked at each one of them and --
               MR. BALLINGER:  But let's be careful, again, let's
     be careful that that data doesn't represent -- if you were
     to take a real tube with a real stress corrosion crack in
     prototypic environments and in prototypic pressures and
     stuff and run several tests again and again and again, you
     would get much, much, much, much, much less scatter than you
     see there.
               That scatter is not due to variations in -- like
     that.
               DR. HOPENFELD:  But still the point is that if you
     were taking many different tubes, actual tubes with cracks
     in them, and you were running them in all these different
     environments, you're going to get different answers.
               MR. BALLINGER:  I think we're trying to compare
     apples and oranges here, and we need to be careful.
               DR. HOPENFELD:  Okay.  Thank you.  I appreciate
     that.  Maybe that's not a right point.  The point is that
     the scatter of this that you have a very dynamic environment
     and you cannot say that because my voltage growth rate was
     over a certain period of time, X, that it's going to remain
     X for the next 18 months.  That really was the point,
     because it is not the same environment, and that's the crux
     of it.
               You don't know where the cracks are.  All you're
     saying, my voltage in the last period was -- had that
     distribution and the same distribution is going to be
     occurring for the next period.     
               In other words, just looking at the extreme,
     suppose you just started at the beginning of that cycle, you
     finish your incubation period and you start into your
     propagation period.
               So how is that going to come into this?  In other
     words, the time, the previous time, the year and a half
     history is not applicable to extrapolate the kinetics of
     cracks, especially in a dynamic situation where these cracks
     grow, coalesce and stop and grow and so forth.
               Here is some plant data, and I think this came
     from Farley, and this shows that the prediction usually are
     that the -- remember, you are not supposed to exceed, at the
     beginning, you're not supposed to -- originally it was one,
     then it went to two volts, but you see you'll find fairly
     high volts, you'll find three, you'll find all the way as
     high 13.7.
               So what you predicted before as real life
     experience doesn't verify that at all.
               DR. BONACA:  Explain to me who are A, B and C
     here.
               DR. HOPENFELD:  These are different steam
     generators at a given plant.  It was Farley and I don't
     remember whether it was cycle 14, it was about three years
     ago, and this is not restricted to Farley.  There are about
     -- we'll go back, I think Breakwood and Byron had the same
     kind of phenomenon.
               So these growth rate -- and Arkansas.  All these
     growth rates that you see are not really consistent with
     this concept of -- that you can take prior voltages and
     project them to the next -- let me ask you, sir.
               Do you know any industry -- I've looked into the
     oil industry and I haven't seen anywhere there where there
     is justification of using the data on the cracks and say,
     well, since it didn't change in the last ten years,
     whatever, we can project for the next ten years.
               This is the only industry in the world, I think,
     that does that.  And I know the Japanese don't do that.  I
     think they don't allow any cracks.  As soon as they see a
     crack, any surface crack, it's being plugged.  The tube is
     plugged.
               So it's a concept, but it has no physical
     rationale to it.
               DR. POWERS:  I guess I don't follow exactly why
     this slide speaks to the projection issue.  I mean, it looks
     like it's a set of data for some particular steam
     generators.
               DR. HOPENFELD:  Yes.  It was at Farley, right, but
     what I'm trying to show you, that you can get very, very
     high crack growth, you can get 13.7 volts, which would leak
     something on the order of six gpm.
               Remember that one gpm limit that they had.  What
     do you think --
               DR. POWERS:  I mean, it seems to me that 13.7
     volts is substantially beyond even three.
               DR. HOPENFELD:  Yes.  But that's my point.  That's
     what you find.  And if you go to the mechanism, you don't
     really need many cracks to cause damage during the steam
     line break.
               DR. POWERS:  But if you had an indication of 13.7
     volts, wouldn't they plug that tube?
               DR. HOPENFELD:  Well, they didn't plug it before. 
     This is what they found during the outage.  They must have
     plugged it, yes.  they pulled it.
               DR. POWERS:  So that particular tube is not going
     to leak anything.
               DR. HOPENFELD:  No, that's not my point.  My point
     is --
               DR. CATTON:  I think the point he's making is that
     in the previous time they did it, they didn't have the 13.7. 
     They were under the three or whatever.
               DR. HOPENFELD:  Yes.
               DR. CATTON:  So in one cycle, they went from three
     to 13.7.
               DR. HOPENFELD:  Well, one or zero.  My point,
     either the POD is not worth anything or they get huge growth
     rates.  I'm not -- now, I don't know whether that represents
     100 percent sample of all the tubes in there, but my point
     here is that this idea of using prior history to tell you
     what kind of voltages you're going to have in the future,
     this is flawed.
               DR. CATTON:  What you're saying is if I had looked
     at this same slide taken at the end of cycle 13 --
               DR. HOPENFELD:  Right.
               DR. CATTON:  -- I would have found no tubes that
     were not plugged that had indications greater than three
     volts.
               DR. HOPENFELD:  Right.
               DR. CATTON:  I'm not sure what they used as the
     criteria.
               DR. HOPENFELD:  Well, I don't know what they used,
     but I'm not even questioning whether they have 2.3 or 2.5. 
     I'm questioning this concept, can you use this concept where
     nobody -- there is no physical reason for it.  There is no
     theory that can justify that.
               MR. BALLINGER:  Do we have the data from the end
     of cycle 13?
               DR. HOPENFELD:  I'm sure we do and I don't know if
     I brought it with me, but I'm sure they have it.
               MR. SIEBER:  If I go back to this --
               DR. HOPENFELD:  Yes.
               MR. SIEBER:  -- overhead of yours, all that the
     Farley data shows me is this is a distribution that tells me
     that it's probabilistic in nature and that's the way the
     methodology for coming up with a bottom voltage versus
     number of indications and then later on the postulated main
     steam line leakage.
               DR. HOPENFELD:  Correct.
               MR. SIEBER:  It's just a combination of a lot of
     probabilities, which define an expectation and the
     uncertainty associated with it.
               DR. HOPENFELD:  Right.
               MR. SIEBER:  So this is what I would expect to
     find for that and that's --
               DR. HOPENFELD:  Well, I don't know if you would
     expect that high, because this is all way, way really here,
     you get really very high.  I mean, you really -- look, what
     you do, you take these numbers, I don't know how many more
     of those, if you had -- you take these numbers and multiply
     that thing by the number of cracks and you ask yourself,
     okay, what is my leakage.
               Well, for one thing, I've got this constraint of
     Part 100.  Well, already you're exceeding with one of them. 
     I don't know.  You have to add all those.
               So you see, you're exceeding that.  You're
     violating the law, for one thing, but never mind the law,
     then the next question is, okay, I've got this baby here,
     now I hit it with that -- say it was left in service.  Now
     I've got the steam line break.  Now what?
               Okay.  I was at the tail of this distribution, but
     now what am I going to do?  I'm going to have one rupture,
     ten ruptures?  That's really what it is.
               DR. CATTON:  Joe, just following what John said,
     is there some argument somewhere about the number of tubes
     that they have to examine at each cycle?  Then you can base
     it on the statistics and say what I'm allowing is that one
     or two tubes escape or three or four tubes escape, on
     average.  Then you would expect that.
               So somewhere there must be a number.
               DR. HOPENFELD:  I think it varies.  I don't know. 
     Sometimes they're 100 percent, sometimes -- I don't know how
     -- what the --
               DR. CATTON:  If you do 100 percent then this is a
     surprise.
               DR. HOPENFELD:  I don't know whether -- I don't
     know what the size of the sample of this one.
               DR. CATTON:  If you do 75 percent of the tubes,
     there's some probability that some number would escape you.
               DR. HOPENFELD:  I don't have an answer to that.
               MR. BALLINGER:  I think you had a sample of 20
     percent.
               MR. SIEBER:  It's 20 percent.
               DR. HOPENFELD:  This was 20 percent.
               MR. BALLINGER:  That's why I was asking if we had
     the previous one.
               DR. BONACA:  Then if you get more than --
               MR. SIEBER:  So many indications.
               DR. BONACA:  -- so many, then you expand it.
               MR. BALLINGER:  Expand it, yes.
               DR. HOPENFELD:  Well, I don't know what the basis
     of that, they didn't indicate to me, you have to read the
     report.  I don't know what percentage.  Sometimes they go to
     100 percent.  I just don't know what this one is.
               MR. SIEBER:  You contract never go 100 percent.
               DR. POWERS:  We may have some authoritative
     information.  If you'll use the microphone, identify
     yourself, speak with sufficient clarity and volume that you
     can be readily heard.
               MR. MUSCARA:  Joe Muscara, again.  This data comes
     from the voltage-based criterion.  It applies to the support
     plate intersections.  They're required to do a 100 percent
     inspection.  So this data is based on 100 percent inspection
     of the intersections.
               DR. BONACA:  So the question I have now is this is
     the end of cycle 14.
               DR. HOPENFELD:  They're in cycle 14.
               DR. BONACA:  Preparing for cycle 15.  What
     criteria do they use here to flag tubes?  Is there anything
     above --
               DR. HOPENFELD:  Anything above -- I don't know. 
     It used to be one.  Then it went to two and now it went to
     three, if you can show that the support plate is not going
     to move.
               And so obviously this one, I don't know what -- I
     remember Westinghouse once came and they wanted 20.  So I
     don't know which criteria you have.
               MR. SIEBER:  That's just one tube, though, right? 
     Do we know anything about --
               DR. HOPENFELD:  It's more than that.  You have
     3.76 there.
               MR. SIEBER:  Yes, but there's one tube at 13.7.
               DR. HOPENFELD:  One tube at 13.7.  Actually, no,
     not really.  If you took the POD into that, then you have to
     multiply -- divide it by .6, right?
               MR. SIEBER:  It would seem to me the probability
     of detection would be pretty good with a flaw --
               DR. HOPENFELD:  But you don't know what the flaw
     is.  Look, you can have that 13.7 here with a network, very,
     very, very tight network with a lot of cracks and it's not a
     crack going through the wall.  You don't know what it is. 
     That's really the problem.  That is exactly the problem. 
     You don't know where those cracks are.
               MR. SIEBER:  Well, I don't know what the
     characteristics of the flaw is for that tube, either.
               DR. HOPENFELD:  Right.  That's really the reason. 
     That's the problem with this concept.
               DR. POWERS:  If we argue, for purposes of
     argument, suppose that the probability of detection is 100
     percent.  This is a 100 percent inspection of the tubes and
     the tube support plate and surely this must represent a
     failure of the prediction from cycle 13.  I presume cycle
     13, everything was plugged, such that they would have
     expected nothing to go over whatever their voltage limit
     was, which I presume was about three volts.
               DR. HOPENFELD:  I don't know.
               DR. POWERS:  Joe Muscara told us that it's 100
     percent inspection at the tube support plate.
               DR. HOPENFELD:  He said on the 13 was also 100
     percent?
               MR. MUSCARA:  It was 100 percent inspection.
               DR. POWERS:  So what the slide clearly
     demonstrates is that there has been a failure of the
     predicted method.
               Now, all right, predictive methods have some
     probability of failure and presumably the question is
     whether this is an excessive one and I think what the
     speaker is arguing is yes, it clearly is, because it goes
     over the one gallon per minute limit.
               DR. HOPENFELD:  Another point -- Dr. Powers, there
     is one more point here.  I didn't bring all of them, because
     there is a limit to the time we have, but if you look at
     other plants, they're showing the same thing.  This is not a
     single event, and I will summarize that later on.
               It's not a unique event.
               DR. BONACA:  It would be certainly for the purpose
     interesting to see the previous reading for one plant to see
     two or three and see how that travels, if it travels.
               DR. HOPENFELD:  That's correct.
               DR. BONACA:  And we don't see that here.
               DR. HOPENFELD:  Right, because the reason is I was
     just trying to make my point here that it's not -- the
     history is not -- you can't -- it's like the stock market. 
     You can't look back and say, well, you know, this stock was
     doing pretty good, it's going to do the same thing next
     year, it's not.
               DR. BONACA:  I mentioned it because to the extent
     there is information you can provide over the next two or
     three days, it would be interesting and important.
               MR. BALLINGER:  In the case of Indian Point Unit
     2, the previous cycle inspection was not 100 percent
     inspection.
               DR. HOPENFELD:  But that wasn't because of -- the
     failure was not in the support plate.  It was somewhere in
     mid span. 
               Okay.  Let me elaborate a little bit on the field
     experience.  I'll read this off.  The first one, the Trojan
     was one, it wasn't -- it was a sleeve.  It wasn't a crack,
     but it did show that the eddy current -- it was the first
     time I think that they have eddy current the sleeve and it
     was supposed to work.  Well, it didn't.
               This is a quotation from Inside NRC that Arkansas
     had -- was consistently wrong in its prediction during the
     inspection, as to what the predictions as to the voltage and
     should be, and I don't know where they got the information. 
     They must have talked to somebody, but it's a quotation from
     inside NRC.
               I already mentioned Farley.  This is a very
     interesting one and we're going to spend a lot of time on
     this one, Breakwood and Byron, because when they had these
     large, observed these large voltage growth, and I think it
     was in '95, back in '95 or '96, I don't remember, even
     earlier than that, they said they came to the NRC and said
     we got this large voltages, would you allow us to fix that
     support plate so it won't move.  I won't guarantee it won't
     move, although a member of the ACRS was under the impression
     it's not going to move anyway.
               Well, now they're coming in and they say we're
     going to fix those things, we'll put some tie rods in there
     or plug some of the tubes and those tubes will prevent the
     support plate from moving.
               And they came in and I don't know whether that's
     part of my presentation, this point might come up later,
     they came back and provided a rationale why that they had
     the capability of tying these support plates so they won't
     move.
               This is a very important point and I will come
     back to it later, but it's lengthy, so I just would like to
     leave it for later on.
               And then recently, I understand there was some
     eddy current at a plant that only a visual observation
     showed that it was leaking.  It wasn't the eddy current.  So
     what you see throughout here, throughout a period of eight
     years, eddy current is not an absolute thing.  It's the best
     we have, but it's not absolute.
               Okay.  Another adjustment that we have, and this
     is a very important point, I'd like to spend a lot of time
     on this.  If you go back to NUREG-1477, all the analysis,
     all the studies are based on that pressure differential, the
     delta P is the one that controls the damage.
               Now, there's a large potential during the
     blow-down event for damage of the tubes.  You have energy
     there that is way above what you need, if you take all the
     tubes together, you have energy in there way above to
     rupture any tube ten times over.
               So the question, what's the efficiency of this
     potential stored energy that you have there to break the
     tubes, and then you have -- during the event, you have
     hydrodynamic loads that bent the -- that could bend the
     tubes, and you also have forces due to the tube sheet
     moving, moving the tubes.
               Now, one important point to make here, and I will
     come back to this again, that these motion of the tube sheet
     and motion -- the constraint of the support plates were
     designed under a condition of 1,500 pounds.  That's how the
     plant was designed, 1,500 pounds.
               But here the forces that we have are all the way
     to 2,500 pounds.  So the plant wasn't designed to withstand
     this kind of environment.
               When you go into the laboratory data, and, again,
     I don't know why it's proprietary, but I may take a lot of
     force to pull some of those tubes.  Sometimes it may take --
     they will just come out.  Some, it takes a lot of force to
     pull them out.  So now we've got this big, huge, massive
     tube sheet pulling those -- pushing on those tubes and you
     have thermal expansion in the system, too.
               So what do you think is going to happen?  Either
     the tube is going to give in, probably is going to give in,
     bend or collapse, and open up more area for a leakage.
               Another mechanism in there that you have is a
     potential for vibration.  You have -- during the event, you
     have a mechanism to set up -- to amplify the natural
     frequency of the tubes, and since there is a large amount of
     energy, the vibration could bend them and, again, increase
     the leakage.
               So you have axial forces that can also break the
     ligaments and you see that.  I mean, you pull those tubes
     out of there and they -- the ligaments are torn.  It's not
     what you have in the -- what you started with before you
     pulled the tube.
               So then you have excitation frequencies that may
     equal the natural frequency, which what it does is really
     amplifies the amplitude of the motion of the tube within the
     support plate.
               And what I would like to do, and I don't know when
     we're going to break for lunch, I would like that after the
     break, that Mr. Robert Spence discuss his experience with
     tube vibration.
               Now, if you remember back to the timeline,
     Research goes to NRC and to NRR and tells them that we have
     never experienced a steam line break in this country.  Well,
     that's just not true and Mr. Spence will describe his
     experience with it.
               The most significant part of it is that evidently
     there are frequencies of that event, like an earthquake, I
     guess, that excite natural frequencies or some components of
     the energy sufficiently large that you can get a lot of
     damage.
               So I would ask him, later on -- I don't know. 
     When are we breaking for lunch?
               DR. POWERS:  We are past what our scheduled break
     time is.  I thought we could come to finishing this point
     and that would lead naturally into Mr. Spence's
     presentation.
               DR. HOPENFELD:  Yes.  I would like to get into
     that --okay.  So I would like to spend another five-ten
     minutes about this, and then Mr. Spence will take over and
     talk in the details about that.  I just want to give you a
     little bit more my perspective, but he is much more
     knowledgeable in that.
               But I would like to show you where I come from on
     this, because I'm not a vibration expert.
               DR. CATTON:  Joe, your argument is not that that
     statement is incorrect, I hope.
               DR. HOPENFELD:  Which one?
               DR. CATTON:  The first one, leakage is the
     function of pressure differential only, because it is.
               DR. HOPENFELD:  No.  If you --
               DR. CATTON:  Let me finish.  What NRC misses is
     the change in the characteristics before and after the MSLB. 
     It's not that it is not a function pressure differential
     only, because it is.  It's just it's changed.  I have a new
     --
               DR. HOPENFELD:  Okay.  I am stating what NRC says,
     that's all I'm saying.
               DR. CATTON:  Well, but that's true.  That's a true
     statement.  Yes.  But you have to include what happens --
               DR. HOPENFELD:  Okay.  I see your point.
               DR. CATTON:  -- to the generator.
               DR. HOPENFELD:  I see your point.
               DR. CATTON:  You put a statement up like that and
     you leave yourself wide open.
               DR. HOPENFELD:  Okay.  I see your point.
               DR. CATTON:  Because it's a true statement.
               DR. HOPENFELD:  Okay.  It is a true statement,
     yes.  It is a true statement --
               DR. CATTON:  However, the following is neglected.
               DR. HOPENFELD:  Right.  You're absolutely right. 
     I should have said, well, if you -- it's a true statement if
     the following doesn't happen.
               DR. CATTON:  That's right.
               DR. HOPENFELD:  If you have a pipe and it's
     pressurized, the only driver is delta P.  But if that pipe
     flexes and breaks -- well, what the point is here, Ivan,
     that it's not only the -- the bottom line here, it's not
     only the pressure, it's also the area, the opening area is
     going to be affected by these other forces.
               DR. CATTON:  It changes.
               DR. BONACA:  Yes, it changes.
               DR. HOPENFELD:  I just want to make sure we're all
     awake.
               DR. CATTON:  I had trouble following what you were
     talking about in your written discussion because of that
     kind of a statement.
               DR. HOPENFELD:  Okay.  I'll do better next time.
               DR. KRESS:  Joe, your second bullet under A, what
     does that -- would you explain what the stored mechanical
     energy is?
               DR. HOPENFELD:  Okay.  You have -- you have this
     big vessel, ten feet in diameter, 30 feet high.  You have
     inventory of water in there at 1,000 pounds and at 550
     degrees F.
               You suddenly, all that energy -- suddenly you open
     the cap, all that energy comes out.  So if you look at the
     enthalpy of this, there is a lot of energy in there at that
     enthalpy.
               DR. KRESS:  That's the enthalpy you're calling the
               DR. HOPENFELD:  That's the thermal energy, right.
               DR. KRESS:  You're calling enthalpy mechanical
     energy.
               DR. HOPENFELD:  Right.  The thermal energy.  You
     say we'll take that and you say, well, that's the first
     thing, if it doesn't pencil out, you don't look beyond that. 
     And this does show you that there is a potential there, and
     it doesn't mean that -- I don't know, conversion could be
     very small.
               Mr. Spence evidently had seen one, he had been
     next to it, and he'd tell you that it wasn't a little wind
     passing by and he'll tell you the thing flew up 150 feet in
     the air.
               So the energy is there.  Now, what damage it's
     going to do, I don't know.  I honestly don't know.  But
     these people, when they come tomorrow and talk to you about
     this and they'll tell you about all the test data they ran
     under internal pressure only, I think you ought to ask them
     about this and it's the burden on them is to prove to you,
     to show you that these delta P's, that's all there is. 
     They've made the calculations, and I'll go back into that
     and discuss this thing after the lunch.
               DR. POWERS:  I think, at this point, we can take a
     recess for lunch until ten after the hour.
               [Whereupon, at 12:10 p.m., the meeting was
     recessed, to reconvene this same day at 1:10 p.m.]
     .                           AFTERNOON SESSION
                                                      [1:10 p.m.]
               DR. POWERS:  Let's go back into session, and I
     guess, at this point, we'll turn the floor to Mr. Spence.
               MR. SPENCE:  Thank you.
               Dr. Hopenfeld asked me to discuss the resonance
     vibrations that I witnessed during a main steam line break
     at Turkey Point 3 in 1997, as well as review past operator
     experience on steam generator tube ruptures, which I'll do a
     little bit later.
               I should say that, in so doing, I'll present my
     own views only, and experience, in the role of independent
     reviewer of U.S. and foreign operating experience that I've
     done for AEOD and Research for the last 10 years as a
     reactor systems engineer.
               To establish my credentials to talk on this
     subject, I've been a member of NRC augmented inspection
     teams and human performance teams investigating operator
     performance during events.
               To qualify as a headquarters operations officer,
     where I assessed the safety significance of reactor events
     in real time to initiate the NRC response, I attended NRC
     systems and simulator courses for each type of nuclear
     reactor in this country, including Westinghouse.
               I've been in charge of the conceptual design of
     the nuclear island for a 600-megawatt, barge-mounted
     Westinghouse reactor for offshore power systems.
               Earlier, as a systems engineer, I worked on heat
     exchangers, valves, pipes, piping design.
               I worked as a turbine operator during a three-
     month strike and a licensed research reactor operator, and
     most importantly to this effort, I was a start-up engineer
     working for Florida Power and Light in the operations
     department during hot functional testing on the two
     Westinghouse units at Turkey Point, when the main steam line
     break occurred there.
               Now, when -- I knew very little about this DPO
     until the EDO appointed me at Dr. Hopenfeld's request to
     serve on a previous DPO panel.
               As Dr. Hopenfeld mentioned, the ACRS approved
     Generic Letter 95-05 as an interim measure, which has become
     essentially permanent.
               NRR is approving increases to Generic Letter 95-05
     alternate repair criteria to 3 volts now.
               But while I was on the panel, I started reviewing
     stuff and found many questions about the technical basis for
     GL 95-05.
               I found unpredictable tube leaks, tube leak
     breaks, and little defense-in-depth against the main steam
     line break that, in my opinion, will result in steam
     generator leaks or ruptures.
               Now, I didn't form that opinion while I was on the
     panel but only afterwards, when I was researching it in more
     detail to appear here.
               After a number of Dr. Hopenfeld's safety concerns
     were ruled out of scope, I recommended that the EDO dissolve
     the panel.
               Now, I cannot adequate address those issues in a
     public forum because of the restrictions placed on the use
     of proprietary design and test information and the emergency
     response guidelines.
               I did provide you a copy -- a proprietary copy of
     my slides for GSI 188.
               There were concerns this morning that Dr.
     Hopenfeld mentioned that he said he couldn't identify.
               Some of those issues, some of the numbers,
     etcetera, are in that package that you have.
               The heart of this matter is really in the
     proprietary information, and I hope that you have access to
     that to review it.
               I noticed you mentioned that you didn't.
               DR. CATTON:  I didn't look at the stack of stuff
     given to me this morning.  Maybe it's in there.
               MR. SPENCE:  Okay.  Only part is, but there's
     masses that aren't.
               Okay.
               At NRR's recommendation, vibration during a main
     steam line break is now being considered as a potential
     generic safety issue, and that's what that's all about.  We
     meet next week.
               That identifies technical inconsistencies in the
     basis -- in the technical basis for GL 95-05.  It also poses
     questions about the Robinson 2 and Turkey Point 3 cladding
     separation, tube leaks, and main steam line breaks that may
     necessitate on-site investigation to answer.
               The GSI panel -- it's my understanding the GSI
     panel will not be allowed to do that.
               I believe that these issues will simply be
     incorporated into Dr. Hopenfeld's GSI 163, which has lain
     dormant for many years despite its high priority.
               The GSI 188 panel can only recommend whether more
     study is warranted, but only your panel can recommend
     whether Generic Letter 95-05 should be rescinded or can be
     rescinded.
               I believe there's enough evidence available that
     you will be able to make a decision on the fate of GL 95-05
     without further research.
               In the few minutes Dr. Hopenfeld asked me to talk
     in, I can only summarize the lessons that appear to have
     been forgotten from the cold hydros and the steam line
     breaks at Robinson 2 and Turkey Point 3 without going into
     proprietary information.
               Both experienced cladding separation and tube
     leaks as a result of their cold hydros.
               You have the information on Robinson 2 in that
     proprietary presentation.
               That's the Robinson 2 steam generator with the
     tube sheet and the divider plate, okay.  The next slide's
     going to show this area here and what happened to it during
     the cold hydro.
               There's going to be three areas that, when you
     have 2,000 pounds or 2,500 pounds or whatever the pressure
     is in the reactor vessel or the safety injection system or
     CVCS charging pump pressure in here, and this, during a
     steam line break, is going to be open essentially to
     atmosphere, assuming that the leak rate is small at that
     point, this here will curve up a little bit, in the middle
     of the D, and this here -- this also in here will raise, so
     you'll have a little bit -- you'll have like that, as well
     as superimposed -- I don't know.  I didn't do that well.
               DR. POWERS:  I think we understand.
               MR. SPENCE:  You got the idea?  Okay.
               This is -- this came out of one of the Robinson
     reports that I believe you have, but it shows the cladding
     separation in here, it shows the weld problems here, and
     this was on 20 to 30 tubes, and it affected the first row --
     80 tubes worth of the first row.
               Okay.  And they observed cracking in this area
     here.  This is the divider plate.  It had come across the --
     this is on the welds of the tubes, okay?
               Now, I do not have pictures of the Turkey Point
     thing, but at Turkey Point, after my crew was running the
     hydrolazer pump, we had trouble maintaining pressure and
     barely got done with the inspection of the primary system
     before we went down to lower pressure.
               Afterwards, I stuck my head in the steam
     generator, saw the drips coming from a tube and surrounding
     wetness on the tube sheet, okay?
               I didn't see any cracks, but for example, if this
     was the tube, stuck my finger up inside there and noticed
     for sure that it was leaking inside the tube, not at a weld,
     and then I noticed water around here that was not leaking,
     okay, but it wasn't right next to the tube sheet.
               I can't tell you which steam generator it was.  I
     can see the leak, but I can't tell you what steam generator
     it's in.
               Okay.
               Because of -- now, at Robinson 2, they ran the
     test pressure basically at 3,000 pounds, 3,100 pounds on the
     primary side, and they had the secondary side of the steam
     generator open to atmosphere.
               Hearing of the results of their cold hydro, Turkey
     Point went ahead and pressurized the secondary side of the
     steam generator so that the delta P across that tube sheet
     would only be a few thousand pounds, perhaps a little bit
     larger, 2,000 psi, and I assume it was not a hydro test
     pressure but some kind of normal operating pressure, but I
     have not been able to find the numbers.
               Regardless, at Turkey Point, the cladding
     separation was not as severe as experienced at Robinson 2,
     but it still occurred at differential pressures across the
     tube sheet that could happen in a main steam line break.
               Okay.
               Now, despite its 2-foot thickness, the tube sheet
     will bow up slightly in the middle of each D, as well as the
     divider plate, and it will push up some of the tubes,
     probably the ones in here and the ones in here worst.
               The tubes are held in place to tube-to-tube-sheet
     welds in this area here, okay, and metallic oxides in the
     gaps between the tubes and the tube support plates.
               If the tube support plates remain in place, then
     the tubes have either -- either have to bend or slide
     through the tube support plate.
               However, parts of the upper and lower tube support
     plates are expected to vibrate at their lowest natural
     frequencies despite stay rod, spacers, bars, and wedges
     welded to the wrapper.
               Now, on page 48 of your proprietary hand-out, I
     think, based on a tech spec amendment that South Texas
     project recently put in, that I believe has not been
     approved yet -- is that right?
               MR. LYON:  That is correct.
               MR. SPENCE:  Okay.  Thank you.
               They only asked for a 3-volt alternate repair
     criteria increment for tube support plates 3C, Charlie
     through M, Mother, because they, quote, did not -- do not
     deflect significantly relative to any tube during normal
     operation or design basis accidents.
               Well, that leaves tube support plates A, D, N, P,
     Q, and R.
               Now, A is the first tube support plate going
     across here, B is an economizer section, and N through R are
     all the way up at the top.
               DR. SIEBER:  What model steam generators are
     those?
               MR. SPENCE:  Warren?
               MR. LYON:  Warren Lyon.
               I believe that's a Model E, if I remember
     correctly.
               MR. SPENCE:  44-E?
               MR. LYON:  All I remember is the E.
               MR. SPENCE:  Okay.
               Now, I have personally seen the resonance
     vibrations from the steam line break at Turkey Point set up.
               I tried to describe my experience in the May 22nd,
     memo that you have copies of, of this year.
               Just very briefly, I came out of the control room
     a little after seven o'clock in the morning to do a round
     before turnover.
               I was the shift start-up engineer on, and I saw
     this valve with the steam coming out of it.  We had already
     had leakers on here.  So, I went up to investigate it.
               I got about to this area, and there was something
     in here -- I think it was some type of scaffolding, but I
     couldn't see the top of this.  But I started hearing
     simmering noises, and they were increasing.
               I had already been through a steam line break over
     in the fossil plant, I knew what it sounded like, etcetera,
     and I went from here to here to here to here, and it blew
     off the line.
               This here cracked, double-ended guillotine, if you
     will, right at the full circumferential break here.
               These two hit the containment wall and then went
     up, and by the time I was here and I heard the noise, I
     looked up, I saw the valves, and they were about at the --
     towards the top of the containment, and then they fell down
     a couple stories down.
               The second boom came from here, and this valve
     here blew off.
               What they later found the problem was is that the
     piping system was designed -- was not designed to take the
     forces, the reactor forces here from relieving of the
     valves.  These valves previously had only been pop-tested
     for setting.
               One point I will mention, in the proprietary
     thing, I've given you my opinion on what would have happened
     if these valves had not blown off at that particular time.
               This was, again, hot functional testing; there was
     no fuel in the pot.
               There was no procedures in place to test the
     operation of these valves.
               The SAR said that they were going to look at doing
     a trip test on the turbines as the power level increased,
     but the procedures did not call out for that.
               This was December 2nd of '71.  On November 24th of
     '71, the AEC identified that little problem to Florida Power
     and Light Company.  It would have been a most interesting
     thing.
               There were a couple of causes for this, and that
     is, the supports here were designed so that the steam line
     had to grow out this way, okay, and it had to move -- these
     things here had to move north and south.  This is north,
     that's south.  So, it had to grow east, south, and north at
     the same time.
               When this valve is shut, okay, this cannot move --
     the thermal expansion is such that it's not going to move to
     the west, okay?
               So, now you're also putting a very high stress on
     the saddle here.
               I think you'll find that the reports I'll pass on
     to you in the next few days do not have a specific number,
     okay, on stress level, but to give you an indication,
     bending moment here is 188,000 foot pounds.
               Now, the results of the steam line break were
     tremendous.
               The piping here, especially down below, moved six
     to eight inches.  You could see it on the supports.
               The turbine duct here was oscillating maybe a
     couple inches up and down.  Everything was moving at
     different frequencies.
               Stuff was going to its lowest natural frequency,
     okay?
               When I got into the control room, stuff in there
     was moving around, as well.
               The noise was such that the operators could -- we
     basically could not communicate, okay?
               If the safety valves were to have lifted and then
     supported properly, etcetera, okay, the safety valves can be
     designed to avoid frequencies under 50 hertz.  Pipe breaks
     cannot be tuned that way.
               Now, I've been unable to find data on the lowest
     natural frequencies of the tube sheet, the U-tube assembly,
     which will have its own individual frequency, or tube
     sections between the tube support plates, okay?
               The tube support plates and tube sheets interact
     in an extremely complicated three-dimensional manner during
     a steam line break that, to my knowledge, has not been fully
     analyzed.
               In fact, the RELAP-5 computer code that the NRC
     and Westinghouse relies upon is a one-dimensional thermal
     hydraulic code, it does not model two-phase transient
     turbulent flow, cross-flow, or time-dependent resonance
     vibrations or frequencies.
               You've been supplied with a copy of a letter from
     Dr. Ward to me on that subject, and Dr. Ward -- I understand
     NRR has got him here in the next day or so, so you can ask
     him about it, if you'd like.
               I believe that resonance number one will be set up
     within the steam generator.
               If they're strong enough to do what I observed,
     they're strong enough to go back through the piping system,
     through the shell, through the wrapper, through the tube
     sheet, through the hydraulics of the oscillations of the
     sonic booms.
               Now, that's something I didn't tell you about. 
     Sonic booms occurred at maybe one to three cycles per
     second.  In an emergency, I don't judge time right, you
     know, so don't quote me on that one, but it's boom, boom,
     and it was very noticeable.
               What was interesting to me is that continued at
     the same rate, not like you'd expect with a pressure
     decreased in the steam generator but at the same rate
     throughout the entire event, until the end, and then, it
     became longer and even louder, with some gigantic booms
     before it stopped down to quiet, okay?
               The reason I started getting into this is because
     I think it's NUREG 6365, as well as 1477, have diagrams of
     the pressure -- secondary pressure, and they didn't look
     right to me, because they didn't match what I had
     experienced, and I started talking with Dr. Ward about it.
               Now, I believe the resonances in the steam
     generator are going to cause tube bending, which is going to
     increase the crack growth, as well as movement between the
     tubes and the tube support plates.
               It's going to increase the crack growth by erosion
     of the lengths between the cracks, both micro cracks and
     macro cracks, through both wear and ablation, and later,
     you'll get some theoretical -- I think it was ASME articles
     on the wear evidenced by movement of tubes.
               I think it's going to expose some of the cracks in
     the intersections that are allowed by GL 95-05 to the
     secondary side and, hence, to the atmosphere.
               Now, when you have a tube support plate that's
     partly moving up here and the next tube support plate is
     moving down here because you have different frequencies --
     each one of the tube support plates has got different
     frequencies, and that's all proprietary information, and
     that's about all I can say about that, but take a look at
     the numbers.
               Now, if there's cracks in there and those cracks
     happen to be especially towards the tail-end of the voltage
     distribution, those are going to be the biggest cracks, and
     those are the ones that are going to open up.
               The closer it gets to through-wall, the more
     chance of it opening up during a main steam line break.
               There's also some proprietary information that,
     once a crack gets outside the tube support plate
     intersection area, there is a very low correlation between
     the exposure of that crack -- let's say, for the sake of
     argument, that this is a tube support plate.
               If the crack is in here and it comes up in here
     versus it comes down to here, there's very little
     correlation between the amount of flow coming out of that
     crack and the amount of distance that the crack is exposed.
               Now, the size of the steam line break and the
     operator actions that are taken will have a significant
     effect on the amount of time this common mode failure
     mechanism is working.
               The longer the mechanism is working, the more
     crack damage they'll cause.
               DR. SIEBER:  Question.
               MR. SPENCE:  Yes, sir.
               DR. SIEBER:  From your observation at Turkey
     Point, once this transient has gone to termination --
               MR. SPENCE:  Yes, sir.
               DR. SIEBER:  -- if you inspect the steam
     generator, do things come back to their normal position, or
     is everything permanently upset or deflected or bent or what
     have you?
               MR. SPENCE:  I did not inspect the internals.  I
     cannot answer that question, but it's a real good question. 
     I inspected -- a reactor operator and I went out and
     inspected the area before we turned the RCP back on, and we
     could observe some movement inside the containment, but we
     couldn't observe any damage, any movement out -- you know,
     that the steam generator area was not designed for.
               DR. SIEBER:  The reason why I asked the question
     is that, if you did have a permanent deflection in a tube
     support plate, that would potentially uncover permanently
     some of the cracking that would have occurred and leave you
     in a more vulnerable situation as far as crack growth and
     leakage.
               MR. SPENCE:  I will be showing an interesting
     slide a little bit later on that subject.
               DR. BALLINGER:  Can I ask a question?
               MR. SPENCE:  Yes, sir.
               DR. BALLINGER:  Was there any estimate of the
     amount of flow through that opening, as compared to the
     normal 100-percent-power steam flow?
               MR. SPENCE:  I don't remember seeing a number.  I
     know, in CE reactors, their restriction orifices on the main
     steam lines are 170 percent.  I've heard that, in
     Westinghouse, it may be less than that.  I'm not sure if
     that number is proprietary or not.
               DR. BALLINGER:  You have several relief valves,
     and it looks like two of them blew off.
               MR. SPENCE:  Three of them.
               DR. BALLINGER:  Out of four?
               MR. SPENCE:  Yes, sir, on the one line.
               DR. BALLINGER:  On one line, but there are --
     there's another eight.
               MR. SPENCE:  On the other two steam generators,
     yes, sir.
               DR. BALLINGER:  Okay.  So, I'm just curious as to
     what fraction of the flow you had compared to the 100-
     percent power flow from that steam generator.
               MR. SPENCE:  The report I read said that the --
     I'm sure it would have been in excess of 100 percent, but
     exactly how much, I don't know.
               The report I read said that the flow was within
     the restriction orifice capability.  In other words, the
     restriction orifice was not choking the flow.  The choking
     was coming at the break area.
               DR. SIEBER:  Do you have any idea of what
     difference in flow there would be with the valves just blown
     off, compared to all those valves open, like you would get
     on a reactor trip?
               DR. BALLINGER:  That's what I was getting at.
               MR. SPENCE:  Okay.
               DR. SIEBER:  They're, what, two-and-a-half-inch
     valves?
               MR. SPENCE:  There's going to be a difference for
     the steam generator, because the steam safety valves are
     tuned.
               DR. SIEBER:  Right.
               MR. SPENCE:  They're not going to have a 50-cycle;
     they're going to have higher, okay?
               So, I wouldn't worry about a full thing.  What it
     is, it's the cycles that the steam line is --
               DR. SIEBER:  This is the pulsation.
               MR. SPENCE:  The pulsations from the steam.
               DR. SIEBER:  Right.
               MR. SPENCE:  That's what's going to kill it.
               DR. SIEBER:  Okay.
               DR. BONACA:  You're not aware if, prior to
     operation again, the plant had a major outage on the steam
     generators?
               MR. SPENCE:  The plant was -- it was delayed by
     more than half-a-year because of this.
               I mean it took -- I didn't tell you about all the
     damage, but it took -- I remember, I couldn't get back up
     here to look at this.
               I think this thing was gone.
               There was damage to this valve, to a bypass valve. 
     There was a pressure -- a tap on here that was gone.  This
     whole -- it was a mess.
               DR. BONACA:  The question I had was regarding the
     steam generator, specifically, the internals.  Do you know
     if there was major work done on those?
               MR. SPENCE:  Shortly after the blow-down, the
     operations superintendent and I were talking about it, and
     we were both concerned about the steam generator internals. 
     I don't know the full results of that, but I know there was
     some investigation done.
               The reports show that there was a one-word
     sentence that Westinghouse steam generator experts looked at
     it and said it was okay.
               Yes, sir.
               DR. SIEBER:  Does the Model E steam generator have
     a pre-heater on it, as I recall, with cross-flow paths?
               MR. SPENCE:  Yes.
               DR. SIEBER:  And would that make a difference as
     far as the dynamics of the way the steam generator operates? 
     I think the cross-flow is on the cold leg side.
               MR. SPENCE:  Yes, it would.
               DR. SIEBER:  To me, it would change the vibrations
     and also change the forces the tube sees due to the flow
     while the stuff is rushing out of there.
               MR. SPENCE:  That's exactly what I was talking
     about with the RELAP code, is the cross-flow would be
     especially --
               DR. SIEBER:  I don't know how you would model
     that, but a Model 51 or 53 doesn't have that feature to it,
     correct?
               MR. SPENCE:  I would suspect that it would have
     less trouble, and it depends where the break is.
               In a steam line, it's one thing.  If the break's
     in a feedwater line, it's another.  So, now you've got
     everything going down backwards, too.
               DR. SIEBER:  Well, on the Model E, the feedwater
     came in pretty close to the bottom, as I recall, whereas 47s
     and 51s, it came in at the top, went around the sparger ring
     with the J-tubes and then down the wrapper, and so, if you
     broke the feed line in a Model 51, I think you would get
     steam out, as opposed to hot water, because it's high in the
     steam generator.
               The only thing that goes in at the bundle area is
     the aux feed, right?  It also goes in pretty high.
               DR. HIGGINS:  Do you know if, during any of the
     testing that the NSSS manufacturers did, they did main steam
     line break simulations with, say, scaled models on steam
     generators?
               MR. SPENCE:  I have not seen -- they did the MB2,
     but that wasn't --
               DR. HOPENFELD:  No.
               MR. SPENCE:  No, I know of no such testing. 
     That's not to say it doesn't exist, you know, but I haven't
     found it.
               DR. HOPENFELD:  They may have done it in-house at
     Westinghouse, but they haven't provided us the data.
               DR. CATTON:  Those of us who tried to do
     experiments to simulate the GE system ran into all kinds of
     problems with this.
               What you have is you have a series of contractions
     in the flow paths, so you have volumes, and all of these
     start to interact.
               They choke and un-choke, and each time they choke
     and un-choke, you get pressure spikes.  It's just really
     bizarre behavior.
               And then you compound it because of the high flow
     rates out.
               There's a critical velocity above which you begin
     to get fluid-induced vibrations, whereas a CE generator,
     they know what these are, because they measured it.
               The Westinghouse, as near as I can tell, guess at
     it, and actually, at North Anna, they got in trouble when
     they changed the recirculation ratio just a little bit.
               If you're anywhere near this, you're going to get
     all kinds of tube vibration.
               I doubt that it would impact much a new generator,
     but if you had one that had cracks that were -- it's
     certainly going to loosen everything up, and then the
     supports -- at each set of supports -- and I don't know how
     many you mentioned, but it sounded like there were a lot.
               As you depressurize this system, you are going to
     get pressure loads across these supports, and they are going
     to move up and down, because they're going to choke and un-
     choke.
               It's a rather chaotic process.
               DR. BALLINGER:  If you have dented support plates
     where they're cracked and you have this kind of thing,
     what's likely to happen to those support plates?  In some of
     these older steam generators, there's a lot of hourglassing
     in the flow slots, and there's a lot of cracking in the
     support plates.
               So, that's another complicating factor.
               MR. SPENCE:  Let me throw in some more
     complicating factors, and then I'll talk a little bit about
     time and break size, too, because a smaller break will take
     longer to depressurize the steam generator.  That means the
     longer steam generator tubes are subjected to these common
     mode failure mechanisms.
               In Robinson 2 case, they only had a six-inch
     break, and it took them an hour to depressurize.  In Turkey
     Point 3's case, it took only a few minutes.  They say they -
     - it was about three.  I think it was about five, because I
     know it went down below -- it still kept -- it kept blowing
     after the instrumentation went to zero.
               It took three to five minutes to depressurize
     during the initial blow-down, but then the steam generator
     repressurized, okay?
               As I was leaving, about an hour later, it was
     blowing out the holes at, I'd estimate, 15 to 20 feet per
     second.
               Now, if my analysis is correct, one could expect
     to see tube leaks or tube wear in grooves where the
     magnitude of the differential movement between the tube
     support plates was high.
               I have no data on Robinson 2, but Turkey Point 3 -
     - can you pick out the steam generator that had the problem? 
     Interesting, right in the groove, and this is the 3A steam
     generator where it happened, this is B, and that's C, and I
     think there were a couple little things down there, okay?
               A and C had the cladding separation during the
     cold hydro, B did not.  So, you might have some effects from
     the two.
               Now, the numbers that were -- the numbers, I
     think, 20 -- I think if you count these up, you got more
     than 20.
               Now, this was for the first ISI inspection in '74. 
     So, that was basically one year's worth of service, okay?
               I talked to a metallurgist out at Region III,
     said, hey, it takes a few years for the corrosion products
     to start doing the kind of stuff that we're talking about,
     that would normally take out tubes in the steam generator.
               DR. BALLINGER:  Let me be clear on this.  This
     generator is the one that went through the cold -- they all
     went through the cold hydro.
               MR. SPENCE:  They all went through the cold hydro,
     but these two had the cladding separation, A and C.  B did
     not, for whatever reason, okay, and A is the one that went
     through the blow-down.
               DR. SIEBER:  After the blow-down, did they do a
     pre-service examination again, or had they done that before
     and said we don't need to do one?
               MR. SPENCE:  I'm going to give you a smart-aleck
     answer.  I don't know, because I left.  I got an office job. 
     I used up too many of my nine lives there.
               Okay.
               Anyway, there here -- now, when I was on the
     panel, I suggested we go down to Turkey Point and find out
     what caused this, let's find out when the tubes were
     plugged, etcetera, let's check the traces on the eddy
     current test, and that was ruled out of scope.
               I also asked my supervisor here -- excuse me -- my
     manager, with respect to the GSI 198, and that's not going
     to be done in that one either.
               It would be a nice idea to check what happened to
     the tubes at Robinson 2 afterwards.
               Okay.
               Resonance vibrations and tube-to-tube-support-
     plate movement are not modeled, and GL 95-05 required
     industry testing of tube samples.
               I also noted some other concerns about the
     industry testing, but they're proprietary in nature, and
     they're in your packet.
               Resonance vibrations and relative tube-to-tube-
     support-plate movement during main steam line breaks are
     common mode failure mechanisms that can drive the issues in
     this DPO, and I think that's exactly why he asked me to
     serve on the panel, when he heard about my experience down
     at Turkey Point.
               These common mode failure mechanisms would
     invalidate any risk analysis the NRC and industry used to
     support GL 95-05 and conclude that the frequency of major --
     multiple major tube leaks or ruptures during a design basis
     steam like break would be on the order of 6 times 10 to the
     minus 6 or 1 times 10 to the minus 7.  Those numbers, of
     course -- if that were true, then it would not be a problem,
     okay?  I don't believe it.
               Now, a little later, I'll talk about how operator
     response to past steam generator tube ruptures may be
     related to the risk of the steam line break.
               Thank you for your attention and for your
     questions.
               DR. BALLINGER:  I have a question.
               I'm looking at that figure, and it's fuzzy, but
     the legend says that the triangles are plugged due to
     thinning and the little dots say they're affected by
     wastage, cavitation, and erosion.
               Now, that implies, at least, that they know what
     those were, not necessarily due to cladding separation.
               MR. SPENCE:  What's interesting, if you really go
     down the line, you won't find any of them that say there was
     leaking.
               DR. BALLINGER:  That's right.
               MR. SPENCE:  And even though I'm here to tell you
     I've seen it, I've seen at least eight leaks.
               Reporting, back in those days, was not quite as
     robust as it is now.  At least, I hope it's more robust.
               DR. CATTON:  Robust just means that it happens.
               DR. HOPENFELD:  Thank you very much, Bob.
               I think this presentation puts the idea of POD and
     the statistical differences in perspective.  I think you can
     see there are much larger uncertainties here that we don't
     even an ability to cope with.
               Let me just briefly summarize basically again.
               You put those defective tubes back in service, and
     at some time during the zero to 18 months, you have a
     rupture.  Initially, you have a large energy release which
     takes on the order of minutes, and again, it depends on the
     size of the break.  It may take even longer.
               Later on, you get into a longer period of time the
     tubes may be exposed to flow vibrations and then also to the
     motion of the tubes due to bowing or thermal expansion of
     the tube sheet.
               Now, it's important at this point to note -- and I
     think that's where -- that the plants were not designed for
     that kind of a pressure.  They were not analyzed for that. 
     They were designed for 1,550 and 1,600, and all the data
     that is being presented to you, even though the severe
     accidents that are being conducted at Argonne are based on
     2,500 and do not consider the other forces that can come
     into play, it's fine to study creep rupture, to study
     ligament breakage, and model that under internal pressure,
     but that's not really the main issue, unless you can prove
     that that is the driving force for the fracture.
               So, basically, if you put yourself in a position
     of the ligament in a cracked tube, really what makes a
     difference is the stress state of that ligament and the
     pressure forces acting on it due to the delta P in the pipe,
     but there are other forces, as we've heard before.
               So, the question is really, what's the largest
     driving force for breaking that ligament, and the person
     that comes in and shows you all that data -- it behooves him
     to tell you that, really, the driving force show you, prove
     it to you, that what really drives this thing is the
     internal pressure, and they haven't done so, and I hope
     that, tomorrow, you will ask him to show you the numbers
     where all these other forces have gone, why are they not
     being considered?
               Going back to the vibration thing, you can see, in
     the typical steam generator, you have a range of -- this is
     a simple equation of calculating frequency, depends on the
     span length here and the rate use, and this is the
     properties of the fluid and the modulus of inertia.
               The main point of this graph is that, when you
     have rate uses varying between one to two feet, you have a
     whole spectrum of possible natural frequencies, and
     therefore, a whole bunch of possibilities for exciting some
     of the tubes to start vibrating.
               That's the whole purpose of this graph.
               Now, this is probably known to the Westinghouse
     people.  They ran a lot of vibration tests in Florida,
     especially under heaters, I believe, that they had vibration
     problems.  So, they realized.
               But when they come here with an application to
     relax the 2-volt requirement to go to higher voltages, they
     provide analysis of what are the forces on the support
     plates, and those forces are basically based on delta P
     across those plates.
               Now, what they have claimed is that they could
     take a code like RELAP-5 and benchmark it against some data
     that was conducted 15 years ago on the prototypic steam
     generator.  That was a MB2 program.
               Let me tell you briefly a little bit, because it's
     very, very important, and the reason it's important, because
     it shows that -- in those particular case, it was ComEd that
     came in for an application to relax the GL 95-05, and it's
     very important to understand how the process works.
               They take the code like RELAP-5, modify it, and
     they claim they benchmark the thing against some data that
     was conducted on the prototypic steam generator, and then
     it's being approved by NRR.
               Okay.
               That particular test had a slice of a full-size or
     95-percent length of U-tubes but was only a slice of the
     steam generator.
               The tubes were enclosed in a large vessel.  Most
     of the volume, as you will see later, was really occupied by
     that vessel.
               The volume ratio, as you can see here, was all
     basically that empty space.  This was only the volume of the
     tubes.
               So, when you benchmark a code against something,
     the first thing you do is see what the scaling factors --
     whether the scaling factors allow you to do that, and when
     we have looked into the scaling of this -- I have a report -
     - it wasn't meant to be scaled to study the dynamic aspects
     of that kind of a phenomena.
               We didn't have any accelerometers on the tubes to
     measure any vibrations.
               Nevertheless, this experiment is being used as the
     justification to ignore vibration, to ignore all the forces
     that you have on the steam generator, because it was
     benchmarked, so to speak, against prototypic data.
               You can see some of the results -- and again,
     these came from computer codes -- compare the flow quality
     with and without the dead space, and you can see that this
     experiment really had nothing to do with the forces that you
     will have during a steam line break.  Yet it is being used
     as a explanation, as a reason why you could operate under GL
     95-05 at much higher voltages.
               Now if you design a washing machine or something
     and you want to go and put it on the market, you go to
     Chicago, go to the UL people and tell them I have this
     washing machine and I made all these calculations and could
     you give me your stamp, because I don't think it vibrates,
     I've got all these computer codes, they say it won't
     vibrate, they'll throw you out.
               They'll say, well, we want to test it.  They're
     not going to put their stamp on it.
               But Westinghouse comes in here, or Com Edison --
     the work was done by Westinghouse, and we approved it.
               We approved that thing without asking any
     questions, and you can go back, and I think you have the
     SERs, and not even one question that goes into why can't we
     just neglect vibrations?
               The next potential damage mechanism is due to
     erosion from jets.
               You have 2,600 pounds or 2,500 pounds on one side,
     and you have zero pounds on the other side.  You have a
     temperature that varies between 1,700 F under severe
     conditions and, I think, 550 under normal conditions, and
     you have a whole range of abrasive material present.
               Now, if you have any one of those two-phase flows,
     could very severely penetrate and damage the next tube. 
     Just to give you an idea, this is a piece that I got in a
     machine shop.
               It took a few seconds to make these slots with an
     abrasive jet.
               Obviously, it depends on -- this is aluminum and
     it depends on the velocity and the pressure and the size of
     the particles.
               In machining -- in regular machining, the
     pressures are more than an order of magnitude, 15 times as
     high as what you get here.
               On the other hand, these things take on the order
     of a few seconds.
               Here we can have minutes or maybe even hours where
     that jet could cause the damage, and the main problem here
     is that we can't predict -- I believe it's impossible to
     predict how much abrasive particles you're going to have.
               You have corrosion products on the primary side
     and especially during depressurization you have what's known
     as particle burst.
               Then you have this big sludge pile on the bottom
     that you have all kind of material in there.
               You basically have the entire periodic table, the
     source is there, and you can go ahead and use your
     imagination how it's going to be trapped, whether it's from
     the sludge pile or from the primary side or for in between
     the cracks in the support plate.
               So, there is a potential here, and in my mind,
     it's almost impossible to predict, but the people that did
     the research said that they know how to do it, they've got
     these computer codes, VICTORIA, I don't know the various
     names they have, and they can predict exactly how many
     particles and what their concentration and they're already
     running tests.
               So, I'd like to go later on and talk about that a
     little bit more.
               DR. SIEBER:  The sludge pile you're talking about
     is not the one that's ordinarily referred to that lies on
     top of the tube sheet.
               DR. HOPENFELD:  Yeah, that's the one I'm talking
     about.
               DR. SIEBER:  That's on the secondary side.
               DR. HOPENFELD:  Yeah.  If you have a jet coming
     out somewhere, it will carry some of that particle on the
     next one.
               Now, exactly the mechanism, how it does it, I
     don't know, but I'm identifying here sources for particles.
               DR. SIEBER:  All right.
               DR. HOPENFELD:  The primary, the secondary, in
     between, and who knows where else?
               I mean I really don't want to spend my -- I didn't
     want to spend the time to get into the detailed mechanism. 
     I'll leave it to those people who write papers, because you
     can come up with an infinite number of mechanisms, and it
     depends on your imagination, but the source is there.
     
               Now, the material that you have is basically -- on
     the primary side, it's chromium, cobalt, whatever corrosion
     products you have, and silver that comes during the severe
     accident, I think there's a lot of silver in there, plus you
     have all kind of aerosols in there.
               Now, originally, when I started calculating this,
     I took some equations that came from several power plants on
     erosion of blades from droplets from wet steam and I've
     calculated erosion rates or penetration rates through the
     next tube on the order of -- I believe it was on the order
     of minutes, but realizing that there's probably an order of
     magnitude, at least an order of magnitude of uncertainty in
     these kind of calculations, but it's an indication the
     potential is there.
               Later on, the NRR people got some data on -- from
     a coal gasification program, and they came up with very,
     very fast penetration due to these hot jets, and I think
     they came up with something on the order of it took 30
     seconds or so to penetrate through the wall, on the average.
               It depended whether there were particles or not
     particles in the stream.
               There is an industrial experience especially in
     the pulp and paper industry.
               In the early '70s and in the '80s, there are a lot
     of steam explosions occurring in capped boilers, and the
     reason for those, really -- there are many reasons, but one
     particular one, or two of them, that I'm personally familiar
     with -- they were initiated with a pin-hole leak in one of
     the tubes that penetrated the next tube, which was about 1
     inch, and all that water was dumped on that pile of green
     liquor that sits there on the bottom of that boiler.
               It's a big capped boiler.  It's a water-cooled
     boiler about 30 feet high, and when you damage one of those
     water tubes, all that water dumps into the bottom, and you
     have a big steam explosion.
               So, this is not completely way out.  There is a
     potential here for damage because of jets, abrasive jets. 
     It depends what the concentration of the particles is and
     what are the particles.
               You can also have probably a clean jet.  In fact,
     they use a water jet, very small, thin water jets to cut
     wafers in the electronic industry.
               So, it depends on the -- what's going to happen
     here, but you cannot ignore it, and that's really my point. 
     I can't prove that it's there or not, but we've got to
     consider that, and I get really kind of very shaky when they
     tell me that the RELAP codes and all these things are going
     to predict the particle size, and I'll go back into that and
     tell you why they cannot.
               So, basically, on this subject, you have a crack,
     depending on what the pressure is the velocity, somewhere
     down you will form a two-phase mixture, drop and solid
     particles, and they will impinge on the next tubes.
               Now, this is -- because the next tube is already
     corroded, the surface is already gone or cracked, you get
     into a brittle type of erosion.
               You don't need much plastic deformation to cut
     through here, and you don't know how much you really need to
     damage it, but that's the kind of thing.
               If you want to run some tests, you can't just
     start with a nice clean piece of metal to run tests on, and
     it will probably require many samples.
               Now, the research people say that they can get
     this information within several months, and NRR is very
     happy with that.
               DR. POWERS:  Joe, I think I understand how a jet
     can impact an adjacent tube.  What's not clear to me is how
     it propagates any further than that.
               DR. HOPENFELD:  I'm sorry?
               DR. POWERS:  If I've got two tubes, one of them
     leaks, and a jet cuts through the adjacent tube, how does
     damage propagate any further?
               DR. HOPENFELD:  Oh, okay.  That was my next slide.
               DR. POWERS:  Oh, I'm sorry.
               DR. HOPENFELD:  Usually those jets expand, and it
     depends on what is a two-phase, one-phase.  If it's one-
     phase, just plain water, it's not going to expand.  If it's
     pure steam, it will expand quite a lot.
               So, you have something like 400-feet-per-second
     jet hitting it, usually you fan out.  As a rough
     calculation, you can say that you'll double its initial
     size, and then this one will double again, and I don't think
     you have to go too many of this.
               So, that's the potential mechanism for enlarging
     the area between the various jets.
               This one will open, and this next one will go, and
     you can see that very, very fast.  You start with two, then
     within -- what do we have here? -- two minutes, you have 16
     gpm.
               So, it doesn't take many of those 7.6 gpm cracks
     there, the tail of that distribution, to start you going,
     and you have -- if you look at the transient, you about an
     hour to do this.
               Now, what the NRR people have done -- and it's
     discussed in my DPO -- they have, after a long time, agreed
     that there's a potential problem, we ought to look into --
     it's under severe accident condition.
               The same thing -- maybe the chemistry of these
     things is different, but you have the same potential
     mechanism during the design basis accident.
               DR. BONACA:  Let me ask you a question about that.
               DR. HOPENFELD:  Yes.
               DR. BONACA:  You say one hour.
               If I have a steam line break --
               DR. HOPENFELD:  Right.
               DR. BONACA:  -- my primary side will depressurize
     immediately --
               DR. HOPENFELD:  Right.
               DR. BONACA:  -- below the head of the HPCI system,
     and then, if I have no steam generator tube rupture, it will
     repressurize to the head of the HPCI, say 1,400 psi.
               DR. HOPENFELD:  Right.
               DR. BONACA:  If I do have a hole, it will
     naturally depressurize to some intermediate level between
     the high head of the HPCI and somewhere below, because --
               DR. SIEBER:  Because of the pump curve.
               DR. BONACA:  Because of the pump curve.  So, the
     pressurize to which it is exposed now, the jet, will not be
     coming in at the same velocity and the same -- I'm saying
     that -- you know, I'm trying to understand the timeframe for
     this, and it seems to me that larger is the hole by which
     they are pressurized, okay, and more you have
     depressurization on the primary side that you can now really
     repressurize by itself, because you are leaking out of the
     secondary side, so that the phenomenon will be self-
     containing a little bit?
               DR. HOPENFELD:  I don't think so.  No, I don't
     believe it's going to be containing, because -- well, maybe
     the pressure may fall down, but the maximum pressure -- it
     goes back up to 2,500, and that's the reason that they are
     testing it at 2,500.
               DR. BONACA:  I'm saying, by the time you have a
     hole, say one rupture, it's not going to go back up.
               DR. HOPENFELD:  It depends on how many do you have
     and how does that affect the pump.
               I mean if it's very small originally, then you
     don't know.
               DR. BONACA:  It cannot go beyond the shut-off head
     of the high-pressure injection, which is typically 1,400 psi
     there.
               DR. HOPENFELD:  That's right.
               DR. BONACA:  Okay.
               DR. HOPENFELD:  But I don't know how long it takes
     to get there either.
               DR. BONACA:  All right.  Well, the blow-down
     typically takes you below that in seconds.
               DR. HOPENFELD:  Right, but then it comes back.
               DR. BONACA:  Yeah, if you have no steam generator
     tube ruptures.
               DR. HOPENFELD:  It depends on the relatively size.
               DR. BONACA:  If you have a tube rupture, then even
     for one or two, you're going to come back to the shut-off
     head.
               DR. HOPENFELD:  Depending on the relative area --
     and I don't know what that is -- it may not be the 2,500,
     but it will be below that, 1,000 or whatever, but that's not
     what's going to be driving.
               I think the biggest uncertainty is really the
     abrasive aspect of that jet, and you know, it doesn't have
     to be 2,500.
               I used the 2,500 because that's what they're using
     to test these samples.
               DR. BONACA:  The reason why I'm making the point
     on the 2,500 is that, when I look at some of the studies
     being done, for example, by INEL, there is a significant
     dependency between the K's they're assuming, like steam
     break, and the delta pressure that is pertinent to that,
     because that says, although steam line break is less
     frequent than a stuck-open valve, the delta pressure is much
     more severe, it's 2,500 psi, once you have the break on the
     secondary side.
               DR. HOPENFELD:  But you see, they usually assume a
     constant area, which is implicit in those assumptions.  This
     is not really a constant area here.
               DR. BONACA:  Okay.
               DR. HOPENFELD:  Obviously, you can't pull more
     than the pump can pull in there, but this is not exactly the
     same situation, it's somewhere in between.  But your point
     is well taken, 2,500 may be too high.
               DR. BALLINGER:  This also assume a dry steam
     generator.
               DR. HOPENFELD:  Yes, it is a dry steam generator.
               As soon as you depressurize, the procedures are
     that the steam generator does stay dry.  You turn off the
     feed pump.
               Okay.
               After this introduction, after the GL 95-05 was
     put into the -- into effect -- and again, I'll remind you
     again, originally it was meant to be only an interim basis,
     we have erosion of that 1 volt or 2 volts and we're going to
     3 volts and we're going above that, and again, the rationale
     that is being provided -- and I already discussed that -- is
     that we can prove and show you -- that's what the licensee
     says -- that we don't have any damage using this MB2 data to
     indicate to you the forces on the plate.
               They may move a little bit, and if you go back to
     your proprietary material, you see they moved with one code
     and they don't move with another code, and you can see that
     all of it hangs on a computer code that was benchmarked
     against the wrong data.
               That data was just not applicable, wasn't designed
     for that purpose.
               But what bothers me is that, when you look into
     the SER, we don't even question that, we just accept it.
               DR. BONACA:  Wouldn't the movement of the plate
     have an impact, also, if you stayed with the original
     plugging criteria of 40 percent through-wall?  Don't you
     think it would be much less impact?
               DR. HOPENFELD:  You would think so, yes.
               I think NRR has a very valid point with the
     rulemaking.
               They said we don't think that 40 percent is really
     ideal, we would like to do something else, we want to
     tighten up our regulations, because that 40 percent came
     from some wastage studies, it's not really applicable here,
     so we want to improve that, and I think that the intent was
     perfect, but as they were going along and the industry came
     along and said, hey, we don't need any of that stuff, okay,
     we want infinite flexibility to decide what we want to plug
     and what we don't want to plug, and that's really what the
     problem is.
               Yes, this is not ideal, but the 40 percent served
     us well.
               Nobody tested it, and I think what Bob was telling
     you, he had some potential problems where there was no 40
     percent, these were brand new tubes, and there was some
     potential damage.
               DR. BONACA:  I guess 40 percent was to give you
     some indication of the residual strength of the tube.
               DR. HOPENFELD:  Yeah, well, 40 percent, you know,
     using the ASME code, you just write it off as a corrosion
     allowance and that's it, you forget about it, whether it's -
     - you don't go and start analyzing whether there are cracks
     or not cracks.
               Now, if you want to go in the second level of
     details, you go into the crack propagation and so forth, but
     that's why I think the 40 percent, from what we have, is the
     best thing that we can do at the present time.
               Now, if you remove the vibration, if you remove
     all those loads and the potential of this erosion thing,
     yeah, that's fine, then you can just go to whatever you want
     to go to.
               One thing to explain away the reason why we could
     go to higher voltages is research is going to provide us
     information on how to -- that would allow us to operate with
     higher voltages, and there would be no problem with erosion
     from jets and so forth.
               I'll give you a few examples of the kind of work
     that is now being proposed, that just a couple of weeks ago
     was sent to NRR.
               It's being proposed as the NRC solution to
     operating degraded tubes, a potential solution.
               One is ANL has developed -- and I'm just quoting
     what one of the latest reports says -- developed a leakage
     methodology, and that is the equation for the flow,
     obviously it's a function of delta P and area, of flow area.
               For some reason, I don't know why, it doesn't have
     the L over D ratio, and I think they would be advised to go
     and see what Dr. Shrock has done, because it's also an L
     over D.
               I've looked at that report.  I think they're using
     mostly, but not all, EDM notches.  There may be some cracks,
     but --
               DR. CATTON:  It really depends on what you mean by
     "A".  The geometry could include L over D.
               DR. HOPENFELD:  No, it did not.  It could, but
     their evaluation was based on the ligament.
               I don't remember the person's name, but his
     calculations were based on the strength of this ligament
     based on the internal pressure only.  Only internal pressure
     came in there.
               So, if you are working in a laboratory and you are
     willing to forget the real world, you have the luxury of
     doing this, but it is not appropriate for licensing
     purposes.
               Now, I've looked at some of the letters that were
     going between NRC and Com Edison after the IP2 incident, and
     they were using -- Com Edison were using these kind of
     equations to predict what kind of leakage you're going to
     have during an accident.
               They don't even state the assumption that the
     other forces that could act on that ligament, and we have
     been through this before, could come into play.
               Now, that is the basis for allowing a plant to
     operate, or it's being used as a basis to allowing plants to
     operate.
               It's fine to do all that research at Argonne, I
     have no problems with that.  When you take this thing,
     without putting it in the right context, and you start
     regulating with it, that's when I have a problem with it.
               Another issue that I'd like to discuss at some
     length has to do with inlet plenum mixing.
               Now, the issue of inlet plenum mixing comes in
     during severe accidents.  You remember now that we are on
     risk-informed regulation, you have to look into severe
     accidents.
               Well, if you are doing severe accidents, what you
     have -- you have a situation where the driving force is
     natural circulation between the reactor vessel and the steam
     generator, and the flow goes up, partially mixed here, goes
     up and then turns around and comes back.
               Now, if you don't mix the flow here, you get --
     during this severe accident, you get to creep rupture
     problems, because the temperature is very high, and you
     rupture the tube before you rupture another component in the
     system.
               The component that most commonly is talked about
     is the surge line.
               So, here is the competition here between any one
     of those tubes and a component in this part of the system. 
     If this component breaks first, then you're okay, because
     this is within the containment, but if you -- if this one
     breaks, you're out into the open.  So, it's a competition
     that we're talking about.
               Well, the easiest way to solve the problem is the
     NRC way.
               What you do, you say, well, I can lower the
     temperature, and I can keep the temperature here relatively
     very low by mixing all that flow.
               So, back -- remember, going back to the time line
     -- that's the reason I put that time line there.  Back to
     the time line, remember, somewhere in '95, the NRR found out
     that they are getting a potential problem here with creep
     rupture in severe accidents.
               Before that, severe accidents weren't that
     important, because they were not part of the risk-informed
     regulation, but now that you worry about it, you have to
     come up with an explanation of why you're not getting -- why
     you're not going to increase your risk of a core melt.
               So, one way of solving -- to solve the problem was
     to mix this.
               So, if you mix these -- I don't remember what the
     temperatures are, but there's a very large temperature
     differential here, something like 500 or 600 degrees F, but
     if you mix this thing perfectly, you lower the temperature,
     and remember, from your creep rupture basic curve, the
     rupture properties are -- you have more strength at the
     lower temperature.
               So, the uncertainty here is not that much the
     creep rupture properties, although they went and built a
     very expensive facility at Argonne to find those properties,
     but that's not really the major thing.
               The major thing is to -- it's not the uncertainty
     in the creep rupture property.  The uncertainty is what's
     going on in here.
               Yes, sir.
               DR. HIGGINS:  It seems like everything you talked
     about up till right now has been associated with the main
     steam line break and a subsequent rupture of the tubes.
               DR. HOPENFELD:  Correct.
               DR. HIGGINS:  It seems like, in this one, now,
     you've jumped to a different type of a scenario.
               DR. HOPENFELD:  Correct.  I should really
     introduce it.
               DR. HIGGINS:  Would you say a couple of words
     about that?
               DR. HOPENFELD:  Yes.
               DR. HIGGINS:  I guess your concerns are broader
     than just a main steam line break.
               DR. HOPENFELD:  Right.  I'm sorry.
               I titled the previous view-graph "Examples of
     Research," how do we resolve -- how do we extend the 95-05,
     and in the case of a steam line break or the design basis,
     is those loads that I talked about, but now, under risk-
     informed regulations, it's not enough just to say here is
     95-05, because 95-05 by itself doesn't talk about severe
     accidents.
               But now when you go and you ask for relaxation
     under that risk-informed regulations, there is somewhere in
     the system that tells you, aha, you've got to look into the
     severe accident case, too, you have to show us that whatever
     you're going to do to the system, whatever you're going to
     perturb the thing beyond your present tech specs, whatever
     relaxation you're asking, you are not going to affect the
     severe accident case.
               Does that answer your question?
               DR. CATTON:  And what it gets down to is that
     there is a race to determine which piece of that system will
     go first.
               Now, depending on the assumptions you make, you
     can make any part of it go first.  If you assume that there
     is no mixing in that lower chamber, hands down, it's steam
     generator tubes first.
               Depending on how much mixing you assume, you bring
     the times closer together, and you can even make the surge
     line or some small pipe that connects into the hot leg go
     first.
               DR. HOPENFELD:  Correct.
               DR. CATTON:  Where it really all comes down, as
     near as I can tell, is the RELAP-5 code -- and I don't -- I
     think you're faulting the -- you're kind of blaming NRC for
     doing it deliberately.
               I don't think it's deliberate; I just think it's
     misinformed.
               DR. HOPENFELD:  No, I didn't get to the RELAP on
     this yet.
               DR. CATTON:  Well, you're going to get there.  But
     that's where the mixing comes from.
               DR. HOPENFELD:  Yeah, but I didn't get there --
               DR. CATTON:  The assumption of mixing comes by the
     nodalization that's used with RELAP-5.  From there on, it's
     justification for having done so.
               DR. HOPENFELD:  Give me a minute.
               DR. BONACA:  I would like also to ask -- here the
     question is -- the issue is steam generator tube rupture
     induced by severe accident.
               DR. HOPENFELD:  Right.
               DR. BONACA:  Okay.
               Now, you also, however -- I wasn't clear whether
     you're making a contention that not only this cooling issue
     is central to that, but also the damages in the steam
     generator tubes.
               Now, it wasn't clear.
               DR. HOPENFELD:  Okay.  I'll try to make it very
     clear.
               The issue of -- if it was four years ago, I
     probably wouldn't even bring it up, or I'd just bring it up
     as of just general interest, but under the risk-informed
     regulation -- and I understand, at this time -- and I think
     Farley was the first one where you have to address the
     severe accident issue, and that's why I'm bringing it now. 
     I wouldn't have brought it out before.
               At this point, when we give somebody -- we're
     relaxing their technical specifications, we ask them to come
     up with a justification that the severe accident is not
     going to affect the core melt frequency, and that's the
     reason I'm bringing that as another example, but I would
     like to get into the technical reasons here, just take it
     one step further.
               DR. BALLINGER:  Now, these are calculations,
     right?
               DR. HOPENFELD:  This is just a schematic.
               DR. BALLINGER:  No, I'm saying you're going to get
     to the calculations.
               DR. HOPENFELD:  Yeah, I will, right now.
               DR. BALLINGER:  But my understanding is that there
     is a discrepancy between the one-seventh Westinghouse test
     and what's been observed at TMI.  I don't see that.
               DR. HOPENFELD:  I'm not going to get there.  Let
     me tell you where I'll get, and then I'll be able to -- let
     me get to my point, what I'm trying to say.
               But did I answer your question, why I'm bringing
     in that severe accident?
               DR. HIGGINS:  You did answer it.  I guess I'm just
     trying to get my arms around the scope of what's included
     here, because there are a number of different ways that you
     could address the steam generator issue.
               One is the core damage-induced steam generator
     tube rupture.
               Another one, the one that you've been talking
     about, the one that's induced by a main steam line break.
               One we haven't even talked about yet is the
     spontaneous steam generator tube rupture at some frequency.
               DR. HOPENFELD:  Well, they're all really part the
     whole picture, and I think this severe accident is part of -
     - if you come in and you tell somebody I want to operate at
     3 volts, under 95-05, their reply would be, okay, well, you
     should look at severe accidents.
               Now, industry has said no, we don't want to look
     at severe accidents, but the NRC said, yeah, you look at
     severe accidents, and in the case of Farley -- and maybe
     that didn't ring a bell at the time, when they came in '99,
     in September '99, and asked for relaxation in the case of
     Farley, the staff did some calculations for them and said,
     well, don't worry about this, we don't have any problem, and
     that's what I'm going to tell you, why they do have a
     problem.
               So, it's not separate, and you've got to take all
     of it together.
               That's why I have so many pages.
               DR. BONACA:  Yeah, but until now, you have spoken
     about steam line break --
               DR. HOPENFELD:  Correct.
               DR. BONACA:  -- which is in the design basis of
     the plant, and our intention is that allowing this kind of
     inspection and flagging makes it a different accident than
     what is in the FSAR.
               DR. HOPENFELD:  That's correct.
               DR. BONACA:  Okay.
               You could say that, within 50.59, we have created
     a new type of accident, because it results in a leakage
     which is much beyond what you'd assume, and in fact, if you
     postulate what you're proposing, it's much beyond that, and
     you get a combination of steam line break and steam
     generator tube rupture, and all those issues come together
     into a challenge of the actual design basis of the plant
     right now.
               DR. HOPENFELD:  Correct.
               DR. BONACA:  Now, this is -- you're saying now,
     separately from that, you have a concern --
               DR. HOPENFELD:  Well, it's not separately.  It
     still has to be addressed.  It was separate three years ago,
     but now it's not separate anymore.
               DR. BONACA:  Separately in a sense that you have -
     - by other means, you come to core damage.
               DR. HOPENFELD:  Oh, yeah.
               DR. BONACA:  That cascades into potential steam
     generator tube rupture if the tubes are not in the pristine
     conditions and you have all those things.
               DR. HOPENFELD:  This is a station blackout type of
     an accident.
               DR. BONACA:  Exactly.
               DR. HOPENFELD:  It's a TML3 or TMLB or something. 
     I didn't get into that, but to give you an introduction of
     the whole thing, yes, this is a different type of an
     accident.  This is not the steam line break.
               DR. KRESS:  There's two or three severe accident
     sequences that can do this.
               DR. HOPENFELD:  An ATWS is even higher than that.
               DR. KRESS:  No, no, I think the station blackout
     is the main one.
               DR. HOPENFELD:  This is the station blackout that
     I'm talking about.  I thought the ATWS has pretty high
     pressure, too.
               DR. KRESS:  It's pretty high, too.  It's up there.
               DR. HOPENFELD:  I'm sorry.  Sometimes I'm going
     too fast.
               But let me say again, I'm talking about -- it's
     not a steam line break, it's a station blackout, and in the
     last two or three years --
               Art, can you tell me when we're supposed to
     address this thing, if somebody comes with a risk-informed? 
     We didn't have to do it in the past.
               DR. KRESS:  I think the ACRS almost forced them to
     look at this.  There wasn't any regulation that said you had
     to.
               DR. HOPENFELD:  In 1999 is the first time that I
     saw -- when Farley came in here -- that it's being
     addressed, and the industry was fighting that.  They didn't
     want to have them do that.
               But since it's here, I think I ought to talk to
     you about it or explain it to you, what it is, to see how
     these things are being approached more than anything else.
               DR. KRESS:  The concern of ACRS wasn't so much
     that this increases the CDF, because if you're into a severe
     accident, you've already got a CDF.  It was that this
     converted it into an increase in the large early release,
     because it could go into containment.
               DR. CATTON:  It has nothing to do with the CDF.
               DR. KRESS:  Well, a little bit.  You can add a
     little to the CDF if this happens.
               DR. CATTON:  You've already had it.
               DR. KRESS:  You've already had it, yeah.
               DR. CATTON:  It's on the table.
               DR. HOPENFELD:  There is a difference, and I think
     the difference is that this is called an LERF, not that you
     have a containment bypass.
               DR. KRESS:  That's right.
               DR. HOPENFELD:  So, you're talking about another
     order of magnitude of safety.
               So, if you could go and live up to 10 to the minus
     4, now you stop at 10 to the minus 5.
               DR. KRESS:  That's the distinction.
               DR. BONACA:  That's the distinction, and we have
     been confident -- I mean there has been some confidence, I
     believe, from 1150, that because of failures of the primary
     side, you will not have this bypass of containment in many
     sequences of this type, and now, this could create a much
     bigger group of sequences that will bypass containment.
               DR. CATTON:  Actually, this all started when
     somebody in Holland got ahold of RELAP-5 and did some
     calculations that were absolutely incorrect, but they
     concluded that -- actually, they argued that it was the
     nozzle on the reactor vessel that would go, and then people
     started to look at the problem, and over a period of time,
     it involved into this particular configuration, and in the
     Westinghouse tests, one-seventh-scale tests were done, but
     nobody did flow visualization.
               The temperature measurements were pretty good, but
     the scaling was improper.
               So, as a result, all you know is that that kind of
     phenomenon can occur.
               DR. POWERS:  To be precise, the Westinghouse
     experiments did not include the steam generator.
               DR. KRESS:  They had a simulated steam generator.
               DR. CATTON:  They had it simulated.
               DR. KRESS:  It wasn't a steam generator.
               DR. POWERS:  It does not look like that at all.
               DR. KRESS:  No, it doesn't look like that at all. 
     It wasn't scaled very well.
               DR. HOPENFELD:  Okay.
               So, going back to '96, I believe, or '95, when the
     NRR felt that they'll -- they got an inkling that they'll
     have to address the severe accident issue, they asked
     research to look at it, and research solved the thing in a
     report called NUREG-1570 that, again, it's being used for
     licensing, and basically, the answer was that, if you have
     good mixing, there is still a chance that you will rupture a
     few tubes, but the probability was low.
               So, at that point, I thought it would be useful to
     take a look at that mixing assumption.
               I had a report, remember, going back to September
     1992, when I assumed that there was no mixing.
               There was no reason to believe that there would be
     any mixing.
               So, I assumed that there was no mixing.
               Then EPRI had a report on this subject, a very,
     very elaborate report, and they assumed that you could have
     mixing between 100 and 200 gpm, and there was a very, very
     clear effect, and when you have mixing, they assumed that
     they had a leakage, primary to secondary leakage of 100 to
     200 gpm.  It will have a profound effect on the mixing in
     the steam generator.
               If you then -- what happens is, when you have
     mixing in the steam generator and if you have a large flow
     due to leakage of the tube, all that leakage will bypass the
     plenum, basically, and you're going to get high-temperature
     gas or steam in contact with the tubes.
               Well, all that was all forgotten, because the
     research studies were based on Westinghouse one-seventh-
     scale model, which, besides the scaling problems that have
     been discussed for a long time, it didn't have any leakage.
               So, all that data that RELAP-5 was benchmarked
     just wasn't applicable.
               Another implication of this is going back to here,
     that we have never really looked into that, and it should
     be, and that is that these very high -- when the flow rate
     here -- the natural circulation flow is very slow.  It's
     like a couple of feet per second.
               When you have large leakage flow, then you really
     have some kind of a combined natural forced convection flow
     in that pipe, and that by itself is going to affect the
     rupture of these components on the primary side.
               So, the point here is that all that analysis came
     to a criticism, and I think Dr. Catton was involved in this,
     and there were a lot of questions, but nothing happens, and
     two weeks ago, we get another letter to NRR telling that
     we're going to do more of the same.
               One of the criticisms that came up during one of
     the ACRS meetings -- there were a lot of deposits in here
     which were not taken care of.
               Actually, what you are really interested is
     knowing what the tube-to-tube temperature variations, and
     those were not calculated.
               So, now, they want to continue this kind of study
     to come up with an improved temperature distribution, which
     is fine, but the main problem here is that we don't have
     data.  There is just no data.
               It's a three-dimensional kind of thing.  RELAP is
     one-dimensional.
               There is no data to justify any of that.
               DR. BALLINGER:  Can I ask a question?
               Can you go back to the previous slide, the one
     that showed the schematic?
               DR. HOPENFELD:  This?
               DR. BALLINGER:  Right.
               Now, I guess I understand the argument, but if you
     have a single or even two tubes failed, isn't that going to
     short-circuit the flow?
               DR. HOPENFELD:  Sure.
               DR. BALLINGER:  So, how do you get high
     temperatures in the other tubes?
               DR. HOPENFELD:  Well, if you already have a
     failure, a large failure, then, you know, you have the
     leakage.  It depends on the relative amount of steam you
     have.  There's a lot of steam there.
               DR. BALLINGER:  But if you've got flow already out
     a leaky tube, that short-circuits the high-temperature flow
     through a tube which has already failed, and so, you don't
     have to worry about a creep rupture problem.  How does it
     get the temperature that would result in a creep rupture to
     the other tubes?
               DR. CATTON:  The tube that's broken -- it's going
     right out the SRV and into the atmosphere.  That's the
     problem.
               DR. BALLINGER:  I thought you were arguing that
     you get high temperatures in other tubes, therefore you get
     rupture of the other tubes, and therefore, you propagate the
     failure.
               DR. HOPENFELD:  No, that's already bypassing. 
     There would be no mixing in here.  Whatever temperature
     comes in, whatever steam comes in here at the higher flow
     rate, it will get out.
               DR. BALLINGER:  So, you don't propagate the
     failure by this mechanism.
               DR. HOPENFELD:  No, I didn't say it would
     propagate the failure.
               DR. BONACA:  But you said that the tubes fail
     first, which I understood the same way, that the tubes would
     be exposed to higher temperature.
               DR. HOPENFELD:  Higher temperature than the surge
     line.
               DR. BONACA:  Why?
               DR. BALLINGER:  But the tube has already failed
     and it's already bypassed.
               DR. KRESS:  So, what's the consequence?
               DR. BONACA:  You have to have a mechanism by which
     you fail the surge line.
               My understanding of your contention was that the
     tubes now -- there is some leakage coming through.  That
     will cause the tube to hit higher temperature than the surge
     line, and that will cascade into more rupture.
               DR. HOPENFELD:  But it's not only the temperature,
     it's the size of the thing.  The component is of a different
     size.
               You have to look into the actual component
     calculation, the stress calculation, and you'll see it.
               I don't have a graph to show you where the cross-
     over point is.
               DR. BALLINGER:  I'm trying to get the scenario
     correct.
               DR. HOPENFELD:  Okay.
               DR. BALLINGER:  You're saying that you have
     multiple damage to steam generator tubes, which are leaking
     at some --
               DR. HOPENFELD:  Correct.
               DR. BALLINGER:  -- small rate.
               DR. HOPENFELD:  But sufficiently large to affect
     the -- I'm not going to have mixing.
               DR. BALLINGER:  But these tubes would not
     necessarily burst during the accident.  But when you get
     this small amount of leakage, you alter the natural
     convection flow.
               DR. HOPENFELD:  I didn't say small.
               It's sufficiently larger than the natural
     circulation, because otherwise, natural circulation would
     dominate.
               DR. BALLINGER:  Well, I'll give you that.  But now
     the hot gas goes up these tubes which are leaking a little
     bit.
               DR. HOPENFELD:  Which are leaking.  I don't know
     how much they leak.
               DR. BALLINGER:  Well, cause a higher temperature
     in the tube, result in rupture of the tube.
               DR. HOPENFELD:  Higher temperature relative to the
     mixing temperature.
               DR. BALLINGER:  I mean higher temperature with
     respect to the stress rupture.
               DR. HOPENFELD:  But you see, you have to go to the
     stress calculation -- to the structure calculation of
     whatever component -- say, the surge line -- versus the
     tube.
               It's not only the temperature, and if you go and
     do that -- which I didn't bring the data with me, but you go
     there and look at it, you will see that, if you lower the
     temperature, okay, if you lower the temperature of the tubes
     or if you allow for mixing here, the surge line will break
     first.
               DR. BALLINGER:  I'm not worried about the surge
     line.
               I'm trying to reduce this to terms that a
     metallurgist can understand.
               DR. HOPENFELD:  It's not a metallurgy problem.
               DR. CATTON:  Maybe I can help.
               DR. BALLINGER:  I'm trying to envision a way to
     propagate this so that you get larger release.
               DR. BONACA:  I had the same understanding as Dr.
     Ballinger.
               I mean my understanding was, if you have this
     effect, okay, of circulation, it will provide cooling to the
     tubes to the point that the surge line heats up first and
     fails first.
               DR. HOPENFELD:  It's not necessarily the heating. 
     It's a combination of the structure and the temperature.
               DR. BONACA:  Conversely, if you have some leakage
     to the tubes, that leakage such that dominates that
     recirculation portion of the steam, that cooling is not
     happening anymore, and this will result in further increase
     of temperature to further failure of the tubes.
               DR. CATTON:  I don't think a change in flow to the
     tube because of a leak impacts the heating rate of the surge
     line much at all.
               DR. BONACA:  I'm talking about the heating rate of
     the tubes.
               DR. CATTON:  If you look at the Westinghouse one-
     seventh-scale data carefully -- and they have some
     appendices with a whole bunch of temperatures in them -- and
     none of their tubes leaked -- what you'll find is that, in
     some of the tubes, the temperature at the inlet is almost
     the same as the temperature coming out of the model hot leg.
               What that says is that it's a rather complex
     process that's going on in that chamber, and making the
     assumption of .87 mixing really is without basis.
               DR. BONACA:  It seems to me that one should give
     some belief to both possibilities, but that's just a
     personal opinion.
               DR. HOPENFELD:  Really, the only way to answer
     your question -- if you go back and see the surge line
     temperature going up and you see where they cross over, that
     temperature makes a difference, but my point is here that
     you cannot ignore, because I calculated it, the Japanese
     calculated the same thing.
               They came up with the conclusion that this is very
     marginal if you allow -- if you don't allow mixing.
               EPRI calculated it the same way.  They had a
     model.  They had, well, you can't use this Westinghouse
     data.  So, they had a model which wouldn't allow mixing.
               So, there were three models here, okay, all of
     them showing there is no mixing.
               Now, we have the NRC people going and developing
     calculations which are based on perfect mixing without
     analyzing -- without really looking for the entire picture,
     looking as to what happens to the surge line, how does that
     affect it, without coupling the whole issue, and then you
     use these results in 1540 to regulate plants.
               That's the thing.
               It's not all this.  I don't mind if you do this
     thing until doomsday playing with these models.  That's
     fine.  It's good to present papers.
               But when you start using this into the regulatory
     arena and you start really licensing plants, you tell them,
     well, you can have this inspection, you can't have this
     inspection, that's where the concern is.
               MR. LONG:  This is Steve Long with NRR.
               I don't think there's much disagreement here
     between the staff and the DPO author on the effects of
     leakage, or at least our inability to handle them.
               The concern is that you're trying to determine if
     the surge line will heat enough to fail first or the tubes
     will heat enough to fail first, and there's a lot of
     discussion about whether or not the scaling for the one-
     seventh-scale test to the prototype, various different shape
     prototypes between CE and Westinghouse, really captures the
     phenomena correctly about leakage.
               When you add the leakage, a whole bunch of
     different things happen. 
               First of all, if you're leaking substantially from
     some tubes, the flow doesn't have to come back from the
     outlet plenum side to the inlet plenum to let hot fluid come
     into the inlet plenum.
               So, you really cut down on the mixing that way.
               So, you may very well get hot gases going up to a
     lot of the tubes.
               Then, in addition, if the leakage is high enough,
     you'll actually cut down on the cycling or stop the cycling
     of the PRV on the top of the pressurizer, so you cut down
     the flow through the surge line and you slow the heat-up of
     the surge line, at least to the extent that the surge line
     doesn't sit at the top of the hot leg and just get the hot
     temperature as it goes by it, it's off to the side.
               So, there are a bunch of different things that we
     don't handle well if you start adding substantial leakage. 
     One of our concerns has been to try to keep the leakage down
     to the approximately 1 gpm that's in the design basis now,
     and if we felt we had to make it lower, then we'd have to
     come up with enough analysis for the backfit.
               DR. KRESS:  What is a good rule of thumb for what
     you would call substantial leakage?
               MR. LONG:  We've done some studies that assume a
     fixed-size hole in the steam generator tube, and if you size
     that hole so that you get approximately 100 gpm leakage
     under the design basis conditions, where there's water on
     the primary -- and I don't remember what the hole size is --
     we can look it up for you -- that hole would stop the
     cycling of the pressurizer valves before you got to failure
     of the RCS by creep.
               I was trying to size the hole so that you could
     relate it to the design basis-type limits that we had in
     leakage of water.
               So, I can't tell you -- that's approximately the
     size that seems to -- in the Surry plant model right now.
               That would make the effect of preventing the
     safety valves on the pressurizer from cycling until the
     point of failure.
               It would alter the flow path before that through
     the surge line.
               We don't know how to handle the leakage effects on
     the mixing.
               So, it may be well below that that the effects on
     the mixing occur.
               DR. BONACA:  Before you move further, Dr.
     Hopenfeld, I would like to ask you -- you presented in a
     previous slide your scenario -- you presented the
     containment bypass frequency of 1.6 times 10 to the minus 5. 
     How did you get to that number?
               DR. HOPENFELD:  This has been a long time.  I'll
     have to recollect how I got the number, but I'll give you
     the rationale.  I don't remember.
               This slide came from a presentation I made to the
     ACRS in '98, I think, and I had that number, and I think Dr.
     Buslick helped me with that, and maybe he will remember, but
     I got those numbers from -- there was a rationale for
     getting those, but I just don't recall exactly where it came
     from.
               DR. BUSLICK:  I don't really remember for sure,
     but 1.6 times 10 to the minus 5 per year, I think, is the
     total station blackout.
               DR. HOPENFELD:  Yeah, I think that's the answer. 
     Very good.
               DR. BONACA:  Then what you did you assumed the
     station blackout and then assumed no conditional
     probability.  You have a station blackout and that will take
     you to a containment bypass.  Okay.
               DR. HOPENFELD:  I am not a PRA man, but I went to
     Dr. Buslick and he gave me a number.
               DR. BONACA:  That's what I saw yesterday from some
     papers, but I wanted to confirm it.
               DR. HOPENFELD:  Thanks a lot, Steve.  You couldn't
     state it better.
               So, we do have an agreement here now.
               The next thing -- what kind of got me a little
     concerned --
               MR. LYON:  Let me raise one more point that Steve
     was sort of getting to.
               Remember, we're starting with a core damage
     situation underway.
               So, the fluid back in the reactor vessel is really
     up there, you've got the chemical reactions going on, and so
     forth, and then, as that fluid flows along the top of the
     hot leg, it is interchanging energy with the cooler fluid
     flowing back, so we're getting a cooling effect there.
               Then, as you get into the steam generator inlet
     plenum, you get into the mixing there, both phenomena, by
     the way, quite uncertain, from what I have seen, but if you
     get into a situation where you have a substantial leak, say
     one tube partially breaks, and you set up a mechanism to
     take that really hot fluid, say 3,000 Fahrenheit, whatever,
     that's back in the vessel, and move that up into the area of
     one tube, and if that is then moving out and hitting other
     tubes, you may have a propagation mechanism for making the
     leak substantially greater and failing a number of tubes.
               DR. HOPENFELD:  My point really here was that
     there is a proposal here to do additional study of this,
     doing more analytical study and code calculation.  I really
     don't think you can do that.
               You have to get some data with leakage to
     benchmark these codes, and I have nothing against that, but
     just to do more of the same that was done before I don't
     think is very useful.
               DR. BONACA:  The last comment I would like to make
     about this is, when I compare these containment bypass
     frequencies, there is a full agreement on the frequency of
     station blackout, and then I believe the DPO takes a
     position that there is certainty that, if you have a station
     blackout, you have a bypass situation, so conditional
     probability is 1, and the other position is surge line fails
     first, so there is no bypass, and you know, I wonder if
     there was an estimation of somewhere in between, given that
     there is significant uncertainty on the phenomenology of
     this.  We can explore that tomorrow.
               MR. BUSLICK:  Steve Long corrected me.  It's not
     the entire station blackout core damage but the high dry
     station blackout core damage frequency.
               DR. POWERS:  Dr. Hopenfeld, are we arrived at a
     point that it would be appropriate to take a break?
               DR. HOPENFELD:  Fine.
               DR. POWERS:  Why don't we take a break till
     quarter after the hour.
               [Recess.]
               CHAIRMAN POWERS:  Let's come back into session. 
     Dr. Hopenfeld?
               DR. HOPENFELD:  Remember, going back to the time
     line, the entire NRC justification for operating with
     cracked tubes is based on NUREG 1477.
               And the assumptions in there are that the primary
     and secondary leakage rate is between 480 to 540, and, of
     course, this is primarily for the risk assessment.  It's not
     for the CFR-500.
               The crack opening is .576 to .72, and the crack
     area does not change once the corrosion products are forced
     out.  Now, you can see that this is a constant area, a
     certain area that was assumed, and a certain flow rate was
     assumed, which really neglects all the items that we're
     talking about, all the factors that we're talking about
     before, the jet and the forces due to the steam line break.
               So, when you make these assumptions, sure, the
     pump, if you write the basic equations for a pump operation,
     obviously there's a certain amount, maximum amount of flow
     that you can force through a constant area.
               Makeup of water was added to the RWST, and the
     main assumption -- and that's the one that we're going to
     analyze and look at a little bit more -- is this ten to the
     minus three, and that's the one really that bothers me more
     than anything else.
               Because where does it come from, and what's the
     justification for it?
               DR. BONACA:  This, if I understand it, is probably
     the where the steam line break is ten to the minus four, and
     operator failure is ten to the minus three?
               DR. HOPENFELD:  The probability of -- no, on this
     one, I believe the probability -- it was not the steam line
     break; it was the safety relief valve, and I think that was
     ten to the minus three, if I remember correctly.  Is that
     right, Steve?
               MR. LONG:  Correct.
               DR. BONACA:  And how do you get ten to the minus
     seven?
               MR. LONG:  Let's talk about it tomorrow.  I have
     to get the book.
               DR. BONACA:  I'm asking --
               DR. HOPENFELD:  Well, ten to the minus four times
     ten to the minus -- let's see, ten to the minus three times
     ten to the minus four is ten to the minus -- this is ten to
     the minus six.  Where does seven come from?  I don't know.
               [Laughter.]
               DR. HOPENFELD:  I got it from NUREG 1477,and
     probably you have the numbers.
               DR. BONACA:  Yes, there is -- I have reviewed
     those documents, too.  There is a full range of spectrums,
     depending on the transient, and that's why I'm trying to
     nail down which accident we're talking about.
               DR. HOPENFELD:  We're talking about a steam line
     break.  This is in NUREG 1477.
               DR. BONACA:  That's a steam line break?
               DR. HOPENFELD:  It's a steam line break.
               DR. BONACA:  You said that it's a stuck-open SRV?
               DR. HOPENFELD:  Well, no.  A stuck-open SRV is a
     steam line break.
               DR. BONACA:  Well, the way it's characterized is
     different frequencies.
               DR. HOPENFELD:  Right, the frequencies are
     different, but originally, actually when I looked at that
     thing, remember, I had two months to look into that problem.
               I talked to various people, and I came up with the
     number of ten to the minus four, and that's why that I stuck
     the ten to the minus four in there, and gave the operator
     zero credit for it, that he didn't do anything.
               Then when the committee was formed and they did
     some more studies, they came up with a higher frequency, and
     they were talking about the relief valve.
               So another way of looking at it, if you want to go
     to the ten to the minus three, then you say, well, ten to
     the minus three, and we'll give some credit to the operator
     that maybe he'll look at it.  But anyway, the number is ten
     to the minus four, as far as I can see in how you come to
     it.
               You may come to it from different angles.
               MR. HIGGINS:  Do you postulate the same drastic
     effects in the steam generators from a stuck-open relief
     valve on the secondary side as the main steam line break?
               DR. HOPENFELD:  Well, this was done by NRC.  These
     are their numbers.
               But I believe that, yes, I think you could --
     within the uncertainty that you have, there is a limiter
     there, but within the uncertainty that you have, it probably
     doesn't make that much difference.
               DR. BONACA:  Yes, but some of the reports,
     however, show, depending on the initiators and how
     challenging it is, they assign different frequencies for the
     initiator, different success criteria, and other things that
     come after that.
               DR. HOPENFELD:  Right.
               DR. BONACA:  And so --
               DR. HOPENFELD:  I'm just showing you what 1477
     used, and what has been used as a justification for the last
     eight years as quoted in the reply to that DPO document. 
     That's what's being used, and that's what I'm addressing. 
     I'm just telling you what they are talking about.
               DR. BONACA:  Okay.
               DR. HOPENFELD:  That's the number that is in that
     NUREG.  Now, tomorrow, hopefully you'll ask them where they
     got this surface area from, where they got this flow rate,
     and they should justify that thing.
               And why is the surface area constant, if you have
     other mechanisms, loads, and that's really the crux of the
     whole thing.
               Sure, if you have a constant area, you're limited
     by the pump, but that's not real life.
               DR. BONACA:  Sure.
               DR. HOPENFELD:  So as I said before, the DPO
     approach was, this is too complicated, whatever the
     frequency you have, that's it, and the probability that you
     would lose the inventory is one, once you get to that point,
     if you have cracked tubes.
               That was the approach from the beginning.  Now,
     whether it's ten to the minus three and you give operator
     credit or it's ten to the minus four, it's not really the
     main point here.
               The main point here is that you are ten to the
     minus four, which is two orders of magnitude, which is an
     order of magnitude higher than what the ten to the minus
     five that we were supposed to abide by.
               If the Commission tomorrow says, well, ten to the
     minus five is not a good number; let's go to the ten to the
     minus four, I'll just retire and just forget about what I
     said here.     
               But that's what they said, and they set the rule,
     and if they set the rule, they would stick to it, otherwise,
     this whole risk-based-informed is just one big joke.
               And that's really the point.  So, the whole thing
     is, if you've got some -- I'm sorry, was there a question
     that somebody raised his hand for?
               So the whole thing could be really explained away
     if you say if you have a super-duper operator and he can do
     marvels and he can put it down, but it's not a simple thing,
     when you have a large leakage, to bring that kind of system
     to an ordinary shutdown, because there are conflicting
     requirements here.
               You have on the one side, you have steam coming
     out from an opening in the steam generator, and it goes out
     to the site, and the only way you can stop that is to reduce
     the pressure on the primary side.
               So when the pressures become the same, the leakage
     stops.  But on the other hand, you can't go too fast,
     because if you go too fast, there is the possibility that
     you uncover the core, plus, you have limitations of PTS,
     pressurized thermal shocks, but that's not the main point
     here.     
               The main point is that you can't go, you're
     limited, this is not a simple operation.  Now, maybe if
     you're running at 100, 200, 300 gpm -- I don't know, because
     I'm not an operator -- you probably could handle it.
               When you get to larger, some theoretical
     predictions can go above 5,000 gpm.  But the point is that
     it's not a straightforward kind of thing, because some
     plants don't have pumps that you can throttle, so you have
     to turn off pumps on and off, and some of them were not
     designed for that purpose.
               You may be overheating them, so if you lose pumps
     while you're operating, then the operator has got another
     problem.
               So it's not straightforward, and I'm not an
     operator, so Mr. Spence will talk about this a little more. 
     But the main point here that I'd like to bring to you, is
     that if you go back and operating experience, then in
     reality, even in IP-2, relatively -- compared to this,
     relatively trivial accidents have caused operator problems.
               The one that I -- that was brought up to me, to my
     attention recently, was the one at, I think, Palo Verde. 
     They took 28 minutes before there was a recognition there
     was a tube rupture.
               Now, this is relatively a no-accident; this was --
     the plant was designed, compared to what I'm talking about.
               So if it takes you 28 minutes, then you can say,
     well, this much more severe accident is going to take --
     he's going to follow and do all these -- sure, he can do all
     of that, if the equipment operates that way.
               But I've driven a lot of cars over the years --
     it's my hobby -- and things just don't happen that way with
     real-life cars.  Reactors are different, but nevertheless,
     this number here that is being used is ten to the minus
     three for operator error, is, I think, very, very
     optimistic.
               DR. CATTON:  Can I ask a question about -- you've
     assigned a number of ten to the minus one for operator
     failure.
               DR. BALLINGER:  Well, let me go back to that. 
     What I did originally, I said ten to the minus four, because
     that was a frequency given to me for steam line breaks
     upstream of the isolation valve.
               See, you have an isolation valve and you can
     isolate that thing, but there's a section there and it
     varies from plant to plant what it is, that independent of
     what the isolation valve does, you have many steam line
     breaks with a bypass.
               DR. BALLINGER:  Okay, so this is not operator,
     this is valve operator.  What's the ten to the minus one,
     operator, the guy?
               DR. HOPENFELD:  Okay, that's an operator.
               DR. BALLINGER:  Now, can that be affected by
     operator training?  What if they trained on these kinds of
     events?
               DR. HOPENFELD:  Bob will talk about that.  I think
     it's a very good question.  I've asked it a couple of weeks
     ago from -- I asked NRR to provide me statistics of the
     operator simulator results on that kind of accident, and
     they don't have it.  But that is one place to get that
     information.
               DR. BONACA:  Because it's a steam line break,
     rather than a tube rupture, so really if you look at the
     procedures, they way they were set, it would involve
     different procedures, probably.
               DR. HOPENFELD:  Well, it's a LOCA, basically. 
     That's all it is.
               DR. BONACA:  But you don't start with the LOCA;
     you start with the rapid depressurization, and you think --
               DR. CATTON:  To pick it up.
               DR. BONACA:  To pick it up.
               DR. CATTON:  But i believe the operator is trained
     on a simulator.  The simulator is based on RELAP, and we
     heard this morning about what you actually will see, and
     they're quite different.
               DR. HOPENFELD:  That's the bottom line here.
               DR. BONACA:  They use RELAP anyway.
               DR. CATTON:  Well, whatever codes are used, RELAP
     is the one.
               DR. BONACA:  When you say RELAP, I agree with you,
     but some say that insofar as the Palo Verde event, you know,
     if you have a straight steam generator tube rupture, and it
     is a minute leak, it may make it hard for the operators at
     the beginning to --
               DR. HOPENFELD:  I don't think this was a minute
     one, though.  I think it was a full rupture.
               DR. SIEBER:  One tends to mask the other.
               DR. HOPENFELD:  Well, I think that particular one
     was not.
               DR. BALLINGER:  It was 250 gallons a minute, I
     think.
               DR. HOPENFELD:  Is that what it was?  Okay, that's
     about half; 250 is about half -- 500 for full rupture, and
     250 is about half.
               DR. BALLINGER:  Two-forty.
               CHAIRMAN POWERS:  I'd like you to be a little more
     accurate in your estimates.
               [Laughter.]
               DR. HOPENFELD:  Well, 240, it sure is higher than
     a one-gpm, 500 is, you have to agree with that.
               CHAIRMAN POWERS:  Yes.
               DR. HOPENFELD:  We looked at the Indian Point 2
     experience and I think there was some problem at controlling
     the steam flow to the condenser, and there was a slow
     cooldown rate, and there were some other problems that I'm
     ont familiar with.  Hopefully Bob will talk about that.
               Theoretical predictions go to something on the
     order of 3,000 to 6,000 gpm, which is the limit that even
     their theoretician claims that there is no way of
     controlling the accident.  It's probably anywhere in
     between.
               Now, to summarize the severe accident, because it
     does fall into all that stuff that I have been talking
     about, already Mr. Bosnick mentioned and this comes from the
     station blackout scenario.
               And the data that was obtained to justify that
     this number would -- that this is going to be the number, is
     based on the study of Westinghouse with a 1:7 scale model
     which did not include the main -- the mixing in the plenum,
     and the phenomenon is a three-dimensional phenomenon, not a
     one-dimensional phenomenon that's being treated by RELAP.
               DR. BALLINGER:  Again, I'd like to put things in
     perspective, though.  Six thousand gallons a minute is about
     ten tubes.
               DR. HOPENFELD:  I think so, yes.
               DR. BALLINGER:  It's about ten tubes, and in the
     Indian Point experience, they did get the plant shut down
     without any damage.
               DR. HOPENFELD:  That's 150 gpm.  But that's a very
     good point.  At 150 gpm, the thing is that it's still -- my
     point is here is about the operator response, okay?
               This was a very mild accident and still the
     operator -- what I'm really trying to say is that there is
     room here for the operator to make errors, and when I see
     ten to the minus three, it's kind of hard to believe.
               DR. BONACA:  Actually, you know, it's interesting
     that in some of the reports like this, the report that we
     have, they are analyzing up to 15 tube ruptures, and they
     present an interesting perspective in this range in the
     middle.  It seems to be the least challenge to the operator
     because it depressurizes so fast that it brings you down to
     no pressure for entry level, so even if you are confused for
     a long time about where you are, but you stay low and
     leaking low.   And the more challenges seem to be the fuel
     tube ruptures, because you're staying, you intend to come
     back to pressurize, or the very high leakage rate beyond 15
     tubes where you cannot make it up.  You cannot make it up,
     so it's an interesting perspective on that report.
               DR. HOPENFELD:  Okay, I'd just like to bring to
     your attention here -- I'll just summarize it, because I
     don't want to harp on this severe accident too much -- that
     the Japanese JAERI came up also with a prediction that the
     creep rupture, that the tubes would rupture much earlier
     than NRC predicts, because NRC said, well, their computer
     codes predict that it doesn't, but they didn't say that they
     are mixing it, and therefore that's what the difference is.
               And, again, one of the discussions in the document
     you have that's called a reply to -- I mean, the DPO
     consideration document -- talks about that these cracks are
     going to be constrained within that support plate.
               And the jet coming out is not going to go
     anywhere, it's going to be deflected by that support plate.
               Now, remember, you have 2500 pounds on the inside
     of that tube, and it's kind of very difficult to see how
     that support plate is going to do anything, especially going
     back, that it's going to move the tube sheet.  Remember, it
     was only designed for 1500 and not for 2500.
               So, to say that this thing is confined within that
     support plate and that it is going to prevent the jet from
     damaging adjacent tubes, is not very realistic.
               At this point, since I didn't talk to much about
     the operator action, it's probably the most important thing
     in this whole presentation, I asked Robert Spence to talk
     about it a little bit.
               DR. BONACA:  You're going to talk about deflection
     of jet?
               DR. HOPENFELD:  That's what they're saying.  I
     don't want to get into that.  I mean, you can come up with
     200 different scenarios.
               DR. BONACA:  All right.
               MR. SPENCE:  For reference to what I'm going to
     talk about, you were given a handout this morning, a table
     of three or four pages, about operator.
               Steam generator tube rupture, operator performance
     and NUREG 6365.  Now, I put that together based on NUREG
     6365, combining basically looking at it from what an
     operator did, what worked for him, what didn't work for him,
     what problems he had with equipment performance, also a
     comparison of radiation releases as well as what kind of
     isotopes were released.
               These were only steam generator tube ruptures,
     basically without main steam line break, et cetera.
               I go back to 1975 and all the way up to Indian
     Point 2.  Where's that pointer?  Can I use it?
               Okay, again, basically what I'm going to talk
     about is that ten to the minus three an appropriate
     estimated probability of operator actions?
               These numbers are not -- you've got three
     different scenarios that will cause the design basis
     problem:  Main steam line rupture, stuck-open relief valve,
     and feedwater line break.
               The interesting part about this slide is the human
     error contribution to the event.  It's very high, and is
     probably going to be some of the highest in any accident
     situation.
               MR. HIGGINS:  Could you clarify a couple of things
     on that?  That is, I assume, 1.0 E to the minus three at the
     top?
               MR. SPENCE:  Yes, that's supposed to be ten to the
     minus three, yes.  The zero doesn't belong there, sorry
     about that.
               MR. HIGGINS:  And the seven on it?
               MR. SPENCE:  Is -- well, refer -- in your
     proprietary document, there will be a reference to where
     that came from.  All these little footnotes are references
     to that.
               DR. KRESS:  And your point about the human error
     contribution to the CDF per year is that it's high like 93
     percent, then that value you get is almost directly
     proportional to what you assume for this human error
     probability?
               MR. SPENCE:  Yes, sir.  And I think these numbers,
     if I'm not mistaken, and somebody can check me on what
     reference I used, but I think it's 1477, NUREG 1477 numbers.
               [Pause to adjust microphones.]
               MR. SPENCE:  How's that?
               VOICES:  Good.
               MR. SPENCE:  Okay.  All right, I'm sorry, did
     anyone else have other questions?
               [No response.]
               MR. SPENCE:  Okay, now, I've tried to get the
     latest -- I've been trying to get the latest Westinghouse
     emergency response guidelines from the owners group since
     May of this year, and have been unable to do so.
               That request has been refused twice that I know
     of.  So, some of -- so what I tried to do is put together my
     own concept of what's important in this faulted or ruptured
     steam generator.
               The first thing he's got to do is maintain -- get
     the reactor subcritical and maintain it that way with some
     type of boron addition.
               This is the diagnostic step that is the unusual
     feature, the newest -- the latest symptom-based procedures,
     he really doesn't have to diagnose it.
               But this is the unusual feature:  He does have to
     diagnose it, and it's very difficult for him to determine
     the primary system flow rate, when everything is in such
     transient conditions.
               One recommendation might be to try to come up with
     in the SPDS system, some type of calculation that might be
     able to tell him some kind of rough number of what -- how
     much leakage he has.
               Now, then this is where your ten to the minus
     three comes in to depressurize, cool down the reactor
     coolant system.  He's got to worry about maintaining
     adequate sub-cooled margin, and yet he has to decrease the
     reactor coolant system pressure, so he's kind if working
     inversely proportional to what he's trained to do.
               Your safety injection system is going to come on,
     and kick the pressure up, and that's also working against
     him because what he really wants to do is take the pressure
     down.
               It's going to take about two hours to get down at
     the best down to RHR cooling.  But by the same token, he
     doesn't want to cool down too fast, because he's got 100
     degrees per hour cooldown rate max, and he's worried about
     vessel integrity.
               The hour-long steam line break at Robinson 2, a
     cooldown, I think, 213 degrees in one hour.  At Turkey
     Point, the cooldown rate that I saw was 60 degrees F within
     three minutes.
               So, he's got all kinds of transients going on that
     he's trying to respond to, and he's trying to get down as
     soon as he can to RHR to stop the release of radiation to
     the atmosphere.
               So those are -- oh, the other thing, the other
     important thing that is in the DPO is that he has to refill
     the refueling water storage tank.  If you look at the
     hierarchy of goals, this is very low in what he's trying to
     do.
               He's got his hands full.  So, I went back and just
     for the sake of argument, I just took what was in NUREG
     6365, and said, okay, how did he meet those goals?  What
     happened in -- there were ten events there, and I included
     IP2, so we've got 11 events, and I think we really didn't
     have good data on a foreign event, so let's call it nine out
     of ten events.
               There was a delay in tripping the reactor.  What's
     interest, at both Turkey Point and Robinson 2, when the
     event occurred -- see, the operator doesn't know what
     happened.  He doesn't know if he's got a relief valve stuck
     open, until he sees a trend, or main steam line, and until
     he sees a trend in the pressure -- in the steam generator
     level going down.
               DR. BALLINGER:  Wouldn't you see tail pipe
     temperature on the relief valve?
               MR. SPENCE:  On the main steam relief valve?
               DR. BALLINGER:  Isn't there a --
               MR. SPENCE:  I don't know of any.  Does anybody
     else know of any?
               DR. SIEBER:  You can hear them.
               MR. SPENCE:  You're right, but you don't know
     whether it's a relief valve and it's going to --
               DR. SIEBER:  Or a break.
               MR. SPENCE:  Or a break, that's right.
               DR. SIEBER:  Relief valves are usually quieter
     than a big break?
               MR. SPENCE:  Yes.
               And what the operators are going to do, naturally
     -- what are they used to?  They're used to working CVCS
     pumps, charging pumps.  So they're going to go over there
     and if they've got one shut down, they're going to start it
     up.
               In fact, they may even, if they've got boration
     going in, they may stop boration, which is what happened at
     -- I can't remember which one of the two events, Robinson or
     Turkey Point -- which is exactly what you don't want to do
     at that point.
               Because now you've got to worry about cold water
     addition, and re-criticality, and what you need to do is
     pump in that nice boron in your refueling motor storage tank
     into the core.
               Okay, this was an old thing where you could either
     use a steam generator tube rupture procedure or a steam
     generator leak procedure.  Again, I don't know if that's
     going to be applicable in today's world or not.
               There have been a number of delays in either
     keeping feedwater going into the steam generator, which is
     just going to exacerbate the continuing oscillations of the
     steam break, giving it more fluid, and making the common
     mode residence frequencies last longer.
               Yes, sir?
               DR. SIEBER:  I think that the more difficult
     problem for an operator is if he ends up with a main steam
     line break somewhere, or a stuck-open safety valve, and then
     the steam generator tube rupture occurs because a lot of the
     parameters will track one another.
               He may make an assumption that he knows what it is
     he's got, and start off down that track without picking up
     for minutes, perhaps, the fact that he's got two problems
     running at the same time.  I think that's tough for an
     operator.
               MR. SPENCE:  Yes, and he's really relying upon his
     radiation monitor.  And if he doesn't have that radiation
     monitor available --
               DR. SIEBER:  You're talking about N-16 monitors?
               MR. SPENCE:  Yes.
               DR. SIEBER:  All plants have them.
               MR. SPENCE:  Yes.
               DR. SIEBER:  And some of them are local readout.
               MR. SPENCE:  Right.
               DR. SIEBER:  So both of those are a little bit of
     a problem.
               MR. SPENCE:  And if you don't have it, he's going
     to misdiagnose it, not always, but it has contributed in the
     past, the loss of that.
               DR. SIEBER:  You'll see that everywhere, probably,
     though, because you'll pick it up on other area radiation
     monitors, the fact that you've got more activity.
               MR. SPENCE:  That's right, but whether or not and
     what the operator attributes that to, I'll talk about some
     simulator testing a little bit later that occurred over in
     Norway, in which I've got the videotape of.  
               And the operators talk about how well the
     condenser radiation monitor, gas radiation monitor off the
     steam generator, et cetera -- well, there's no flow going
     through that line, so that's why it's alarming.  They could
     rationalize it out.
               DR. SIEBER:  Well, the other problem is that you
     may not get a radiation signal, because when you get a trip
     like that, well, the safety valve opening is all being
     bypassed.
               MR. SPENCE:  Yes, and there's no radiation
     monitors there.
               DR. SIEBER:  That's outside, and you don't have
     anything there to pick it up because it's not a monitor
     release point.
               MR. SPENCE:  Right.
               DR. BONACA:  I hear you talking about current
     response using EPGs.  I mean, symptom-oriented procedures,
     right?
               MR. SPENCE:  These here are what happened.
               DR. BONACA:  This is before at Westinghouse.
               MR. SPENCE:  Some of it is applicable; some of it
     may not be because of the change to the symptom-oriented
     procedures.
               DR. BONACA:  Okay.
               MR. SPENCE:  And I think one case there was --
     they were releasing radiation that they didn't have to,
     because the swap over with the lines going back inside the
     containment didn't swap.
               And I think that was a radiation monitor thing,
     too.
               MR. SIEBER:  That's on the air ejecter?
               MR. SPENCE:  Yes.
               MR. SIEBER:  Okay.
               MR. SPENCE:  The other thing I alluded to before,
     when I was talking about the noise-- it affects
     communication and operator performance.  This was, you know,
     I mentioned it at Turkey Point, but it was also mentioned in
     the report from Robinson, too.
               Okay.  The pressurizing cool-down.  In these
     things, it's -- well, when the safety ejection comes back
     in, and whether or not you have pressurizer spray determines
     whether or not you can control the pressure.  If you -- when
     you've got decay heat in the there, and if you isolate a
     feed water generator, steam generator, you've got to start
     your auxiliary feed water into your good feed water heaters.
               DR. CATTON:  How could they recognize whether or
     not they have a trip level in the head?  Oops, sorry.  Go
     ahead.
               MR. SPENCE:  You're going to get a pressurizer
     level, basically down to zero, which happened.  That -- at
     Turkey Point, that lasted I think for 15 minutes.  For
     Robinson, I think it went 30 minutes.  Okay.
               And you also have -- I'm sorry -- you also have
     temperature -- should have temperature indication up there.
               DR. BONACA:  This is all for steam generator tube
     rupture.  I mean, this is not steam line break?
               MR. SPENCE:  This, this.  You're right.  This is
     steam generator tube rupture.
               DR. BONACA:  Okay.
               MR. SPENCE:  Okay.  The only thing that wasn't was
     my comment about the noise.
               DR. BONACA:  That's right.
               MR. SPENCE:  Okay.  If you loose the pressurizer
     spray, you can also go solid on the primary system for a
     long period of time.  Several plants overfill their steam
     generator.  In the Halden experiments, I think it was two,
     and please correct me if I'm wrong, Jay.  Two operator
     simulations basically were going to rupture the steam
     generator tube sheet, is that correct?  Okay.  Two out of
     four dealing with that particular scenario.
               Power operator relief valve.  This happened at
     Indian Point Two, because it took them so long.  They were
     running out of pneumatic supply, and they had to make a
     containment entry to put in some more bottles.
               Delaying the power operator relief valve, again,
     is the operators want to keep the pressure up, and for the
     sub-cooled margin, when they actually got to open it up and
     get down as soon as they can.
               Okay.  Delay in initiating RHR happened in Indian
     Point Two, where they had a procedure glitch with respect to
     I think it was the temperature where they could get it on. 
     It was changed in one procedure, but not in another.  Yes,
     sir?
               MR. HIGGINS:  Based on all of these things, you're
     saying that the one times ten to the minus three human error
     probability is too low, I assume, and are you proposing your
     own alternative value or are you just saying it's too low,
     you don't like that one?
               MR. SPENCE:  I'm suggesting it's too low.  I don't
     like ten to the minus three.  That's a 99.9 percent chance
     of everything working, including the operator.  I am not
     proposing a specific number, because these are all problems. 
     Now, these are all successful events.  All I'm saying is
     there were a heck of a lot of operator problems involved in
     these events.
               MR. HIGGINS:  The typical value for this error in
     most of the IPEs in their tube rupture sequence is about
     times e to the minus two, would you agree with that one?
               MR. SPENCE:  It would depend -- I think it would
     be on a sliding scale, believe it or not.  I think, because
     the operator error rate and how it affects a steam generator
     tube rupture and main steam line break is going to depend
     upon how much time he has to fulfill his functions, and as
     his time decreases, the more the probability of him being
     unable to fulfill his functions is going to get smaller. 
     So--
               DR. BONACA:  I would like to comment on one thing
     about that.  This scenario probably is one of the most
     challenging that the operator has, because right now, the
     operator has goals of containing the release within 30
     minutes.  That's one thing that challenges the operator to
     no end, because they get into the event.  By the time they
     recognize it, they are dealing with all these issues, and so
     the issue is not really core damage, but they are focusing
     always on stopping the release within 30 minutes, and that's
     very challenging.  I mean, for some plants, it's very hard
     to demonstrate and get to something that they have to do on
     the simulators or show they can do it.  And so, it puts a
     lot of pressure on that.  Although the other one is much
     more complex steam line break, everything goes in the
     direction of taking you down to the RHR.  The larger is the
     break that you have on the secondary side, even if you don't
     recognize it, and you're depressurizing fast, and you're
     unable to come back and pressure the primary site because of
     the leak.
               So I'm saying that, you know, I'm not questioning
     at all that 10 to the minus three might be overly
     optimistic.  In fact, it may be, but I'm only saying that
     this is a different scenario and is one of the most
     challenging to the operators, because of the goals that set
     on them, which is the 30 minutes to stop the release..  And
     that's very hard to do, very hard to do.
               MR. SPENCE:  And I think that between the maximum
     and minimum breaks that we might be talking about here, I
     think the worst case is going to be in the middle some
     place, because like you say, one, the reactor is going to
     take itself down and the other -- and the one in the center
     is the one he's really going to work on.
               DR. BONACA:  And small, too.  The small ones may
     be the most confusing because he has a steam line break.  He
     doesn't have much leakage.
               MR. SPENCE:  Right.
               DR. BONACA:  Therefore, he may stay -- you know,
     the steam generator may not blow down as fast for him to
     recognize it.
               MR. SPENCE:  Right.
               DR. BONACA:  And he might just do something that
     is totally, you know--
               MR. SPENCE:  But then, he doesn't have to worry
     about the refueling water storage tank as much because he
     has a longer period of time to respond.
               DR. BONACA:  That's true.  That's true.
               MR. SPENCE:  Right.
               DR. POWERS:  Mr. Bonaca, I wonder in some sense if
     the event tree doesn't have to be fairly complicated here? 
     Because an operator can, in the end, do everything
     correctly, but if it takes an excessive amount of time, not
     so excessive that we would run into the RWST probe; that if
     we have damage propagating at a crack growth rates, that
     gets you into an irreversible problem, and I'm wondering if
     simply debating over 10 to the minus two, 10 to the minus
     three in an operator's success or non-success is a
     sufficiently sophisticated event tree for this.
               MR. HIGGINS:  Yeah, in actuality, the dominant
     sequence is related to tube rupture in most of the plants is
     a failure of HPI, coupled with the steam generator tube
     rupture.
               DR. POWERS:  Right.
               MR. HIGGINS:  And then the other item in that cut
     set is typically this operator failure to rapidly
     depressurize.  And it varies from plant to plant, and it
     varies depending on the leak size.  But often times, they
     only have in the neighborhood of 15 minutes to do that for
     success so that puts even a tighter on the operator action
     in order to have successfully cooled down without core
     damage.
               MR. SPENCE:  Yeah, but now, with our symptom-based
     procedures, by the time he figures out what he's got, and
     gets into the procedures, if it's small, okay, and then he
     takes, you know, 20 minutes to get into where his actions
     are going, he's in trouble.
               I'll try this, and if you want to but in and take
     over, go ahead, Jay.
               Jay Persinsky is our team leader on human
     performance issues and research.  And he had a study on
     human performance over at Halden, which is in Norway, right? 
     And they were working with the LEVISA crew out of Finland. 
     And they were looking at both -- at staffing levels with
     respect to the current type of operations on the current
     type of plant control rooms versus the new type of CRT
     displays.
               And that you were looking at four operators on the
     normal plant, and two operators on the other plant.
               The scenario that -- they did a number of
     scenarios, but the scenario that was of interest, of course,
     to me was a steam generator leakage rate -- leak rate --
     which was then followed by an open steam generator safety
     valve for an unfiltered release to atmosphere.  Like I said,
     we've got the tapes, the videotapes of the actual scenarios,
     with an English translation somewhat.  I looked at it--at
     one particular one -- that -- and it was really consistent
     of what could be found in an American plant.  They were
     using some procedures.  One of the fellows was trying to
     diagnose stuff, but he was not -- they were not diagnosing
     the scenario correctly.  Okay.
               This -- one of two four-man conventional reactor
     crews, and one of the advanced reactor crews performed very
     poorly, and I've got the tape on this if you'd like to see
     it.  And the interesting result is that the longer -- this
     scenario, too, goes on for a long time, because he's cooling
     down for a couple of hours.  Someone asked about training. 
     The trouble with the training is that once -- because the
     utilities have got to train on so many different scenarios,
     once the operators diagnose it, they say okay let's stop
     that, and we'll go on to the next one.  Where they're
     running into trouble is the long-term cool-down and switch
     over on this thing.
               DR. POWERS:  I just have to ask a question.
               MR. SPENCE:  Yes, sir.
               DR. POWERS:  Isn't Holden a boiling water reactor?
               MR. SPENCE:  Jay?
               MR. PERSINSKY:  Yup.
               MR. SPENCE:  Yeah.
               MR. PERSINSKY:  Jay Persinski, Office of Research. 
     The Halden reactor is, in fact, a boiling water reactor. 
     This was done on the simulator.  The simulator is, in fact,
     a DVBR, which is a type of pressurized water reactor.
               DR. POWERS:  I guess -- then it comes to mind that
     we have a Russian crew working this or a Finnish crew
     working this?
               MR. PERSINSKY:  It was a Finnish crew working. 
     It's a LEVISA crew that typically worked the LEVISA plant. 
     One of the -- where he talks about the conventional reactor,
     that was actually done at the LEVISA simulator.
               DR. POWERS:  Oh, okay.
               MR. PERSINSKY:  The advanced crew, or the advanced
     reactor was done at the Halden simulator.
               DR. POWERS:  So we didn't have a problem of
     boiling water reactor crews trying to do a PWRC?
               MR. PERSINSKY:  No, we did not have that problem.
               MR. SPENCE:  Not only that, but the simulators
     were modified somewhat to look like an American reactor.
               DR. POWERS:  Now, did that introduce any problem. 
     I mean, I've got a Finnish crew familiar with a BBR Russian
     reactor working on an American modified simulator.  I could
     believe they might have some trouble.
               MR. SPENCE:  That wasn't the problem.
               DR. POWERS:  Okay.
               MR. SPENCE:  The problem was their diagnosing and
     getting the correct answer of what was really happening to
     the plant, okay.  And that was the same type of thing I
     would have expected to see in a control room.  I saw it in
     Turkey Point for quite some time.  When I got in there,
     about 30 seconds after the line blew off, you know, I'm not
     believing that I saw a safety valves go up and fly over the
     containment.  I didn't want to tell them that.  You know, I
     says -- they would have thrown me right out, okay.  And it
     wasn't until, you know, the noise stopped and we could go
     out and didn't have to worry about shrapnel and so fort that
     we could ascertain what really happened.
               Okay.  The point being that this takes a long
     period of time to cool down and to stop that release and
     that the training scenarios probably don't go into that long
     thing.  And the high work load is going to build up on these
     guys, as time goes on.  That was an interesting conclusion
     there.
               They also tried it with three men and what was it,
     Jay, on the one out of two?  Did they cut down to one or--
               MR. PERSINSKY:  No, it was two or three in that
     situation.
               MR. SPENCE:  It was three here, normally, and then
     they cut down to two?
               MR. PERSINSKY:  Right.
               MR. SPENCE:  Okay, and this was four, they cut
     down to three.  Well, that's exactly what's going to happen
     in an actual scenario, because either you're turbine
     operators are not going to be there, or you're going to send
     a reactor operator out to find out what's going on, or
     you're going to have fires, and somebody's going to have to
     go off into the fire brigade.  Or you're going to have to
     call the NRC and stay on the line and tell them what the
     heck is going on.  So you're going to lose somebody.
               DR. CATTON:  And you also couple this with some
     wort of implicit faith in the ability of the simulator to
     represent the event, and we know that's not true.
               SP Yeah.  Yeah.
               DR. CATTON:  I just thought I'd put that out.
               MR. SPENCE:  And operate it -- when it really hits
     the fan, operators just kind of stop for a minute to try to
     think what's going on.
               DR. CATTON:  An interesting example of this in
     some of the testing that was done at the University of
     Maryland, where they found that the water in the primary
     system was moving from one loop to the other, and all kinds
     of strange things were appearing on their instrumentation. 
     And that doesn't happen with a simulator.  And you wonder
     what would the operator do if he saw that.  It doesn't fit
     any of his symptoms.
               MR. SPENCE:  Yeah.  I -- you know, I can tell you
     from real life that the minute that happens, the operator
     just -- you kind of freeze to try to figure out what's going
     on.
               DR. CATTON:  Not according to NRC.  Not according
     to NRC.  Relap properly reproduces the accident.
               DR. POWERS:  Well, first -- Catton, I point out to
     you that we do have a list of events where they successfully
     got the plant down.  So.
               DR. CATTON:  In spite of all these operators.
               DR. POWERS:  In spite of all these possibilities,
     it is possible to get these plants down.
               MR. SPENCE:  It is possible, okay, and those were
     relatively small leaks.  Okay.  Jay, had--
               MR. BALLINGER:  I would -- Gannai with 700 gallons
     a minute.
               MR. SPENCE:  Well, that's also--
               MR. BALLINGER:  The water was -- my was 700 in
     Maguire.
               MR. SPENCE:  That's the initial, that's the
     initial leak rate.  And then it decreases from that.  So
     that's only the top.
               MR. BALLINGER:  And you would expect that in any
     case for a steam generator tube rupture?
               MR. SPENCE:  Yes, sir.  Okay.  But now, to reach
     your part 100 limits, I believe you're dumping 10 gallons a
     minute off site.  So -- I think the average is 130 to 135
     GPM or something like that of all the steam generator tube
     ruptures.  So you can put that in -- and if you assume that
     your pressure -- that at main steam line break point, you're
     going to have X and then you're going to have one-tenth X
     later on, you're still up.  The NRC assumes a factor of 10
     difference in the leakage rate between main steam line break
     and normal operating conditions.
               DR. HOPENFELD:  In the case of Gannai, the tubes
     were not -- there was an effect on other tubes, but the
     tubes were not defective -- the fuel was brand new.
               MR. BALLINGER:  It was a wrench or something.  A
     loose part, right?
               DR. HOPENFELD:  A loose part, but so that really
     -- they did it.  I think they took samples -- it was -- they
     took samples from the snow in that spot that did exceed, but
     it was really a brand new fuel, so there was no really
     reason to expect it.  But the point is, in my DPO, my
     thinking at the time when I reviewed all the data, I thought
     after a thousand that when you exceed a thousand, that's
     where we really -- that's where we really start worrying.
               DR. POWERS:  Dr. Kress, while you were out,
     professor Catton brought up the experiences at the
     University of Maryland, I believe, where because you have
     multiple loops you got water transferring from one loop to
     another.  I think that's done correctly, and I think that's
     an issue that you were mentioning to me is the concern.
               DR. KRESS:  It definitely was.
               DR. POWERS:  And you might want to pursue that a
     little with professor Catton.
               DR. KRESS:  Yeah.  We'll get together.
               DR. CATTON:  Well, we raised that issue.  That was
     before I left the Committee when that issue was on that. 
     And we were told that the simulator -- the simulator
     fidelity is proven by comparison to RELAP, and that's the
     way it is.
               This has been something that has bothered me for
     15 to 20 years.
               DR. POWERS:  RELAP is the ASME standard of--
               DR. CATTON:  Whatever.
               MR. SPENCE:  I've got one last point to make on
     the operator thing.  And that is with respect to risk and
     the probability of whether or not the operator is going to
     perform his functions.  Jay Persinski worked with
     Microsinks, is that -- with a -- he got a little contractor
     -- Microsink Task Network Model, which was basically a
     modeling of operator performance for steam generator tube
     rupture and a stuck open relief valve, okay.  We could have
     had it modified to see what a steam generator -- I'm sorry
     -- a main steam line break with a steam generator tube
     rupture could have done.  This was ruled out of scope in the
     previous DPO Panel, and it was also ruled out with respect
     to research by our manager.  We really thought that that
     would have been good, because then we could have got in
     there -- it's got the whole analysis of what the operator
     actions have to be.  You could tweak the times.  Try to set
     them up.  It was already set up with respect to the Halden
     experiments.  And we could have gone back to fit in some of
     the steam generator tube rupture events as well as done some
     testing down at TTC to set up some scenarios.  But again,
     that's out.  That would have been a good thing to do to
     really find out what the operators might be expected to do. 
     Jay, do you have any comments on that or -- any other
     questions?
               Thank you.
               DR. HOPENFELD:  I have two items to cover, and one
     of them is fairly simple.  The other one is very much more
     complicated, and I'd like to go fast so, because I see
     already that that I'm starting losing my clients here.  So.
               DR. POWERS:  I think you've got the panel here
     with -- in rapt attention.
               DR. HOPENFELD:  As you see, I have a very, very
     lengthy summary about 50 pages, well, maybe not 50, but
     about 20 pages of specific questions which really summarize
     what I've been talking about, but on a much more specific
     level.  And I though that because of the time clicking here,
     I guess everybody probably want to go home.  So I'm going to
     just complete this part of the presentation.  Go through two
     subjects.  One is the iodine spiking, which is relatively
     easy.  And then the other one, which is very difficult for
     me to talk to, but I have to, and that's an independent
     assessment.  But I don't think that's going to take us --
     oh, probably, we should be done by 5:00 p.m., and what I'm
     going to leave the discussion, the specific questions to NRR
     for you to look at, because they go to a lower-level of
     specificity and, in the future, if you want to address those
     to NRR, I don't know how else you could handle it.  If you
     had more time, I would have gone through it, but I think --
     I'll try to give you the flavor as to what I'm talking
     about, and I think that going through these slides is not
     going to really add too much to the overall understanding. 
     It's just another level of specificity.
               But let's go to the next item, and that so far
     we've been talking primarily on the design basis accident. 
     We talked a little bit on the severe accidents.  The next
     one is a legal requirement that you have to meet part 100,
     which you have to leave -- I mean 300 REM as the result of
     an accident.  What the -- what the dose is, is very simple. 
     The equation for calculating dose is extremely simple.  What
     it is is the leakage time the spike times the initial
     activity.
               What the spike means is when you go -- disturb the
     system or disturb the primary system, due to temperature or
     pressure drop or whatever, any crack in the cladding will
     flush some of the fission products out of the fuel and that
     goes into the coolant.  There are also other sources.  This
     is not the only source.  There are corrosion products that
     may be laying around, and when you shock the system, you may
     get corrosion product coming into the -- that were deposited
     on the fuel.  So it's a -- the mechanism is not understood,
     but I don't know how important it is to understand it.  The
     calculations that we are doing -- the important thing is
     that this is not exact science.  People, over the years,
     sort of empirically came up with some numbers.  And there
     was a conservatism, and nobody really tried to quantify that
     conservatism.  It may not even be necessary.
               Iodine chemistry is a very complicated thing,
     especially if you can see, though we are talking about very,
     very low concentration.  We're getting into the region that
     maybe the classical chemistry may not even work anymore,
     because the mean -- because the molecules already is not
     getting out of where you can calculate your equilibrium
     factors.  So we don't want to get into that, but we don't
     want to do things that violate some basic laws.
               And that's exactly what NRC does.  What happened,
     again, going back, remember, we had steam line -- you had
     SGTR, and you have a steam line break.  Now, we've got a new
     phenomenon, so if -- when you come up with larger leakages
     that would allow you to meet the 300 REM requirement, and
     I'll go back to the 300, too, but what you can do, going
     back to the equation, is a very simple mathematical trick is
     -- well, you can say, well, this spike here, well, if the
     leakage is higher than off the one GPM, what I can do is
     just get this one down, and I'm back in business.  I'm
     sorry, I can get the initial activity down, because I have a
     control over that with a clean up system.  And most of the
     power plants operated at a lower than tech spec activity
     anyway, and then I'll be in business.
               Well, it turns out that you can't do that; that
     it's not that simple.  And the reason it's not that simple
     because there is data to indicate that if you are -- if you
     lower the iodine concentration in the coolant, then it
     affects this spike.  I don't exactly claim to understand
     why, but if you look at the data, it shows that you can't
     just arbitrarily -- there is some dependence here between
     the spike and the initial concentration of the iodine in the
     coolant.
               Now, for years, the plants did not want to lower
     that initial concentration.  They were happy with the one
     microcurie per gram, and I don't know -- it could very well
     be because of contractual obligations or the legal mumbo
     jumbo that was in the contract between the supplier and the
     power plant.  But anyway, they didn't want to go to a lower
     than one microcurie per gram.  Now, suddenly, we find that
     NRR says, well, in order for us to meet Part 100, let's
     lower that tech spec, allow them to operate at point -- give
     credit for operating at point one or whatever.  Well, you
     can't do that if there's data out there to show that if you
     do that, that 500 number, whatever that number is, but it's
     sort of a consensus number, you can't take that 500 number
     and still lower the concentration at the same time, because
     you can have a spike that's just -- that's all the way up to
     10,000.  Alright.
               The point I'm trying to get across -- you can't
     just do these things -- adjust these things just to meet --
     to get a final answer that you are happy with.  You have to
     be consistent as to what you're doing, and I think the NRR
     people are not consistent with what they're doing.  And I
     think this was recognized a long time ago.  I think in '94,
     when I presented this and we discussed that, but nothing has
     been done since.
               What was done basically, and I think that's what
     you'll probably hear tomorrow, NRR provided a table that
     shows -- basically agrees with my argument here that if you
     lower the concentration and if you put a larger leakage, and
     the larger spike, then you would -- you could exceed the SRP
     value of 30 REM.  Now, in the -- Part 100 calls for 300
     REMs.  The SRP calls for 30, and I don't know exactly what
     caused -- where the 30 number comes from, but again, it sort
     of evolved over the years, and it's an empirical number, and
     you said, in order to meet that 300, we have to use 30. 
     Otherwise, why not use 300?  So they put in the SRP, and
     that's what the licensees are required to meet, is the 30. 
     So when we're talking about meeting the requirements it's
     the 30, and it's not the 300.  So you can't just say, well,
     that what's was done in the table that they provided us is
     that, look, you'll have to have a huge spike in order to
     exceed the 300 REM.  But it's not the 300; it's the 30.  But
     even then, the main point is that where you don't have any
     data, and one argument was that, well, steam line breaks
     don't occur very often.  Well, they don't -- we hardly have
     any, even though we heard one or two, then why even worry
     about the regulations.  Just forget about Part 100.  Just --
     if we don't have to worry about it.
               So the argument was -- that's made -- and that's
     the crux of this thing is that we don't have data to show
     that on the steam line break conditions the depressurization
     is so high that the iodine spike is going to be very large,
     so don't you just ignore it?  And what I'm claiming here is
     that you just can't do it in an arbitrary way.  And I think
     that hasn't been resolved as being recognized as a potential
     issue and it's still there.
               Now, the thing away.  But then, after the comments
     on the DPO came from the -- after it came back from public
     comments in the summer of 1999, they just took that sentence
     of the paragraph which says that they're going to ask the
     licensee to come up with a better leakage assessment or put
     uncertainties on it, and that's why I say, well, if you do
     that, then you better go and look at this iodine spike,
     revisit the whole thing again.  You have to address this
     issue.  And they just know -- I don't know how you resolve
     it, and I don't know what you do.  Now, there's some
     suggestion from Dr. Powers several years ago, but I don't
     know of anybody who picked up on that.
               So, basically, you cannot -- to summarize it, we
     cannot arbitrarily to say, well, because you want to meet
     the Part 100 requirements, we're just going to lower the
     activity, the initial concentration without really looking
     at what the data.  If you do that, you selectively use
     what's available there.  What the database is.  If you want
     to operate in that -- on the basis that you can use
     selective reasoning, then it's okay.
               Let me go back a little bit now.  I'm done with
     the iodine.  I know you don't want to harp on it, because I
     don't know what I can add to it.  Let me go back to the time
     line, and I stop here, around June or in mid-June, ConEdison
     submitted a proposal for to justify -- or the justification
     for the next cycle.  The public, or some members of the
     public, the Union of Concerned Scientists, was very critical
     of that, and they have asked me to -- or they asked the NRR
     or NRC to allow me to talk about these issues at the public
     hearing.  And NRR said no.  I was kind of a little bit
     disturbed about it, because what is it that I could -- why
     prevent me?  What is it that I could harm anybody by talking
     about these issues, basically, would summarize what I told
     you all today, I would summarize into a few minutes, so
     somebody would get a flavor what different -- perspective on
     this.
               But that -- that -- really what bothered me about
     their reply -- that -- the reason that was given -- the
     reason was given that they don't want me to talk about this
     at the public hearing was because the DPO issue is the
     generic issue, and the IP2 is the specific issue.  Now, it's
     been now three months, and I've talked to a lot of people in
     trying to help me to understand the difference between the
     specific and the generic.  I don't see how you can separate
     the two.  But anyway, later on, it occurred to me the reason
     that they really didn't want me to -- prevented me from --
     to come and talk about it was basically what the IG found
     out in two months or three months later.  And that is that
     we let inexperienced engineers review those actions, which
     are very, very important safety actions.  They are not
     supervised, and they have constraints on them.  They're not
     allowed to have an open dialogue with the licensees.  So you
     have an inexperienced person -- reviews an action, and he is
     constrained to follow up on that.  And what -- the reason
     I'm bringing all this is that it calls into question as to
     how we do business, and what is really is needed -- what is
     really needed is an independent assessment.  When a licensee
     comes here, and he wants to take a -- ask for relaxation,
     whatever the relaxation is, I think we should have a third
     party that says, that provides an independent assessment of
     what that action is.  When you go and buy some instrument
     that has to do with monitoring the environment, you can't
     put it on the market until you get EPA approval on it that
     it was tested by a third party.  And the same thing here. 
     You have to have an independent third party that can step
     aside and assess what the licensee is submitting to you,
     because you don't have enough checks and balances within
     this agency to take care of that.
               Now, one of the items that I talked about, and
     it's a follow up on actions at the NRC, and it does relate
     to the independent assessment.  In the -- one of the -- I
     believe -- I don't remember the date.  I think it was -- I
     think it was the '94 ACRS meeting, the ACRS told the staff
     that we need more adequate data for empirical correlation. 
     The empirical correlation was inadequate.  I don't see that
     we have any -- after six years that we have any data which
     is more adequate.  We have some little bit more data, but
     it's not necessarily more adequate if you consider all these
     effects of vibration and forces that you get through a steam
     line break.  So we don't have any.
               Then a more adequate characterization of the
     gradation of leak assessment and morphology affect the
     morphology on the leak.  We don't have that.  Then there was
     a requirement for NRR to come up and quantify, and you can
     look at the letter to the Commission to quantify the
     conservatism because they claimed that it's too conservative
     independent of how you -- in spite of how you use the iodine
     spiking.  The request was that they quantify this.  There's
     nothing on that.  Then we have another, and that is the
     GSI-163.  That 163, which is a high priority, has been in
     the works now for nine years, eight years.  It's still
     fairly young compared to some of the 17 years that you've
     seen before on the pump seal.  So it's not really that --
     it's not desperate yet.  It's still got many years to go and
     incubate.
               But that 163, the reason for that was given that
     it's not being worked on is that first, we got to resolve
     the DPO.  I submit to you the resolution of this 163 and the
     resolution of DPO are completely two different things.  The
     subjects are the same, but the procedures, how you resolve
     GSI is different.  You go to a cost benefit.  You look into
     different design options.  It really is not the DPO.  It
     just talks about the issue.  It just briefly looks into
     this.  I haven't had a chance to go and look into really --
     put -- start with a clear -- see what other options are, and
     there are options.  I may not just give you something off
     the top of my head.  You can put a double-walled pipe in
     there, with leak detector.  I'm just talking off the top of
     my head.  But there are other options.
               And that's where the GSI is supposed to look at. 
     But if nobody wants to work on it, you continuously keep
     delaying it because it could very well be that you'll have
     to have a back fit.  So if you -- well, let me ask you,
     right now, the latest thing in the gimmicks -- and this is
     the means which we communicate to the public -- it says that
     it depends what you people are going to come up with. 
     That's how you're going to be -- you are the ones who going
     to be resolving this GSI-163.  I don't think that that's
     what you -- you may have not know that, but that's what
     you'll be doing.  If you say that that DPO doesn't have
     enough merit, you also said, well, you might as well close
     this GSI-163.  And that's exactly what they have done.
               Now, there is, at the same time, I told you after
     the failure of the rule making, the generic letter, the
     regulatory guide, all these were substituted by discussions,
     which I haven't been to any of them.  I don't know whether
     they are open door or closed door.  It doesn't matter,
     because all the data is all proprietary.  So you can even
     sit there, but you don't know what they're talking about --
     I mean, if you're from the public.
               And there's such a huge amount of data that you
     have to spend your lifetime to go through there, and it's
     very difficult to understand it, and I hope you'll go
     through some of it, and you'll see it for yourself.  So you
     have this discussion going with NEI to come up with an
     agreement.  And now NRR says, well, the DPO has nothing to
     do with this agreement that we're working.  In other words,
     the DPO has nothing to do with degraded tubes because it's
     not related to it.  We have something else we're talking.  I
     hope that tomorrow, they'll tell you what it is that they're
     talking to NEI about.  They are not talking about any -- I
     mean, according to what they stated, and they stated on
     several, and I have the thing in writing from the EDO saying
     that the discussion with NEI, that really is going to come
     up as to how we going to regulate the steam generators for
     the next 20 or 30 years really has nothing to do with all
     those items that we talked about today.  So I don't know
     what they're talking about, but I hope you ask them.  Ask
     them, what is it they're signing.  What is it they're
     agreeing with it?
               About a week ago, the IAG came up with a
     recommendation -- finding about the DPO process at the NRC. 
     Now, why I'm telling you?  Why is the DPO related to?  If I
     am asking you or I'm recommending that you have a function
     that does an independent assessment to NRC activity, the
     reason for it is that you don't have a check and balance
     system within the NRC.  There is a system what's called
     DPV-DPO, which I briefly talked to you at the beginning of
     this meeting, but it's ineffective.  So putting all this
     together, you have a function at NRC, the regulatory people
     do not take your recommendations seriously.  They do not
     follow up on that.  At a meeting in '96, I believe it was,
     and I brought it in, you can look up in your time line, you
     asked me or you specifically recommended to the Commission
     that the NRC -- the NRR staff resolves the DPO and resolve
     the GSI before they come up with their rule making.  Well,
     now, they've substituted the rule making with the agreement
     with NEI, and they say, well, the DPO and the GSI are not
     related to it.  So it's sort of going in circles here.
               To summarize, the methodology in GR-95 was adopted
     by NRC in its entirety from Westinghouse.  Westinghouse had
     a very good reason at the time.  They were being sued left
     and right.  And they had a very good reason to come up and
     explain away how they can keep these steam generators alive
     for a longer period of time before they are replaced.  And
     we took it, what they recommended, and followed up
     completely, and bought it completely.  The ACRS was sold on
     the 95-05, and I've spent some time before, there was a lot
     of information that was provided to you what I believe was
     misleading.  So when you concluded on that basis that the
     risk was really 10 to the minus seven or whatever, that was
     on the basis of the information that was provided to you.
               And because of that, and the 1570 relates to the
     severe accident.  That's not really the main thrust of my
     presentation, but basically what this -- what this reads to
     a conclusion, recommendation, and that's basically the
     bottom line to rescind 95-05 and shut down all the plants
     that don't meet the 40 percent -- the 40 percent plugging
     criteria.
               I think I'm 10 minutes over my time.  And I really
     appreciate the time that you gave me.  We could -- I don't
     want to bore you with all the questions I have, and I'm not
     going to go through that.  I thought that if we had time, I
     would, but it doesn't look like it would be a fair thing to
     do.
               DR. POWERS:  Well, I don't want to deter you.  If
     you think that the questions are self-explanatory
     sufficiently.
               HOP I think so.  I think after this presentation,
     they are.  I believe so.
               DR. POWERS:  Well, in that case, first, I'd like
     to thank you for an outstanding set of presentations.  Very
     well put together.  Very clear.  Fast-paced.  Went right
     through the material in a nice way.  Then I'll turn to the
     rest of the panel and the consultants, and ask if you have
     any questions on the material you'd like to direct to Dr.
     Hoppenfeld at this time.
               MR. BALLINGER:  I have a question of you.  If we
     read these questions, and then we discover that there is
     something we don't understand, can we?
               DR. POWERS:  We'll figure out some way to handle
     that.  I think Dr. Hoppenfeld may be away toward the end of
     this week, so he may not be directly accessible, but in some
     way, we will get a hold of you.
               DR. BONACA:  I would like to point out -- I
     thought the agenda that we had time until 5:30 p.m. for
     summary.
               DR. POWERS:  We have plenty of time.
               DR. HOPENFELD:  I would like to make a comment to
     reply to you.  My telephone -- you have my telephone number. 
     I'll be -- and obviously, any question you have, though,
     please e-mail it, and I'll e-mail back to you or reply.  I'm
     going to be out of the country for three weeks as of Friday,
     but then I'm going to be back, and I don't know how long I'm
     going to be here, but I'm going to be enough to answer any
     questions.
               DR. POWERS:  Yeah, the protocol for members of the
     panel to communicate with anyone on the staff is go through
     Undine.  That is, talk to her, and she will get the answer
     for you.  Right?  Of course.
               DR. HOPENFELD:  I am responsible for all these
     questions, and I would answer them very, very -- there were
     a couple of things -- I just in passing in mentioning.  I
     think, when you hear from the staff telling you about their
     beliefs or their judgement, or their -- I think you got to
     find out what their experience is, what the qualification is
     to make these judgements.
               DR. CATTON:  Could I just try to make sure that I
     understand what the primary issues are?  After listening to
     you all day, I kind of get lost in the detail, but the first
     was the meaning of voltage and its relationship to leakage. 
     That was number one.
               Number two was impact of the main steam line break
     or other similar kinds of upsets on leakage in overall tube
     integrity.
               The third was the severe accident issues as raised
     by risk-based regulation.
               DR. HOPENFELD:  That's right.
               DR. CATTON:  The fourth is--
               DR. HOPENFELD:  Because it's raised by risk--
               DR. CATTON:  I understand.  Without risk-based
     regulation, you have the deterministic approach and the
     issue doesn't come up.
               The fourth is the operator performance.  And the
     fifth really is managerial issues and how DPOs are treated.
               DR. HOPENFELD:  Process.  Process.
               DR. CATTON:  Okay.
               DR. POWERS:  Process.
               DR. CATTON:  Okay.  Managerial process.
               DR. POWERS:  Raising the issue across this reminds
     me some have asked about the plans of the subcommittee in
     conducting its business.  I went through those some
     yesterday, but I don't think they got the full exposition. 
     The schedule that the subcommittee has set up for this week
     was intended to allow Dr. Hoppenfeld and the NRC staff to
     present their views on the issues at hand.  And, in some
     sense, the various parties may be surprised by the
     respective views, since I'm sure that over the course of
     time views have been refined and expanded.  And there may be
     instances where it would be useful to have a rebuttal of
     those views.  The meeting this week has not been planned to
     accommodate a rebuttal, but the subcommittee would be very
     interested in any rebuttal views that people would like to
     have and so we have implored the ACRS itself to make
     available some time during its November meeting, and again
     in its December meeting to allow rebuttals.  The ACRS has
     graciously consented to do that with a proviso that anyone
     wishing to provide a rebuttal of the -- on the views that
     are presented today and in the next few days that they
     provide in advance a written summary of the rebuttal.
               That's some piece of information that people
     should have.  Are there any other comments that the panel
     wants to make?
               What I would like people to do is clearly Dr.
     Hoppenfeld has provided us a list of questions of some
     length and of some interest, and I will hope that the panel
     members will take some time to examine these questions and
     examine the presentation today to see if they want to refine
     their list of contentions that they prepared last night.
               And with that, we'll stand in recess until
     tomorrow morning at 8:30 a.m. And, again, thank you very
     much, Dr. Hoppenfeld.  That was very nicely done.
               [Whereupon, the meeting was recessed, to reconvene
     at 8:30 a.m., October 12, 2000]
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