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Joint Subcommittees on Plant Operations and Reliability & Probabilistic Risk Assessment - February 21, 2001

 

                         
                
               
                
                Official Transcript of Proceedings

                  NUCLEAR REGULATORY COMMISSION



Title:                    Advisory Committee on Reactor Safeguards
                               Plant Operations and PRA Subcommittees
                               South Texas Project Exemption Request



Docket Number:  (not applicable)



Location:                 Rockville, Maryland



Date:                     Wednesday, February 21, 2001







Work Order No.: NRC-077                               Pages 1-172




                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
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                     Washington, D.C.  20005
                          (202) 234-4433                         UNITED STATES OF AMERICA
                       NUCLEAR REGULATORY COMMISSION
                                 + + + + +
              ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
                  PLANT OPERATIONS AND PRA SUBCOMMITTEES
                   SOUTH TEXAS PROJECT EXEMPTION REQUEST
                                 + + + + +
                                WEDNESDAY,
                             FEBRUARY 21, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
                       The Subcommittees met at the Nuclear
           Regulatory Commission, Two White Flint North, Room
           T2B3, 11545 Rockville Pike, at 8:30 a.m., Doctor
           George Apostolakis, Chairman, presiding.
           COMMITTEE MEMBERS:
           GEORGE APOSTOLAKIS, Chairman (of ACRS and) PRA
                 Subcommittee
           JOHN D. SIEBER, Chairman, Plant Operations
                 Subcommittee
           MARIO V. BONACA, Vice Chairman, ACRS
           THOMAS S. KRESS, Member
           DANA A. POWERS, Member
           WILLIAM J. SHACK, Member
           ROBERT E. UHRIG, Member
           
           NRC STAFF:
                 GOUTAM BACCHI, NRR/DE
                 RICH BARRETT, NRR/SPSB
                 MIKE CHEOK, NRR/SPSB
                 BILL DAM, NRC
                 STEPHEN DINSMORE, NRR/SPSB
                 JOHN FAIR, NRR
                 HUKAM GARY, NRR/DE/EEIB
                 BOB GRAMM, NRR/DLPM/PDJV-I
                 JOHN HANNON, NRR/SPLB
                 DONALD HARRISON, NRR/DSSA
                 KEN HECK, NRC
                 SAMUEL LEE, NRR/SPSB
                 JOHN NAKOSKI, NRR/DLPM/PDIV-I
                 GARETH PARRY, NRR/DSSA
                 STU RICHARDS, NRR/SPSB
                 MARK RUBIN, NRR/SPSB
                 DAVE BLANCHARD, Tenera
                 TONY BROOKS, NEI
                 WILLIAM BUREHILL, Exelon
                 BIFF BRADLEY, NEI
                 RALPH CHACKAL, STPNOC
                 NANCY CHAPMAN, SERCH/Bechtel
                 STEVE FRANTZ, Morgan, Lewis & Beckins
                 RICK GRANTOM, STPNOC           NRC STAFF: (cont.)
                 BOB JAQUITH, Westinghouse
                 MIKE KNAPIK, McGraw-Hill
                 STANLEY LEVINSON, Framatome ANP
                 J. RUSSELL LOVELL, STPNOC
                 ALLEN C. MOLDENHAUER, STPNOC
                 JIM PETRO, Winston & Strawn
                 CRAIG SEIVERS, ITSC
                 GLEN SCHINZEL, STPNOC
                 DOUG TRUE, ERIN
                 TAKASHI YAMAGUSHI, Kyusho EPCO
           
           
           
           
           
           
           
           
           
           
           
           
           
                                           A-G-E-N-D-A
                                                       Page No.
           Introductory Remarks, GEORGE APOSTOLAKIS,
                       Subcommittee Chair . . . . . . . . . . . . . 5
           Industry Presentation. . . . . . . . . . . . . . . 6
                       RICK GRANTOM, STPNOC
                 GLEN SCHINZEL, STPNOC
                 RALPH CHACKAL, STPNOC
                 RUSS LOVELL, STPNOC
                 ALLEN MOLDENHAUER, STPNOC
           NRC Staff Presentation . . . . . . . . . . . . . 126
                 RICH BARRETT, NRR
                 STU RICHARDS, NRR
                 JOHN NAKOSKI, NRR
                 SAMUEL LEE, NRR
           General Discussion and Adjournment
           
           
           
           
           
           
           
           
           
                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:30 a.m.)
                       CHAIRMAN APOSTOLAKIS: The meeting will now
           come to order.  This is a meeting of the ARCS
           Subcommittee, Plant Operations and PRA.  I'm George
           Apostolakis, Chairman of the PRA Subcommittee.  Mr.
           John Sieber on my left is Chairman of the Plant
           Operations Subcommittee.
                       ACRS members in attendance are Mario
           Bonaca, Thomas Kress, William Shack, Robert Uhrig and
           Dana Powers.
                       The purpose of this meeting is to discuss
           categorization and associated open items related to
           the South Texas Project request to exclude certain
           components from the scope of special treatment
           requirements in 10 CFR, Parts 21, 50 and 100.
                       Maggalean W. Weston is the ACRS staff
           engineer for this meeting.
                       The rules for participation in today's
           meeting have been announced as part of the notice of
           this meeting previously published in the Federal
           Register on January 29, 2001.  A transcript of the
           meeting is being kept and will be made available as
           stated in the Federal Register notice.  It is
           requested that speakers first identify themselves and
           speak with sufficient clarity and volume so that they
           can be readily heard.
                       We have received no written comments from
           members of the public regarding today's meeting.  
                       We'll now proceed with the meeting, and I
           call upon Mr. Rick Grantom of South Texas to begin.
                       Rick?
                       MR. GRANTOM: I appreciate the opportunity
           to address the ACRS.  We are here today to talk about
           STP's categorization process.  This process was
           started back during the time when we went for the
           graded quality assurance pilot which was developed
           during that period of time.  We've done some
           refinements to address the treatment requirements for
           special treatment requirements, and at this time what
           we plan to do is, Glen Schinzel will be doing most of
           the presentation.  We brought with us Russ Lovell,
           Allen Moldenhauer from my staff, and Russ Lovell from
           the Training Department, and Ralph Chackal.
                       So, with that, I'll turn it over to Glen
           to start the presentation, if there aren't any other
           questions.
                       DOCTOR SHACK: Can you just tell me how
           many open items are left on the categorization process
           from the SER?  I was trying to keep track of that.
                       MR. SCHINZEL: We have three open items
           specific to categorization.  All three of those are
           still open, have not yet been fully resolved.
                       DOCTOR SHACK: That's what, 32, 33  
                       MR. SCHINZEL: 34, 35 and 36.
                       DOCTOR SHACK: You guys punted on the
           common cause one, 31.
                       MR. GRANTOM:  Yes.  We went back to the
           way that we had done that in the graded quality
           assurance.
                       MR. SCHINZEL: We will discuss that in our
           presentation.
                       Okay.  If we could get our Power Point
           presentation.  Okay.
                       Again, good morning to the ACRS members.
                       The STP attendees today, like Rick
           mentioned, includes Rick Grantom, who is an Expert
           Panel member on our process groups, Allen Moldenhauer
           is to his left.  Allen is our Working Group PRA
           member.  Russ Lovell to his left is a past Working
           Group chair.  Ralph Chackal, to the far left, is our
           Working Group facilitator, and my name is Glen
           Schinzel, I essentially serve as the Working Group
           sponsor for our graded quality assurance Working
           Group.
                       CHAIRMAN APOSTOLAKIS: It's not obvious
           what the difference is between a sponsor, a
           facilitator and a chairman of the Working Group.
                       MR. SCHINZEL: Okay.
                       Essentially, the chair has the
           responsibility for maintaining the meeting, the
           activities of each Working Group meeting activity. 
           The facilitator, essentially, prepares the information
           to be brought to the meetings for the Working Group
           members, and then as a sponsor I'm the primary
           interface between the Working Group and the Expert
           Panel, and in showing that from a schedule standpoint
           we are getting done what we have intended to.
                       CHAIRMAN APOSTOLAKIS: So, you are a member
           of the Expert Panel?
                       MR. SCHINZEL: I'm not a member of the
           Expert Panel or the Working Group.
                       CHAIRMAN APOSTOLAKIS: I see.
                       MR. LOVELL: Can I mention, Russ Lovell,
           I'm also now a member of the Expert Panel.  I
           originally was the Working Group chairman, now on the
           Expert Panel.  It was my reward for doing things
           right, I guess.
                       MR. SCHINZEL: Any other questions?  Okay.
                       We'll continue with the next slide. From
           a categorization process, our categorization does
           include two areas.  One is the PRA input, the other is
           the deterministic input.  As we start in on each
           individual system, we do review the bases for the PRA
           model for that particular system.  We look at the
           model inputs and the results coming from that model. 
           In addition, for the model components we identify what
           the categorization results from the PRA are for those
           individual components.
                       On the deterministic side  
                       DOCTOR KRESS: Is that based on importance
           measures?
                       MR. SCHINZEL: Yes, it is.  We are going to
           go through that in some detail, as to exactly how we
           determine those.
                       So, here I just want to give a very high-
           level overview of the process, I'll just do that on
           one slide, and then we'll step into the details.
                       On the deterministic side, we do identify
           the functions that are performed by the system, those
           primarily come through our design basis document, also
           with input from our system engineer.  We established
           a risk significance for each one of those functions,
           and that goes through our categorization process,
           asking our five critical questions.  We'll go through
           that in some detail later.
                       DOCTOR BONACA: Just a question with that,
           the deterministic process is to focus only on the core
           damage issues or containment challenges, you do not
           look at the intermediate goals that you have inside
           the FSAR, for example.
                       MR. SCHINZEL: That's correct.
                       DOCTOR BONACA: You don't look at DNB as a
           condition that you want to  
                       MR. SCHINZEL: That's correct, we focus on
           core damage frequency.
                       DOCTOR BONACA: So, your deterministic
           process really is not part of the   FSAR, it just
           still focuses on the same criteria that you meet.
                       MR. SCHINZEL: That is correct.
                       DOCTOR BONACA: All the intermediate
           criteria that were in the FSAR are not of concern
           anymore.
                       MR. SCHINZEL: That's correct.
                       DOCTOR KRESS: Since risk is inherently a
           probabilistic issue, are you going to explain what a
           deterministic risk significance is and how that
           differs from the normal risk significance?
                       MR. SCHINZEL: We will.  I think as we step
           through the presentation we'll try to make that clear.
                       CHAIRMAN APOSTOLAKIS: I think the use of
           the word deterministic is unfortunate here.  It's
           really a non-PRA or a subjective categorization,
           because there's nothing deterministic about it.  I
           mean, you are asking people to categorize things and
           put them in bins, so the word deterministic really
           doesn't belong here.
                       But, it's not obvious what a better word
           is.
                       DOCTOR BONACA: No, but when you read
           deterministic the first thing you do, you say, oh,
           okay  
                       CHAIRMAN APOSTOLAKIS: Subjective is
           better, but I can understand why you would be
           reluctant to use that word.
                       MR. GRANTOM: That's kind of evolved over
           time, where the word deterministic has been used to
           characterize judgment.
                       MR. SCHINZEL: And, I think as we go
           through the process you'll see that there is structure
           to the process.
                       CHAIRMAN APOSTOLAKIS: Sure.
                       MR. SCHINZEL: There's consistency to the
           process, so one thing that we want to ensure that you
           understand is, it's not a group of people, and a
           different set of people coming in at different times,
           throwing in different ideas, different bases for the
           determinations.  
                       CHAIRMAN APOSTOLAKIS: Maybe you can call
           it methodology using structured judgment, because
           that's really what you are doing.
                       MR. SCHINZEL: It is.
                       CHAIRMAN APOSTOLAKIS: It's a structured
           judgment approach.
                       MR. SCHINZEL: It is.
                       CHAIRMAN APOSTOLAKIS: Because
           deterministic is   and deterministic risk
           significance, as Doctor Kress said, is kind of an
           oxymoron, right?
                       MR. SCHINZEL: If you could kindly accept
           our use of deterministic for the focus of this
           presentation, we're going to use it several times.
                       CHAIRMAN APOSTOLAKIS: We are just trying
           to be constructive.
                       MR. SCHINZEL: I understand.
                       DOCTOR BONACA: I think it's substantial
           for a reason, that again the point I made is that a
           member of performance measures, which were the
           original designer of the plant, for certain transients
           of a given frequency, are eliminated, and that's
           really where the whole deterministic process was
           focusing on, was the ANSI standards, the approach to
           categorization, and what kind of performance measure
           you accepted for that.
                       So, there is a history behind that, that's
           why I was confused at the beginning when I was reading
           it over, I jumped into that and I said, well, it's not
           here.
                       MR. SCHINZEL: Once we do identify the
           significance of each function, then we map that
           function to the individual components, and then based
           upon that mapping process a determination is made of
           the significance of each individual component, and
           that's broadly what we do in that portion of the
           determination or the risk significance process.
                       Once we have gone through the PRA and the
           deterministic aspects, then we come up with the final
           categorization for the individual components, and
           that's comparing the categorization for both the PRA
           and the deterministic, and we select the higher of the
           two and we can never have the final categorization
           being less than what the PRA categorization is.
                       In addition, we do identify critical
           attributes.  These are the attributes that have made
           that specific function or that specific component
           important, and then the Working Group, once we
           document the bases for all of our information and
           decisions, then these decisions are presented in draft
           form to an Expert Panel, and the Expert Panel reviews,
           critically assesses the product, and then the Expert
           Panel has the priority of, or the responsibility of
           approving the process before it can be used.
                       CHAIRMAN APOSTOLAKIS: Now, when you say
           based on the higher of PRA and deterministic, do you
           mean for every component that is part of the PRA you
           also did the deterministic risk evaluation?
                       MR. SCHINZEL: That is correct.  Every
           component receives, if it's in the PRA, it also
           receives the deterministic side.  Those that were not
           in the PRA only received the deterministic.
                       CHAIRMAN APOSTOLAKIS: Now, how consistent
           were the rankings according to the PRA and the
           deterministic?
                       MR. SCHINZEL: Generally, they were very
           consistent.  There are times where, based on the
           subjective insight from the panel members, we've
           identified areas where we feel that the categorization
           should be higher, and in those cases we made it
           higher.  In some of those cases, PRA came out with a
           categorization of low, deterministically we felt that
           the categorization should be somewhat higher.  So  
                       DOCTOR POWERS:  That would suggest to me
           that there must be something in the PRA that is not
           reflective of the group's judgment.  Have you tried to
           identify what that is?
                       MR. GRANTOM: I think a lot of the cases
           that happened in there is the fact that the PRA is
           focused on being a power model, and the deterministic
           sets of questions follow things from emergency
           operating procedures, is it necessary for a mode
           change or shutdown safety, and that's part of the
           reason why we asked both deterministic and
           probabilistic, we cover those uncertainties.  Some of
           those differences lie in the answering of those kinds
           of questions.
                       DOCTOR POWERS: So, the improved technology
           in the area of, say, shutdown as an example, could
           obviously help.
                       CHAIRMAN APOSTOLAKIS: Well, what you are
           saying, Rick, is that, perhaps   I mean, the way I
           understand it is that, if I were to do a PRA
           categorization, using importance measures that would
           focus on intermediate goals, as Doctor Bonaca said
           earlier, rather than CDF, let's say on a function,
           then, perhaps, the rankings would not be that
           different, because you said that in the deterministic
           categorization people look at things like, well, in
           addition to shutdown, support of procedures and so on. 
           So, you know, it's a matter of focus.
                       MR. GRANTOM: Exactly, it's a different
           question.  The traditional   of merit that we have
           used have been based on 5046 criteria, ETCS acceptance
           criteria, this is based on a core damaging event,
           that's different.
                       CHAIRMAN APOSTOLAKIS: Yes, sure.
                       So, you brought in some of that old
           thinking through the deterministic categorization.
                       MR. GRANTOM: Right, to handle issues like
           uncertainties and incompleteness, scope issues.
                       CHAIRMAN APOSTOLAKIS: Right.  We'll come
           back to that, yes.
                       MR. SCHINZEL: The next slide shows a very
           broad overview of a flow chart of the categorization,
           and, again, this is a very high level.  It does show
           on the far upper left-hand side our PRA ranking.  The
           model will develop a ranking of either high, medium or
           low, and we'll go through those in some detail as to
           how we developed those.  It does factor in station and
           industry experience separately from the PRA
           categorization.  There is a graded quality assurance
           Working Group categorization, and again, the bullets
           there broadly identify the activities of the Working
           Group to analyze performance data, consider the risk
           ranking, inject the deterministic insight, and then
           develop recommendations regarding the final
           categorization and those programmatic controls that
           would be placed over those components.
                       Then, coming from the Working Group, there
           is a documented, what we call a risk significance
           basis document, which documents the judgments and
           results from the working group. That documented bases
           is then sent to an Expert Panel.  The Expert Panel
           reviews these inputs, considers the risk
           categorizations recommended, and injects their own
           deterministic insights into the process.
                       Upon approval, then those changes to the
           processes are available to be inputted into the
           station, and we do have an ongoing feedback loop that
           feeds back into both the PRA and the deterministic
           insights of the Working Group for potential changes to
           either the PRA model or the Working Group's inputs and
           following categorizations.
                       So, that was, basically, the high-level
           overview.  We'll start into  
                       MR. SIEBER: Maybe I can ask a question.
                       MR. SCHINZEL: Certainly.
                       MR. SIEBER: Overall, you've deal with or
           categorized something like 42,000 components, how many
           of those actually appears specifically in your PRA?
                       MR. SCHINZEL: We have a total of
           approximately 1,200 components that are in the PRA. 
           Now those, for the systems that have been categorized
           to date, 886 of those model components are included in
           those categorized systems.  So, it's roughly 3/4s.
                       MR. SIEBER: And, what process do you go
           through to gather the 39 out of 40 that don't appear
           in the PRA into the categorization process?  Just go
           through your Q list?
                       MR. GRANTOM: That's what we are going to
           cover here in just a second, just go through how we
           handle those components that are included within the
           scope of the PRA.
                       MR. SIEBER: Okay.
                       MR. GRANTOM: And then, that's in several
           of the slides in here, so we'll be able to address
           your question.
                       DOCTOR KRESS: Your categorization from the
           PSA is based on importance measures, do you have a  
           what was your criteria on which   where to draw the
           lines between high, medium, low and none?
                       MR. SCHINZEL: We are going to have a
           specific slide that goes through that, as far as where
           those thresholds are.
                       DOCTOR KRESS: Okay.
                       MR. SCHINZEL: So, as far as the next page,
           the categorization controls, again, just broadly,
           generally, the industry views this as an integrated
           decision-making process.  We call that our Expert
           Panel and Working Group.  These are made up of
           experienced, qualified personnel.  There is specific
           training that we have identified for these personnel. 
           There's a designation of experience that we want these
           members to have.
                       The membership is diverse.  We have people
           from our maintenance organization, licensing
           organization, operating experience from our PRA group,
           operations, a broad background, a broad insight that's
           brought to the table, and then we ensure from a
           decision-making standpoint that we do use consensus
           decision-making.  If we have one member who feels that
           he can't support the final recommendation or judgment,
           we do have the ability, it's procedurally allowed, to
           document a differing opinion, and that differing
           opinion is then taken up to a more senior panel, and
           that more senior panel then hears the pros and the
           cons and makes a judgment on what the final
           categorization or what the resolution for that issue
           should be.
                       Like I said, the process is procedurally
           controlled.  There is a Working Group procedure and
           there's a separate procedure for the Expert Panel, and
           we do categorize our components into one of four
           categories.  We have the high safety significant,
           medium safety significant, low safety significant and
           not risk significant.  And, that traditionally follows
           a four box approach that the NRC staff and the
           industry is currently looking at.
                       That takes us into the specifics of the
           PRA categorization approach, and we'll get into some
           of the details specifically with the PRA.  The PRA
           risk ranking process is procedurally controlled. 
           There are several procedures that give insights as to
           how we do that categorization.  The PRA model at South
           Texas, it is a full scope model quantification that
           includes at-power Level 1 and Level 2, with both
           external events and internal floods and fires.  I
           mentioned that we modeled roughly 1,200 components,
           that's on a per unit basis, so with both units that's
           2,400 components.
                       DOCTOR KRESS: When you say it includes
           fires, do you have a PRA that has fire initiating
           frequencies and models that carry that to core damage
           frequency?
                       MR. GRANTOM: We do have a fire PRA.
                       DOCTOR KRESS: You have a fire PRA.
                       MR. GRANTOM: A fire PRA, and we do have an
           internal flooding PRA.
                       DOCTOR POWERS: The fire PRA handles all
           areas of the plant, it doesn't look at only a subset
           of fire regions.
                       MR. GRANTOM: All areas.
                       DOCTOR POWERS: Nothing is screened out.
                       MR. GRANTOM: Yes, there are things that
           screen out, yes.
                       DOCTOR BONACA: You said your PRA model is
           about 1,200 SSCs, and there was a question before, I
           didn't get the answer I guess, but when I look at this
           breakdown I see that probably roughly 40,000
           components are addressed insofar as the separation, so
           that's   but only 1,200 of those are really modeled
           in the PRA.
                       MR. SCHINZEL: Yes.  We've had   you know,
           on that slide it shows roughly 44,000 or so that have
           bene categorized.
                       DOCTOR BONACA: Something like that.
                       MR. SCHINZEL: Out of 29 systems.
                       Now, of those we've mentioned that there's
           1,200 that's included in the PRA, but only 886 of
           those are included in these 29 systems that have been
           categorized.  So, roughly, 3/4s of the modeled PRA
           components are included in what we've categorized
           already.
                       MR. LOVELL: Basically, what happens when
           we get to doing the deterministic side of it  
                       DOCTOR BONACA: Yes.
                       MR. LOVELL:    is we do it by system, and
           we take a list of all of the components that are
           listed in our total plant numbering system, and that's
           then the group that we do the deterministic ranking
           on.  That's why it's a much larger size.
                       DOCTOR BONACA: You take categories, okay,
           that's what I wanted to clear up.
                       MR. LOVELL: You take the whole system,
           like, for instance, safety injection, we take
           everything that's listed in their total plant
           numbering system, and then rank it from there.
                       DOCTOR BONACA: Okay, so also   okay.
                       MR. SCHINZEL: For example, the safety
           injection system might have 3,000 tagged components. 
           There may be 50 of those that are included in the PRA.
                       DOCTOR BONACA: Yes, I understand.
                       MR. SCHINZEL: But, we'll categorize every
           one of the components, and we do that for each system
           as we go through the categorization process.
                       CHAIRMAN APOSTOLAKIS: But, at some level
           all of these are in the PRA, because I can go higher
           and find the component or a subsystem which is in the
           PRA.  Now, below that you may have a number of
           components that do not appear explicitly in the PRA,
           correct?  Because if the function of the system
           appears in the PRA, it depends how far down you go.
                       MR. SCHINZEL: That's true, however, there
           are a lot of components in the system that are
           associated with maintenance functions, or testing
           functions, or maybe just monitoring functions, that
           would have the system tag number would be pulled into
           the categorization process, but they don't play a role
           directly in the actual safety significant function of
           the system.
                       So, when we talk about we look at all the
           functions, we are really talking about we are looking
           at all the functions a system does, everything from
           draining the system, to venting the system, to
           monitoring the system, all of those things represent
           a function that are categorized or risk ranked by the
            
                       CHAIRMAN APOSTOLAKIS: But, the function
           itself must be in the PRA someplace.
                       MR. SCHINZEL: Yes.
                       CHAIRMAN APOSTOLAKIS: Maintenance, for
           example.
                       Now, you are saying there are lots of
           things that we do in the course of maintenance that do
           not appear explicitly in the PRA, but maintenance
           itself does.
                       MR. SCHINZEL: Yes.
                       CHAIRMAN APOSTOLAKIS: That's important for
           later.
                       MR. SCHINZEL: Maintenance is in there,
           both planned and unplanned.
                       CHAIRMAN APOSTOLAKIS: Yes, right.
                       DOCTOR BONACA: The reason why I was asking
           that question is that you have in one of the documents
           we reviewed you have three tables, where you have
           general categories.  For example, category one, vent,
           drains, test valves, one inch or less in size, no risk
           significant, that captures a significant population of
           valves.
                       MR. SCHINZEL: Correct.
                       DOCTOR BONACA: Each one of those is part
           of the 44,000.
                       MR. SCHINZEL: Correct.
                       DOCTOR BONACA: Okay.  I'm trying to
           understand it because otherwise I confuse system level
           versus component level.
                       These categories here must capture a very
           large fraction of the component that you have.
                       MR. CHACKAL: Just to clarify, the 43,000
           number is for both units.  The PRA numbers that we
           mentioned earlier, 1,200, and 886, are on a per unit
           basis.
                       CHAIRMAN APOSTOLAKIS: Per unit, so per
           unit we are talking roughly about 20,000.
                       MR. CHACKAL: Right.
                       CHAIRMAN APOSTOLAKIS: That's important.
                       How long did it take you to do this,
           40,000 components?
                       MR. SCHINZEL: We started with the
           categorization process in the second quarter of '98,
           and by the time we got to the latter part of '99 we,
           essentially, had finished with the categorization of
           these 29 systems, and we've been focused on our
           exemption request and trying to get it completed prior
           to moving forward with additional systems. So, it was
           about 18 to 20 months.
                       MR. LOVELL: One of the things that helps
           on that is, you have those large number of components,
           but we are a three train plant, so like for safety
           injection, by doing   reviewing one train you covered
           all three trains in both units, so that helped us
           quite a bit in the numbers.
                       CHAIRMAN APOSTOLAKIS: There's a certain
           symmetry to it.
                       MR. LOVELL: Right.
                       And, I also point out, both units we've
           kept them very close to identical.  The major
           difference between the two units right now is we
           replaced steam generators in unit one and are getting
           ready to replace steam generators in unit two.  Other
           than that, the difference between the units are very
           small.
                       DOCTOR BONACA: At some point during the
           presentation, I would appreciate an explanation of how
           you can eliminate the full class of components based
           on a genetic statement.  Okay, I'm sure you have some
           logic for that, it would be interesting to see how you
           do that, okay, and you'll know the time in the
           presentation when it's best to do that.
                       MR. SCHINZEL: Okay, we'll do that.
                       With the PRA categorization, the fourth
           bullet, the PRA model is periodically updated.  It is
           considered a living document, and this will reflect
           changes in performance of individual components and/or
           changes in Station design, whether there's been
           modifications that have been installed, or the way or
           manner in which we operate the plant.
                       CHAIRMAN APOSTOLAKIS: When was your PRA
           completed?
                       MR. GRANTOM: The original   we started
           the PRA study at STP in 1982, and we completed the
           initial phases of the PRA in the middle '80s.  '87 we
           had our final PRA completed, and ever since that time
           the PRA has undergone just a periodic care and feeding
           type of stuff.  We've used it for application since
           then, but that's about the time frame that we started.
                       CHAIRMAN APOSTOLAKIS: So, how many times
           have you updated, or is it difficult to say this was
           an update?  I mean, does it happen in a continuous
           manner, or as necessary, or every 18 months?
                       MR. GRANTOM: It used to happen   when we
           weren't controlled and proceduralized, it used to
           happen almost continually.  We found that we really
           have administrative problems in doing that when you
           are dealing with an operating station, so now we
           proceduralize the update process to where it's a
           controlled roll-out periodically, every 18 months we
           have a controlled roll-out, and we'll have a statement
           in there of what the scope of a particular update is. 
           You know, we can't physically update everything that's
           in the PRA.  We don't update the human performance
           analysis every time, but we'll have a scope statement. 
           At a minimum, we update performance, design and
           procedure changes.  So, that's the way that the
           process works.
                       DOCTOR BONACA: In between the 18 months,
           do you perform a PRA significant determination of each
           change that you have not reflected in the PRA yet?
                       MR. GRANTOM: Yes.  We have a configuration
           control process with a database that reads the drawing
           database, the procedure database.
                       DOCTOR BONACA: Okay, so you do that.
                       MR. GRANTOM: As a matter of fact, that's
           a performance indicator for the PRA group, is how well
           they keep up with their reviews.
                       MR. SCHINZEL: The next bullet is going to
           get us into the PRA categorization.  We do base it on
           importance measures of Fussel-Vesely and RAW, risk
           achievement worth and Fussel-Vesely, and the next
           slide will show the details.  And, I'll let either
           Rick or Allen step through the categorization itself.
                       MR. MOLDENHAUER: Basically, this
           categorization process that we have here was agreed to
           with the staff for the GQASER back in '98, I believe
           was the date, and what we base it on is both the risk
           achievement work and the Fussel-Vesely values.  As you
           can here, the criteria we have for high, and then
           there's the medium, what we call medium R, or needing
           further additional review, which, basically, says to
           the Working Group that the critical attributes, or the
           attributes modeled in the PRA, should have full
           quality QA programs associated with them.
                       And then we have another group, medium,
           and then the final group of low.
                       DOCTOR KRESS: Is there some reason why
           these numbers are appropriate for RAW or Fussel-
           Vesely?
                       MR. MOLDENHAUER: What we have found is
           that these numbers match up real well with the
           deterministic aspect of it, and we feel comfortable
           with these thresholds as our current PRA
           categorization process.
                       DOCTOR KRESS: I had in mind more like
           something like, if you fall into the high category,
           does this RAW or Fussel-Vesely translate into a
           certain contribution of that set of components to the
           CDF?
                       MR. GRANTOM: The values that we have in
           here originated for us back when we had the document
           of the EPRI PSA Applications Guide, and these values
           were listed in there.
                       There is a correlation.  We have a cap on
           the RAW and the Fussel-Veselys, and you can see that
           the RAW are greater than 100, anything that would
           change core damage frequency, in and of itself, by two
           orders of magnitude is considered a high component. 
           And, RAW looks at the avail   the importance of the
           availability of the component, where Fussel-Vesely is
           a little bit more aligned with the reliability of it.
                       So, and then we have a combination of the
           two.  The RAW values of a doubling of CDF has been
           pretty much a standard that has been carried through
           the PSA Applications Guide, I think even before that,
           as some measure of significance.  So, we've started at
           that point, and through the negotiations with the
           staff there was a concern that components that may not
           necessarily show up in the results of the PRA, because
           they are so highly reliable, but when removed from
           service could have a big impact.  So, that's why you
           see the cap of a risk achievement worth of 100, so
           that we don't   we wouldn't reduce controls on a
           component strictly because of its reliability as being
           so good.
                       CHAIRMAN APOSTOLAKIS: What is the core
           damage frequency now for South Texas?
                       MR. MOLDENHAUER: It is approximately 1E to
           the minus 5, it's a little above that, 1.174, I
           believe.
                       DOCTOR KRESS: If your core damage
           frequency were considerably higher than that, would
           you still use these same RAW values and Fussel-Vesely
           values?
                       MR. GRANTOM: Well, that's kind of an
           issue, the RAWs and the Fussel-Veselys are going to be
           relative.  If you have a ten to the minus two core
           damage frequency, you'd still end up with numbers like
           this.
                       CHAIRMAN APOSTOLAKIS: As a matter of fact,
           you know, what we can do, just to play a game, we can
           put a system in series with everything else you have
           now, that fails with a frequency of ten to the minus
             or five ten to the minus four per year, then the
           whole categorization is thrown out of the window
           because you cannot increase the core damage frequency
           by a factor of 100 by failing any one of the other
           components, because you have this big one now there
           which controls the core damage frequency, which is a
           good example of what you just said, that the absolute
           value of the core damage frequency   really doesn't
           enter into this.  It's a very relative thing.
                       MR. GRANTOM: Well, in your example I'd say
           you probably need to go back and look at the PRA.
                       CHAIRMAN APOSTOLAKIS: You are violating
           the goals that way.
                       MR. GRANTOM: Yes, but it is, you have to
           depend on the fact that we have a robust PRA, it's a
           PRA that's been reviewed, both internally and
           externally, and we have confidence that the model has
           a good degree of fidelity and robustness that's
           associated with it. It's been proven over time.
                       So, but your concern is valid, these are
           relative importance measures, and risk ranking
           methodology and importance measures are going to, I
           feel, continue to evolve and we have to be ready to
           evolve with that.  I think that's a good point.
                       CHAIRMAN APOSTOLAKIS: And, to take the
           other extreme, what if you have a unit that has a ten
           to the minus seven?
                       DOCTOR KRESS: They are unfairly penalized
           in a sense.
                       CHAIRMAN APOSTOLAKIS: You are penalizing
           them.
                       DOCTOR KRESS: Yes.
                       CHAIRMAN APOSTOLAKIS: Because it would
           still have  
                       DOCTOR KRESS: It works both ways, yes.
                       MR. GRANTOM: It does, and with South Texas
           we'd say we might be penalizing ourselves in a sense
           with the investment of a third train having lower core
           damage frequency numbers, but these are relative so we
           are still treating these as important.
                       DOCTOR KRESS: Well, that's why I brought
           the whole question up.
                       DOCTOR POWERS: I am hardly expert in this,
           but my recollection is that these numbers are, risk
           achievement worth and risk reduction worth, are
           achieved by looking at the components only one at a
           time, and we don't look at the possibility that one
           component is degraded and the other one is either
           completely efficient or completely inefficient.
                       DOCTOR KRESS: Other than where we factor
           in common cause, that's true.
                       MR. MOLDENHAUER: Well, we did do a
           sensitivity study where we increased the failure rates
           for all the low risk significant components by a
           factor of ten, to see what the impact would be on core
           damage frequency and whether the components would
           change classification from low to either medium or
           high.
                       MR. GRANTOM: It might be interesting to,
           when we get to the slide on the sensitivity studies,
           to get the committee's feelings and thoughts about
           that, because just like Mr. Powers question, we tried
           to answer that, we just don't look at the PRA and take
           the average PRA and here's the risk, the RAWs and the
           Fussel-Veselys and that's it, we go through a whole
           series of sensitivity studies to manipulate the model,
           to see what the sensitivities are.
                       So, when we get to that, maybe we can talk
           about some of the other   there might be some other
           questions that come up relative to things like that.
                       DOCTOR BONACA: Before you move away from
           this ranking, in the papers we got there is a
           description of how in some cases you may have a high
           safety significant system and components that make up
           the system, for example, the trains, be redundant, may
           be classified at a lower safety significant level.  I
           would like to see how you go through that process.
                       MR. GRANTOM: Okay.
                       CHAIRMAN APOSTOLAKIS: That's in the
           deterministic part, right?
                       DOCTOR BONACA: Is it?
                       CHAIRMAN APOSTOLAKIS: Yes, right.
                       DOCTOR BONACA: Okay, so for the
           probabilistic you have   all right.
                       CHAIRMAN APOSTOLAKIS: The documents other
           than those from STP really don't go into full
           categories, right?  They consider only two, I believe,
           high risk significance and low.
                       MR. GRANTOM: Right.
                       CHAIRMAN APOSTOLAKIS: And, they are all
           greater than two and Fussel-Vesely greater than .005
           puts you in the high category and anything else, I
           think, puts you in the low.  Something like that.
                       MR. GRANTOM: Something like that, yes.
                       CHAIRMAN APOSTOLAKIS: Now, what is the
           benefit of having a more detailed categorization
           scheme, have you thought about that?  I mean, do you
           really gain much by going through this, or a simple
           up/down scheme is good enough?
                       MR GRANTOM: Well, I think there's a
           benefit to the medium category.  I think it's an
           important aspect that through the process of updating
           a PRA, or in the event that you find an error, that
           you don't have mass migrations of equipment from low
           to high, and you need some intermediate buffer that
           keeps components treated very close to what you are
           already doing for the high component, so that if you
           do have some movement the impact isn't nearly as great
           to the Station, the impact is not nearly as great to
           the requantified analysis.
                       However, with the way that the exemption
           request works, you know, low and non-risk significant
           components, through,  just hypothetically speaking,
           some error were to show that one of those should be
           high, then you have a whole list of issues that could
           be concerning you then on how that component was
           treated, how you had recertified and reverified that
           component.
                       So, I feel that medium is an important
           buffer to have, and high and medium corresponds to
           what the staff has put, they call it the risk one box,
           that's basically where we have it, and low and NRS
           would be box three.
                       CHAIRMAN APOSTOLAKIS: Where is the no risk
           significant category?  I thought you had one like
           that.
                       MR. SCHINZEL: We do have one for the
           deterministic only, not for the PRA, and for the
           deterministic that, essentially, identifies where, you
           know, the risk overall is so low that we call it non-
           risk significant.  And, we'll go through the
           thresholds that we use in that also.
                       CHAIRMAN APOSTOLAKIS: So, you have two
           medium categories, give an example of this medium R,
           this is the focused thing?
                       MR. GRANTOM: Right, there was still a
           concern that even a component that would change the
           core damage frequency by an order of magnitude, by the
           fact that it was out of service, was still a concern
           and we might need to look at the reliability level. 
           Is it because it's just reliable, or what are the
           other reasons?  And, some of these components, I mean,
           components that get high risk achievement worth are
           sometimes very reliable components.  They can be
           passive, like a locked open manual valve that
           basically is a piece of the pipe, or it can be
           something very important like a solid state protection
           system, which are extremely reliable systems, and,
           therefore, in core damage scenarios they don't show up
           very often because they are very reliable.
                       You have this classic category here where
           the risk achievement could be, you know, greater than
           ten, but it's really less than 100, so we ought to
           look at those more.  And so, it was just to make
           certain that you don't classify things without some
           scrutiny associated with those things that fall in the
           middle here.
                       DOCTOR KRESS: Do you have an example of
           one?
                       MR. MOLDENHAUER: The only example I can
           think off my head is a locked open manual valve that
           we've modeled as transfer and close during the mission
           time, and there's probably one maybe in the auxiliary
           feed water system would be ranked medium R.
                       DOCTOR KRESS: I'd like to return a minute
           to Doctor Powers' question.  If you have a component
           that has, say, a low risk significance coming out of
           the PRA, based on these RAW and Fussel-Vesely values,
           but you actually have 100 of those components in
           separate systems, and if the failure of the components
           are by chance, which is sort of the way we deal with
           them in PRA, then shouldn't those Fussel-Veselys and
           RAWs be multiplied by 100?
                       MR. GRANTOM: The sensitivity studies that
           we do, and the ones that we've done, is we've taken
           those ones that fall into the low and have increased
           their failure rates by an order of magnitude in total,
           to see what the impact on core damage frequency does,
           and, of course, the impact increases core damage
           frequency, but it's still within the guidelines of Reg
           Guide 1174.
                       DOCTOR KRESS: Yes, well, that's the nature
           of sensitivity studies, but I'm trying to come up with
           a philosophical logical basis for how to deal with
           multiple components, rather than one at a time.
                       MR. GRANTOM: Well, there's a common cause
           aspect that we deal with, and common cause is
           explicitly   common cause basic events have their own
            
                       DOCTOR KRESS: Yes, but even say there were
           no common cause failures at all, the probability of
           one of those things failure is the probability of one
           failure times the number of them that are there.
                       DOCTOR SHACK: But still, I mean, your
           ultimate goal is the delta CDF, and as long as that
           remains small in total, that's truly the real check on
           this.  This is only a way to get you to some
           categorization, but the ultimate check is when you
           look at the delta CDF, it better be small in toto.
                       CHAIRMAN APOSTOLAKIS: Yes, we'll come back
           to that two slides later, when they talk about
           sensitivity studies, because that's an important
           point.
                       MR. GRANTOM: Yes.
                       CHAIRMAN APOSTOLAKIS: So, the main message
           here is that these threshold values are sort of
           reasonable, that there is no really technical basis
           behind it, I mean, they just turned out to be
           reasonably in agreement with what people would expect
           to see.
                       MR. GRANTOM: Yes, and this is something we
           worked out with the staff to be reasonable.
                       CHAIRMAN APOSTOLAKIS: Yes, okay.
                       MR. SCHINZEL: The next slide gets into the
           approach to common cause.  I know that there was a
           question about this when we met with the committee
           back in December.  What we've evolved to here, that
           STP will use the conservative common cause approach
           that was approved in graded quality assurance.
                       Now, with that we recognize that there are
           some potentials for improvement, so we also recognize
           that his is a conservative approach, and from the
           standpoint of the application for this time it's
           probably going to be the right approach for us.
                       The approach that we're using does sum the
           Fussel-Vesely RAW importance measures for all the
           causes of basic event failures.  The final component
           Fussel-Vesely RAW importance includes the total common
           cause contribution and the different failure modes.
                       CHAIRMAN APOSTOLAKIS: Well, I guess, is
           the staff going to get into more detail on the issue
           of common cause failures?
                       UNIDENTIFIED SPEAKER: I don't know that
           we'll go into more detail.
                       MR. LEE: We are prepared to discuss, in a
           little more detail, as to the issue that you had
           raised in the last meeting, and how we came to a
           resolution of that, yes.
                       CHAIRMAN APOSTOLAKIS: Right.
                       Now, if we have, let's say, a three train
           system, okay, and you have the pump.  You have three
           pumps, you will have the random failures plus the
           common cause contribution.
                       For Fussel-Vesely, I guess it's okay to
           add them up, because it's added, it's just all the
           minimal cut sets that contain the component, so it's
           okay.
                       For RAW, though, I'm not so sure we can do
           that, and, in fact, don't you say somewhere in your
           letters of January that for RAW you did something
           else?  You said that, in Attachment 1 to your letter
           dated January 15, 2001, from Mr. Rosen to the NRC,
           open item 3.1, you say you are doing something else
           with RAW.  "It has been determined that the PRA risk
           ranking incorrectly adds risk achievement worths
           across differing failure modes.  Rather, the proper
           approach considers the role for the component to be
           equal to the highest component failure mode and not
           the sum of the failure modes."  This would appear to
           be inconsistent with your slide.
                       MR. MOLDENHAUER: Yes, we have gone back to
           the original, what we'd said in the graded QA SER, in
           that where we were going to sum them all up, instead
           of doing the approach, and I think we've probably
           resubmitted that, haven't we, Glen, that we were going
           to  
                       MR. SCHINZEL: Yes, that has been
           resubmitted.  We had this as our original response to
           open item 3.1.  The letter dated January 18,
           Attachment 6, includes a revised open item response to
           3.1, and in that  
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. SCHINZEL:    our response coincides
           with what we have on our slide.
                       CHAIRMAN APOSTOLAKIS: So, let me
           understand now, there are two letters here, one is
           dated January 15th, and the other three days later,
           January 18th.  In the January 15th, the first letter,
           there is an attachment that says that what you did
           with RAW was not proper, and that you will change it. 
           But, three days later you say, let's go back to what
           we did with it in the GQA and be done with it.  Where
           does that leave the advisory committee?  Which one is
           right?
                       MR. GRANTOM: The one that we've chosen, as
           far as the way we did it in the graded QA is generally
           acknowledged as being a conservative approach.
                       CHAIRMAN APOSTOLAKIS: But, RAW, it cannot
           be added.  You can't do that, I mean, as you yourself
           submit.
                       MR. GRANTOM: Right, we are not   we are
           trying to categorize equipment into groups, and we're
           not trying to make an accurate calculation of common
           cause contribution.
                       We recognize that there are better ways to
           do this, and certainly want to pursue solving this in
           the correct manner, but the constraints associated
           with getting the exemption request approved preclude
           us going to a totally new approach and the reviews
           associated with that.
                       So, we elected to go and maintain the
           conservative aspects of this.
                       CHAIRMAN APOSTOLAKIS: But, Rick, these are
           your words, "STPNOC will revert back to the recognized
           conservative approach for PRA risk rankings from the
           GQA SER, with one exception as stated below."  These
           are your words.  And, the exception refers to RAW.
                       But then, three days later you come back
           and say forget about it, it's okay, because I think
           you are right in the January 15th letter, you are
           right, I mean, that's what you say, and if you have
           three failure modes you go with the highest, which is
           the correct way of doing it, because RAW assumes other
           component is down.
                       Now, I don't know what happened to the
           GQA, did you do that?  Maybe that should be a question
           to the staff.
                       MR. SCHINZEL: I agree.
                       CHAIRMAN APOSTOLAKIS: Not right now, but
           you'll have time later.
                       So, what you have on the slide there is
           inconsistent with your January 15th letter, but it is
           consistent with the January 18th letter, which is all
           right.
                       MR. SCHINZEL: Yes, based on  
                       CHAIRMAN APOSTOLAKIS: Consistent with the
           latest.
                       MR. SCHINZEL:    upon receipt of our
           January 15 letter, the staff and South Texas did have
           some discussions, some phone conversations, and based
           on those phone conversations the decision was made
           that we would revert back to our graded quality
           assurance approach.  And so, that predicated the
           revision to that open item response, and our follow-up
           letter of January 18.
                       CHAIRMAN APOSTOLAKIS: Let me tell you what
           my overall feeling is about all this.  I think the
           methodology, and we'll come to aspects of it as we
           review it, I think the methodology could be improved
           in several areas, and some things, perhaps, as you
           say, are improper and so on.
                       The problem I'm having is that I'm not
           sure that if one did it correctly one would find a
           very different categorization than you guys came up
           with.  So, it is all well that ends well.  That's a
           problem I'm having, and if this was a routine
           application maybe I wouldn't care that much, but this
           is setting a precedent.  There will be some rulemaking
           in the near future, and so on, and so if it worked
           here why not put it in the rule.  Well then, I'm going
           to really object.
                       But, the importance measures   it really
             I don't think   and it's not because you don't
           know, I mean these things are as a community, now we
           are scrutinizing them more because they are becoming
           so important.  So, I'm not blaming you guys, I mean,
           you did the best you could do with the available
           methods.  But, the truth of the matter is that a lot
           of this stuff really could be improved and in some
           ways it is really wrong.
                       But, the ultimate result still remains,
           and I have another case where this happened, I mean,
           where Sandia did 1150, first time around they were
           criticized that they didn't use formal methods for
           expert opinion elicitation, and then they went back
           and did it, spent a lot of dollars, and what was the
           result, the same as before.
                       MR. GRANTOM: Doctor Apostolakis, I would
           agree with you that risk ranking methodologies can
           improve.  We were the first out of the box to go and
           do this stuff, and this is an important lesson learned
           and, hopefully, we can continue to work with the staff
           to improve the methodologies because there are some
           things that are out there that we would like to do,
           possibly, you know, at a formal professional or
           institutional conference somewhere, to say here's the
           difference between these two methods here, and we'd
           like to do that, but we are trying to get an exemption
           request approved also.
                       CHAIRMAN APOSTOLAKIS: Now, another thing
           I don't understand, Rick, is, if you get your request
           approved, why would you continue to work with the
           industry to start to improve risk ranking methods?
                       MR. GRANTOM: Because we agree with you,
           they need to be improved.
                       CHAIRMAN APOSTOLAKIS: It was a glory of
           science.
                       MR. GRANTOM: It is for getting the right
           answer.
                       MR. SCHINZEL: Yes, it's really driving
           toward the right answer.   We recognize that what we
           have is overly conservative, and in the process of
           discussing this with the staff it was recognized that
           in the PRA community there's not final agreement on
           what the right answer is.
                       And, we can turn this into a research
           project right now, but it's not the right time for
           South Texas to have this turned into a research
           project.  So, from that perspective, we go back to a
           very conservative approach, which is recognized to be
           conservative, but at the same time we are not
           satisfied with where we are with this resolution.  So,
           we want to continue to work with industry and staff,
           come up with a community position on what the right
           thing to do is.
                       CHAIRMAN APOSTOLAKIS: I think it's not
           really a matter of the final results changing that
           much, it's a matter of confidence.  It's really a
           matter of confidence that we know what we are doing,
           and Doctor Wallace is not here to tell us how it's
           important to keep the technical communities on our
           side.
                       Shall we go to the next slide?
                       DOCTOR POWERS: He completely wore himself
           out yesterday.
                       CHAIRMAN APOSTOLAKIS: I'm sorry?
                       DOCTOR POWERS: He completely wore himself
           out yesterday making that point.
                       MR. SCHINZEL: You mentioned that you
           didn't think that the results would change that much,
           and I think I'm correct in saying that going to this
           alternate approach that we had in our January 15
           letter, there were only a total of 46 components that
           ended up changing their categorization.
                       CHAIRMAN APOSTOLAKIS: But, they did
           change.
                       MR. SCHINZEL: They did change.
                       CHAIRMAN APOSTOLAKIS: But, you see, that's
           an interesting question now.  I mean, if they changed
           because we changed the way you calculate RAW, why
           didn't the Expert Panel catch that before you
           recalculated it?  We seem to be placing a lot of
           confidence and trust in the Expert Panel, they are
           always conservative, they would move things up in the
           categories, and here are 46 components where you did
           something new with RAW, and the Expert Panel said not
           to change it.
                       MR. MOLDENHAUER: For the most part, the
           Working Group and the Expert Panel did catch that. 
           They were deterministically ranked higher, there was
           only 12 of them that we had to actually go back and
           reclassify.
                       CHAIRMAN APOSTOLAKIS: So, only 12 instead
           of 46.
                       MR. SCHINZEL: Well, we had 46 that
           changed, but that was out of the PRA. 
           Deterministically, all by just a handful had already
           deterministically been shown with a different
           categorization.
                       MR. MOLDENHAUER: And, they went from the
           rank of medium to high, so they were still not  
                       MR. GRANTOM: That's why it's important to
           have a buffer.
                       CHAIRMAN APOSTOLAKIS: So, you are already
           doing something.
                       Well, that's a good point.  So, shall we
           move on to the sensitivity study?
                       MR. SCHINZEL: With the sensitivity
           studies, and I'll let Allen step through some of the
           details here, we do have 21 sensitivity studies that
           are currently in use in the South Texas PRA model.  We
           give on this slide some of the sensitivity studies
           that are in use, and, Allen, I'll just let you talk
           through what you want to focus on, and we can step
           through some of these in more detail if the committee
           needs us to.
                       MR. MOLDENHAUER: I'd like to put up a
           slide here that was part of the additional handouts. 
           And, this is how we categorized the PSAs.  On the
           left-hand side are the component tag numbers, our
           total plant numbering system, to identify them, and
           then we had each of the sensitivity studies here going
           across and some of   the first set of sensitivities
           here are planned maintenance, and that where we are
           looking at, if you are in this planned maintenance
           state, if you have a central cooling water train out
           of service what is the effect of the other components
           that are still in service?  Do their risk rankings go
           up?
                       And, there's 13 of them, of the planned
           maintenance ones.  The last three, PM1, PM2, PM3, deal
           specifically with no planned maintenance activities. 
           And then, the GN1 through 10 deal with different
           maintenance activities that will be occurring on our
           12-week rolling maintenance site for planned
           maintenance.  Then the next set here is the increased
           failure rates. When we initially did it, we went and
           we looked at increasing the failure rates by a factor
           of two, five and ten, to see if there was any
           differences.  The next one, NCC, is the removal of
           common cause, we wanted to see what the component risk
           ranking would be if we didn't have common cause in the
           model.  REC is for removal of any operator recovery
           actions, to see just what the independent failures
           themselves, without the ability of the operators to
           mitigate the accident, what the impact would be.  STP
           here is the average core damage frequency model.  The
           LER is a sensitivity study on the large early release,
           where we decrease the frequency of steam generator
           tube rupture, so that we can see the effect of
           components, because steam generator tube rupture
           dominates our large early release and there aren't
           very many components that can mitigate it after that. 
           The STP L2 is the large early release rankings, and
           then we had a composite ranking out of these, and then
           we did a final category   excuse me, the final
           ranking is based off of looking at and making sure we
           are getting consistent results between the trains.
                       CHAIRMAN APOSTOLAKIS: This business of
           multiplying the failure rates by two, five and ten,
           now if I   let's take again the three train system,
           the failure rate of a pump will appear in many terms,
           but the two terms that are of importance are the
           random failure of the three pumps, so it would be Q3
           typically over one by other terms, and then a common
           cause term that will be Q times beta, times gamma in
           the multiple Greek letter method.
                       When you multiply the failure rate by ten,
           do you multiply it everywhere where Q appears,
           including the common cause term?
                       MR. MOLDENHAUER: We did include it in the
           common cause, but we didn't increase the failure rates
           of the beta and the gamma factors.
                       CHAIRMAN APOSTOLAKIS: No, but in Q?
                       MR. MOLDENHAUER: But, we did in the Q.
                       CHAIRMAN APOSTOLAKIS: So, the common cause
           term goes up by a factor of ten as well?
                       MR. MOLDENHAUER: Yes.
                       CHAIRMAN APOSTOLAKIS: I thought Rick told
           us last time you didn't do that in December.
                       MR. GRANTOM: I don't recall that, Doctor
           Apostolakis, so if I did I might have misspoke.
                       DOCTOR SHACK: You might have been talking
           about the betas.
                       MR. GRANTOM: Yes.
                       CHAIRMAN APOSTOLAKIS: No, the beta cannot
           be multiplied by ten, because it becomes one.  The Q
           itself, because if you did that, then Doctor Shack is
           right, that what do I care?  I mean, if the total is
           delta CDF is negligible it's okay, but if you didn't
           do that then that argument is not valid, because you
           are increasing selectively terms.  So, this is a key
           question, because Q appears in a number   I mean, it
           also appears in the maintenance terms, right?
                       MR. MOLDENHAUER: Yes.
                       CHAIRMAN APOSTOLAKIS: That one pump is
           down, the other  
                       DOCTOR SHACK: I'd say assuming the failure
           rate goes up by a factor of ten, it's a fairly
           conservative assumption.
                       CHAIRMAN APOSTOLAKIS: But, you see, that's
           what bothers me about these things, when we increase
           it by ten and we find out the number is acceptable,
           then we are all happy.  If it not acceptable then we
           say, well, gee, a factor of ten is really too high. 
           Well, I'm sorry, either you go with ten or you don't. 
           Okay?  And, if it turns out to be unacceptable, then
           don't come back and say, well, gee, it was too much.
                       MR. GRANTOM: Well, I appreciate Allen
           being here to correct anything that might have
           happened in the previous meeting, but that's why we do
           these series of sensitivity studies, to see what
           happens when you increase things by a factor of ten
           across the board.
                       CHAIRMAN APOSTOLAKIS: So, you actually
           included the common cause terms in increasing by a
           factor of ten?
                       MR. MOLDENHAUER: Yes, we did.
                       CHAIRMAN APOSTOLAKIS: Well then, you are
           right.
                       DOCTOR POWERS: Could you remind me  
                       CHAIRMAN APOSTOLAKIS: If that's the case,
           then it doesn't matter.
                       DOCTOR POWERS:    could you remind me
           what T stands for in this table?
                       MR. MOLDENHAUER: Oh, T is for truncated. 
           Those are components that fall outside of the PRA that
           we didn't get any results from.  They were modeled,
           but there were no   they weren't captured in the
           sequence database.
                       DOCTOR POWERS: So, T is less than low.
                       MR. MOLDENHAUER: Yes.
                       DOCTOR POWERS: T is off the table.
                       MR. MOLDENHAUER: Still from a graded
           quality assurance standpoint, we call it low, because
           anything that's modeled in PRA has got to have some
           risk associated with it.
                       CHAIRMAN APOSTOLAKIS: Isn't it amazing,
           though, that you took all the low components, how many
           of those do you have, thousands, don't you?
                       MR. MOLDENHAUER: In the PRA?
                       CHAIRMAN APOSTOLAKIS: Low risk, in the PRA
           you have a few hundred, I guess.
                       MR. MOLDENHAUER: Yes, a few hundred.
                       CHAIRMAN APOSTOLAKIS: You increase their
           failure rate by a factor of ten, and you still didn't
           find any impact of the core damage frequency?
                       MR. MOLDENHAUER: The impact of the core
           damage frequency was approximately 2.5 E to the minus
           seven.
                       MR. LOVELL: Allen, do you want to pull up
           that slide?
                       MR. MOLDENHAUER: Sure.
                       MR. LOVELL: We have a slide that
           specifically goes through this.
                       MR. MOLDENHAUER: When we initially did the
           PRA risk ranking, we didn't know which components were
           going to come out low through the graded quality
           assurance process, so when we initially did it we just
           took check valves, we figured that for the most part
           check valves, if they only had one state they needed
           to open, or, actually, they may have two states they
           need to stay open, we increased their failure rates by
           a factor of two, five and ten, but after we had gone
           through the process and we knew exactly which
           components were going to be ranked out low from this
           process, we went back and that's when we increased the
           failure rates for those components specifically, and
           here's the results from it.
                       CHAIRMAN APOSTOLAKIS: So, when you say low
           rank components, you mean all of them?
                       MR. MOLDENHAUER: Yes, all of them.  Well,
           all of the 843 that have gone through the risk ranking
           process are in the PRA.
                       CHAIRMAN APOSTOLAKIS: Well, I guess this
           is a powerful argument.  I mean, the staff has
           confirmed all this?
                       MR. BARRETT: Yes, the staff has reviewed
           all this, it is a powerful argument.  You know, the
           other side of this, of course, is to assure ourselves
           that the changes that are in the treatment are such
           that the reliabilities do not degrade beyond the
           factor of ten, because some of these equipments have
           ten to the minus three and ten to the minus four based
           on reliabilities.
                       MR. LOVELL: Yes, I think the simple part,
           I'm not an expert in the PRA, but being involved in
           the graded QA, the thing I get out of it is, in fact,
           if it's rated low it's low.  There's not a lot of core
           damage impact, and even if you change it a number of
           times it still doesn't affect the overall number.  So,
           low is really low, and we ought to be looking at it
           from that standpoint, even when we get into the
           treatments.
                       CHAIRMAN APOSTOLAKIS: What do you mean the
           removal of common cause failures in the previous
           slide?
                       MR. MOLDENHAUER: That was one of the
           sensitivity studies that we thought   we wanted to
           see if there would be any impact on just the
           independent failures of the component, not including
           common cause.  If for some reason the component would
           go from a low to a medium or a high.
                       CHAIRMAN APOSTOLAKIS: I thought   I mean,
           removing common cause failure terms is kind of an
           optimistic thing.  Why would it make the ranking of
           the component worse?
                       MR. MOLDENHAUER: There were no cases where
           it did make it worse, but it was just something that
           we needed to prove to ourselves.
                       CHAIRMAN APOSTOLAKIS: I guess what I'm
           saying is, it's kind of obvious, but anyway.
                       DOCTOR SHACK: But, I think, isn't it sort
           of like the steam tube generator, because they
           dominate the thing you really take away the high stuff
           to sort of see   you get a more sensitive
           appreciation of what the individual component does if
           you get rid of the thing that's really dominating the
           picture.  At least that's sort of what I see.
                       MR. GRANTOM: Well, and with STP it's
           particularly true.  I mean, you know, global common
           cause failures pretty much dominates everything, and
           so when you do a risk ranking they always pop up to
           the top.  So, when you go in to remove those, you can
           kind of get a feel for what's the independent
           components, I mean, when you are viewing the PRA under
           different alignments, okay, different trains running,
           different trains may be in standby, the alignment
           subsystems can play a role when you are looking at
           individual component effects and the number of common
           cause events also changes, too.  So, there's some
           things that filter out of that.
                       CHAIRMAN APOSTOLAKIS: Why do we have to
           bother with all this importance measure business and
           deterministic thing?  Why don't we say this will be a
           performance based decision?  You tell us which
           components you want to put in the low risk category,
           you come in and say, we want these, then you multiply
           their failure rates by ten and if the   CDF and LERF
           is negligible then your argument is acceptable? 
           What's wrong with that, so we don't have to worry
           about Fussel-Vesely? I mean, you made the case, you
           multiplied everything by ten, then next time 20, until
           somebody gets into trouble, but as far as I'm
           concerned this is it.
                       DOCTOR KRESS: Well, you have to choose
           that pen carefully.
                       CHAIRMAN APOSTOLAKIS: But, that's the next
           thing, as Rick pointed out, that then you have to ask
           yourself, you know, the removal of certain things,
           does it decrease  
                       DOCTOR KRESS: But, in principle, I think
           you are right.
                       CHAIRMAN APOSTOLAKIS: Why do I have to
           bother with all this stuff and create all sorts of
           questions?  I mean, this set of components, if they
           are multiplied by ten doesn't do anything.
                       MR. BARRETT: I'll take that as a question
           for the staff. I'm Richard Barrett, I'm with the NRR
           staff.
                       There are, as was pointed out, a number  
           a large majority of the pieces of equipment in the
           plant that are being categorized that are not modeled
           in the PRA, and it's true to say that a lot of them
           are not in the PRA because they have no particular  
           they have no strong impact on the risk of the plant,
           and I think for those pieces of equipment it's fair to
           say that they are not credited in the PRA, which is
           another way of saying they really don't matter very
           much.
                       On the other hand, there are a number of
           pieces of equipment in that category that are
           implicitly in the PRA. They are not explicitly modeled
           in the PRA, and yet they can have a very strong impact
           on the result in a way that is not particularly
           modeled.  And so, that's really a lot of the questions
           that we've raised have to do with, for instance, the
           questions of pressure boundary type of issues and
           things like that.
                       So, you know, there are, I guess I'll call
           them secondary effects, but I agree with you, that the
           argument that you've taken everything, requantified it
           and shown that the impact on CDF and LERF is very,
           very small, I think that's a very powerful argument.
                       CHAIRMAN APOSTOLAKIS: The danger is that
           another licensee in the future may not be able to live
           with a factor of ten increase, so you guys have
           extreme redundancy, and where did the pen come from? 
           Right?
                       MR. BARRETT: Yes, those are the two  
                       CHAIRMAN APOSTOLAKIS: I mean, you are
           taking the arbitrariness here and moving it somewhere
           else.
                       MR. GRANTOM: Well, the ten has a bit of a
           basis to it, because we count, on our corrective
           action program, there's also 10 CFR 5065, which is a
           maintenance rule that looks at functions and how they
           are working, and those are barriers, in a sense, that
           preclude failure rates to reach such a bounding level
           as a factor of ten.  And, the corrective action
           program is used across the site for all components, no
           matter what their risk significance or non-risk
           significance is, and to have a component that would
           reach a factor of ten in its failure rate, those
           controls and those programs would come into play well
           before that level would happen.
                       So, we felt like the ten is a really, in
           a sense, a bounding case, based on an effective
           corrective action program.
                       CHAIRMAN APOSTOLAKIS: Right, plus I think
           in the PRA community we are dealing with factors of
           ten, because we are being conditioned from the  
                       DOCTOR SHACK: Well, again, George, you
           wouldn't be disturbed if a plant with a higher CDF
           couldn't put as many components in the low category.
                       CHAIRMAN APOSTOLAKIS: No.
                       DOCTOR SHACK: These guys get an advantage
           for having three trains.
                       CHAIRMAN APOSTOLAKIS: Yes, although it's
           not clear to me that the higher your CDF the fewer
           components you can put in the low category.  It's not
           clear at all.
                       DOCTOR SHACK: Well, it may not be, because
           they don't have any effect on it.  If it turns out
           that way.
                       CHAIRMAN APOSTOLAKIS: Yeah, if it turns
           out that way it turns out that way.
                       Shall we go to slide 12, because we are
           running out of time.  Yes, please go to 12.
                       MR. SCHINZEL: Slide 12 takes us into the
           deterministic categorization function.  As a Working
           Group, we do use what we call five critical questions
           in aiding us and guiding through the deterministic
           categorization process.  These five critical questions
           are summarized below.  We ask ourselves if the failure
           would directly cause an initiating event, whether the
           loss of the function would fail another risk
           significant system, whether that system mitigates
           accidents or transients, whether it is specifically
           called out in our emergency operating procedures or
           emergency response procedures, and if it's significant
           for either shutdown or mode changes. Those are the
           five specific areas that we look at.
                       And, as we go through and address those
           questions, we'll either address those in either a
           positive or a negative response.
                       CHAIRMAN APOSTOLAKIS: But, again, well now
           actually we are getting into a territory where things
           become more important, because you can't use your
           sensitivity analysis to make the argument, right?
                       MR. SCHINZEL: Correct.
                       CHAIRMAN APOSTOLAKIS: Now, this is really,
           what you are using here is an application, really, of
           decision analysis, where you have your categories,
           five categories, and then you rank   you rate each
           component from zero to five within each category,
           multiply by the weight and add them up.
                       One of the important constraints when you
           use methods like this is that your objectives, or what
           you call questions, should be preferentially
           independent.  So, when we ask a question, is the
           function specifically called out in the emergency
           operating procedures, and then we ask, is the function
           used to mitigate accidents or transients, isn't there
           a significant overlap there?  Are you double counting? 
           I mean, if the function is specifically called out in
           emergency operating procedures or emergency response
           procedures, doesn't it follow that that function most
           likely is used to mitigate accidents or transients?
                       MR. GRANTOM: Yes, it does.  I think you do
           see some overlap.  However, and Russ can probably
           speak to this much better than I can, there's a lot of
           other   there's other equipment that the operators
           may use for accident mitigation.  Maybe, Russ, you can
           fill in.
                       MR. LOVELL: Probably the difference more
           is there's a lot of equipment that's called out in the
           emergency operating procedures that's used for
           monitoring of the accident and decision making of
           where you go in the procedures that may not be looked
           at quite as much as accident mitigation.
                       CHAIRMAN APOSTOLAKIS: So, for a number of
           components then there is double counting, and for some
           there isn't.
                       MR. LOVELL: Correct.
                       CHAIRMAN APOSTOLAKIS: Well, maybe a more
           careful  
                       DOCTOR POWERS: Is this double counting? 
           I mean, all it is is a set of questions, they are not
           counting anything here.
                       CHAIRMAN APOSTOLAKIS: No, because then
           they put a weight of five to each, and then they
           multiply  
                       MR. SCHINZEL: We have different
           weightings.  We can go through those details if you
           wish us to.
                       CHAIRMAN APOSTOLAKIS: In your letter dated
           January 23rd, Attachment 4, that's what you say, that
           you have a weight of five, five, four, four, three and
           three.
                       MR. SCHINZEL: Correct.
                       CHAIRMAN APOSTOLAKIS: Then you rate each
           component from zero to five, starting from negative
           response all the way to positive response.
                       MR. SCHINZEL: That's correct.
                       CHAIRMAN APOSTOLAKIS: With respect to each
           one of these, right?
                       MR. SCHINZEL: Correct.
                       CHAIRMAN APOSTOLAKIS: See what they do
           their, Dana?  So, they take now one component that is
           important with respect to accident transient, and also
           EOPs, and multiply the rating times five and find the
           weights, and they get scores, 25 and 25.  That
           component now gets a score of 50, essentially, for the
           same function, because it is important to mitigate the
           accident, and it also appears in the EOPs, but the
           reason why it's in the EOPs is because it's important
           to mitigate accidents.
                       MR. LOVELL: In many cases that's right.
                       The other thing to point out, though,
           because this is a problem that we ran into in trying
           to explain this thing, is we do not use these rankings
           for component categorization, we do it only at the
           function level, the system function level, not at the
           component level.
                       CHAIRMAN APOSTOLAKIS: Which brings up
           another, system function, why do you have to do this? 
           The system functions should be in the PRA, shouldn't
           they?  I mean, I can't imagine that there is a
           function that is important to accident mitigation that
           is not in the PRA.
                       MR. GRANTOM: That's true, they are, but
           there are a lot of  
                       CHAIRMAN APOSTOLAKIS: So, why do I need
           this?
                       MR. GRANTOM:    there are a lot of
           functions that a system does that aren't in a PRA
           also, and there may be   and, I don't really  
                       MR. LOVELL: Let me give you an example. 
           One of the things we have up here is the ability to
           make sure you can make a mode change, or you don't
           make a mode change, you maintain your shutdown, I
           don't believe that's covered in the PRA, but we
           included that in our deterministic review.
                       MR. SCHINZEL: And, there are certain
           systems that really the PRA doesn't have any interest
           in.  We've categorized some of those systems.
                       CHAIRMAN APOSTOLAKIS: Wait, wait, let's
           not confuse the issue.  If I look at the five
           questions, they all use the word function, not system,
           right?
                       MR. SCHINZEL: Right.
                       CHAIRMAN APOSTOLAKIS: Is the function used
           to mitigate, is the function specifically called, does
           the loss of the function directly fail another risk
           significant system, it's always function.
                       And, it seems to me that these questions
           are at a high enough level, except for the shutdown
           because your PRA is only for power and mode changes,
           that these are at a high enough level that I can't
           imagine that there is a function that does any one of
           these and is not in the PRA.  So, why do I need to go
           to this weighting scheme to find out how important
           they are when the PRA tells me how important they are? 
           In other words, find the Fussel-Vesely and RAW of the
           function, you already have done a lot of it.
                       MR. MOLDENHAUER: One function that
           wouldn't be covered by the PRA that would be risk
           significant is fuel handling building accidents, spent
           fuel pool cooling.
                       CHAIRMAN APOSTOLAKIS: Yes, because you are
           talking about different   well then, it seems to me
           that it would have been much more clean to say these
           things, that we are going to do this, which is highly
           subjective for functions that are not in the PRA.  In
           other words, we are relying on the PRA as much as we
           can, and get the RAW and Fussel-Vesely for the
           function, which you don't need because you know that
           they are   to begin with.
                       MR. MOLDENHAUER: Well, to some extent we
           did do that.  We did a straw man before we took this
           to the Working Group, where certain individuals in the
           Working Group are responsible for taking a first cut
           at answering these questions, and I was responsible
           for doing the mitigation of accidents and transients
           and causes initiating event, and the input I provided
           into that was from the PRA perspective of it, and I
           looked at mainly the common cause issue in that.  If
           you have a common cause issue that could affect this
           function here, you get a function ranking, and that's
           basically how I came up with whether it should be a
           five, four, three, two, or one.
                       DOCTOR KRESS: There are some people on the
           committee who think the risk of shutdown is at least
           comparable to risk at-power, so that brings me to a
           question of why three weighting for that particular
           item instead of a five?
                       CHAIRMAN APOSTOLAKIS: And not only that,
           but this is probably the only question where you will
           identify systems and components that are not in the
           PRA, right, because your PRA is not shutdown.
                       MR. GRANTOM: Let me clarify something,
           though, too.  There are functions that aren't modeled
           in the PRA.  Draining the system is not modeled in the
           PRA, it's a function that a system does.  Every system
           does it out there.  They've got certain components
           that drain the system for maintenance for those types
           of things.  When we say, all right, we are looking at
           drain valves, does that mitigate accidents or
           transients, the probable answer to that is low or no. 
           So, we are covering all the functions that a system
           does.
                       Yes, there's the significant functions of
           mitigating the core damaging event, and those are
           going to be asked too, which they are going to get a
           very high ranking and the components get a high
           ranking.  So, that's why that happens.
                       But, in regard to the shutdown issue, the
           PRA does, in fact, cover, you know, the power
           dissension pieces of that, to cold shutdown, and what
           we are concerned about now is, now that we are in a
           cold shutdown condition, the weighting comes, there's
           longer times to recover from many of the plant
           configurations, and I wouldn't argue the fact at all
           that more work needs to be done in shutdown risk
           models, I mean, and once those are matured, you know,
           that could roll into this process here.
                       But, currently what we have, we are
           concerned with already being in a shutdown mode.
                       DOCTOR POWERS: Are all shutdown modes
           slow, are all shutdown accidents slow to develop?
                       MR. GRANTOM: Not all, no.
                       MR. LOVELL: The main one would be when you
           are mid-loop.
                       MR. GRANTOM: Yes, front end mid-loops
           where time to boiling is very short.
                       DOCTOR POWERS: So, I mean, shouldn't the
           weighting factor then depend on whether it affects
           this mid-loop operation or not?
                       MR. GRANTOM: I guess, you know, one could
           make a clarification that if you wanted to include
           something special with mid-loop, you are still dealing
           with the same systems, residual heat removal
           capabilities, which have already been categorized
           through the PRA.  So, most of the systems have been
           subsumed just in the power transition to mid-loop.
                       There are some other things associated
           with mid-loop, you know, with people being in
           containment that need to look at as far as the plant
           systems have been subsumed.
                       MR. SCHINZEL: We based these five
           questions as a guide for the Working Group for all
           systems.  As we've got to systems where mid-loop is an
           issue deterministically the members bring that to
           light as we address our specific questions, what the
           final categorization is.
                       MR. LOVELL: I can't think of a specific
           component or function we did this on, but I remember
           in our discussions we had a couple where we just
           raised the risk ranking in the Working Group based on
           the fact that it specifically affected mid-loop.
                       MR. MOLDENHAUER: There were some level
           indicators.
                       MR. LOVELL: Level indicators, that's
           right, we moved them up significantly, just on the
           fact that it was so important for the mid-loop, raised
           them to medium.
                       DOCTOR KRESS: I was intrigued by the
           parenthetical expression that says your weight was
           based on contribution to public health and safety, and
           the only way I know how to get that contribution is
           with a PRA.
                       CHAIRMAN APOSTOLAKIS: Sure, that's my
           point.
                       DOCTOR KRESS: And so, being a little bit
           of a loss as to where the weighting factors actually
           come from, and  
                       CHAIRMAN APOSTOLAKIS: The other thing is,
           why do add, why didn't you use them as a norm, in
           other words, you tell the group, look, these are five
           questions, if you think that this particular function
           is important to anyone, then we'll look at it, instead
           of adding them up, and double counting, and triple
           counting.
                       MR. CHACKAL: We do that in instances where
           there's a high answer to one particular question, and
           we don't want it to mask the other questions.
                       CHAIRMAN APOSTOLAKIS: Yes, I remember
           that.
                       MR. CHACKAL: We do that.
                       CHAIRMAN APOSTOLAKIS: But, this score
           there of 25, plus 25, plus 20, is so artificial, it
           really doesn't mean anything.
                       MR. CHACKAL: Well, the other thing to note
           is that we really are   our approach here was to
           provide an independent subjective, if you will,
           determination apart from the PRA, independent of the
           PRA, where we as a group, our experiences and
           knowledge of our particular plant, would reach
           conclusion.
                       Now, it's true that in a lot of cases
           there end result from that subjective grouping turns
           out to be the same as with PRA, but we felt it was
           important to provide that independently to make up
           some of the PRAs limitations and assumptions.
                       CHAIRMAN APOSTOLAKIS: Well, I guess the
           way I would look at this is  
                       DOCTOR POWERS: They're just being risk
           averse, George.
                       CHAIRMAN APOSTOLAKIS: Huh?
                       DOCTOR POWERS: They're just being risk
           averse, that's all.
                       CHAIRMAN APOSTOLAKIS: I don't know what
           they are doing.
                       Well, the real issue, the problem here is
           that you don't have the sensitivity study at the end
           that saves the day, because these things are not in
           the PRA, although you could.  See, the way I see it,
           at some high level the function is in the PRA, and the
           only way to connect anything you do with public health
           and safety as Doctor Kress said is through the PRA.
           Otherwise, what have we been doing all these years.
                       Then you keep going down, and I admit, you
           know, as you said, that   it's not a matter of
           admission actually   that's the way it is, as you go
           down you find certain functions and so on that are not
           explicitly modeled in the PRA, yet at some level they
           affect the PRA.
                       So, why don't we start with the PRA there
           and keep going down, in other words, why don't you do
           what Westinghouse proposed for in-service inspection,
           with surrogate components and all that, which ties
           very nicely with the PRA and deals with things that
           are not in the PRA, and it seems to me this cries for
           it.
                       Now, you probably were not aware of it,
           the surrogate component idea.
                       MR. GRANTOM: No, I'm not familiar with
           what that is.
                       CHAIRMAN APOSTOLAKIS: Basically, what they
           do is, they take a pipe, a piece of pipe that is not
           in the PRA, obviously, but then they ask themselves,
           if this fails what are the consequences, it affects
           this component, or this system which is in the PRA, so
           now I can tell what the impact is.
                       MR. GRANTOM: I haven't heard it called
           surrogate, but, yeah, well, in fact, we  
                       CHAIRMAN APOSTOLAKIS: I think that's what
           they call it.
                       MR. GRANTOM:    yes, we've had
           discussions with this about, is this process robust
           enough to categorize passive components, and for the
           very reason you just said this process does that. 
           We'd asked the very same question, we fail this piece
           of pie, well, it's associated with an aux feed water
           train.  Well, what does it do?  Well, it fails that
           train, which goes directly back up to the risk
           significant function that it's associated with.
                       CHAIRMAN APOSTOLAKIS: But, that's not what
           you do, you are assigning a weight to the auxiliary
           feed water system.
                       MR. GRANTOM: Right, but you are talking
           about an auxiliary feed water system, what about the
           little local pressure indicator over there that merely
           is used by an operator to go around and look at what
           the pressure of the system is right now, and it's not
           used for anything else, it's just merely for him to go
           and check off a control room log.  It's safety
           related, so how are we going to categorize that?  I
           don't think it's going to cause an initiating event,
           and I don't think it's going to fail the system, but
           the indicator, it's not going to actually be used to
           mitigate the accident.  I don't think   it would
           probably fall as a no to a lot of these things and be
           called non risk significant, but when you are going
           through a total plant numbering system and you are
           looking at all of the tag numbers that are associated
           with the system, you are going to have to somehow be
           able to do the bookkeeping here to say we looked at
           all of this.
                       And, a lot of them have functions that are
           somehow related, like you say, to maintenance, but
           they are only maintenance during shutdown conditions
           when we completely drain the system and go do stuff at
           that point.
                       So, their function is different, and you
           are really talking   and that's why the PRA is the
           way it is, people always ask why are there so few
           components modeled in the PRA, because, you know,
           those are the components that really determine the
           risk. Those are the main big pumps, big motors, those
           types of things, active components that have to work,
           so we can tie it all to this, and I don't disagree
           with you all, that we probably are double counting
           some of these things in here, but we are also trying
           to get a conservative process because we are a
           prototype effort going forth here, and there's a lot
           of things that can be improved.
                       CHAIRMAN APOSTOLAKIS: And, it's really
           maybe unfortunate or, I don't want to use the word
           unfair, but, I mean, you guys, because you are
           pioneers, you get all these questions.  So, I'm
           completely aware of that, but I would like also to
           make a point here which may be obscure to you, but
           it's directed to Doctor Powers.  One of the reasons
           why you see all these things here is precisely because
           as a community we have not paid attention to decision
           making theories.
                       DOCTOR POWERS:    to you to ignore the
           narrative   I mean, to ignore that, the failed
           methodology.
                       CHAIRMAN APOSTOLAKIS: What failed  
                       DOCTOR POWERS: To ignore the decision-
           making failed methodology, not make the mistakes of
           the famous F-111.
                       CHAIRMAN APOSTOLAKIS: It's very difficult
           to communicate with this group.  I think as a
           community we have not paid much attention to these
           kinds of methodologies, which are being used routinely
           elsewhere.  In fact, the Department of Defense uses
           these a lot, but you have to  
                       DOCTOR POWERS: They being a paragon of
           economic and judicious decision making.
                       CHAIRMAN APOSTOLAKIS: As you have told us
           many times, that they know how to plan research.  So,
           it seems to me that again you are being put on the
           spot here for something that has not been scrutinized
           by the community.  But, the issue of double counting
           is very, very important.  I mean, you can't have
           decision theories like that.
                       DOCTOR POWERS: Well, yes, the double
           counting is not that important, it is simply a
           reflection of a different utility function.
                       CHAIRMAN APOSTOLAKIS: Oh, no, no, no.
                       MR. GRANTOM: And, I would like to just add
           here, these questions here are very similar to the
           same screening questions used in the maintenance rule,
           for scope in the maintenance rule, it's very similar.
                       CHAIRMAN APOSTOLAKIS: That's why I'm
           saying, instead of adding them up, it probably would
           have been an "or" gate there, if any one of these is
           important do something, because they overlap so much.
                       MR. GRANTOM: I think that's part of the
           reason of the weighting, if the weighting falls into
           place it kind of creates a pseudo kind of "or" gate,
           because if you multiply it by its weighting it flops
           over into  
                       CHAIRMAN APOSTOLAKIS: So, there's the
           issue of the questions overlapping, there is the issue
           of the appropriateness of the weights, right, and then
           the  
                       DOCTOR KRESS: And then there's the
           threshold.
                       CHAIRMAN APOSTOLAKIS:    and the bigger
           issue is really why didn't we use the PRA coming down,
           and then, like you say   the component, and the final
           issue is on the next slide, which is related to the
           thresholds that Doctor Kress raised, why is the score
           range between zero and 20 non risk significant, and
           does that correspond to Fussel-Vesely less than .05 or
           whatever it was, and risk achievement were less than
           two, right?
                       DOCTOR KRESS: These are the questions,
           yes.
                       CHAIRMAN APOSTOLAKIS: This is really the
           question here.  I mean, actually, it was low safety
           significance, I think, in that case.  But, I mean, how
           did we decide, and that's where, again, the double
           counting comes in to its full glory, that a score less
           than 40 corresponds to a Fussel-Vesely less than .001,
           and RAW less than two.  Obviously, it's a judgment,
           right?
                       MR. SCHINZEL: It was judgment on that. 
           You know, we took the overall score range of 100, we
           looked at the lower 40 percent being low and non risk
           significant, and then the upper 60 percent being high
           or medium safety significant, and from the perspective
           of the thresholds that was judgment on our part as to
           what was considered reasonable, as far as where we
           would draw the lines to segregate low from non risk
           significant, medium from high.
                       DOCTOR POWERS: Have you done anything just
           to validate that judgment, by running a few things
           that you run the Fussel-Vesely through just to see if
           it works?
                       MR. SCHINZEL: One thing that we've done
           is, we've done, you know, extensive comparisons with
           all the components that we've categorized to date, and
           we've seen very good correlation with the PRA
           categorization in deterministically what we've come up
           with.
                       DOCTOR POWERS: I think I would take some
           credit for that, and advertise that a little bit, so
           that you can avoid him getting lock horned to these
           decision theory things that he likes to do.
                       MR. LOVELL: I think it's been a help to,
           like for myself as an operator, I have an SRO, is that
           it does give a lot of credibility to the process, and
           we go through it, and then you compare the results,
           and generally they are comparable.  There are some
           cases where we rate it higher and some cases we would
           have gone lower, but the PRA had it higher and we went
           with that rating.
                       So, it's kind of the internal consistency
           that, for me to understand it and to have confidence
           in it, has really helped.
                       MR. CHACKAL: And, this is the type of
           process that we might use if we didn't have the PRA. 
           I mean, we developed this independent of what   of
           the PRA.  We said, well, how would we do this as a
           Working Group subjectively, deterministically, what
           kind of a threshold do we want to establish, and this
           is what we came up with, and it was, again, to provide
           an independent perspective.
                       And, just to give out some numbers, out of
           886 modeled components, PRA modeled components that we
           had already categorized in our systems, 800 were the
           same ranking.  So, it's about 85 percent or so, and
           the ones that were not the same ranking are, of
           course, by definition, higher.  We deterministically
           ranked them higher, because we can never be lower than
           the PRA.
                       CHAIRMAN APOSTOLAKIS: Well, the PRA, if we
           want to push this point, things that are in the PRA,
           and are ranked high in the PRA, will definitely be in
           the high safety category here, because you have triple
           counted them.  So, that doesn't surprise me a bit.  It
           doesn't prove anything.  Right, because there will be
           important initiating events, they will be important  
           all the questions, the function will be in the EOPs,
           does the loss of function directly affect other
           systems, you know, the whole thing, except for the
           shutdown.  So, those systems will get five, times
           five, times five, plus, plus, plus, 95.
                       MR. LOVELL: Well, let me give you an
           example, a specific one that I always give Mr.
           Moldenhauer a bad time about, and that's a refueling
           water storage tank.  I mean, doing it
           deterministically it's an important piece of
           equipment, but its failure rate is, essentially, zero. 
           You know, it's a very reliable piece of equipment, and
           we would have ranked it, I don't remember what, but it
           was less than the high that the PRA had, I think
           probably because of the RAW score?
                       MR. MOLDENHAUER: Yes.
                       MR. LOVELL: And so, deterministically, we
           would have actually come out with a lower number than
           what the PRA had.
                       CHAIRMAN APOSTOLAKIS: But, the PRA  
           excuse me, the PRA in the RAW says assume the system
           is down, so the failure rate is irrelevant, so in
           terms of RAW it would sky rocket.
                       MR. LOVELL: That's right, but overall,
           even deterministic, going through these questions, we
           came out with a lower risk ranking than high.  So, it
           doesn't necessarily say that the PRA systems
           automatically go to the same things because of how we
           add these things up.
                       CHAIRMAN APOSTOLAKIS: If you take the
           refueling water storage tank, is the function used to
           mitigate accidents?  Is it needed?  Yes.  I don't know
           that it's called an operating procedure, probably not.
                       MR. LOVELL: It is.
                       CHAIRMAN APOSTOLAKIS: It is, specifically? 
           Okay, so that's there, too.  Does the loss of the
           function directly fail other risk significant systems?
                       MR. CHACKAL: You bet.
                       CHAIRMAN APOSTOLAKIS: You bet.
                       Is the loss of the function safety
           significant for shutdown or mode changes?  Does the
           loss of the function in and of itself directly cause
           an initiating event?
                       MR. CHACKAL: No.
                       CHAIRMAN APOSTOLAKIS: No, so we have four
           yeses and one no.
                       MR. LOVELL: But, what would happen,
           though, is, one of the things we used in our
           deterministic ranking is the reliability of the
           component.  So, instead of writing it at a five for
           any of those answers, and it was probably a three  
                       CHAIRMAN APOSTOLAKIS: But, if you go to
           the PRA and calculate RAW, the fact that you have to
           assume that a tank is down, I mean, defeats so many
           things.
                       MR. LOVELL: Right.
                       CHAIRMAN APOSTOLAKIS: So, it's not  
           anyway, I mean  
                       MR. GRANTOM: Well, George, the questions
           are good screening questions for what you ought to put
           into a PRA.
                       CHAIRMAN APOSTOLAKIS: Sure.
                       MR. GRANTOM: They really are.  And, what
           we are trying to do here is, we are trying to make
           certain that somehow there isn't some function that an
           operator knows about, that is used somewhere, that
           somehow has been screened over in the PRA because it's
           not directly called for, but has been used for a mode
           change or shutdown, or it has been shown in our
           experience that this component tripped the plant, even
           though it probably cascaded to some degree.  So, it's
           trying to catch things in that regard, but I don't
           disagree with you that, yeah, you can use the PRA
           strictly, but also you have to realize this is also
           supposed to be a risk informed approach, which is
           supposed to blend probabilistic and subjective  
                       CHAIRMAN APOSTOLAKIS: Yes, structured
           judgment.
                       MR. GRANTOM:    structured judgment.
                       CHAIRMAN APOSTOLAKIS: I guess what I'm
           saying is that  
                       MR. GRANTOM: And so, this is an attempt to
           blend those pieces together.
                       CHAIRMAN APOSTOLAKIS:    I think what you
           are doing in your so-called deterministic approach in
           parallel to the PRA.
                       MR. GRANTOM: Yes, it is a parallel
           process.
                       CHAIRMAN APOSTOLAKIS: The blending is not
           very good.
                       MR. LOVELL: And, where this really comes
           in important is, is that as we mentioned, most
           components we've ranked do not have a PRA ranking. 
           So, this is how we really get to rank them for those,
           the majority of the components, the vast majority.
                       CHAIRMAN APOSTOLAKIS: Is there a
           sensitivity study here?  Did you assume that all the
           low safety significant and non risk significant
           components are down, and you sort of know   did you
           do anything dramatic as in the PRA case?
                       MR. GRANTOM: There is certainly no
           quantified, they are not in the scope.
                       MR. LOVELL: But, on the other hand, we've
           talked about this in the Working Group, and again,
           this is all subjective judgement, but, basically,
           looking at the people who are in that group looking at
           it, is what would happen if all these lows went away,
           and the feeling we had with our subjective judgment is
           that it really did not impact the overall core damage
           frequency.
                       CHAIRMAN APOSTOLAKIS: So, you actually did
            
                       MR. LOVELL: Informally, I mean  
                       DOCTOR SHACK: But, to use something like
           a RAW, where, you know, you don't want to penalize the
           component because it's normally so reliable, that, you
           know, if it failed, as unlikely as it was.
                       MR. GRANTOM: Well, then you are really
           kind of getting into   I don't know, to me the
           question came up, you know, what if all the drain
           valves failed during an event, I mean, now you are
           getting into ridiculous, you know, assumptions about
           things.
                       I mean, if all of the non risk significant
           components failed, would it be a good thing, well, of
           course, it wouldn't be a good thing, it would probably
           be messy or something, but it wouldn't preclude our
           ability to bring that plant to a safe shutdown
           condition. It might be messy, and things might have to
           be fixed, but it's not   it's not going to make or
           break our ability to maintain a safe plant, or protect
           public health and safety I should say.
                       DOCTOR KRESS: Well, the fact that you came
           out with a consistency with your PRA in this process
           is helpful to me in saying, for your particular system
           that you may have chosen the right weighting values
           and the right ranges for the thresholds, but what
           bothers me is, the next plant that comes in, which is
           going to be a lot different than your's, will
           probably, because we've set a precedent, will want to
           use these same values, these same thresholds, and even
           the same process, and I'm not sure that this is not a
           plant specific consistency, because I don't have a
           firm basis for choosing this that is based in the
           actual risk numbers in some way.  And so, I'm not sure
           that this is universally true.  That's my problem.
                       I would be willing to accept that you've
           validated it for your system by the consistency.
                       CHAIRMAN APOSTOLAKIS: One could have done
           this without any knowledge of the PRA technology.
                       DOCTOR KRESS: You could have, but you
           would have trouble, in my mind, saying   picking the
           right range for the score of the thresholds.
                       CHAIRMAN APOSTOLAKIS: Yes, but it  
                       DOCTOR KRESS: Because that was completely
           arbitrary. You know, I might have picked one, somebody
           else might have picked another, but the fact that they
           are shown as a consistency then says you probably
           picked pretty good values for your plant.
                       CHAIRMAN APOSTOLAKIS: Sure.
                       MR. GRANTOM: Well, there are criteria that
           go to determining how frequent a component's demand
           is, and what the impact of the failure of that
           component is, and that's included in the number that
           would be assigned to that component or that function.
                       DOCTOR KRESS: The number  
                       MR. GRANTOM: The number, and then the
           weighting gets multiplied by that number.  If we
           expect something that's always continuously demanded,
           which is possible because it's a running system,
           continuously running system, well, that gets the
           highest level.  If it's something like accumulators,
           we might say that never or at most once per lifetime
           would it ever be demanded to do  
                       DOCTOR KRESS: Well, are these criteria
           spelled out somewhere?
                       MR. GRANTOM: Yes.
                       DOCTOR KRESS: Is there guidance given as
           to how much  
                       MR. SCHINZEL: We'll put those slides up
           and we'll go through that.  That's included as the
           additional information.
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. SCHINZEL: Originally, in the graded
           quality assurance safety evaluation report, we were
           responding to these five questions with just a yes and
           a no.  We started into the detailed categorization and
           looking forward at implementation, we recognized that
           just a yes/no answer didn't give us the necessary
           insights.
                       CHAIRMAN APOSTOLAKIS: How much time do you
           need?  I mean, shall we take a break now, because we
           are already late, and then come back and continue with
           you?
                       MR. SCHINZEL: Yes, that's probably good.
                       CHAIRMAN APOSTOLAKIS: Okay.  Let's take a
           15-minute break until 10:30.
                       (Whereupon, at 10:16 a.m., a recess until
           10:30 a.m.)
                       CHAIRMAN APOSTOLAKIS: Okay, we're back in
           session.
                       How much more time do you gentlemen need,
           because we have to have time for the staff.  Ten
           minutes?
                       MR. SCHINZEL: We can, it's dependent on
           your questions.
                       CHAIRMAN APOSTOLAKIS: How much time does
           the staff need?
                       MR. SCHINZEL: Doctor Apostolakis, we are
           going to adjust our presentation to shorten it up to,
           what, maybe 25 minutes.  It can be even shorter.  A
           lot of what we have to say is actually the whole
           categorization process, which has been fairly well
           covered here.  So, we just might want to highlight
           some points and give you an opportunity to ask
           questions.
                       CHAIRMAN APOSTOLAKIS: Well, we also have
           a  
                       DOCTOR BONACA: We have an hour for
           discussion anyway, we can discuss it for one hour.
                       CHAIRMAN APOSTOLAKIS: Well, maybe what we
           could do is give you ten/15 minutes now, then go to
           the staff, and then have a session at the end where we
           discuss issues, you know, after we have had the chance
           to hear from the staff as well.
                       You gentlemen will be here until 12:30?
                       MR. SCHINZEL: Yes, we will be.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       So, why don't we do that.
                       MR. SCHINZEL: Okay.
                       CHAIRMAN APOSTOLAKIS: And, you don't have
           to go over every single vu-graph and bullet.
                       DOCTOR BONACA: We also have some questions
           that may take some more time than just what the plan
           is.
                       CHAIRMAN APOSTOLAKIS: Well, that would be
           unusual.
                       Where are we now?
                       MR. SCHINZEL: The question prior to the
           break was associated with some of the foundational
           bases to the answers that we have for our five
           critical questions.  The slide that we have on the
           overhead does show the weightings or the responses
           that we can give for each of the positive responses,
           and they go anywhere from a one, which is incidents
           that can impact are occurring very rarely, up to a
           five, which is high impact, or occurring frequently. 
           Now, each one of those impacts or occurrence
           adjectives we recognize that there is subjectivity
           associated with those. 
                       We tried to offer a guideline to the
           Working Group membership to guide them in how to
           address what is high impact, what's occurring rarely,
           so those are given under the frequency definitions,
           occurring frequently, up to occurring very rarely, and
           these are, again, guideline definitions that the staff
           uses.
                       On the next slide, we give the same type
           of insight for the impacts, from a high impact down to
           an insignificant impact, and again, these help guide
           the Working Group in the overall categorization.
                       And then, as we get toward the weighting
           scale on the following slide, we do have the questions
           that have a specific weight assigned to them. We've
           already discussed that, and then how we calculate the
           weighting factors against those scores, and come up
           with our maximum score of 100.
                       One thing that we do want to identify on
           the next slide, under the guidelines for the scoring,
           we do have some exceptions that we have, and that
           would be to ensure that there is no masking, if there
           is a specific question that comes out with a very high
           score.  So, the exceptions that we show is that if we
           have a single question with a weighted score of 25,
           and that would be true for the two questions of EOP or
           accident mitigation, even if all the other questions
           are answered in the negative that component or that
           function would still be categorized high.
                       On any one question, if it's 15 to 20,
           automatically that function is going to be medium, and
           then nine to 12 automatically going to be low, as a
           minimum.
                       So, those are some of the exceptions that
           we put into place to ensure that the masking isn't a
           problem for us as we go through the categorization.
                       So, those are kind of the backstops that
           we have with some of the subjective insights that we
           have.
                       DOCTOR KRESS: Would you explain that
           bottom line again to me, with the weighted score of
           nine to 12, on any one question it means it goes
           automatically to low, even though it may have ranked
           high on the other questions?
                       MR. SCHINZEL: No, that means that if we
           have a question, one single question that would come
           out with a score of nine to 12, and all the others are
           something less than that, might come out zeros, or non
           risk significant, but just because that one question
             yes, you may have four questions answered in the
           negative and receive a score of zero, but this one
           question only might receive a score of nine or 12, and
           normally if you looked at our scoring range that would
           normally have us down in the non risk significant
           area, but because one question received that type of
           mark it would be low.
                       DOCTOR KRESS: It's a kind of a way to deal
           with George's "or" comment.
                       MR. SCHINZEL: Yes.
                       DOCTOR KRESS: But, in a graded way.
                       MR. SCHINZEL: That's correct.
                       CHAIRMAN APOSTOLAKIS: Has the staff
           disagreed with any of the rankings, categorized
           components?  Have you more or less agreed that what
           they've done is reasonable?
                       MR. LEE: This is Sam Lee of NRR.  Are you
           asking, in particular, to the deterministic process
           here?
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. LEE: In general, we have.
                       CHAIRMAN APOSTOLAKIS: You have what?
                       MR. LEE: In general, we do agree with the
           process.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       MR. LEE: However, this has taken some
           time.
                       CHAIRMAN APOSTOLAKIS: You agree with the
           process or the results of the process?
                       MR. LEE: We agree with the process.  We
           are evaluating the process, so we are either approving
           or disapproving the process.
                       CHAIRMAN APOSTOLAKIS: So, you have not
           looked at the 40,000 components and looked at a sample
           and said, do we agree that this is low risk?
                       MR. LEE: We have taken a look at samples.
                       CHAIRMAN APOSTOLAKIS: And, you have what?
                       MR. LEE: And, we have found that in
           general that they have been good, and we have had some
           questions of samples that we reviewed that we needed
           to address, but, in general, they have been good.
                       CHAIRMAN APOSTOLAKIS: You know, this is a
           critical point for me, because, frankly, I think the
           methodology needs a lot to become reasonable, but if
           you guys agree with the final result, more power to
           everybody.  That's great.  I'm the performance based
           guy, right?  If you agree, I mean, why not, but I
           can't say nice things about this.
                       Let me ask you a couple of questions that
           I have.  In your letter dated January 23rd, Attachment
           4, you say, page six, "In general ...,"   you don't
           have to find it, you believe me, right?
                       MR. SCHINZEL: I believe you.
                       CHAIRMAN APOSTOLAKIS: "In general..."  
           I've had to believe you many times today, right?  "In
           general, a component is given the same categorization
           as the system function that the component supports." 
           When I read that, I thought of Rick.  Many times he
           was furious, you know, you can't say that, that this
           little component here has the same safety significant,
           safety related because the system is.  So, I said,
           what's going on.
                       "However, a component may be ranked lower
           than the associated system function."
                       MR. SCHINZEL: That's right.
                       CHAIRMAN APOSTOLAKIS: So, Rick won.
                       Then I asked the question, how is that
           done?
                       Then, there is another transmittal,
           January 18th, Attachment 1, which says that   well,
           it's a long paragraph, I don't want to read it, but,
           "In cases where failure of an individual component
           will not fail the function due to redundancy,
           diversity or other factors, and where component
           reliability has been good, the initial risk may be
           lower."  But again, it doesn't tell us how.
                       So, is there a place where you explain
           how?
                       DOCTOR BONACA: In fact, I had a question
           on this specifically, because the   says that you may
           have a system that is rated, say, medium safety
           significance, you have multiple redundant systems
           below supporting it, you classify them as low and you
           take them out of your cure as part of the problem.  Is
           it possible?  So, you would have a system that is
           rated medium, and yet you have components that are not
           anymore in the quality product.
                       MR. SCHINZEL: That's correct, yes.
                       DOCTOR BONACA: It's possible.
                       MR. SCHINZEL: Yes.
                       As far as the control, we have a procedure
           that the Working Group uses that governs the approach
           and process for categorization, and specific for the
           area of redundancy and diversity there is a guideline
           in one of the addenda that tell us exactly how and
           when we can use redundancy and diversity as factors in
           adjusting the categorization process.
                       DOCTOR BONACA: Is it how you got the
           certain piping systems in the auxiliary system to be
           low safety significant?  Is that how you got that?
                       MR. SCHINZEL: Yes.
                       DOCTOR BONACA: That surprises me.
                       CHAIRMAN APOSTOLAKIS: So, the scores that
           you show this apply only to functions, not to
           individual components.
                       MR. SCHINZEL: That is correct.
                       CHAIRMAN APOSTOLAKIS: But, function,
           though, is something that is not well defined.  I
           mean, Rick mentioned there your draining functions,
           other kinds of functions, why didn't you apply it to
           the component level?  Wouldn't it have been a more
           reasonable thing to do, because you are using judgment
           after the function is categorized to do it now for the
           components, right?  You say you are using things like
           redundancy, diversity, or other factors.  Wouldn't it
           have been better to actually use a scoring rule to do
           that?
                       MR. CHACKAL: The way that we do it is, we
             after we identify the functions, we risk rank the
           functions using these questions, we then map the
           components to the functions.  For every component we
           identify the functions that that component supports,
           and, of course, in some courses more than one.  We
           then provide   we then give the component the highest
           risk, you know, the risk of the highest system
           function that it supports.
                       CHAIRMAN APOSTOLAKIS: Right.
                       MR. CHACKAL: Okay?
                       And, that's our baseline.  And, most
           components stay that way.  But, when we discuss, when
           we deliberate on redundancy, diversity and
           reliability, in cases where we can take credit for
           those, we are able to conclude that the failure of
           that specific component will not fail the function. 
           Why is that?  Well, there is another component
           available, or there is a diverse method of
           safeguarding that function.
                       CHAIRMAN APOSTOLAKIS: And then, how do you
           decide, though, how far down to go and say this
           component now, even though the function is of high
           risk significance, this component is  
                       MR. CHACKAL: Generally, we only go down
           one level.  One level, if it's high, if it supports a
           high risk function  
                       DOCTOR BONACA: But, you said this is a
           deterministic process, right?
                       MR. CHACKAL: Right.
                       DOCTOR BONACA: But, the auxiliary system
           has to be in the PRA, so for that you have a rule that
           says when you classify something of a high level in
           the PRA, any supporting components is as high in
           classification as the top, but in this case you didn't
           do it somehow.  Why, I don't understand how you got to
           those parts of the piping system of the auxiliary
           system as low safety significant.  You told me that
           you got through the deterministic process, but really,
           the auxiliary system is in the PRA, therefore, you
           don't apply that deterministic process.
                       MR. CHACKAL: Well, when we come out of the
           deterministic process, okay, with a risk rank, we then
           look at the PRA risk, and if the PRA risk is higher,
           of course, procedurally we go with the higher PRA
           risk.
                       DOCTOR BONACA: That's right.
                       MR. CHACKAL: Okay?
                       If the deterministic risk is higher, we go
           with   we go with the higher of the two.
                       DOCTOR BONACA: Yes, and then with respect
           to one of the two would say the auxiliary system is
           pretty high safety significant, or medium I mean, no
           less than that.
                       MR. GRANTOM: Right, but there are other
           things that come off the system, the piping that comes
           off the system, instrument sensing lines, there can be
            
                       mR. LOVELL: Recirculation piping.
                       MR. GRANTOM:    recirculation piping
           that's small, and even in PRA, and this is common in
           most PRAs, that's why in PRAs we don't model all of
           these ancillary equipment, we can say, well, even if
           you lose that pipe you can't have enough flow out of
           that one-inch line or less to fail the system.
                       DOCTOR BONACA: So, there are specific
           elements, all right.
                       MR. GRANTOM: And, there are some rules of
           thumb about how, you know, we apply that in the PRA.
                       CHAIRMAN APOSTOLAKIS: But, I remember in
           your GQA presentations, I remember vu-graphs used by
           Mr. Grantom and Mr. Rosen, one of the very first
           systems you looked at was the diesel generators, which
           certainly is of high significance, the diesel, the
           function of the diesel.
                       And, you had some very impressive numbers
           there, that there were, what, 5,000 components
           associated with each diesel, and an incredible number
           were really not risk significant.
                       MR. GRANTOM: Yes.
                       CHAIRMAN APOSTOLAKIS: So, was that then
           based on judgment?
                       MR. GRANTOM: No, a lot of it, for the
           diesel example, we are looking at a diesel that we are
           trying to make certain that diesel can operate under
           the emergency mode operation of a diesel.  There's a
           lot of other equipment that's associated with testing
           the diesel that we use, that has a diesel generator
           tag number associated, but it's only used for testing,
           or it doesn't prevent the system from operating in
           emergency mode.  There's a lot of trips and other
           things that are associated with the diesel.
                       CHAIRMAN APOSTOLAKIS: Right.
                       MR. GRANTOM: So, there's a lot of that
           equipment, that's the equipment that falls out,
           George, that isn't, it's the stuff that makes the
           diesel work when it really has to work under an
           emergency mode condition.
                       CHAIRMAN APOSTOLAKIS: The statement was
           made earlier that if the system function is high, then
           the most you can do is take individual components of
           the system and put them one level down, but in here it
           seems that you went down two, three levels.
                       MR. CHACKAL: Well, let me explain it this
           way. For the diesel, there's probably 50 separate
           functions, okay?
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. CHACKAL: And, for example, one of the
           functions is standby lube wall system heating, to
           ensure that the lube wall is always at a certain, you
           know, minimum temperature.  That's a separate
           function.  That function was ranked low.  The
           components that support that function, the standby
           lube wall pump, not necessary for the operation of the
           diesel in emergency mode, would be ranked low as well.
                       So that, just to clarify it, I guess, the
           number of functions that we typically identify in a
           system, typically, at least 30 separate functions,
           it's not just the higher level functions.
                       DOCTOR BONACA:  But, so much of this is
           really outside of the PRA.  I mean, the PRA   so the
           question I have is, could your application be
           supported by a pure deterministic process?  I mean, a
           lot of the judgments you are basing your decisions on
           is really deterministic, it's solid, I mean, in many
           ways.
                       CHAIRMAN APOSTOLAKIS: Another way of
           putting it is, why is this risk informed?
                       MR. GRANTOM: Well, it's risk informed for
           a couple of reasons.  First of all, if you didn't have
           the PRA you might have a tendency to fall back to
           Chapter 15 in ECCS criteria, which is going to say
           accumulators are risk significant because you have no
           weighting of the frequency of the event.  That's one
           important element.
                       The other part of it being risk informed
           is the fact that you know, by the mere fact that you
           know what's in the scope of the PRA, you know you've
           got an analysis that's put these components at a
           special quantifiable level, and the rest of the items
           over here are supporting something else.  That's good
           information in and of itself.  
                       Yes, you could go and do strictly what
           we've done here on these deterministic questions, but
           you are going to pull   well, you'll have almost
           essentially the cross of safety related/non safety
           related that you  
                       CHAIRMAN APOSTOLAKIS: The context within
           which you apply the methodology is changed.
                       DOCTOR BONACA: And, you look at this
           general   that we discussed in the beginning and ask
           the question, like, you know, category one, bent
           frame, test valves, there must be hundreds of those or
           more.
                       MR. GRANTOM: Yes, thousands.
                       DOCTOR BONACA: Now, the argument you are
           using I believe is a credible and solid argument, but
           it doesn't need the PRA to do that, so I was wondering
           why would any power plant today not use the same
           argument throughout?  I mean, it's just a question we
           have to ask ourselves, because we are making this kind
           of step conditional on the existence of a solid PRA,
           and yet, so many of the elements are  
                       MR. GRANTOM: It's a good question, and
           it's question that is somewhat as a result of the time
           we were licensed and the time that we were
           constructed.  The Q list associated with some of the
           older plants aren't as large as the Q lists that are
           associated with plants that are post TMI.  So, you are
           seeing   what you are seeing is an artifact of the
           architect engineer and the licensee, in order to get
           licensed, putting everything into safety related
           because it was the way to get licensed.  Now we've
           overscoped it tremendously, huge O&M costs to be able
           to do this, regulatory processes that lump on it, I
           mean, it all carries its own 9 tons of baggage, and
           now we are trying to extract some of that in the risk
           informed manner, so that's the roots of where a lot of
           that came from.
                       DOCTOR BONACA: I understand.
                       CHAIRMAN APOSTOLAKIS: The thing is that,
           I mean, again, Regulatory Guide 1174 says that risk
           informing the regulations means to look at the
           integrated decision-making process and one element of
           it is the input from delta CDF and delta LERF.  Then
           we go on and use importance measures that are not
           really related to delta CDF and delta LERF, and now we
           are going one gigantic step beyond that, we don't even
           use importance measures, we go to another methodology
           and so on, and that's within risk informing the
           regulations.
                       MR. GRANTOM: George, I agree with you.
                       CHAIRMAN APOSTOLAKIS: They may be very
           valid reasons. I mean, what you mentioned earlier
           about the Q lists and so on, I agree with you.
                       MR. GRANTOM: We are in an evolutionary
           process right now.  I would like to think that we
           could be much further along with the acceptance of
           these technologies in the purest sense of what the PRA
           produces, but I don't think the culture, both within
           the staff and even within our own utilities, has
           reached that point to where they just readily accept
           PRA results and enable us to move on.
                       CHAIRMAN APOSTOLAKIS: I guess the question
           in my mind is that, when people ask us what is a risk
           informed regulatory system, and we say read Regulatory
           Guide 1174, is that really a fair answer?  It is not. 
           This is only one part of it.
                       MR. BARRETT: I would  
                       CHAIRMAN APOSTOLAKIS: And, a small part as
           it turns out.
                       MR. BARRETT:    I would point them to a
           more recent document, which is SECY 00168, which I
           think goes a step beyond Reg Guide 1.174 and talks
           about the whole question of using different types of
           information, such as the qualitative information and
           how that can be appropriate in some areas and in some
           ways, and how you have an integrated decision-making
           process that takes into account various types of
           information and the implication that that has for the
           quality of PRA.
                       I think that if you look at Attachment 2
           to SECY 00160   I think it's 168  
                       CHAIRMAN APOSTOLAKIS: What is it about?
                       MR. BARRETT: It's, basically, about
           decision-making processes within the risk informed
           methodology.
                       CHAIRMAN APOSTOLAKIS: Yes, we should get
           a copy.
                       MR. BARRETT: I'll see to it that you get
           a copy of that.
                       CHAIRMAN APOSTOLAKIS: Thanks.
                       Okay, what else do you have to say that is
           extremely important?
                       MR. SCHINZEL: Well, one thing I wanted to
           make sure that the committee understood, we have
           general notes that we do use to support some of the
           documentation.  There's been some references made to
           the vents drain valves.  Recognize that this is not an
           alternate categorization means, this is an aid for
           South Texas in documenting the bases for why things
           fall into certain families and the bases for the
           categorization that those have.  So, I just wanted to
           bring that point up, make sure that the committee
           understood that portion.
                       DOCTOR BONACA:  So, could you have a
           situation  where a normally opened   well, that's not
           a good example, but say a type 3 valve in a specific
           location, in a specific condition, could, in fact?
                       MR. SCHINZEL: Yes.
                       DOCTOR BONACA: So, you do look at those.
           So, although you do have a general classification, but
           then you are looking at individual applications and
           making the judgment.
                       MR. SCHINZEL: Right, we are looking at
           each individual component and showing that its
           classification is proper.
                       DOCTOR BONACA: Okay.
                       MR. SCHINZEL: This just aids us in
           documenting the basis for why it is categorized as it
           is.
                       DOCTOR BONACA: I understand.
                       MR. LOVELL: It also helps with
           consistency, so how we started out with these in some
           ways was, we'd say, well, how do we handle this
           situation in the other systems.  This helped us with
           consistency, but in each case there's a specific
           evaluation, do these apply, and is this the right
           decision.
                       DOCTOR BONACA: Good.
                       CHAIRMAN APOSTOLAKIS: Can you go to slide
           16?
                       MR. SCHINZEL: Certainly.
                       Slide 16 reflects two of the open items
           that have not been fully resolved between South Texas
           and the staff.  Open item, I believe it's 3.4, deals
           with containment integrity, and currently this was
           discussed last week with the staff.  South Texas has
           agreed to go back, take a look at our PRA for how well
           it deals with latent effects, and to determine whether
           we need to do an additional sensitivity study to fully
           integrate the latent effects into the overall
           categorization process.
                       So, that is still an issue that South
           Texas is working with and has yet to be resolved.
                       The other open item, open item 3.5, deals
           with pressure boundary categorization, and South Texas
           had proposed for Class 1 and 2 piping that we would
           envelope in the risk informed in-service inspection
           categorization process on top of graded quality
           assurance.  Graded quality assurance does take a look
           broadly at the pressure boundary categorization for
           the system.  Risk informed ISI takes a very narrow
           look at specific segments of piping and looks at the
           importance of those individual sections.
                       For Class 1 and 2 piping, we are doing a
           risk informed ISI categorization for those.  We are
           going to take the highest, or we are going to factor
           in if the risk informed ISI categorization comes out
           higher in graded quality assurance, that's going to be
           the categorization that we are going to use.
                       South Texas was proposing using the graded
           quality assurance categorization only for Class 3
           piping.  Currently, our risk informed ISI process is
           not individually categorizing the Class 3 piping. 
           What we have found is that there is good correlation
           between the risk informed ISI results generally, and
           the graded quality assurance categorization approach,
           you know, in most cases we are coming out with the
           same categorization.  So, for the class rate piping,
           we're proposing to use the GQA ranking only.
                       The staff has recommended that we go back
           and perform risk informed ISI categorizations on those
           Class 3 piping, and currently that's being evaluated
           by South Texas.
                       DOCTOR KRESS: Could you explain your
           second sub-bullet under containment integrity to me?
                       MR. GRANTOM: Right.  What we've talked
           about here is, we used large early release frequency
           as a figure of merit for the containment performance
           analysis.  The feeling, or the surrogates for
           protecting against large early release, from an
           equipment point of view we've pretty much done
           everything we can do to protect from late over-
           pressurization.  Most of the stuff that's associated
           in the containment event tree that we use to calculate
           the level 2 for the release categories is
           phenomenological stuff, at least in South Texas it's
           PRA, there's very little equipment that's associated
           with that, it's mostly early/late, you know, burns,
           those type of things.  The question of whether you
           have dry or wet containments have already been
           answered and it's coming out of the plant damage
           states of the level 1.
                       So, we feel like LERF pretty much covers
           most of the stuff for the latent cancer fatalities
           also.  There has been an issue that's been brought up
           about late over-pressurizations.  We run the analysis
           out to 48 hours.  After that, we pretty much are very
           uncertain as to what the outcomes, resources, things
           that may happen in any given situation where you can
           look at those.
                       DOCTOR KRESS: But here, you are not really
           saying, none of these are surrogate for latent
           fatality risk, because it's a surrogate for
           everything. 
                       MR. GRANTOM: Right.
                       DOCTOR KRESS: But, you are saying that it
           encompasses latent fatality because of the next sub-
           bullet?
                       MR. GRANTOM: Right.
                       DOCTOR KRESS: Now, does that next sub-
           bullet deal strictly with the comparison between
           latent fatalities and early fatalities, is that what
           that is dealing with?
                       MR. GRANTOM: Right, the level 3 studies
           that we have done in the past, we don't have a level
           3, but we have taken a comparison for it and took a
           look at that level 3 analyses, show that by and large
           the dominant contributor to public health and safety
           is the large early release.
                       DOCTOR KRESS: The risk of early fatalities
           is higher.
                       MR. GRANTOM: Right.
                       DOCTOR KRESS: But, does that   that
           doesn't   I know there's in Reg Guide 1.174, and it's
           in other documents, there's no risk acceptance
           criteria for something like land contamination, but is
           that to say it's not important, that we shouldn't be
           thinking about it?  You know, if you have late over-
           pressurization, and late release, it may not kill a
           lot of people, because you've already evacuated.
                       MR. GRANTOM: Right.
                       DOCTOR KRESS: It could cause some latent
           fatalities, because you don't evacuate everybody, but
           surely it's going to contaminate the land.  Now, the
           question is, which is the dominant consequence, or the
           dominant risk?
                       MR. GRANTOM: Let me go back to what I was
           saying.  You are right, the land contamination, those
           are still important issues  
                       DOCTOR KRESS: But, do you capture those
           some way in your importance measures, or in your
           subjective deterministic process?
                       MR. GRANTOM: No, not those kinds of
           issues, land contamination, we don't.  We are trying
           to categorize equipment in the station, and that
           categorization of equipment pretty much stops at the
           plant damage state level that leads into the
           containment performance analysis models.  And, it
           doesn't carry on to what other equipment may or may
           not be used to prevent land contaminations or other
           issues that may be associated with that.  It doesn't
           go that far.
                       DOCTOR KRESS: So, if such equipment
           exists, then it might end up in the low classification
           or non risk significant?
                       MR. GRANTOM: It probably wouldn't be
           classified at all.  We would continue to treat it the
           way we currently treat it, but I can't think of an
           example of such a type of equipment. I mean, you are
           talking about severe accident management guidelines
           and those types of issues that come up now, and as I
           said we are very uncertain in the quantified sense of
           the level 2 analysis is to what types of resources
           would be flawless in the event we really did have a
           catastrophic event at a station.  So, we pretty much
           have a pinch point of the plant damage state, where
           all the equipment has been statused to determine what
           the plant damage states are in, and then the
           containment event analysis is pretty much
           phenomenological, that would step you into various
           release categories of whether you had early/late
           melts, early/late burns, phenomenological issues that
           are associated with that that carries to frequencies
           of release categories.
                       We feel like by capturing the equipment  
           we've captured the equipment of what we can do,
           everything after that are things that are either not
           proceduralized, which I'd be hesitant to take credit
           for in the PRA, or they are very uncertain, or they
           would be the result of outside resources coming in,
           you know, beyond the 48-hour time period.  We wouldn't
           capture that.  To answer your question, we wouldn't
           capture that class of components.
                       DOCTOR BONACA: On this subject, you know,
           on the same thing, if I look at Attachment 4 to your
           January 18 letter, "Containment isolation valve is
           typically characterized as low safety significant if
           they meet one or more of the following criteria," and
           the last one is, "The valve size is 1 inch or less,
           that is, by definition the valve failure does not
           contribute to large early release."  And, I was
           surprised by that in a certain way, because it seemed
           to me that in a deterministic judgment you would still
           say, well, it's still an isolation valve that would
           prevent releases maybe in the late phase of an
           accident and we should still categorize it as, you
           know, keep it in our Q list.  I mean, that's the
           judgment I would make when I look at that statement
           that way, and so if you could elaborate on that a bit.
                       MR. GRANTOM: Yes, the categorization
           process would have looked at other things associated
           with it.  It may be a 1-inch valve, but is the piping
           line rated much higher than the containment building
           itself.  Is it in a closed system.  There's even some
            
                       MR. CHACKAL: There's a redundant valve on
           it.
                       MR. GRANTOM:   yes, there's a redundant
           valve that's somewhere else that can be closed off.
                       DOCTOR BONACA: But, it says that
           typically, if they meet one or more of the following
           criteria, and one is this, and that's  
                       MR. GRANTOM: And, that's true, typically,
           you know, for the definition of large early release,
           large has typically been something that we would say
           would have met the containment atmospheric conditions,
           well then, you win out.  This type of thing would  
                       DOCTOR BONACA: See, I'm not troubled at
           all by the fact that you are stepping down your
           quality program for intermediate events, for
           anticipated transients, although certainly we'd be
           interested to know if there is any big penalty we are
           going to see from that, and we don't know.  I don't
           think so, but here you are talking about a containment
           which is   and that's why, you know, I saw this
           issue.  I mean, that's not   we may make a judgment
           that, you know, a 1 inch release, 1 inch size is not
           much of a release, I wonder if other people around the
           plant, how happy they would be with the judgment.  We
           agree it's not a large early release.
                       MR. GRANTOM: Right, but this doesn't  
           the fact that we may have categorized it to low
           doesn't mean that it's not maintained, not   I mean,
           it doesn't mean the controls are off of it, that it's
           left to fail.
                       DOCTOR BONACA: Yes.
                       MR. GRANTOM: I mean, we still expect those
           components to function and do their intended purpose.
                       DOCTOR BONACA: I understand.
                       MR. GRANTOM: So, there's nothing in here
           that assumes that in any way that we expect components
           to fail.
                       DOCTOR KRESS: But, you may lessen your
           frequency of inspection or something like that.
                       MR. SCHINZEL: We could adjust some of our
           processes and maybe decreasing some of the
           inspections, but we would still give ourselves the
           assurance, the reasonable assurance that this
           component is still going to meet its function.
                       MR. LOVELL: Yes, really what you are
           talking about here is how much effort are you going to
           go to verify that it will meet its function.  We
           expect it to meet its function, and we'll put an
           appropriate level of controls on that, but it may not
           be as full level as a larger valve, one of our 48-inch
           valves for instance.
                       DOCTOR KRESS: Do you have a buffer system
           to control iodine re-evolution from sump water?
                       MR. LOVELL: Yes, we have, what is it, it's
           large   trisodium phosphate baskets in the bottom
           containment.
                       DOCTOR KRESS: Would that be classified
           then as non safety significant, your process?
                       MR. LOVELL: I think we rated those low,
           just because it's a very passive system.
                       MR. GRANTOM: And, that doesn't mean that
           we wouldn't check the basket, that doesn't mean
           anything, it just means that the controls would be
           commensurate with the importance and would be
           associated with the proper function and failure by the
           component, that made the component important.
                       MR. LOVELL: If water touches it will work,
           and so we do a surveillance every outage to make sure
           it's there, and we keep that at the same level.
                       DOCTOR POWERS: Do you check the
           dissolution of it?
                       MR. LOVELL: Pardon?
                       DOCTOR POWERS: Do you check the
           dissolution on your tide, the trisodium phosphate?
                       MR. LOVELL: I am trying to remember the
           text back off the top of my head, but if I remember
           right it's just a level.
                       DOCTOR POWERS: It does cake together and
            
                       MR. LOVELL: Right.
                       DOCTOR POWERS:   get tough to dissolve
           after a while.
                       MR. MOLDENHAUER: Should we move to slide
           17, or  
                       CHAIRMAN APOSTOLAKIS: I think we should
           move on with the staff now, and come back.
                       MR. MOLDENHAUER: The remaining two slides
           are just summarization slides.
                       CHAIRMAN APOSTOLAKIS: Summary, yes, I saw
           that.
                       DOCTOR BONACA: I just have one last
           question, and it's just a judgment on your part, you
           clearly are proposing, you know, to take away some of
           the pedigree and certainly step down some of the
           quality of some of the functions, even including some
           instrumentation that goes with the LPS, and I'm sure
           you asked yourself the question, what is the impact,
           if any, on the probability and consequences of
           anticipated transients in the FSAR.  That would be an
           interesting question.  Have you ever thought about
           that?
                       MR. GRANTOM: I don't think that there's
           very much, if any, impact on any of those things,
           because most of   a lot of the things that are in
           Chapter 15 are what most of us would call incredible
           events.
                       DOCTOR BONACA: No, I'm talking about, you
           know, loss of flow events, you have protection for
           that, clearly the protection is merely a focus of this
           kind of evaluation, because, I mean, you know, you go
           to some fueling DNB, well, some fueling DNB.  I mean,
           it has nothing to do with   frequency.
                       MR. GRANTOM: Yes, I mean, the loss of the
           feed water and those types of things.
                       DOCTOR BONACA: So, what are you going to
           do, are you going to take the equipment, for example,
           from a specific trip and maybe put it at a low
           quality.  I mean, some of the instrumentation doesn't
           need to be there.
                       MR. GRANTOM: No, you have to   one of the
           things that I kind of tend to preach on a little bit
           is that this categorization process is intended to
           answer the question that would be associated with
           public health and safety, core damage frequency, large
           early release frequency.  Those components that are
           necessary for that would include loss of feed water,
           some of the balancing plant equipment, are included in
           here.  There is a whole different analysis sitting out
           there that's associated with reduction in transients,
           which I would call a balance of plant model, which is
           a different question to ask at that point in time,
           because now you are talking about losses of
           generation.
                       This process is focused on the regulatory
           application, which is focused on public health and
           safety, and all the questions here that are associated
           with that are to be sure that those components that
           are necessary to ensure public health and safety are
           afforded the proper attention and the proper
           awareness, and that even includes some non safety
           related components that we've identified.
                       DOCTOR BONACA: No, I agree with you, I'm
           only   you realize my question went to the fact that
           you used now two measures of performance, CDF and
           LERF.  The original design on the plant had all kinds
           of measures of performance, okay?  For certain
           transients at a given frequency you could not have
           more than   you could not fuel in DNB.  Well, now
           it's not anymore a criteria, so you are going to have
           some components by definition, and they are not
           unsupported, I'm just trying to assess in my mind what
           is the potential impact, if there is any, on the kind
           of performance which is really intermediate level of
           performance.
                       CHAIRMAN APOSTOLAKIS: But, I thought
           that's what they were doing in the deterministic
           categorization, didn't they say that?
                       MR. GRANTOM: We are not going to go and
           determine that this component is important from DNBR,
           and what's the amount of margin we are affecting on
           DNBR.  You know, the safety analyses and those types
           of things, they stand by themselves, and the
           components and the controls that we have in the
           station, our DNBR curves that we use in operations are
           still predicated based on the safety analysis.
                       DOCTOR BONACA: I understand, but you are
           showing me a table that you are taking one of the high
           pressure trip in the containment and you are calling
           it low safety significant, and I don't disagree with
           you, it may be very much because you have redundant
           functions there.  The result of that will be that it
           will taken out of the Q list.  It will be still there,
           most likely, okay, but you have a lot of freedom in
           doing what you do.
                       So, I think the original question on my
           part of saying, have you ever thought about it, just
           to get a feeling for, you know, what are the
           consequences of taking down some of these existing
           defenses, which may not be important, but I'm saying
           that  
                       MR. GRANTOM: Well, we still expect the
           components to work, and we still intend to buy the
           components, and procure components, and install
           components that are capable of meeting their design
           functions, which include accident conditions and
           normal operations.
                       DOCTOR BONACA: So, you expected the
           liability to be increased.
                       MR. GRANTOM: I would not expect the
           liability to be increased.
                       DOCTOR BONACA: Although, in some cases
           environmental quantification is not anymore a
           requirement.
                       MR. GRANTOM: I would not expect the
           reliability to decrease, I would expect that there
           would be examples to where we may have availability of
           even better components for certain areas, even though
           they may not have Appendix B programs associated with
           it, but for those that we still have to procure I
           would expect that those components will still be able
           to function.  And, we have feedback processes in place
           and corrective action programs in place to assure that
           they  
                       DOCTOR BONACA: Yes, but I think that in
           the long run these are important questions, because I
           think since we are making a big change in the
           regulation we need to   almost like a verification
           process at the end, say, yeah, we feel comfortable
           because, okay, the consequences of what we've done is
           not the reincarnation of  
                       MR. GRANTOM: It goes back to belief in the
           categorization system, if we've done the
           categorization correctly, then if any one particular
           component is not going to prevent the station from
           protecting public health and safety, or of these small
           groups of components.  So, that comes up frequently,
           and your concern is well noted, we are certainly aware
           of that and sensitive to it, but we believe we have a
           robust categorization process.  We put our best people
           doing it.  We put a mix of disciplines, SROs, design
           engineers, system engineers, who know the plant very
           well, and we believe that once it is categorized as
           lower NRS that we can control that through our normal
           processes.
                       DOCTOR BONACA: Okay.
                       CHAIRMAN APOSTOLAKIS: Okay, thank you very
           much.  Please, stick around so we can have a
           discussion later.
                       MR. NAKOSKI: While South Texas is leaving,
           I'm going to introduce the staff that's going to be
           doing the presentation.  I'm John Nakoski, I'm the
           Project Manager responsible for facilitating the
           review.  Doing a presentation is going to be Sam Lee,
           Steve Dinsmore, and Mike Cheok.  Sam Lee is the Lead
           Reviewer for the South Texas Exemption Categorization
           Process.  Steven Dinsmore was the Lead Reviewer for
           the GQA submittal, and Mike Cheok is the Lead Reviewer
           for Option 2 Categorization process.
                       And, with that, I'll turn it over to Sam
           Lee.
                       MR. LEE: Good morning.
                       CHAIRMAN APOSTOLAKIS: A lot of your vu-
           graphs really are of low presentation significance.
                       MR. LEE: Doctor Apostolakis, we wanted to
           be able to point to what we were talking about.
                       CHAIRMAN APOSTOLAKIS: I didn't use any
           scoring scheme, I just declare them.  I'm pretty
           confident that I know what I'm talking about.
                       So, if you can skip them, or go over them
           very quickly, that would help.
                       MR. LEE: Yes.  Much of what we have here
           is repeat of what South Texas folks has given us.
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. LEE: If I may make a couple of points,
           highlight a couple of points, and propose how we
           should end our presentation, and give you an
           opportunity to ask questions.
                       Many of the concerns that you had raised
           regarding the two parallel processes, probabilistic
           process, as well as the expert judgment process, if we
           were to re-term it, in the arena of the probabilistic
           process we share your concern about the use of
           importance measures, but, you know, strictly using
           that, not so much to categorize the components and
           that's it, we rely on them as sort of a screening
           process, if you will.
                       And, as was discussed earlier, the
           powerful argument really for supporting the
           categorization is that if you put these LSS components
           and then multiply them by a factor of ten, and look at
           the results of the postulated increase in
           unreliability, that's a very powerful argument, and we
           really take comfort in the results for that.
                       CHAIRMAN APOSTOLAKIS: Would you put that
           in the rule?
                       MR. LEE: Would we put that in the rule?
                       CHAIRMAN APOSTOLAKIS: Yes, take the
           failure rates, multiply them by ten.
                       MR. LEE: Well, as far as I know, it's
           currently in 1.   oh, multiply them by ten.
                       MR. CHEOK: For option 2, we haven't said
           anything about multiplying by ten, but we did say that
           you have to requantify the change in risk so that your
           change in risk is comparable to what's going to be in
           Reg Guide 1.174.
                       CHAIRMAN APOSTOLAKIS: The problem with
           that, Mike, is that we really don't know what the
           input from the failure rates will be.
                       MR. CHEOK: That's correct, and I think we
           will probably suggest something like a factor of ten.
                       CHAIRMAN APOSTOLAKIS: All right.
                       So, the methods that South Texas is
           proposing will find their way to the rule.  Okay.
                       Can you go to slide 4?
                       MR. LEE: Sure.
                       CHAIRMAN APOSTOLAKIS: Now, this is kind of
           a new definition of RAW, isn't it?  I mean, RAW says
             there isn't such a thing as RAW pump A, plus RAW
           common cause.
                       MR. LEE: You are absolutely right.
                       CHAIRMAN APOSTOLAKIS: There is only RAW
           pump A, and you go everywhere and you set pump A down.
           So, I don't understand what this is.
                       MR. LEE: You are absolutely right, and
           maybe Steve can elaborate on this, but this goes back
           to your December concern about how can you do this,
           and we recognize that this is not an accepted practice
           per se.  However, it does give us some feel for how
           contribution from common cause can be accounted for
           when we risk rank these components.
                       CHAIRMAN APOSTOLAKIS: But, I mean, pump A
           appears in a number of places in the PRA, one being
           the common cause failure of redundant components,
           another being maintenance contributions, right, and so
           on, so the definition of RAW says go to all of these
           terms, set A down and recalculate the CDF and LERF,
           right, that's the definition.
                       MR. LEE: That's right.
                       MR. DINSMORE: Yes, the stated input,
           that's the definition, but sometimes that's difficult
           to calculate, because what you have to do is, you'd
           have to recalculate the PRA for each component and
           turn all its events on to  
                       CHAIRMAN APOSTOLAKIS: True, that's true.
                       MR. DINSMORE:   and the difference, what
           happened with this discussion between the initial GQA
           CCF, the proposed one, and the final one, is we worked
           together with some of the research engineers and they
           determined that if you do that the CCF methodology
           suggested by South Texas to use for the exemption
           request produced a lower number than if you go in and
           actually set each individual basic event  
                       CHAIRMAN APOSTOLAKIS: A higher number you
           mean.
                       MR. DINSMORE: A lower number.  If it
           produced higher it would be okay, because then it's
           conservative, but it was producing a lower number. 
           So, there was a bit of a discussion about that, and I
           think instead of really trying to resolve that issue
           South Texas just decided to go back to the old
           calculation.  But, again, there's a difference  
                       CHAIRMAN APOSTOLAKIS: Oh, not, but I'm
           talking about the old calculation, and this would
           probably be a higher number, wouldn't it?
                       MR. DINSMORE: The old, yeah, the original
           GQA calculation produced a higher number.
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. LEE: Yes, this is the method.
                       CHAIRMAN APOSTOLAKIS: But, the point is
           that RAW is a global quantity.  It says RAW pump A,
           that means everywhere where pump A appears has to be
           down.  There isn't such a thing as RAW pump A failing
           independently, or RAW pump A failing in common cause,
           and that implies that there is.  Actually, this is
           conservative, because you set the term of common cause
           failure equal to one, where in   I mean, if you
           follow the definition it should be just beta in the
           multiple grid, right?  So, Q is one beta, so that says
           it is conservative.
                       MR. CHEOK: Unless you want to add in the
           HEP factor of using pump A in a recovery action, then
           the common cause does not cover that.
                       CHAIRMAN APOSTOLAKIS: That's right.
                       MR. CHEOK: Okay.
                       MR. LEE: The other point that I wanted to
           make about the expert judgment process, without going
           through all the pages, and surely feel free, we can go
           to any page you like, but the other general point that
           I wanted to make with regards to the expert judgment
           process is that the scoring scheme that we are relying
           on has evolved through several versions, and initially
           the staff didn't quite know what the score of zero
           meant, or what the score of three meant per se per
           question, and I think as a result of further
           discussion with the licensee what you see, and if I
           may just put it up for your review is    South Texas
           folks have provided this also   is anchoring, if you
           will, of these scores, and that helps us to say, hey,
           three means this, and two means that.
                       And, if we go further down to the overall
           total scoring scheme, where they take 100 points, and
           we have these ranges of score for categories, one
           thing   or maybe one thing that I can share with you
           that might shed some light is that if you take a
           component per se and you rank the functions, and let's
           say the highest ranking function had a score of two
           for each question, and if you multiply by the
           weighting factor and sum it up, the maximum score, if
           you score a two, is 40.  And, 40 is the high end of
           the LSS.  So, there is some reasoning behind these
           scoring ranges, and a score of 40 for questions that
           you answer two for each one of those, give us some
           level of comfort as to why they used that scheme.
                       CHAIRMAN APOSTOLAKIS: You see, this
           methodology is the same one that SLIM MOD uses for
           quantification of human error, and it's really
           decision theory.
                       MR. LEE: Yes.
                       CHAIRMAN APOSTOLAKIS: That's what it is,
           you have a number of objectives, you weigh them and
           you rate the thing, and multiply and add them up.
                       The most important question here is not
           whether 40 means this or that, the most important
           question is on your slide seven, will these five
           things represent something meaningful, or are we
           repeating the same question five different times with
           different words?
                       If you go to the literature and decision
           theory, this is the key.  In SLIM MOD case, instead of
           critical questions they call them performance shaping
           factors.  The big question there is, are you using a
           set of PSFs that are reasonably different from each
           other.  Right?  That's the issue in human error
           quantification.  Here is a different one.  So, this is
           really the fundamental question, does it really   is
           it really meaningful to ask the same question five
           times?
                       And then, the next step is, of course, the
           weighting factor.  As Doctor Kress said earlier, why
           is it a three for shutdown and so.  I mean, so these
           are the key questions here, and the bigger question,
           of course, is why didn't the PRA find their own here
           someplace at the function level?
                       So now, the question I have for you
           gentlemen is, you have looked at the results of the
           categorization, do you have any problem with the
           results?
                       MR. LEE: When we looked at a component
           level, and we take a component?
                       CHAIRMAN APOSTOLAKIS: Anything.
                       MR. LEE: In general, the examples that we
           have looked at we have not had problems.  Now, there
           are a couple of issues that we are still following up
           on that pertains to the usability of this particular
           expert judgment process.
                       CHAIRMAN APOSTOLAKIS: No, not the process,
           the results.  How was   maybe some of my colleagues
           can help me   how was the Q list developed?  Was it
           a judgment thing within the staff and the licensee?
                       MR. SIEBER: Not really, it was the
           architect engineer.
                       CHAIRMAN APOSTOLAKIS: Yeah, the architect
           engineer.
                       MR. SIEBER: And, it was based on Chapter
           15.
                       CHAIRMAN APOSTOLAKIS: It was, basically,
           you know, you think this, we think that, and we both
           agree.
                       MR. SIEBER: Right.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       How is that different from what happened
           here?  Why can't we say the staff has reviewed the
           results of the STP process, they find them reasonable?
                       MR. NAKOSKI: This is John Nakoski, if I
           could answer that.  What that would require is that
           South Texas complete the categorization for every
           single component, provide us with a list, and the
           categorization and the classification of all of the
           components from which we could then take a sample,
           and, basically, inspect to ensure that those
           classifications are correct.
                       What South Texas is proposing to do is,
           and the staff has agreed to consider is, approve a
           process.  We have, to some limited extent, looked at
           a sample of the risk significance bases documents that
           have the categorization of components, and the basis
           for the categorization of those components, and as Sam
           said, we generally found those were reasonable and
           acceptable.
                       Moving forward with the exemption, though,
           we need to rely on these processes or we need to have
           the complete list of components that then would be
           scoped within the exemption.  At this time, we would
           prefer to go forward with the process.
                       MR. BARRETT: Let me add something to that,
           though.  I think that if you look at the list of open
           items, it's down to three, and, in fact, it's probably
           down to two, really.  And, you might ask yourself, are
           there examples in those two areas of component
           classifications that we at least have questions about,
           and the answer, I believe, is yes.  I think the
           answer, for instance, regarding the whole issue of the
           containment as a defense in-depth boundary against
           late containment failure in core damage accidents, the
           question   essentially, all of the equipment that
           might be related to that, or that you might expect
           would be related to that question, has been
           categorized as low safety significant.
                       So, that raises the question in the
           staff's mind, and that's why that's an open issue.
                       In the area of the, I think Steve could
           probably do a better job on this than I can, I'm
           certain he could, but in the area related to the
           pressure boundary, I think we've seen some examples as
           well of cases where the categorization process has led
           to what we would call surprising results in any event,
           so we are pursuing areas where we believe that there
           is a logical reason for the staff to have questions
           about the categorization process, and where there are
           some examples that raise questions as well.
                       But, by and large, what we see across this
           entire process is a good process, a logically sound
           process that we are comfortable with, that produces
           results.  When we look at those results, that we are
           also comfortable with.
                       MR. NAKOSKI: And, just to add one more
           thought to carry it through, many of the open items
           that we identified were specifically the result of our
           review of how specific components were categorized.
                       MR. DINSMORE: If I may add something, you
           asked earlier if we could do this without PRA, and I
           think the answer would be no, because these questions,
           you seem to be focusing on these questions and how
           reasonable they are, and these questions really only
           categorize stuff that's not in the PRA.  So, we are
           kind of assuming, and we are fairly certain, that the
           PRA is actually modeling most of the real important
           stuff.
                       So, we go into these questions with that
           feeling, that, okay, most of the important stuff is in
           the PRA, we have a way of dealing with it, we think
           it's conservative.  We are pretty sure that the LSS
           stuff that comes out of the PRA is actually LSS.  Now,
           the question is, what are you going to do with all
           these other thousands of components?
                       And, South Texas has proposed to deal with
           it like this, and I think we might not approve this as
           a stand alone, that's just kind of my personal
           opinion.  If you just did this on all the components
           in the plant, maybe we wouldn't really be as
           receptive, but we are just doing this with what's not
           included in the PRA.
                       CHAIRMAN APOSTOLAKIS: But, let's look for
           a moment at what the process that we like is.  We are
           using measures that, perhaps, are not perfect, but at
           the end what really counts is the fact that they
           multiplied the failure rates by ten, including common
           cause terms, you've checked that?
                       MR. LEE: Yes.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       And, it turns out that the delta CDF is
           small.
                       Is that something now that would   I
           mean, for this plant, maybe this is good enough, but
           to say that this will be the way we are going to do it
           in the future, I mean, bothers me.  Why ten and not
           15?  And, why   you know, and what if in some cases,
           you know, the risk of all the sensitivity studies you
           find the delta CDF is unacceptable?
                       MR. CHEOK: I think that all applications
           we have to see the other side of the coin, which is
           what kind of relaxations we are allowing.  In this
           case, it's treatment requirements, and we are going to
           retain function.  So, in this case we feel that a
           factor of ten is, indeed, bounding.  For other cases,
           ten might not be bounding, and the way we define our
           requirements would have to factor in this factor of
           ten, basically.  We have to relate these two
           considerations together.
                       CHAIRMAN APOSTOLAKIS: The factor of ten
           where, Mike?  I mean, these things have distributions. 
           It's a factor of ten on the mean?  That's an
           incredibly high change.
                       MR. CHEOK: Yes, it is.
                       CHAIRMAN APOSTOLAKIS: That the mean
           shifted by a factor of ten.  So, where are you   what
           is the point of reference of the factor of ten?
                       MR. DINSMORE: The factor of ten came from
           discussions with the different   I guess the QA
           engineers and  
                       CHAIRMAN APOSTOLAKIS: Yes, but ten  
                       MR. DINSMORE:    the system engineers,
           and their opinion was that, they said, well, could it
           go up by a factor of two if you stopped doing  
                       CHAIRMAN APOSTOLAKIS:   but, what is it
           that goes by a factor of ten?
                       MR. DINSMORE: The failure rate.
                       DOCTOR KRESS: The mean failure rate.
                       CHAIRMAN APOSTOLAKIS: A factor of ten on
           the mean is you are shifting the distribution way out
           there.
                       MR. CHEOK: Probably up to the 95th
           percentile.
                       MR. LEE: Typically, Doctor Apostolakis,
           typically, I think for South Texas, for most
           components, the 95th percentile is about an error
           factor of three.
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. LEE: So, ten really exceeds that, and
           it is highly conservative.
                       MR. DINSMORE: But, it was a general
           agreement, I mean, most of these numbers, including
           those cutoff values, the 110 and all that stuff, there
           was very many very intense discussions between
           different groups, and the eventual judgment, common
           judgment was that those would bound us, those were
           reasonable.  And, that's kind of where the factor of
           ten came from.  It was just people believed that if
           you changed the treatment like this, and now I think
           it's a bit twisted, that people are looking to make
           sure the treatment will keep it below a factor of ten,
           but there was a common belief that this factor of ten
           would bound it.
                       And, since we were interested in moving
           forward, and everybody agreed that the factor of ten
           would bound it, we used it, and when the result came
           out reasonable we were very happy.
                       CHAIRMAN APOSTOLAKIS: Okay, do you do that
           for the future, can you really put it in the rule and
           say that in the future you want option two benefits
           tell us which components you want to put in the low
           risk significant category, and then do the sensitivity
           analysis and if it works, it works.
                       MR. NAKOSKI: This is John Nakoski again. 
           I think an important part of their categorization
           process is the feedback mechanism that takes into
           consideration increase in failure rates of these
           components, which I believe would keep them well
           within the bounding analysis of increasing the failure
           probability by a factor of ten.  I think that's an
           important aspect of their process and, Mike, correct
           me if I'm wrong, but I think that would be a part of
           the process that would be in the rule going forward in
           option two.
                       CHAIRMAN APOSTOLAKIS: I don't understand
           it. Isn't the basis of the acceptance of this the fact
           that the sensitivity study shows the delta CDF is
           small?
                       MR. CHEOK: That's correct.
                       I guess your question was why do we do
           importance analyses.
                       CHAIRMAN APOSTOLAKIS: Yeah, skip it.
                       MR. CHEOK: Well, I guess the answer would
           be  
                       CHAIRMAN APOSTOLAKIS: Or, they can do it
           in private without submitting it to you.
                       MR. CHEOK:    that's true, but I guess
           the answer would be, if they want the biggest group of
           SSCs possible they would do an importance analysis,
           because if they are just picking and choosing they
           could have picked some high safety significant ones,
           and so they will be dealing with four SSCs as opposed
           to 800.
                       So, if you want to have the most SSCs that
           would conform to some delta risk increase, you would
           use importance analyses.  That's one.
                       The second part of this is that, we are
           also looking for people to identify SSCs that may be
           high safety significant, that may not be treated as
           they should be.  And, in this sense, importance
           analysis would help us identify those SSCs, and I
           guess importance analyses, as flawed as they may, do
           tell you things like defense in depth.  I mean, if you
           have a high RAW, in essence, you can say, hey, look,
           maybe this is a single event cut set.  Maybe this is
           not a event that I want to deal with in the box three
           case.  Importance analysis can also point out some
           components that may not be performing as well as they
           should be in the plant now, Fussel-Vesely was pointed
           out to you, if you have a high failure rate.
                       In essence, I don't think we want to go
           ahead and allow people to put things in box three that
           are already risk outliers.  We want to know that the
           components they are dealing with are, indeed, low
           safety significant from  
                       CHAIRMAN APOSTOLAKIS: But, the RAW really
           has nothing to do with special treatment, because it's
           such an extreme measure, just put the thing down.  I
           mean, come on.
                       MR. DINSMORE: The RAW tells you that the
           increase in the CDF, that this component is not
           functioning.  It gives you a piece of information. 
                       CHAIRMAN APOSTOLAKIS: So, do many things.
                       MR. DINSMORE: Well, we need a couple
           pieces, and that was one of the pieces.
                       DOCTOR POWERS: I wonder if I could come
           back to the slide that you have up there and ask what
           the staff thinks about those weighting factors.  I
           mean, they are kind of remarkable, if you ask me.  We
           have   functions used to mitigate an accident
           transient we'd give it a five, but if it initiates an
           accident we only give it a three?
                       Similarly, if a function   if a function
           causes impact on a safety significant system it gets
           a four, but if it initiates an accident it's still
           only a three.  I mean, that seems remarkable to me.
                       CHAIRMAN APOSTOLAKIS: See, if you want to
           focus on the process, this is the kind of thing you
           have, because now this has to be scrutinized.
                       MR. BARRETT: I think   let me say a word
           about the whole question of the factor of ten, because
           I think if you take   I'll get back to this question
           of weighting factors in a minute   if you do a
           sensitivity analyses using a factor of ten on the
           unavailability, unreliability of every piece of
           equipment that's ranked risk three, LSS or NRS, and it
           comes out acceptable, that basically tells you that
           somehow or other you've bounded the potential impact
           of this, provided, provided that the treatment you
           provide to this equipment assures its functionality.
                       And so, that result, combined with another
           result which you didn't do, namely, that if you took
           every piece of equipment in risk three and set its
           unreliability to one, you know what the core damage
           frequency there would be, it would be something close
           to unity.
                       So, you know that you can't allow this
           equipment   the treatment of this equipment to be
           such that it would have a high probability of failure,
           and you know that you have to concentrate, therefore,
           on things like environmental qualification, where the
           question might be functional versus non-functional, as
           opposed to reliable versus unreliable.
                       So, there's a very important result there,
           it's a qualitative result that comes out of the
           quantitative answer, and, yeah, you can certainly
           question whether there should be a factor of three or
           a factor of ten in the end reliability, but the
           important thing is that you are not   is that if you
           set the unreliability to a factor of ten you can make
           reasonable choices about the treatment of this
           equipment in order to stay within those bounds.  And
           so, you have a decision process that allows you to
           make a coupled decision, a decision that couples the
           categorization process with the treatment process.
                       Now, the question of whether we are
           comfortable with the weighting factors, I think it's
           fair to say we didn't focus on these weighting
           factors.  I think this is a sufficiently qualitative
           process that they could have come in with weighting
           factors that were different.  I think probably if we
           had seen weighting factors that were off by orders of
           magnitude we might have focused on it a little more,
           but since this is, essentially, a qualitative process
           I think we kind of glossed over the difference between
           a five and a three, and I think that's probably a fair
           statement.
                       MR. LEE: Yes, that would be a fair
           statement, but if I may add to that, the difference
           between, say, a function   is the function used to
           mitigate accidents or transients that has a weighting
           factor of five, versus number five, does the loss of
           the function in and of itself directly cause an
           initiating event.  I guess an example that I can think
           of is, if you lose the turbine, which initiates
           reactor trip, does that really contribute a whole lot
           to reactor safety, and the answer is there are safety
           systems there to mitigate that particular initiating
           event.
                       However, if we are talking about, say, a
           safety injection pump, or any other safety equipment
           that is used to mitigate an accident initiating event,
           I think in general that we would find that to be a
           little bit more important than equipment that would
           cause an initiating event.  So, there is some sense as
           to why these weighting factors are the way they are.
                       DOCTOR POWERS: It makes no sense to me at
           all, absolutely no sense to me at all.  There's an
           initiating event, I get excited.  The fact that the
           safety injection pump goes out, and there is no
           initiating event is something I can handle.  I mean,
           it seems to me that if something initiates   I mean,
           it's like saying, ah, we lost the integrity of the
           steam generator tube, oh, well, darn.  Come on, I
           mean, why did it get a ten? 
                       CHAIRMAN APOSTOLAKIS: That's what RAW is
           supposed to do, actually.  I mean, if you do RAW with
           initiating events consistently they run very high.
                       MR. DINSMORE: This is for non PRA
           components.
                       CHAIRMAN APOSTOLAKIS: Presumably, there is
           some correspondence.  I think Doctor Powers is right,
           I mean  
                       DOCTOR SHACK: Yes, but I think the answer
           was, you know, that, one, this really isn't meant to
           be used on components that really   that's not the
           function that's being assessed here really, you know,
           as Mr. Dinsmore pointed out, that's really been
           addressed in the PRA itself, in the truly functional
           sense.  The functions we are talking about here are
           the sort of auxiliary functions of the system.
                       The other answer is, you know, when they
           do go through the PRA and this, they seem to come up
           with comparable answers.
                       MR. CHEOK: And, a good test of this system
           would be for STP to bring this system up for all their
           PRA components and see if using this scheme they would
           come up with similar rankings, or if not more
           conservative rankings.  That would be a good test of
           how robust this system would be, or these weighting
           factors would be.
                       CHAIRMAN APOSTOLAKIS: It's a bit late now
           for that, because the assessment will not be  
                       DOCTOR SHACK: They've mentioned the
           numbers, they've actually made the comparison
           themselves, it's 800 and 846 or something like that.
                       MR. DINSMORE: It's also, we weren't sure,
           as Rich implied, you know, are we going to argue that
           the first one should be four and the third one should
           be five?  I mean, once we start down that path, it
           would be, you know, we should  
                       CHAIRMAN APOSTOLAKIS: Doesn't double
           counting bother you guys at all?  Those things overlap
           like hell.
                       MR. LEE: Is double counting conservative?
                       CHAIRMAN APOSTOLAKIS: I don't know that it
           is.  I don't know that it is.  How could it not be?
                       DOCTOR KRESS: It could not be because of
           where you put the thresholds.
                       CHAIRMAN APOSTOLAKIS: Yes.  I mean, the
           obviously important ones will be counted four times,
           so they will be up there, and then the ones that are
           not that important, necessarily, will go down.  These
           are relative, aren't they?
                       MR. DINSMORE: These aren't relative, these
           are absolute.  They get the score for each function.
                       CHAIRMAN APOSTOLAKIS: The way they do the
           rankings it's relative, when the assessors do it.
                       MR. CHEOK: The relative part of it comes
           from the single component, but once you start adding
           them, I guess you go away from the single component
           aspect of it.  So, when you talk about masking the
           relative part of it, you are doing it at the PRA
           importance measures level.  At that point, that's
           relative, but as soon as you take the single
           importance out of it and start adding them, they are
           no longer   they wouldn't affect the rest of the
           rankings of the rest of the components.
                       MR. DINSMORE: It's an absolute score.
                       CHAIRMAN APOSTOLAKIS: It's an absolute
           score, so some components, which are important, appear
           in all five categories, or four of them.
                       MR. DINSMORE: But, these are functions.
                       CHAIRMAN APOSTOLAKIS: So, they get the 70
             they are functions, yes.  So what, what difference
           does it make?
                       MR. DINSMORE: Well, they do the scoring at
           the function level and they come up with a score for
           the function.
                       CHAIRMAN APOSTOLAKIS: Right.
                       MR. DINSMORE: And, the function is, for
           example, control and ventilation, which is one which
           we looked at, and they get a score for that function
           and they give that a category based on their merits,
           and then they start   when they start going through
           the individual components that support that function
           they start with that function safety significance, if
           it's medium or if it's high, and then they have this
           process to include diversity and reliability and
           include that ingoing from the function to the specific
           component.
                       But, each function is an absolute score,
           and they assign the highest function safety   when
           they start going through the components, they start
           with the highest function safety significant for each
           component.  So, I would say that it has more   it's
           more likely to be somewhat conservative than to double
           count.
                       CHAIRMAN APOSTOLAKIS: Well then, they
           themselves don't trust the process, and they say if in
           any particular category you get a high score, right,
           forget about the total, you look at it.
                       MR. DINSMORE: Well, again, it's a judgment
           process, and these little catches that keep you from
           maybe doing  
                       CHAIRMAN APOSTOLAKIS: Yeah, and it says I
           really don't trust my process.
                       MR. DINSMORE:    or I don't trust my
           process to that fine a degree.
                       DOCTOR KRESS: Why did we settled on these
           particular five questions? For instance, would not the
           defense in depth question in there that says, does
           this function serve to preserve the containment
           integrity, for example, either late or early.
                       MR. LEE: That's a question that the staff
           has asked to the licensee also, and for that
           particular issue we are   hopefully, we are in the
           resolution path in addressing that.  But, you are
           right, that is not explicitly asked in this
           deterministic process, and  
                       DOCTOR KRESS: And, it doesn't show up in
           the PRA process  
                       MR. LEE: That's exactly right.
                       DOCTOR KRESS:    because you are focusing
           on large early release.
                       MR. LEE: That's exactly right.  
                       MR. DINSMORE: We are guided by 1.174,
           which actually doesn't promote this.
                       DOCTOR KRESS: But, 1.174 does say you
           should preserve defense in depth, which gives you a
           1.174 handle to grab a hold of.
                       DOCTOR BONACA: Although, I mean, the
           presentation from South Texas shows that they also
           have a list of questions which has to do with defense
           in depth, and that's why we are asking the question
           about containment, because it seems like that slipped
           through.
                       CHAIRMAN APOSTOLAKIS: Well, that's later
           for the components.
                       DOCTOR BONACA: I understand that.
                       CHAIRMAN APOSTOLAKIS: So, we have a
           situation here where none of the methods used can
           really withstand scrutiny, but the total results
           somehow is okay, right?
                       MR. LEE: No, that is  
                       CHAIRMAN APOSTOLAKIS: Isn't that true?
                       MR. LEE:    no, we have an open item that
           addresses this very question about the containment.
                       CHAIRMAN APOSTOLAKIS: Yes, but there are
           so many others.
                       MR. LEE: And, we are looking at a path in
           addition to these schemes   methods, I should say  
           to address and highlight the importance of containment
           systems.
                       MR. DINSMORE: I think each individual
           point you could obviously argue about.  You could
           argue about whether number one should be five, and you
           could argue about whether the cutoff should be ten,
           and you could argue about whether change in
           reliability should be a factor of ten, and earlier you
           said why do we go through this whole process, why
           don't we just get a delta CDF from them, and if that's
           okay we say fine, do it.  And, I think what we are
           approving is, we are approving kind of everything
           together.  So, you can always find individual points,
           but I think, at least for the GQA stuff, in the end
           everybody that had to agree agreed that it was a
           reasonable process, in toto.
                       DOCTOR KRESS: Would that reasonableness
           encompass the concept that this is reasonable because
           you showed this consistency between the PRA and the
           deterministic results for a significant number of
           components that have already shown up in both, and
           does this reasonableness also encompass the fact that
           when you take the low safety significants and increase
           them by a factor of ten in this case, because it's
           special treatment, that you still don't impact the CDF
           very much or the LERF very much.  I mean, is that part
           of the package of why this is reasonable, and would be
           incorporated in the thinking for the next one that's
           coming in, which may not be, you know, it may have
           different things, it may not just be for special
           treatment, it may be for  
                       MR. DINSMORE: That would be reasonable,
           it's also reasonable, it includes the sensitivity
           studies that make the PRA results a little less
           sensitive to some of the more questionable modeling
           techniques.  It's kind of everything, because, again,
           each individual one, each individual item one could
           discuss for a long time, but eventually you have to
           make a decision, which could be no.
                       DOCTOR POWERS: Doctor Kress, you are an
           expert on defense in depth, let me ask you a question. 
           If I have an initiating event, do I challenge my
           safety systems?
                       DOCTOR KRESS: Yes, you do.
                       DOCTOR POWERS: And, is that considered
           within the context of safety regulations a challenge
           to the defense in depth?
                       DOCTOR KRESS: I would consider it as such,
           yes.  I don't know, I am not expert enough to know how
            
                       DOCTOR POWERS: If I discover, say, a
           failed system, a failed safety system, do I challenge
           the safety systems?
                       DOCTOR KRESS: Yes.
                       DOCTOR POWERS: If I discover it, I don't
           think so.
                       DOCTOR KRESS: Not if you discover it.
                       DOCTOR POWERS: I discover it, if I don't
           discover it maybe I do, but   so I don't   I mean, it
           seems to me that if I operate from a defense depth
           perspective, not only do I turn this table upside
           down, I change the magnitude of the numbers as well.
                       DOCTOR KRESS: Yes, I think that's always
           my   that was one of the reasons I brought for
           bringing defense in depth in as an explicit criteria.
                       MR. LEE: Doctor Powers, in the events
           assessment arena, when we have an event at a plant,
           whether it be an initiating event or unavailability or
           a failure of a safety equipment, we actually quantify
           those risks for the initiating event frequency, where
           the initiating event has occurred we calculate a
           condition of core damage probability for that event. 
           Whereas, in a situation where you have a safety
           equipment that's unavailable due to some sort of
           failure, and you have no initiating event, that still
           basically reduces your safety margin, and you
           calculate a condition of core damage probability for
           that event.  And, depending on which equipment we are
           talking about, one could be higher or lower.
                       DOCTOR POWERS: I think probably if you
           went through that and did it that you could make an
           argument to defend those tables, in the sense   in
           just the sense that you mentioned earlier, that all
           the initiating events that are liable to be triggered
           by this table are going to be relatively mild ones
           because you caught the big ones already in the PRA,
           but it may be also true of those things that are item
           two, you may have already caught the big ones there,
           too, but it still may turn the table upside down.
                       MR. LEE: We did not do that.
                       DOCTOR POWERS: It's a futile exercise to
           carry out.
                       CHAIRMAN APOSTOLAKIS: I suspect that the
           real use of these five questions is in an "or" sense. 
           If you go back to one of the back-up slides from South
           Texas, where they say exceptions, I would say that's
           the rule.  If a weighted score of 25 on any one
           question it's high, weighted score between 15 and 20
           is medium, that probably would make much more sense to
           treat those five questions as being analyzed that way,
           and then the expert panel takes over and discusses it,
           and the medium may become high and so on.  But, when
           you take the sum you are really doing things that fly
           in the face of a lot of people and their work, and I'm
           not one of them by the way.
                       So, this is   you see, that's what I'm
           saying, I mean, Steve makes a point that it's the
           total, and this and that, but you can't ignore the
           fact that individual pieces cannot be scrutinized. 
           You can't ignore that.  I mean, I understand   that's
           why I'm trying to find a way out, that maybe the final
           result is okay, but this is not the weighted sum, this
           is probably treated as an "or" in practice, and then
           it works because you don't have to worry about
           overlapping.
                       DOCTOR SHACK: An "and" is more
           conservative than an "or."
                       CHAIRMAN APOSTOLAKIS: No, no, no, let's
           not put conservative arbitrarily, I don't know what
           conservative means in this case.  "Or" is more
           conservative, because they are telling you if in any
           category you do this  
                       DOCTOR SHACK:  But, the and/or.
                       CHAIRMAN APOSTOLAKIS:    you are out.
                       Oh, yeah, and then what is the other one,
           not, let's put that one, too.
                       MR. DINSMORE: It's inscrutable insofar as
           you can go back and look  
                       CHAIRMAN APOSTOLAKIS: It's inscrutable to
           me.
                       MR. DINSMORE:    insofar as you can go
           back and find out why they put this thing  
                       CHAIRMAN APOSTOLAKIS: Even if it's wrong.
                       MR. DINSMORE:    well, that's right. 
           When we did the audit, at least this provides us with
           a point of discussion.  We say, well, why did you put
           the two  
                       CHAIRMAN APOSTOLAKIS: Yes, but shouldn't
           you guys scrutinize this and say, well, gee, it's
           really an "or" situation here, I mean, instead of
           saying, no, that sounds reasonable, let's accept it,
           and what's worse, put it in the rule.
                       And then, let's take number three, does
           the loss of the function directly fail another risk
           significant system?  What is a risk significant
           system?  Something that has already been evaluated
           with the five questions or what?  What is a risk
           significant system in a methodology that is intended
           to identify risk significant systems?  Isn't that kind
           of circular there?  See, that's the kind of scrutiny
           you have to survive.  I don't understand question
           three.
                       MR. DINSMORE: Well, they were supposed to
           do the   these are maintenance rule questions, so
           that we maybe didn't look a whole lot at the actual
           questions, since they were already in the rules.
                       Again, what I was trying to say was, it
           makes it inscrutable insofar as you can go back and
           say, if they just said this safety significant   this
           function is high, and you say why, well, you know, we
           sat around and we talked about it and we decided it
           was high.  But, when they break it out like this, when
           we did the audit we could go back and ask exactly what
           you asked, for example, well, why is number four in
           this particular function two?  Why isn't it three, or
           why isn't it zero?  And, we did that back and forth a
           bit.
                       So, in that respect it provides a path for
           review, and understanding why they chose   why they
           ended up where they were.
                       CHAIRMAN APOSTOLAKIS: And, I fully agree
           with you.  I think that's the great value of these
           methodologies, but that doesn't mean that we cannot
           question the premise and the basic   I mean, the fact
           that it gives you an opportunity to go back, I mean,
           is very commendable and it's good, but again, I mean,
           we have five questions, if they are treated in an "or"
           gate I would be much more comfortable with that.  And,
           the fact that these are the maintenance rule
           questions, I mean, so what, this is not a maintenance
           rule here.
                       MR. DINSMORE: Well, it gives them some
           validity.
                       CHAIRMAN APOSTOLAKIS: Yes, some validity,
           but, I mean, we are doing something else here.
                       And, I'm really bothered by this factor of
           ten, Mike.  I really don't know where it came from,
           and this is the perennial problem with sensitivity
           studies.  It's like in the old days, you know, boy the
           core damage frequency is ten to the minus 90, and then
           it turns out it is not, and we have to try to prove to
           people that it really didn't matter that it was ten to
           the minus 90.
                       As long as sensitivity studies work,
           everybody seems to be happy, without thinking ahead
           that maybe some time they will not work, and then what
           do you do?  If you have a precedent that you have to
           multiply all your failure rates by ten, which is
           ridiculous in this case.  Ten, wow.
                       DOCTOR KRESS: It would make more sense to
           have a distribution and do a Monte Carlo and get an
           uncertainty, wouldn't it?
                       CHAIRMAN APOSTOLAKIS: A lot of other
           things would make much more sense, but somehow   so,
           that's what I'm saying, that I'm really torn here.  I
           think each method cannot stand scrutiny, yet the final
           result seems to be reasonable.
                       MR. BARRETT: George, let me  
                       CHAIRMAN APOSTOLAKIS: Explain to me how
           one writes a letter that says that.  One sits down and
           writes it, right?
                       MR. BARRETT:    let me make a suggestion
           that in a sense what we are talking about here is two
           separate issues.  We're talking about whether the
           staff has a technical basis for granting these
           specific exemptions for this specific plant.
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. BARRETT: And, South Texas is a unique
           plant in many ways, unique in the quality of its PRA,
           in the redundancy of its systems, and the size   
                       CHAIRMAN APOSTOLAKIS: Yes.
                       MR. BARRETT:    of its containment, and
           all that sort of thing.
                       CHAIRMAN APOSTOLAKIS: And, the sensitivity
           study worked in this case.
                       MR. BARRETT: In this case, I think   I
           hope you feel comfortable, as we do, that having
           resolved the open issues regarding the categorization
           that this is a good categorization as the basis for
           these exemptions for this plant.
                       The second thing on the table, however, is
           that this plant is a first pilot or a proof of
           principle for option two, and a lot of the questions
           you are raising are questions that we should really
           throw in the hopper for option two.
                       CHAIRMAN APOSTOLAKIS: And, I think you
           stated it in a way that I cannot disagree.  I think
           this is exactly the issue.  What worries me is that
           these things will be approved for the future.  My
           concern is not so much here, I mean, you can change
           the words here, because they've already done a lot of
           things that are complimentary, overlap a lot, and they
           give you that warm feeling, but for the future,
           though, I mean, I'm really troubled by this.  Just
           because it worked for one of the more recent plants
           that well run and very redundant and so on, that
           doesn't mean we put it in the rule.
                       Anyway, are there any other comments or
           questions?  Well, first of all, do you gentlemen want
           to add anything?
                       MR. LEE: Well  
                       CHAIRMAN APOSTOLAKIS: At the risk of
           raising more questions.
                       MR. LEE:    that's about the extent of
           our presentation.  At the end there, we have a couple
           of open items that we can go over with you if you
           wish.
                       CHAIRMAN APOSTOLAKIS: But, these are the
           results.
                       MR. LEE: But, the South Texas folks
           already have  
                       CHAIRMAN APOSTOLAKIS: Can you tell us a
           little bit about   I mean, one of you, I think it was
           you, Sam, said that you actually looked at random
           samples of components to see whether you agreed with
           the classification.
                       MR. LEE: As you know, we have quite a few
           staff members working on the review of this, and not
           just us, but from other branches, they have looked at
           this.
                       CHAIRMAN APOSTOLAKIS: Yes, but did anybody
           find cases where there was disagreement, significant
           disagreement, not minor.
                       MR. LEE: And, actually, this was actually
           what led to the open item 3.4, I believe, which is the
           containment systems, and we've looked at those
           components and they were ranked to be low, and we
           didn't understand why they were ranked low, so now we
           are further reviewing where  
                       CHAIRMAN APOSTOLAKIS: But, again, this is
           only because they were using different criteria.
                       MR. LEE: That's correct.
                       CHAIRMAN APOSTOLAKIS: But, for the
           components where the criteria were common   
                       MR. LEE: Yes.
                       CHAIRMAN APOSTOLAKIS:    did you find any
           differences?
                       MR. LEE: We have not.
                       CHAIRMAN APOSTOLAKIS: Well, that's good to
           know.
                       Maybe you can make that a little more
           formal, pick up random components and look at them and
           see, because I think this has to be based on the
           results.
                       Any comments from my colleagues?  Staff? 
           South Texas?
                       MR. SCHINZEL: A couple of comments.
                       Doctor Apostolakis, you made the comment
           about South Texas didn't trust our categorization
           process because of the need for  
                       CHAIRMAN APOSTOLAKIS: You are scrutinizing
           my every word now?
                       MR. SCHINZEL: You are scrutinizing our's.
                       CHAIRMAN APOSTOLAKIS: You have to take my
           comments in toto.
                       MR. SCHINZEL: We do want to say that we
           have full confidence and trust in our categorization
           process.  We feel it's very robust, and the exceptions
           where identified were really identified more as
           backstops to ensure that there would be no masking in
           the overall categorization process.  We recognized as
           we were going through the categorization process that
           there could be the potential where a single question
           could end up with high significance, but because of
           the total score could come out low.  And, we kind of
           treat individual questions both as "or" gates and
           "and" gates.
                       CHAIRMAN APOSTOLAKIS: Isn't it true,
           though, that what you are doing is you are looking at
           all five categories and the scores and then you
           deliberate?  That's really what you are doing.
                       MR. SCHINZEL: We do stand back and say
           does it make sense.
                       CHAIRMAN APOSTOLAKIS: Exactly, which is
           what you should do.
                       Now, let me ask you, would you take your
           methods, everything you've done, edit it a little bit
           and say this is a new rule for option two, for all
           plants around the country?
                       MR. SCHINZEL: Well, I would say that we
           would have to look   to work with the industry to
           make sure that a process similar to this is going to
           be workable.
                       I think what we've proven is that, for
           South Texas, this works well.  I can't say explicitly
           that this exact same process, exactly how South Texas
           did it, is going to work equally as well for every
           other plant in the industry.  But, I do think it's a
           very sound process, it's a robust process.  It's a
           conservative process, and it's coming up with the
           right end result.  And, I think based on it coming up
           with the right end results, that's the springboard for
           moving into option two, and adjusting the treatments
           on these components.  It goes back to the original
           intent of 98.300 that said for the components that are
           low safety significant you ought to be able to reduce
           that treatment and go down to commercial practices. T
           hat's what we certainly feel confident of we can do.
                       MR. GRANTOM: Doctor Apostolakis, we do
           need to take this   and realize, this is the first
           out, first of a kind effort to do this, we are going
           to have lessons learned out of this.  Some of the
           points you brought up are good points.  I think when
           you look at our process of categorization, the key
           elements of it, I think, are translatable to any case. 
           There may be some refinements, some positions, some
           other areas that maybe need to be looked at from a
           lesson learned point of view, but from the overall
           structure of how we are doing this I think it's a very
           good process to go and regroup these components for
           any station, I'd say for any industry.
                       CHAIRMAN APOSTOLAKIS: Any other comments?
                       MR. LEE: I'd just like to make one
           correction.
                       CHAIRMAN APOSTOLAKIS: Sure.
                       MR. LEE: In your page five graph, we
           actually graphed the RAW versus Fussel-Vesely that was
           used.  That number should be 100, not ten.
                       CHAIRMAN APOSTOLAKIS: All right.
                       Now, there are two mediums there, which
           one is the medium-R?
                       MR. LEE: Medium-R is this one.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       MR. LEE: But, for all practical purposes
           in the multiple exemption case, medium is the same as
           the highs, and really the exemption applies only to
           the LSS components.
                       CHAIRMAN APOSTOLAKIS: Any other comments
           from anyone?
                       MR. SCHINZEL: I have a couple comments I'd
           like to make.
                       CHAIRMAN APOSTOLAKIS: Sure.
                       MR. SCHINZEL: From the standpoint, I think
           we recognize that there is conservatism in the
           categorization process.  I don't think necessarily
           that should be viewed as a negative.  It ought to
           garner some additional confidence in the results that
           South Texas is gaining, and based on those results it
           ought to have confidence that we are truly segregating
           those components that are important to safety and
           those that are not important to safety, and then based
           on that go in and adjust the treatments as specified
           in SECY 98-300.
                       So, you know, we recognize the
           conservatism, and I think that that conservatism is
           adding to the confidence of the results that we're
           receiving.
                       CHAIRMAN APOSTOLAKIS: Any other comments
           from anyone?
                       DOCTOR POWERS: I wonder if they had any
           response to my question about an initiating event
           versus some obscure piece of equipment that shows up
           in the Ops.
                       CHAIRMAN APOSTOLAKIS: Is that question
           asked to STP?
                       DOCTOR POWERS: Yes.
                       CHAIRMAN APOSTOLAKIS: I don't think they
           followed it.
                       MR. SCHINZEL: Could you repeat the
           question, please?
                       DOCTOR POWERS: Well, if you are looking at
           something that is called   a loss of some function
           that's called out in the emergency operating
           procedures but doesn't show up in the PRA you weight
           it a five, but if there's some loss of function that
           will produce an initiating event then you have
           weighted three.  I guess I don't understand that.
                       MR. SCHINZEL: There are some functions
           that can be lost at a station that could create an
           initiating event for which some safety systems would
           not be required, a general transient turbine generator
           trip would not require the actuation of any safety
           systems.  So, there could be a whole category of
           components that you'd say, yes, you get an initiating
           event, but you might be able to answer no on the other
           questions.
                       DOCTOR POWERS: So, really, the defense of
           that table is that your PRA is sufficiently big that
           it gets all of those initiating events, you have the
           safety of systems rule reactivated.
                       MR. SCHINZEL: Yes.
                       DOCTOR POWERS: And, that this is really  
           I mean, I think this is a good answer, is that those
           things that are categorized three truly are three.  I
           mean, they are very inconsequential things, and they
           shouldn't be there, whereas, not having something
           available in the procedures that the operator
           anticipates being available, whether he needs it or
           not, is going to be disrupting to him.
                       MR. SCHINZEL: Exactly, yes.
                       DOCTOR POWERS: I think that's a good
           answer, but what it does is, it makes that table
           conditional upon having a sufficiently high quality
           PRA.
                       MR. SCHINZEL: Yes.
                       CHAIRMAN APOSTOLAKIS: One of the lessons
           learned, Rick, is, I think, the presentation of the
           methodology.  I think what is actually being done and
           what you are inviting are not quite the same.  I think
           what is being done is much more comprehensive and
           integrated.  It doesn't rely on any one of   any
           single approach to really make a decision, because
           even with the scores, you look at the individual
           scores, you add them up, you look at that, too, God
           knows what else you are doing.  I mean, that's
           different, that's different from just the presentation
           that says, and we add them up and if it's between 70
           and 100 it's this, because that's not really what you
           do.  You are looking at a lot of things, and I think
           a lesson learned is that when you go to methodologies
           like this, which are really trying to structure the
           process of making judgments, the presentation is very
           important.
                       MR. GRANTOM: I agree.
                       CHAIRMAN APOSTOLAKIS: Okay, any comments
           from the public, members of the public?
                       This is it, thank you very much.
                       (Whereupon, the meeting was concluded at
           12:11 p.m.)

Page Last Reviewed/Updated Wednesday, February 12, 2014