464th Meeting - July 15, 1999

                       UNITED STATES OF AMERICA
                           SAFEGUARDS (ACRS)
                        U.S. Nuclear Regulatory Commission
                        Two White Flint North
                        Conference Room 2B3
                        11545 Rockville Pike
                        Rockville, Maryland
                        Thursday, July 15, 1999
         The committee met, pursuant to notice, 8:31 a.m.
         DANA POWERS, Chairman, ACRS
         ROBERT SEALE, Member, ACRS
         MARIO BONACA, Member, ACRS
         JOHN BARTON, Member, ACRS
         GRAHAM WALLIS, Member, ACRS
         ROBERT UHRIG, Member, ACRS
         THOMAS KRESS, Member, ACRS
         WILLIAM SHACK, Member, ACRS
         JACK SIEBER, Member, ACRS.                         P R O C E E D I N G S
                                                      [8:31 a.m.]
         DR. POWERS:  The meeting will now come to order.  This is
     the second day of the 464th meeting of the Advisory Committee on Reactor
     Safeguards.  During today's meeting the committee will consider the
     Proposed Final Regulatory Guide for Updating Final Safety Analysis
     Reports, Control Room Habitability, Proposed Amendment to 10 CFR 50.55a,
     Report of the Reliability and Probabilistic Risk Assessment and
     Regulatory Policies and Practices Joint Subcommittee Meeting, Proposed
     Plan for the Preparation of the Annual ACRS Report to the Commission,
     Proposed ACRS Reports.
         This meeting is being conducted in accordance with the
     provisions of the Federal Advisory Committee Act.  Dr. Richard P. Savio
     is the designated federal official for the initial portion of the
         We have received no written comments or requests for time to
     make oral statements from members of the public regarding today's
         A transcript of portions of the meeting is being kept, and
     it is requested the speakers use one of the microphones, identify
     themselves and speak with sufficient clarity and volume so they can be
     readily heard.
         I open the meeting by asking if members have any comments
     they would like to make.
         [No response.]
         DR. POWERS:  Seeing none, let's turn to the first item of
     business today, which is the Proposed Final Regulatory Guide for
     Updating Final Safety Analysis Reports.  John, I think you are the
     cognizant member on that.
         MR. BARTON:  Yes, sir.
         DR. POWERS:  And I will ask you to take charge of the
         MR. BARTON:  Good morning.  The purpose of the meeting this
     morning is to review the Proposed Final Regulatory Guide 1.181.  The
     content of the update is Final Safety Analysis Reports in accordance
     with 10 CFR 50.71e and NEI Document 9803, Revision 1.
         The committee last reviewed matters related to Updated Final
     Safety Analysis Reports in December 1997.  At that the time the staff
     proposed issuing a Generic Letter.  In an SRM the Commission sent down
     in June of 1998 they disapproved the proposed Generic Letter, directed
     the staff to work with NEI and other stakeholders to finalize an
     industry guidance document that the NRC could endorse.
         Since then the industry and NRC have been working on such a
     document and today we are going to hear from NEI on their proposal,
     which is 9803, Rev. 1, and then we will hear from the NRC staff on the
     proposed Regulatory Guide to endorse the NEI document.
         At this time I will -- oh, the committee action with respect
     to this, there will be a letter as a result of this presentation today. 
     Now, I will turn this over to Russ Bell from NEI, who will lead the
     discussion on the 9803 document.  Russ.
         MR. BELL:  Good morning.  I have a number of slides to go
     through today and we will try and get through those and get to your
     questions.  I thank the ACRS, it was kind of a joint invitation of the
     committee and the staff to come and speak with you this morning about
     NEI 9803.  The reason it makes sense, I am pleased to say, is because
     the NRC's Reg. Guide on the FSAR Update Rule is essentially go endorse
     the industry guidance, and that is the culmination of a really
     productive interaction between the industry and the NRC to arrive a
     mutually acceptable guidance in this area.
         FSARs -- FSAR updates is one a triad of issues we call -- we
     like to refer to, the other two issues being 50.59 and design bases, and
     at NEI, I work on each of those, and each of those is in a various state
     of completion.  This one is the farthest along.  I am happy to say there
     is more background material on this than there are things left to do. 
     The reason these issues are important is because they are somewhat
     foundational, they touch on all, nearly all the issues we work on at NEI
     and that come before the ACRS.  So it is important, I think, for the
     committee to hear about these things like the one on the agenda today,
     and to understand them.
         So, with that, I will get into it.  I will tell you I want
     to talk about -- I will give you an overview of the guidance itself. 
     There were some changes that we made to -- there were minor changes
     around the edges when we revised the document last month and issued it
     to the industry and to the NRC.  And I will touch briefly on the status
     of implementation.
         In the industry we had a workshop last month which was very
     well attended, this was one of the main -- this and 50.59 were the main
     focuses -- foci of that, of that meeting.
         Briefly through the background, which actually goes back
     considerably farther on this issue than this slide would indicate.  This
     issue really started because FSARs started out 30-odd years ago so very
     different, each one a work of art in itself, unique.  Over the years
     they grew, but, again, they each out started out different.  They went
     from there to being maintained differently by the licensees.  One reason
     for that is there was no guidance on how to maintain them, on how to
     update them.  The Update Rule wasn't even issued till 1981 -- I think
     the Update Rule itself doesn't go back as far as many of the plants. 
     And then the FSAR plays, frankly, a different role at different plants.
         So these factors, coupled with the sheer side of some of
     these documents made it, you know, not too surprising to -- really
     probably to anyone that the NRC and the industry identified a number of
     discrepancies or weaknesses in their FSARs, led to the lessons learned
     reviews, outcomes of the Millstone, Maine Yankee lessons learned, and
     increased focus on the SARs by both the NRC and the utilities.  But
     there was never a safety issue, never a safety issue.
         There is still a -- there is certainly a sense that there is
     a rule on the books says we need to have a SAR.  It really is intended
     to be complete and accurate, as the words -- as that phrase has come to
     be.  And so it was taken seriously that something needed to be done. 
     This situation was tailor-made for the NRC to grant some enforcement
     discretion for licensees to refocus on their SARs and bring them up to
     speed, again, there being really no urgent safety issue involved.  And
     that is exactly what they did.  That enforcement discretion continues.
         The industry worked -- really expedited work to develop a
     guideline last year and we issued it in November, that was Rev. 0.  That
     document was attached to a Draft Reg. Guide.  Public comments came in in
     April.  And we revised the document as a result of that iteration and
     issued it, as I say, in June in a Rev. 1 form, and I think the committee
     has that document.
         I could include on the background here that -- as I just
     mentioned, that the Rev. 1 document was issued, and we did that at our
     June workshop.  Since then we have followed up and sent copies to every
     utility at all our contacts, and copies to NRC with a request to endorse
     the document in a final Reg. Guide this time.
         We got on that path, the staff flirted with a Draft Generic
     Letter, and I think that was last year as well.  But, again, our
     preference was to stay on the industry guidance track and that is
     exactly what we did.
         I want to get into the guidance itself, the main purpose
     again of which is to provide really the first ever guidance for meeting
     the requirements of the FSAR update rule 50.71e, which says basically
     this:  the SAR needs to be updated to reflect new NRC requirements, and
     the effects of changes, evaluations of changes, and new analyses that
     might have been performed as a result of safety issues over the years. 
     It's essentially what the rule says.  There's obviously reporting
     requirements that go along in it, but this is the meat of the guidance.
         But it's not every new requirement, every change, every
     evaluation, or every new analysis that needed to be reflected in the
     SAR, and that's really where the guidance came in.  We in the staff
     settled on -- well, we recognized we needed a set of criteria for
     determining when something needed to go in the SAR.  And we came up
     with --
         DR. APOSTOLAKIS:  Excuse me.
         MR. BELL:  Sure.
         DR. APOSTOLAKIS:  So how often do you expect, how frequently
     do you expect the FSAR to be updated?  Every time there is a change, or
     there will be fixed intervals?
         MR. BELL:  In fact there's two ways to answer that.  With
     the SARs going to electronic formats, the licensees actually keep them
     very nearly real-time.  Once a change is made, approved, signed off, and
     so forth, it can be reflected in the SAR for the utility's own use.  But
     now I can answer it from the regulatory-requirement perspective.  You
     can take up to 24 months in terms of your -- which is generally designed
     to match your fuel cycle.
         DR. APOSTOLAKIS:  So, on another subject, I can tie this
     then to the notion of a living PRA, and since you say you can update
     this very quickly, maybe the PRA can become alive very quickly too at
     regular intervals, right?
         MR. BELL:  Perhaps.
         DR. APOSTOLAKIS:  Yes.
         MR. BELL:  Perhaps.
         DR. APOSTOLAKIS:  Interesting.
         MR. BELL:  This is of course a very deterministic --
         DR. APOSTOLAKIS:  I know.
         MR. BELL:  View of the plant.
         DR. APOSTOLAKIS:  But it's a basis, though.  It has --
         MR. BELL:  Yes.
         DR. APOSTOLAKIS:  All the information that you need.  Not
     exclusively.  There may be more.
         MR. BELL:  The criteria we -- what we said to ourselves, we
     in the staff and with the help of a task force of utility guys, folks,
     and we said well, what is it about the SAR that makes it unique?  What's
     the really important information in there?
         It's really -- we turned up that it's -- the SAR contains
     the -- presents the design bases, the safety analyses for the plant, and
     description to go along with those things provided an adequate
     understanding.  That's sort of a very practical view of it.  It also
     comes from -- you can get there from 50.34b, which is the rule on the
     format or content of original final safety analysis report.  So, you
     know, if you want a license here, you've got to give us this
         These items, the design basis safety analyses and the
     description that goes along with those, are very clearly laid out as
     requirements in the original SAR.  It makes sense that that's the
     critical information that also needs to remain up to date.  So we
     focused on these areas for -- as our criteria for determining which of
     those changes, which of those new requirements, which of those new
     analyses need to go in.
         The guidance itself breaks down, you know, when you have a
     flow chart and there's really just two or three boxes on it.  It's
     really quite straightforward.  It's just that it hadn't been written
     down or thought through clearly.  We've now done that.  In the case of a
     new requirement, did it result in a change to your plan?  Did it produce
     new design basis safety analyses or description that belongs in the SAR?
         Now, not every new requirement does that.  Take one that
     does, the ATWS rule.  Really define a new scenario for the plant that
     was important enough.  The NRC issued a regulation, you know, you shall
     be able to respond to this scram situation or transient without scram.
         DR. KRESS:  Is there any definition of what constitutes a
     change?  Just replace one minor component, that could be considered not
     a change.
         MR. BELL:  In fact, the definition of change actually is in
     the 50.59 world, as you might expect.  And so I would probably point you
     to that.
         DR. KRESS:  It doesn't qualify for 50.59, then it's a
         MR. BELL:  You could have -- 50.59 of course wouldn't come
     into play if the change was governed by, you know, some other rule.
         DR. KRESS:  But you would expect it to be consistent
     with it.
         MR. BELL:  Absolutely.  Absolutely.
         DR. POWERS:  Tom, at the end of a 12-month period you were
     supposed to collect together all these 50.59 changes, and they were
     supposed to appear in the FSAR.
         DR. KRESS:  That what I was --
         DR. APOSTOLAKIS:  So the 50.59 changes do appear in here.
         DR. POWERS:  Yes, I think they have to show up.
         MR. BARTON:  Yes.
         DR. APOSTOLAKIS:  They have to show up.
         MR. BARTON:  Yes.
         DR. POWERS:  They have to show up because they are changes
     in the facility.
         MR. BELL:  Remember, we said that not every change, new
     requirement, or new analysis would show up in the SAR.  In fact -- well,
     let me finish this.  For instance, the fitness-for-duty rule really
     doesn't produce design bases -- so here's a new requirement that would
     really screen out of our process -- a licensee may choose to summarize
     that type of -- or supplement their SAR with that type of information. 
     But we don't see that as coming from the regulation, and we don't
     capture that as a practice that's necessary for the guidance.
         The maintenance rule is another interesting case.  As, you
     know, prominent and provocative as that rule can be, really, it's how
     you maintain your plant, not -- it doesn't go to the core of your design
     bases.  It's not new safety analyses.  And so that too would be an
     optional thing in terms of whether a licensee discusses that in their
     SAR or not.
         The chart on changes isn't much more complicated.  Does the
     change affect existing SAR information, to get to your question. 
     Obviously if a change you make causes a SAR to be incorrect, you've got
     an inconsistency you're supposed to resolve.  But it doesn't just stop
     there, because a change could be of such significance that it could
     produce new design bases safety analyses and require a description to go
     along with it.  So we bring you down into this box, and you'd answer
     that question.
         It's really of significance or, as Joe whispered to me, a
     level-of-detail kind of issue.  And if it meets those criteria, then you
     need to go update the SAR for that change.  So it's not every change. 
     There may be very, you know, there's hundreds of minor changes that
     really wouldn't rise to the level of either affecting the SAR
     information or modifying the design bases or safety analyses.
         Similarly, -- I wish all the issues had flow charts that
     were this simple.  Similarly, for analyses -- now, this would be, you
     know, as a result of Generic Letter or Bulletin perhaps, and you are
     asked to perform an analysis to make sure this system will operate as
     you think it will.  We have -- we, NRC, have identified a new concern.
         A lot of that comes out and doesn't really cause you to
     cause any changes to the plant.  You run your analysis and you determine
     that, no, my design -- I hear your concern, but my design is fine as is. 
     You respond to that Generic Letter or Bulletin, but, really, there is no
     impact on the SAR.
         The other case certainly may be, and there are examples both
     ways, where NRC has identified an issue that perhaps wasn't well handled
     in the existing design, it led to a design change and that design change
     would get -- if it involved new design bases, safety analyses, et
     cetera, would get it incorporated into the SAR.
         I have, let's see, a couple of examples, and I apologize for
     not bringing a set of slides, but do they have their packages of slides
     yet, Mike?
         MR. MARKLEY:  Yes.
         MR. BELL:  Okay.  In there, -- then I won't be too ashamed
     to put this up.  In there are some examples, and you can look at these
     as we talk or at your convenience later.  We talked about the first two,
     Generic Letter on testing of safety-related circuits.  Here is a case
     where a licensee was asked to verify that the circuit design met the
     surveillance requirements.  They went and did that, found everything was
     fine and there was no change to the SAR.
         MR. BARTON:  Now, if the licensee determines as a result of
     that he had to make a design change to the plant, then he would have to
     reflect that description in the SAR?
         MR. BELL:  It is possible.  Again, it would be a level of
     significance thing.  This seems to involve some potential inadequacy of
     the surveillance requirement, and that may be a level of detail, the
     type of information that would not need -- that isn't now reflected in
     the SAR.  It doesn't sound like design bases or safety analyses and
     wouldn't rise to the level.
         Certainly, if they made -- if this circuit design was
     described in the SAR or the surveillance requirement that needed to be
     changed was described, and they made a change, obviously, you need to
     come back and fix that.
         DR. KRESS:  The shortcut description of your flow diagram
     might be --
         MR. BELL:  Shorter?
         DR. KRESS:  Yes.
         MR. BELL:  Great.
         DR. KRESS:  I will give you a one-liner.  If the change
     makes your FSAR wrong, then change it.
         DR. APOSTOLAKIS:  What is wrong?
         DR. KRESS:  If you read it, you would have a wrong
     impression of the plant.
         MR. BELL:  We would only complicate it somewhat more than
     that because there may be new information that comes along.  You know,
     station blackout, a whole new genre of discussion wasn't even in there
     before.  So the fact that you added a blackout diesel and change -- it
     wouldn't make the SAR wrong necessarily, but it would not be complete
     any more, we would say.
         DR. KRESS:  Wouldn't be complete.  That is a little
         DR. APOSTOLAKIS:  Was there an answer to your question about
     what is a change?
         MR. BELL:  That is one answer, if it affects your SAR.
         DR. KRESS:  It affects your SAR, then it is a change.
         MR. BELL:  In this context.
         DR. APOSTOLAKIS:  It is almost circular.
         DR. KRESS:  That is a circular.
         DR. APOSTOLAKIS:  That is a definition of change.
         MR. BARTON:  There is a definition in the NEI document, 612,
     which talks about what kind of changes, what are changes.
         DR. APOSTOLAKIS:  So it does not define, it just gives
         MR. BARTON:  It describes them.
         MR. SIEBER:  It is my understanding, though, that you are
     not limited to some minimum set of things that you can put in the SAR.
         MR. BARTON:  That's right.
         MR. SIEBER:  An example would be the mini-flow.  It may not
     be described in the SAR, the plant may be adequate.  When you analyze
     it, you can determine that it is adequate.  But that analysis becomes
     part of the design basis.  It really should be reflected in the SAR, at
     least from the standpoint of future use as a reference to say let's not
     remove this sometime in the future.
         MR. BELL:  Absolutely.
         MR. SIEBER:  So the SAR continues to grow partly by
     regulation and partly by the licensee's desire to have a complete
     description of the plant.
         MR. BELL:  I think that is a good summary.  Obviously,
     changes include things that are NRC inspired, like the mini-flow issue,
     Bulletin 80.04, but this last one is a change the utility decided was
     needed, the high-point vents on the safety injection line.  This went to
     functionality, operability of the system and the utility determined that
     it rose to the level of the type of description that you would need to
     supplement your SAR with.
         These are the examples that -- well, we presented these at
     actually our workshop in the fall of last year, so these are the types
     of things that we are putting out in front of the utilities to provide
     them guidance.  We have supplemented these somewhat with some more
     utility-specific experience.  We did that in our last workshop.  But
     similar to these, this is what the utilities are hearing.
         And we can come back to that, but I can -- there is a whole,
     there is another part of the document and we call it Appendix A.  We
     wanted to distinguish it from the guidance itself, the guidance that is
     there to help you meet 50.71e.  Appendix A deals with optional
     modifications you may want to make to your SAR.
         The other thing utilities are doing now, it is kind of
     satisfying, I really think they do not have blinders on, they are not
     merely checking the accuracy, if you will, in a pure sense of the SAR. 
     Does the plant look exactly like I describe it here, or do we operate it
     exactly?  They are taking this opportunity, and some resources have been
     given them from their management because of the tension of this issue,
     to make some real improvements.  And 9803 I think is important, it gives
     them some tools to help them do that.  It lets them reformat things.  It
     lets them remove some dead wood.  It lets them simplify some of the
     information and this is going on, I think it is all to the good.
         Many utilities make to make this -- as I said, the role of
     the SAR is different depending on where you go, but many utilities want
     to make it more integral to what is going on.
         Obviously, if you do a document, you put it on the shelf and
     you never go to it except every 24 months, you have kind of designed
     yourself a problem.  On the other hand, if you use that document more
     and more on a daily basis or it becomes a box on your flow chart for
     configuration management, then it is much more likely to stay accurate
     and up to date.
         So these kinds of things are going on, and I think 9803
     gives them some tools.
         DR. APOSTOLAKIS:  Let me ask a naive question.  Why do we
     have to do all this?  Why do we need guidance when to change the FSAR
     and so on?  Do other countries do this, or is it the unique legal system
     we have here?
         MR. BELL:  I tell you, we never did an international --
         DR. APOSTOLAKIS:  Isn't it a waste of time to spend
     resources on reformatting the FSAR?
         MR. BELL:  Well, the simple answer is there is a rule on the
     books we have to meet.  Without guidance, it can be interpreted as any
     new requirement, any change, any new analysis needs to go in.
         DR. APOSTOLAKIS:  But I mean the issue --
         MR. BELL:  But that was really no one's intent, not ours or
     the staff's.
         DR. APOSTOLAKIS:  The industry has used in another context
     the words "good business practice," QA and so on.  Would it not be good
     business practice to have an updated FSAR without the regulations
     requiring it?
         MR. BARTON:  No, George, I think you found during the
     Millstone investigation that that wasn't really going on.  People were
     -- it was varying degrees of licensees doing various things to FSARs. 
     Some of them doing a real good job keeping it up to date.  Some of them
     hadn't updated them for a long time.
         DR. APOSTOLAKIS:  But the rule existed.
         MR. BARTON:  Even though the rule existed.  The rule existed
     but, you know, I don't think it was really looked at.  There was not a
     focus to the agency.  Inspection guys were not really looking at that in
     a lot of detail.
         DR. APOSTOLAKIS:  Isn't it a bit sad, though, that we have
     to regulate this kind of thing?
         DR. POWERS:  Well, I think you raise an interesting
     question, George, when you say, what about other countries?  We know
     that, for instance, in several of the European countries that the
     general rule is that the plants be safe and at the state of the art all
     the time.  Now, in practicality that means that at a frequency of about
     ten years, it is different for different countries, but a fairly
     exhaustive examination is done and there is not such a thing as a
     backfit rule.  If the technology has moved on, then they update, and
     they were fine.  It is a fairly big undertaking in Germany when those
     things go on.
         I think it would be interesting to explore some of these
     alternative approaches to this issue.  Now, is it necessary?  Let me
     point to the experience with the DOE reactors where, indeed, there was a
     Safety Analysis Report that was written at the time that the reactors
     were prepared and there was some effort to keep it up to date for four
     or five years, but then it fell into a forgotten dustbin and we started
     adding improved systems on systems on systems, and it quickly became --
     when the guy that had it all in his head retired, the whole house of
     cards started coming down because you literally had conflicts in systems
     and whatnot.
         DR. APOSTOLAKIS:  That is not good business practice.
         DR. POWERS:  You are absolutely right.
         DR. APOSTOLAKIS:  What I am saying is that it is common
     sense to have a central document with all this information in it.
         DR. POWERS:  Well, I think when you chased it down to try to
     find out why it was not done at DOE, -- because people at DOE are not
     stupid, and they said, well, it makes common sense to keep some
     documentation of where all the piping is and things like that in the
     plant, -- you found out that there is a finiteness of resources, and
     there is no penalty associated with skipping the update one year.  And
     you can skip the update one year every year, and every year the penalty
     associated with it is still in the future, but someday it does
     eventually catch up with you.  And that is -- I think that is the
     problem is that there is no immediate penalty associated with deferring
     it one year.
         MR. BARTON:  Jack, did you have something to say?  You look
     like you want to jump in here.
         MR. SIEBER:  Yeah, I guess there is a number of issues. 
     Number 1, the SAR in most utilities is the primary document that is used
     to make changes under 50.59.  So that becomes a reference both for the
     NRC, all the oversight committees, the safety review boards, the design
     engineer, as the basis of design information in the plant.  Not
     everybody did it and regulation regulate to the worst performer, and
     that is unfortunate, but that is the way it is.  And so that is why you
     end up with regulations like this.
         DR. APOSTOLAKIS:  Well, how about if you say that if you
     want to use 50.59, you have to have an updated FSAR and leave it at
         MR. SIEBER:  You use it every day.
         DR. APOSTOLAKIS:  And it will be updated, I can assure you. 
     It is just that this proliferation --
         DR. POWERS:  Clever, George.  Clever.
         DR. APOSTOLAKIS:  This proliferation of regulations, I mean
     to tell people to update a document that they need to use anyway in
     other regulations.  Didn't the Vice President advocate simplicity in
         MR. BARTON:  Yeah, and they keep passing new laws all the
     time, George.
         DR. KRESS:  Is that that guy from Tennessee you are talking
     about?  That guy from Tennessee, the one that invented the Internet?
         DR. APOSTOLAKIS:  From Tennessee, yes.  Do you discount the
     pronouncement because he is from Tennessee?
         MR. SIEBER:  It seems to me that before they passed the
     Update Rule, it was typical that utilities didn't update.
         MR. BARTON:  That's right.
         DR. UHRIG:  That's right, they didn't.
         DR. APOSTOLAKIS:  So how did they use 50.59 then?
         MR. SIEBER:  Good question.
         MR. BARTON:  Don't ask, George.  Don't ask.
         DR. UHRIG:  Well, I can tell you what we did for many years. 
     We had a finite set of documents we kept up to date, there were like 300
     diagrams and drawings were literally up to date, and that was what we
     used.  It was not the complete FSAR.  FSAR was a historical document
     until it was required to be brought up to date.
         DR. APOSTOLAKIS:  I understand that, but still, I am at a
     loss understanding why we have to regulate every little --
         MR. MARKLEY:  George, I think one of the problems you run
     into with this is that there is a distribution in the population of the
     FSARs.  Some of them are three volume sets and some of them are 30
     volume sets.  And the level of detail in those, I mean if you have a
     very scant FSAR, that changes the level of depth you would theoretically
     have to go through in doing your 50.59.
         DR. APOSTOLAKIS:  But this rule doesn't help us with that. 
     It doesn't tell you to have a uniform set.
         MR. MARKLEY:  No, no, no.  This is --
         DR. APOSTOLAKIS:  It just tells you make sure that what you
     have is up to date.
         MR. MARKLEY:  Right.
         MR. BARTON:  And it gives you guidance.
         DR. APOSTOLAKIS:  So it doesn't apply here.
         MR. BARTON:  And it gives you guidance as to what you have
     to consider in updating, and it gives you options on what you don't have
     to put in the SAR.
         DR. APOSTOLAKIS:  Well, has anybody ever thought that maybe
     this is part of the intrusiveness of the regulations that we are trying
     to reduce?
         MR. BARTON:  I don't think so.
         DR. APOSTOLAKIS:  No.  Well, if you guys say it is okay, who
     am I to --
         DR. KRESS:  It doesn't sound like a big deal, George.
         MR. BARTON:  No, I think this guidance is --
         DR. APOSTOLAKIS:  Well, we are spending an hour-and-a-half
     talking about it.
         MR. BARTON:  I mean this is good guidance, you get some
     uniformity.  I think this is good guidance.  You get uniformity across
     all licensees as to, you know, what is important to keep and what is not
         MR. MARKLEY:  Right.  And it enables them to look past hat
     level of detail problem that they have got and wonder how they are going
     to deal with it from one site to the next.
         DR. APOSTOLAKIS:  Well, I am impressed by the unanimity of
     the opposition, so --
         DR. POWERS:  Well, again, George, I think that it doesn't
     hurt for us to spend some time thinking about are there -- not in
     connection with this particular issue, but, in general, for us to think,
     are there alternate paradigms that could be explored here?
         DR. APOSTOLAKIS:  Yes.  Exactly.
         DR. POWERS:  And it might be something that we want to do
     with our -- interrogating our quadripartite partners to understand a
     little bit more about their rationale and approaches on this, because it
     may well be that in the future an alternate paradigm is more useful to
         DR. APOSTOLAKIS:  Right.
         DR. POWERS:  Especially if the uses that we put the FSAR to
     in the course of the operating of the plant evolve in the direction of
     greater use of risk.
         DR. APOSTOLAKIS:  And we do have an alternate paradigm in
     this country.  We never really -- we never required the utilities to
     have to upgrade their IPEs and have a good PRA.  But in 1.174 --
         MR. BARTON:  But you are ratcheted.
         DR. APOSTOLAKIS:  -- we are saying if you come to us using
     risk arguments, you had better have a good PRA.  So you can do the same
     thing with 50.59.  Do whatever you like with your FSAR, but if you use
     50.59, it had better be good.  Then you solve your problem and you don't
     need an additional rule.
         DR. POWERS:  Well, I am not sure that you solve your problem
     because then you get trapped into the question of -- what is good?  And
     that is what these gentlemen are trying to answer is, what is good?
         MR. BARTON:  Right.
         DR. APOSTOLAKIS:  We will have to have the ASME issue a
     standard.  What is a good FSAR?
         DR. POWERS:  Well, their track record is not good enough
     right now for me to jump on that one.  I think I will rely on NEI.
         DR. APOSTOLAKIS:  Anyway, you know, I managed to unite
         MR. BELL:  I appreciate that.
         DR. APOSTOLAKIS:  Never have so many been against one guy.
         MR. BELL:  I had a couple of slides that went into a bit
     more about some of the guidance that went along with the modifications
     that should be made.  Don't take it out if it was required to be there. 
     Make sure you have a disciplined process.  And there are some examples,
     and you are welcome to peruse that.
         But I thought I would move on to -- and this is just the
     only slide I have on this subject.  Again, the basic guidance we issued
     last November held up very nicely through the initial trials, that when
     people tried -- different utilities tried to use it, they fed back to
     us, gave us some feedback.
         In addition, we had the public comment period, some
     suggestions from the NRC, and we rolled up all of those into Rev. 1. 
     And, basically, none of the fundamental guidance changed.  The NRC
     thought it worthwhile to make very clear that, although this document is
     not, you know, a probabilistically based document, there may be some
     risk significant information in there that is not otherwise required,
     per se, to be there.  Well, you just shouldn't remove that type of
     information, and so that we included that kind of admonition.
         DR. POWERS:  George has raised the question of the PRA that
     some plants have and maintain.  There is a variability, but some of them
     pay a lot of attention to the PRA that they use nowadays.
         And I guess I'd ask the question, is their information
     incorporated in the PRA?  They cannot be found in the FSAR with regard
     to hardware procedures and the like.
         MR. BELL:  I would think so, because --
         DR. POWERS:  I think so too.
         MR. BELL:  The FSAR was so design-basis-event driven.  All
     the safety analyses are focused there, and all the previous chapters are
     about the systems relied on in the safety analyses.  And so in terms of
     how to use those systems differently in response to severe accidents, I
     would imagine there's --
         DR. POWERS:  One of the critiques that has come about the
     IPEs, and I too make the distinction between the IPEs and the PRA,
     because I believe they're two very distinct things nowadays, is that the
     IPE submittals sometimes did not reflect the plant as it is.  And I
     wonder -- not in this, but if I was sitting here looking at Rev. 6 on
     this, would we be saying and information used in your PRA if you have
     one should be in the FSAR?  Is that an evolution that we're making or
     should make?
         MR. BELL:  I don't know.  My own reaction is if we go to a
     much more risk-informed world, the FSAR would be more of an anchor
     around our necks than I think something that could be supplemented and
     tweaked and made useful to serve that new approach -- you know, I don't
         DR. POWERS:  What you're saying I think is, okay, the FSAR
     can become an anachronism and some other document becomes the source
     book, or the alternate view is the FSAR and its structure and what not
     evolves to keep up with the changes.  And I don't know what the right
     way to go is, but I think we have to think about that.  Maybe not today,
     but certainly --
         DR. APOSTOLAKIS:  But if you did this, Dana, would then that
     information from the PRA to the FSAR become part of the current
     licensing basis when in fact now it may not be?  That would be a legal
     implication of that.  And the industry may not want that.
         MR. BELL:  And we've always felt it important to leave a
     pretty hard line between the FSAR and the IPEs and PRAs, and never the
     twain shall
         DR. APOSTOLAKIS:  Maybe --
         DR. KRESS:  I think the PRA eventually ought to become part
     of the design basis.
         DR. APOSTOLAKIS:  Sure.
         DR. KRESS:  Because it spells out the equipment
     reliabilities and the -- and I know it's pretty severe, but --
         DR. POWERS:  Somehow I think we've got to explore some of
     these thoughts for the Commission, not for today, but to keep in their
     mind for the coming years, as they progress along on this
     risk-informed -- I think something has to change, because I think I
     agree with you that as design bases that we've used in the past become
     more and more anachronistic, the FSAR really could become just a dead
     weight hanging off the side of the licensee.
         The aspect of the FSAR that says the pipe is connected here
     and the wiring goes here, I don't think that ever goes away.  But the
     chapter 15 becomes something that it's crazy to keep up if you've gone
     into a completely risk-informed regulation.
         I think we ought to explore this.
         MR. BELL:  I was certainly talking out of turn, but I think
     I agree with you, Dr. Powers, and there are obviously a number of
     discussions going on about that brave new world that we're probing.  I'm
     not sure they've talked about the role of the SAR.  I'm not aware that
     that --
         DR. POWERS:  I don't think so either, and that's why I'm --
     maybe sometime in the future we can get together and just have a
     collegial discussion if you guys have some thoughts on this area.
         MR. BELL:  Good.  In terms -- oh, let's see.  This term
     "incorporation by reference," what is the SAR, well, if you've
     referenced a document in the SAR, is that part of the SAR itself?
         Well, the answer, and the lawyers help us on this, no, the
     term of art is you need to so-call incorporate it by reference in the
     SAR and use those explicit words.  Otherwise you've simply provided
     additional information that the reader can go to.
         What came out and what this document has helped clarify is
     people need to be careful.  I mean, we've misused that term over the
     years.  We want you to go incorporate that reference into your SAR. 
     Well, did you mean you want it to become part of the SAR and subject to
     50.71(e) reporting, and update it and change pages and oh, it's subject
     to 50.59?  Well, no, I didn't mean all that, I just want you to put that
     information.  Okay, now I understand.
         So I think one healthy thing that's come about is a greater
     understanding of that term of art.  Not everybody liked it, because they
     had been using the term a bit loosely, and now they may have to scrub
     their SARs for some information that appears to be actually part of the
     SAR incorporated but was really never intended to be.  So --
         DR. POWERS:  Yes, but I think we still need to allow people
     writing the SARs to cite additional information to clarify what they're
     talking about without having to keep that in 50.71.
         MR. BELL:  Absolutely.  The purpose, as someone said, it's a
     reference document.  And if you force me to take out all the references
     to other useful -- it becomes much weaker for that purpose.  We again --
     as a result of the comment period and the early implementers we amassed
     25 questions and answers that we distributed with the revised guidance. 
     We shared those with the NRC staff informally and got their informal
     buy-in that we seemed to be giving, you know, the right answers to those
     kinds of questions.
         We had the industry workshop in June, as I say.  Licensees
     are working within the schedule of the enforcement discretion.  The
     enforcement discretion begins to phase out next April 1 for
     risk-significant information in the SAR.  So people who are able to
     identify that are concentrating there.
         MR. SIEBER:  Will all licensees be complete in your
     estimation by the time enforcement discretion goes away?
         MR. BELL:  My sense is yes.  In fact, many I think will be
     ahead of schedule, some completing the whole review by April 1 when it
     only begins to phase out.  So they've been working on this for some
     time, you know, as you know.
         But the guidance -- let's remember the guidance isn't even
     endorsed yet.  So there's a chicken and egg here, but we're able to tell
     people that look, the staff and we are of like mind.  It's already gone
     through the public comment process.  You should be using it.  So --
         DR. KRESS:  Can the updated FSAR be strictly an electronic
     version, image on a computer or CD?
         MR. BELL:  In fact, I'll let the staff speak to that.  Their
     whole ADAMS program, which they've probably spoken to you about, as --
     you know, they focus on the SAR, you know, somewhat, and particularly
     because of its unique, you know, size, importance, and so forth.  But I
     think folks will be switching over to electronic submittals.
         DR. KRESS:  It's a lot easier to update.
         MR. BELL:  Absolutely.
         MR. BIRMINGHAM:  I think -- Joe Birmingham.
         I think that what we're seeing in ADAMS right now is
     preliminarily that yes, we can go to electronic FSAR updates.  We're
     kind of in the stage of working out the details.  There are some
     concerns about how, you know, how soon is it transmitted and how valid
     is that transmission that we have to resolve.  But once those are
     resolved, I think we're looking to try to go that way.
         MR. BELL:  Some of the utilities are making those types of
     voluntary modifications to streamline, improve their document, and I
     think again using the resources that they've been given to make some
     real improvement in their overall update process.
     In a configuration management sense, bringing some information
     technology to bear to take advantage of the electronic update and
     submittal options.
         This is just what we've been talking about.  Utilities are
     focusing on this linkage here.  There ought to be like a break in this
     line.  Remember, this document could be up to 30 months behind this
     configuration because they don't need to submit but every 24 months, and
     they need to have a cutoff date six months prior to the submittal to
     prepare the submittal and so forth, so -- at least that's the way the
     rule is written.
         While this is the focus of their FSAR reviews, they are
     taking a look at this whole process, which smacks of good configuration
     management, good business, and looking at that whole process.
         So this is my last slide.  It's been a very successful, I
     think, interaction with the staff.  We had common goals.  There was no
     urgent safety issue, and it allowed for, you know, practical solutions
     to be arrived at.  The result, I think, is effective guidance is out
     there and helping people.  It seems to be well received.  And the SARs
     and the whole process for maintaining them I think are the better for
         So I think it's a success story.  One of our three issues in
     our triad has gone very well.  And the other two are coming along, as I
     say, at their own pace.
         What questions can I answer?
         Thanks very much.  I think the NRC is going to fill in with
     the status of the reg guide, and so forth.
         MR. BIRMINGHAM:  Yes.  I am Joe Birmingham, in the office of
     NRR, and I'm just going to present the status of the Reg Guide 1.181. 
     The staff proposes to endorse NEI 98-03, Rev. 1, without exception.  We
     have a regulatory position of five parts.  One, that NEI 98-03 provides
     an acceptable method for complying with 50.71(e).  Endorsement will not
     extend to the documents that are referenced within NEI 98-03.  The
     examples in NEI 98-03 are for illustration only.  And the existing
     commitments to updated FSAR content and format must continue to be met,
     unless the licensee chooses to modify the existing commitments.  And
     five other methods are also acceptable.
         We did have 14 public comment letters on the Draft Guide
     10-83.  Thirteen were from licensees.  We had one from NEI.  Of these 14
     letters, we felt that we had about four substantive comments.
         There were some comments received during some public
     meetings we held to discuss NEI 98-03.  The four substantive comments,
     Russ actually talked about -- but one was incorporation by reference. 
     As the ACRS has already discussed, this needed to be worked out,
     licensees need to be able to reference a document without having to
     maintain it to 50.71e standards, or those documents that the NRC is
     requiring to be maintained at those standards has to be clearly
         The concern, the staff found it acceptable for reference
     documents incorporated by reference to be with the staff on file.  We
     had a concern about the retention of information associated with
     risk-significant structures, systems, and components.  We were afraid
     that these would be removed from the updated FSAR, and we felt that in
     the future one, as we go more and more risk-significant, risk-informed
     regulation, that this type of information was needed, necessary.  NEI
     added a statement to Rev. 1 to indicate that this was not the intended
     purpose of NEI 98-03 to remove that type of information.
         Another comment was on removal of commitments.  Staff was
     concerned that it could be interpreted in NEI 98-03, Rev. 0 that you
     could remove all commitments.  NEI did change Rev. 1 to indicate that
     those commitments which were needed to meet the required understanding
     of safety systems and analyses, that those kind of commitments could not
     be removed.
         There was quite a bit of discussion on removal of drawings. 
     We felt -- were concerned that to allow the drawings to be removed and
     have simplified schematics would improve the SAR, but we were also
     concerned that some of the information in those drawings could be --
     that was pertinent could be lost.
         NEI addressed this by adding a statement that the drawing
     could be removed only if two conditions were met.  One, that the drawing
     was not required by an existing NRC commitment, and, two, which was
     perhaps the one that was the crux of this, the information in the FSAR
     provided sufficient understanding of the facility's design bases, safety
     analyses, and operations to compensate for that removal.
         DR. POWERS:  That's the thing that caused me the most pause. 
     On those occasions when I plow through FSARs on particular issues,
     frequently I find redundant drawings, but usually I find one drawing I
     can interpret without going back and really researching the text to
     understand it.  And the second drawing just makes it clear as a bell. 
     Whereas I'll admit it's redundant, it helps me quickly ascertain what
     I'm trying to find.
         Now, whether I can find what I'm looking for or not is
     probably not a big concern to either the staff or the licensee, and
     shouldn't be, but I worry about trying to make the FSAR like a
     mathematical proof, maximizing the terseness of it by minimizing the
     amount of information flow.  You know, it causes me pause.  Clearly what
     you establish in regulations and regulatory guides is the minimum
     necessary, but on the other hand I think it would be unfortunate if it
     took Talmudic scholars to understand the FSAR.
         MR. BIRMINGHAM:  We agree, and that's the purpose of trying
     to get these two criteria in there, to make sure that the understanding
     is still there.  We feel that there are parts of the drawings that can
     be deleted fairly readily that aren't really pertinent to the
         DR. POWERS:  There are some of them in there that are
     absolutely unintelligible, because they've been shrunk, they've been
     copied excessive numbers of times and what not, and all the notes on the
     drawings -- you can't read them anyway, why have it there?  I mean, the
     sketch is far better than the actual drawing.  But on the other hand, I
     would have relished if in addition to those two criteria you'd said
     something like it's worthwhile to remember communication is at least one
     of the objectives of the FSAR.
         MR. BELL:  In fact, the words here are:  Drawings should
     generally not be removed from the SAR where they are helpful in
     understanding the textual description and the design.
         DR. POWERS:  Very good.  That's the kind of thing.
         MR. BELL:  So we really come at it from exactly your --
         DR. POWERS:  Good.  Good.  I like that.
         MR. BIRMINGHAM:  So the licensees feel the same way?
         MR. BELL:  Yes.  Absolutely.  They are not rushing -- look,
     they really don't have the resources to, you know, oh, boy, now I can go
     in and all kinds of things -- they're not doing that.  They'll do that
     when it makes sense to do that, when something's been problematic in the
     past, but that kind of captures --
         DR. POWERS:  I think that's where I was going.
         MR. BELL:  Good.  Good.
         MR. BIRMINGHAM:  Okay.  Having reviewed the NEI 98-03 and
     Rev. 1, having incorporated the comments, the staff has a schedule for
     implementation proposed.  We expect to be able to complete the ACRS and
     CRGR reviews in the month of July.  We hope to submit the final reg
     guide for Commission approval in August, next month.  We plan, if that
     happens, to publish the final reg guide in September.
         The licensee implementation for information associated with
     risk-significant SSCS was -- we expect that by March 2000, for remaining
     information by March of 2001.  Somewhat of a risk-informed way of
     implementing the NEI 9803 in the new Reg Guide.
         Now, that is the staff's position on NEI 9803.  If there are
     some questions about how we arrived there or --
         MR. BARTON:  I think this is a fine example of industry and
     the staff working together to come to a good document and a good way to
     solve the FSAR issue.
         MR. BIRMINGHAM:  Yes.  We think of it as an industry
     initiative that met a growing need and something that worked out well
     for both sides.
         MR. BELL:  Thank you, very much.
         DR. POWERS:  I think you've done a pretty good job on what
     your objective is here.  I think you guys need to start thinking about
     what's the future going to look like here as we go to risk-informed
     practices and the PRA assumes greater and greater importance.  It's a
     funny situation because I think we can anticipate a certain fraction of
     the licensees seeing no merit whatsoever to maintaining a PRA to any --
     because they just don't use it, or make a minimal use of it, and I think
     you see other licensees that are four-square behind this.  I mean,
     they're charging off there.  And I think their needs and the staff's
     needs for a reference document tied not to design bases but to the PRA
     become greater and greater in the future, and you may have to evolve
     this whole concept of the FSAR so it doesn't become what you talk about,
     is this document covered with dust that nobody ever uses anymore, and
     why maintain it if it's no longer useful?
         MR. BELL:  A point well taken.
         MR. BARTON:  Hearing no further comment, thank you very
     much, and I'll turn it back to Dr. Powers with a half hour to spare.
         DR. POWERS:  I think I want to take a little of this time
     now to discuss -- we need to send a letter up on this subject.
         MR. BARTON:  I've already got a draft.
         DR. POWERS:  And I suspect that the draft you have speaks to
     the specifics of the issue here, and I'm wondering, do we want to
     explore for the Commission some of the thinking that they need to have
     in the future on this.
         DR. KRESS:  I certainly think that would be of great -- much
     more value than just saying we like this update and go forward, which
     probably is what the letter says.
         MR. BARTON:  Basically.
         DR. KRESS:  Yes.  So I think that would be a -- having that
     flavor in it also would sure add a lot to the value of the letter, I
     think.  And this seems to be the right place to do that.
         DR. POWERS:  It's an opportunity to --
         DR. KRESS:  It's an opportunity.
         DR. POWERS:  -- say to the Commission, okay, you can't
     forget about these other things as you move forward in other directions,
     and it becomes more complicated now because you have a voluntary process
     to evolve.  I mean, a licensee can stay fixed, can say, I don't like
     this new stuff, my plant is running just fine way it is and I'm happy
     with it, my people are all trained in this area with business as we've
     done it in the past, I don't need to move forward.  On the other hand,
     you have other licensees that are actually pushing the NRC, they want to
     move faster and change more.  And somehow, we're going to have to find a
     way to accommodate everybody here.
         MR. BIRMINGHAM:  I think you'll find those licensees whose
     licenses are closer to expiration, they're reluctant to make those types
     of changes.
         DR. POWERS:  Sure.  Legitimately so.  And there's not -- I
     can't fault them a bit.  In fact, I kind of worry about the ones that
     want to change.
         MR. BIRMINGHAM:  Yes.
         DR. POWERS:  Just from a cost perspective.
         MR. NEWBERRY:  Mr. Chairman?  Scott Newberry of the staff.
         We were here talking about risk-informing Part 50 with you
     and the different options, Option 2 and Option 3, of course, and this
     issue that you brought up we agree is an issue in the context of those
     risk-informed options; that is, what is the role of the design basis in
     the FSAR as you would take -- move forward on Option 2, which is the
     scope of regulation, you know, what is the -- our notion right now is
     that the design basis would stay intact, but you would focus on a
     risk-informed scope, but that -- it's more complicated than that, and I
     share with you -- you know, we've articulated the issues there.  I think
     we're going to be -- we're planning on addressing those issues in the
     product we come up with in September and October and will be prepared to
     talk to the Committee.
         DR. POWERS:  Fantastic.  Fantastic.  I mean, that sets the
     stage for handling some of more nitty-gritty things, like what documents
     do we have.  That interface between the design basis, design basis
     concepts and the new risk-informed concepts will dictate what we need.
         MR. NEWBERRY:  I think our thought right now, subject to
     considerable discussion and perhaps change, is that the design basis
     would remain the same for Option 2 but could be altered on Option 3. 
     Now, depending on how far you go on Option 2, there's a question there,
     we think, and I think we'll be interacting with counsel as well on that.
         DR. POWERS:  Well, I'm sure you will, and you may well find
     out that you need a rule change.  It wouldn't be the most stunning thing
     in the world.  As Professor Apostalokis pointed out, you've got rules
     that are on fairly nitty-gritty things here.  When you change the whole
     context, nitty-gritty rules get changed.  I mean, it's an inevitable
         Are there any further comments that people would like to
     make on this?
         I'll take upon myself a task of trying to draft a paragraph
     or so for you, John --
         MR. BARTON:  Okay.
         DR. POWERS:  -- on this to share with the rest of the
     members.  I encourage the members to think about what they would like to
     include in this, and we'll make a decision on whether to include it in
     the letter when we get to the consideration of our reports.
         Okay.  We can't start the next section of the meeting until
     10:15, so we're on break until 10:15.
         DR. POWERS:  Let's come back into session.  This next
     session deals with control room habitability, which has been a topic of
     continuing interest to this Committee for 20 years, I guess, as long as
     I've been involved with the ACRS, episodically, we have met to discuss
     the issue of control room habitability, and we're going to get something
     of a tutorial on the subject from a fellow that Dr. Kress and I know
     very well, our invited consultant, Lou Kovach.  We know him as a
     gentleman of insight and perspicacity, an engineer's engineer as I would
     call him.
         So with that, I'll turn the rest of the meeting over to Dr.
     Kress, and you can continue with the introductions.
         DR. KRESS:  Okay.  Thank you, very much, Mr. Chairman.
         We have had a longstanding interest in this issue.  The
     reason is I think there's potential for risk-significant issues here,
     and we do plan to follow up this meeting with a Severe Accident
     Management Subcommittee meeting in September which we will hear more
     from the staff and from NEI.
         At this particular meeting, we will also hear from NRR, who
     I think are considering or had been considering a generic letter on this
     issue.  We'll also hear from NEI, who are drafting a guidance document.
         We want to assimilate all these viewpoints, and perhaps
     we'll have -- I think we're scheduled at the moment to have a letter in
     possibly October, but it may get moved up to September, so there would
     be no letter yet from this.
         Next on the agenda is, we're very fortunate, I think, to
     hear from Dr. Kovach, who I consider probably the world's most
     knowledgeable individual on this subject, and other subjects too.  So
     he'll give us a perspective and tutorial, as Dana said, and I guarantee
     you he'll be worth listening to.
         So with that, I'll turn it over to Lou.
         DR. KOVACH:  Thank you.
         Is it permissible to sit down?
         DR. KRESS:  Yes.
         DR. POWERS:  Please.  In fact, we hope it's pleasant for the
     presenters and it's much more pleasant for us if you're standing there
     rather than dictating to us because I know you can swing that pointer
     with certain viciousness.
         DR. KOVACH:  Good morning.
         First as an introduction, I would like to say that the last
     thing I want to do is to get in the middle of some licensing issues
     here.  I'm going to talk about technical issues that I think are
     important to understand for a licensing issue.  And this is the second
     time that I am in front of the ACRS on control room habitability and my
     recollection is that none of you were members at the time when the
     previous event took place, which also gives away my age here, this
         But in the last few years, there is renewed interest in
     control room habitability relating mainly to determine really what are
     the conditions of air flows and air purification in these control rooms,
     and a test methodology was selected lately to determine leakage rates in
     control rooms, and this is a release of a tracer agent and in monitoring
     the tracer agent in the particular control room, and from that, using
     the classical equations to determine what the leakage is.
         This methodology is very good for spaces which are
     relatively close.  In most of our control rooms, we have exhaust air
     systems, we have intake systems, and we have many different alignments
     of the control room, depending on what type of hazard it may face --
     normal operations, toxic gas, accident conditions -- and each of these
     require different alignment of the various air-cleaning systems.
         Additionally, we have air-cleaning systems outside the
     control room that are also affecting ingress and egress of air flow from
     the control room, and while the leakage tests that were being performed
     showed some very interesting results from a maybe even engineering
     common sense standpoint, the actual early measurement showed anywhere
     from 2 to 55 times higher in leakage than what was originally used in
     the design basis evaluations.  So some of these control rooms leak like
     a sink.
         At the same time, some of these control room architect
     engineers claimed for these control rooms like 10 cfm maximum.  Now, I
     don't know how many of you actually tried to make measurements.  I'm
     willing to give a $10,000 award to anybody who could measure within 10
     cfm in this room.  It's impossible.  Even if you have minimum exhaust
     and intakes into the control room, that was totally unrealistic.
         Even the newer determinations, and there was a --performed
     about two years ago and it was reported, and I'm not going to name
     reactors; I'm just going to call them A, B or something.  I don't like
     to get into the middle of some of this rock-throwing.  As they tightened
     down the control room in leakage, finding leak paths and sealing it up,
     and it is the tolerances are important.  In the Reactor A, System A,
     they went from 186+/-93 scfm to 122+/-55; in System B, it's 273+/-99,
     88+/-62.  Another reactor, 341+/-91, 294+/-87, 228+/-88, 162+/-91, and
     so on.
         So now we are not any more at the mercy of a ASTM procedure
     for trace or leak testing; we are at the mercy of how well we can
     measure the flows that are going in and out that have to be incorporated
     into this measure.  And basically, it looks like somewhere ar 80, 90 cfm
     plus-minus is the best that we can do.  So really trying to go down to a
     condition, somebody, an engineering firm or whoever claims 10 cfm in
     leakage, it's ludicrous.  It's impossible even to measure it, to verify
     it, at least as long as you have the air flows coming systems in and
         Now, what are the additional problems?  I was listening to
     one of the reports in performing this sulfur hexafluoride tracer, leak
     test, and they carefully said, well, we put people on the doors to the
     control room to make sure that there's minimum opening and closing of
     the rooms because we wanted to get a good test.  Well, what is a good
     test?  Some of you who may have been or heard about the TMI control
     room, we had contamination in the control room.  People were pulling
     their gas mask up to talk to each other at times.  There were more
     people going in and out of the control room than any time during normal
     operation rather than guarding the door so nobody comes in.  So how
     realistic is this test?  Are they really testing under a condition that
     we would have in case of an accident?
         MR. BARTON:  I think the difference between TMI and the
     status of emergency preparedness, the emergency plan where people are
     stationed then as compared to now where everybody had to go in the
     control room to find out what's going, I think has dramatically changed
     to where, in an accident scenario today, you see a big difference with
     the door issue itself, because everybody now managing the accident is
     outside the control room.
         Except for the licensed operators that are trying to respond
     to symptom-based procedures.  So I think the door room issue is probably
     not as realistic today as it was during the TMI accident.
         DR. KOVACH:  Yes, but it would still depend on the grade of
     the accident, whether you abandon the control room and you go offsite or
     whether you are still managing it from the control room.
         MR. BARTON:  In the emergency that gets you above an alert
         DR. KOVACH:  Yes.
         MR. BARTON:  You do not go have a lot of access in the
     control room.  And that's a pretty low threshold.
         DR. KOVACH:  Yes.  So then you go into normal leak paths. 
     There is a particular plant where they have fire detectors installed in
     the control room wall, but these need to be frequently calibrated, so
     about half of them are removed at any particular time for calibration.
         MR. BARTON:  That must be very unusual, because if I had
     fire detectors that I had half of them out of service all the time for
     calibration, there's something wrong with the design and I think I'd
     change out -- there's something wrong with the corrective action system
     at that plant that hasn't got to the root cause and solved that, because
     that I'm sure is not what was intended in the design.  And I think
     that's an anomaly and you won't find that across the board in control
         DR. KOVACH:  So you take a measurement with those holes
     taped up to make sure that that's not counted in?  If we do that, what
     we need is a definition that 30 days before an accident you stop
     calibrating them.  Then it would represent --
         MR. BARTON:  I'm saying that's not a realistic condition in
     most control rooms.
         DR. KOVACH:  It's not most.  I was talking about one
     specific one.
         MR. BARTON:  Then I'd say that they have a particular
     problem with their fire-detection equipment.  If they have to have half
     of them out all the time for calibration, there's something wrong.  I
     don't think that's a valid data point to say across the board that's an
     issue with control room inleakage or outleakage or whatever.
         DR. KRESS:  Well, if even one of them is out, that's a
     pretty good-size hole, isn't it?
         DR. KOVACH:  Yes.  Additionally, we have air cleaning and
     air handling systems that are operating in normal operation outside the
     control room, and these affect the pressure differentials between the
     control room under normal operation and in case of an accident when many
     of them would not operate.
         So again what is the condition under which we perform this
     leak test?  We have a very accurate and a very precise leak test method. 
     The question is how do we and when do we apply this leak-test method
     that would be realistic for a condition that would exist under an
     accident.  Similarly, what is the alignment of these air-cleaning
     systems?  Do we align it for a toxic gas mode.  Do we align it for an
     accident mode?  Is it in the normal operating mode at the time of
     performing the test?
         So really the problem is not with the test method itself,
     it's a very precise, very accurate method.  The question is how
     applicable it is to a condition and how many different conditions you
     need to determine inleakage to have an idea as to what is happening in
     the control room.
         There is another issue, and I'll just put it on as a
     typical -- well, that's a normal, so let me put on one that's -- air
     cleaning system components.  Prefilter, HEPA, carbon adsorber, HEPA
     filter, fan.
         Normally in these systems as a safety component the
     consideration is for the HEPA filter and for the carbon adsorber.  HEPA
     filter is supposed to take care of the particulates, and the carbon
     adsorber takes care of the gaseous components.  And naturally along
     between these two lines normally pressure drop is being measured to make
     sure that the HEPA filters are not loaded up.
         DR. KRESS:  Are the adsorbers activated carbon?
         DR. KOVACH:  Adsorbers are typically activated carbon,
     granular activated carbon.
         DR. POWERS:  With a teda impregnation?
         DR. KOVACH:  KI teda coimpregnation.  However, the prefilter
     is not considered as having a safety function.
         DR. WALLIS:  Why do you call this an exhaust system?
         DR. KOVACH:  Well, it just happens to show that there are
     exhaust and normal.  This would be an intake filter also.
         DR. WALLIS:  Yes, but it would be an intake.  Not concerned
     with --
         DR. KOVACH:  It's just out of a handbook, because it shows
     all the components.
         The main thing that I want to stress is that the major
     buildup of particulate material is in the prefilter.  In normal
     operation your prefilter is going up in pressure drop because you have
     just the normal operational contaminants present.  But that's not
     considered a safety device, and very often the delta P is not measured
     across the entire train except from HEPA filter across a HEPA filter and
     across a carbon filter.
         So you have a continuous variation in pressure drop across
     intake and exhaust filters that are varying depending how dirty your
     HEPA filter is.  How bad it can be, in two plants now in the last five
     years they found a sudden rise of HEPA filter pressure drop, and the
     reason was is because the pre-filters built up so much that they were
     blown into the HEPA filters, and suddenly they have seen a sudden
     pressure rise.
         So, again, we are talking about several tenths of an inch of
     water gauge in balancing a control room, and we are getting more effect
     from that, from an unmonitored component of the air cleaning system that
     is cycling up and down.
         DR. KRESS:  Are those systems included at all in the PRA,
     George?  You know, if we were going to decide what conditions to run a
     tracer test in, you might to run through some sequences in the PRA and
     find out the worst condition for most inleakage and run the test under
     those conditions.  I just -- I don't recall that these are ever modeled
     in any of that.
         DR. APOSTOLAKIS:  In special studies, maybe, but, routinely,
     I doubt it.  I doubt it.  Only if --
         DR. KOVACH:  I am not aware of anybody going through these
     steps and seeing which would be really the most conservative condition
     under which you would perform this test.
         DR. KRESS:  That would be the logical way to do it.
         DR. KOVACH:  Yes.  At the same time that may require you
     also to shut down some of your external air cleaning systems that are
     air handling systems because they affect the outside pressure.  I mean
     we are talking about, again, few tenths of an inch of water gauge
     differential between the control room and the outside.  In fact, even
     with an atmospheric high or an atmospheric low, in some cases, they are
     effecting the performance of the air cleaning systems.
         So if we have the good method to do it, the question is,
     when and under what circumstances do we perform this test?  If there is
     general clatter coming out as to how to do it and what to do with it,
     then I think we have to be careful as to under what condition are we
     going to go into this extra effort of determining various conditions.
         DR. WALLIS:  If there is too much build-up on the
     pre-filter, it would seem that it is poor design, the big arrows.
         MR. SIEBER:  Or changed.
         DR. WALLIS:  Or changed out more often.
         DR. KOVACH:  Changed out more often.  But if they are not
     monitoring the pressure drop across them, in some cases, on the total,
     you may have a local delta P gauge and they wait until it gets real high
     and then it is changed out.  Again, the only part that is considered as
     a safety system is the HEPA and the absorbers, so the rest are not as
     well taken care of, monitored or anything else, but they do effect the
     overall delta P of the system, which effects the quantity of air that
     you take in or you put back into the controller.
         DR. WALLIS:  Well, this is one of the problems of
     designating things as safety systems and other things as not.
         DR. KOVACH:  I think if you put in an air cleaning system,
     then all the components of it are part of the system, and I can just say
     that this is part of a safety system.  We have in some of them, we have
     electric heaters.  Again, don't go by the titles, it just some of them
     are --
         DR. WALLIS:  The inflow nozzle is a safety feature because
     if something blows up against it and blocks it, then there is no flow.
         DR. KOVACH:  Certainly.  In some of them we have moisture
     separators and electric heaters to maintain relative humidity and those
     are just as much a part of a safety system.  A moisture separator,
     unfortunately, is at times put ahead of a pre-filter and it has higher
     efficiency for particulate material than the pre-filter.
         DR. POWERS:  Sure.
         DR. KOVACH:  So what gets plugged up?  The pre-filter lasts
     forever and the moisture separators are all clogged up.  We have to try
     to make these decisions on a more logical basis than on an arbitrary
     basis, that the HEPA filter and an absorber are the major components,
     but the system needs to be operating, not just a carbon absorber and the
     HEPA filter.
         So I am not going to dwell in very great detail as to what
     are the other problems relating to what the bounder is.  I think there
     are numerous conditions that we have to evaluate as to under what we
     conditions we do.
         It is, in all fairness, and it is almost impossible even to
     balance.  As an example, under normal operation on a air flow, and then
     you switch to a toxic gas mode, and you have to readjust dampers to make
     sure that you maintain the appropriate flow.  So under which condition
     is the most critical to balance the control room, the air flow balancing
     or to maintain positive pressure in relation to the outside?
         Would there be a reason to perform tests earlier someplace
     under the various conditions?  Yes, I think I would recommend both to
     NEI and NRC, that before they start writing a set of conditions, let's
     determine what is the condition under which we want to determine the
     actual inleakage.
         DR. WALLIS:  I have a question about the moisture
         DR. KOVACH:  Yes.
         DR. WALLIS:  If there is a lot of moisture, then this thing
     is going to get saturated.  Where does the water go?
         DR. KOVACH:  Well, these are coalescers, basically.  There
     is a water drain system also that normally goes to rad waste.
         DR. WALLIS:  If the water also collects particulates, then
     you have got to do something with this dirty water.
         DR. KOVACH:  Yeah, it goes to rad waste.
         MR. BARTON:  Rad waste liquid systems.
         DR. KOVACH:  Also, in addition to that water, some of these
     systems also have fire prevention systems that spray water on them for
     quite a long time, and at times if you look at those quantities of water
     balanced against the capacity of the liquid rad waste system, you may
     run into some surprises also that they are in fact not.
         Now, completely aside from the actual air flow aspects of
     it, we have another problem also.  Certainly, I endorse the current
     source term inside the containment.  I have a great deal of difficulty
     endorsing that same composition for outside the containment.  Iodine is
     extremely reactive.  Anything that gets out -- so once we are at the
     stage that we would get to the control room, it is exposed either to
     atmospheric or other reactor building, or other conditions where you can
     convert a fair amount of this to organic iodides, which behave very
     differently from the iodides or the particulate material.
         In crediting, and let me just put back just for a reference
     point here, if I have elemental iodine in particulate form, then it will
     lay out onto a HEPA filter.  But how long?  It will still have a vapor
     pressure.  So just because I assume and credit a HEPA filter with 99.95
     percent efficiency in place to remove elemental iodine in particulate
     form, that will be a short-term removal and all of that will repartition
     over into the absorber unit.  Either it is elemental iodine or it is
     because already in a larger surface, it helps you to convert to organic
         So, generally, what we are seeing in these cases, a much
     larger fraction of the total iodine will be in organic forms than what
     we assume actually as a fraction inside the containment in a case of a
     severe or loss of coolant accident.
         DR. POWERS:  Even inside the containment, I think the new
     source term specifies what comes in from the primary piping system, and
     then says, okay, figure out what is in there.  And that step of figuring
     out what is in there, the mix between metallic iodides, I2 and organic
     iodide, for just the reasons you say, the high reactivity of the I2 and
     even the reactivity of the metal iodides, is a challenge that I don't
     think has been sorted out to an level of definitiveness.  And we see
     from the Canadians -- for a long time, we say, okay, the organic iodide,
     we can treat it as methyl iodide.  Well, Canadians are coming back and
     saying, well, maybe.  But there are a lot of other things in there. 
     They are coming in with propylene iodides and a variety of other things
     that they see being reacted largely from the vapors coming off paints.
         DR. KOVACH:  Yes.  You can run in vinyl iodide.  I think
     vinyl iodide was actually identified by mass spec on some of the TMI
     samples that were taken.  Unfortunately, at that time people still for
     some reason claimed fairly large fractions of HOI, which in the vapor
     phase is nearly impossible to have other than for a few microseconds.
         But even under normal operations, the measurements that were
     made were found in the reactor building, 62 percent organic iodide; rad
     waste building, 84 percent; turbine building, 40 percent, and so on.  So
     we are getting a large percentage conversion even though there is really
     no organic iodide in the primary coolant.  Once you are coming out,
     these are all reactions after release, leaving the primary system.
         So it is -- you have to be very careful in trying to come up
     with dose calculations for the control room, assuming a certain amount
     of air flow in and a certain amount of filtration efficiencies which are
     being taken of 99 percent removal of methyl iodide and 99.95 percent of
     particulates, because neither the source term is the same at the entry
     to the control room, neither of these efficiencies will be maintained.
         I think that we have, and for some now years now I keep
     hearing that we have very good behavior on nuclear air cleaning systems,
     and I would like to revisit that issue because -- let's see what
     happened at TMI.  Maybe a figure is better.
         There were two major air-cleaning systems that were
     monitored.  The auxiliary building, A and B units in the fuel-handling
     building, A and B units.  Both the aux building and the fuel-handling
     building A and B units are two identical units.
         What happened here is because we had very high iodine
     loading on the adsorbent batch we couldn't redetermine the efficiency. 
     So these are two-inch-deep beds, and they were carefully broken out into
     half-inch segments.  And we counted what was actually in the direction
     of the probe from inlet to outlet, and the unit is in microcurie per
     gram carbon.  All back-calculate to the March 1979.  That's when the
     accident occurred.  The filters were removed actually about a week
         You can see the two auxiliary building units show to the end
     here if I extrapolate this to the two-inch unit almost identical
     behavior, but none of them were up in the 99.99 range.  We already had
     some coming through.  As a matter of fact, if you extrapolate these
     curves down to zero, you can pretty well determine how much iodine was
     released through these units at TMI.  But there is the air-handling unit
     from the fuel-handling building, and two very different behaviors, even
     though both of them were running.
         What happened is they were not balanced, and the dampers
     were offset so a large amount of flow was going through this unit.  As a
     matter of fact, that unit released about between 27 and 30 curies of
     iodine at TMI, which is just about matching the total amount of iodine
     that was released at TMI, while the other one was actually in fact
     efficient to 99.99 percent.  Why?  Because there was not much -- about
     half the air flow was going through here, and three-quarter -- 1-3/4 or
     so, the design volume was going through the other.
         Now we also took measurements by taking samples before and
     after the filter at various times in the accident before these were
     removed, and about a week after the accident we had a DF of 1.2, because
     the inlet iodine was already going down while there was iodine bleeding
     off the other end of the adsorbers.  So this assumption that we maintain
     99.9-plus percent efficiency for a very long time based a laboratory
     test that's performed for one or two hours is not appropriate for those
     determinations in a control room.  Because what we have is a long-term
     operation, and depending on the age and type of the adsorbent, it will
     have a different behavior if it's run continuously for a week than if it
     is run only for two hours under rather controlled conditions.
         Looking at the curves really, except for some front-face
     elemental iodine, this indicates the distribution was pretty close to
     methyl iodide.  There wasn't a major variation at least in there.  Or
     something that behaves similar to methyl iodide.  Because if we had
     different iodine species, we would have breaks in the curve, depending
     on the efficiency of the removal.  We don't have any breaks, except on
     the face we have some higher volumes which would be mostly elemental
     iodine that's pretty well backed up.
         Now in all fairness I also have to tell you that these two
     adsorber trains were also present at the time when they were painting
     the containment.  They got an extension on replacing them because they
     were going to change them out at the next refueling time.  So again what
     we need is a requirement that a certain number of days before the
     accident you have to change the filters out, whether you paint in the
     containment or not, to make sure that we are in an appropriate condition
     for this particular event.
         So what I'm seeing is from various groups claiming that we
     don't really have to worry as much about the control room, because with
     the efficiencies of particulate removal, with the efficiencies of iodine
     control, we remove so much of the iodine during the forced ventilation
     of the system that the inleakage is not going to be a significant
         Well, the inleakage can be a significant factor, and our
     efficiency, if we are basing it on the actual species that we will --
     this system will see rather than an arbitrary condition, taking again a
     source-term-based reactor accident, source-term-based iodine speciation,
     and assume that for the input then it's not going to work.  It's going
     to be -- the iodine species present are going to be different.
         Again, just as a demonstration example as to what we are
     seeing in some cases, now this is a little different system, because you
     can see when that's going to 50 centimeters rather than 5 centimeters
     like we have in the U.S.  These are the German systems.  And they claim
     some assistance from this depth from the behavior of organic materials.
         They were looking at the organic materials to build up on
     the carbon, convert even elemental iodine to organics on the carbon. 
     Carbon is a very good catalyst.  It's a large-surface-area material.  We
     pick up iodine on it.  It all says adsorbed organics.  There's a much
     better chance for contact through this system.  And you can see when
     they start up in operating time in two months on the system you can see
     some organic buildup in the bed in the initial part of it.  Then you can
     see that four months and going up to 14 months the high-volatility
     material tends to move through the adsorbent bed, and you actually get a
     mass transfer zone moving through, while the higher boilers are much
     more strongly adsorbed and they stay on the system.
         But if I look at what happens in the first five centimeters,
     you can see that really there isn't a lot of difference, and it's very
     difficult to interpret in a 5-centimeter-deep system really how much
     credibility we can give to these very high efficiencies in a long-term
     exposure.  These were again two months, four months, 14 months
     continuous operations.
         DR. POWERS:  Was this with a radioactive iodine or with --
         DR. KOVACH:  Yes.  They were running it two ways.  They were
     running both radioactive iodine tracer, and they also had a sampler, the
     same bed depth, that was segmented.  So they were taking the segments
     out and stripping them.
         DR. POWERS:  I've always wondered if the self-dosing effect
     was significant or not in these beds.
         DR. KOVACH:  I think it is.
         DR. POWERS:  I would think it would be.
         DR. KOVACH:  So the, you know, they have a different design
     concept.  Basically what they are trying to do is to have a deep enough
     bed that even if you have organics, by the adsorption-desorption step,
     you delay the iodine long enough that you are significantly
     decontaminating it rather than an efficiency of removal.  So they
     actually are operating iodine delay vents similarly to the way we have
     noble gas delay vents on some of the reactors.
         Personally I think it makes more sense, but they started
     designing these systems after a lot of design data was available.  We
     wrote regulations first, before we had design data available.  So we are
     frozen at a certain stage in our engineering designs relating to
     air-cleaning systems in nuclear powerplants.
         Basically what is -- yes, there are problems.  I think if we
     want to look at control rooms, we have some things that we have to look
     at, and it's almost different in each individual plant.  We have some
     plants where the emergency diesel exhaust is darn close to the
     control-room air intake.  I think elimination of something like that
     should be a higher priority than directly determining the leakage into
     the control room.  And really a good walkdown of the overall system is
     very important.
         But basically what I'm proposing is that we should consider
     the conditions under which the control room envelope and the ventilation
     systems are tested, and they should be carefully established to yield
     realistic data under whatever the most conservative or a range of
     conditions before we actually start proposing that this is the method
     that you have to use.
         The test method should be selected to be commensurate with
     the magnitude and accuracy of the needed data.  If I run an extremely
     precise test but because I can't measure my air flows in and out better
     than about plus-minus 90 CFM, there is only a limited effect to go down
     to determine inleakages to plus-minus 1 CFM in a test by the test
         The radioiodine removal efficiency credits postulated for
     the control room air-cleaning system should be based on realistic
     application of the physical chemistry of iodine species and their
     potential changes during long-duration operations.  What's not useful is
     leak-testing performed under unrealistic conditions.  I don't know what
     you do with it.  You have a number, and how do you apply it?  Assuming
     laboratory radioiodine test conditions is representative for long-term
     operational efficiency.  Again, a two-hour test is not going to tell you
     how a system behaves in a week or a month or whatever duration you want. 
     In case of an accident, it will most likely be longer than a couple
     hours' operation, and hopefully less than months.  We are talking about
     maybe weeks at most, or a week.
         Assuming in-containment iodine speciation for control room
     air intake or air inleakage locations, I think that if we are going to
     evaluate directly the dose to the workers, we have to assume not the
     iodine distribution that exists in the containment, but what actually
     would be the condition at the control room intakes or where the
     inleakage can take place, and make sure that we are using realistic
     credits in assuming the calculations.
         I'm not saying anything here that's new.  I don't claim that
     I'm the discoverer of this.  I'm just trying to recite things that in my
     opinion are significant before there is a generic letter written, and
     I'm not sure if September or October is a realistic time based on where
     we are with it now, at least on my knowledge.  We have not run to my
     knowledge any control room air inleakage tests under these conditions
     where we would actually determine that what is the most conservative or
     what is the most realistic for an accident condition, how to line up the
     system for that type of a test.
         So what I'm pleading for is to consider under what
     conditions to run the tests and how relevant it is from a dose
     standpoint again should be evaluated at what is a realistic dose that we
     want to prevent and not just an idealistic condition.
         And with that, if you have any questions or anything else,
     I'll be happy to answer anything.  There are some additional examples
     given in the paper.  I'm not going to recite them.
         DR. POWERS:  I guess what comes immediately to mind is
     that -- two things -- is that I think we do want to see some more
     attention to this in the probabilistic assessment, and you think about
     it, what is it that you need to consider in setting up probabilistic
     models for these things?  Variabilities in the leakage rate? 
     Variabilities in the speciation?  Variabilities in the efficiencies of
     the --
         DR. KOVACH:  Yes.
         DR. POWERS:  And then you have some protracted period of
     time, so it changes in time.  Are you going to be able to do this in PRA
     space, George?
         DR. APOSTOLAKIS:  I don't know.
         DR. KOVACH:  With some data I think yes.  With no data it
     will be very difficult to come up with even a PRA.
         DR. APOSTOLAKIS:  We need expert opinion.
         DR. POWERS:  It's always good to get expert opinion.  When
     in doubt, go to expert opinion.
         MR. SIEBER:  What about shift changes?
         DR. POWERS:  Ooh, shift changes.
         MR. SIEBER:  Yes, sure.  People only stay there 8 to 12
     hours, and then somebody else gets the next shift.
         DR. KOVACH:  I think that, you know, some initial conditions
     can be established.  They may not be the same for all plants.  I mean,
     we don't have identical air-handling systems and identical control room
     sizes and control room envelopes.
         DR. POWERS:  I am aware of some studies that -- anecdotal
     accounts of studies that went on in Great Britain about HEPA filters
     with self-dosing of iodine on the surface, and, you know, they
     deliberately put radioactive iodine on the paper for the paper HEPA
     filters and looked at the retention.  And the answer was retention was
     extraordinarily high in the first 10 minutes.
         DR. KOVACH:  Sure.
         DR. POWERS:  And it went to zero, because you turned the
     iodine into an organic iodide and it went right through the paper.  Are
     HEPAs typically paper filters, or are they --
         DR. KOVACH:  No, they are typically glass now, but we have
     more organics than the old -- the paper was phased out because of the
     fire hazard.
         DR. POWERS:  Right.
         DR. KOVACH:  Now they are mostly glass fiber, but they also
     have water-repellant organic coatings and binders in them, so the
     propensity for reaction is, if anything, maybe worse.
         Again, they are really -- HEPA filters are for true
     particulates that have no vapor pressure or no reaction on the HEPA
     filter itself.  If you don't have those conditions, you can't assume the
     efficiency from the available test data as to what it's going to be.
         DR. KRESS:  Are there no test data on the conversion of
     iodine species to organic on HEPA filters?  Do we need some more
     research, is what I'm asking.
         DR. KOVACH:  That aspect of it is -- there may be some in
     the literature from which you could at least get a starting point.  Some
     people actually looked at -- but even isotope exchange in beds with
     elemental iodine --
         DR. KRESS:  Yes.
         DR. KOVACH:  You know, where particulate's going through.
         DR. KRESS:  Yes.
         DR. KOVACH:  If you go to a particulate, you can run through
     the same processes, except your kinetics goes to hell because your
     diffusion -- it will be a direct relation to your diffusion --
         DR. KRESS:  Yes.
         DR. KOVACH:  Coefficient.  So even a submicron particulate
     has a very different -- much lower diffusion coefficient than methyl
         DR. KRESS:  Sure.
         DR. KOVACH:  The other thing that happens is the short-term
     test gives you another sort of a misleading condition that methyl iodide
     removal is by isotope exchange.  You put actually stable iodine on the
     adsorbent bed and you let methyl iodide come in.  The methyl iodine
     group is not so strongly held.
         DR. KRESS:  So they --
         DR. KOVACH:  As long as you have statistically an excess of
     stable iodine on the adsorbent, you get an isotope exchange.
         The higher organic molecules are really removed by physical
     adsorption for a limited time.  So you also have a high efficiency for a
     short time, because it's a big molecule.  On methyl iodide you don't. 
     If you don't have isotope exchange that methyl iodide zips through,
     because it's highly volatile.  But if I go to ethyl iodide or propyl
     iodide, I have a half-hour, hour retention.  But again, what happens
     after 10 hours, 8 hours, or whatever is the actual duration that we are
     looking at.
         The other thing, you have to realize that we are talking
     about in some of these control rooms air intake, air inleakage, and then
     we have recirc systems.  Now if I bring in some of this iodine, even
     though I may have a shift change now from the intake standpoint, what I
     put on the recirc unit may be just recircing through there and I can
     have this distribution that I showed you, a very flat distribution,
     after a while, on the iodine on that recirc system, and a very low
     defendant on the recirc unit.  So we have to make sure that at each step
     we understand what's happening.
         DR. KRESS:  Would chemical thermal dynamics calculations be
     useful here?
         DR. KOVACH:  I think so.  Also, I mean, this is, as you
     know, there is a lot of experimental data being generated by the French,
     Canadians looking at the reactivity of iodine under various conditions,
     and it can be both good and bad.  You can have electrical cabling,
     insulation paints that actually remove iodine.  The question is that
     most of the people are looking at iodine removal in a short term and not
     the possible reentrainment of the organic iodine species after the
     reaction takes place.
         DR. POWERS:  Yes.  Assuredly what the Canadians are saying
     is that within the containment itself you get two classes of organic
     iodides.  You get those -- essentially methyl iodide or maybe it's ethyl
     iodide, or multiple iodides.  The other one is you get these
     high-molecular-weight iodines which is better for retention than even
     metal iodide.
         DR. KOVACH:  Yes.
         DR. POWERS:  Back in the sixties I believe that there was
     some work done at Battelle on trying to develop an optimal paint for
     iodine retention.  I don't know where that went.  The idea there was to
     of course trap it.
         DR. KOVACH:  Use a type of paint that actually --
     unfortunately I think at that time most of it was still looking at
     elemental iodine, and there's very little work was done on the full
     speciation.  And there's a tremendous amount of good data out there that
     I think can be looked at to get an initial start, at least to lay out an
     experiment at a plant as to what you want to do.
         DR. POWERS:  Another thing that's always intriguing is that
     you have a lot of these zinc-based paints, typically as primers, and
     when they're covered over with another kind of paint, nothing happens,
     but if you have the primer bare, that is a tremendous absorber of
     elemental iodine.  I don't think you'd get anywhere with methyl iodide. 
     I don't think anything absorbs methyl iodide well.  And, for instance,
     in AP600 we gave no credit for their zinc-based paints at all on iodine
     absorption.  But it is assuredly true that the primer -- not the actual
     paint, but the primer -- is the great absorber of --
         DR. KRESS:  Suck it up and hold it.  It stays there, too.
         DR. POWERS:  It essentially turns it into zinc -- hydroxy
         DR. KRESS:  It's pretty stable stuff.
         Well, if there are no more questions, well, thank you.
         DR. KOVACH:  Thank you for your time.
         DR. KRESS:  Thank you, Dr. Kovach, and at this time we are
     scheduled to hear an NRC staff presentation from NRR talking about
     some -- continuing on issues related to control room integrity.  So I'll
     turn the floor over to our NRR rep right now.
         MR. HAYES:  Thank you very much.
         DR. APOSTOLAKIS:  Is there a reason why this has started in
     the Probabilistic Safety Assessment Branch?
         MR. HAYES:  Pardon?
         DR. APOSTOLAKIS:  Are you doing PSA on this?
         MR. HAYES:  On this issue?
         DR. APOSTOLAKIS:  Yeah.
         MR. HAYES:  No, I'm not.  I'm in the Probabilistic Safety
     Assessment Branch.  That sums it.
         DR. APOSTOLAKIS:  Yeah, that's why I'm asking.  Why is this
     issue within that branch?
         MR. HAYES:  Okay, this issue is within this branch because
     the accident analysis component of NRR was just reassigned to the
     Probabilistic Safety Assessment Branch.  Formerly, it was in the
     Radiological Assessment Branch, okay.  It was actually Radiological
     Assessment and Emergency Preparedness.  You must understand that the
     issue of control room habitability encompasses a number of different
     review areas.  It involves the Plant Systems Branch, which has the
     responsibility for the ventilation system itself.  It involves the
     Materials and Chemical Engineering Branch, which is involved with toxic
     gas analysis.  And it also involves the human factors area, which is now
     in a different component.  They have been merged with about two other
     branches and the Radiation Protection Implant Health Physics person.
         So, if you will, I am making this presentation because the
     section that I am in is sort of the focal point for control room
     habitability, but I can assure you that the reviews and the assessments
     that we do are quite integrated.  When these issues come in, there's
     continual discussion with the various branches to make sure that we try
     as much as possible to look at this as an integrative fashion.  Okay.
         As Dr. Powers indicated, control room habitability has been
     an issue --
         DR. APOSTOLAKIS:  Would you focus it a little bit?
         MR. HAYES:  Sure.
         DR. APOSTOLAKIS:  Yeah.  Thank you.
         MR. HAYES:  Is that better?
         DR. APOSTOLAKIS:  Thank you very much, Greg.
         MR. HAYES:  Dr. Powers indicated that control habitability
     has been an issue with this committee for approximately 20 years.  It
     started out in 1980, and, at that time, quite frankly NRR was rather
     slow in responsiveness to the committee in terms of identifying and
     understanding the concerns which this committee had.  But eventually, in
     1983, generic issue 83, control room habitability, was established, and
     a control room habitability working group was formed.
         Now, as a part of this control room habitability working
     group, it was determined that there needed to be an assessment of the
     actual control room habitability at three plants.  So sort of a
     mini-survey was performed of those three plants.
         The result of that survey was that a more detailed
     evaluation was required of the existing control rooms.  And that
     resulted in a 12-plant survey, which started in the fall of 1985 and
     concluded in January of 1987.  Now, one of the chief areas of
     concern--and there is a number of them that this committee had--was the
     question of how did licensees implement TMI Action Item 3D34 in their
     plant modes of operation.  In other words, is -- was the as-built, as
     operated system similar to what was described in a TMI Action Item 3D34?
         So, members of the staff and a contractor went out to these
     12 plants to determine whether the as-built as-operated systems
     reflected TMI Action Item 3D34.
         Now, this was rather a straightforward evaluation.  The
     staff and their contractor evaluated normal and emergency operating
     procedures.  They walked down the systems.  They reviewed the updated
     FSARs.  They reviewed the safety evaluation which was issued in
     conjunction with TMI Action Item 3D34, and they even made flow
     measurements, as much as possible, at these 12 plants.  And what these
     flow measurements were, they were an attempt to determine where the
     licensees were getting the flow that they had anticipated.  In other
     words, if they had assumed a pressurization flow of a thousand CFM, were
     they actually getting that?  If that had assumed a recirculation flow of
     4,000 or 5,000, were they actually getting it, or were they getting some
     other number?  In other words, the flow wasn't coming in, you know,
     where they anticipated.
         They also -- we also looked at the technical specifications. 
     Did the technical specifications mirror the way the system was operated? 
     Did it mirror some of the assumptions which went into the accident
     analysis?  For example, if they assumed 95 percent as the charcoal
     absorber efficiency, was an appropriate laboratory test performed to
     demonstrate the 95 percent?
         Now, I should point out that in no time in this evaluation
     of the survey of the 12 plants was there ever an assessment as to
     whether there is an adequate toxic gas or radiological assessment.  In
     other words, we did not go back and recalculate doses or toxic gas
         Now, on June 22nd, 1987, we provided to you all the
     conclusions as a result of this 12-plant survey.  And I guess you might
     say that I feel somewhat like the Austin Powers of control room
         DR. POWERS:  Do you think you've been shagged?
         MR. HAYES:  You know, because here we are again, you know. 
     And I'd like to summarize the results of those findings back in 1987.
         With respect to the as-built and as-operated system and
     comparing that to 3D34, we found that the as-built and as-operated were
     different than the 3D34 evaluations.
         And one of the major findings we had was that it appeared
     that the flow rates and inleakage was much different.  As Dr. Kovach
     indicated, many of these licensees had, in essence, assumed that they
     had a perfectly zero inleakage control room, because the tent CFM is not
     due to inleakage; it's due to ingress and egress, okay.  When we found
     that there was communication, we found that the flow rates, like
     pressurization flows didn't match, and it was sufficient at a number of
     these plants so that there was some question as to the capability of
     these plants to meet GDC 19.
         We also had issues with respect to the technical
     specifications.  We felt that they were inadequate and, in some cases,
     inaccurate for some of these plants.  For example, one of the probably
     the deficiencies we with respect to technical specifications on control
     room habitability is that nowhere do we address the integrity of the
     envelope.  We address the capability of the system to filter.  We
     address the system capability to isolate.  But nowhere do we take into
     account this boundary, and that's one of the most important, if not the
     most important, thing in the evaluations.
         Some of the inaccuracies we saw--we saw, for example, that
     licensees may have assumed 95 percent absorber efficiency, and they were
     testing to 90. We saw flow inaccuracies.  For example, maybe they
     assumed 300 CFM of pressurization flow, and in actuality they were
     seeing a thousand.  Okay.
         And then finally, the last conclusion was with respect to
     the importance of ventilation systems.  You may recall back in the
     1980s, there was a comedian named Rodney Dangerfield, and his famous
     line was he couldn't get any respect.  And that is somewhat the way we
     found the ventilation systems at that particular point in time is that
     it seemed to be that ventilation systems really didn't have ownership. 
     You saw engineers who were recycled through those particular job
     descriptions, but no one was ever assigned on a permanent basis.  You
     didn't have a system engineer that, if you will, stayed with that system
     for a long time.  You know, I remember one visit we had at a plant in
     doing that 12-plant survey when we were asking for some information, and
     they asked this one fellow:  they said, well, didn't you have that?  And
     he said, yeah, I had that system at one time.  He said, but then I got
     promote to rad waste.
         And so that sort of gives you a flavor of the way that
     ventilation systems have been, you know, presumed in the past in terms
     of their importance.
         DR. SEALE:  A card carrying ASHREA member gets no respect.
         MR. HAYES:  That's right.  That's right.
         Now, here we are, if we fast forward ourselves to the 15th
     of July 1999, and the question is well, what has changed, you know, or
     what are the conditions today?  And we can be safely said that if you
     want to look at the conditions of control room habitability, you can
     just about look at the slide which was given back in 1987.
         Now, the one exception I think that there is is that there
     has been an increased interest in the importance of ventilation systems
     at the grass roots level.  There is an organization called NHUG, which
     stands for Nuclear HVAC Utilities Group.  They have been very
     instrumental in bringing to the front ventilation system problems.
         You're also seeing in terms of these utilities much more a
     system engineer approach, and these people are starting to stay with the
     systems for some significant period of time.  So that has been a very
     good improvement.
         However, if you look at the problems with respect to the
     adequacy of the tech specs with respect to inleakage, you will find
     these same problems exists, and, in fact, what we have seen is an
     enhancement of the conclusions which we were given in 1987.
         And to demonstrate this, and I think if you want to pull one
     thing from this meeting and presentation from the staff this morning,
     it's this next issue, and this is dealing with the issue of inleakage. 
     And then we'll talk about unfiltered inleakage.
         The next two slides deal with tracer gas testing of control
     room envelopes.  Okay, this is a graphical presentation of it.  The red
     is an indication of the measurement of unfiltered inleakge in CFM. 
     This, in the green, is the values which were assumed in their accident
     analysis.  Okay.  That gives you an order of magnitude.
         DR. POWERS:  A plant that certainly sees the two big spikes
     you've got there must be just shocked because verification of your
     assumptions is a critical part of any aspect.  We just heard about the
     FSARs, verification of the assumptions.  There is a required activity. 
     How do they react to that?  I mean, I -- shoot themselves?
         MR. HAYES:  Well, if you look at this data, this data, 13
     control rooms have been tested out of roughly 72 that exist--21 reactors
     out of about a hundred and some.
         So that, if you will, this sampling represents 20 percent
     approximately of the entire industry, okay.  None of these plants, which
     were tested and did the tracer tests, met their licensing basis.  None
     of them.  Not one to date.  And I think when I say that, I want to point
     something out to you that I think is very important.  Do not label these
     people who have done these tests bad guys.  On the other hand, label
     them the good guys.
         DR. POWERS:  They tested.
         MR. HAYES:  Yes, because they've had the guts to go out and
     test this.  Because I can assure you, nobody in the industry really
     wants to go out and do the tests, because they're very familiar with
     this data.
         DR. POWERS:  Yeah, I can believe this.
         DR. WALLIS:  Would you tell me about the assumptions.  Were
     the assumptions made by engineers or were they were something that was
     specified by the NRC?
         MR. HAYES:  The -- there was guidance given in the Standard
     Review Plans, but the guidance says, hey, licensees, you are to
     determine and tell us what your inleakage is.  In other words, what I
     found when we did this survey is like, for example, if you took a
     particular architect engineer, and you went to, say, a mid-70's plant,
     and you went to, say, a mid-80's design, it didn't seem like the
     architect engineer ever went back and verified that the system that they
     had done in 1970 worked as they had intended, so they maintained the
         And, you know, and I just don't think -- you know, no one is
     raised from infancy -- you know, you don't see your sons and daughters
     saying, hey, I want to be a ventilation engineer.  I think it's
     something that people sort of get pushed into, and so I don't think that
     they were really very well appraised of this potential -- these
     potential problems.
         DR. WALLIS:  Yeah, but if they all estimated so low, is this
     because there's something generically wrong about the way they're taught
     or that the literature in the field or something.  What is it?
         MR. HAYES:  I think it's both.  I think it's both.
         DR. WALLIS:  And they all make naive assumptions.  You'd
     assume some of them might assume in the wrong direction or is it
     management tries to push them to making assumptions that look good on
     paper.  What is it?  Or, it's all of the above?
         MR. SIEBER:  Well, I think there's another factor is that as
     far as inleakage is concerned, it's door seals, which wear out as you
     open and close doors.  Sheet metal that's not fit together well.  Holes
     that are --
         DR. POWERS:  The architect engineer is going to have built
     this building and said that there's a certain inleakage on it.  But he's
     going to have a design construction --
         MR. SIEBER:  The construction would then produce it.
         DR. POWERS:  But somewhere in this plant, there is going to
     be a specification for control room that says, this is the kind of
     inleakage we want.
         MR. SIEBER:  That's right.
         DR. POWERS:  Okay.  I would bet you that these guys made
     their estimates of the inleakage by going to that specification and
     saying, it's this.  We'll bet on that, because the guy wanted to meet
     the spec.
         And it's just what Jack says.  The first thing was
     construction probably couldn't meet that, and didn't, and had no way of
     checking it.  And second thing is that, as time goes on, all the seals
     and what not, which everybody has forgotten where they are, because
     they're all over the place, have gone away, and, as Dr. Kovach's
     discussed, you're taking things in and out of these things.  And you run
     off and calibrate this, knock a new hole for a conduit, and things like
     that, and it just gets forgotten in this stuff.
         I'm willing to bet that's how the evolution progresses.
         MR. SIEBER:  That's exactly right.
         DR. KOVACH:  In some cases, modifications were made also.
         MR. SIEBER:  Right.
         DR. KOVACH:  From that time to the original time.  And you
     have a lot of other penetrations that were not sealed because they --
         DR. SEALE:  There are lot of the equivalent of parking lot
         DR. KOVACH:  Yes.
         DR. SEALE:  On these control rooms.
         DR. POWERS:  Getting wide -- these shopping carts ready to
         DR. SEALE:  Yeah, exactly.  Yeah.
         MR. HAYES:  Go ahead, Mark Reinhart.
         MR. REINHART:  This is Mark Reinhart of the Probabilistic
     Safety Assessment Branch, and I head the dose assessment team under my
     section.  I wanted to ask Jack, is it worthy to comment back on your
     chart the difference between some of the large spikes and the smaller
     spikes if I understand this correctly is that the plants that did
     sealing before the test got the lowest spikes.
         MR. HAYES:  Oh, sure.  Let me show you a couple what I
     consider good examples.  If you see this plant C.  Plant C had a design
     basis of 260.  When they did their first test, it was 4,000 plus.  Okay. 
     This values here are subsequent tests.  You know.
         DR. WALLIS:  It looks like 518,242.
         MR. HAYES:  Oh, I'm sorry.  It's really 518 and 242.
         DR. POWERS:  Yeah, well, what happened was the plant manager
     saw the results, and he went right through the roof.
         DR. APOSTOLAKIS:  By the way, this is a good place where the
     use of a semicolon would be valid.
         This is for my colleagues who hate to use those in letters. 
     Semicolon would be good here.
         DR. POWERS:  Or even a space.
         MR. HAYES:  But this particular facility has a -- is owned
     by a utility that has another reactor.  As soon as they found that they
     had this inleakage associated with this plant, the ventilation engineers
     said, hey, get some sealers to this reactor and start sealing.  And
     that's why, as Dr. Kovach, mentioned the lowest factor that we have in
     terms of the measured versus the analysis is a factor of 1.5
     approximately, and that's because these people started sealing first.
         The same way with this value right here, 440, versus 120. 
     They also sealed first.  And finally, the last example here, this plant
     number H, or letter H rather, which had an assumption of 10 and came up
     with 71, that was one of the plants we did at the -- during the 12-plant
     control room habitability survey.  And we made measurements in there,
     and I can tell you for sure that the leakage wasn't 71 CFM.  And when
     the person who did the tracer test went into some of these various
     areas, he sort of compared it to going to Luray Caverns, where you had
     stalactites and that hanging down, because they had so much sealant
         And so I think it's fair -- it's fair to say that there is
     solutions to this issue of control room habitability.
         DR. APOSTOLAKIS:  Yes.
         MR. HAYES:  And, and -- because this plant here was not a
     new plant that did this ceiling.  And, in fact, to go, if you will, from
     this level down to this level and the vintage of that plant, I think
     it's a tremendous, tremendous step, you know.  Yes, sir.
         MR. SIEBER:  I think another problem, and this points out
     the importance of updating the FSAR is that when a designer puts a
     penetration in the control room, and looks at seals, he thinks they're
     firestops, unless he reads the FSAR and the design basis.  And so what
     he places in there, even as a temporary mod, allows leakage.  And so
     those are the kinds of things that generate these problems.
         DR. BONACA:  But also, this shows that even in the cases
     where they were so good at putting insulation, they never, except in one
     case, met their analysis inleakage.
         MR. HAYES:  That's -- that's correct.  You know, in no cases
     did they ever met the original analysis.
         DR. BONACA:  So those are, you know, impossible to achieve
     almost, as --
         MR. HAYES:  Well, I think, you know, to assume that you have
     significantly low values of inleakage is -- may be a stretch on many
         DR. BONACA:  That's right.
         MR. HAYES:  Because one of the -- you know, we have found as
     a result of a lot of this work that it depends upon whether you're
     ventilation equipment goes outside the envelope, because if it goes
     outside the envelope, then the air handling units, you know, the duct
     work, are very susceptible to inleakage and bringing contamination. 
     Plus, if you have ductwork which traverses the envelope that may have
     nothing to do with the control room -- for example, you may have aux
     building, turbine building ventilation systems that go through the
     envelope.  Those can be a source of inleakage.
         MR. SIEBER:  Yes, that's right.
         MR. HAYES:  You know, like, like, some of those lower
     values, like here, you know, this is very good, and this is a recent
     test, and it's because in essence all the equipment is within the
     envelope, you know.
         DR. KOVACH:  Yep, I'd still like to caution that in almost
     all of those values, you can put in about a plus minus 8 to CFM.  And
     don't assume these measured values to be the worst because they were
     still, you know, outside -- air handling systems were still operating
     and this is not the most conservative condition under which these were
         DR. KRESS:  May I put plus and minus 80 on that 70 one?
         DR. KOVACH:  Yes.
         DR. WALLIS:  I guess I can say that inleakage and outleakage
     are the same thing.  Same number, simply by conservation of math.
         MR. HAYES:  Well, you don't blow the -- if you don't blow it
     up or you don't implode it, you know.
         DR. WALLIS:  I just wondered, though, if you measure it some
     consistency in the measurement of that?  What did you measure in or out
     or both and take the average or what?
         MR. HAYES:  Okay.  I myself did not perform these tests. 
     These were performed by the licensees' contractor.
         DR. WALLIS:  It would be interesting to see if there are two
     numbers vastly different depending on how you measure.
         DR. POWERS:  Well, I think the -- I think we in the material
     we had in preparation for this, there was a section that fairly
     exhaustively discard the test procedures and that they did, and it
     differs depending on the type of system you have, and the amount of
     leakage you anticipate.  And I think the -- the interesting conclusion
     was that sometimes if you think you're going to get 10, and you're going
     to get 4,000, they system doesn't work very well.
         MR. HAYES:  For example, this plant right here which was
     done was just done within the last couple months.  You know, the
     individual who did the plant told me for sure the he didn't believe that
     the number was going to be 35.  He did anticipate that it was going to
     be a couple hundred, and it was on the order of a thousand.
         DR. WALLIS:  Well, this leakage, though, it depends on
     what's happening.  I mean, it's driven by something.  Sure.  If there
     are pressure differences through a building because of something like
     the wind outside, it makes a difference.  If this room is hotter than
     another room, and there's circulation-driven stuff, you can't just
     measure a leakage and say this is leakage.  It depends on what's going
         MR. HAYES:  Okay, most of these leakages, if you will, are
     mechanically induced by either the air handling units which are
     operating --
         DR. WALLIS:  Under some sort of special conditions.  If the
     conditions change to an accident, leakage will change.
         MR. HAYES:  Okay, the -- they would if they changed, but
     the, if you will, the conditions under which they are measured are with
     the emergency control room ventilation system operating.
         Now, I agree with you and Dr. Kovach that the important
     thing is to find your limiting condition, because it is influenced by
     adjacent ventilation system areas.
         DR. WALLIS:  Right.
         MR. HAYES:  And so, if you will, it depends upon whether you
     have a loss of off-site power or you don't have a loss of off-site
     power, whether you're running one train or two trains.
         Now, you know, I don't know in all these cases whether that
     myriad of ventilation of cases were analyzed.  But you're right:  they
     have to be investigated to find which is most limiting for your
     particular situation.  And I would also maintain that, if you will,
     ventilation systems are dynamic.  And what's true today might not be
     true next week, next month, you know.  And so this is a changing
         DR. BONACA:  Did plant A have walls around the control room? 
     I mean, 4,300 CFM --
         DR. POWERS:  Walls?  It was a tent.
         DR. BONACA:  It's an enormous flow rate.
         MR. HAYES:  It is enormous.  It is enormous.
         Okay, so to summarize a little bit with respect to these
     conclusions on these tracer gas is that you recognize now that
     approximately 20 percent of the control rooms, 20 percent of the
     reactors have been tracer tested.  None have met their design basis, and
     some we're sure did not meet GDC 19.  Okay.  There's a -- the variation
     between the measured and the assumed in their accident analysis is a
     factor of 1.5 to actually 55.  Some did seal prior to their testing, and
     it improved their condition.  I think it can be determined that the
     analysis level integrity does not exist.  And then finally
     statistically, there is no confidence of envelope integrity.
         Okay.  Now, the question is, okay, where do we go from this. 
     Okay.  In addition to having the tracer gas test results, we have had a
     significant amount of issues involving control room habitability that
     have been, if you will, inundating the staff.  We've had issues
     involving licensees' regional and resident inspectors finding and
     identifying the design, operating, and integrity flaws, you know.  I
     think probably it's true that many people hoped the issue of control
     room habitability would go away, but it hasn't.  You know, we
     continually find things.  Licensees find things.  Resident inspectors
     find things.  Regional people find things.  We have 50.59 evaluations
     where there's questions raised as to the adequacy of those reviews in
     terms of the changes licensees have made.  We have unreviewed safety
     questions.  We're continually, you know, looking at control room
     habitability issues.  Okay.
         We go to the point where, if you will, you know, we said,
     hey, stop.  Things have to get better.  We have to come up with some
         And so in July of last year, NRC, NEI, and NHUG held a joint
     workshop on control room habitability, where the staff outlined their
     concerns and the issues that they're dealing with.  We had some of the
     people who had done tracer tests made presentations, and then we also
     had NEI spokespersons make discussions with respect to the various
     aspects of control room habitability.  Out of that workshop was a
     control room habitability task force formed from NEI.  The staff has met
     with that task force on three different occasions, okay--in September,
     April, and then June of this year.  And what the staff is looking
     towards is NEI is putting together a guidance document on control room
     habitability.  And Mr. Cozens from NEI, he will be discussing that
     particular document.  But the staff is basically waiting to see that
     document before we take our next step, because the directive to the
     staff from the executive team of NRR was to work with the industry to
     try to resolve this problem.
         DR. WALLIS:  Can you put this in some perspective, and is
     there a problem of habitability with these leakage rates?
         MR. HAYES:  Well, I think that --
         DR. WALLIS:  Are the operators at risk in some way that they
         DR. UHRIG:  Not during normal --
         DR. POWERS:  Under accident conditions under a design basis
         MR. HAYES:  Yeah, under normal operation, as the gentleman
     said, there is none, but --
         DR. WALLIS:  Under normal, that's right.
         MR. HAYES:  But if you would have a toxic gas or if you
     would have a smoke event, or if you had a radiological situation, the
     operator could be impaired.  You know, I don't -- I think it's fair to
     say that I don't think any of us believe that at these integrity levels,
     that an operator is going to be killed from a radiological accident.
         However, I think it's also fair to say that we think it's
     unacceptable for the operator to try to perform their function with
     self-contained breathing apparatus on in the event of a radiological
     event, and in the case of a toxic gas challenge, well, we all ought to
     have serious concern for those facilities that have, you know, possibly
     inleakage rates as great as that.
         DR. WALLIS:  Well, the conclusion seems to be from your
     studies that all them leak like sieves except when patched up for a
     test.  That -- that -- and yet nothing concrete gets done about it yet. 
     They're making studies.
         DR. SEALE:  Have you detected any graded concern -- there
     are few plants which live in environments where there is an increased
     toxic fumigation from an adjacent facility.
         MR. HAYES:  Right.  Waterford is a good example.
         DR. SEALE:  Yes.  Have you detected any heightened
     sensitivity from plants like that?
         MR. HAYES:  Not any more for them versus, say, people who
     don't have it.
         DR. SEALE:  Okay.  No difference from them and Palo Verde?
         MR. HAYES:  That's correct.  Not that I have been exposed
     to.  Now, there may be, but I haven't been exposed to it.
         DR. SEALE:  Okay.
         DR. WALLIS:  I guess I'm trying to figure out how much of a
     -- how much of a problem this really is.  If it is a problem, why it's
     taken so long?  Maybe why it's taken so long is -- it doesn't help, but
     just to note that it seems to have taken an awful long time.  You go
     back to 1980 -- to still have control rooms, if this is an important
     problem, leaking sort of 10, 100 times as much as they're supposed to on
     paper.  If it's an important problem, it seems it rather strange to me.
         MR. HAYES:  Well --
         DR. WALLIS:  What's going to happen down the road?  I mean,
     is the purpose of bringing them back to the design basis or something? 
     Or there is no design basis, because it's not in some kind of
     regulation, I guess.
         MR. HAYES:  Well, the design basis is in their accident
     analysis and their licensing assumptions.
         DR. WALLIS:  Well, you could close them down if this were a
     problem design.
         DR. POWERS:  But that's all -- the general design criteria
     and applicable to this isn't --
         MR. HAYES:  Okay, yeah, the general design criteria says 5
     REM whole body or its equivalent, okay.  And so, if you will, the design
     criteria is not safe.  You know, 100 CFM of unfiltered inleakage or a
     1,000 that -- so, for example, if they can get by with 4,000, you know,
     and still meet the design criteria from a dose standpoint, you know that
     has to be considered to be acceptable.
         DR. WALLIS:  But has that been considered?  Has someone made
     this connection?
         DR. KOVACH:  I think NEI is working on that aspect of it.
         DR. WALLIS:  They're working on it.  I mean, God, I'm sort
     of puzzled --
         DR. KRESS:  Well, but those calculation involves a source
     term --
         DR. WALLIS:  Yeah.
         DR. KRESS:  And a transfer through the atmosphere.  You have
     to a have a transfer to the atmosphere --
         DR. WALLIS:  But you have to answer the question --
         DR. KRESS:  Close in --
         DR. WALLIS:  You have to answer the question are these
     operators during an accident?  And to say that someone's working on it,
     doesn't give any answer.
         DR. BONACA:  Well, one thing I've noticed is the point that,
     you know, in part, there is I think a complacency in the --
         DR. WALLIS:  Yeah, incredible.
         DR. KRESS:  Which is tied to two issues.  One is that's true
     that this things are not, you know.  And the other one is source harm is
     so conservative that it creates all kind of -- and so you have -- you
     have a certain attitude on the part of radiological engineers that they
     see both sides of the coin, and that's too bad, because it means that we
     have no understanding of where this issue is.  Okay.  What I'm trying to
     say is now that we are going towards a more realistic source term
     treatment, this becomes more important than ever before, because I think
     there are going to be more realistic assumptions of source term.
         Well, I'm not so sure because previous assumptions just
     assumed it was all metal iodine, and that may be a better assumption in
     this case.
         DR. BONACA:  Okay.
         DR. KRESS:  Going to the new source served.
         MR. HAYES:  But I caution you with respect of the new source
     term.  The new source term is only good for field damage accidents.  You
     still have accidents, like steam generator tube ruptures -- you know,
     the main steam line breaks, and you know in part of your evaluation. 
     And I think the steam generator tube ruptures is one that you really
     need to look at as a real, real, potential accident, which has nothing
     to do with the source term of NUREG 1465; it's a coolant source term. 
     And so your chemical form in those considerations are much, much
         DR. BONACA:  So there is urgency that this issue get
         MR. HAYES:  Well, you know, I think it's an issue which, you
     know, we should deal with it and put it to bed.  You know, it's sort of
     like having a car where you have a starter problem, you know.  And you
     can't run your car because the starter is always acting up, you know. 
     You should get the starter fixed and put it to bed.
         DR. WALLIS:  But you know that.  That seems to be in all
     diffused.  It would seem that if the control rooms are left and not
     source sealed up for the test, they're going to degenerate again until
     the leakage is in the order of thousands of CFM.  That's -- that would
     seem to be unacceptable, unless this -- some other mitigating
     circumstance somewhere.
         MR. HAYES:  Okay.  My impression from the sealing work that
     has been done to date, you know, prior to these tests, is not -- I don't
     think it's a situation where you're just going to degrade, say, from
     like this value of 260, which was on there, to, you know, which had
     4,000 and went down to, like, 242.  I don't think you're going to see
     that type of degradation.
         Unfortunately, we don't have a whole lot of data in terms of
     subsequent test.  You know, I think that's something that the staff
     believes.  When we had our workshop, we thought that one of the
     potential solutions to this issue was periodic surveillance of the
     control room envelope that demonstrates the integrity, say, on a
     refueling cycle basis.
         DR. KOVACH:  But, one of the -- maybe easier things to
     perform for continued surveillance is how many CFM do you need to
     maintain a certain pressure in the control room?
         DR. WALLIS:  That's a measure of the pressure.
         DR. KOVACH:  Measure, measure the intake flow to maintain a
     certain positive pressure.
         DR. WALLIS:  That's right.
         DR. KOVACH:  That will give you what your outleakage is if
     it's deteriorating or not.  You don't necessarily have to go back to
     tracer test.
         DR. WALLIS:  You can do that very quickly.
         DR. KOVACH:  I can do that quickly, and that's why I said
     that we have to have a commensurate test for the relevance of the
         MR. HAYES:  Okay, let me point out something about that
     proposal, though.  That proposal presumes that, in essence, you have a
     steel box, with the only penetration being that particular ventilation
     system.  Because the people who did the test at that plant C, see, would
     tell you that they had no problem achieving a positive pressure.
         DR. WALLIS:  No, no, no, no.  It doesn't -- it has leaks in
     it, so you figure how much you have to pressurize it, and to start the
     flow rate.  That gives you a measure of the leakage.
         DR. POWERS:  Yes.
         DR. WALLIS:  What comes in has got to go out.  It's not just
     pressurizing the box.
         DR. KOVACH:  That's correct.
         MR. HAYES:  But you have to be able to measure the path
     that's coming in and out and with the duct work that traverses.  In some
     of that, you don't see those pathways.
         DR. WALLIS:  Put a fan in the door and measure the pressure
     in the room that it creates.  That's all you have --
         DR. KOVACH:  I mean, these have positive, you know,
     ventilation system that feed air into them.  What you'd have to do is to
     very carefully monitor that and see what -- how much you have put in to
     maintain the pressure, because the arrow in that test is exactly the
     same arrow that you will see in the tracer test also, because you'll
     have to adjust it with the fresh air coming in, because you are looking
     at a dilution of a tracer.
         DR. WALLIS:  I'm not sure it's a linear system.
         DR. KOVACH:  It is.
         DR. WALLIS:  If you have something like a curtain, and
     there's a wind, the curtain moves.
         DR. KOVACH:  Yes.
         DR. WALLIS:  This is an exaggerated case, but if you have
     something like a curtain, it doesn't take much pressure to move
     something which is venting flow, which is like a curtain.
         MR. SIEBER:  Maybe I could add that the control room
     envelope is often very complicated.  They contain a number of rooms that
     are separate from one another.  And the adjacent rooms may have all
     different pressures depending on the ventilation there.  You may have
     penetrations that leak in, and others that leak out at the same time
     while the system's in pressurized operation.
         MR. HAYES:  Yes.
         MR. SIEBER:  So it is really not a simple problem.
         MR. HAYES:  You are correct.  Very much so.  For example, I
     think the -- if you look on your slide, the B plant that was -- has I
     think around 100,000 cubic feet in their volume.  It's like goes five
         MR. SIEBER:  That's right.
         MR. HAYES:  You know, and it's very different.
         MR. SIEBER:  And inleakage and outleakage are often
         MR. HAYES:  Yes.
         MR. SIEBER:  Mainly because of the door seals, you know,
     they're like diodes.  Do they leak out better than they leak in,
     strangely enough?
         DR. WALLIS:  I'm trying to put it in perspective, and there
     is some other situations where if the licensee were off by sort of two
     percent in something, he will be shut down.  Here, he's off by 2,000
     percent and isn't shut down.  What's the justification for tolerating
         MR. HAYES:  I think probably that the licensee has utilized
     Generic Letter 91-18, you know, which allows them to assess it on a
     realistic basis, you know.  And they have the opportunity to bringing it
     back within the design specifications or make a determination that they
     can change it and change this design.  And they -- they assess it based
     upon their impression of the safety significance of the particular
     element.  And I think it's fair to say that in some cases, control room
     habitability is down on the importance level.
         DR. WALLIS:  So there is some sort of a paper escape clause
     that says, although things are lousy, they can continue that way because
     we've written some paper.  I'm just being naive, but that's what seems
     to have happened.
         DR. POWERS:  I don't know that you're being naive.  I think
     you're just being puzzled.
         DR. WALLIS:  I am not perplexed yet.
         DR. POWERS:  I'm always perplexed.
         DR. KOVACH:  I think it's worth mentioning, though, Jack,
     that some of them manage to bring it down to the levels that you
     indicate by excluding certain parts that prior to the test were
     considered to be part of the envelope.  And as long as they consider
     those also, there was no way to bring it down, and they actually
     narrowed the control room envelope.  And certain areas that were prior
     to the test were considered to be part of the envelope became excluded
     from it because they were hopeless.
         DR. WALLIS:  I'm trying to just figure out if the ACRS has
     to take some position on this.  And what do they do it, between saying
     everything is fine and dandy or this is completely intolerable. 
     Somewhere in this spectrum is the right view of things, and I don't
     quite know where it is yet.
         DR. KRESS:  Because you don't have a risk analysis.  It
     tells you the importance.
         DR. WALLIS:  And if I don't know where it is, I've got to be
     conservative and say it's intolerable.
         DR. POWERS:  Well, I think you're going to get a chance to
     pursue this further in your --
         DR. KRESS:  Yeah, in our subcommittee meetings --
         DR. POWERS:  Subcommittee meetings -- so maybe want to move
     on in this?
         DR. KRESS:  Yeah, I think now is a good time to move on to
     the NEI presentation.  We need to --
         DR. SEALE:  I have a feeling that this problem has been
     subjected to a rather interesting kind of management attention, namely,
     without an accident, it's a mess to fix.  And it won't stay fixed -- the
     dents in the parking lot problem.
         DR. WALLIS:  Is this a generic problem?
         DR. SEALE:  Yeah.
         DR. WALLIS:  Management attention?
         DR. SEALE:  In this -- I think it's generally what's
     happened.  And with an accident, this is the least of your worries, at
     least until the lawyer shows up.
         DR. POWERS:  Well, I think you -- I mean, if you think in,
     say, design basis accident space, where you require -- you're certainly
     hoping that you have operators --
         DR. SEALE:  Yeah.
         DR. POWERS:  Essentially capable of doing their job for an
     infinite amount of time, but certainly for 30 days.  You know, there is
     these questions that -- of habitability clearly are very important --
         DR. SEALE:  Yeah.
         DR. POWERS:  And the questions that Dr. Kovach raised about
     how do you assess these filtration systems for my two-hour test to 7
     days, 30 days plus become very real.
         DR. SEALE:  There's whistling in the dark going on to answer
     your question.
         DR. POWERS:  And if you move to severe accident space, I
     think the attack on the control room becomes a good deal more severe
     than it is under design basis space and maybe -- on the other hand maybe
     the demands on having operators present and capable drop off pretty
     dramatically, too, because there is not much they can do once you get
     into a severe accident.
         DR. WALLIS:  How do you find leakage?  You don't go around
     with a candle.
         DR. KOVACH:  Certainly, there's precedence for it.
         DR. WALLIS:  Worked once?
         DR. KOVACH:  You actually generate a tracer and use the
     outside tracer detector in areas --
         DR. WALLIS:  You go around and sniff for it?
         DR. KOVACH:  You sniff for it, and then you can shroud off
     -- in many cases, you can see it.  You don't need to run a tracer test
     for 90 percent of the latter, just find the holes.  In fact, you can
     hear the whistling in some cases.
         DR. WALLIS:  I was just wondering if you would -- the
         MR. HAYES:  Mark?
         MR. REINHART:  This is Mark Reinhart again.  I'd just like
     to add, there are a number of facets to this, this issue, and the staff
     really does want to see it resolved as a package, all the facets, so
     that we do have a proper control room habitability.  And I think that's
     what we're looking for right now.  We're hoping this NEI initiative gets
     the industry started in the right direction, so we're going to be
     looking to see what happens there.  I think Mr. Cozens will probably
     update us on that, but we're looking for something this month as their
     initial proposal.
         DR. WALLIS:  I dare say I was very surprised.  Here's a
     problem which affects public safety, or at least some safety of people. 
     Here is an agency in charge of that waiting for this could be to give
     them something, tell them what to do.  It seems to me extraordinary.
         Again, I am being my naive self, and this is my reaction.
         DR. KRESS:  Well, with that comment, I would like to turn
     the floor over to Cozens' NEI to give us some presentation.
         MR. COZENS:  Good afternoon.  I'm Curt Cozens from NEI.  I
     am the senior project manager responsible for this issue at NEI, and we
     have a summary here of where we stand today, and how we got to where we
     are, and I'd like to share that with you.
         Just as the punch line I think was mentioned earlier that
     the staff is waiting for our guidance document.  That is true.  We've
     discussed it with them, but we have not actually provided it to them as
     of yet.  We're still having to work on some of the details.  It's a
     fairly substantial document--about an inch thick.  And we're looking for
     guidance that will both educate the industry, because there's always
     that issue of bringing everybody to a common baseline, as well as the
     effort to give some structure to provide a consistent set of guidance
     that licensees can, indeed, follow.
         So having said that, which is a little bit of a stealing the
     thunder on my presentation, let me just do a little review of where
     we've been on this thing.
         We actually did not get involved in this until last year,
     1998.  Formerly, we probably kicked off our activities of understanding
     this issue on a more generic basis in July of '98.
         DR. WALLIS:  So, mate, those were emerging concerns for a
     problem which has realistically been here all along.
         MR. COZENS:  These are issues that we have been aware of. 
     We had been -- the GSI was at 83, had been put to bed, and those were
     the reactions that were responding to.  Subsequent to some additional
     test issues that have come out since then, new information has become
     available.  It's not always readily cognizant of the significance to
     individual plants, and that's one of the things we've been developing in
     this process as we've gone further and further into it.
         As a result of the workshop, which did, indeed, define the
     issues of concern to the NRC staff; it redefined it to the industry,
     taking Jack's slide.  It looks like, indeed, these were some of the same
     concerns that had existed previously, and we revisited them and have
     worked on understanding better what these really mean to the industry.
         As a result of this workshop, NEI did, indeed, form a task
     force to deal with this and to - with the goal of providing guidance
     back to the industry, and I'll get more into that in a bit.
         Back in September of last year, we had formulated some of
     our thoughts on how to approach this issue, some of the concerns.  As
     you can imagine in an issue of this nature, there is a lot of wrangling
     that goes on with 100 odd plus plants, various utilities, individuals
     with different perceptions and needs, and we have to bring them together
     in a single position.  That's an interesting challenge that, indeed, we
     needed to wrestle with and are continue to wrestle with.
         DR. POWERS:  Well, I guess the question comes up when they
     see results of a sampling that says 100 percent of the sampled control
     rooms failed to meet what was assumed in the FSAR for the inleakage and
     not by small margins.  Did somebody actually say that now that's good
     for everybody else, but my control room's okay?
         MR. COZENS:  There was some interesting discussions on that,
     but I think we'd have to conclude that that's an issue at hand.
         DR. WALLIS:  It seems interesting.  The response to all this
     is to discuss it?
         MR. COZENS:  No, what we're doing here -- we could come in
     and everybody could manage it in 104 different manners.  That's not a
     good use of resources.  We're trying to provide some consistent guidance
     and some logic behind it.  And any time you're dealing with this type of
     issue, you must realize that there will be differing of opinions. 
     They're not always right, but at some point you need to bring them
     together and provide a logic that is somewhat irrefutable, because not
     everybody has all this information at hand.
         MR. SIEBER:  Curt?  The small bullet under the third item,
     issues of compliance, concern, but low safety significance.
         MR. COZENS:  Yeah, I think one of the things that Jack's
     slide, which I thought was good -- it showed that there was quite a
     variation in measured in unfiltered inleakage.  This is what we're
     talking about, which is really a focus of the radiological issues more
     than the toxic gas, because you may not have unfiltered inleakage, you
     just may have inleakage because you were isolated, not necessarily
     pressurized for the toxic gas.  There may be more experts in this room
     that can clarify that more than I can, but issues of compliance.
         Compliance is what did you assume in your analysis, and what
     do you actually have there?
         That is the different number than you might -- the maximum
     number you might be able to tolerate and meet the requirements.
         MR. SIEBER:  Well --
         MR. COZENS:  So we don't have -- in many cases, these
     numbers were, to be quite frank, cookbook, the 10 CFM.  That was a
     number that was widely used back when these designs were being made,
     rightly or wrongly, apparently it actually looks like it's probably not
     a good assumption.  And it was readily accepted in the days that those
     were made, and so being that that had been an example of reasonable
     number to use as an assumption, it was used by a large number of people. 
     It wasn't challenged by staff or industry.  Wrongly, rightly, that's the
     way things were at that point in time is a poor assumption.
         DR. WALLIS:  Ten CFM, excuse me, led to some sort of
     radiation -- REM calculation or something?
         MR. COZENS:  Yeah, it did and all it would have demonstrated
     that you were lower than some other value.
         DR. WALLIS:  Well, but then, what was the margin to
         MR. COZENS:  That's one of the things that's many people are
     going to have to probably look at as they examine this situation.
         DR. WALLIS:  Well, crudely speaking I say if I got 10 CFM, I
     have ten to the minus five millirem or something. I've got a thousand
     times as many CFM, I just multiply it by a thousand.
         MR. COZENS:  They're -- we're probably -- I don't have a
     hard number to provide.  That will be a very pleasant --
         DR. WALLIS:  Isn't that an order of magnitude calculation
     that's not unreasonable?
         MR. COZENS:  Probably.
         DR. WALLIS:  And does that exceed some acceptable dose rate?
         MR. COZENS:  Not necessarily.
         DR. WALLIS:  Does it or does it not.  I mean, as a
     calculation, it can be done very simply by -- without discussing
     anything -- just taking the numbers on Jack's slide and saying, is there
     a problem here or not.
         MR. COZENS:  The -- what I'm saying is that once they used
     an assumption that gave them an acceptable answer, they didn't establish
     the margins.
         DR. WALLIS:  They did -- if the allowable number is 10, and
     then calculated 1, then is something goes up by a factor of 10, they're
     up to the limit.  Is it not as simple as that?
         MR. COZENS:  If that was the number.  The point is, and what
     I'm saying here I don't know what each plant had, so I am unable to
     answer your question.  I can say --
         DR. WALLIS:  But the NRC or someone could have said, do this
     calculation.  It takes five minutes, and let us know the answer if
     you're outside what was originally -- what -- whatever the regulations
     say you should have for a dosage to operate, is then we'll shut you down
     or something.  I don't under this waiting for some --
         MR. COZENS:  Well, if you let me continue with this
     presentation --
         DR. WALLIS:  I'm sorry.  Maybe you should go on.
         DR. KRESS:  Well, the question I might have asked about that
     is how is this determination about low safety significance made?
         MR. COZENS:  We have done an analysis of margins on the
     various parameters that are input into this analysis, and have concluded
     that we're on the order of 50 to 100 factor of excessive margin in
     assumptions that are put into the analysis.
         That is no -- that is a rough order estimate.  And that's
     something that we've shared with the staff in June.
         And they have yet to have a chance to totally review it, so
     I don't want to go beyond the fact that's what -- when we did our
     analysis, that's what we came up with.
         But the point is, it's clear there's a lot of margin in
     these analyses, and that's something that will be included.  That's not
     to discount the concept of compliance.  That's just a technical
     understanding of what the this thing is
         And so based upon that, that plus the value in the GDC is
     believed to be extremely conservative, that just because one would
     exceed the GDC criteria, we don't believe is a ready indication that the
     operator would, one, be unable to perform his duty, nor would it result
     in an immediate health issue for the operator.
         DR. BONACA:  Although I can tell you that I have seen cases
     where the calculations have been redone entirely, and for normal
     accident analysis, they come very, very close to the limits for control
     room habitability.  So I am saying that I don't think there is the
     margin that you seem to indicate there is.
         MR. COZENS:  This margin is within the way that the analysis
     is structured, which will be detailed more in our presentation, probably
     in September.
         But we had concluded, based upon our evaluations under
     basically the guise of Generic Letter 91-18, for the individual
     licensees, when they did their studies, that they were able to continue
     to operate and, indeed, I believe did in all cases.  But the point being
     that there is a difference between what is used as an assumption and as
     a licensing basis, versus what the maximum number would be, and that is
     something that needs to be studied further.
         And then we basically have taken our path the guidance to
     the industry for resolving this issue, something they would be able to
         Over a period of time in the September to October timeframe
     of last year we, in writing, laid out to the staff where we were going
     with this issue.  We received some feedback from staff urging us to take
     extra emphasis on the unfiltered inleakage issue, which we have, and we
     responded back to them.
         We have subsequently developed some early drafts of the
     guidance document that we are continuing to work, taking into
     consideration some of the comments that we did receive from the staff,
     from our presentation material, and also some additional work that we
     have been doing.
         We met with the staff in June of this year to provide them a
     review of the margins analysis that we have done.  Again, we got some
     additional feedback on that which we are continuing to pursue.
         Our objectives are very simple.  We are interested in
     assuring adequate protection of the control room operator.  This is of
     very high importance to us.  We do indeed need tight control rooms for
     that.  How you manage that is the subject of our guidance.  Given what
     we see this as, the relative safety significance, what is the effective
     response process?  That is one of the things that we have had to wrestle
     with, there are many competing demands when you get into providing
     generic guidance to an industry.
         DR. WALLIS:  Excuse me.  These margins analysis, did you
     submit documents where you calculated the dose and so on?  You indicated
     there was a 50 to 100 factor margin.  Do you have -- is that written
     down somewhere?
         MR. COZENS:  Not in this presentation.
         DR. WALLIS:  Could we see if it is written down somewhere?
         MR. COZENS:  It will be provided at the September meeting,
         DR. WALLIS:  In September?
         DR. KRESS:  We are having a subcommittee meeting in
         DR. WALLIS:  So it is all put off, right?  We haven't see
     anything quantitative about this issue.
         MR. COZENS:  Staff has that information.
         DR. WALLIS:  Staff has it.  Can they give it to us?
         MR. HAYES:  We have had a discussion on it, but we don't
     have anything in terms of -- we haven't seen the discussion of it.
         DR. WALLIS:  We are back to discussion again.
         MR. COZENS:  Pardon?
         DR. KRESS:  We hope to get some hard information in the
     September subcommittee.  That is why it was put off till September
     actually, to have time to get this information together.
         DR. WALLIS:  Well, maybe I will have to ask my colleague,
     Dr. Bonaca, to give me his figures where he says they actually come
     pretty close to a margin.
         MR. COZENS:  We are studying the assumptions that are put
     into the analysis, not the actual analysis, and have dissected it and
     which does demonstrate a fairly significant margin.
         DR. POWERS:  I assume we can translate that and the
     objective is to find a paper way out of this problem.
         MR. COZENS:  No.  I will emphasize what the purpose of that
     is simply.  To say that you have margins does not eliminate to have
     compliance with the regulations.  It is a technical understanding of
     what is the consequences of this.  It is useful in doing an operability
     determination, but it would not eliminate the need to be in compliance.
         DR. WALLIS:  Are there any other regulations like this?
         MR. COZENS:  I am not certain I understand your question.
         DR. WALLIS:  Where you can say we don't meet the licensing
     basis, but there is a huge margin, so we don't need to worry.  Are there
     are other regulations like that?
         MR. COZENS:  The licensing basis frequently establishes a
     number far lower than the regulatory requirement.  That is what we have
     here.  The assumptions that were used for unfiltered inleakage, which is
     just a -- I would have to check carefully with our licensing folks. 
     That in itself is not the regulation, it is a number that was used in
     the design.
         DR. WALLIS:  So we are back to margins and what they mean.
         MR. COZENS:  But that is not the solution to this problem,
     as I just said.  The solution to this problem will require compliance to
     assure that they in compliance.
         DR. KRESS:  Well, we just heard that there is a lot of the
     plants assume 10 CFM.
         MR. COZENS:  Yes.
         DR. KRESS:  And we also heard indications that that is
         MR. COZENS:  Yes.
         DR. KRESS:  So, I mean you are going to change the licensing
     basis, is that the way you get into compliance?
         MR. COZENS:  The plants that have done the testing, -- and,
     Jack, maybe you could confirm this, did they change their licensing
         MR. HAYES:  Those that didn't restore them to the original
     level.  Like some of those plants, like I think it was C, maybe E or F,
     they had the values at 260, they went below their original licensing
     basis, so they restored it.  Other ones have not, they have used some
     higher value and come up with a new analysis.
         DR. KRESS:  They still meet the GDC criteria.
         MR. COZENS:  That's correct.
         MR. HAYES:  Yeah, they still meet the GDC.  Yeah.
         Probably with some form of a margin on top of that even. 
     Those are very plant-specific situations that need to be analyzed by the
     plants.  We are trying to provide the generic structure on how to
     approach it so they can walk into this using good, appropriate resources
     balanced against other needs in the plants.
         DR. WALLIS:  I am kind of interested to see what would
     happen with a 50.59, where you were trying to prove your change
     inleakage was minimal.  It would be a really interesting exercise to
         DR. POWERS:  If your inleakage is 4,300 cubic feet per
     minute, to make a small change in taking out a fire detection system,
     leave a hole in there, I suspect it is a 50.59.
         DR. WALLIS:  Well, there is a connection.  I am sorry we are
     -- the reason I am doing this, because it impacts on so many other
     things we have discussed in this committee.  In all our discussion of
     50.59, there was this reluctance to give up margin, and this slowly
     takes small bites out of it and so on.  Here it seems as if there is a
     willingness to give up the whole margin, in fact, not even quite know if
     you are doing it or not.
         You had better go on.
         MR. COZENS:  The approach that we have taken in this report,
     which will be provided, recognizes the significant variation in plant
     design and licensing criteria.  Plants are very different.  Each plant
     has its own unique physical configuration, frequently different
     hardware, very often different licensing requirements that impact them,
     very often different technical assumptions that were made that have to
     be walked through, validated, and generated.
         The unfiltered inleakage which is one of the questions that
     arise was only one of the issues that was raised by the NRC staff.  We
     are looking at all of the issues that were identified by the staff.
         We are looking at trying to provide guidance that will
     indeed provide a balanced approach, one that demonstrates that the
     operational staff is indeed protected, that is in compliance, but also
     is using an optimization of the resources that the licensee has.  These
     are all things that each licensee needs to balance to be an effective
     producer of electricity.  And that's just one of the -- how we're
     approaching this thing.
         The document which is NEI 99-03 develops guidance that
     licensees can use.  It has a very strong educational role for licensees. 
     As I said, a lot of staff rotation has occurred on this.  Different
     States, and I'll be quite frank, believe in the significance of this. 
     We need to bring it to a common point.
         DR. WALLIS:  Is this close to be a finished document?
         MR. COZENS:  Yes.
         DR. WALLIS:  Or is it just an outline?
         MR. COZENS:  No.  It's about 100 pages right now.  We're
     doing the polishing on it right now.
         DR. WALLIS:  How much more is left to be done?
         MR. COZENS:  I'll address the schedule in a second.
         DR. KRESS:  When you do a design basis calculation here to
     determine the dose, do you just input into that calculation the
     unfiltered leakage rate?
         MR. COZENS:  You might be better off asking that specific
     question of somebody -- maybe the gentleman next to you, Dr. Kovach.
         DR. KRESS:  That's the reason I asked, because Kovach said
     that may be a real problem.
         DR. KOVACH:  It's a combination of they take credit for the
     forced ventilation for the system plus that it's assumed that what is
     the inleakage.  And there are questions whether the assumptions put into
     the forced ventilation efficiencies are realistic or not.  Those are the
     99.9-pluses.  Because how much inleakage you can tolerate depends
     greatly on what is the efficiency of your --
         DR. KRESS:  What you're saying is there's two parallel
         DR. KOVACH:  That's correct.
         DR. KRESS:  And one of them has a filter.
         DR. KOVACH:  Yes.  The other is not.
         DR. KRESS:  And so since there's 99 percent, it doesn't
     enter into the dose.
         DR. KOVACH:  If you in fact get a 99 percent.
         DR. KRESS:  Yes.  Because that's what they use.
         DR. KOVACH:  Yes.
         DR. KRESS:  It doesn't enter into this calculation.
         DR. KOVACH:  Yes.
         DR. KRESS:  So that looks like -- is that being addressed in
     the NEI document at all?
         MR. COZENS:  We primarily are focusing on the --
         DR. KRESS:  Unfiltered.
         MR. COZENS:  Assumptions that had been taken in the initial
     analysis and giving them guidance on how to make more appropriate
         DR. KOVACH:  But the mix that will give you the dose is a
     factor of both.
         DR. KRESS:  Yes.
         DR. WALLIS:  I don't think you should give guidance on
     assumptions.  You should give guidance on reality.
         MR. COZENS:  As in many engineering features in a plant,
     there's thousands of assumptions made that keep these plants operating.
         DR. WALLIS:  That's one of the problems.  You have to know
     how close these are to reality.  You have to know something about the
     uncertainties.  When you use a number you've got to have some awareness
     of -- you can't just say it's an assumption.  You've got to qualify it
     and quantify the nature of that assumption.
         MR. COZENS:  It has to be based on something.  We agree.
         DR. POWERS:  Dr. Kress, I'll call attention to the timing
     here, recognition that we will be doing a subcommittee --
         DR. KRESS:  Yes, I think we need to move on.
         DR. WALLIS:  I'm sorry I'm taking too long.  I suppose it's
     because I'm surprised.
         DR. KRESS:  We'll get a chance to talk about this some more. 
     You're welcome to come to the subcommittee meeting.
         DR. WALLIS:  I was afraid you might say that.
         MR. COZENS:  Let me hit on the near-term activities.  As I
     said earlier, we will be giving the staff a copy of the draft document
     for formal commenting prior to the NHUG meeting, which will take place
     about the time of the August ACRS meeting, or is there -- August 12, 13
     I believe is when the NHUG meeting is.  We'll be also in a parallel path
     providing that to the NHUG members, and we'll be soliciting feedback
     both from the staff and from the NHUG members.
         Once we take that input, make whatever refinements are
     justified based upon the comments we receive, we will be making
     adjustments to the document, and we hope to get that final document out
     for industry use late September, early October time frame.
         I have outlined here the basic sections of the 99-03
     document, and we'll be happy to go through those in detail if you wish,
     but in light of the time I don't know if you want me to continue on that
     or not.  It's pretty self-evident.
         DR. KRESS:  Yes, looking at the slides, I think we could
     postpone that part to the subcommittee meeting later when there's --
         DR. SEALE:  That's a good idea.
         DR. KRESS:  When we can get into really detailed questions
     on it.
         MR. COZENS:  Yes.  We'll have more expertise with this that
     would probably be better equipped on a few of the questions.  Okay?
         DR. KRESS:  Okay.
         DR. WALLIS:  Do you know ahead of time, is this document
     going to say there is a problem or there is not a problem?
         MR. COZENS:  We are giving guidance for plants to make that
         DR. SHACK:  Look at slide 8.
         DR. SEALE:  Yes, that's -- 8 did it.
         DR. POWERS:  I just can't help but note that those of us
     that run chemical facilities -- and I guess, Dr. Kovach, you know more
     about this than I do -- seem to be in the world of where -- we live in a
     world of ratcheting protection on our workers with ever finer and finer
     demands being placed on us to assure their protection against chemical
     hazards, and ever greater and greater scrutiny from both State and
     Federal officials on our ability to protect our workers.  This seems to
     be a very relaxed environment relative to that.
         Fair statement, sir?
         DR. KOVACH:  Reasonable.
         DR. POWERS:  Reasonable.
         MR. SIEBER:  Could I ask one final question of Mr. Hayes?
         Does the NRC staff believe that this issue is one of low
     safety significance as the NEI slide indicates the industry believes?
         MR. REINHART:  I think that we've not concluded that.  The
     bottom line is is it's an issue to the operator, and if the operator
     doesn't function, is he available to take actions for the plant, and to
     what extent would this impair his abilities not only radiologically but
     toxic gas, smoke?  So those are concerns we have.
         MR. SIEBER:  Is that safety-significant?  Your concerned?
         MR. REINHART:  It's significant.  I don't know that we have
     an answer as to how significant.
         DR. WALLIS:  Just naively, I would think 4,000 cubic feet of
     smoke would be one humongous hazard in a control room.
         MR. REINHART:  I think smoke and toxic gas definitely.
         MR. SIEBER:  About half the plants clean their condensers
     with gaseous chlorine, and that's usually within a couple hundred yards
     of the control room air intake, and I've seen a couple cylinders go. 
     That's -- they're five-ton.  And that's bad news.
         DR. KRESS:  Yes, but leakage is not 4,000.  It's going to be
     like 400.  Yes.
         DR. POWERS:  Well, good.
         DR. KRESS:  Okay.  And with that we'll --
         DR. POWERS:  I'm going to recess until one o'clock.
         DR. SEALE:  Till when?
         DR. POWERS:  One o'clock.
         DR. SEALE:  Okay.
         [Whereupon, at 12:12 p.m., the meeting was recessed, to
     reconvene at 1:00 p.m., this same day.].                   A F T E R N O O N  S E S S I O N
         DR. POWERS:  Let's come back session now.  The subject for
     this afternoon is the proposed amendment to 10 CFR Part 50.55a.  And Dr.
     Shack, I believe you're the cognizant member on this and I'll turn the
     meeting to you.
         Incidently, in the course of this presentation, I will be
     transferring control of the meeting over to the member-at-large, to --
     so -- and disappear, unfortunately, for some other purposes.  So, Dr.
     Kress, you will -- might as well assume the gavel right now.
         DR. KRESS:  Okay.
         DR. SHACK:  Again, 50.55a is the portion of the code,
     essentially where you endorse the ASME code for -- incorporate by
     reference the ASME code.  Mr. Scarbrough will be discussing that today. 
     There's a number -- it's been a while since this has been updated, so
     there's a list -- he's responding to, I guess, public comment that
     ranges about an inch-and-a-half on various aspects of it.  In many ways,
     or at least in my mind, one of the most important things is to
     incorporate the necessity for performance demonstration of ultrasonic
     inspections and that was one of the contentious items in the thing,
     since it was an expedited schedule for the implementation of the
     performance demonstration.
         Again, you can say in the old ASME code, the requirements
     for Inservice Inspection were prescripted.  They told you what to do. 
     It didn't matter when you did it whether you found the crack or not, you
     know, you followed the rules.  The performance demonstration says that
     you actually have to demonstrate that your technique, whatever it is
     that you use, will find cracks.  And so, I believe that's an important
     one.  But, there's a number of other changes and in looking at Mr.
     Scarbrough's view graphs, I think he's going to do a heroic attempt to
     try to summarize all the changes and all the public comments that were
     received.  Again, another large part of the public comment is the fact
     that the NRC endorses the code with some limitations and modifications. 
     And, again, the consensus people always have a little problem when their
     work is not adopted completely.
         But, I understand Dr. Sheron wants to give us an
     introduction to this.
         DR. SHERON:  I'm Brian Sheron.  I'm an associate director of
     Project License and Technical Assessment.  I had asked if I might have a
     couple of minutes of your time to talk about one of the issues and I
     discussed this with Dr. Powers some time ago.  I thought it might be a
     good idea just to kind of least put a perspective and a question on the
     table, because it will come up again, and that has to do with the
     necessity of when we update 50.55a, whether it's necessary to require
     licensees to update to the latest endorsed edition of the code or
     whether there is a position, in which we only require them to update to
     those aspects of the code that provide a substantial increase in safety,
     namely -- or a backfit, you might say.  In other words, we pass some
     sort of a backfit test.
         When we looked at the ASME code, the '95 edition, the only
     piece of it that would pass a substantial increase in safety test or a
     backfit test, cost benefit, was Appendix 8.  The industry had proposed
     -- and this goes back aways to about 1994, '95, Entergy came in before
     they were required to do their 10-year ISI update, and proposed to be
     able to cherry pick, you might say, from the next edition of the code. 
     They argued that imposing a new edition on the code in total constituted
     a real burden for them, or at least some licensees, in the sense that
     every time they would -- you would change something, a lot of times it
     involved having to change manuals in the plant for doing the Inservice
     Inspection and testing; you would have to retrain some of the
     technicians.  But, the extent of the change was not such that it may
     really enhance safety.  It was just perhaps a better way to do
     something, but not something that would provide any quantifiable
     increase in safety.
         We did not agree with the ability to cherry pick.  We
     struggled with the issue for some time.  Finally, when we were getting
     to the final throes of endorsing 50.55a, NRR decided that we could not
     basically demonstrate that there was any measurable safety enhancement,
     i.e., from the 50.5109 standpoint, and so we said that we would endorse
     it as a voluntary code, namely that the industry could use it.  We had
     no objection to them using it, but they were not required to.  The only
     piece they were required to implement was Appendix 8.
         That, obviously, generated a lot of debate.  I believe the
     ACRS issued a letter on that.  The Commission finally decided that we
     would endorse, as a requirement, the '95 edition, with the '96 addenda
     of the code, and that we would come back to them this fall, presumably,
     with the recommendation on the question of voluntary versus mandatory
         I just wanted to bring that out, that the approach we're
     taking, it may have been misperceived that we were not going to allow
     anyone to update to a later edition of the code.  The only thing we were
     saying is we were certainly allowing -- and some utilities may find
     benefit in updating to a newer edition of the code, for whatever reason. 
     A lot of it is plant -- plant specific.  Of the utilities, for example,
     a plant that may be shutting down in two or three years, it may not be
     worth their while to spend the kind of money it takes to update, just to
     operate for a few more years.  So, we felt that in order to be able to
     rationalize when someone had to update versus when it could be
     voluntary, we should apply some sort of a safety test, which fits in
     with some of the NRR goals of no unnecessary burden.
         I do want to point out that we raised this issue with ASME,
     I know I raised it personally several years ago, and have asked the
     ASME, it would be very, very beneficial if, when they issue an edition
     of the code, they could distinguish between what is -- should be a
     voluntary or an acceptable way to update versus what is mandatory.  If
     that was in the code, itself, in other words, if they did the screening,
     that would make our life a lot easier.
         I don't believe they do that now.  We asked them, you know,
     perhaps to do some sort of a qualitative risk assessment or the like of
     what the benefits are.  That's not being done.  We have -- I feel that
     the NRC has an obligation, that we should not automatically impose a new
     edition of the code on the industry, without being able to quantify what
     the safety benefit is compared to what the burden is.
         DR. POWERS:  As you know, Brian, when we talked about this,
     I thought the suggestion -- this point of view that you had, had broader
     significance in this particular issue, in thinking about further -- how
     does that interface with the public law, concerning the use of consensus
     standards?  And I noticed in a lot of the public comments that same
     issue came up.  Have you thought about that at all?
         DR. SHERON:  Yeah.  People are interpreting that in many
     different ways, usually to their own benefit.
         DR. POWERS:  Of course.
         DR. SHERON:  You know, people that are advocates of
     mandatory updating will cite the public law and claim that, you know, we
     are required to use the code.  The public law basically says --
         DR. SHACK:  Well, you're currently required to use it and it
     will take a rule change not to update.
         DR. SHERON:  Right; yeah.  But what I'm saying is that the
     public law says that we will use consensus codes and standards, okay, as
     long as they are not contrary, okay, basically to the agency's mission
     and the like.  And to me, I interpret that to mean that we have our own
     regulations, including cost benefit, you know, backfit rule and so
     forth.  And to the extent that we endorse the ASME code, I feel it's
     consistent with the public law.  But, we're endorsing it as voluntary to
     use.  It's acceptable to use, okay.  We're not -- we're not telling
     people they can't use it.  But, we're not forcing them, that you must
     use that edition of the code and only that edition.
         We ran into this a little bit on IEEE 603.  I don't know if
     you remember that.  It replaced IEEE 279, which was actually withdrawn
     by IEEE, I think, back in the '80s; and, yet, our regulations still
     endorsed it.  We thought it was going to be a real simple thing, because
     603 was the new version, okay.  We went out with a direct final rule to
     change our regulation to replace 279 with 603, and we ran into a buzz
     saw from the industry, because they argued that it had -- it went beyond
     the scope of 279, because it did include digital.  They claimed that
     they had to, you know, do a -- I can't remember the exact words, but you
     had to go to the system level -- I'm sorry, down the component level, I
     believe it was.  But, anyway, we immediately had to drop off the direct
     final rulemaking approach.
         We thought we fixed the problem by backing off and saying
     that they only had to do the assessments down to the system approach. 
     That still ran into a buzz storm of -- you know, of objection from the
     industry.  And we wound up, basically, endorsing it as a voluntary -- as
     a code that could be voluntarily used.  But, we could not justify -- we
     could not pass a cost benefit test that says, you know, we can impose
     this.  So, we're running into that kind of a problem, is that as these
     codes are updated, it's very difficult to be able to sit there and say
     this is a substantial increase in safety, okay.
         We need to address the issue.  We asked the Commission if we
     could have more time to address the issue, to dialogue more with the
     committee.  I don't want to dialogue now.  I am not asking for that.  I
     want to get off here and let Tom get up here.  But, I did want to place
     the issue, you know, kind of on the table, let you think about it,
     because we will be back, okay, probably with a recommendation in this
     area.  And I know the Commission, and I've spoken to some of the
     Commissioners, they are not very comfortable when the ACRS and the staff
     are at odds, okay.  So, we would like to reach some sort of a consensus
     with the committee on how we can address this concern.
         And this is a concern with the industry.  Most of the
     industry comments that we've received, if I'm correct, basically agreed
     with the NRC's position, that we should not automatically mandate the
     next edition of the code.  So, I'm kind of struggling myself, because
     ASME is supposedly -- the code is an industry code, and, yet, I get
     letters from the industry that say don't impose it, and the ASME says
     you must impose it, okay.  So, we're kind of struggling there and I've
     kind of asked NEI if they could work with ASME and solve what these
     differences are.  It would be a lot easier for us if both sides came in
     and said this is the right way to do it.
         DR. POWERS:  There is a second stage in your position, as we
     discussed it, and that was we don't impose, if there should be something
     in an update that a rule of tremendous significance, the staff could
     always mandate that.  And in thinking about that, I said, well, does the
     staff have the capability to -- clearly the staff has a very clear
     capability and will establish capability to look at particular issues
     and say this is safety significant and it satisfies the backfit rule and
     I can impose it, and do that assessment.  But, these industry standard
     codes, they have lots of little things in them and especially now a
     days, it's lots of little things.  You're not getting --
         DR. SHERON:  A lot of them are just relaxations.
         DR. POWERS:  A lot of them are relaxations.
         DR. SHERON:  Right.
         DR. POWERS:  And -- but on the other hand, lots of them
     bring new technologies that allow lower worker dose and things like
     that.  The staff have the capability to look at lots of little things
     and combine them all together and then say, now, does that satisfy the
     backfit rule.
         DR. SHERON:  Not very easily, no.  But, you know, that's one
     of the issues that we have to struggle with, okay, is that, yeah, you
     could say, you know, how do I add up a whole bunch of little good things
     and a whole bunch of relaxations, you know, and try and say where does
     that come out and is that something that I can, you know, force the
     licensees to adopt or the like.  I just don't know.  I don't know how to
     answer that.  I think research tried that, at one point, and they kind
     of threw their hands up and they said they really can't.  Because, a lot
     of times, I know they've changed things in one part of the code and it
     affects another part, and you can't -- so, that's why we eliminated this
     any option called cherry picking, okay.
         The other thing I did want to point out is that from a
     safety standpoint, you can have a plant that reached its 120-month
     update, say, last year, I guess, okay, and they would update to the 1989
     edition of the code.  Well, with the exception of Appendix 8, they're
     going to run another eight or ten years, before they have to go to the
     '95 edition, okay.  So, it's very hard for me to argue and say, there is
     enough of a safety benefit that I can impose this.
         What I'm saying is one plant has to update today; another
     plant doesn't have to update until 10 years from now, okay.  Why is
     that?  If this is so good, why don't I make everybody update at that
     time?  Why can I allow these 10-year periods to go between plants? 
     That's a difficult thing.  I mean, I realize it's just the nature of the
     beast, but it's something that, you know, is hard to answer.
         Anyway --
         DR. POWERS:  How many other states -- how many other plants
     are located in states, where the state makes them update like within six
     months?  States aren't liberal as you are.
         DR. SHERON:  I'm going to have to turn to any you guys, if
     you know, because I don't.
         MR. SCARBROUGH:  Tom Scarbrough.  That's another question
     we've indicated from trying to get information from the states in that
     area, but we don't have an answer for you right now
         DR. POWERS:  They don't -- theirs is not -- the states that
     do it are not nearly as good -- I mean, they say do it.
         DR. SHERON:  But, I think that's only for the non-nuclear
     part.  They don't have the --
         DR. POWERS:  Yeah.
         DR. SHERON:  -- jurisdiction.
         DR. POWERS:  Yes, where they have jurisdiction.
         DR. SHERON:  Yeah.  So, anyway, unless there's any further
     questions, I just kind of wanted to, you know, lay out the issue and let
     you know we'll be back.  If you can think about it and, you know, we'd
     like to reach some sort of a consensus, so we can go back to the
     Commission and -- I'm trying to urge NEI and ASME to see if they can
     reach some sort of consensus, too, because they seem to be miles apart
     on this, and it makes our life much more difficult.
         DR. POWERS:  The ASME sounds like it's in survival mode
         MR. SCARBROUGH:  Good afternoon.  I'm Tom Scarbrough.  We're
     going to give you -- attempt to go through the significant changes and
     response to public comments that we received on the proposed rule change
     that we sent out.  And I want to give you a little bit of background, to
     back up a little bit, and sort of tell you how we got to the point where
     we are today.
         As a little introduction, as you know, the regulation --
         DR. POWERS:  I can't help but think you've been looking at
     codes and standards too long.  You try to produce view graphs that read
     like the ASME code.
         MR. SCARBROUGH:  Yes, I've been accused of that by others,
     as well.  I apologize.
         DR. POWERS:  But, you're not going to change, right?
         MR. SCARBROUGH:  I've told people the same thing.  It's too
     late; I'm too old.
         In terms of the regulations in 50.55a, they require power
     plant owners to construct, inspect, and test specific components in
     accordance with the ASME Boiler and Pressure Vessel Code, with certain
     limitations and modifications.  Back on December 3rd of '97, the NRC
     published a proposed rule to update the regulations, to incorporate by
     reference the '95 edition with a '96 addenda on the ASME Boiler and
     Pressure Vessel Code and the new ASME code for Operation Maintenance of
     nuclear power plants, the OM code, with certain limitations and
     modifications.  We, also, had provisions in there for endorsement of
     specific code cases and other portions of the code, to try to advance
     the technology aspects.
         We went through those comments.  We revised the rule.  We
     took out several proposed limitations or conditions that, based on
     public comments, appeared to be well founded.  So, we reviewed those or
     modified other aspects to make it more clear.
         Then on April 27th of this year, we published the proposed
     rule supplement, which focused on the 10-year update requirement and the
     proposed elimination of that requirement.  And then on June 24th, we
     received a staff requirements memorandum from the Commission, which
     directed us to proceed with completing the December '97 proposed rule
     expeditiously and to address elimination of the 10-year update issue in
     a separate rulemaking.  So, we have two separate tracks now that we're
     working on.
         DR. POWERS:  In your separation of tracks, is the 120-month
     update track going to accumulate lots of baggage along with it, or is it
     going to be -- remain pristine?
         MR. SCARBROUGH:  We're going to try to just keep it on a
     10-year update issue, so that we don't bring other things into it.  I
     think one thing we have talked about is in the next rulemaking or so, to
     try to go through 50.55a and sort of scrub it and make it more readable,
     which would be a nice idea.  And so -- but, we're trying not to do that
     in these, just because we're trying to focus just on the issues we're
     trying to deal with.  But, that's something we've talked about.
         DR. SEALE:  No new areas of confusion.
         MR. SCARBROUGH:  We're going to try to do that, right; try
     to stay away from new areas of confusion.
         I won't talk about the third slide there, the elimination of
     the 10-year update.  Brian has already given you kind of background on
     that.  Let me just go right into what the current regulatory
     requirements contain and to give you a little bit of feeling from where
     we are today.
         50.55a presently requires that power plant owners construct
     class one, two, and three components to the 1989 edition of Section 3 of
     the ASME Boiler and Pressure Vessel Code; inspect class one, two, and
     three components to the 1989 edition of Section 11 of the Boiler and
     Pressure Vessel Code; inspect MC and CC containments, metal and concrete
     containment components to the '92 edition, with the '92 addenda of
     Section 11; and then test class one, two, and three pumps and valves to
     the 1989 edition of Section 11 of the Boiler and Pressure Vessel Code.
     And then, as we talked about, there's a requirement that they update
     every 120 months to meet the edition and addenda of the code,
     incorporated by reference and, in effect, 12 months prior to the start
     of the new 10-year interval.  So, there's sort of a one-year grace
     period up there, to allow people to get ready for the new change.
         We talked a lot about trying to give you some highlights of
     what the major changes are, so that maybe it's easy as possible to work
     your way through this.  The highlights of the rule -- for example, we
     update 50.55a to reference the 1995 edition, with the '96 addenda of
     Section 3 and 11 of the Boiler and Pressure Vessel Code; and then, also,
     endorse the 1995 edition, '96 addenda of the OM code, so that brings up
     to that year.  We have one expedited schedule, as a backfit to require
     Appendix 8, regarding performance demonstration for ultrasonic
     examination systems, to be implemented as contained in the '96 addenda
     of the Boiler and Pressure Vessel Code, Section 11; or, in response to
     the industry's performance administration initiative, they can implement
     Appendix 8 as described by the PDI.  So, there's two paths that they
     could use to expedite.  Also, there's a relaxation on the schedule, too.
         We, also, provide certain limitations on portions, as always
     we do.  For example, the use of the ASME standard NQA-1 on quality
     assurance, seismic design of piping issues and MOV stroke-time testing. 
     And, also, we permit several code cases to be implemented.  So, that's
         DR. POWERS:  If I wanted to use the code cases, but I
     currently had a plant that was in compliance with the '89 edition, could
     I use these code cases?
         MR. SCARBROUGH:  Yes.  They have to have -- they're subject
     to NRC Commission approval.  There's a portion in there.  But, this
     endorses them, so there won't be any extensive review.
         DR. POWERS:  I understand, to upgrade to the '95 -- to use
     the '95 code cases?
         MR. SCARBROUGH:  No, no.  You have to make sure that if
     there's any cross references, straighten those out.  But, no, you do not
     need to update.
         Okay.  One of the things I did when I inherited this project
     was -- we wanted to go through and try to decide what was changing. 
     What does the current regulation say and what's the final rule going to
     say.  What's the main changes?  Because, in the interim, there's a
     proposed rule, and it had a number of changes in it, proposals in it,
     and some of those are no longer there and they've been taken out.  But,
     I didn't want to dwell on those, because you all don't have the benefit
     of a pre-proposed rule meeting, so that really wouldn't seem very
     important to you.  So, we tried to focus on where the regulations are
     now and where they will be if the rule is issued as currently drafted.
         So, in terms of paragraph (b) of 50.55a, we just change --
     we have to add a reference to the OM code and the address changes; so
     just administrative there.
         In (b)(1), we talk about Section 3.  We're going from the
     '89 edition and the '88 addenda, up to the '95 edition and '96 addenda. 
     There were no limitations in the current regulations on Section 3.  And
     we're going to -- we're proposing to add five, in terms -- in the
     endorsement of the '95 edition of Section 3.  And those five have to do
     with materials -- and we'll talk more about these specific slides on
     these -- materials, well dimensions, seismic design, QA, and inspection
     independence.  So, those are all -- that's all the limitations
     associated with the '95 edition.
         DR. POWERS:  The staff does not participate in the
     development of these rules?
         MR. SCARBROUGH:  Yes.
         DR. POWERS:  Oh, standard code --
         MR. SCARBROUGH:  Right.
         DR. POWERS:  -- sorry, the ASME standard?
         MR. SCARBROUGH:  Absolutely.
         DR. POWERS:  Why do so many limitations show up?
         MR. SCARBROUGH:  Well, I wouldn't consider so many, in terms
     of because it is from '89 all the way up to the '96 addenda.  So,
     there's a lot of time in there and there's a lot of changes.  For
     example -- I'll just give you an example for the materials, number one
     there.  There was significant numbers of printing errors in the '92
     edition and what this does is it alerts licensees to that and indicates
     they should use a different addenda for that.  And that's a type of
     thing that came up.  It wasn't able to be corrected in the '92 edition,
     so this was alerted -- an alert was made in here.  Because, what this
     does is it's really endorsing all of those editions and addenda, up
     through the '95 edition.  So, there's a lot of editions and addenda to
     look at there.  So, you know, there are some, but I wouldn't consider a
     significant amount from -- from -- considering how long it's been since
     we endorsed one of the codes.
         MR. TERAO:  Yes.  But, I would also like to point out that
     the ASME -- that the staff representative on ASME committee, there's
     only one person.  So, we only have one vote, of course.  So, any changes
     to the ASME code, the NRC staff representatives may not approve of it,
     but that does not stop it from going through.
         DR. WALLIS:  Now, the naive public might assume that NRC
     would be stricter than the ASME, that would require more and not here to
     require less.
         MR. SCARBROUGH:  I would say that when we do look through,
     if there's something that concerns us, in terms of some type of
     relaxation, you know, I'm sure you would see that.  But, there is a
     pretty good collegial process, in terms of trying to come up with the
     best possible code, before it's issued.  I know on the code committees
     I'm on, we go round and round, trying to come up with a good consensus
     opinion.  But, sometimes, it just isn't possible.  Sometimes, we just
     get to a point where we have to agree to disagree.
         DR. BONACA:  I have a question.  Why does the ASME keep the
     editions of the ASME codes, if we seem to believe that we can stay with
     the 1995 edition and not go further?
         MR. TERAO:  Well, first of all, let me answer that.  That is
     not the ASME's position that we should stay with a specific edition and
     addenda; that's the NRC staff's position.  And, of course, the ASME is
     in the business to develop the codes and standards, and they get the --
     it's a voluntary consensus.  They get representatives from the industry,
     as well as the NRC staff, to participate on those codes and committees. 
     So, it is -- it's to reflect the latest state of the art or techniques
     that are available for either design or inspection or testing.
         DR. POWERS:  Does ASME decide on when it's going to do a new
     edition, based on the calendar or based on the technology?
         MR. TERAO:  Yes, it's based on calendar.  It is now at the
     point where they issue an addenda every three years -- I mean, an
     edition every three years and an addenda every year.
         DR. SHERON:  Excuse me, this is Brian Sheron.  Mario, could
     I just -- I want to just respond to your question.  We certainly -- we
     don't -- while we say, you know, that -- let me start again.  We're not
     advocating that we just stop everything at the '95 edition or the '89
     edition, okay.  We certainly encourage the code to develop new editions,
     okay, with improvements in it and the like.  We have no objection.  And
     as I said, we would -- you now, we're trying to actively endorse, on a
     timely manner, these new editions, as they come out, because we
     recognize that there is some improvements in them, okay.
         But, from the standpoint of saying can we justify closing it
     on a licensee, as a requirement, you must do this, okay, we feel that we
     need to have some sort of a measure, okay, on when we should do that and
     when it should be just voluntary.  As I said, we tried to use -- we
     figured the backfit rule, which is what we use for everything else, you
     know, was an appropriate tool, okay.  But, we are not saying that the
     code development should come to a screeching halt, by no means, okay. 
     We certainly encourage it and we would encourage licensees to adopt the
     latest edition of the code and to use it.
         DR. POWERS:  We understand -- somebody wrote this rule in
     the past that says 120 months, update to the latest edition.  Do we
     understand why they wrote that rule?
         DR. SHERON:  I believe, at the time, it was first
     promulgated -- the code, at least Section 3 and 11, were in their
     infancy stages and there was an anticipation that there were going to be
     a lot of changes made, a lot of improvements, which is the case.  And,
     therefore, the provision was built in to automatically update.
         What we're seeing is that the code has reached a level of
     maturity and we don't see any quantum leaps in safety, you might say, or
     benefits.  And that's why we're saying, at this point, we think that
     further updating -- requirements for updating would only be voluntary,
     okay.  But the reason was, is that we saw, at the time, that the
     technology was rapidly changing, okay.  So, it was written into the
     rule, the provision, to allow us to -- you know, to allow the industry
     to use that.
         DR. POWERS:  You saw the early stages of where the rapid
     change -- new sections being added, new systems being covered.  Now,
     you're see a plateauing off and we're wheedling it.  Is this an
     asymatope approach or is this just a hiatus?  The 2003, I see a quantum
     change in the whole technology for doing that.
         DR. SHERON:  And if that's the case, we would probably be
     able to justify a safety -- you know, a large safety benefit.  I would
     also point that the deregulation of the industry may be, to some extent,
     driving a large part of this.  Remember in the past, when a licensee had
     to update their programs, it was because it was an NRC requirement and
     that meant they could pass that cost right on to the rate payers, no
     questions asked.  So, what do they care, okay.  Now, that's not the
     case.  Everything they do, they are challenging us, basically, if
     there's a NRC requirement, okay.
         DR. POWERS:  I've noticed.
         DR. SHERON:  Right.  It's no longer a matter of I can just
     pass this cost down to a rate payer, okay.  You know, everything now
     that costs them money comes right off -- you know, right out of their
     margin.  So, we have become much more sensitive, now, at NRC, okay, on
     what we impose on the industry, because we recognize that we no longer
     can just sit there and say do this and do that, recognizing that they
     can pass it on to the rate payers.  So, it's a whole new -- whole new
     world out there, you might say, which is driving a lot of this.
         DR. WALLIS:  Are there other regulated industries and other
     industries that use the ASME code?  There must be, because it will not
     test for nuclear units.  And if they adopt and nuclear somehow is
     laggardly in adopting it, that doesn't -- perhaps not too good for
     nuclear.  How does this compare with other industry?
         DR. KRESS:  Other regulated industry.
         DR. WALLIS:  Other regulated -- well, other regulated and
     non-regulated.  But, are other regulated industries encouraged
     voluntarily to adopt the ASME codes or what?
         MR. SCARBROUGH:  I couldn't answer that.
         DR. WALLIS:  The NRC seems to often operate in a vacuum, as
     if, you know, they make its own decisions, based on its own criteria. 
     But, an outside worlds is going to make comparisons.
         DR. POWERS:  If I build a pressure vessel and locate it on a
     government reservation, I have to get it as a code vessel.  And I'd get
     it code stamped against the current edition of the code.  Now, I have no
     experience doing this with either Section 11 or Section 3.  I have with
     the sections.  And I have that stamped for all time, until that vessel
     falls apart.  I have a requirement to do period testing on it, but
     against that standard against which I got here.  I don't ever have to go
     look at another code.  So, effectively, in the non-clear area, at least
     in the area I have an experience with, I never had to update.
         Now, if I --
         DR. SHACK:  But, you only update your inspection and your
     ISI and IST.  I mean, your construction standard remains the same.
         DR. POWERS:  But, I don't change my testing standard.  I
     test against whatever -- what was enforced at the time I built that
         DR. WALLIS:  Is this common practice, do you think?
         DR. POWERS:  The commonality, I'm not sure of, but I know
     what I do.
         DR. BONACA:  Generally -- oftentimes, changes in the
     industry drive changes in standards, because you have additional needs. 
     So, we are now thinking of license renewal for these plants.  There is
     aging issues and so on and so forth.  Are we expecting to see
     contributions from the ASME in modifying inspection programs and things
     of that kind, which relate to aging mechanisms?  And in that case, have
     we thought about that, in saying that we know enough about it and there
     isn't sufficient movement now of the ASME editions from one to the next,
     that deserve to be considered?
         MR. SCARBROUGH:  Yes, that's one of the issues that we need
     to deal with, as we go through the public comments, and resolve them
     regarding 10-year update issues; is what do we do about the life
     extension, the plant can go on for a long period of time.
         DR. BONACA:  Okay.
         MR. SCARBROUGH:  Let me go on and tell you what we've done
     with this rule.  For Section 11, we've gone from the '89 edition of --
     up t the '95 edition.  There were 10 limitations -- there are 10
     limitations in the current regulations, regarding Section 11 and the
     earlier editions.  And for this rule, there would be 12 limitations. 
     There's three new limitations and one limitation has been deleted,
     having to do with containment isolation valves, IST.  There's three
     modifications that are associated with the Appendix 8 issue, and there's
     one voluntary provision to allow use some code cases.
         Basically, the changes are where you have some sliding of
     the numbering system.  So, it's a little awkward, in terms of how the
     regulations are numbered.  But, basically, provision six had to do with
     the metal link or concrete containments; eight was the OM reference,
     which were standards back in those days and now it's their own codes. 
     We had to update that.  We deleted the containment isolation, so now
     everything slid up numbering-wise.  The concrete containments went up
     from nine to eight in the list.  Similarly for metal containments, they
     went from provision ten to nine.  So, there was renumbering that took
     place with -- which basically, there's no change in the content.  It was
     just that we renumbered them.
         And then we have the new limitations.  Once again, we have
     the QA, and that has to do with NQA1.  There was some class one piping. 
     There's a limitation associated with some provisions in the code,
     regarding exemption of certain welds.  We had one division, which was in
     there, twelve, and we deleted it.  So rather than trying to renumber
     things, once again, we just make it reserve and then we'll clean it up
     in the next revision of the regulations.
         Class three piping in provision 13 is a permissible for code
     cases -- excuse me, code cases, for class three piping.  Fourteen,
     fifteen, and sixteen, and we'll talk more about these, basically, those
     are the modifications associated with appendix 8 endorsement, the
     expedited implementation.  And then 17 is a limitation associated with
     the reconciliation of quality requirements and has to do with the
     purchasing replacement items.
         Okay, these are the changes for Section 11.  For the OM
     code, this is a brand new code, so we have a new section, paragraph
     (b)(3).  And there's one limitation on that code.  There's one
     modification.  There's three voluntary provisions.  Once again, we have
     the quality assurance, NQA1.  Then, there will be stroke-time testing. 
     Then, we have three voluntary provisions, which allows first a code case
     OM one to be used, as an alternative to stroke-time testing for MOVs; a
     provision for the use of Appendix 2 on check valves for condition
     monitoring programs, to replace the current code requirements for
     monitoring and testing check valves.  And then finally, snubbers, the
     use of snubbers allows the use of Subsection ISTD, which provides some
     guidance on snubbers, which can be used to meet the Section 11
     requirements for ISI, for snubbers.
         So, those are -- that's the meat of the changes.  Now, there
     were some changes back in the F -- paragraphs F and G, which has to do
     with implementation schedules, to reflect these updates and the Appendix
     8 expedited limitation schedule.  But mostly, that was minor, in that
     sense.  So, there were some changes back there, but these were the
     principle changes, in terms of technical.
         Okay.  I was going to go through a little bit on the
     details.  And we have some of the folks here, who are the technical
     experts in these areas.  So, if you have a question about a particular
     aspect or particular limitations, just let me know and we'll call on
     those individuals to give us some details.
         In terms of the construction, Section 3, the rule permits
     the use of the 1989 addenda, all the way up through the '96 addenda for
     the boiler and pressure vessel code, and with five limitations.  We
     talked about the '92 addenda that was on materials, because of the
     printing errors.  There was like 160 errors in the tables in that -- in
     the 1992 addition.  So, there's a cross reference there that says,
     rather than using the '92 edition, use the '92 addenda, which corrects
     most of those errors.
         There's a limitation regarding the 1989 edition for weld leg
     dimensions, because there were conflicts in later addenda.  It was a
     1989 addenda and later allowed weld dimensions, in some cases, to be
     smaller than the pipe thickness.  And the staff had concerns about that
     and that was the limitation that was placed on that, to go back and use
     the '89 edition.  There was a limitation on the -- providing the use of
     specific articles for seismic design, because of weaknesses and the
     technical bases.  There's quite a bit of testing that was gong --
     occurred to evaluate those -- that information and those articles, and
     it was decided that those specific articles were not supported.  So,
     there's a limitation, in terms of that.
         Regarding acceptability of ASME NQA1, what the rules says is
     that when you apply the reference to ASME standard NQA1, as part of your
     code program, you need to also use the QA provisions of Section 3,
     because Section 3 QA provisions are adequate.  But, there's a cross
     reference in the code to NQA1, and NQA1 has some weaknesses, in terms of
     operational details and there's some procurement auditing concerns in
     that areas.  So, there's a cross reference to make sure that you cover
     all the aspects of QA programs; so if there's a cross reference, use
     your QA provisions.
         And, finally, there's a prohibition for inspection personnel
     from reporting directly to the immediate supervisors responsible for the
     work inspected, to ensure their independence.  So, that's something that
     -- that was felt to be it needed to be a limitation.  So, those are the
     basic limitations on Section 3.  So, there was a large number of addenda
     and additions that were looked at and that's what came out to be the
         For ISI, Inservice Inspection, the rule referenced the '95
     edition with the '93 addendum of Section 11, with three limitations. 
     The NQA1, once again, that pops up again.  So, now it references back to
     the QA provisions of Appendix B.  There was a concern, regarding
     unacceptable code cases that exempt certain welds from examination in
     the 1989 edition -- or later addenda, excuse me.  And there's a cross
     reference back to the 1989 edition for those class weld piping items. 
     So, that was a limitation placed on the later addenda and sends them
     back to the '89 edition.  And then, finally, there's a limitation on --
     regarding the use of the owner's QA program.  We're replacing the --
     purchasing replacement items, to make sure there's full coverage there,
     in terms of the QA program.  So, that was the limitation associated with
     the one, two, and three -- class one, two, and three components.
         Okay, now, for Appendix 8, there is an expedition of the
     implementation of the performance administration for ultrasonic systems. 
     There was a concern regarding the quality of the current methods for
     qualifying personnel in performing that -- those ultrasonic
     examinations.  There was a proposal to provide for that expedited
     implementation within about a six month or so period, and response to
     public comments has been stretched out to be folded in over a three-year
     period.  So, there was some response there.
         Also, since the proposed rule was issued in '97, there's
     been a lot of interaction between the NRC staff and the industry's
     performance administration initiative, which has been working to
     coordinate the use of ultrasonic examination systems and the
     qualification of personnel and such.  And as a result, there's been
     agreement that the licensees can either use Appendix 8, as referenced in
     the '96 addenda of Section 1, or they could use Appendix 8, as
     implemented by PDI.  So, that provision is in there.
         Unfortunately, it makes it a little wordy, because there
     wasn't a document that the rule could reference directly and just say go
     out and use PDI document such and such.  There wasn't a good way to do
     that.  So, as a result, there are several pages of description of what
     the PDI initiative is and what the requirements are.  So, that's one
     reason why that rule is a little wordy in that area.  But, basically,
     the bottom line is I should use Appendix 8, as in the code, or Appendix
     8, as implemented by PDI.
         Now, there were three modifications associated with that. 
     And the first one was the personnel qualification for eight hours of
     recent hands-on training, and that's been adjusted to match the PDI.  In
     the initial proposal that went out for public comment, that was a
     different requirement, a much more extensive requirement.  But after
     some discussions and interactions with PDI, it was decided to follow the
     PDI approach, to give that eight hours of recent hands-on training.
         The second limitation is basically having to do with the
     description of the PDI program and what are the requirements for cracks
     and fabrication flaws.  And finally, there are some additional
     provisions on single sided examinations, in terms of comparison to
     two-sided examinations.  So, there were some provisions there that was
     felt to be needed.  So, those are the modifications on the expedited
     implementation of Appendix 8.
         DR. SHACK:  What would the code have permitted for the
     implementation?  You know, is it longer than the three-year period?
         MR. SCARBROUGH:  With the code, it would have been the next
     10-year update.
         DR. SHACK:  Oh.
         MR. SCARBROUGH:  Okay.  So then we have some voluntary
     permissibles, whatever you want to call them, in terms of certain things
     that are allowed.  And the final rule allows licensees to meet
     Subsection IWE on metal containment components or IWL on concrete
     containment components of Section 11, by using either the '92 edition --
     '92 addenda, or the '95 edition, '96 addenda.  Previously -- currently
     in the code right now -- in the regulations right now is a reference to
     the '92 edition.  And what this adds in the '95 edition.  So, now, they
     have an option to use either one.
         The rule, also, allows licensees to use two-code cases,
     N-513 and N-523-1, related to the temporary acceptance of flaws in class
     three piping, which might be detected during operation.  It gives them a
     chance to evaluate those flaws and possibly operation until the next
     outage to deal with those.  And there's a couple of limitations on the
     use of the 513 code, having to do with safety factors and scope.  But,
     mostly, for the most part, it's a pretty straightforward endorsement of
     those two code cases.
         Okay.  So, that's all for ISI.
         DR. SHACK:  What do they do for class three piping before
     the code cases, that was a case-by-case basis?
         MR. SCARBROUGH:  The class three piping person.
         MR. STROSNIDER:  This is Jack Strosnider, director of
     Division of Engineering.  We've been spending about half a man year
     every year -- or half an FTE, as we call it, looking at plant specific
     temporary repairs, as we call them.  And there was some guidance that
     was put out in a generic letter, with what constituted -- you know, ways
     for analyzing and justifying those sort of temporary conditions.  So,
     this basically would codify that approach and will get us out of the
     loop.  Licensees will be able to do it on their own.
         MR. SCARBROUGH:  Okay.  For Inservice testing, IST, the
     final rule will incorporate by reference to '95 edition, with '96
     addenda of the ASME OM code, for class one, two, and three pumps and
     valves.  And that's the first time we've endorsed in the regulations OM
     code.  And that's good that we're doing that, because all the
     responsibility is now transferred from the Boiler and Pressure Vessel
     Code into the OM code, and all the work now is processing through the
     OMB code committee.  So, this is a good thing to do, to make sure we
     have the proper reference in the regulations.
         There's one clarification, one limitation, one modification. 
     In paragraph (f) of 50.55a, we clarify that the IC program is -- the
     scope is narrow than -- narrow than implied for earlier license plants. 
     There was a concern that the earlier license plants were being unfairly
     penalized for more recently constructed plants, and the wording has gone
     around and around a little bit, in terms of trying to make sure that
     really -- the purpose really was achieved, in terms of not penalizing
     those earlier plants.  But, we think we've got the words down now.  We
     got some good comments from the public on that and we think we've got
     that taken care of now.
         There's a limitation regarding the -- limitation of the
     code, regarding NQA1, in terms of quality assurance provisions, once
     again, because of weaknesses in NQA1.  There's a modification regarding
     the supplementing of MOV stroke-time testing with design based
     capability programs, and that's been -- that's been approved, in terms
     of the language.  The language that went out for the post rule was a
     little cumbersome and we think we've straightened that language out a
     little bit and make it more directly related to the design based
     capability programs the licensees developed.  And the rule deletes the
     current modification in the regulations on inservice testing of
     containment isolation valves.  So, we feel that's adequately covered by
     Appendix J, and it doesn't need to be repeated through 50.55a.  So,
     that's been taken out.
         The final rule permits licensees to use the ASME code case
     OM one, which is alternative rules for stroke-time testing, providing
     for diagnostics and exercising diagnostics on a much longer interval and
     then exercising every outage.  We have two modifications -- one
     modification, one clarification.  But, one modification has to do with
     the evaluation of test data over the first five years.  The code case
     allows licensees to go 10 years on their diagnostic testing.  And what
     we've asked the utilities to do, implement this, is to evaluate the
     first five years, before they go long distances out.  And then the
     clarification had to do with the evaluation.
         There's a provision in OM one, which says that licensee
     should evaluate the potential risk involved in extending quarterly
     exercise and quarterly stroke-time testing out to every outage basis. 
     And what the clarification says, to amplify that consideration of risk
     for that provision, we say -- what we think that means is to consider
     the potential increase in core damage frequency and risk, in extending
     those exercise intervals from quarter to every outage, those higher risk
         We, also, permit in the rule Appendix 2, check out condition
     monitoring in lieu of the exercising requirements in Subsection IST   of
     the OM code.  And we have three modifications:  one involving
     bidirectional testing, make sure that taken care of in the Commission
     monitoring program; two, that the initial interval is -- not exceeds two
     cycles or three years, with extension not to exceed one cycle per
     extension of ten years.  So, anyway -- so what that basically says is --
     it's a step-wise approach.  You work your way up by stepping up on your
     intervals.  You don't go out very quickly all at one time.  You walk
     your way out, the step by step approach.  And, also, that if you
     discontinue the program, you have to go back and pick up the whole --
     pick up your ISTC requirements again for checkoffs.  So, we have that
     modification in there.
         DR. SHACK:  You had some additional testing requirements by
     general letter from MOV, right?  Does this subsume all that now?
         MR. SCARBROUGH:  That folds in the weaknesses.  This will
     resolve the weaknesses in the code that we saw back when generic letter
     89-10 was first developed.  It now says, in addition to stroke-time
     testing, you have to have a program, which confirms, on a regular basis,
     your design base capability.
         DR. POWERS:  Okay.  So, this, in fact, obviates the need for
     the generic letter.  That's really be incorporated into this?
         MR. SCARBROUGH:  Right, right.  This is moving us right into
     the modification onto the code, itself.
         And then the last permissible there is the use of subsection
     ISD of the OMC code.  So, there's some testing provisions in IST's CD,
     which is very helpful for leaving your ISI, in terms of inspection
     requirements, of section 11.  It allows you to apply that information
     back to meeting those section 11 requirements.
         So, that, in summary, is -- extended the changes.  It's just
     hard to walk through, because there are so many areas that were -- that
     we're dealing with:  section three, section 11, and OMM.  But,
     basically, there are not a lot of changes to the -- this massive amount
     of code that's been updated.  We end up with 65 different public
     commenters, with over 560 comments.  And Wally Morris, in the Office of
     Research, worked through this for a long period of time, pulled them all
     together, and allowed them to be responded to by each of the core
     groups.  And this is a list of the various commenters that sent in
     comments on the rule change, NEI, ASME, Epry, a number of utilities and
     individuals.  We, had a pretty broad cross section of comments.
         What I want to do is kind of give you a flavor for the
     comments, because the comments package, itself, is 260 pages, in terms
     of the comments and responses.  So, it's so extensive, it's -- it just
     takes a long time just to read it.  But, we tried to focus on what were
     the major comments that were received and how we dealt with them.  The
     first comment was received is a general comment that NRC should update
     the regulations more frequently and we agree.  And we're trying to
     achieve that.
         A second comment that we received was -- had to do with a
     proposed limitation on the use of engineering judgment.  There was
     language in the forward of the code that concerned the staff and there
     was a proposed limitation regarding the use of engineering judgment, in
     the proposed rule that went out in '97.  Well, in response to public
     comments and the description of the public comments and the resolution
     of those comments, it was decided that that specific limitation was not
     needed.  So that was taken -- that's been taken out.
         DR. WALLIS:  What does engineering judgment mean?
         MR. SCARBROUGH:  Well, there was some language in the
     forward, which said that these -- this -- I'm paraphrasing, that the
     provisions of the code could be adjusted or accounted -- revised, in
     accordance with your engineering judgment.  It was written a little
     general and there was some concern that that might be taken a little too
     far; that the code is the code and there are these requirements.  And so
     with the description that -- of course, any time you apply anything in
     the power plant, you're going to be using your own judgment, no matter
     whether it's motor operated valves or check valves or ISI or whatever.
         And so, in response to that, there was a discussion in -- we
     put in the statement consideration, and it's more detailed in the --
     detailed in the response of the comments of -- that, yes, of course, you
     need to use engineering judgment, but just don't go too far, in terms of
     making adjustments to the code, in terms of when you're implying that,
     that you need to make sure that you follow the code.
         DR. WALLIS:  You used the ACRS meeting, when all other
     explanations fail.
         DR. WALLIS:  I'm really wary of it appearing -- you
     appearing to endorse it.  It can cover a multitude of sins.
         MR. SCARBROUGH:  And that's why there's a lot of discussion. 
     I think the public comments goes on for 20 pages of just our response to
     that issue and there is some more discussion in the SOC, itself.  So, it
     was decided that there was a significant amount of explanation of what
     the NRC expected, that we are comfortable with it.
         MR. HERMANN:  Yeah, I was just going -- Bob Hermann, staff. 
     We've put some inspection guidance out, in terms of the appropriate way
     to use -- or looking at engineering judgment, in terms of using it as
     how to apply things, rather than engineering judgment to come up with
     let's say what we would call new requirements, in lieu of those that
     might get there by interpretation.
         MR. SCARBROUGH:  So that was one area that we responded to
     public comments.  There was a -- regarding IST program scope, there was
     concern that our attempt to clarify the IC program scope just went the
     other way, and expanded it.  And when we read it, we could see how
     people could read it that way.  So, that was revised, to make sure that
     were not penalizing those earlier license plants, because that was the
     goal.  So that -- I think that's been achieved.
         There was comments that this proposed schedule for
     implementation of Appendix 8 was too aggressive and also there was
     comments that we should try to adopt the PDI program.  And we've
     accomplished that, we think, by allowing a phased in approach over a
     three-year period for Appendix 8, and also allows an alternative for the
     PDI program.  So, we think we've been responsive to those comments, as
         There were comments that we received on the training
     requirements that were in the proposed rule regarding the qualification
     of non-destructive examination personnel through Appendix 8 and that
     those requirements were excessive, and there was quite a bit, it was
     like a 40 hour timeframe annually.
         The NRC staff went back, looked at that, agreed with those
     comments and decided that the PDI position of eight hours of actual
     recent hands-on training was probably more helpful in terms of making
     sure licensees were able to deal with having qualified non-destructive
     examination personnel, so we made a change in that area.
         There was a proposed requirement for HPSI Class 1 piping
     examination.  There is a sort of missing portion of the code which --
     where Class 2 piping is dealt with, but Class 1 piping wasn't for HPSI,
     and there was a proposed requirement for expedited implementation for --
     in terms of the HPSI piping examination.  However, there has been some
     industry initiatives in that area to deal with question and resolve it,
     so the staff is planning to defer regulatory action in that area and
     allow that industry initiative to address the issue.
         There was a proposed limitation also in the rule on Class 2
     piping or Class 2 components which were subject to examination contained
     in ISI plans and such.  In response to public comments, it was decided
     that there were suitable controls in place through the ISI program plan
     that we didn't to call that out in the regs themselves, so that was
         DR. SHACK:  One of the things you didn't mention, and I
     haven't looked at it myself, is the portion of the code that deals with
     steam generator tube repairs, sleeving repairs.  In the past you have
     approved each of those sort of on a case by case basis, right, somebody
     devises a repair and you analyze that.
         MR. SCARBROUGH:  Right.
         DR. SHACK:  You will now be able to do that by the code
     without an independent NRC analysis?
         MR. HERMANN:  This is Bob Hermann of the staff.  I am on the
     Repairs and Replacement Committee.  There have been several rules that
     have been written by the code recently in terms of steam generator
     repairs, some sleeving, some for sleeving, some for mechanical plugging,
     some for welded plugging.  Those rules generally have gone in place. 
     They probably address some of the issues that are related to
     implementing those repairs, but in some cases there have been things
     that have been beyond that.
         The sleeving case I think you have had discussed over here
     before, the electrosleeving, and, certainly, things like severe
     accidents were not part of the code action.  So there have been issues
     outside of those that have gone through the code.
         I think the rules are there to put a good repair in place,
     but there may be other regulatory questions that may be beyond the
     things that went into the code.
         DR. SHACK:  But would they now be able to implement the
     repair technique without an independent NRC evaluation?
         MR. HERMANN:  I don't think so, and I think it is probably
     because of the tech specs.  The tech specs basically -- I think
     basically only talk about plugging as an acceptable action for repairing
     steam generator tubes.  So, although there is rules in the code for how
     to do it, you may have a conflict between what is in the code and what
     is in the tech specs, and the tech specs take precedence.
         DR. SHACK:  The specs win.
         MR. SCARBROUGH:  Mostly it is just a discussion of caution
     in the SOC about being careful in terms of following, they estimate --
     stating that requirements were generally acceptable, but just to keep
     them in perspective.
         Of course we didn't respond to every public comment in terms
     of changing the proposed rule into the final form.  We had a comment
     that the rule represents a backfit and the discussions of the 120 month
     update.  And the staff, through its position, has had a historical
     position that the 120 month update is not a backfit.  However, we are
     evaluating the need for continued periodic updating and the accelerated
     implementation of Appendix 8 was justified as a compliance backfit under
         There was a number of comments in terms of the need for
     clarification or revision of the rule and we responded to that.  We did
     clarify several aspects and revise several aspects.  For example, we
     deleted a proposed modification on the length of time between
     construction and docket dates deleted.  The ASME commented that there
     was some work in that area for a code revision and it was decided that
     was probably the better avenue to deal with that issue rather than
     through the rule itself, so that was taken out.
         We have prepared a detailed backfit analysis as one of the
     attachments to the package.  In terms -- in the first, the section 3 is
     voluntary for licensees to update between the '89 addenda and the '96
     addenda.  It was determined that a backfit analysis was not required for
     the ten-year update issue.  And the position -- the staff's position on
     that has been based on three basic points.
         One is that section 3 is voluntary.  It's updated only for
     new construction codes, new construction.  Two, utilities understand
     that the update requirement is part of their license when their license
     is granted.  That's part of the requirement.  So that historically has
     been understood by licensees.  And, third, that the ASME code is a
     national consensus standard, and that the revision process includes a
     general examination of costs and benefits.  So those were the three
     prongs that the staff has based its view on on the ten-year update
         DR. SHACK:  Yes, it is curious that, you know, as Brian
     mentioned, there seems to be an industry position against the update,
     but of course, I mean, the ASME code, you know, there's no ASME coders,
     you know, this is all done by industry people basically, you know,
     except for the lone NRC representative.  There's not even a Union of
     Concerned Scientists representative, you know.  So there's an industry
     on the one hand that is producing these changes, and someone else is
     objecting to the changes.
         MR. SCARBROUGH:  There's a significant difference of opinion
     from individual people who work in that field, you know, the utilities
     themselves.  It's quite a broad spectrum of views on what to do on that
     particular issue of the ten-year update which we're going to have to try
     to muddle through in the next project that we're working on.
         MR. WESSMAN:  If I may interrupt for a minute, Tom, this is
     Dick Wessman from the staff, sometimes the word "industry" can be
     treated, you know, far more broadly or perhaps more narrowly, and I
     think it's important to recognize that the consensus committees on the
     code have a very broad balance of interest.  And when we say industry
     and NRC, yes, there's one NRC.  Industry may be utilities, it is
     consultants, it is vendors and suppliers, it is State insurance
     representatives.  So there is quite a broad perspective of industry
     that's part of that overall consensus process.  And that's one of the
     values of that process.
         MR. HERMANN:  But I think it's probably fair to mention, if
     you started counting heads on section 11, what Bill said is absolutely
     right, if you counted the beans, the majority votes would be people that
     are, quote, utility reps.
         MR. SCARBROUGH:  Okay.  And then on the -- it was determined
     that the administrative change go from the O&M standards, the O&M code,
     was not a backfit.  For the Appendix 8, expedited implementation, that
     was determined to be necessary to bring licensees into compliance with
     GDC 14 of Appendix 8 of Part 50, and then criteria 2 and 16 of Appendix
     B under the QA program.  And so there was a justification for that
     specifically in the rule package itself too.
         DR. SHACK:  What does GDC 14, Appendix A say?
         MR. SCARBROUGH:  That says that licensees have to have a
     reliable means for testing -- several other things -- but testing to
     limit abnormal leakage and the possibility for abnormal leakage or gross
     failure.  And so there's concern there that testing wasn't adequate.
         Okay.  Well, in conclusion, the final rule incorporates the
     '95 edition with the '96 addenda of the boiler and pressure vessel
     codes, sections 3 and 11, and ASME O&M code.  It endorses most of the
     provisions.  I think, you know, there are some -- volume-wise you can
     see some changes there.  But for the most part, five or so for section
     3, three new ones for section 11, and really only two provisions for O&M
     codes.  Other things in there are permissibles or voluntary aspects to
     endorsing code cases and such.
         It does require expedited implementation of Appendix 8, as
     described in the code itself, or through PDIs.  So we think we've given
     some options there to allow licensees to implement what's best for them.
         It's been decided that the rule does not substantially
     change the character of the codes and does not represent a Government
     unique standard as defined by the National Technology Transfer
     Advancement Act of 1995.
         And, finally, we think the rule provides improvement in
     construction and service inspection and service testing of nuclear
     powerplant components.
         Where we are with the package -- and I do appreciate ACRS
     listening to us and letting us brief you on a package you don't have in
     your hands yet -- the draft that we sent to you is very, very similar to
     what's currently in the package.  We've tweaked it a little bit in terms
     of trying to take out some of the rule language that wasn't changed so
     you don't have so much to read in the back in terms of the actual rule. 
     We put a little asterisk in there.  But for the most part, it's
     basically the same as what you have.
         Currently we have received OGC concurrence on the package. 
     We should be receiving CIO information office concurrence here in the
     next day or two.  I just talked to them today.  The financial office is
     looking at it.  They've checked with our financial people, and that
     should be coming through pretty soon.  The administrative office is
     looking at it for how the words should fit into the Federal Register,
     making sure that our current method of saying things is consistent with
     how they like to say things in the Federal Register.  So they're working
     on that.  And the Office of Research, I've talked to some of their
     people, and they haven't seen anything in it that causes them major
         So currently we hope with -- the packages have been updated
     to reflect OGC comments and our own internal NRR folks who deal with
     rule changes.  As soon as I get these other -- whatever comments these
     other offices have and their concurrence, we'll finalize it, so we hope
     to have the package ready to go early next week, and to have it signed
     out and sent over to you -- and it is, you know, that thick -- sometime
     next week.  So that's the plan right now.  But basically that's the
     rule, and we'll be happy to answer any specific questions you have, and
     we have some folks here that can answer questions, if you have any more.
         DR. SHACK:  What's been your track record in the past?  I
     mean, how often have you actually managed to update, incorporate
     reference -- are you behind your historical record or, you know, you're
     on track?
         MR. TERAO:  If I can answer that, Bill, I did some research
     in looking at the Federal Registers going back to 1971, when 50.55a was
     first put into the regulations, and it's interesting, because from about
     1971 to about 1986, we issued updates of 50.55a endorsing or
     incorporating by reference the next edition addenda about every year,
     sometimes twice a year.
         But around 1986 is when the packages got a lot more
     complicated.  And some of the things that happened around that time is
     when we split paragraph G into F and G.  So there were a lot more
     administrative type of issues that came up as well as dealing with CRGR
     and I think more obstacles for the staff to overcome.  And in those
     days, say before, from '71 to eighties, there are no public comments. 
     Zero.  So it was very easy to -- or relatively easy to get a package
     out.  And today we have over 500 comments.
         So of course the last rule change was in 1992, and that was
     when we endorsed IWE, IWL for containment inspection.  But before that,
     of course, the 1989 rule came out.  I think that was 1992 or 1994.
         So it's been quite a while since our last update.  And this
     package has gone through literally three full revisions since it was
     first proposed for issuance back in the 1994 time frame.  So what you
     see here is not just a development of a package from when it was
     initially prepared about six years ago.  This is about the third
     reincarnation, a complete new package.
         So yes, it's gotten a lot more complicated.  We're hoping
     that in the future it won't be quite as complicated as this one, but
     we're hoping to of course get the rulemaking out a lot quicker in the
         DR. BONACA:  I had another question regarding the ASME
     position.  If I remember, they have written, they are on record, right,
     with the NRC that they do not agree with this?
         MR. SCARBROUGH:  Not with this package.
         DR. BONACA:  No, I'm talking about with this change, rule.
         MR. SCARBROUGH:  Well, they disagree with the ten-year
         DR. BONACA:  Right.
         MR. SCARBROUGH:  But this does not change that at all.  This
     maintains that as always.
         MR. DUDLEY:  There is a discussion between the staff and
     ASME -- I guess -- yes, between the staff and ASME on what is it, 1994
     addendum to the code.
         MR. TERAO:  Oh, you're right, there are some disagreements
     between ASME code and NRC on some of the positions, of course, or
     limitations that the NRC staff has imposed on the use of some of the
     addenda such as the seismic design, and that's a major issue.  I
     think -- I'm not sure if the NRC staff has briefed the ACRS --
         DR. SHACK:  No.  I mean, that's been an ongoing
     discussion --
         MR. TERAO:  Right.
         DR. SHACK:  For several years now.  We've had subcommittee
     meetings on that.  I mean, that obviously is a major sort of technical
     difference between the code and the staff.
         MR. TERAO:  But aside from that, I think the overall package
     as far as the NRC staff going forward and endorsing the 1995 edition of
     the ASME codes up to and including the 1996 addenda, there's no
     disagreement there.
         DR. BONACA:  No, I was talking about not requiring the
     ten-year update.
         MR. SCARBROUGH:  They've sent a letter in on that.
         DR. BONACA:  They disagree.
         MR. SCARBROUGH:  Yes, they disagree.  Right.
         DR. BONACA:  That's what I was referring to.
         What's your opinion on that letter, thoughts?
         MR. SCARBROUGH:  I haven't started looking at it because I
     really wanted to focus on getting this package out, you know, on its
     way, and what we are doing right now with all those comments, we have
     like 26 or so comment letters.  All the comments are being collated and
     categorized.  And over the next few weeks, we'll be reading them
     carefully and working up responses to them.  So that's the plan right
     now.  But we really haven't got to the point now where we could say, you
     know, what our position would be on those.
         DR. BONACA:  Because I think you've made a business case
     for, you know, eliminating the requirement, but I think the letter from
     the ASME makes some technical case that would be valuable for us to look
         DR. SHACK:  Well, I mean, we will be seeing the 120-month
     update again.
         MR. SCARBROUGH:  Absolutely.  We're on your calendar for
         MR. HERMANN:  This is Bob Hermann of staff.  I think Brian
     made it clear that that's a separate issue from where we stand right
     now.  It just might be worth mentioning there was a public stakeholders'
     meeting where everybody's opinions to update or not update got taken in
     as part of the stakeholders' meeting, and I'm sure that as part of the
     package that comes in here, you'll hear a summary of what came out of
     the stakeholders' meeting.
         DR. BONACA:  Okay.  Thank you.
         DR. SHACK:  Are there any more questions?  Curt, are you
     going to say something about the code?  Gerry?
         [No response.]
         DR. KRESS:  Well, we thank the staff for this very
     interesting discussion and at this time --
         MR. EISENBERG:  Tom.  Dr. Kress.
         DR. KRESS:  Yes.
         MR. EISENBERG:  I would like to --
         DR. KRESS:  Okay.  Okay.
         MR. EISENBERG:  I wasn't planning to say anything.  I am
     Gerry Eisenberg from ASME, and I just wanted to make the statement that
     we are quite pleased that this rule is going forward in its present
     state, despite any differences we might have had with the particular
     limitations.  But over on the overall, it is a big step forward.  It has
     been nine years in the making.
         DR. KRESS:  Thank you.  And we think that is it.  Thank you
     very much.  We look forward to hearing the discussion on the 120 days.
         At this time on the agenda we are schedule to have a report
     from the chairman of the subcommittee meeting that we had Tuesday.  The
     chairman of that subcommittee is not here, that was George Apostolakis. 
     The co-chairman of the Joint Subcommittee is here, that is me, and I
     guess that would leave me to provide a summary of this report.
         Now, the interesting thing about this is this was a Joint
     Subcommittee of the PRA and Reliability and the Regulatory Policies and
     Practices.  It turns out that everybody on the committee was there at
     the Joint Subcommittee meeting except Bill Shack.  So the question is,
     do I need to make a summary of a Tuesday subcommittee meeting for the
     benefit of Bill Shack or not?  Or can you just read --
         DR. SHACK:  Did I miss the airplane?  I have the minutes, I
     will read them.
         DR. KRESS:  You just read the minutes.  I think that would
     be appropriate because I really can't, you know, since George is not
     here, we could probably use this time for -- well, that is another
     problem.  We could move on to the next item.
         MR. BARTON:  Which is the break.
         DR. KRESS:  Well, --
         DR. WALLIS:  Well, I have a question for you, Mr. Chairman. 
     It says representatives of the NRC staff will provide their views.  Are
     there any NRC staff waiting in the wings we will cut off if we leave
     this item?
         DR. KRESS:  Oh, that is a good question.
         MR. BARTON:  I don't think so.
         DR. KRESS:  No?
         DR. WALLIS:  Well, you see, they are not expected to be here
     till 2:30.
         MR. BARTON:  They are not here to get their wings cut.
         MR. REED:  This is Tim Reed from NRR, and the only comment I
     would like to make with regard to our briefing for the ACRS Subcommittee
     is we certainly appreciated the ACRS's input and I think we understand
     that we need to better articulate our objectives and what we are doing
     risk-informing Part 50 and to have been criteria defined, and we heard
     that loud and clear.
         DR. KRESS:  I think that was the major message.
         MR. REED:  Yes.
         DR. KRESS:  So, we appreciate that.  We certainly appreciate
     having this early kind of discussion with the staff on things like that. 
     It was very beneficial to us.
         DR. WALLIS:  Now we have your statement on the public
     record, we can hold you to it.
         MR. REED:  I knew you were going to hold us to it anyway.
         DR. KRESS:  Well, I think I will declare a break at this
     time and let's make it for 20 minutes and be back at a quarter till
     3:00, and at that time we will move on to the next item on the agenda,
     which was Graham Wallis'.  And we will start that way 15 minutes early. 
     I think that is within the uncertainties of the schedule.
         DR. WALLIS:  If we start it without our esteemed chairman,
     we might make some progress.
         DR. UHRIG:  Do you want that off the record?
         DR. POWERS:  Well, the feeling was that our esteemed
     chairman would be back by then.  If he is not, we can discuss whether to
     start without him or not.  I am perfectly willing to start without him.
         DR. SHACK:  Well, we might want to go to John's letter since
     he is about to turn into a pumpkin.
         DR. KRESS:  We might go through the letters first.  So we
     will --
         DR. SEALE:  Yes, I would point out that the next thing on
     the agenda after that is a break for the preparation of reports and we
     might just want to --
         DR. KRESS:  We might to do that now.
         DR. WALLIS:  Let's do that now.
         DR. SEALE:  We will do that now and do John's letter.
         DR. KRESS:  Why don't we break until 3:00 then.
         DR. SEALE:  All right.  And then let's do John's letter.
         DR. KRESS:  And then let's come back and do John's letter at
     that time.
         DR. SEALE:  Yes.
         DR. WALLIS:  Maybe we can avoid some of this later full
         DR. KRESS:  That's a very good thought.  Will that help John
     if we break now?
         MR. BARTON:  Yes, because I have got two letters I have got
     to at least read through first reading before I leave.  So let's break.
         DR. KRESS:  Would you rather break for 10 minutes and then
     do your letter?
         MR. BARTON:  How about breaking until a quarter of?
         DR. KRESS:  Let's do that.  And then we will do your letter.
         All right.  So I declare a recess until a quarter of.
         [Whereupon, at 2:28 p.m., the open portion of the meeting
     was recessed, to reconvene at 8:30 a.m., Friday, July 16, 1999.]

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