476th Advisory Committee on Reactor Safeguards (ACRS) - October 6, 2000

                             UNITED STATES
                          476th ACRS MEETING
                              Conference Room 283
                              Two White Flint North
                              11545 Rockville Pike
                              Rockville, Maryland
                              Friday, October 6, 2000
               The above-entitled meeting commenced, pursuant to
     notice, at 1:30 p.m..     MEMBERS PRESENT:
     Dr. Dana A. Powers, Chairman
     Dr. George Apostolakis, Vice-Chairman
     Dr. Thomas S. Kress, ACRS Member
     Dr. Robert L. Seale, ACRS Member
     Dr. William J. Shack, ACRS Member
     Dr. Robert E. Uhrig, ACRS Member
     Dr. Mario V. Bonaca, ACRS Member
     Mr. John D. Sieber, ACRS Member
     Dr. Graham B. Wallis, ACRS Member
     Mr. Graham M. Leitch, ACRS Member
     John T. Larkins, Executive Director, ACRS
     Noel F. Dudley, ACRS Staff
     Michael T. Markley, ACRS Staff
     Howard J. Larson, ACRS/ACNW Staff
     Ralph Beedle, Senior Vice President, Nuclear Energy
     Alex Marion, Nuclear Energy Institute
     Lynette Hendricks, Nuclear Energy Institute
     Doug Walters, Nuclear Energy Institute
     Doug Walters, Nuclear Energy Institute
     Tony Pietrangelo, Nuclear Energy Institute
     Mike Mayfield, Office of Nuclear Regulatory Research, NRC
     Ed Hackett, Office of Nuclear Regulatory Research, NRC
     Safish Aggarwal, Office of Nuclear Regulatory Research, NRC
     Robert Lofaro, Brookhaven National Laboratory
     Amarjit Singh, ACRS Staff
     Jose Calvo, Office of Nuclear Reactor Regulation, NRC
     Richard P. Savio, ACRS Staff
     Paul A. Boehnert, ACRS Staff
     Mark Cunningham, Office of Nuclear Regulatory
     Research, NRC.                         P R O C E E D I N G S
                                                      [1:30 p.m.]
               DR. POWERS:  The meeting will now come to order. 
     This is the second day of the 476th meeting of the Advisory
     Committee on Reactor Safeguards.
               During today's meeting, the committee will hold a
     discussion with industry representatives concerning industry
               We will also discuss GSI-168, equipment
     qualification; generic guidance documents associated with
     license renewal; future ACRS activities; and, have a report
     of the Planning and Procedures Subcommittee.
               We will reconcile ACRS comments and
     recommendations and discuss proposed ACRS reports.
               The meeting is being conducted in accordance with
     the provisions of the Federal Advisory Committee Act.  Mr.
     Howard Larson is the designated Federal official for the
     initial portion of the meeting.
               We have received no written statements or requests
     for time to make oral statements from members of the public
     regarding today's sessions.
               A transcript of portions of the meeting is being
     kept and it is requested that speakers use one of the
     microphones, identify themselves, and speak with sufficient
     clarity and volume so that they can be readily heard.
               With that little piece of business out of the way,
     Ralph Beedle, welcome to the meeting with the ACRS.  As I
     commented earlier, we have gotten just absolutely heroic
     service from members of your staff here supporting us and
     pursuing various individual issues.
               We never get a chance to sit down and talk
     philosophy, talk approaches, talk strategic plans, and we
     have had a chance to examine your strategic plan and I
     congratulate for a well written and very useful document.
               We hope to be able to cover four or five areas of
     great interest, but I'll turn it to you to give any opening
     comments you'd like to make.
               MR. BEEDLE:  Thank you very much, Dr. Powers.  I
     appreciate the opportunity to join you today.
               Let me, I guess, follow-up on your admonition.  My
     name is Ralph Beedle.  I'm the Chief Nuclear Officer for the
     Nuclear Energy Institute, here in Washington, D.C.
               With that, I would like to start with kind of a
     brief overview of NEI.  NEI, Nuclear Energy Institute, is
     about six years old.  We were a result of the consolidation
     of NUMARC, the technical group within the nuclear industry
     that interacted with the NRC on a variety of licensing and
     technical issues, as well as the ANEC, the lobbying
               So we tried to combine those and provide an
     industry focus to the collection of lobbying, advertising
     and the technical issues that were being dealt with by the
               There are about 126 people at the NEI
     organization.  I believe you have an organization chart that
     shows the basic organizational structures, divisions that
     represent nuclear generation, basically the power reactor,
     the technical side, business operations that are looking at
     issues associated with benchmarking of perhaps new plant
     construction in the future.  Also, their focus is on Yucca
     Mountain and the activities associated with high level waste
     disposal.  Then we have the typical communications and
               More importantly, the organization was -- there
     was a recent change in it, where we created a division under
     Angie Howard to focus on policy.  That, in large measure, is
     a result of the consolidation with the industry and we see
     our roughly 200 members decreasing in number as both the
     utilities consolidate and as the NSSS vendors consolidate.
               We expect we will see considerably more of that
     activity as time goes on.
               So with that, the question is how do we provide
     the services and support for our members and as a result of
     trying to answer that question, we created this group under
     Angie Howard to provide some clear focus on that.
               We are involved in a great many activities, and
     they, as you can imagine, range from activities on the Hill. 
     We support Congressional information trips to Yucca Mountain
     and to other nuclear facilities, to help inform our elected
     representatives of what the nuclear business is all about.
               We also spend a great deal of time in the
     communications area.  As you drive to and from work in the
     Washington, D.C. area, you probably hear some Nuclear Energy
     Institute ads on the radio, tune into WTOP-1500 on your AM
     dial and you'll hear those.
               And, again, those ads, I think, have an effect in
     the long haul.  They, combined with the performance of the
     industry, the increased focus on electricity and demand,
     energy issues are becoming more and more a subject of
     conversation, and the net result is that nuclear is looked
     at differently today than it was four years ago, even three
     years ago, and, in large measure, that's a result of the
     effort on the part of a lot of people to try and educate the
               We have often that it would be almost mission
     impossible to try and educate the public.  It's the desire
     to go into the public school system and provide educational
     devices and programs.  It's almost impossible to do that.
               So our focus has been on the policy-makers, the
     people that are making these decisions that affect our
     day-to-day life.  It's the decision to release or not
     release oil from the strategic reserve.  Those things have a
     profound impact on whether or not you're going to have home
     heating oil in New England next winter or whether or not
     you're going to have gasoline next summer.
               And part and parcel to that is a better
     understanding of the entire regime of energy supply within
     this country.
               As a philosophical approach to this whole process,
     NEI has been endeavoring to make sure that people understand
     the value that nuclear brings to this country.  Nuclear is
     not a religious event.  It's a business.  We operate
     businesses based on a technology called nuclear and if we
     can't make money in that business, you're not going to stay
     in business.  It's as simple as that.
               One of the reasons that we have not built a new
     plant in this country for roughly ten years is the fact that
     the cost of construction is high and the rate of return
     isn't all that great.         
               Not only that, the tremendous uncertainty
     associated with the regulatory process makes it a tremendous
     risk on the part of any business venture that you might
               So our effort has been to try and develop a stable
     regulatory environment, one in which there is predictability
     and surety for the licensees as they go forward in the
     operation of these plants.
               I would argue that the license renewal program, as
     successful as we deem it to be, is successful only because
     of the surety that we have in the licensing process and in
     the operational process that we have today through the
     revised reactor oversight process.  A little later, we'll
     talk about both of those programs. 
               So this approach that we have of trying to get
     clarity, surety, objectivity in the regulatory process and
     environment is a necessary ingredient if the nuclear
     programs are going to survive in this country.
               So that, coupled with the significance of 20
     percent of the generation in the country being produced by
     nuclear generation is rather significant.  We look at the 20
     percent capacity basically and almost every year we see that
     that is exceeded in terms of generation, and we generate
     somewhere in the 23 to 25 percent, simply because of the
     reliability of these power plants.
               We find more and more effort on the part of the
     utilities to provide that reliability.  I'm sure you're all
     familiar with the problems associated with power supply in
     the Illinois area, with ComEd, and the relatively low
     capacity factors, and then with Oliver Kingsley and his new
     approach to management of that company.  It was all ten all
     summer, this past summer, and they did a very good job at
     doing that.
               The energy supply issue in the center of the
     country isn't near as critical as it was last year, simply
     because of the performance of the plant.  But nonetheless,
     it points out the value that nuclear adds to that mix.
               The other element of the nuclear equation is the
     clean air and with the Kyoto Accord and the focus on clean
     air, there is only one way that you and I are going to
     achieve clean air in this country, and that's through the
     use of nuclear as a key ingredient in the energy mix.
               If we were unable to keep license renewal on
     track, we would have a very significant problem in trying to
     meet those accords. 
               So the combination of clean air, regulatory, and
     the emphasis clean air puts on this energy source, the
     license renewal process, improved environment, all that has
     caused nuclear to become more and more of a subject of
     discussion within the Administration, within the political
     leadership in this country, and I think we're going to see
     eventually a major shift in that focus, such that we will
     have an environment in which we can produce new nuclear
     generating facilities.
               Let me ask, are there any questions about NEI and
     what we're trying to do?
               DR. POWERS:  I guess I'd like to understand a
     little more what you mean about stability in the regulatory
     process, because we may be working at cross purposes here. 
     We've got a committee that historically is, for as long as
     I've known the ACRS, and it's getting to be pretty close to
     26 years that I've appeared on one side of the table or the
     other in front of this institution, has endorsed a move
     toward a risk-informed regulation or even a risk-based
               That's a pretty profound change and that doesn't
     seem to be consistent with the idea of regulatory stability.
               MR. BEEDLE:  Well, I would take a little bit
     different view.  I think risk-informing the regulation is
     very much consistent with stability.
               When we look at the reactor oversight process, and
     I think that is really the fundamental change that's taken
     place in the last couple years, and it is the single most
     significant thing that has occurred that's produced some
     stability in the regulatory environment.
               And it's an interesting situation because we went
     into this revised reactor oversight process with the
     objective of having clearly defined performance criteria
     through the performance indicators and the various
     categories and from that, then, a predictable outcome.
               I would say that prior to this revision, there was
     not a chief nuclear officer in the industry that didn't feel
     that he was only one event away from the watch list.  One
     event away from the watch list.  And there wasn't one chief
     that didn't feel that way, because what they saw happening
     in the industry is the event occurred and then the NRC would
     send their inspection team in and they would spend as much
     time as necessary to develop a catalog of problems and we
     had an uncanny ability to make mountains out of molehills
     and we said every problem is important and you have to fix
     every problem that we've identified before you can ever
     start up again, and we were automatically in a $200 million
     fix, get well program and about two years to accomplish it.
               It was predictable in that sense.  You had an
     event.  If we could have just figured out how to write a
     check for $200 million and be done with it, I think most
     chief nuclear officers would have been glad to do that.
               So that unpredictability and inability to look
     long haul and say I can guarantee that I will be able to
     operate, it's not to say you aren't going to have some
     problems, but to have some reasonable outcome when you do
     examine some of the problems, that was what we were after.
               So we go into the oversight process and we have
     the set of performance indicators, on the one hand, and we
     said, well, that's going to really help us out because if
     I'm in the green band, you kind of leave me alone, let me do
     my job; if I'm in the white band, you increase the
     inspection hours and we try and determine what caused you to
     be in the white band, and we accept that, we'll go figure
     out how to make things -- improve the performance and get
     back in the green band.
               So, I mean, if you give me a target, I know how to
     achieve performance to match that target.  It's when you say
     shoot at the wall and then you draw the target that we have
     our problems.
               So the oversight process gave us some targets that
     yielded predictable outcome on the part of the inspection
               DR. POWERS:  Maybe it gave you more.  It gave you
     trends so that you didn't have this roll-off-the-table kind
     of phenomena, that you can see when things are becoming --
     maybe your performance was beginning to lag a little bit.
               MR. BEEDLE:  Absolutely.  Absolutely.  And with
     those trends, though, as you cross thresholds, you knew what
     would occur as a result of that change.
               The other component in this oversight process was
     the inspection and there is no question about the fact that
     there are many, many things that take place in this power
     plant operation that don't lend themselves to performance
               And, indeed, the idea of the performance
     indicators was developed with the idea that once you have a
     set of indicators, if the indicators indicate a declining
     performance trend, it then gives the NRC the ability to use
     those indicators to focus their inspection resources and go
     examine those areas that represent the declining
     performance, and you focus on that as a way of getting
     better understanding of the problems and ultimately improve
     the performance, as opposed to the just send in and inspect
               You could have a problem with a steam generator
     and they'd be in there inspecting the rad waste system.  You
     say what's the purpose of that; well, we're just looking for
     problems, you know.  So anyway, you end up with this
     performance indicator process.
               In order to evaluate the significance of the
     findings that are developed during the inspection process,
     the NRC constructed a process called significance
     determination.  And so the SDP or significance determination
     process is probably the single most important element to
     come out of the revised reactor oversight process, because
     it helps the NRC and the licensee understand the
     significance of an event, of a finding, of some disturbance
     in the normal order of business.
               It tells you whether or not something is of safety
     significance or it is not, and, based on that, you can
     disposition it with reasonable surety that you're doing the
     right thing.
               Now, the value of that significance determination
     process as it applies to the inspection program has been
     recognized in many areas and we have significance
     determination processes for each of the cornerstone areas in
     the oversight process.
               We find that fire protection has one now.  We've
     got one in just about every area where you need to answer
     the question of how significant is the finding or the
     concern that you're trying to address, and that, I think, is
     the item that has helped us understand better how to treat
     the various discrepancies that may be uncovered in the
     inspection program or identified by the utility, as well.
               DR. WALLIS:  I thought Dr. Powers had a somewhat
     broader question about the effect of a move to change the
     regulations in some fundamental way using risk information.
               MR. BEEDLE:  I'll get to that.  I have not
     forgotten that.
               DR. WALLIS:  Thank you.
               MR. BEEDLE:  But I think this is important that
     you understand what we have managed to do in this revised
     reactor oversight process; this ability to define the
     significant versus the insignificant, the relevant versus
     the irrelevant.
               DR. SEALE:  Is it fair to say then that the real
     message in that process is not in the color, but in the
     determination of the significance of the event?
               MR. BEEDLE:  I think the answer is yes.
               DR. SEALE:  And that's what drives the actions of
     the utility and of the inspectors.  And as long as the
     outside process continues to focus on colors, then you don't
     have the adverse consequences of over-sensitivity to the
     relationship between the NRC inspection process and the
     operators of the plant.
               MR. BEEDLE:  I think they are very closely linked,
     because the construct of the performance indicator is such
     that its thresholds are set to tell you how far you are, on
     a relative scale, from something that looks to be
     unacceptable from a risk point of view.
               DR. SEALE:  Yes.
               MR. BEEDLE:  Presumably, the margin to safety is
     less if you're in the red area than if you're in the yellow
     area than if you're in the white area, and the green area
     represents kind of the nominal performance of the industry
     and, in fact, the definition says that if you're in the
     green area, you are operating within the industry norms.
               If you're in the white area, you're starting to
     depart from the industry norms.  If you're in the yellow
     area, you have some reduction in the margin to safety or
     margin of safety, and then if you're in the red area, you
     have a significant reduction.
               DR. SEALE:  Is there an event significance
     determination for something that allows you to remain in the
     green area?
               MR. BEEDLE:  When we have an event or a finding
     through an inspection process, then that event is evaluated
     through the significance determination process and a color
     is assigned.  So you can have lots of events where it's
               DR. SEALE:  But you're still worried.
               MR. BEEDLE:  The fact that you're green does not
     mean that you don't go address the problem.  What happens is
     if you have, let's say, a valve fails to operate the way
     it's supposed to and you evaluate it and it's green, we
     don't just walk away and say the valve broke and let it
     remain that way.
               DR. SEALE:  No.
               MR. BEEDLE:  We put that into our corrective
     action program and we go about the process of correcting
     that deficiency, just as though we had discovered that thing
     ourselves, which is more than likely the case.
               Similarly, if you have an event that would place
     you in the white area or in the red area or yellow area,
     then what that -- I mean, the utility is going to go ahead
     and resolve that problem.
               DR. SEALE:  Yes.
               MR. BEEDLE:  But that would then bring with it a
     change in the inspection routines that the NRC inspectors
     would conduct, and they would go increase their level of
     inspection as a result of that.
               Now, this whole process is not possible unless you
     have an understanding of risk calculation and the ability to
     predict and calculate these things.  So the risk-informing
     of the regulation I think is a necessary follow-on to the
     application of these risk insights that we are using in this
     oversight process.
               DR. APOSTOLAKIS:  Isn't it also necessary, though,
     for each unit to have a decent PRA?
               MR. BEEDLE:  Yes, but even with that statement, we
     have an oversight process that is built on the results of
     the IPEs that were developed back in 1988 or so.
               Now, I'm not suggesting that we stop the clock and
     just stick with that, and I'll cover that in a minute, but
     what I'm saying is we don't have to have a detailed PRA in
     order to use risk insights in the operation of these plants.
               Now, if I am going to go to a risk-informed
     regulatory basis, yes, we need the use of the PRA, a good,
     solid, well founded PRA to do that.  There is no question
     about that.
               DR. APOSTOLAKIS:  Yes.  I'm not talking about a
     detailed PRA, but maybe, for most units, something that's a
     little better than the IPE, because the IPEs are, after all,
     12 years old now.
               MR. BEEDLE:  Yes.
               DR. APOSTOLAKIS:  Or not 12, but a number of years
     old, and I think the process would be much more efficient if
     both the licensee and the NRC inspectors have access to
     probabilistic models that people can believe and do these
               MR. BEEDLE:  The NRC, when we put together these
     SDP processes, they started out using the information that
     they had here in their offices in the form of the IPEs,
     which it was our obligation to submit as a result of a
     generic letter in the 1988 timeframe.
               But they went out and visited the plant and
     validated the SDP process with the plant's PRA as it stood
     as recent as a year and a half ago.
               So they have looked at those PRAs.  I mean, it's
     not a case of the utility has this PRA and they're not going
     to let anybody look at it.  In fact, that PRA has been used
     by the inspectors and, in fact, the inspectors will go back
     to that PRA when they're trying to determine the outcome of
     an SDP process.
               The question, and this has come about over the
     course of the last several months, about quality of PRA and
     the comment that the NRC staff doesn't have all these
     current PRAs at their disposal, we're trying to examine ways
     to develop an improved or increased level of confidence on
     the part of the staff in the development of these PRAs.
               One of the things has been the peer review process
     that we've got ongoing.  We expect to have that completed by
     the end of 2001.  That's kind of coupled with some issues on
     ASME code development and so forth.     
               But there are some very robust PRAs out there. 
     There are probably a half a dozen plants that probably need
     to go spend some more time in their PRA.  We know that and
     we're working on those plants.
               But by and large, those PRAs are pretty solid and
     well constructed and are providing good results.
     DR. POWERS:  So I take it, just an anecdote to embroider
     what you're saying, I think, the committee had a chance to
     visit Davis-Bessie and I think they were one of those plants
     that maybe people thought hadn't espoused risk-informed
     regulation as much as some of the others.
               When we got there, we found that these guys are
     doing an incredible amount with the resources that a single
     unit has, which is not an infinite number of resources, but
     they were taking maximum advantage of things like owners
     groups' efforts and things like that and doing great things
     to improve their PRAs to come up to snuff, so much so that
     they raised questions, in my mind, whether this SDP process
     might not be running into difficulties because of the
     quality of computational tools available to the staff.
               That if, in fact, the PRA capabilities of the
     licensee were vastly superior than cruder tools available to
     the NRC staff, you might get conflicts based on differences
     in technology.
     It's a question that came to our mind during this visit to
     the Davis-Bessie plant.
               MR. BEEDLE:  Well I don't think that that is
     really a major issue.  I mean, as you get further and
     further down the SDP process, I mean, you could get to the
     point where you're really trying to get down to the third
     decimal place to figure out something.
               But by and large, the band in which you're
     operating is so huge that you never really get to that
               Let's just take one parameter that we measure, and
     that's the reactor scram or reactor trip.  We've got a
     threshold that sits around the four mark to get you into the
     white band, but to get in the red, you've got to have about
     21 of those things.  It's like diesel reliability.  We're
     shooting for a 99.99 percent reliability, but the truth is
     you can operate with about an 80 percent reliability or 75
     percent and still not be in red.
               And what that ought to tell us is that the margin
     of safety, the robustness of the design is tremendous. 
     We're operating like, you know, a tenth of a second is going
     to make the difference between core melt or not, and that's
     called science fiction, gentlemen.
               DR. SEALE:  But, Ralph, aren't we getting -- you
     come back to the IPEs and Dana says, yes, but they're 12
     years old and so on.
               And by inference, you certainly led me to
     recognize, and I think I knew it before anyway, that the
     guys who are really on top of it are so much beyond the
     status or the capability as reflected in their original IPE
     that there's really very little relationship between that
     IPE and what they have now to evaluate.
               They've sharpened their tools.  They've gone back
     when they had a problem that had to do with this particular
     train and represented that train more discreetly, so they
     could really look at what the interactions were in it and so
               Granted, there are still some utilities who
     haven't looked at the fourth page in the original IPE yet,
     but most of them have done much, much beyond that.
     Aren't we under-representing the capabilities, the
     understanding that now exists in these utilities, when we
     refer to their database as being the IPEs?
               MR. BEEDLE:  I agree, absolutely.  Absolutely.
               DR. SEALE:  But, see, there are a lot of people on
     the outside who also know that IPEs were pretty rudimentary. 
     So they say, well, your representation of your PRA is
               MR. BEEDLE:  Well, I think that comes from our
     regulatory focus on things.  I mean, you can't deal with
     regulatory posture unless you have things docketed and on
     the record and submitted in triplicate, one of those kind of
     things, and that's what we're dealing with.
               All those IPEs were submitted.  There was no
     requirement to submit your PRA.
               Now, in fact, a lot of plants, this thing we're
     calling IPE, they're actually PRAs.
               DR. SEALE:  Yes.
               MR. BEEDLE:  Because when we looked at what it
     costs to do a PRA versus what it costs to do the IPE, we
     said I'd be foolish to do an IPE and make the static
     analysis, let's do a PRA so we can take some advantage of it
     and learn something about our plant.
               So we developed the PRA and we made an effort to
     try and keep the thing up-to-date, and that's what was
     submitted to the NRC.
               So a lot of these things that we're calling IPEs
     are, in fact, PRAs.
               But set that aside for a moment.  The fact that
     we're able to, I think, with a great deal of validity,
     address the SDP processes on the basis of that 1988 analysis
     ought to tell us something about the robustness of that
     analysis technique.
               It tells you a lot about how you can analyze the
     comparative risk of one sequence versus another, this
     component's failure and its effect on the outcome and the
     performance of the plant.  These are really pretty good
     systems that have been developed.
               Granted, the details and the level of detail that
     you put into the thing, whether or not you're using third
     decimal place data for reliability or fourth decimal place,
     turns out to be, in my opinion, really on the margin.  It
     has not had a lot of difference.  It hasn't produced a lot
     of difference in outcome.
               But as a result of this whole process of analysis,
     we've seen a lot of improvement in the plant performance. 
     We've looked at putting in systems that weren't originally
     designed that have improved our results of the PRA.
               So it's been, I think, an extremely successful
     venture on the part of the NRC and the industry.
               So all of that said, in order to take advantage of
     that process, we need to risk-inform the regulations so that
     we are focused on the right things.
               I would suggest that spending thousands of dollars
     on a pump that is no different than the $150 pump only to be
     covered by a piece of paper does not make a lot of sense,
     and that is only a small cost, because it then gets layered
     with maintenance routines and operational tests and
     performance checks and qualifications of people.
               We've put all these trappings around it and it
     really doesn't buy us anything in terms of reliability.  And
     the way you gauge that is through risk-informing the
     processes that help you categorize and determine the level
     of attention needed for those various systems, and that's
     precisely what we're trying to do with the risk-informing of
     regulation, and we'll talk about that in just a moment.
               So in answer to your question, Dr. Wallis, that
     really is where the value in this comes and if we can figure
     out how to separate the significant from the insignificant
     in terms of our treatment, both from a procurement and an
     operational and a maintenance point of view, I think the
     industry will be much better off.
               DR. WALLIS:  I was wondering, though, in the
     long-term, if you didn't see a bigger kind of benefit from
     risk-informing, where actually a lot of the excess margins
     were better understood and could perhaps be reduced and so
     on, where there was actually a more realistic regulatory
     process, and if you didn't see real advantages maybe five or
     ten years down the road from that.
               MR. BEEDLE:  Well, I think that that would maybe
     be a follow-on activity for us.  For example, if we look at
     some of our design criteria, there's a tremendous amount of
     margin in there.  Now, how do you play this margin in design
     versus risk in terms of performance of the system is
     something that really would have tremendous benefit in terms
     of construction costs, time and so forth.
               But our focus at this stage of the game in trying
     to risk-inform the regulation is saying do you need to have
     regulatory purview over that system, that component, and
     that structure, and, if not, then what is the proper
     treatment for it, and that's the struggle we're going
     through right now in trying to deal with the Option 2
               DR. BONACA:  Mr. Beedle, I have a question.  If we
     pointed out the significance of the corrective action
     program, really it's almost like a cornerstone element,
     together with the significance determination process.
               One question we've been wrestling with is should
     there be indicators regarding the performance of the
     corrective action program.  We realize that the indicators
     on the corrective program, or some indicators, would be
     almost like some more indicators of culture, to some degree.
               If you have, for example, an insignificant event
     and you have a repeat, a repeat, and a repeat, it tells you
     something about the fact that your corrective actin program
     may be not be working right.
               I would like to have your thoughts about that. 
     The reason why I'm asking is that the utilities pay a lot of
     attention and they look at a corrective action program, the
     way it works, as an element of the health of the
     organization and does it have a worth in regulatory space.
               MR. BEEDLE:  The corrective action program is one
     that I think has matured over the last roughly ten years. 
     INPO has had a significant -- has been significant in
     influencing the utilities in how to construct an effective
     corrective action program.  They follow-up with their
     periodic inspections of the plants to look at the execution
     of that program.
               More importantly, I say more importantly, it's a
     device and a mechanism used by plant management to ensure
     that problems are resolved.  So it's a very significant
     program.  It's not just something that sits on the side and
     collects things that the NRC inspectors find.
               It's an active, very useful, necessary mechanism
     employed by the utility to improve the performance of their
               Now, if the inspector finds a problem and it's
     judged to be green, and it is a problem and it needs to be
     fixed, so it goes in the corrective action program, how many
     of those green problems do I have to have to make a white?
               That's the question that I think is underlying a
     lot of this angst over the corrective action program.
               DR. BONACA:  No, no.  I said they repeat, another
     repeat of another insignificant issue.  I'm only saying that
     you do have an issue, you say it's not very significant. 
     There may be some intermediate significance.
               I mean, I'm not specific about the measurement of
     this significance determination process.  You put it in the
     corrective action program and later on you find that you
     have another problem identical to that.  The root cause of
     the first one hasn't been fixed yet, and so on and so forth.
               Now, that's one issue that is significant, they
     pay attention to those.
               MR. BEEDLE:  That's part of the corrective
     program, is whether or not the problem you're trying to
     address today is one that existed in the past and whether or
     not that root cause had been addressed.
               DR. BONACA:  That's right.
               MR. BEEDLE:  And if the problem comes up today and
     you judge that you obviously have missed the target, you
     didn't quite get the root cause, you go fix it again and you
     keep working that.  There's a little feedback loop in there
     that says what have you had in the past.
               So that's part of the corrective action program.
               DR. BONACA:  I'm saying in some cases it may not
     work, the feedback, and I'm saying that should there be
     something there for which there is an indicator.
               MR. BEEDLE:  I think that's the whole process that
     we're trying to address here, is what should you take
     regulatory purview of and what shouldn't you.  And I would
     suggest that if it's green, it's green, let the utility deal
     with it.
               You have inspection modules that look at the
     corrective action program and if you find that there is some
     failure in the corrective action program because they don't
     have that feedback mechanism, then you address it through
     that process.
               DR. BONACA:  Okay.
               MR. PIETRANGELO:  But there's another issue.  Your
     question, Dr. Bonaca, was specifically on whether the CAP
     should have its own EIs.  There's the PIs on the equipment
     that are in the revised oversight process, but I would also
     add that the maintenance rule sets performance criteria on a
     lot bigger scope of SSCs than just are in the revised
     oversight process and if you hit the performance criteria,
     you're required to do root cause analysis, take corrective
     action, and set a goal to determine the effectiveness of the
     corrective action.
               I would argue that just based on the equipment
     alone, under the scope of that rule, there's ample
     indication to monitor the effectiveness of the corrective
     action program and until that's proven that it doesn't work
     very well, and I don't think it has yet, I don't think
     there's a basis to -- I understand your point very well.
               It could, I suppose, have some indication on the
     culture of the organization, but I think just on the hard
     equipment itself, there's a lot of indication already.
               DR. BONACA:  The reason why I asked the question
     is that clearly there is -- we're going towards an
     environment where we rely much more on the instruments of
     the utility to repair problems than on the regulatory
               As we do so, then we have to be confident that
     those instruments work and the corrective action program is
     a fundamental instrument and that's why we're asking the
               I agree with your comment that, in fact, the
     maintenance rule provides another window.
               MR. PIETRANGELO:  And that's in the regulatory
     purview.  That's not just the licensees looking at that.
               MR. BEEDLE:  There has been a question raised
     probably once a year or so, somebody says what's the
     connection between economic performance of a utility and the
     safety performance, do they go hand-in-hand.
               INPO has attempted to answer that question a
     number of times.  I think the is yes, there's definitely a
     linkage, because the same people, the same management
     philosophy that's driving your good economic performance is
     also driving your safety performance.
               And there is not one utility executive that wants
     to have a safety problem at the plant, because a safety
     problem means failure on the economic front, and everybody
     understands that.  No question about it.
               So I think that the -- you know, if you look at
     the economic performance of these, I'm not suggesting we
     have an indicator here, yet --
               DR. POWERS:  You're among friends.  This committee
     is dead set opposed to economic indicators.
               MR. BEEDLE:  The first six months of this year,
     the industry produced six percent more electricity than they
     did last year for the same six-month period.  You don't
     achieve -- and we're already at about 90 percent capacity
               I mean, you don't achieve that kind of performance
     just on a whim and you don't do that setting aside all your
     focus on safety.
               So these things really work hand-in-hand and I
     think Tony's comment that the performance of the plant will
     be reflected in the way the plant material condition is
     carried out, and that is going to tell you something about
     that corrective action program.    
               The corrective action program and self-assessments
     that have been fostered through the INPO process over the
     last ten years have probably done more to improve
     performance at the utilities than any other thing.
               They've caused the utilities to become more
     familiar with their equipment.  They look at problems.  They
     take that problem, correct it, feed it back into their
     maintenance systems, and, as a result, you see improved
     performance across the board.
               I hope that answers the question.
               Dana, let me turn to a couple other areas here, if
     I may.
               DR. POWERS:  Please.
               MR. BEEDLE:  I've got Tony Pietrangelo, who is the
     Director of our Licensing Strategic Group.
               MR. PIETRANGELO:  Not anymore.
               DR. POWERS:  We hardly know Tony at all.
               MR. MARION:  Whatever is says on the chart.
               MR. BEEDLE:  Alex Marion, Lynette Hendricks, and
     Doug Walters.  Tony is going to talk a little bit about the
     risk-informing regulation and some of the interactions we've
     had with the ACRS and the staff and give you some insight
     into that.
               Alex is going to discuss a little bit about the
     oversight process.  Lynette is going to touch on
     decommissioning activities, and I know that was an issue
     this morning when you were talking with the Commissioners,
     and then Doug will talk a little bit about the license
               But before they do that, let me just make kind of
     an observation on ACRS.  ACRS is, I think, a relatively
     unique element in the regulatory process and I talk about
     the regulatory process as opposed to advisors to the NRC
               You are an integral part of the regulatory
     process.  You're important to the Commissioners and I think
     they underscored that with some of their comments this
     morning.  And you're important to the industry.
               Your judgments, or lack thereof, your definitive
     recommendations or ambiguous suggestions create problems for
     the industry and we have to address them, deal with them in
     some fashion, because they have an effect on the staff and,
     consequently, an effect on us.
               DR. APOSTOLAKIS:  They never solve any problems?
               MR. BEEDLE:  They do solve some problems.
               DR. APOSTOLAKIS:  Some problems.
               MR. BEEDLE:  I'm saying they're on both sides of
     that fence.
               DR. APOSTOLAKIS:  Now you say it.
               MR. BEEDLE:  The direct ones, some of the not so
     direct ones.
               DR. APOSTOLAKIS:  Fine.
               MR. BEEDLE:  And my comment, I think, would have
     to be considered to be somewhat in synch with the feedback
     that you got from the Commissioners today, and say, hey,
     what do you expect me to do with that recommendation.  I
     can't do anything with that recommendation.  What do you
     want me to do?
               So that's part of, I think, your challenge, to
     deliberate on issues that you think are important, that the
     Commissioners need to hear about, and give them some good,
     solid recommendations.  I don't think this half of the ACRS
     can give them recommendation A and this half can give B and
     you send that to the Commissioners and ask them to
     auctioneer.  That doesn't help them.
               DR. WALLIS:  I think we can't go too far.  We can
     point out things, but we can't do everything.  Resolving a
     problem sometimes involves capabilities from elsewhere, not
     just the ACRS.
               MR. BEEDLE:  Well, I guess I would take a little
     bit different view of that.  I don't think that it's
     sufficient to just point out there may be a problem there or
     I'm uncomfortable with that result or I think that's a
     little bit too high or that's a little bit too low.
               That doesn't help them.  If you feel that there is
     an issue in which the staff has not come up with the right
     answer, you have this gut feel, your intuition tells you
     that there is a problem with the fidelity of the process,
     then you need to go ferret out that problem.
               You can't just walk in and tell the Commissioners
     I've got a stomach ache.  It doesn't help.  They don't know
     what to do with that.
               I would submit that you do that on almost every
     issue.  Somebody could have some angst over just about
     everything that goes on in this industry, but I don't think
     that's particularly helpful to the Commissioners and it
     certainly doesn't help me.
               DR. WALLIS:  But somebody else is working these
     problems, as well as us.
               MR. BEEDLE:  That ought to be part of your answer
     then.  Anyway, I just want you to know that you are an
     important element in this regulatory process and you're
     important to the Commission, obviously, and you're important
     to the industry.
               We end up frequently up here making comments and
     observations, we the industry, and I think that ought to be
     testimony to the value that we put in it.  We would
     encourage you to continue to look at lots of issues, but
     focus on providing good, sound advice to the Commission that
     is not ambiguous.
               So with that, let me turn to Tony and ask him to
     talk a little bit about risk-informing regulation and some
     of the things that he's been involved with, when he was the
     licensing manager.
               DR. APOSTOLAKIS:  What are you now, Tony?
               MR. PIETRANGELO:  I'm the -- go ahead, Ralph, my
               DR. POWERS:  Risk and Performance-Based Regulation
               DR. APOSTOLAKIS:  So this is up-to-date.
               MR. PIETRANGELO:  Yes, that's the new one.  I
     actually had responsibility for our risk activity several
     years ago and had a lot of interaction with this committee,
     and then we were kind of to the point we are now, I think,
     with a lot of the activities and then we went through what I
     term our blue period, from 1996 through 1999, where I think
     some of the things Ralph talked about before, trying to get
     stability back into some key regulatory processes was of
     greater importance than trying to reform the regulations
     with risk insights.
               So I tried to get out and they pulled me back in,
     George, to risk-informed regulation.  So here we are.
               DR. APOSTOLAKIS:  They did that very well.
               MR. PIETRANGELO:  Let me start just by saying that
     there's already a lot of industry interest in risk-informed
     regulation, and it's present today in the regulatory
     process.  Just to name a few items, the monitoring, the
     level of monitoring done under the maintenance rule is
     risk-informed.  The new A-4 configuration risk management
     process is certainly risk-informed.
               The reactor oversight process is risk-informed in
     terms of the significance determination process, as well as
     the areas that the inspection process focus on.  Sixty
     plants are getting ready to submit risk-informed in-service
     inspection requests and almost all plants have gotten some
     kind of allowed outage time extension through risk-informed
     tech specs.    
               So the fact is that risk insights are already
     being used in the regulatory process to a great extent
     today, even though, and I think this was mentioned before,
     but maybe not this way, there is no requirement for PRA in
     the regulation.
               All we have is that IPE generic letter, which was
     just do you guys want to do one and if you do, can you send
     it to us.  And you're right, we've come a long way since
     then and I think as part of the effort going forward, and
     that's kind of the where are we now part, I think, as an
     industry, we recognize that that old information that was
     docketed as part of the IPEs is insufficient as a foundation
     for moving forward with risk-informed regulation.
               So both on a macroscopic level, from the fleet of
     plants, risk information, from the risk information that's
     submitted on a plant-specific level, we've got to put
     something on the docket that's available to the public,
     that's transparent, so that to make some of the changes
     we're talking about in risk-informed regulation, that has to
     become part of the licensing basis and has to be very
               We're analyzing several alternatives now on how to
     do that best and I think you'll be hearing from us in the
     near future on that.
               DR. SEALE:  Tony, could I ask a question?  This
     morning, you were there, I believe.
               MR. PIETRANGELO:  I was not there, Bob.
               DR. APOSTOLAKIS:  Ralph as.
               MR. PIETRANGELO:  Ralph was there.
               DR. SEALE:  One of the comments that was made was
     that in several contexts, we find that the process of
     docketing something has a tendency to ossify what's done. 
     So when you say you want to put the PRA in the docket, yes
     and no, in the sense that we sure would like to have the PRA
     on the docket, because that's something that everybody then
     has some access to.
               And so the unfounded impugning of the level of
     consideration of risk issues would be hopefully diminished
     if someone was willing to look at the PRA that would be
     available.  But at the same time, we would hate to think
     that if you put the PRA on the document, that you would then
     be reluctant to upgrade it at appropriate intervals so that
     it continued to be a living document.
               So somehow -- and I don't think there is a
     provision for this right now.
               MR. PIETRANGELO:  There is not.
               DR. SEALE:  But somehow, between yourselves, and
     clearly you're a party to it, the Commissioners and, I
     guess, this committee is an honest broker, hopefully honest
     anyway, we have to come up with an idea of how we docket
     something that also satisfies the idea of being a living
               MR. PIETRANGELO:  And that's one of the things.  I
     don't think we said we're going to put the PRA on the
     docket, but in the same vein, though, I think some of the
     things we're thinking of, for example, even with the ALWRs,
     there was a summary of the PRAs put in the FSAR.
               The FSAR is updated on a regular basis.  You could
     have the main contributors.  You could have some of the
     metrics that are associated with the PRA.  It could be
     updated on an ongoing basis.
               I think as part of the application, if you're
     going to be a player in risk-informing the special treatment
     requirements in Part 50, you're going to have to put
     something on the docket and have to keep that updated over
               There's already mechanisms in the current
     licensing basis to do that, to put it in your CLB, whether
     it's the FSAR or a commitment or somewhere else in the
     licensing basis, and they already have mechanisms to update
     and even change control processes for those kind of things.
               DR. SEALE:  Okay.
               MR. PIETRANGELO:  And I think that's -- because we
     really haven't had much discussion on that yet, that may
     have been driving some of the issues that have come up in
     risk-informing Part 50, particularly in Option 2.  We've had
     a lot of talk about the PRA standards and the
     prescriptiveness of it, the detail of the Appendix T for
               And because we don't have something that the
     regulator has direct oversight over in the licensing basis,
     kind of using these longer levers to try to get control over
     the PRA quality, and maybe that's not the best way to do it.
               So the other thing I think that I want to talk to
     you all about, and I think your letters and deliberations
     have been helpful already, is that we need to understand the
     process of how this is going to work to be able to put the
     individual pieces in, like the PRA standard and like the
     peer review process, and, yes, the prior staff review, prior
     to the application.
               I think in some of the documents you've seen, the
     objective for the detailed Appendix T and the detailed
     standard being no prior NRC staff review and I think that's
     probably a false premise for the kinds of applications we're
     talking about in risk-informing Part 50, Option 2 and 3.
               There is going to be a need for prior staff
     review.  Reg Guide 1.174 is about the staff's review of
     licensee submittals to change their licensing basis with
     risk insights. 
               I think the process we envision is that some of
     these pieces, like the standard and the peer review process,
     can help facilitate the staff's review.  We can even get it
     down to a template such that the thing doesn't take the time
     that South Texas is taking right now to process their
     exemption request and that those could be done in a very
     efficient way.
               The risk-informed ISI submittals are down to
     templates.  This committee has looked at a lot at
     risk-informed ISI over the years.  One of the specific reg
     guides is on ISI and IST, and we've got the submittal down
     to a template.  It's not the FSAR-like volumes of work that
     were done to support ISI, but it lifts the pertinent
     information out that the staff needs to conduct its review,
     and I think we can get to that same point on risk-informing
     Part 50, Option 2.
               DR. APOSTOLAKIS:  I think we're running out of
     time real quick.  So I h tow questions that I would like to
     ask you.
               We hear -- in fact, the Commission had asked this
     morning, but we heard it, some in the industry think that
     perhaps we're going too far in trying to risk-inform Part 50
     and you hear things about low-hanging fruit and so on.
               MR. PIETRANGELO:  There is no -- we'll have to get
     that out of the lexicon.  There is no low hanging fruit in
     the regulatory process.
               DR. APOSTOLAKIS:  But do you -- is NEI's sense
     that we are going too fast?
               MR. PIETRANGELO:  No.
               DR. APOSTOLAKIS:  Okay.  Good.  Second question. 
     I think sometimes one learns from one's not so successful
     efforts and -- how to put it in a more straightforward way
     -- do you think that any of the views that the ACRS has
     expressed in the last several years have, in fact, not been
     helpful or they missed the mark or whatever?
               MR. PIETRANGELO:  No.  I think the views the ACRS
     expressed, that have been expressed by the ACRS have been
     pretty good and on point.  I just wish it wouldn't take you
     so long to do it.
               I mean, it took almost four years to get that
     series of reg guides out.
               DR. APOSTOLAKIS:  So you're not just blaming the
     ACRS for that.
               MR. PIETRANGELO:  No.  But I think this is to
     underscore Ralph's point.  You're not just deliberating here
     off-line.  You are part of the process and I think as an
     industry, our sense of time needs to change a little bit. 
     Some of the generic safety issues that the staff and the
     ACRS reviews have been in that log for a long, long time and
     you start to ask yourself, well, how important can that
     thing be if it's been there for 15 years.    
               So I think in the industry, with deregulation and
     other things, that our timeline has to change a little bit
     in terms of how long it takes to do some of these things,
     because you can't sustain that level of resources to focus
     on that problem for that many years.
               We've got to have something that's either
     step-wise growing up to the end goal or decide it's not
     worth it and get out of it, because it's a lot of resources
     for us to support your meetings.  I know it's a lot of
     resources on the staff to support your meetings.
               I wanted to compliment you on waiving your review
     of the final reg guide on 50.59.  I think you recognized
     that you done a good job on the preliminary reg guide, there
     weren't that many changes on it, and there was no -- was
     going to be no value added by another ACRS review.
               I think you should look at that more often in the
     future.  And on the risk-informed stuff, your insights are
     vital to the process and for public confidence in the
               But I think what I'm trying to get at is we can
     find a way to get them in or at least think about the times
     that you really want to weigh in.  Do you want to weigh in
     on the front end or do you want to let the staff kind of
     bake something and interact with us and then bring you
     something or when?
               DR. APOSTOLAKIS:  What do you think of that? 
     Because that has been a criticism of the committee from some
     quarters, that if we get involved from the beginning, then
     we are not independent.
               MR. PIETRANGELO:  That's right.
               DR. APOSTOLAKIS:  On the other hand, if you look
     at the history of this committee, up until maybe ten or 15
     years ago, it was very common that the staff would invest
     two or three years into a project, then appear before this
     committee, but the committee would disagree and you would
     have all sorts of acrimonious debates.
               It's unfair to the staff because they have already
     invested a lot of time, but it's unfair to the committee,
     too, to say, at the end, well, gee, you know, we've invested
     so much time, you better go along.
               On the other hand, you are accused that you are
     not independent.
               MR. PIETRANGELO:  Sure.
               DR. APOSTOLAKIS:  It seems to me you can be both,
     but I would like to know what you think.
               MR. PIETRANGELO:  And I think it depends on the
     situation, of course.  There's a balance between -- you're
     not line management for the NRC.
               DR. APOSTOLAKIS:  Yes, we are aware of that.
               MR. PIETRANGELO:  I don't know how many meetings
     I've walked into where the first slide was ACRS concerns. 
     Well, you know, the thing is just starting out and I think
     it's something to think about with each of the issues the
     committee deals with, about when you interact, is it the
     right time, and not to just assume some rote schedule for
     that interaction.
               I think I've already seen some things about
     backing off some of the process type issues and focus in
     more on the safety standards type issues.  I think that
     makes perfect sense for this committee.
               But overall, and there's no right or wrong answer
     to your question, George, I think it's got to be a balance
     and it's got to be a consideration in the back of the
     committee's mind of when you weigh in and is it the right
     time in the process.
               DR. APOSTOLAKIS:  And sometimes, of course, that's
     beyond our control.
               MR. PIETRANGELO:  That's right.
               DR. APOSTOLAKIS:  When we get an SRM, we have to
               MR. PIETRANGELO:  Absolutely.  Absolutely.
               DR. POWERS:  One of the motivations for this, we
     were so anxious to have this meeting and, of course, we do
     do a self-assessment of ourselves.
               MR. PIETRANGELO:  Right.
               DR. POWERS:  And, in fact, one of the assessments
     that we did, we looked at the number of issues that we were
     trying to tackle and said it's too many and set up some
     criteria for when to, as you say, not weigh in, because it's
     outside of our expertise or we really didn't have anything
     to contribute.
               We do keep metrics on ourselves and I'm proud to
     say that whereas our metrics are not as good as the -- the
     performance metrics are not as good as the nuclear
     industry's, we are on an effector.
               MR. BEEDLE:  I hope most of them are green.
               DR. POWERS:  Since we get to set the color bands,
     we're white in two and green in the rest.
               MR. PIETRANGELO:  Doug is going to talk about
     license renewal in a second, but I know this committee is
     thinking about license renewal and not too long, probably
     every month, you're going to be deliberating on someone's
     application for license renewal, and that's a statutory
     requirement for this committee to do that and you are part
     of the process, make no mistake about that.
               And it's worked well thus far.  We know we can
     process two at a time or three at a time now and in a couple
     of years, that's going to be eight to ten.  Again, if you
     don't get on top of this when you interact in the process
     thing, when you're having that kind of workload coming down
     the stream, I think you're going to put yourself in a
     critical path position on some of these.  So it's something
     to think about.
               MR. BEEDLE:  Dana, we have until three on your
     agenda, is that correct?
               DR. POWERS:  Sure.
               MR. BEEDLE:  I just wanted to try and make sure we
     didn't run over.
               DR. POWERS:  We got a little slop.
               MR. BEEDLE:  Why don't we touch on license
     renewal, Doug?
               MR. WALTERS:  Good afternoon.  I'm Doug Walters. 
     I have responsibility for renewal.  As Tony said -- well,
     let me start off by, I guess, saying that we've been fairly
     successful, as you know.
               I think you've had the opportunity to review at
     least two applications.  We have three that are under review
     now and by our own assessment, there's somewhere on the
     order of 30 more units that will come in with applications
     between now and about 2003-2004.
               So the interest in renewal is swelling and as Tony
     said, you do play an important role in that process.
               I know that you're going to talk about the GALL
     and the standard review plan and the other guidance
     documents, and that's really our focus in the industry right
     now.  We're reviewing those documents.
               With the exception of the applications that have
     been submitted, I think these documents represent probably
     the most significant thing that's come out of renewal in a
     while, and these are extremely important documents for the
     follow-on applicants because they intend to rely on them.
               And I would point out that in the review of
     Calvert Cliffs and Oconee, the number is somewhere between
     85 and 90 percent of all the programs that were credited
     were existing programs.
               So what we really need to focus on is that
     remaining, whatever the number is, ten to 15 percent and
     make sure that we understand what enhancements are needed or
     what new programs might be necessary.
               To pick up on a point that Ralph made about ACRS
     and the role you have in that process and the impact that
     you have, I just thought of two examples that I will share
     with you.
               One is the environmental effects of fatigue, which
     has probably been debated to death and nobody wants to
     regurgitate, and I understand that.  I feel that way myself.
               But I would just point out to you that it's not
     that we're whining about where that issue came out.  I think
     what we would like to see, though, is perhaps more
               For example, if you read the staff's letter, they
     indicate that this is not an issue for ALWRs.  Yet, they use
     the same, at least as I understand it, ALWRs use the same
     methods for evaluating fatigue as we did on the operating
               And somehow, on the operating plants, for renewal,
     we come out with a different result.  And when we know an
     issue like that is coming to an independent technical body,
     we're anxious to see how you look at that and is there
     consistency across the issue.
               And I'm not so sure, in this case, and I'm not an
     expert in the fatigue area, but based on what I read and
     what I do know of the issue, I'm perplexed by that.
               The impact of that, though, is we now, as an
     industry, have to go out and figure out a way to deal with
     environmental effects only from year 40 to 60 and we go to
     the ASME code, they haven't changed the curves, I think
     something is underway perhaps, but it presents a real
     problem for us, because it's up to the applicant, the
     renewal applicant to deal with that issue and we're not
     quite sure how we do that.
               We'll get there.  It's not to say it's not a real
     phenomenon, but when a decision is rendered that, yes, this
     is something you need to address in renewal, we need to do
               Another area is rule changes, when there is a
     change to a regulation, and I will mention 50.55(a) and the
     adoption if IWE and IWL, and there is an example where we
     have an opportunity to look at that rule change and say,
     okay, if we adopt this change to IWE and IWL, how does that
     impact renewal.
               I think in this case, the staff concluded that
     what they were doing in the rule change would cover the
     license renewal period.
               Now, the renewal staff came back and published a
     reg guide and disagreed with that.  So, again, we're in a
     predicament that we've got a regulation that says IWE, IWL,
     and, specifically, the focus is in accessible areas, and we
     have a regulation that says that should be okay for renewal,
     but we have also a reg guide or a NUREG that says, no, we
     don't agree with that.   
               We need somebody besides ourselves to kind of look
     over the broad spectrum and say is there consistency there,
     and I think these are two examples, not necessarily -- it's
     being candid with you.  I'm not trying to be critical with
               But we need that kind of broad overview to say are
     we being consistent technically.  The process issues we can
     deal with.
               So as we go forward, we hope that that's the kind
     of keen eye you will give to the GALL, principally the GALL. 
     I think that's where all the technical meat is.  And we need
     that document to be technically correct so that when these
     30 or so renewal applicants come in over the next couple of
     years, we know we can rely on that document and there will
     be some success there.
               That's all I have, unless you have any questions.
               MR. BEEDLE:  Okay.
               DR. APOSTOLAKIS:  Just out of curiosity, if we
     have 30 units in the next four years, would risk-informing
     the process help a little bit or you don't want to touch
     anything?  The process is working.
               MR. WALTERS:  I'm going to defer to the end of the
     table for the specifics.  I will tell you that this is
     another consistency issue, in my view.
     If I may put the risk-informing aside for a moment, it's
     curious to me that the maintenance rule, for example, has a
     scoping criterion safety-related and that scoping criterion
     is the same in license renewal for safety-related.  Yet, we
     haven't figured out a way of how we can give credit for what
     we do under the maintenance rule.
               If we go to risk-informed scoping, it seems to me
     that you ought to be able to apply that to license renewal. 
     That would be, it seems me, the prudent thing to do.  That
     makes it consistent.
               But as Tony can explain to you, the way that
     Option 2 is working, if you do renewal, you can't do Option
     2.  I don't know if you want to expound on that.
               MR. PIETRANGELO:  Yes.  There is a perverse
     consequence of a staff position on not applying the
     risk-informing Part 50, Option 2 to Part 54.
               For the near-term applicants in the queue who are
     already in the process of preparing their applications, it
     has absolutely no effect, because this rulemaking is going
     to take a couple of years.  It's not even slated to go out
     for public comment until late next year.
               So it will not have an impact on the near-term
     applicants.  Rather, if one of those near-term applicants
     wanted to also take advantage of Option 2, you would -- the
     way the process is going to work is the safety-related, low
     safety-significance box, the RISC-3 box, there would be some
     kind of minimum requirement in lieu of the special treatment
     requirements for those components.
               In the license renewal process, there is a
     demonstration that the effects of aging are being managed
     effectively, and a lot of those come from the special
     treatment requirements.
               So you're asking -- unless the staff wants to
     stipulate up front that whatever that minimal requirement is
     would be adequate for the demonstration, you're going to
     undo a lot of the things you did in risk-informing Part 50,
     Option 2, and it's going to be a disincentive to moving
               So we think that Part 54 should be included in the
     special treatment requirements.  We think it will not have
     an impact on the applicants that are in the queue.  It will
     make the process more efficient and coherent across Part 50
     and Part 54 for the remaining 60 to 70 plants that are going
     to come through the license renewal process in the future.
               I just think it's just not consistent.  This was
     Douglas' point that says we can us risk insights to focus
     our resources on the right things in Part 50, but we don't
     want to do that for Part 54.  To me, that's not consistency
     and coherency in the regulatory process.
               MR. BEEDLE:  I think it points out some of the
     difficulties that the staff has and the industry, as well,
     in trying to figure exactly how you take this risk-informing
     and lay it across all the regulations.
               Short of just taking a clean sheet of paper and
     starting to develop these regulations, I think you're going
     to continue to run into these sort of problems.  But we
     would hope that there would be more thought given to the
     statements that you find in SECYs, for example, because
     those things carry a lot of weight.  They carry an awful lot
     of weight.
               That's, in part, the challenge that you gentlemen
     have in trying to provide advice and counsel to the
     Commissioners.  You make a statement and the staff uses that
     and they act on it.  They think that that's --
               DR. POWERS:  We are well aware the Commission
     today asked us both questions, are we going too fast and
     should we be working on 50.54.
               I think, in sympathy to lots of people suffering
     from future shock, they have to be a little patient here. 
     I'm sure there's going to be some dislocations.
               But you're talking to a committee that, if they
     had their druthers, would have taken out a clean sheet and
     written the whole thing in risk language and moving 54 in
     there would have -- I mean, when that decision not to have
     license renewal be risk-informed was made, I think we
     understood the practicalities and the time pressures at the
     time, but I think we were disappointed that that didn't
               MR. PIETRANGELO:  I think the concern is upsetting
     the apple cart and I think that's a false --
               DR. POWERS:  And I think that's a good point,
     Tony.  I think I'd like to have you come down here and make
     that point to us a couple more times.
               MR. PIETRANGELO:  Ralph made this point to the
     Commission in a briefing last week.
               DR. APOSTOLAKIS:  It takes us three times.
               DR. POWERS:  It is a problem which we have right
     now, which is an inconsistency between one end of the table
     and the other, and we've been whistling along saying, well,
     we'll evolve toward it, and I think what you're telling us
     is let's help Mother Nature evolve a little faster, let's do
     some genetic engineering here.
               MR. WALTERS:  Well said.
               MR. BEEDLE:  If we could, let's turn to -- do you
     have anything else, Doug?
               MR. WALTERS:  No, I don't.
               MR. BEEDLE:  Turn to Lynette and a little bit of
     discussion in decommissioning activities.
               MS. HENDRICKS:  I'd like to take probably what
     little time I have and talk about risk-informing the
     decommissioning regulations.  There were some other things
     on your agenda about cask process and decommissioning
     process, but if I had my druthers, I guess I'd like to say a
     few things first about the spent fuel pool risk study and
     how that's being used to risk-inform the decommissioning
               I did not, unfortunately, have the opportunity to
     attend your briefing, but I do have the benefit of your
     slides and I concur with the position you're taking here,
     that when you start to risk-inform this special event over
     here with the pool, you're in different space, and I see
     that in your recommendations that the LERF may not be as
     appropriate as it had initially appeared to be when you
     start to look in more detail at the consequences.
               I think the ACRS has been very helpful and very
     astute at trying to direct the staff's attention to refining
     the consequences, but I guess I would hope that since we are
     in different space, we would give the same emphasis to
     refining the probability.
               What I mean here is that at this point, we are --
     the whole event, as you know, is driven by the single,
     somewhat bounding seismic event, and that's different than
     what we have in operating space.
               In fact, the same event is a background risk
     factor and I think we're going to have some unintended
     consequences if we are not equally careful in balancing the
     consequence refinement with the probability refinement.
               I'll give you an example of that.  It's in the
     SECY-00-145 that's before the Commission today, and
     understanding that that's going to change, but I guess what
     troubles us with that is it seems like we've missed some
     opportunities to apply real risk insights on a practical way
     by basing all of our concern on this single bounding seismic
     event, for which there are no mitigating factors.
               I can say that more in pragmatic terms.  What you
     end up with is a rulemaking that essentially layers
     deterministic requirements; in other words, you don't get
     out of your EP and you don't get out of financial protection
     until you can demonstrate the event cannot happen.
               At the same time, the rulemaking plan proposes to
     layer these new requirements that we worked constructively
     with the staff to come up with to address all the other
               We propose some real practical solutions to
     identifying and mitigating and responding to these slow
     leaks and loss of cooling and we also put forward a seismic
     checklist that we were hoping would help screen out this
     event, which, actually, if you look closely at the implied
     requirements, really you're talking about a big imposition
     in a regulatory sense.
               What it ends up with is you have a voluntary rule
     that industry is not likely to take advantage of at all.  So
     you're going to have a status quo.  All this rulemaking, all
     these risk insights for nothing, because the industry will
     have to look at that rule and say, jeez, you know, I've
     operated with this out here seismic risk and I have
     financial protection, I have EP, I shut down, I have one
     thing to worry about, just the pool, and I have this
     background event that's now predominant and I have to, in
     order to still have EP and financial protection, incur all
     the costs of these additional requirements.
               It's kind of an untoward outcome in risk space. 
     So to sum up, we certainly appreciate your --
               DR. APOSTOLAKIS:  Is there a good risk analysis
     that the industry has done on this issue that I can look at?
               MS. HENDRICKS:  If you will recall, we
     participated early on.  We had ERIN Engineering provide
     input to when we were predominantly looking at these events.
               Remember, the staff initially said this risk was
     equivalent to an operating plant risk because there was very
     little credit for the long duration of the events and
     they've since refined their HRA analysis and now we're
     working very diligently on the seismic risk and we had hoped
     to sort of put that to bed.
               DR. APOSTOLAKIS:  If you do that, you deserve a
     statute.  A seismic issue?  In this context.
               DR. POWERS:  And one of the points we tried to
     raise with the Commission was that this bounding seismic
     analysis was strictly inconsistent with the whole philosophy
     we were pursuing everywhere else and it was expedient, but
     it was not useful.  So I think we're sympathetic in that
               I think we're looking for a much more stately
     approach to this than maybe is what you're looking for.  We
     don't get the phenomenological things squared away and then
     proceed into the risk analysis and going, it seems to us,
     completely to risk, rather than a damaged frequency or
     something like that.
               MS. HENDRICKS:  Thank you.
               DR. KRESS:  We recognize from the start that the
     bounding seismic analysis that was used, the CFCLP concept,
     was very conservative and we knew if you were going to get
     any relief at all, that that's the end you would have to
     work on.  I'm glad to hear that somebody is addressing the
     real risk, not just bounding it, because actually there's
     two parts, there's the consequences and there's the
     frequency and you've got to have both of them.
               And we really had no way to focus on the
     frequency, other than in our evaluation, all we could look
     at is consequences.  Now, somebody has to look at the
     frequency and balance the two and I think that's what you're
     trying to say.
               MS. HENDRICKS:  We are and I think, to a certain
     extent, it poses a challenge because we're sort of changing
     horses, too.  For operating plants, we use the sort of a
     more deterministic approach to seismic, with the safe
     shutdown earthquake and you look at the tectonics and say
     this is worst case, with some dealing with the uncertainty,
     whereas now we're deciding, well, let's embrace probability.
               So we pick up either the Livermore report or the
     EPRI report.  When you try to look at the whole scheme,
     you're always going to have an over-focus on these very
     large, very low probability events.     
               So I know this is coming back to you and I know
     the staff is looking at it, but if we would think even
     beyond, well, kind of what we've gotten from the staff is,
     well, you wanted probability and here's the number you get,
     but that's not looked at in the consequence of one event
     driving the whole sequence.  We may come out with funny
     screening numbers.
               DR. KRESS:  I think what you're saying there is if
     you have just one event driving your whole risk, that your
     risk acceptance criteria might be viewed differently --
               MS. HENDRICKS:  Exactly.
               DR. KRESS:  -- than if you had a whole lot of
     things, and I think there's some truth to that.
               DR. POWERS:  Not only that.  I think you run into
     the challenge of interfacing defense-in-depth concepts.
               DR. KRESS:  That's an additional depth to this
               DR. POWERS:  You've got to think very carefully
     about how you're going to be consistent with the
     defense-in-depth philosophy when you've got one dominant
               DR. KRESS:  Absolutely.
               DR. POWERS:  It's a strange thing.
               MR. BEEDLE:  Well, it's not an issue that's going
     to be resolved this afternoon, which I judged from the
     Commissioners' comments this morning.
               Let me turn to Alex and ask him to provide a few
     comments on the revised reactor oversight process.
               MR. MARION:  Thank you, Ralph.  My name is Alex
     Marion.  All I can tell you at this point is I think I work
     for Ralph.
               DR. POWERS:  It says licensing and programs.
               DR. SEALE:  He thinks so, too, I take it.
               MR. MARION:  Just very briefly.  I know we're
     pressed for time.  Let me just indicate that overall, we
     think the process has been very successful in that we have
     been working very closely with the NRC staff and other
     interested stakeholders to make sure that the entire
     community of interest understands what the indicator system
     is all about, understands what the thresholds for regulatory
     action that Ralph alluded to earlier in terms of inspection
     is all about, and that entire process is scrutable.
               As you all know, the first year of implementation
     is getting close to being completed.  They're into the third
     quarter.  The second quarter data has been already provided. 
     Third quarter data is going to be submitted to the NRC, I
     believe, the 21st of October.
               It doesn't indicate that everyone is in the green
     area.  It's starting to identify a mix and I think as we go
     through that process, we'll be able to evaluate the
     indicators and the thresholds and the action and draw some
     conclusion as to whether or not it's doing what we expected
     it to do in terms of the overall scheme of things.
               The NRC has just recently announced the formation
     of a FACA panel, similar to the pilot plant evaluation
     panel, that will start the effort to begin the lessons
     learned review of the process during this first phase, this
     first year of effort.
               That panel is scheduled to have the first meeting,
     I believe, early November, November 1st and 2nd.  Again,
     that body will, as necessary, include various stakeholders
     to provide the overall assessment of the process in terms of
     internal NRC benefit, understanding scrutability to external
     stakeholders, as well.  So we find that to be very positive.
               There is one performance indicator that's being
     changed.  It begins with the letter S, dealing with counting
     of automatic and manual scrams.
               We have reached an understanding with the NRC on
     alternate indicator and we're going through the
     implementation phase of benchmarking or testing that
     indicator through a pilot process.  We have 21 units
     involved and that process began this month and will continue
     through March of next year.
               And fundamentally, if it's found to be acceptable
     by NRC, then we expect it to be implemented third quarter of
     next year.  We find that to be positive.
               So it is a dynamic process.  It seems to be
     working well.  We're, quite frankly, pleased.  We believe
     that the changes that have been identified and agreed to are
     necessary changes and there will likely be changes in the
     future, and we're just pleased to see everyone working on it
     and applying their best efforts and making sure that it's
     accomplishing its intended objectives.
               DR. POWERS:  One of the issues that we have
     debated around this table, to no successful resolution,
     except an accommodation, was that the cross-cutting issues
     that include things like human performance, will they, in
     fact, be revealed adequately early by the other performance
               I think the accommodation the committee came to
     within itself over that was to say this is an untested
     assumption and it needs to be considered as we get into this
     assessment and whatnot.
               Is that one of those things that you're paying
     attention to at all?
               MR. MARION:  Yes.  It is being considered.  I wish
     I could provide you a definitive answer at this point in
     time.  But I suspect as we go through this cycle, we will
     probably have a more confident feeling on how that
     particular element is being considered in the overall
     program.  But it's something that everyone is aware of.
               DR. POWERS:  Yes, that's good.  The other area
     that the committee has not spent any time on, because of a
     variety of things, is the significance determination
     process.  We understand what it is, but we have not gone
     through the details of it, especially for those things where
     there is not a PRA capability available, things like the
     significance determination process for fire protection
     issues and things like that.
               MR. BEEDLE:  Well, there are a number of them;
     fire protection, security.
               DR. POWERS:  Security.
               MR. BEEDLE:  And if you'll recall, security, EP,
     rad protection, are not elements that are amenable to the
     PRA focus.
               DR. POWERS:  The current PRAs can't do that.
               MR. BEEDLE:  But they were nonetheless important
     elements in this overall assessment process for the facility
     and we aged with the inclusion of those pieces as
     cornerstones and the necessary outcome was to have some sort
     of a significance determination process.
               We have, just for an example, an SDP in the rad
     protection area, talks about if you have a planned
     maintenance evolution with a target exposure and you are
     approaching that and you go over that exposure calculation,
     then that puts you in white.  That makes that a white
               Well, safety significance is zero, but we agreed
     that that is something that is important and we understand
     the ground rules.  Again, if I know what the target is, I
     can figure out how to deal with it.
               Well, there is a provision to go in and change
     that target and then you get into the philosophical argument
     of whether or not it's best to change your target or not
     change your target, what's the effect on people and how do
     they deal with that whole issue of management control.
               So we've got that behind us.  Now, that's a good
     example of where a very deterministic pre-determined course
     of action would be taken, given a certain set of
     circumstances.  We understand that, and there are a lot of
     areas like that.
               DR. POWERS:  I guess what we were concerned most
     about is it seems like some of those non-PRA things, the
     thresholds are a good deal more stringent than the
     corresponding ones that are treated with a probabilistic
     risk assessment, and we worried are we losing the advantage
     of focus by putting in very stringent thresholds on some
     cornerstones and not so stringent on the others.
               MR. BEEDLE:  I think that's a very valid question
     to be asking and I guess maybe the corollary to that is
     what's the effect on does it divert management attention and
     are you really looking at the right thing and so forth.
               So I think we'll have to continue to look at that. 
     We'll get our FACA panels to look at that.
     DR. POWERS:  I think it would be interesting to pursue that,
     because I think there's -- my own feeling is there is
     discontinuity when you go away from those that are
     subjective to quantitative assessment to those that are more
     qualitatively or traditionally assessed.
               MR. BEEDLE:  I would suggest that the underlying
     principle involved here is don't let go of anything.  So
     we've got to have that cornerstone.  I can't let go.  I know
     it's not safety-significant, it's trivial in the grand
     scheme of safety, but I don't want to let go of it.
               I've always managed that, I've always had to look
     at it, I've always had some inspection activity there.  So
     the staff is looking for some element.  
               Now, the other part of it is public perception. 
     It doesn't serve the industry or the NRC well to not have
     something in there that speaks to protection of the public
     to radiation exposure limits, along with emergency planning.
               DR. POWERS:  I think I don't want to provoke
     concerns by the public.  But I think when we set thresholds,
     that those are a little more arcane than whether you have a
     cornerstone or not.
               MR. BEEDLE:  That's true.  Well, back to your
     question on the cross-cutting.  The cross-cutting issues are
     important to the industry, no question about that.  They're
     important to the NRC.
               I think that over the course of the last year, the
     cross-cutting issues of safety-conscious work environment,
     corrective action program, human performance have taken on
     increased significance.
               There has been more discussion of those issues and
     those programs and focus by the NRC staff on those issues
     today than there was a year ago, two years ago, three years
               And I do believe that they are self-revealing in
     the performance of the facilities.
               DR. POWERS:  Commissioner Diaz argues that the
     corrective action program is the unspoken third element of
     the new risk-informed regulatory process.  Three attaches a
     great deal of significance to that cross-cutting issue.
               MR. BEEDLE:  Yes.  I don't have anything else to
               DR. POWERS:  Well, this has been truthfully
     excellent, in my point of view.  I especially like it when
     Tony can come in and tell me things I'm supposed to be
     doing, and that's good, because I need to be reminded often
     and I'm glad to have him do it, because he does it in a very
     gentlemanly way.
               And I appreciate all the presentations and --
               MR. BEEDLE:  And he's not even Irish.
               MR. SIEBER:  That helps.
               DR. POWERS:  I appreciate all your program
     directors and their comments and whatnot and I hope that
     they will feel free to come to us and say, hey, these are
     the things we need you to pay attention to and give us the
     high sign occasionally, because we are very much in the
     situation of having a lot more issues come to us than we can
     possibly handle and we have to do some picking and choosing.
               And I kid you not, we do track our own performance
     metrics on things that we are declining to review and things
     that we do accept to review, and we'll take all the help we
     can in making that selection, because it's sometimes hard to
               So I appreciate all the comments you made and
     taking time to come down here and talk to us.  It's been
     very, very useful, for me at least.
               MR. BEEDLE:  Thank you very much, Mr. Chairman.
               DR. POWERS:  With that, I will recess us for 15
               DR. POWERS:  Let's come back into session.  We are
     now going to turn to the subject of GSI-168 and equipment
     qualification.  Professor Uhrig, I think you're going to
     provide the leadership here.
               DR. UHRIG:  Today we're talking about the
     safety-related electrical cables, primarily low voltage
     associated with transmission of signals from plant to I&C
     devices and instruments, as well as medium voltage that
     conducts power to safety-related devices.
               The business of environmental qualification
     started about 1971 or thereabouts.  There are three
     categories of plants today; one, those that started
     construction before '71; those that started construction
     after '71, they had the IEEE Standard 323, the 1971 version
               The trial standard did not address aging and
     required dynamic -- required a systematic program of
     analysis, testing and quality assurance, whereas those that
     were before '71 were held to high industrial quality as the
     primary standard.  And after the plants with CPs after
     7/1/74, there was a '74 version of the standard.
               So that's a little of the background.  The 1982
     equipment qualifications rulemaking process led to the 10
     CFR 50.49.  The Commission did not backfit this to the older
     plants and today, we have, again, three separate categories
     of plants, the largest being a group that were
     grandfathered, some 70-odd, if I understand correctly, to
     the original standards.
               So we'll hear more about this and with that, I
     guess, Mike, do you want to say a few words before you
               MR. MAYFIELD:  Yes, just briefly, to frame this. 
     We had hoped to come to the committee at this meeting with a
     proposed resolution to this generic safety issue.  However,
     as you'll hear, sort of the last bullet in the slide
     package, we're still considering some of those closure
               So we're not prepared today to talk about the
     closure.  What we wanted to do was to come and present to
     you what we have done, what we have found, and looking both
     at the testing that was done and at the risk evaluations,
     the scoping studies that have been performed, and to solicit
     any input, any questions you might have, any areas that you
     think we should specifically be prepared to address when we
     do bring the closure package.
               So it's something of a status briefing, but at the
     same time, we're hoping to see if there are any insights you
     particularly want us to make sure we address when it comes
     to the committee.
               DR. UHRIG:  Are you asking for a letter in
     conjunction with this?
               MR. MAYFIELD:  I think at this stage, a letter
     would be premature, because we don't have the closures to
     propose.  If the committee chose to write a letter, of
     course, that's obviously your prerogative, but we are not
     specifically seeking one.
               When we bring to you the proposed closure package,
     at that point, we would need a letter.
               DR. SEALE:  When do you expect to have closure?
               MR. MAYFIELD:  I had hoped to have it for this
               DR. SEALE:  I understand.
               MR. MAYFIELD:  At this stage, hopefully yet this
     year.  We are on a list that goes down to Capitol Hill that
     shows closure by December 31.  So I am hoping to make that
     milestone, but I also wouldn't want to prejudge this.  I'm
     not trying to give you a flip answer.  It's just while the
     staff is still debating this, I'm hesitant to venture a
     strong guess.
               DR. SEALE:  We appreciate your incentives.
               MR. MAYFIELD:  With that, I'd like to turn it over
     to Ed Hackett, who will start the briefing.
               DR. POWERS:  Ed, before you start, I noticed that,
     in looking through your viewgraphs, that some of the
     research was done by Sandia National Laboratories.
               I have some vague association on a very episodic
     basis with that organization, and so I may have a conflict
     with this.
               MR. HACKETT:  Okay.  I guess, like Mike said, on
     the schedule, we're actually revising our operating plan
     milestones just today and we'll hopefully still be able to
     live with some of the ones we put forth there.
               I guess some introductions are in order here.  The
     folks at the table here, myself, I'm Assistant Branch Chief
     for Materials Engineering Branch, in the Office of Research.
               On my right is Dr. Bob Lofaro, from the Brookhaven
     National Laboratory, who is the actual researcher who has
     performed a lot of the research under contract for NRC.
               To my left, immediately, Satish Aggarwal.  Dr.
     Aggarwal is the RES Program Monitor for the program at
     Brookhaven and has done the bulk of the work in this area,
     along with Dr. Jit Vorah from the Office of Research, and
     Jit is over there behind Mike.
               And to the far left is Mark Cunningham, who is the
     Chief of the Probabilistic Risk Assessment Branch in
     Research, and Mark will be addressing some of the risk
     significance aspects of the work.
               I'm sorry.  Satish just reminded me.  Jose Calvo
     just joined us, also, from NRR.  He is at the table next to
     Mike.     So with that kind of talent at hand, we ought to
     be able to hopefully -- don't want to get too cocky here,
     but hopefully we ought to be able to address some of the
               DR. APOSTOLAKIS:  Finish it up today.
               MR. HACKETT:  In terms of a purpose or objective,
     I think Mike covered that, but just to restate it here, we
     had hoped to have sort of a resolution path or approach to
     discuss with you in more detail today.  
               Obviously, as Mike said, we're not going to be
     able to do that today.  So what we want to do is basically
     review the technical background and the regulatory
     background to the issue and then just give you sort of
     status of where we are in a technical and regulatory sense.
               I think Dr. Uhrig covered an awful lot of the
     background, but I'll go into some more of that in a block
               Before that, I had one I was going to put up that
     is not in your package.  I debated whether to put this up or
     not, but since there are a variety of different folks and
     backgrounds represented in the room, I thought I would at
     least mention some of this in the way of background, and I
     hope I'm not offending anybody here.
               But, basically, what we're looking at here, as
     Mike Mayfield has characterized many times, is less of an
     electrical engineering problem, actually more of a polymer
     materials engineering problem in terms of degradation.
               You've got the polymeric materials, basically the
     jackets and insulators that are degrading.  They are
     subjected to obviously thermal and irradiation environments
     in the nuclear plants.
               DR. POWERS:  Can you give me some sort of feeling
     about the total doses that these jackets are getting?
               MR. HACKETT:  I cannot, but maybe Bob, Satish.
               DR. AGGARWAL:  We plan to cover that when we
     discuss the test program with you.  Would that be all right?
               DR. POWERS:  That would be fine.
               DR. WALLIS:  These are not subjected to
     ultraviolet or something?
               MR. HACKETT:  Not at -- don't worry about it, Jit,
     I'll do it from here.
               DR. WALLIS:  There's no ultraviolet radiation
               MR. HACKETT:  Not that I'm aware of.
               DR. WALLIS:  They're away from bright lights.
               MR. HACKETT:  They're in the containment, mostly.
               DR. AGGARWAL:  The cables are qualified to all TID
     source term and that's what these require for all nuclear
     power plants, TID source term.
               MR. HACKETT:  This was, again, just, also, in
     terms of setting the stage, but like a lot of these types,
     we just briefed the committee yesterday on neutron
     irradiation embrittlement of reactor vessels.
               Like that, this degradation is progressive with
     age, like you would expect, results in embrittlement.  I
     think Dr. Aggarwal has some samples here we'll pass out at
     an appropriate time to show you the extent some of this
     embrittlement can take.  It can be pretty dramatic.
               And, obviously, the embrittlement increases their
     susceptibility to cracking, and that almost goes without
     saying.  A lot of times, the failure mechanisms are then
     from moisture intrusion, which can either lead to gross
     failures or shorts in the cables or potentially leakage
     currents, undercurrent type situations, which could give you
     misleading information in terms of instrument and control.
               So that's just in the way of sort of setting the
               DR. WALLIS:  So there's no humidity effect or
     anything.  You say thermal and irradiation.  It seems to me
     a lot of the things degrade --
               MR. HACKETT:  Yes, absolutely.  I didn't mean to
     imply there's not a humidity effect.  That's obviously there
     and it's synergistic with the other effects, too. 
               So with that, what I would do is move on to the
     next slide in the package, sort of an attempt to run through
     how this is set up and I think Dr. Uhrig covered a lot of
     this, so we don't need to be overly redundant.
               But, obviously, this goes back to the regulatory
     basis, including an EQ rule, which was promulgated in 1982. 
     There's a Regulatory Guide 1.89 which is part of the process
     that endorses IEEE standard, that basically set a qualified
     life or a qualified envelope type of approach to
     qualification of these cables.
               However, on the slide you see here, the EQ aging
     research that was conducted at Sandia, as Dr. Powers noted,
     showed some failures of low voltage I&C cables and in some
     cases here, you'll see, Dr. Aggarwal is going to go into
     greater detail on an upcoming table here, but there were
     percentage failures that increased with time in different
     cable categories, and we'll go into some more details there.
               This was about vintage 1992, that this research
     was completed.  There were information notices that were
     issued by the Office of Nuclear Reactor Regulation to cover
     this area.
               There were also issues associated with connectors.
               DR. APOSTOLAKIS:  Are these accelerated tests?
               MR. HACKETT:  They are accelerated tests, and
     that's part of what will be covered, too, the aging.
               DR. APOSTOLAKIS:  It will be covered.
               MR. HACKETT:  Yes.
               DR. SEALE:  You say 18 at 20 years, 23 at 40
     years, 32 at 60 years.  Are those aggregates?  That is, is
     the increment between 20 and 40 the difference between 18
     and 23?
               MR. HACKETT:  I'd turn that over to Satish.
               DR. AGGARWAL:  The numbers are actually -- they
     did the tests on 20, 40 and 60 years.
               DR. SEALE:  Yes.
               DR. AGGARWAL:  When they did the testing at 20
     years, 18 percent of the cables failed had low IER.  When
     they were doing it for 40 years, it was 23 percent failure.
               DR. SEALE:  Twenty-three percent more.
               DR. AGGARWAL:  Of the set.
               DR. SEALE:  Of the set.  So that included the 18,
     plus five more.
               DR. AGGARWAL:  No.  We studied the independent
     test.  They are doing three tests.
               DR. SEALE:  Okay.
               MR. HENDRICKS:  One for qualified life equivalent
     to 20 years.
               DR. APOSTOLAKIS:  It's cumulative.
               DR. SEALE:  There are separate ones, but --
               DR. UHRIG:  Separate tests.
               DR. SEALE:  Yes, okay.
               DR. UHRIG:  Not the same cables.
               DR. SEALE:  Not the same cables, but presumably
     comparable sensitivities.
               DR. UHRIG:  Yes.
               DR. APOSTOLAKIS:  And clearly it's not linear.
               DR. WALLIS:  The rate slows down.
               DR. SEALE:  Well, it's saturating.
               DR. SHACK:  You can only get so dead.
               DR. SEALE:  That's right.  That's the truth.
               MR. HACKETT:  Dr. Shack's comment is probably
     particularly appropriate.  When we pass some of these
     samples around, I think you will see that some of these,
     that the failures can be fairly dramatic, particularly with
     the bonded jacket cables.
               DR. SEALE:  Now, let's don't make bad comments
     about geriatric activities.
               MR. HACKETT:  Okay.
               DR. APOSTOLAKIS:  You will talk about these tests
               DR. AGGARWAL:  Yes, sir, if you'd like to hear.
               DR. APOSTOLAKIS:  Well, if you talk, I'll hear.
               MR. HACKETT:  Trying to move across the chart
     here.  Out of the research work and the regulatory summaries
     that were issued, that coupled with some knowledge of what
     was going on in terms of operating experience is what you
     see on the center of the chart, led to some additional staff
               There was an EQ task action plan which was
     promulgated in 1993, which was at least one of the issues
     that was to be addressed in that task action plan was
     looking at accelerated aging and was accelerated aging
     indeed a valid way of coming at this thing.
               And for those of you who have been involved in
     this, this involves the Arrhenius methodology.  I think the
     bottom line is what comes out of that is, yes, that's a
     valid methodology, as long as you're not changing the
     mechanisms of the cable aging or failure as you're going
     through that process.
               The EQ task actin plan was actually closed by the
     NRC in 1998.  The long-term research aspects of that were
     transferred into a new GSI, 168 at the time, which is the
     subject of why we're here.
               Then there was ongoing research, obviously,
     associated with that GSI.  Forth-three technical issues,
     you'll see, at the bottom of the slide, that were identified
     and that was in NUREG-CR-6384 in 1996.
               Those research issues have been ongoing or
     addressed in ongoing research for us at the Brookhaven
     National Laboratory.
               I should also point out that the industry has also
     been active in this area, even more so now with the EPRI/DOE
     NEPO program.  There is continuing work at Sandia and
     elsewhere under EPRI funding working in this area, too.
               Some of the cable types that are addressed you can
     see under the box that has the EQ aging research under
     Brookhaven identified.  We've seen failures across many
     different types of manufacturers.
               Again, Satish and Bob maybe will get into some
     better definition here as we go through what is or isn't a
     failure, some of that is problematic in how you define these
               But to the -- maybe just the final point, the top
     of the chart, obviously, considering license renewal, I
     think one of the things we'll come to in summary is that the
     situation for the operating plants I don't think we feel is
     any dire situation by any stretch.
               For the license renewal period, on the other hand,
     we think something is going to need to be addressed.  The
     something and the process and the approach for doing that,
     like Mike was saying, remains to be determined or proposed
     by the staff, but that's sort of where we are now.
               DR. WALLIS:  Excuse me.  Your 18 percent at 20
     years is the result of some research program.
               MR. HACKETT:  That's correct.
               DR. WALLIS:  There have been plenty of cables out
     there for 20 years already.  So how do they do?  Do they
     fail at the same rate?
               DR. AGGARWAL:  When you're talking about 20 years
     cable, you're talking about the operating plant and their
     operating environment.  When we are talking about the test
     here, we're talking about an axial cable and LOCA test.  We
     are not reporting here these are expected failures in the
     operating plant in normal life.
               DR. WALLIS:  How do we relate these numbers to
     reality out there in the plant?
               DR. AGGARWAL:  I'm going to talk about it as we
               MR. HACKETT:  That part will come.  As a matter of
     fact, what I will do at this point is just outline the
     remainder of the presentation.  I will turn this over at
     this point to Dr. Aggarwal and he will summarize some of
     these tests, and Bob Lofaro is here, also, from Brookhaven
     to assist with that, if needed.
               In the part of your package that goes to the risk
     considerations, Mark Cunningham will address those.
               At this point, I guess I would say, though, if
     there are any overall questions on this background for any
     of the staff that are here present, this would probably be a
     good time to hear those.  Otherwise, we'll just go ahead and
     move on.
               Hearing none, I will turn this over to Dr.
               DR. AGGARWAL:  Thank you, Ed.  Before I talk about
     the program, and what we have done or not done, I would like
     to take the opportunity to pass the board, on my right side,
     which shows you the typical I&C cable which are used in a
     nuclear power plant and these are new cables.
               On my left, I am going to pass some photographs of
     the cables which are degraded conditions during the test.
     Anther example I am going to hand you is the Okonite 40 year
     post-LOCA cable, and please look at the condition what we
               The next sample I have is the anaconda cable,
     three-conductor, No. 12, unbundled cable.
               DR. UHRIG:  These are used primarily for signals,
     I&C signals.
               DR. AGGARWAL:  That's right.  All the cables which
     you are looking at are used in a nuclear power plant for
     instrumentation and control only.  We are not discussing any
     power cables at all.
               DR. UHRIG:  What voltage?
               DR. AGGARWAL:  Normally, they are rated 600 volts,
     but in a plant, they may be 24 volts.
               DR. UHRIG:  Twenty-four volts mostly.
               DR. AGGARWAL:  Right.  I am going to pass another
     sample of a Rockbestos cable, which is a two-conductor XLPE
     neoprene.  This is the 40-years aging and you will see the
     cracks which are visible for -- without glasses you can see
     them.  At the same time, you will see the jacket is brittle.
               I am going to pass two samples, one on this side
     and one on that side.  These are the Samuel Moore cables,
     which are two-conductor, No. 16, EPR Hypalon bonded, which
     fail during our look at test No. 4.
               Before I go further, that we were, in other
     program, looking at only three types of these cables, which
     are most popular and commonly used in nuclear power plant,
     and the sample which I've passed on to you, the big board
     has all those three kind of cables and the other sample
     which I am passing on are essentially the cables which
     failed or did not meet our acceptance criteria.
               Now, this two-sample, Samuel Moore, which I passed
     on, you will see some cable mark, black spot.  This is where
     the cable failed.  One rad conductor was punctured.
               The next sample I have is a Rockbestos XLPE
     neoprene, 60 years, which is similar to test No. 4.  And if
     you look at it, you will see how the jacket is cracked and
     is brittle.
     Another sample I have here to show to you is after LOCA test
     and, again, this is Rockbestos XLPE neoprene jacket, which
     undergone 60 years of aging and post-LOCA.
               DR. UHRIG:  I want to make sure I understand. 
     This is aged to 60 years and then --
               DR. AGGARWAL:  To a LOCA.
               DR. UHRIG:  Then to a LOCA.
               DR. AGGARWAL:  Bob, if you like, I can run down
     basic program how we do the testing.
               DR. UHRIG:  I think it would be useful to at least
     give us a quick review of that.
               DR. AGGARWAL:  Let me do that.  Let me finish one
     more sample and I go back to that.
               DR. UHRIG:  All right.
               DR. AGGARWAL:  This cable is the Okonite cable, 60
     years of aging, post-LOCA, and look at the -- this thing
     completely failed.  You could see the conductor through all
     the length.
               DR. WALLIS:  If we handle this, it will fail some
               DR. AGGARWAL:  I just wanted you to have a feeling
     what you're going to look at.
               This is the Anaconda cable, which is 40 year and
     post-LOCA, and you could see, again, the cable here.
               DR. WALLIS:  Is it the LOCA that does this to it
     or is it in pretty lousy shape before?
               DR. AGGARWAL:  It depends on what kind of
     insulation you are looking at.
               DR. UHRIG:  Do you have any test where you apply
     the LOCA to brand new cable?
               DR. AGGARWAL:  Yes, sir.  Each cable, we had a
     controlled sample.
               DR. UHRIG:  Controlled sample.
               DR. AGGARWAL:  Yes.  Let me go through the process
     very quickly and that will give you some understanding.
               As discussed earlier, you know that our
     requirement is 10 CFR 50.49, the EQ rule, the reg guide,
     they require that cables be qualified and qualification here
     is a verification of design.
               Namely, we want to ensure or assure us that these
     cables will perform their intended safety function in the
     expected environment.
               It is a one-time test.  Although the reg guide
     makes it implicitly that this qualification should be
     maintained for 40 years, qualified life.  But there is no
     explicit requirement in our regulations which require that
     we do any kind of monitoring.
               Keeping that in mind, let me try to explain the
     qualification process to you.  What we do here, we will take
     a brand new cable, and our goal here is to bring that cable
     to the end of life, qualified life.
     If it is 40 years, then we want to bring that cable to the
     equivalent to at the end of 40 years, and the reason being,
     a LOCA can take place at 39 years and 364 days.
               So we are trying to bring that cable to end of
     life condition.  How do I do that?  Because we don't have a
     nuclear power plant which have seen 40 years of natural
               So we had to go and look at the Arrhenius theory
     and see what does it tell me.  Coupled with the activation
     energy, we come out with a certain number.  That for so many
     hours, if you preheat the cable at this temperature, then we
     will consider that this is equivalent to 40 years.
               Now, NRC paid no role in arriving those
     conditions.  The manufacturers were told that go ahead, we
     understand their limitation of the Arrhenius theory, but
     come back with those parameters and those parameters were
     picked up by each manufacturer as he deemed necessary.
               And it is also interesting to note, many times,
     you find the same kind of material, but different
     manufacturers.  They came out with different numbers.
               Again, NRC was not dictating those numbers, they
     were there.  In our test program, we decided that we will
     use the same parameters which were originally used by the
     manufacturer.  We will make no deviation whatsoever in terms
     of the rate of aging.
               So what we do now, we'll take a cask sample, brand
     new, put in an oven at a certain temperature, and for so
     long time in each case as dictated by the manufacturer.
               When that is done, then we will put, on the same
     cable, the operation type radiation and then we go to the
     accident rating.
               Once that is done, then we go into what we call a
     LOCA test.  The guidance for test, how you do all these
     things, is provided in IEEE 323.74, which is endorsed by Reg
     Guide 1.89.
               Now, this particular standard for wide profile are
     for B's and B's and they are typical and these standards
     clearly state that you can follow them, they are typical, or
     you can have plant specific.
               My experience tells me that the industry chose to
     use those profiles.  The profiles were two peak profiles and
     a single peak profile and, again, these profiles were
     provided to us many, many years by manufacturer, vendors,
     and they are typical in nature.
               This is a two-peak LOCA profile and it's
     definitely more conservative compared to a single peak.
               Now, again, some manufacturers chose to qualify
     their cables to two-peak rather than one peak and NRC
     accepted both.
               DR. WALLIS:  You test in water.  Are you going to
     get to that?
               DR. AGGARWAL:  Yes, sir.
               DR. WALLIS:  Are you going to say what the water
               DR. AGGARWAL:  Yes.
               DR. WALLIS:  Because there are all kinds of water.
               DR. AGGARWAL:  Then there are certain tests which
     are called post-LOCA testing.  What we are doing here, we
     take the sample, which has come out of the LOCA test, after
     doing some condition monitoring and so on, we apply what we
     call the strain test.  The cables are now submerged in
               This is a requirement of IEEE 383.1974 that these
     cables must meet this requirement.  The water is ordinary
     tap water and it the cable is somewhat into it and we apply
     80 volt per mil.  Usually insulation is 30, so you see about
     24 on the board.
               Now, note it is not always necessary that cable
     will fail at 2,400 volts.  It can fail at any intermediate
               Any failure which cable, if it fails to withstand
     water 2,400 or lower will be considered as failed.
               DR. WALLIS:  There's nothing about the chemistry
     of the water.  It's just some sort of tap water.
               DR. AGGARWAL:  It is tap water.  This is what is
     required under the standard and this is how the industry has
               DR. WALLIS:  We don't have tap water in
     containment after a LOCA.
               DR. AGGARWAL:  True.  That's very much true, but,
     again, we are just meeting acceptance criteria in the 1970
     timeframe and -- I'm just telling you what industry doing or
     what we have done.
               DR. SHACK:  Again, so you're not irradiating the
     cables.  You're simulating all the damage by some sort of
     aggressive thermal history.  Is that the idea?
               DR. AGGARWAL:  No, we are putting radiation doses,
     too, as a part of the pre-aging.  We go through the sequence
     of thermal aging and then the normal radiation and then the
     accident radiation.
               DR. APOSTOLAKIS:  So the normal radiation you use
     some kind of a law like the Arrhenius law again to determine
     the time?
               DR. AGGARWAL:  Generally, as I said earlier, the
     industry came and 50 mega rad was considered to be standard
     number that the industry has used, not only in this country,
     but throughout the world, for qualification.
               One may argue, and that is my next point, people
     have argued that these tests are too conservative and I want
     to present my personal point of view, not NRC staff point of
     view, my personal point of view are these tests are really
               The first point is that pre-aging environment,
     which we are preconditioning the cables to, as I told you
     earlier, you take the activation energy, the Arrhenius
     theory tells you so many hours equivalent.
               DR. APOSTOLAKIS:  But that's for temperature.
               DR. AGGARWAL:  That's the temperature, the time.
               DR. APOSTOLAKIS:  Not for radiation.
               DR. AGGARWAL:  No.
               DR. APOSTOLAKIS:  Okay.
               DR. AGGARWAL:  So now people say, well, in a
     nuclear power plant, you never see those conditions.  All
     right.  Sitting here, I don't know any better matter to
     bring a cable to the end of condition 40 years life.  Only
     thing I know of the limitation, the Arrhenius theory, and
     this is what we do --
               DR. APOSTOLAKIS:  I don't understand this.  You
     never see what conditions?  The temperatures that you are --
     that is not the idea of an accelerator test.
               DR. AGGARWAL:  The idea of accelerator test is to
     bring the cable to the end of condition.
               DR. APOSTOLAKIS:  Right.
               DR. AGGARWAL:  Forty year.  What industry argued
     is that the tests are unrealistic.  In real life, cable
     never sees these kind of temperatures and the point I am
     making there, the only criteria in the consensus standard
     was to bring the cable to the end of life, 40 years, and
     they came with a number.
               Bottom line, I'm saying, in my opinion, those
     numbers are not very conservative.
               DR. APOSTOLAKIS:  So if we put it in a different
     way, the argument is that if you have a cable subjected to
     temperature T-1 for 40 years and then you have an
     accelerated burst at a higher temperature for 260 hours, the
     result of the test, the damage to the cable is not the same
     as you would get for T-1 for 40 years.
               DR. AGGARWAL:  Some people argue.  Let me make
     another --
               DR. APOSTOLAKIS:  Is there any basis for that?
               DR. AGGARWAL:  Yes.  Another argument -- may I put
     -- from the industry's point of view, in my 30 years in EQ
     at NR, what I found, any failure in the EQ area can always
     be explained and you can declare victory.
               I have not found, it is not because of requirement
     are not very clear, explicit, they require single prototype
     be tested.
     If it fails, the staff didn't know.  Industry is not
     required to report, but declare cables are qualified and
     they are there in the plant.
               DR. WALLIS:  Can you tell me more about this
     accelerated test?  You don't have to just do it at T-1 for N
     hours.  You can do it at a lot of temperatures for a lot of
     different times and show that this fits on a curve and it's
     all -- that, therefore, your theory is kind of valid.  You
     don't just do one test.
               Isn't that done?
               DR. AGGARWAL:  No.
               DR. SHACK:  Was it done once upon a time?
               DR. APOSTOLAKIS:  Well, when Arrhenius proposed
     the law, I guess he did it.
               DR. SHACK:  That's a long time ago.
               DR. APOSTOLAKIS:  It was a long time ago.
               DR. SHACK:  I mean, for the particular cable, I
     presume that somebody did a test over a range of
     temperatures and demonstrated a kind of linear behavior.
               DR. AGGARWAL:  No.  They used the activation
     energy and the Arrhenius theory and came up with a number.
               MR. MAYFIELD:  This is Mike Mayfield, from the
     staff.  If you go back into the polymer science, you'll find
     that that kind of work has been done and the Arrhenius
     applies for it, just like it does in metallurgy, as long as
     you stay within the same degradation mechanism.  If you go
     high enough in temperature, the mechanism changes, the whole
     thing is over.
               From the test reports I've seen that we've
     acquired, when they qualified a cable, they did not run at a
     series of temperatures.  They set out to qualify it for a
     set of conditions where you could operate the cable
     ostensibly at this set of conditions for 40 years and the
     tests were run to qualify the cable to operate at those
               There weren't a series of tests run, but this --
     now we're talking about the practical implementation of a
     piece of science.  The series of temperatures, that type of
     work was done in the research labs effort the standard was
               So there is science that says as long as the
     degradation mechanism doesn't change, this methodology
               DR. SHACK:  But, I mean, you've established that
     the range we're extrapolating over is within the range that
     people had demonstrated.
               MR. MAYFIELD:  Yes.  Now, there's been subsequent
     work done at Sandia looking at -- because some of the
     polymers exhibit, which called non-Arrhenius behavior, and
     Ken Gillen out there at Sandia has done some work looking at
     why that occurs, when it occurs, and how to predict it.
               And for the work we have here, we didn't feel like
     it was much of an issue, but it's something that is being
     followed up both through the DOE/EPRI NEPO program, as well
     as stuff that we're at least following what's going on.
               So there is continuing work in this area sort of
     at the basic technology.  What we are presenting today is
     the application end of it.  But the underpinning, the
     scientific underpinnings are there.
               It's just they're not -- it's not done for each
     qualification test.
               DR. WALLIS:  Where does the conservative adjective
     come in?  I would think the question is are these realistic
     tests.  What is the difference?
               MR. MAYFIELD:  Well, the concern -- I think your
     characterization is exactly right, Dr. Wallis.
               DR. WALLIS:  Are they realistic tests?
               MR. MAYFIELD:  It's are they realistic versus
     conservative, the argument being that, oh, they're too
     conservative, but then are they realistic, and I think it's
     a fair question.
               The issue was to try and qualify cables within an
     envelope, if you will, for unrestricted use in the nuclear
     power plant.
               DR. WALLIS:  Conservative, to me, would mean that
     you look at the errors in the Arrhenius theory, the
     deviations from it.  You've got some kind of a bounding
     thing because of the uncertainties and then you go to that
     bounding test, and no one has said that anyone has done any
     bounding test.
               It looks as if this is some sort of an average
     realistic type test that's being done.  So we don't know the
     limits in terms of a bounding conservatism.
               DR. AGGARWAL:  That's correct.
               DR. WALLIS:  Maybe the word conservative is
     irrelevant in describing these tests.
     DR. AGGARWAL:  I was just trying to pose -- well, concluding
     that, we do the same task, where I explained to you, that
     some is in the water.
               DR. WALLIS:  And this is just tap water.
               DR. AGGARWAL:  Yes, sir.
               DR. SHACK:  Let me go back just to the question
     again.  Now, we did the pre-aging and then the irradiation. 
     Have people examined the effect of the sequences?
               DR. AGGARWAL:  Yes, sir, they have and there are
     different conclusions.  Incidentally, I've been already
     reminded twice about the time.  Last night I told my wife
     that don't wait for dinner for me.  So I will be here as
     long as you want me.  The pleasure is all yours.
               DR. APOSTOLAKIS:  But we will not.
               MR. MAYFIELD:  Dr. Shack, this is Mike Mayfield,
     from the staff.  The tests done at Sandia, in fact, do
     simultaneous temperature and radiation exposures, but the
     IEEE standard has sequential exposures.
               I guess I personally don't know if someone has
     swapped irradiation versus temperature, but I know that we
     got somewhat different results and I think you'll see some
     of that in the next couple of slides that Satish presents,
     when we do simultaneous thermal and irradiation exposures
     versus sequential.
               The sequential appears to be more severe than the
               DR. UHRIG:  What is the radiation test?  Gamma?
               MR. MAYFIELD:  It's gamma.
               DR. UHRIG:  Is it Cobalt-60?
               MR. MAYFIELD:  Cobalt-60 sources.
               DR. UHRIG:  So it's not the same energy spectrum
     that you might expect in a plant.
               MR. MAYFIELD:  It is not the same energy spectrum. 
     It was a TID source term estimation and they take a
     cumulative gamma dose and irradiate the cables using the
     Cobalt-60 sources.
               DR. WALLIS:  I guess all these questions wouldn't
     be so important except that the failure rates are a
     significant percentage, and therefore, we do have to worry
     about the meaningfulness of the test.
               DR. AGGARWAL:  Bill, to your question, I just want
     to add that in certain part of the world, for certain type
     of insulation, they have found that if you do the radiation
     first, and thermal things later, it's more conservative for
     some type of insulation, not all, and it is consistent with
     the conclusion what Sandia reached some time ago.
               And, incidentally, I may also point out, in this
     program, we have produced that many reports which have been
     circulated around the industry and public for their comments
     and their input will all be incorporated.
               Now, I would like to move on to page 3.
               DR. WALLIS:  I'm sorry.  This temperature test is
     uniform temperature?
               DR. AGGARWAL:  Yes, sir.
               DR. WALLIS:  Are these cables carrying current? 
     They're not subjected to --
               DR. AGGARWAL:  Yes, sir.  They are energized in
     the nuclear power plant.
               DR. WALLIS:  They just set an environmental
     temperature.  There's no heating because of the current in
     the cable.
               DR. AGGARWAL:  Right.
               DR. WALLIS:  Is that right?
               DR. AGGARWAL:  The temperatures, we tried to
     maintain, what we came out, we are not giving any kind of
     credit for the heating created by the current going through
     the cable, because these are very small cables.
               All we have a very limited current.  So really
     there's not a heck of a lot of current.
               DR. WALLIS:  Right, as long as someone has
     assessed it.
               DR. AGGARWAL:  Yes.  Well, we have taken those
     temperatures which the manufacturers had taken.  We did not
     make an attempt how --
     DR. WALLIS:  It's just if you have a lot of cables bundled
     up in a tray and they're all generating small amounts of
     heat, it might affect the temperature in a way which isn't
     just the environmental temperature.
               DR. AGGARWAL:  You're right, but again, normally,
     on a controlled cable, you only allow 60 percent and there's
     plenty of space and these cables are hardly getting any
     current.  They are control and indication type cables.
               In this, all I want to tell you, if you go to the
     bottom line, you will note this is what they found in
     Sandia, two out of five fail in the 20 year, one out of
     eight fail in 40 years, and five out of 11 fail, then we are
     talking about 60 years
               DR. WALLIS:  Show us on the table where those are?
               MR. SIEBER:  The two and five are -- two failures
     and five -- what is the category here, marginal criteria?
               DR. AGGARWAL:  Right.
               MR. SIEBER:  A and B, down here at the bottom.
               DR. UHRIG:  You had two failures and five marginal
     is what that means.
               MR. SIEBER:  Out of 39.
               MR. LOFARO:  So seven had a problem out of the 39.
               DR. UHRIG:  Seven out of the 39.
               MR. LOFARO:  Two of them were failures and five
     were just marginal.
               DR. WALLIS:  So two failed in that 20 years and
     one failed in 40 years.  So one that was failed recovered.
               DR. AGGARWAL:  It's a separate --
               DR. WALLIS:  I know it's a different test, but if
     you think it's meaningful, that would look as if one
               DR. UHRIG:  It's within the error of the
               DR. WALLIS:  But then it seems a very small number
     to rely on, doesn't it?  If there is that sort of behavior.
               DR. AGGARWAL:  Well, it all depends, again, how
     you define your acceptance criteria.
               DR. WALLIS:  I'm not defining anything.  I'm
     asking, really.
               DR. AGGARWAL:  In that particular test, the
     criteria was that if you have higher value, they're lower,
     or you blew a one-amp fuse, then it would be considered a
     failure or marginal.
               DR. WALLIS:  But if I drew a curve of sort of
     failure rate versus time and I had tow and then one and then
     five, with these numbers, I wouldn't have much reliance on
     the meaningfulness of the result, would I?  Very small
     sample size and not even consistent with the trend.
               DR. AGGARWAL:  You're right.  You're right.  And,
     again, we --
               DR. WALLIS:  So who decided these were adequate
               DR. AGGARWAL:  Who decided?  They came out of the
     IEEE Standard 323, which is a national consensus standard. 
     This is what EQ experts are telling is the right thing to
               DR. APOSTOLAKIS:  Do they specify the size of the
               DR. AGGARWAL:  They don't talk, but it's implicit
     that you take -- well, let me rephrase it.  There's no
     explicit statement in the standard what industry have done,
     they test one sample and if that passes, you declare
               DR. WALLIS:  And if it doesn't?
               DR. AGGARWAL:  You test again.
               DR. APOSTOLAKIS:  We should risk-inform that.
               DR. AGGARWAL:  That is one of the concerns we
     have, whether we should be doing.
               DR. UHRIG:  That's what the manufacturer does. 
     That's not what you did here.
               DR. AGGARWAL:  We reported what we found.
               DR. UHRIG:  You had about ten kinds of cables
               DR. AGGARWAL:  Right.
               DR. UHRIG:  And I notice you had five specimens,
     some you had two.  Was there --
               MR. SIEBER:  Some you had one, the Anaconda.
               DR. POWERS:  Yes.  And the question is how was
     that number determined.  On the basis of the amount of that
     cable that was used?
               DR. AGGARWAL:  Not really.  The number of the
     cable size, then we had -- This will go, again, a little
     more in detail.  Some of the cables were around the
     mandrill.  Some were in the tray.  And it's different --
               DR. WALLIS:  But does the failure rate depend on
     how long the cable is?  Is there one-inch cable or one-meter
     cable and they're looked at the same way?
               DR. AGGARWAL:  I believe you use a ten-foot long
               DR. WALLIS:  The whole thing seems somewhat
               DR. UHRIG:  It also looks like certain cables,
     like Anaconda, unbounded very well in this first test.
               DR. AGGARWAL:  Right.
               DR. UHRIG:  And on the other hand, it didn't do
     very well over in the 40-year test on the second page.
               DR. AGGARWAL:  Correct.  The second page you are
     looking at are the tasks which we did at Wylie Testing Lab.
               DR. UHRIG:  It says Brookhaven here.
               DR. AGGARWAL:  Yes.  Brookhaven don't have the
     lab, the testing.  They're actually Wylie Lab.
               DR. UHRIG:  So Brookhaven supervised it.
               DR. AGGARWAL:  Right.  They have a contract on
     this program.  If I turn over to the next slide, again, this
     is a summary of six tests which we did.  And you see the
     results.  And I will be willing to answer your questions and
     explain to you what those failures were
               DR. WALLIS:  Tell me.  If you do five feet of one
     foot of cable, is that different from doing one length of
     five foot of cable?  What's the difference?  So why is it
     five tests?
               MR. LOFARO:  What we did in the test program is we
     used links of cable as recommended in the IEEE standard,
     which is they suggest you use about ten feet so you get the
     proper effect.
               Obviously, if you took one foot of cable, you
     might miss something.  So you want to take a sample that's
     at least representative of what the cable might actually see
     in the plant.
               DR. WALLIS:  So they do specify a length.
               MR. LOFARO:  They recommend a length of about 10
     feet, and that's what we use in our program.  And what they
     do is our program we actually wrap it around the mandrill,
     so that there was a good ground plane.
               DR. WALLIS:  These five samples are put in the
     same testing apparatus or they're tested at different times?
               MR. SIEBER:  They were all tested exactly the same
     time.  What we did is --
               DR. WALLIS:  So if I had 50 feet of cable, it
     would be like having five pieces of ten foot.
               DR. AGGARWAL:  Right.
               DR. WALLIS:  Because they all put through the same
               DR. POWERS:  They are all put through the same
               MR. PIETRANGELO:  They go the
               DR. AGGARWAL:  Right.  They go through the same
               MR. LOFARO:  Well, what we wanted to do is we
     wanted to have multiple samples in there so that we could do
     some -- have some statistical accuracy on the samples.  We
     put control sin there that did not get aged.  We also put
     samples in there that were pre-aged to different years. 
     Some tests were 20 years, some tests --
               DR. WALLIS:  I'm sorry.  The cable, the ten-foot
     cable fails, does it fail in one place or in many places or
     all over?
               MR. LOFARO:  Well, that's one of the things that
     we were looking for and what we actually found is that some
     of the cables had a global degradation.  For example, the
     Okonites I think that will be touched on.
               We found some cables that only failed locally,
     where most of the cable was in excellent shape, but when we
     subjected it to a subjected it to a submerged high pot test,
     there were single point failures in the cable.
               So it depends on the type of cable you're looking
     at and the materials they're constructed of and what
     conditions they're exposed to.
               DR. WALLIS:  But you never seem to get five out of
     view.  Still, if you put these links in and one survives and
     the others don't.
               MR. LOFARO:  If we had a case where there were
     five out of five failures, I think that would clearly point
     to a problem.
     DR. WALLIS:  I'm just kind of surprised that you'd take five
     lengths of identical cable and do exactly the same test,
     you'd think that in many of these tests, you either get the
     all pass or they fail.
               You wouldn't get many cases where one fails and
     the others don't.
               MR. LOFARO:  Well, unless they're reaching a point
     where the degradation is just borderline.  Maybe there's a
     problem, maybe there's not.
               DR. APOSTOLAKIS:  That means you have alliatory
     uncertainty.  That's exactly what you have.
     DR. AGGARWAL:  I think it's very difficult to predict how
     many will pass or not.  For example, Okanite cable, three
     sampled or three failed out of three.
               DR. WALLIS:  But these cables are sort of
     identical.  The manufacturer --
               DR. AGGARWAL:  Yes.  They are coming out of the
     same reel.  Mike wants to add something.
               MR. MAYFIELD:  I was just going to reiterate
     something that I guess Satish had said earlier and ask you
     to please keep in mind the qualifications standard is based
     on one successful prototype test.  The issue that we were
     addressing with these cables is, is that realistic.  If you,
     in fact, test more than one sample, do you get all passes.
               The notion that one prototype are ten foot length,
     nominally, tested and successfully passes the IEEE test
     qualifies all cable of that particular type is one of the
     things we were challenging through this research.
               So whether we got all passes or all fails, and,
     Dr. Wallis, I think you talked earlier about are the tests
     conservative or are they realistic, the part of the notion
     is to put the cables through their original qualification
     and with multiple samples, whether it's three or five, to
     determine whether or not this notion that qualify one sample
     and, therefore, all cables are qualified, is that really a
     legitimate notion.
               And I think at least these test results raise some
     questions about that and it's a dialogue that we will
     continue to have with IEEE.
               DR. WALLIS:  It may well be that to answer the
     question, you need to test 100 of them.
               MR. MAYFIELD:  That's the question, is how large
     would the sample have to be.  Conversely, do you accept the
     notion that this qualification standard doesn't get you to
     all cables pass and, therefore, you test perhaps more than
     one and then try and establish some failure frequency.
               DR. WALLIS:  Don't you have just experimental
     theory that you're relying on to reach conclusions here?
               MR. MAYFIELD:  Say again, please, sir.
               DR. WALLIS:  Don't you have some kind of a
     theoretical background about failures and statistics which
     tells you whether or not this is a significant experiment,
     what it means?  I mean, this is a well worked area of
     planning experiments and deducing things, making conclusions
     when there are random variables.
               DR. AGGARWAL:  I'm aware, in Sweden, they use some
     statistics and they came out with a sample size of ten, but
     in U.S. it is one.
               I think, as I recall, in that time arena, what
     IEEE was worrying about, that if you do ten samples, or
     hundred, for that matter, and they argued that nine out of
     ten pass or 95 of 100 pass, do you declare victory or you
     don't.  And there were no criteria for them.  So they
     decided you just do the one test and the sense of the
     standard now and with the whole work to do that.
               Now, we can debate the numbers and --
               DR. WALLIS:  Well, victory should be based on some
               DR. AGGARWAL:  When we look back now and think,
     you're right.
               MR. MAYFIELD:  Again, Professor Wallis, our
     objective here was to challenge what was being done and to
     see if it seemed to hold together.  I believe the test
     results here suggest there are some concerns.  I think the
     kinds of things you're raising, we agree with you.  We're
     not here to try and defend the standard, simply to report
     this is what we followed and it seems to be raising some
               DR. AGGARWAL:  If I might turn to the next
     viewgraph and give you some basic data out of the operating
     experience.  This is an EPRI report, July 1994, where they
     collected some data from '68 to '92, and they found there
     was 87 events which identified degradation of in-containment
               We know that we have problem with the splices at
     operating power plants.  We also know that in our test, we
     had the problem with splices in all the tests, test number
     one, two and three.
               Two passed without a problem, but first and three,
     they said there was a moisture intrusion.
               DR. WALLIS:  Where did the moisture come from?
               DR. AGGARWAL:  Steam.
               DR. WALLIS:  There's a steam environment?
               DR. AGGARWAL:  Yes.  It's a LOCA test.
               DR. WALLIS:  It's a LOCA test.  I'm sorry.  They
     had actually had LOCA in operating experience?
               MR. SIEBER:  No, they tested it.
               DR. AGGARWAL:  I'm just making two points.  One
     was that there had been a problem --
               DR. WALLIS:  This is to support an LER, so it
     can't be a LOCA test.
               DR. AGGARWAL:  No, no.  Two points.  There are
     real life problems.
               DR. WALLIS:  But you said moisture intrusion in an
     LER.  So the moisture came from somewhere --
               DR. AGGARWAL:  No, I jumped a gear.
               DR. WALLIS:  I'm sorry.
               DR. AGGARWAL:  I think went to the second point to
     make, that in our test, we also found problems with the
     splices and there we have the LOCA.
               DR. UHRIG:  But you also have problems with
     splices at the operating plants.
               DR. AGGARWAL:  That's right.  That is the point
     I'm making.
               DR. UHRIG:  There was not a moisture problem
               DR. AGGARWAL:  No.
               DR. UHRIG:  That's probably a faulty splice.
               DR. AGGARWAL:  One of the reasons.  But you know
     when many of the LER do not go to root cause analysis and
     tell you what really happened. But I know on a personal
     experience that you ever try to splice cracked jackets,
     splice it, you'll never succeed.
               MR. CALVO:  Jose Calvo, from the NRR staff.  The
     problem that we found with the splices in the operating
     plants was just the way they was done, in the installation. 
     The procedures was not followed, they didn't make it long
               Sometimes moisture was found in the terminal boxes
     and things like that.
               I think it was mostly installation, they didn't
     follow procedures and I guess the same question was raised
     when we were doing this test with Research and maybe the way
     the splice was put together, it was not appropriate and
     that's why the issue of failures.
               MR. LEITCH:  How were the 87 events identified? 
     Is that 87 LERs or how did they come up with the conclusion
     that there were 87 events?
               DR. AGGARWAL:  This is a proprietary report of
     EPRI, which I cannot really go more in detail.  But the
     conclusion, it is reasonable to conclude that those 87
     events were independent events in different nuclear power
     plants over the period.
               MR. LEITCH:  I would think there could be a
     considerably larger number.
               DR. AGGARWAL:  Again, everyone is not reported. 
     You have in a plant, an MOV fails.  What do you do?  You go
     there, you look at the cable, and you see, well, it doesn't
     look very good, you disconnect the cable, put a new cable
     and connect it up.
               Do you report it to NRC as related?  No.
               MR. LEITCH:  That's my point.  There could be many
     more than 87.
               DR. AGGARWAL:  Exactly.  Exactly.  In the LER and
     the NPRDS data, we also found that there were specific
     problems with the neutron monitoring systems and failures
     were due to high temperature and moisture intrusion.
               DR. WALLIS:  Where did the moisture come from?
               DR. AGGARWAL:  In an operating plant, you might
     have --
               DR. WALLIS:  Are these outdoor plants?
               MR. SIEBER:  It's in containment.
               DR. AGGARWAL:  It's in containment.
               MR. SIEBER:  If you get a little leak someplace,
     humidity goes to 100 percent and --
               DR. WALLIS:  So these are associated with some
     other event, like a leak.
               DR. AGGARWAL:  Right.
               DR. UHRIG:  Why was the neutron detecting cable so
               DR. AGGARWAL:  Radiation.
               DR. UHRIG:  Neutron monitoring cable.
               DR. AGGARWAL:  Radiation.  And as I was talking to
     you earlier today, my basic concern is every plant had hot
               DR. UHRIG:  Right.
               DR. AGGARWAL:  And my concern is do the plants
     really know where their hot spots are, are they really
     monitoring those environments, are they really doing
     something, I have no idea.
               Then we talked to the industry informally, they
     say, yeah, many utilities do, but are they all doing, I
     cannot answer that question.
               MR. SIEBER:  I don't think that you survey to find
     every place where there is a neutron beam.  A lot of times a
     cable would fail on a power range monitor at the connector.
               DR. AGGARWAL:  Right.
               MR. SIEBER:  Because it's exposed there and it's
     in a pretty high neutron flux.  Find the same things on the
     top of the reactor head and a lot of utilities will end up
     shortening and shortening and shortening the cable until
     they run out of cable because it ages right where the
     connector is.
               DR. AGGARWAL:  And they made choose to make a
     splice there.
               MR. SIEBER:  Well, other ones may have.  Splices
     are more trouble than you can imagine.
               DR. AGGARWAL:  I would like now to turn over the
     rest to Mark.  The only point I want to make, that cable
     aging can be this significant and let the expert take over.
               MR. CUNNINGHAM:  Thank you, Satish.  I've got a
     couple of slides to talk about the context of what the
     implications are of aging I&C cables might be to risk
               Over the years, there's been about three studies
     done, risk studies done to look at this issue.  All of them
     have really been in the form of sensitivity studies, because
     you get to -- basically, get to a -- you require a level of
     information to go beyond the sensitivity study, which we
     just don't have.
               We don't have the information to work with.  These
     studies have generally shown that the risk of aging I&C
     cables could be significant under a certain set of
               The studies looked at basically a spectrum of pipe
     breaks or LOCAs in the containment and tried to deal with
     the fact that the LOCAs would create an environment, a hot
     spot, if you will, either very locally in a small break or
     very broadly in a large break that could compromise these
     cables, as we've seen.
               Then the question becomes, well, if the cables
     fail, what does that do to the function that's associated
     with those cables or does it give a set of indications to
     the operator that could mislead or confuse them.
               So the cable failures, either the gross cable
     failures or the leakage types of failures have the potential
     to certainly complicate the accident or remove equipment,
     make equipment unavailable, or to confuse the operators.
               To go beyond anything like kind of a general
     sensitivity study, that you need a fair amount of
     information that we don't have, and that's kind of itemized
     on slide seven.
               In the context of the cables themselves, you need
     to have a sense of what types of cables are associated with
     what types of equipment in the containment and what are the
     more critical pieces of equipment in the containment.  You
     also need to have a sense of the extent of aging of those
     cables, those particular cables and then relate that to the
     cables and the location of the cables to the potential
               Again, the offer of what's the relationship
     between the hot spot from a pipe break or something like
     that with a cable of a certain type for an important piece
     of equipment.  The other part of that is given these types
     of things, how would the operators respond.  Do partial
     failures of cables cause more problems than complete
     failures and that sort of thing.
               So the risk study in this case is, in one sense,
     simple.  It could be important.  We don't have enough
     information on the details of where the cables are and the
     functions and the types of cables and that sort of thing to
     take it much more than saying it could be.
               DR. WALLIS:  You're saying this is what you would
     have to do if you were to do a risk assessment, but
     essentially a risk assessment has not been done.
               MR. CUNNINGHAM:  A risk assessment has been only
     done in a very general sense, gross sense, that's right.
               DR. UHRIG:  So one of the considerations you have
     under study is to seek this information from the utilities.
               MR. CUNNINGHAM:  That comes back to Mike's
     discussion earlier of the options for pursuing this generic
               DR. UHRIG:  This is one of the options then.
               MR. CUNNINGHAM:  That's one of the things we talk
     about, yes, is trying to obtain this information from
               MR. LEITCH:  Would you expect that BWRs would be
     significantly different than PWRs in this case?  I'm
     thinking about under the bottom hood of the BWR, there's
     just a real rat's nest of cables under there.
               MR. CUNNINGHAM:  I couldn't tell you whether that
     would be more important or not.
               MR. MAYFIELD:  One of the scoping studies looked
     at BWR versus PWR and the B's came in somewhat lower, but,
     again, it went to -- I wouldn't want to put a lot of
     credibility in the number simply because of the level of
     uncertainty and the level of information we don't have to do
               But they weren't -- it wasn't night and day, but
     the B came in lower than the P.
               DR. UHRIG:  What about international studies, what
     else is going on?  I remember hearing a report about five or
     six years ago on some work in Sweden, I believe it was.  A,
     do you have access to it, and, B, is it comparable results?
               MR. MAYFIELD:  We have had and continue to have
     dialogue with the international community.  There was work
     in Sweden.  In fact, we had talked with the plant manager
     from Oskarshamn about the possibility of getting -- they
     re-cabled the plant when they basically rebuilt it.
               We've had some dialogue with them about trying to
     get aged cable samples for testing.  We've had dialogue with
     the Germans, fairly active dialogue with the Germans, as
     well as with the French.  The Japanese have ongoing programs
     and we've had some dialogue with them.  
               I think, in general, the observations are
     consistent.  I wouldn't want to say that there have been
     strict comparison tests.
               There was a coordinated research program with IAEA
     that Bob Lofaro was involved in looking at this.  So there's
     been a fair bit of international dialogue.  The staff does
     have access to, I guess, most of that information.
               DR. UHRIG:  Are they carrying out any of the kind
     of analysis that you would -- a risk analysis for which this
     type of data would be sought?
               MR. MAYFIELD:  I guess that I don't know.  I'm not
     aware of any of those studies, unless Mark is.
               DR. AGGARWAL:  If I may, different country have
     different approaches.  When you look at Germans, they don't
     go in PRA.  What they do, they put sample, what they call
     cable deposits, and then they do the testing every five
     years and then they determine whether they have level of
     confidence or not.
               When you talk to the French, their LOCA profiles
     are somewhat lower than ours and they qualify the cable
     using IEEE standard.
               Sweden, we have all the reports you describe in
     our office here and we have looked at them.  We have visited
     Sweden several times and our conclusion is theirs are
     totally consistent with ours.
               IAEA program, which Mike just mentioned, they are
     coming out with a guidance document, a guide and the
     recommendation is this is the international feeling that
     these cables you qualify one time, you simply can't walk
     away from these cables and do nothing.  They want to see
     some kind of condition monitoring be done.
               IAEA is going to come soon, the guide will be
     printed there recommending condition monitoring in certain
               DR. UHRIG:  And yet we have 70 percent of our
     plants grandfathered to where no additional monitoring or
     any additional work is being done.
               DR. AGGARWAL:  Actually, 100 percent plants are of
     that view.  We do not require any kind of monitoring.  If
     you turn over to my next slide --
               MR. MAYFIELD:  If I could -- I want to come to
     that.  It gets to be an important distinction, I think,
     between what we require versus what the industry may or may
     not be doing.
               DR. UHRIG:  Some of them are doing something and
     some are not.
               MR. MAYFIELD:  I think that's an important
     distinction.  We are not in a position today to tell you
     exactly what they are or are not doing.  We know that some
     have aging management programs, if, for no other reason or
     for no other examples than the Calvert Cliffs and Oconee
     plants in their license renewal applications.
               So we know that there are programs in the
     industry.  We can't tell you definitively how widespread
     they are or how effective they are, but I would not want to
     leave the committee or the public with the impression that
     nothing else is being done just because it's not required.
               DR. UHRIG:  But you do have resident inspectors in
     every one of the plants.
               MR. MAYFIELD:  Yes, sir.
               DR. UHRIG:  Do they undertake to report this type
     of thing?
               MR. MAYFIELD:  No, they do not.
               DR. UHRIG:  They do not.
               MR. MAYFIELD:  It's not part of their regular
     inspection program.
               DR. UHRIG:  It's not part of their responsibility.
               MR. MAYFIELD:  No, sir.
               DR. POWERS:  Can we come back to the risk
     significance?  Give me a feel for what happens in a sequence
     where instrument aging becomes -- loss of instrumentation
     becomes important?  I can imagine it in a long-term station
     blackout for a boiler.  What PWR sequences get me in trouble
               MR. CUNNINGHAM:  You can take -- I guess I'd start
     with LOCAs, LOCAs where you have some -- if you have some
     unfortunate interplay between the location of the pipe
     break, the type of cable that might be in that vicinity, and
     the function that that cable is associated with, that if you
     could first compromise the function by not causing actuation
     or something like that.
               DR. POWERS:  Sure, I understand.  But what am I
     trying to actuate?
               MR. CUNNINGHAM:  Again, it depends on the
     different types of plants, what type of equipment could be
     important, but, again, small LOCAs, you'd be interested in
     the relationship of cables that might actuate high pressure
     injection, for example, or perhaps, more importantly, cause
     signals to either the automatic signals or the signals in
     the control room on that equipment to be either wrong or
     confusing or that sort of thing.
               MR. SIEBER:  But the valves and the pumps are in
     the aux building.
               MR. CUNNINGHAM:  Yes.
               MR. SIEBER:  What you're really trying to do is
     trip the plant right away and usually you can see that on a
     loss of pressure before the containment environment gets so
     bad that it will wipe out the cables.  Then the other thing
     you have is you get a phase A and B containment isolation,
     and almost all the isolation valves are air operated valves
     with solenoids, but they fail closed if it were to short out
     or the fuse would blow.
               But you're talking a hundred of those that have to
     operate probably.  And beyond that, everything else is
     outside containment, except you probably -- if everything
     went, you couldn't monitor pressurizer level, pressurizer
     pressure, reactor pressure, steam generator levels.
               You would be able to monitor pressure because the
     isolation valve for the steam generators is outside
               DR. POWERS:  What you are concerned about is an
     increasing fraction of accidents ordinarily terminated
     benignly that go on to core melt, is what you're concerned
               MR. CUNNINGHAM:  That's right.  That's right.
               MR. DUDLEY:  This is Noel Dudley.  Just to put it
     in another perspective, each step in your emergency
     operating plan is based on an indication, it's better
     supplied by one of these cables.
               MR. SIEBER:  That's right.  It's either a go or a
     no-go to the next step.
               DR. WALLIS:  So something like pressurizer level,
     if it was malfunctioning, gave a wrong indication, might
     really upset the operator's response.
               DR. AGGARWAL:  Yes, that's correct.
               MR. CUNNINGHAM:  Either change it or delay it or
     something like that, and that's a big aspect of the risk
     part of it that we don't have a good handle for.
               MR. SIEBER:  But that's practiced in the simulator
     a lot.  That's part of operator training to simulate failed
     instrumentation and have the operator detect it and decide
     what to do.  You've got several different level instruments.
               MR. CUNNINGHAM:  Just to be clear, we're not
     suggesting that this is a risk issue.  We're saying it could
     be under a certain set of conditions.
               MR. SIEBER:  That would be hard.
               MR. CUNNINGHAM:  We're kind of caught and not able
     to go much further without a substantial increase in the
     amount of information that we have.
               DR. POWERS:  It's not going to increase the number
     of initiators and it's not going to change those accidents
     that we think go to core melt now, which is increasing the
     number, the sequences to go to core melt, that's all.
               MR. SIEBER:  A homemade success path.
               DR. POWERS:  Yes.
               MR. HACKETT:  Let's go ahead and see if we can
     move to our summary here, of what is obviously not the
     prettiest of stories, let's say.  I think that's been
     covered in significant depth here on some of the points Dr.
     Wallis made and I think they're very well taken and there's
     going to be more work to be done, suffice it to say.
               But I think the first bullet we really covered,
     the regulations, as Dr. Aggarwal emphasized, don't require
     periodic inspection or monitoring and in some cases, we
     could get into a discussion of that being problematic, given
     access and so on and some of the techniques that are
     available, maybe push the state-of-the-art.
               But there are periodic spec surveillance tests
     that do evaluate operability that these systems are
     energized, but, of course, they're not of the capability to
     evaluate aging and the degraded state of the cables and any
     pending failures that might result.
               The operating experience that Dr. Aggarwal
     summarized does indicate some service-induced degradation
     that was attributable to the elevated temperature conditions
     and some moisture intrusion, but I think, also, as was
     pointed out, I'm sure there are plenty of other conditions
     that were not captured here.
               In addition, there are things, cable failures
     related to other than specifically aging degradation.
               Maybe the most important point so far is that the
     -- and I think Mike Mayfield summarized this pretty well. 
     The research results from both Sandia and Brookhaven and
     Wylie, which are separated by at least five or six years,
     and maybe emphasize some slightly different aspects of the
     qualification, both show that not all these cable types
     would do this qualified life type of function, even for 40
     years, considering a LOCA.
               And at 60 years, this becomes more problematic,
     but, again, this is assuming that you're operating these
     things at the rated temperatures.
               The caveat at the bottom says, of course, that the
     realistic conditions are in-plant service generally less
     severe than the parameters used for these qualifications.
               DR. WALLIS:  How about 20 years?  You said 40 and
     60, but I thought many of your significant number failed in
     the 20-year.
               MR. HACKETT:  That's a good point.
               DR. WALLIS:  That's before license renewal.
               MR. HACKETT:  That's correct.  I guess we're
     jumping ahead a bit.  There's at least one of the summary
     pieces here that covers that.
               DR. WALLIS:  Okay.
               MR. HACKETT:  The next slide, Mark, again, just
     summarized pretty well.  The risk studies can give you
     relatively high CDF values, again, conditioned on some of
     these situations, are all the cables failed during a LOCA.
               The bottom line is I think we're in need of
     further research data to support a sufficiently low failure
     rate or to get the CDF values to an acceptably low level.
               We are planning currently on Mark's branch doing
     some work in this area over the next year or two and we have
     budgeted for that in our budget cycle.
               The risk studies, Mark, again, emphasized, are not
     as definitive because of lack of detailed information.  One
     of the things that was discussed is that may be one of our
     -- at least one of the options under consideration by the
     NRC staff is to -- how to go about obtaining that
     information, if it's decided that that's needed to be done. 
     That's one of the issues under consideration.
               More data is obviously needed to really more
     carefully define the risk significance.
     I think it's pretty clear, one of the messages, I think, we
     wanted to leave with the committee, it's pretty clear that
     these research data, at least as limited as they are, as Dr.
     Wallis pointed out, I think this is definitely one of those
     cases and experimental endeavors where you would certainly
     like to have more data, but these LOCA tests are expensive,
     we are resource limited.
               There is certainly a strong indication there that
     something will need to be done for aging management for
     license renewal, some way this particular phenomenon will
     need to be addressed for the license renewal period.
               And at the bottom, that the staff is, at this
     point, still considering resolution options, I think, one of
     which was discussed here for the current license term, but
     the staff has not reached consensus on the resolution
               I guess with that, that summarizes what we had --
     again, as Mike mentioned, when we came down here, we wanted
     to be able to tell you more about this resolution path and
     hopefully we'll be able to be back soon with a story for you
               But at this point in time, that kind of summarizes
     what we had planned to say and be glad to take any
               DR. UHRIG:  What other options are you looking at,
     other than a reporting requirement?
               MR. HACKETT:  Did you want to take a crack at
     that, Mike?
               MR. MAYFIELD:  We literally have been discussing
     things that range from no action, other than supporting what
     would -- what has gone in the license renewal world, up
     through the potential for a rule change to 50.49.
               I would not want to suggest to you that any one of
     those is a favored approach at this point, but it's that
     full range of options that have been being discussed, ways
     to solicit more information, generic communications, all of
     those regulatory devices are being discussed and we are just
     not in a position today to say yes, this is -- even the
     direction we're leaning.
               But virtually all of those options have been
     discussed in one form or another.
               DR. UHRIG:  I gather from reading the document
     here that the Commission has faced this issue in the past
     and backed away from it, in the sense that they did not
     require backfitting.
               MR. MAYFIELD:  They did not require backfitting
     when they imposed 50.49.
               DR. UHRIG:  And the rule came along and they had
     not really imposed and the grandfathered plants.
               MR. MAYFIELD:  And when we saw the data, the
     Sandia data in the early '90s, the information notices went
     out, the staff went to the task action plan.  A number of
     things were evaluated at that point.
               We came to these 43 issues through a series of
     public meetings we held with the industry.  We got a lot of
     additional information from the industry, additional test
     reports that helped us resolve most of those 43 issues.
               We got it down to six that were being addressed
     through the specific research program.
               So as we've laid this information out for the
     industry, they very quickly provided significant additional
     information that we were able to evaluate and resolve most
     of those 43 issues.
               DR. UHRIG:  Could you identify the six issues that
               MR. MAYFIELD:  Not off the top of my head, but I'm
     betting Satish can.
               DR. AGGARWAL:  I can.  Bob, one more point I
     wanted to clarify before I go to the six issues.
               Number one, when we were writing the rule and reg
     guide in 1981-82 timeframe, we did not have any data which
     indicated failure.  The issue before the Commission of
     backfitting was not whether you require condition monitoring
     or not.
               The issue at that time was that in '79 and 1980,
     in response to the Commission memorandum and order, plants
     were required either to meet the guidelines or NUREG-0588
               What the Commission ruled or decided at that time,
     that billions of dollars were spent in qualification, so
     they don't want to go back and ask the operating plants to
     do more requalification based on new requirement.
               But there were no issues at that time that
     condition monitoring required or not required.  When we
     wrote the Reg Guide 1.89, the staff was concerned and we did
     put in our discussion portion that consideration should be
     given for some kind of monitoring, condition monitoring,
     because we cannot really bring any test lab a cable at end
     of life at 40 years.
               So we must do something.  If you read very
     carefully IEEE standard 323.74, it also encourages people to
     do something.  The Commission was informed by a SECY paper
     that the staff feels, at that time, like '97, that we think
     some kind of condition monitoring should be done, and this
     is a part of the SECY paper.
               Now, let me turn over to your question about those
     six issues.
               Ed pointed out to you that we have 43 issues and
     our plan is to look only at the six.
               The first issue we wanted to look at was basically
     a comparison between the accelerated aging techniques and
     also what we find in real life, how these properties
               The staff has concluded that the accelerated aging
     techniques are acceptable.
               Issue number two was the people are using
     different numbers for the activation energy and we want to
     go back and look at what the limitations are, what the
     industry has done is right or wrong.  Our conclusion is
     that, yes, they are using reasonable correct assumptions and
     the staff is satisfied.
               The number three was that do the multiconductor
     cables have different failure mechanisms as compared to
     single failure, single conductor, and if so, what are those
               The staff has concluded that really there is
     nothing that measure, but we have problem with the Okonite
     cable which I told you earlier.  They were bounded cable,
     which was the next item that do they have a failure
     mechanism, bounded cable compared to unbounded cable.
               In multiconductor or single conductor cable, we
     did not find any major concern.  But under the fourth issue,
     we did have the problem with Okonite and we are dealing with
     that problem or rather NRR with industry as to what to do.
               DR. UHRIG:  That's a one-brand problem.
               DR. AGGARWAL:  Right.  We have found the next
     issue is what we looked at or referred to as any condition
     monitoring for determining cable condition, and our
     conclusion is yes, there are several techniques they are
     promising.  They cannot be used for all kind of insulation,
     including visual examination, walk-downs during refueling
     and so on.
               And the last issue was do we know if condition
     monitoring cable, which not only tells you the health of the
     cable, but can it predict whether the cable will survive a
     LOCA, and the answer is we really do not have a definitive
               In a nutshell, we found there were problems with
     one of the cables.  We found problems with the Samuel Moore
     in test No. 4, where two out of three cables failed, 60
     years, pointed out to you several times, almost every cable
     had problem, either low value or simply failed.
               In a nutshell, this is the story.
               MR. HACKETT:  Let me add one clarification, based
     on Dr. Uhrig's question.  Bullet number four, basically, the
     bottom line there is that problem exists with any cable that
     has Hypalon bonded to EPR, or could exist, depending on what
     the aging parameters are.
               So I guess I don't want to leave anyone with the
     misconception that it may be only an Okonite problem.  With
     Hypalon EPR, that specific polymeric combination could lead
     to problems, depending on what the aging parameters are.
               MR. LEITCH:  I'm concerned about the confusion
     that could be caused in an operating environment post-LOCA
     and it seems to -- by misleading or failed cables.
               It seems to me that there is a rather small subset
     of instrumentation in the control room that was especially
     -- that was environmentally qualified, and I'm remembering
     Reg Guide 1.33, I don't know if that's right number or not.
               MR. SIEBER:  1.97.
               MR. LEITCH:  1.97, was it?
               DR. AGGARWAL:  Post accident monitoring.
               MR. LEITCH:  Post-accident monitoring, yes.  It
     would seem to me that that subset of equipment would take a
     higher priority in resolution than some of the other
               MR. SIEBER:  But I don't recall that it had
     anything special in terms of cable.  It had independent
     circuits and independent power supplies and you were able to
     disconnect the control room part of that.  And that goes to
     the shutdown panel and you can control the plant from the
     shutdown panel, but I don't recall anything special about
     the cabling.
               MR. LEITCH:  I'm not saying there's anything
     necessarily special about it, but a failure in that cable
     would be particularly distressing to the operators.  They
     have been trained that that particular subset of
     instrumentation is dependable post-accident.
               DR. AGGARWAL:  Your observation is correct.  In
     the rule, all post-accident monitoring equipment, cables
     included, must be qualified to the requirement.
               MR. SIEBER:  Right.
               DR. AGGARWAL:  Because those instruments are not
     treated safety-related, but the rule require if they are
     variable one and variable two, as defined in the reg guide,
     must be qualified.
               So this is the regulation.
               DR. UHRIG:  Any other questions from members?
               DR. POWERS:  It seems to me one of the issues that
     you need to chase down maybe a little more is the footnote
     on one of your slides that says the service conditions are a
     lot less hazardous, because you are working with an
     Arrhenius expression, which is an exponential expression.
               That could be a very, very significant change. 
     I'm not sure what your activation energies are here.  I
     myself have never been satisfactorily persuaded that
     Arrhenius works that well for low temperatures, but I
     understand the database that exists for polymers here.
               But it seems to me that I would look and see if
     perhaps there may be not too demanding in the aging
     condition that we're presuming takes place at the beginning,
     because I think you've got orders of magnitude there and
     everything else is factors of two.
               DR. WALLIS:  I'm wondering about the real cause of
     failures of cables.  You seem to treat it as a chemical
     phenomenon, but if you take a cable and bend it, put this
     stuff under stress, then that changes the failure mechanism,
     doesn't it?  There are all kinds of things that contribute
     to failure of a cable.
               It's kinked or it's bent or it's under some other
     kind of load or something, as well as the chemistry.
               DR. AGGARWAL:  That is true.  Again, we were not
     trying to reinvent the wheel and find some new mechanism.
               DR. WALLIS:  The real question is when do these
     things fail or might they fail in a real plant, not some
     abstract test somewhere.
               DR. AGGARWAL:  True.
               DR. POWERS:  I mean, what happens in the polymers
     is that you start getting cross-linking and you lose
     plasticizers.  A combination of things makes them --
               MR. SIEBER:  Brittle.
               DR. POWERS:  Brittle, yes.  Real brittle, as a
     matter of fact.  So anything that happens to it subsequently
     cause fractures.
               MR. SIEBER:  In fact, one of the questions I
     wanted to ask is when you wrap the wire around a mandrill to
     test it, it then is subjected to the radiation and the LOCA
     spray, do you unwrap it to do the voltage test?  Because if
     you do, it's going to crack to smithereens.  Or do you test
     it on the mandrill?
               MR. LOFARO:  We tested it on the mandrill.  WE did
     not --
               MR. SIEBER:  So you didn't even get that stress.
               DR. POWERS:  I'm also reminded by Dr. Kress that
     Hypalon evolves hydrochloric acid as it ages, which has its
     own ramifications.
               DR. UHRIG:  Any other comments?  Any from the
     staff?  Industry?
               If not, Mr. Chairman, back you.
               DR. POWERS:  Thank you.  I'm going to recess us
     for ten minutes.  We can bring the transcription to a close
     at this point.
               [Whereupon, at 4:51 p.m., the recorded portion of
     the meeting was concluded.]


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