479th ACRS Meeting - February 2, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Reactor Safeguards
479th Meeting
Docket Number: (not applicable)
Location: Rockville, Maryland
Date: Friday, February 2, 2001
Work Order No.: NRC-005 Pages 241-379
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
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NUCLEAR REGULATORY COMMISSION
+ + + + +
479TH MEETING
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
(ACRS)
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FRIDAY
FEBRUARY 2, 2001
+ + + + +
ROCKVILLE, MARYLAND
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The Advisory Committee met at the Nuclear
Regulatory Commission, Two White Flint North, Room
T2B3, 11545 Rockville Pike, at 8:30 a.m., Dr. George
Apostolakis, Chairman, presiding.
COMMITTEE MEMBERS:
GEORGE APOSTOLAKIS Chairman
MARIO V. BONACA Vice Chairman
THOMAS S. KRESS Member
GRAHAM M. LEITCH Member
DANA A. POWERS Member
ROBERT L. SEALE Member
WILLIAM J. SHACK Member. COMMITTEE MEMBERS: (CONT.)
JOHN D. SIEBER Member
ROBERT E. UHRIG Member
GRAHAM B. WALLIS Member
I-N-D-E-X
AGENDA ITEM PAGE
Introduction . . . . . . . . . . . . . . . . . . 244
Regulatory Effectiveness of the Anticipated. . . 245
Transient Without Scram (ATWS) Rule
Overview of the Mixed Oxide Fuel . . . . . . . . 302
Fabrication Facility
Statement of Chairman Meserve. . . . . . . . . . 348
Adjourn
. P-R-O-C-E-E-D-I-N-G-S
(8:29 a.m.)
CHAIRMAN APOSTOLAKIS: The meeting will
now come to order. This is the second day of the
479th meeting of the Advisory Committee on Reactor
Safeguards.
During today's meeting the Committee will
consider the following: regulatory effectiveness of
the ATWS rule, other view of mixed oxide fuel
fabrication facility, NRC safety research program,
future ACRS activities, report of the planning and
procedure subcommittee, reconciliation of ACRS
comments and recommendations, proposed ACRS reports.
In addition, the Committee will meet with
NRC Chairman Meserve at 1 o'clock to discuss topics of
mutual interest.
This meeting is being conducted in
accordance with the provisions of the Federal Advisory
Committee.
Mr. Sam Duraiswamy is the designated
federal official for the initial portion of this
meeting.
We have received no written comments 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 the speakers use one of the
microphones, identify themselves and speak with
sufficient clarity and volume so that they can be
readily heard.
I would remind the Members that we have
interviews with candidates during lunch time. We also
have cake and coffee for Bob Seale at 12:45 in the
subcommittee room.
MR. SEALE: The rest of you are invited.
(Laughter.)
CHAIRMAN APOSTOLAKIS: Including the
Chairman. And please review the reconciliation items,
No. 14. Each of you must have a copy because we want
to go over it quickly later on.
The first item is regulatory effectiveness
of the ACWS rule.
Doctor Kress, will you lead us through
this?
MR. KRESS: Thank you. If you recall, the
former AEOD part of research has been engaged in the
activity of a retrospective look at some of the
regulations to determine whether they accomplished
what we thought they would and whether the regulatory
analysis process has worked correctly and we
previously reviewed one of these looks. It was the
Station Blackout rule a few months ago. I don't
remember exactly when. This is the second one and the
idea is to look at this and see if it's accomplished
what it intended to and see if the regulatory analysis
was valid and to see if there are any lessons learned.
It sounds like a real good idea to me. So with that
I'll turn it over to Jack Rosenthal.
MR. ROSENTHAL: Thank you. My name is
Jack Rosenthal, Research. And Farouk Eltawila, my
Division Director is also in the room.
I just want to make the point before we
start, although this originally started as an AEOD
activity, one of the -- as a direction setting issue,
it's now been incorporated as an RES function and we
have a regulatory effectiveness team which is looking
at rules and other matters and we intend to continue
looking at rules or regulatory processes at a rate of
about two a year.
Let me say no more. George Lanik is the
team leader of the Reg Effectiveness and Operating
Experience Team. And Bill Raughley who will be the
principal spokesman is also a member of that team.
MR. POWERS: Jack, let me ask you a
question. When you say "team" that seems to hint that
maybe this group of people looking at regulatory
effectiveness comes from organizations other than RES.
Is that a correct assumption?
MR. ROSENTHAL: No. We've just gone to,
instead of sections, where section leaders have
administrative functions, to smaller teams where the
team leaders can spend more of their time on technical
matters and less on administrative matters.
MR. POWERS: I had the sense without
attributing why we got that sense, that maybe the
enthusiasm for the re-examination of these rules like
the ATWS and the Station Blackout is not universally
high with the Agency.
MR. KRESS: No comment?
MR. ROSENTHAL: Actually, I got some good
feedback on the blackout rule. Bruce Boger was one
who, in particular cornered me and said hey, here's a
good example of the Agency being able to be
introspective and examine itself and he wanted to take
credit for it as one of our self-assessments that we
promised to do in the strategic plan.
And a number of people listened to the
issues in the blackout and we got some change already
in the inspection program. So I think it went well
and I know on the ATWS, we're now working with NRR and
they're quite receptive to what we have to say
technically.
MR. SEALE: Is there any predisposition or
policy decision that would limit the membership on
these teams to people on RES?
MR. ROSENTHAL: No. If I can arrange to
get some help, I'd like that.
MR. SEALE: I'm thinking, for example,
rules that might have a high inspection element in
them that where some help from some qualified
inspection people from the regions could be extremely
useful and I know we've been in the past been
connected with the efforts that some of those people
have made contributions they've made in other areas.
MR. ROSENTHAL: Sounds good. No, you're
right. We'll try that on the next ones.
MR. LANIK: As Jack said, my name is
George Lanik. I'm a Team Leader for this activity.
I think Dr. Kress gave us a pretty good introduction.
One thing I'd add is these studies basically, the
reason we picked the studies we have so far is that
they were listed in the IPE inside report as those
which are continue to be risk contributors and we're
sort of doing them based on that.
The other point I'd like to make about
Research's responsibilities and independent assessment
is that we also have some role in independent review
of operating experience and I think because at least
one aspect of these studies is a looking at the
operating experience. We think that also contributes
to that role for Research.
On a more technical level, I'd like to
make two points about these studies. First of all,
the -- if you look at any of these rules, it's really
a very short version that you see in the Code of
Federal Regulations and you have to go back and look
at the background information including the statement
of considerations and other documents that were
developed at the time these things were implemented to
get what they really intended to accomplish.
And in particular for this one, if you
read the rule you see that all the PWRs had to install
both an automatic driven trip and automatic emergency
feed water initiated, but only CE and B&W had to
installed the so-called diverse scram system which is
a totally diverse system to the normal RPS. And none
of that's -- the reason for any of that is not
mentioned in the rules so you have to go back and look
to see that there were design considerations for why
that was true at the time.
And that had to do with the fact that if
you did the analysis of these plants and the pressures
they would reach during an ATWS event where the CE and
B&W plants would typically go above this 3200 pound
pressure limit which was the -- a design pressure
which they thought would start -- you might start
seeing some damage. And in the case of Westinghouse
with the design conditions they were operating at that
time, they would only exceed that pressure for about
1 percent of the cycle time. So that was one of the
considerations in that rule.
The second point I'd like to make is that
in the type of risk analysis that we're using in this
report, basically what we're doing is we're saying
that the risk is the frequency at which during an ATWS
event you will exceed that 3200 pounds. We are not
using the measure of poor damage probability or large
early release. This is the same measure that was used
in the initial decision to make about the ATWS rule.
And the other point is that we're using
the same basic models that were used then. And one of
the reasons for that is that we wanted to show that
what the improvements that have been made have been
improvements in the operations and equipment
performance rather than improvements in the PRA model.
And secondly, in a lot of cases it's easier to
understand and you can get a better idea of the big
picture if you have the simpler model than the
complicated model.
MR. KRESS: Is it all right for us to
equate this probability of exceeding this pressure
with a core damage frequency? The core damage
frequency would be less than that, but --
MR. LANIK: I think what you can say is if
you don't exceed 3200 pounds, I don't think anybody is
claiming that there will be any core damage.
If you do exceed 3200 pounds, there is
some probability and the other thing is with the
thermal hydraulics the way they are, it's very
difficult to calculate exactly what that is, so you
know, if you only go 100 pounds above that, you're
probably not going to damage any valves or anything to
cause a problem. But if you exceed it by 500 pounds,
you probably are going to damage some equipment that
you would need to mitigate and prevent core damage.
You haven't reached core damage by the
time you've hit that point, of course. It will happen
some time afterwards based on damage to equipment and
being unable to respond --
MR. KRESS: But in thinking of the risk
implications it would be --
MR. LANIK: Yes, it's a surrogate measure.
MR. KRESS: It would be a surrogate --
MR. LANIK: Obviously, it's going to be a
little less.
MR. KRESS: Yes.
MR. LANIK: So without further ado, I'm
going to -- Bill Raughley's going to take us through
the major findings of the study including discussions
of the background and methodology, some of the
technical details and the basic conclusions.
MR. RAUGHLEY: I am Bill Raughley, I'm a
senior engineer in Research and I've prepared a half
a dozen slides that I didn't get stapled. They have
the same orientation in the packet. Sorry about that.
Anyway, it's about a 25 to 30 minute
presentation and we have slides on the background, the
assessment, the results, some of the highlights of the
conclusions or the comments received from the industry
and the conclusions in the report.
We'll spend a little time on the
background just to get every start simple and work up
to some of the details you need to know to understand
the results in the conclusion.
We are talking about the draft report
mentioned there. That was issued in October 2000 for
internal and external comment and we've received the
last of the -- we received all of the internal
comments in December of 2000 and we received all the
external comments as of about two weeks ago.
And that was just to define an ATWS and
it's defined in 10 CFR 50 as an expected operational
transient which is accompanied by a failure of the
reactor trip portion of the protection system and the
reactor trip portion includes the RPS system itself,
the control rods and the control rod drive mechanisms.
ATWS is usually discussed in terms of the
three factors I've listed there, the initiation event
frequency, the RPS reliability and the mitigating
systems and it's usually also discussed by PWR type,
Westinghouse, CE and B&W and the GE BWR type. So all
three of these factors are discussed individually for
those different reactor types.
The ATWS rule was first detailed in 1973
in WASH 1270. Soon after the Commission made it an
unresolved safety issue A9. In response to that
issue, the staff prepared NUREG 460 which is four
volumes and 18 appendices which detail the
deterministic and probabilistic analysis associated
with ATWS. That report relies heavily on the
manufacturer's analyses for deterministic input and
then our own -- and in conjunction with the industry
some probabilistic assessment.
Pivotal to the ATWS issue and through the
whole discussion of 460 there was considerable
discussion or disagreement about the value of the RPS
reliability. If you look in 460 it ranges from 10-12
up to 10-4 and they agree to disagree over the range
being 10-4 to 10-6.
MR. KRESS: It's hard to measure that,
isn't it?
MR. RAUGHLEY: And that was -- the
discussion was over the inclusion or exclusion of
data, whether you look at it just in the U.S. and
include foreign experience and whether we even had all
the experience because the RPS system failures aren't
all reportable.
MR. LEITCH: I notice in the table here
that River Bend, for example, has an ATWS core damage
frequency 1 times 10-10. Is that a difference in
interpretation?
MR. RAUGHLEY: On the BWRs that was one of
the findings or conclusions of the report. On the
BWRs there's a very large variation in the human error
probability. It ranges from .5 up to 1 in 10,000.
There's a very wide range and largely the answer you
get on the BWRs is dependent on what value you select
for operator.
MR. LEITCH: So the BWR, of course, and
that was very sensitive to operator actions and --
MR. RAUGHLEY: Yes.
MR. LEITCH: That difference --
MR. RAUGHLEY: I would just guess that
Riverbend used 10-3 or 10-4 for operator.
MR. LEITCH: So it's not physical hardware
that's different. It's rather a different assumption
about operator action --
MR. RAUGHLEY: Yes, and that's one of our
principal conclusions.
MR. LANIK: However, there are two sort of
two different approaches to BWRs. One of them --
there are a couple of plants out there, the BWRs that
actually installed an automatic SLC.
MR. RAUGHLEY: High capacity SLC and those
don't rely so much on the human performance and they
would do better.
MR. WALLIS: What sort of experiment would
you do to assure yourself of the probability of a
human error was of the order of 10-4?
MR. RAUGHLEY: Jack, can you take that?
MR. ROSENTHAL: We observe that in the IPE
analysis which included ATWS that there was a wide
range of human factors. In fact, I don't know how to
affirm such a low value and the conclusion, really and
I'm jumping all the to the conclusion is that when you
do a rule and in that rule you're heavily reliant on
human actions, then now in retrospect and retrospect
is always 20-20, you should recognize that 10 to 15
years later, you're not going to be able to confirm
that the rule is being met within some uncertainty
events.
MR. ELTAWILA: This is Farouk Eltawila.
To answer your question, I think there are the
training center in Chattanooga and things like that
that run this type of scenarios and they watch the
performance of the operator and there have been a lot
of data collected in the Halden Project for ATWS
scenario although that was for pressurized water, but
they observed the operator and it's a training tool to
respond to ATWS event because it has a unique feature
that the operator does the counter intuitive things.
He has to lower the level of the water in the core, so
that's why it makes it extremely difficult compared to
other scenarios. But there have been a lot of
collection of data on ATWS either through the training
centers or through the Halden Project.
MR. KRESS: Let me ask you a question
about -- you're next -- about the BWR, human error
versus the automatic actuation of the SLC.
In the -- when I looked at the event trees
for those two issues that you had in the report, the
automatic didn't have a line for failure of the SLC,
whereas the one with the operator action did.
It did occur to me that the failure rate
of this automatic is probably about the same as this
operator action failure rate, if it's really that low
and I was wondering if you actually looked at the
comparison of how good the automatic actuation was
compared to just the operator action?
MR. RAUGHLEY: No, we did not.
MR. KRESS: Okay.
MR. WALLIS: I guess the problem is you
want to get a number of 10-4, you have to do what --
MR. ELTAWILA: I am not just defining the
10-4, I'm just saying they are collecting information
on that --
MR. WALLIS: You can't collect
information, but if you try to get those --
CHAIRMAN APOSTOLAKIS: It's really
circumstantial evidence. It's important evidence, but
you can't really treat it like a statistical evidence.
MR. KRESS: That's why there's large
uncertainty associated with --
CHAIRMAN APOSTOLAKIS: When you do it
right, there is uncertainty. You have to do it in a
Category 1.
VICE CHAIRMAN BONACA: A question we had
was why do you have -- why does the standby liquid
system in some cases be automatic and some cases it is
not. Is it an option?
MR. RAUGHLEY: Yes, it was for the BWR 5
and 6s. It was required. It was based on a date of
licensure for all plants licensed after a certain
date.
VICE CHAIRMAN BONACA: So it met the
requirement of the -- resulting from the ATWS or was
it?
MR. RAUGHLEY: It was as a result of the
ATWS rule. BWR 5s and 6s were required to install an
automatic initiated high concentration.
VICE CHAIRMAN BONACA: But there was no
requirement to backfit the older plants?
MR. RAUGHLEY: No, on the value of impact
analysis, that didn't come out to be favorable.
VICE CHAIRMAN BONACA: The other question
I had was regarding the event trees used here in the
additional material. It shows -- maybe we can talk
about it later, simply that there is some event tree
where the standby liquid system is shown to fail with
the RPS. When the RPS fails, both the electrical,
then the mechanical one is not -- there is no window
there, there are not cut sets for that and there are
no cut sets for the standby liquid system. Is it
because the standby liquid system is tied to the same
electric instrumentation of the RPS?
MR. RAUGHLEY: No, it's not tied to the
RPS. The fault trees came from -- the origin of the
fault trees is they were -- if you let me get to it
further, if you look down in the presentation --
VICE CHAIRMAN BONACA: Please, whenever
you have an opportunity to address that. That's
Figure A2 that has that but we can talk about it
later.
MR. RAUGHLEY: So as I was saying, there
was considerable uncertainty on RPS. Human error was
another point of debate on the BWRs and on the
analytical side there was considerable discussion on
the codes that would be used. And on the sensitivity
of results, the certain operational design factors.
On the PWRs, the B&W and CE reactor pipes
have different moderator temperature coefficients
throughout the cycle, smaller relief capacity, smaller
steam generators and different mechanical design
factors and then there's questions on whether you're
operating with the rods and auto or manual, whether
the PORVs are blocked or unblocked. So you get with
quite a maze of conditions to analyze.
In the 1980s, we had the Brown's Ferry
event and that was in Brentwood. Not all the rods
inserted due to a problem in the scram discharge
volume and that resulted in a confirmatory action
letter to install a reactor recirc pump trip.
Immediately following that, the NRC issued
a Draft ATWs Rule with three option, the Staff Rule,
the Henry Rule and the Utility Group Rule. The Staff
Rule was largely dependent on the deterministic
analysis, analyzing the pressures and temperatures
associated with an ATWS. The Henry Rule emphasized
improving RPS reliability, a specific program in that
area. And the Utility Group was a more practical
approach based on modifications focused on preventing
and mitigating an ATWS.
In 1983, we had the Salem events. There
were two events three days apart and that resulted in
several generic letters mandating improvement to the
RPS trip system. Immediately following that, there
was a task force and steering committee organized by
the Commission and its primary deliverable was SECY-
83-293 which contains the technical basis and
regulatory analysis for the ATWS rule.
SECY 293 relied heavily on NUREG 460 for
the deterministic analysis and it adopted the Utility
Group approach for the risk assessment and it also
used the Utility Group value impact analysis.
The SECY-83-293 defined P(ATWS) which was
the annual frequency of an ATWS event, leading to
unacceptable plant conditions that exceed certain
design parameters which George referred to earlier in
the discussion. And for PWR, that unacceptable design
condition was the ASME Service Level C, pressure of
3200 pounds and for the BWR which was suppression of
full temperature of 200 degrees F. which was
established in 839.
On the BWR, just to quickly run through
the event, you start with an initiating event and you
have the RPS failure and it's assumed that there's no
credit for operator scramming their reactor.
Increased pressure, if discharged through the SRV sort
of suppression pool and the severity of the heat up
depends on whether you close the MSIVs to isolate, in
which case you would not have the condenser as a heat
sink or nonisolation transient where they don't close
and you have the condenser and the suppression pool
available for the heat sink.
The outcome is heavily dependent on
operator action. The operator is required to lower
the water level, to mitigate the event and for the
BWRs 1 through 4 standby liquid controls and for most
of the 5s and all the 6s start the standby liquid
control pump.
MR. KRESS: They lower the water level
about halfway into the core?
MR. RAUGHLEY: It is down to level -- I
don't know the specific -- which level, 7 or 8.
MR. LEITCH: It is well below the top of
active fuel though. It's down like a third of the way
down into the --
MR. WALLIS: It is a little touchy because
you've got to maintain cooling, but not maintain
reactivity.
MR. KRESS: That's the idea.
MR. RAUGHLEY: And for an isolation
transient, the operator has two minutes to make that
decision and for a nonisolation transient he has 17
minutes to make that decision. And the probabilities
for those action are taken --
MR. WALLIS: Does he have good feedback so
he knows that his level is the appropriate level that
he's trying to get --
MR. RAUGHLEY: I don't know.
MR. WALLIS: That it's really working out
--
MR. RAUGHLEY: BWR instrumentation is not
-- doesn't have real good feedback.
MR. ROSENTHAL: Can I just chime in? What
we tried to do in assessing the rule was say what do
we know at the time of the rule and what do we know
now and what are the changes? Separate from that
activity we now know that if you trip the recirc pumps
you will fall into a region of potential instability
where you get isolations.
And that introduces a whole new set of
technical concerns including what would the instrument
displayed to the operator, because the instrument is
not connected to the inside of the core and has its
own delay times, etcetera. And we're looking at those
BWR isolation issues as part of Research's work, but
we're trying not to introduce that into the assessment
of what was known at the time of the rule and what did
we get? So we do have future work planned on those
issues.
MR. LANIK: Yeah, and also I think for our
particular case here, we did not give a lot of
operator credit in our particular analysis, we didn't
give anywhere near as much as you noted for River
Bend.
MR. RAUGHLEY: Okay, on the PWR, you have
an initiating event RPS failure also, no credit for
operator action to scram the reactor. You increase
the RCS pressure, then the pressure is relieved. You
start HPI and aux. feed. And that's also dependent on
whether the turbine trips or the turbine doesn't trip,
whether you have the condenser available for a heat
sinc or not.
The peak pressure on the PWRs is dependent
on the moderator temperature coefficient which is a
measure of the reactivity as a function of
temperature. And in general, sufficiently negative
and works with a Doppler to give you a negative
feedback coefficient. However, there are points in
the fuel cycle at the beginning of the fuel cycle.
You have a positive, PMTC sufficiently negative or
slightly positive and that can give you a positive
feedback characteristic. And the amount of time that
it's insufficiently negative or positive is called the
unfavorable exposure time.
The ATWS risk analyses were done assuming
that the MTC was acceptable 99 percent of the time and
that the deterministic analysis supplied by the
manufacturers were done assuming the MTC was
sufficiently negative 95 percent of the time.
MR. SIEBER: Why did they allow the
moderator temperature coefficient to be positive at
any time? You can absolutely design that out of the
fuel by putting in burnable poisons.
MR. RAUGHLEY: It is a function of the
fuel cycle length.
MR. SIEBER: You put in burnable poisons,
it's a matter of how many hours worth of neutrons
you're willing to spend to maintain the negative
moderator temperature coefficient.
MR. RAUGHLEY: Yes, and you would also,
it's a function of what you said, the boron
concentration --
MR. SIEBER: The less, the better off you
are.
MR. RAUGHLEY: But dependent on how you
vary all those factors and controls, the --
MR. SIEBER: You can design that out.
MR. RAUGHLEY: Yes.
MR. SIEBER: And so it would seem to me to
minimize the exposure you'd have licensees design it
out, design out a positive temperature coefficient.
VICE CHAIRMAN BONACA: I don't think you
an totally eliminate that effect because of what you
have. You have at the beginning of the transient you
have number pressure transient, enough scram. You
have a temperature increase. I think you're going in
a region where you have some positive feedback.
I'm not sure you can leave it at that
completely. That has been difficulty there.
MR. SIEBER: I was under the impression --
we managed to do that and I was under the impression
it can be done, given sufficient burnable poison,
coated pellets, inserts and so forth.
MR. LEITCH: One of the things that I
found interesting in that respect and we're concerned
about the combined effects of power upgrades and
license renewals and extended fuel cycles and so forth
is a sentence here on page 17 of the report that I
felt was interesting in that regard.
It says fuel designed to achieve longer
cycles result in less negative MTCs at full power, but
a larger fraction of the cycle time during which time
half this mitigation is rendered ineffective. And I
just think that's one of these effects of longer cycle
time that might not be apparent. That's one of the
things that we've been kind of worried about.
MR. KRESS: It's one we ought to put on
our list, maybe.
MR. LEITCH: Yeah, right. Just a comment.
MR. RAUGHLEY: That is one of the
conclusions the report is -- that we should continue
to give that attention because as a result of
deregulation and the emphasis to be more competitive,
the BWRs would likely go to longer cycle times, 18-
month and 24-month cycles which requires you to
further increase the MTC.
But this is from NUREG-1000. It's based
on Salem-specific factors that has an MTC of -8 which
is their normal value at hot, full power, all rods out
and the 95 percent -- at 95 percent of the fuel cycle.
What you can see is the pressure does go up to 3500
pounds in about 100 seconds and one of the debating
points in NUREG-460 is whether the manufacturer was
looking at 100 and the NRC's analysis was looking at
60, but the point being is very short, it ramps up
real quick in a very short time.
MR. LANIK: Basically, that's timed with
usually steam generator dry out time, as soon as the
steam generator dries out, the pressure shoots up.
MR. KRESS: What was used to calculate
that? RAMONA and RELAP together?
MR. RAUGHLEY: Westinghouse uses four
programs. They use LOFTRAN, maybe Farouk -- there's
four different codes, so depending on where you are on
this curve --
MR. KRESS: I should have known that.
MR. RAUGHLEY: They use LOFTRAN down in
this area and they switch off.
Then last but not least, the ATWS rule was
passed in 1984 which requires specific modifications
by reactor type that we'll discuss in detail on the
next slide.
And as George mentioned earlier, when
you're looking at a rule, not everything about the
rule is written in the Code of Federal Regulations or
some important background, one being that along with
the FRN that issued the rule, there were two
recommendations made by the Commission. One was that
they expected that the licensees would undertake an
RPS reliability improvement program and the other was
that they would reduce the number of automatic scrams.
We'll breeze through this slide quick,
since you saw it before in the station blackout
presentation.
(Slide change.)
MR. RAUGHLEY: But the --
MR. WALLIS: Well, the regulation is
effective if expectations are being achieved.
Sometimes the statements of consideration don't give
a very clear exposition of just what is expected.
MR. RAUGHLEY: That's true and in this
case that's true and we have to go back to SECY. Most
of the meat and potatoes for the ATWS rules in SECY-
83-293 which the statement of considerations refer to.
And then the statement of considerations also refer
you, that if you're interested in the deterministic
analysis, they're in the appendices of NUREG 460, but
it provides you with a roadmap on which documents to
go back and review.
The basic approach we took to effect this,
as the regulations effect, the expectations are being
achieved and we got those expectations from the NRC
documents, as I mentioned, largely SECY-82-293 and the
outcomes, we used operating experience, the NRC PRA
IPE data bases which is available on the webpage LERs,
NRC surveys of the moderator temperature coefficient
that was done in 1995 and NRC RPS reliability studies.
The scope of the rule was to stay within
the confines to compare what, exactly what they did to
the outcome. We didn't try to read anything into the
rule, change the method. We used their methods, tried
to do the calculations the same way they did, so we
had an apple to apple comparison.
Certainly, some things could be done
better, more precise and with technology today, but
then you wouldn't know if you made any progress as far
as what the authors expected in 1984.
The ATWS rule required certain
modifications by reactor type. For the PWRs, were all
required to install AMSAC which is the ATWS mitigation
system actuation circuitry which -- that's what I'm
referring to in the first line there and that's a
diverse means to trip the turbine and auxiliary
feedwater and what that does is -- AMSAC monitors
steam generator levels and initiates when the level
drops below a certain set point.
The CE and B&W PWRs installed a diverse
scram system referred to as a DDW and this Scams the
reactors on high RCS pressure, about 2450 is what most
of them are set at and that signal is derived from the
riffle system.
The CE and BWR reactor types have an
insufficient MTC, approximately 40 percent of the fuel
cycle. It seems like a longer exposure. That was the
primary driving force for installing the diverse scram
system, but you can -- this is for the -- I want to
say CE reactor. They're showing for 18-month and 24-
month fuel cycle, the percentage of time that they
would be above the 3200 pounds.
MR. WALLIS: Is it worse at the beginning?
MR. RAUGHLEY: Always. Typically, the
moderator temperatures --
MR. WALLIS: Counter intuitive. You
usually expect new things to be better.
MR. POWERS: Not true in fuel reactivity.
You burn the fuel up, see?
(Laughter.)
MR. RAUGHLEY: All PWRs have MTC tech spec
limits at hot zero power and how full power. And
we'll summarize those a little further down in the
discussion.
For the BWRs installed, an alternate rod
injection system, which is typically DC scram valves
on the exhaust discharge volume. And BWRs have, as we
discussed before, high capacity, high concentration
standby of the control systems. The systems were
typically about 40 GPM and the rule requires them to
increase them to 86 GPM and most BWR 5 and 6 is
installed automatic standby liquid control.
The ATWS rule also required installation
of recirc pump trip which also is redundant to the
confirmatory action letter that was issued after the
Brown's Ferry event.
As far as another -- all of the
modifications were installed in the 1986 to 1990 time
frame. As far as the Commission recommendations, the
frequency -- the number of automatic scrams was
reduced. It was 6 in 1980 and the industry started on
a program in the early 1980s to reduce it and it was
4 in 1984 at the time the ATWS rule was passed and
that was what was used as an input to the ATWS
analysis.
And in 1997, 1998 and 1999, in each of
those years it was .5 trips were year and within that
it should be noted in each of those years the 60 to 70
percent of the operating reactors had zero scrams and
in any one year 10 to 20 percent had 2 to 4 scrams.
So they're the two ends.
CHAIRMAN APOSTOLAKIS: But is this
reduction frequency the result of the rule?
MR. KRESS: That was sort of a secondary
thing the Commission asked for.
MR. RAUGHLEY: It is second, but what did
come as a result of the rule was four days before the
ATWS rule was passed, the industry briefed the
Commission on the fact that they were going to make
scram reduction a program, that this would become a PI
in 1985, 1986. I think it was a catalyst to
formalizing a program and getting it, giving it
visibility rather than something that was being done,
that we were to assume being done.
CHAIRMAN APOSTOLAKIS: Is it fair to claim
that this was the effectiveness of the rule?
MR. KRESS: It was a response to the rule
being promulgated.
VICE CHAIRMAN BONACA: This study provided
really a lot of sensitivity in the industry in
regarding the acquisition and that's part of the drive
of the concern with the failure of the RPS was coming
from.
CHAIRMAN APOSTOLAKIS: What were the main
reasons that we had this order of magnitude reduction?
What did they do?
MR. RAUGHLEY: More attention to analyzing
the scrams that they had.
MR. ROSENTHAL: The dominant contributors
to react a trip was number one to the turbine systems
and number two to the feedwater systems. And we've
gone through a whole generation of improvement.
There's now a lot of digital feedwater control systems
that help you go up. There's a trip reduction
program. You walk around a plant and there's taped
off areas, telling people not to trip over stuff.
There was a time when you had technicians
-- you'd put a probe inside a cabinet and there's some
likelihood you're going to slip, well, there's a lot
of banana jacks around so that you connect up your
scope right without slipping. So there were real
hardware things associated with the turbine and the
feedwater which have commercial implications as well
as safety implications. And then just plain better
maintenance.
VICE CHAIRMAN BONACA: Better training,
heavily dependent on training because the sensitivity,
for example, testing was an issue.
MR. KRESS: We heard about a reactor in
Switzerland yesterday that's gone 10 years without an
automatic scram.
MR. LEITCH: One of the things that
perhaps is lost up there is where it says upgrade
EOPs. I think that was a very significant step in
scram reduction, coupled with well thought out
emergency operating procedures, coupled with operator
training, along in this time is the advent of plant
specific simulators which I think helped a great deal
in the scram reduction.
But I wonder, like George, if you just
upgraded the EOPs and improved operator training and
reduced automatic scram frequency, reduced RPS --
increased RPS reliability, wouldn't that have greatly
improved the situation? In other words, I guess what
I'm wondering is I guess it's not really possible to
separate out how effective the hardware modifications
were in making these improvements.
MR. RAUGHLEY: Two slides down we do.
MR. LEITCH: Very good, thanks.
MR. RAUGHLEY: I think we're getting to
the same place you are. And then the other
recommendation as far as RPS reliability -- could you
put up that slide?
(Slide change.)
MR. RAUGHLEY: Put a table in the report,
basically shows the first line is what
SECY-83-293 expected and that was calculated based on
one failure from Brown's Ferry and Westinghouse for
each of the reactor types to get the value here. This
is the improvement expected as a result of RPS
reliability --
CHAIRMAN APOSTOLAKIS: Let me understand
this. Was the Brown's Ferry incident really a
failure?
MR. LEITCH: Not a total, partial failure.
CHAIRMAN APOSTOLAKIS: It was partial
failure.
MR. RAUGHLEY: There were --
CHAIRMAN APOSTOLAKIS: They were buying
themselves time and they were going to drain the water
from the scram discharge volume.
MR. LEITCH: Some of the rods inserted all
the way, others failed to insert.
CHAIRMAN APOSTOLAKIS: Right, over a
period of time they managed to actually scram. This
is really conservative, is it not, to say that there
was one failure? This has been the perennial problem
with scram reliability. There were raging debates.
MR. RAUGHLEY: It was to find more than,
I think it was a third of the rods did not go in, that
would be considered a failure.
CHAIRMAN APOSTOLAKIS: It was not that
they didn't go in period. I mean this was a dynamic
event. The operators intervened and so on and that's
not here. So 10-5 doesn't really mean much.
MR. LEITCH: Did the rods go in to make
the reactor subcritical? I think they did.
CHAIRMAN APOSTOLAKIS: Pardon me?
MR. LANIK: No, they were at about 20
percent power.
MR. LEITCH: Were they?
MR. LANIK: Yeah.
MR. LEITCH: I'd forgotten the details.
MR. RAUGHLEY: As I mentioned earlier the
pivotal to the ATWS is the RPS reliability, does make
a difference in the numerical answer, whether you use
10-4, 10-6 and the discussion you're starting is
exactly the discussion in the 1970s over whether you
count this as a failure or not and what number do you
use.
CHAIRMAN APOSTOLAKIS: I mean this
probably should have been analyzed as a precursor
event, following the sequence and seeing what kind of
probability you get rather than a straight forward
classical statistics analysis because it was not a
failure.
I mean that's clearly an upper bound, if
you assume it's a failure, the number you have there?
MR. RAUGHLEY: They calculate upper and
lower bounds about these values.
CHAIRMAN APOSTOLAKIS: How do they get the
lower bound?
MR. RAUGHLEY: They use a binomial
distribution.
CHAIRMAN APOSTOLAKIS: Oh God, oh.
MR. RAUGHLEY: Again, I didn't challenge
what the people did.
CHAIRMAN APOSTOLAKIS: Is this being
recorded? Oh. Let's go off.
MR. RAUGHLEY: That was 1984, George,
before you came along.
CHAIRMAN APOSTOLAKIS: I was an Assistant
Professor.
MR. POWERS: I get the vague sense that
maybe you're a little disappointed?
CHAIRMAN APOSTOLAKIS: You always read me
right.
MR. RAUGHLEY: This is the expected
improvement. This is the result, if you treat the
calculation the same as they did in the ATWS rule.
You can see they didn't get the improvement achieved,
the improvement you wanted. And then this is using
the latest methodology in NUREG-5500 which starts with
data from 1984 to the present.
And this is the value you get. But
there's not much --
CHAIRMAN APOSTOLAKIS: It that done like
a precursor analysis in the 5500 or again is it the
straight forward statistics?
MR. RAUGHLEY: 5500 is they modeled the
different components. They broke the RPS system down
into 30 or 40 different components and got the failure
data on those components and modeled it as a system.
CHAIRMAN APOSTOLAKIS: The important
lesson from the Brown's Ferry incident is the
operators do have time to intervene. It's not a yes,
no event.
MR. RAUGHLEY: I think I mentioned at the
beginning you have to 2 to 17 minutes depending on --
that's the consideration they gave to it.
CHAIRMAN APOSTOLAKIS: Okay.
MR. KRESS: Before you take that off, if
we believe the bottom line why then we can say the
expectation was met. If we believe the next to the
bottom line, we say a dozen.
Since I'm a Bayesian of sorts, I like the
bottom line. I presume that's one we ought to
believe?
MR. RAUGHLEY: If you throw out the
failure data, you get a good answer.
CHAIRMAN APOSTOLAKIS: That is usually the
case.
(Laughter.)
But remember though there is also a
question about the denominator, what is the demand?
MR. RAUGHLEY: Yes.
CHAIRMAN APOSTOLAKIS: It is a big
question. Right? So the number of demands they use
there, one probably --
MR. RAUGHLEY: The denominator is probably
a good estimate. We do understand how many time a
month they test a reactor. What's in question is the
numerator, because not all reactor
-- not all of these failures are reported.
CHAIRMAN APOSTOLAKIS: But even the
denominator, wasn't there an argument made that
they're moving all the time. You don't scram, but
that's an indication of how things work and that's a
very difficult piece of evidence. It's not that the
rods are there and either they go in or not.
That was a big argument in the 1970s. I
mean how much credit do you take for that and the NRC
finally said no, we'll count real scrams.
I notice a reluctance to show event trees.
The report has report trees, but your presentation
does not. Is there any reason why you don't have --
MR. RAUGHLEY: We have event trees.
CHAIRMAN APOSTOLAKIS: I know you have
event trees. I'm just asking why you don't show it.
Anyway, okay, please go ahead.
MR. RAUGHLEY: This slide next.
(Slide change.)
MR. RAUGHLEY: As far as P(ATWS) in
getting to what Mr. Leitch, I think, was headed, most
-- as you can see, as far as P(ATWS) goes, it did meet
the goal of 1.0E-5 in all cases, but the majority of
the improvement came from the initiating event
reduction and not from the modifications.
CHAIRMAN APOSTOLAKIS: That is an
interesting --
MR. KRESS: That's an interesting --
CHAIRMAN APOSTOLAKIS: Why is that?
MR. KRESS: It's a direct multiplier. The
other one, you have to --
CHAIRMAN APOSTOLAKIS: I mean if you
install hardware, if you make hardware modifications,
shouldn't you see some --
MR. KRESS: It's the number of scrams.
You don't challenge the hardware.
CHAIRMAN APOSTOLAKIS: All PWS install
diverse means to trip the turbine or that affected
what, the initiating event frequency?
MR. LANIK: Basically what that does is
affect the operator action time. It lengthens the
time you have water in the steam generator. You're
talking about tens of seconds.
MR. KRESS: Let me ask you a question
about this table. We have a set of ATWS sequences in
the event trees. What was their contribution to the
overall risk, say CDF, if we use a P as the CDF
surrogate to the point for those classes of plants?
MR. LANIK: We did not summarize those in
aggregate. They're listed individually in the
appendices for each plant of their contribution. What
they estimate is their contribution on a
plant-specific basis. We didn't go back and add those
up.
MR. KRESS: But it was generally a high
times 101-5 approaching 10-4. Is that -- I'm trying to
figure out why the ATWS events were considered an
unacceptable risk in the first place and of course
that depends --
MR. RAUGHLEY: It's a low probability,
very high consequence. It's an unforgiving event,
with the high pressure and the PWRs.
MR. KRESS: And high uncertainty also?
MR. RAUGHLEY: Yes.
MR. KRESS: But I was trying to put some
numbers on it. How much contribution does that set of
sequences give to the overall CDF of giving class a
plant, say it was the number I'm looking for?
MR. LANIK: I am just looking in our
appendix and I see look at Tewkesbury and they claim
24 percent as the contribution of ATWS.
On others, you can just look through the
list, I guess.
MR. LEITCH: But if you go to the extreme,
you've got .000645.
The difference is what one assumes about
operator action.
MR. KRESS: But I'm wondering why that was
considered unacceptable so we had to have a rule in
the first place. That's the point I'm getting to.
MR. LANIK: I think it's the point that
Jack made earlier. It was the uncertainties --
MR. KRESS: Large uncertainties.
MR. LANIK: Large uncertainty in these
things and the fact that some people were claiming 10-
8 and I think that's a number that nobody would
believe.
MR. KRESS: Frankly, I think that's a good
answer, that there was large uncertainty -- that it
was a sizable contribution and it was high uncertainty
in that number.
MR. ROSENTHAL: And as a matter of fact,
we've spoken a number of times and in fact, we got an
opportunity to interview Mr. ATWS at the NRC which is
our office director. And as much as anything else, at
least in my mind the purpose of this rule was not to
suppress the risk of the plants so much as to suppress
the uncertainty in the risk of the plants. And we had
gone back and forth for 15 years with the industry and
then came up with what seems like a pragmatic approach
to drive down the uncertainty.
But let me just go on with the risk a
little bit more. If you take the Limerick Plant which
I just happen to know, ATWS is 1 percent of the core
damage frequency, so that's a small contributor.
However, because in ATWS you fail the containment
before you melt the core, it was the dominant
contributor to large early release.
Now those are insides that at least I have
post the ATWS rule, but that was still as important on
boilers, especially because of the fact that you
failed the containment before you failed the core.
MR. KRESS: Frankly, I'm very pleased to
hear you say that one good purpose of rules is to
reduce uncertainty. I'm really glad to hear that.
MR. RAUGHLEY: I think the other thing
they were wrestling with then is you had the very low
numbers, but you also had three events. If it's
really 10-6 or 10-8 well why do we have three events?
MR. KRESS: Why do we have three events,
that's right. Bayesian thinking again.
MR. RAUGHLEY: We'll go to the comments.
(Slide change.)
MR. RAUGHLEY: We sent this out, as I
mentioned in the beginning of the discussion for
public comment and we've received internal comments
from NRR from Rich Barrett's group, the BRA Assessment
Branch and the Reactor Systems Branch and we've
received external comments from the people I've listed
there.
Some of the highlights of the comments,
UCS and Westinghouse commented that the risk approach
was very simplistic and that's a --
MR. KRESS: We've made the comment before
that the complexity and extent of the risk ought to
depend on the application and how much of a risk
analysis do you need for retroactive look at something
like this? I don't know how simplicity -- simplicity
doesn't seem to be too bad to me in this case.
MR. RAUGHLEY: And then alluding to a
question -- well, by the --
CHAIRMAN APOSTOLAKIS: The analysis of
Brown's Ferry, for example, could have been done
better.
MR. KRESS: I don't think that's the
analysis I'm talking about.
CHAIRMAN APOSTOLAKIS: That's not the
issue here.
MR. RAUGHLEY: In the final value impact
analysis, I did not -- the original value impact
analysis, the costs were divided up into the
modifications and then the costs for lost power due to
spurious scrams due to the installation of systems
such as AMSAC and I went back and identified the
number of spurious scrams which were considerably less
than expected which helped make it more favorable.
And then I also stuck, there's a couple of sentences
in there about I gave the NRC some credit for the
scram reduction program because there are significant
bucks. It's in excess of $10 billion if you credit --
somebody gets credit for that and a lot of people
suggested, as George maybe was, that the NRC had
nothing to do with it.
MR. LEITCH: Did you consider the downside
of false automatic boron injections?
MR. RAUGHLEY: There weren't any, but that
was --
MR. LEITCH: I know there was one at
Limerick.
MR. RAUGHLEY: On the original actual just
Tewkesbury's actuation of the systems that were being
installed under the ATWS rule as calling a scram,
diverse AMSAC which there have been several spurious
actuations of, I think, 13. But that's a lot lower
than the one or two per plant that was expected per
year. And the --
MR. LEITCH: But you're talking about
false scrams.
MR. RAUGHLEY: Yes.
MR. LEITCH: I'm speaking about false
boron injections.
MR. RAUGHLEY: I don't think they
considered that in the original rule.
MR. LEITCH: But in the economic benefit
of this, did you debit that?
MR. RAUGHLEY: No, because they didn't do
it in the original rule. I did whatever they did in
the original rule.
MR. LEITCH: I see.
MR. RAUGHLEY: Just so you could measure
the expectation versus the outcome.
MR. LEITCH: Because there have been, I
think, a few of those and then that increases the
outage time because you have to clean up and several
days sitting there cleaning up. Okay.
MR. RAUGHLEY: The other discussions on
the PWR comments, one is to recognize that there were
sensitivities to different design features between the
Westinghouse and in contrast to the CE and B&W plants
and we have a few sentences in there on that, we'll
beef that up in the final report.
And then there were opposing comments from
the industry, de-emphasized the MTC/UET issue and the
NRR wanted us to increase our emphasis in that area.
We have a lot of "mays" and "could be's"
and NRR would like us to make those hard statements.
UCS had a comment tying the steam
generator tube issues to the MTC issue and then in all
cases, both the BWR and the PWR manufacturers would
like us to give more credit for operator action in the
scram. We've acknowledged that in the report based on
the NUREG-5500, if you credit the operator or scram
you halve the factor of 2 on the risk. So we'll roll
that up into an observation or conclusion of the
report.
And then what we plan to do is each
comment will be addressed in an appendix of the report
like we did in the station blackouts so you'll see the
comment as submitted, and then we'll provide a
response to it. And those will be issued with the
final report.
The conclusion, we concluded primarily
based on the risk that the ATWS rule was effective,
the modifications were installed as intended and it
was effective in reducing the risk. The target was
1E-5 for P(ATWS) and as you saw they were in the order
of 10-6. However, there's still uncertainties in the
RPS reliability. You still have to -- if you give
benefit to the full range of the statistics, you can
still get some answers that are -- maybe you wouldn't
like.
And you still have questions about the
data because RPS failures aren't always reported. And
then in the area of the mitigative capability, we have
the concerns about the fuel management issues as we
discussed earlier with the utilities need to become
more competitive and a way to do that is to extend the
fuel cycle. To do that, you've got to increase the
MTC and that's as Westinghouse has submitted.
VICE CHAIRMAN BONACA: And for BWR isn't
it true that given the chance there's some dependency
on operator action?
MR. RAUGHLEY: And that was our third
problem that we thought we needed attention and as far
as getting back to Mr. Wallis as to what to do, we
didn't come up with a solution.
VICE CHAIRMAN BONACA: No, the question I
had was I thought that I remember a power operates
coming in for BWRs and those are likely to accelerate
sequences including the ATWS sequence. Wouldn't that
challenge further the operator action that -- or
defectiveness of it?
MR. ROSENTHAL: Yes, we are planning a
separate research initiative on what we call the
synergistic effects of the power upgrades, the longer
cycles, the change in fuel designs and we'll be coming
up with a plan and likely write a Commission paper
before we embark to try to figure out some way to put
these together in a synergetic effect, rather than
looking at the issues one by one.
That's a separate activity.
MR. LEITCH: Just a comment on Table 1B,
the column that's headed modification summary, is
there any reason why you didn't annotate that to
indicate which plants had automatic boron injection,
automatic standby liquid injection?
MR. RAUGHLEY: I thought we did for a few
of them.
MR. LEITCH: Table B2, there's a table
called modification summary and I don't see any
indication there which plants have automatic SLC
injection.
MR. RAUGHLEY: We can add that.
MR. LEITCH: Just out of curiosity.
MR. RAUGHLEY: We can add that.
VICE CHAIRMAN BONACA: Before I raise the
question regarding the Figure A2, Figure A2 shows in
the event tree you have the branch where you assume
the electrical RPS failure. And that doesn't have any
-- of course in a failure you do have also a
consequential and mechanical RPS failure. You have no
-- not that one. A2.
MR. LANIK: We do not have that first
slide.
VICE CHAIRMAN BONACA: It has a branch
that essentially shows failure of the electrical RPS
and then a straight line, I don't know for the
arranged your CAT sets to assume successful failure of
the other components downstream. Why is it? I can
understand if you have a failure of the RPS electrical
you have also failure of the mechanical, but what
about the automatic standby liquid system?
MR. LANIK: Well, this is basically the
event tree that was in the NUREG and we didn't change
these. And as a matter of fact, we didn't really use
this in any of the calculations we did. So I would
say we didn't look at this one very closely. The
other ones we actually have the tables with the
numbers that we plugged in and we looked at those
closely. This one -- we took it from the original
ATWS rule, NUREG and put the numbers in that we got
from the people in the reliability area.
I don't know the reason why that was left
out. I think it doesn't matter much because the
electrical is so reliable, really, I mean in other
words you always -- you usually go that way.
You're not going to have many
contributions there.
MR. WALLIS: These are all amalgamous LCs.
Maybe that makes a difference.
VICE CHAIRMAN BONACA: That's right, but
then at that point you would have a gate and you will
have success or failure system still.
MR. LANIK: It's almost never -- you know,
it's a very small number. That's not going to be much
of a problem.
MR. SIEBER: A minor question. It seems
to me from my memory, AMSAC was a non-safety grade
system?
MR. RAUGHLEY: Yes.
MR. SIEBER: On page 10 you discuss in the
report reliability of ATWS mitigating systems. Did
the fact that AMSAC is non-safety grade have any
impact on the estimate of reliability that's discussed
there and in the previous table, top of the page?
MR. RAUGHLEY: No. The reliability we
have is from the operating experience. So whether
they got it --
MR. SIEBER: One way or the other?
MR. RAUGHLEY: One way or the other. It--
MR. SIEBER: Well, somebody some place
must have made a judgment that you don't have to have
AMSAC of safety grade.
MR. RAUGHLEY: All the ATWS modifications
are non-safety.
MR. SIEBER: Right.
MR. RAUGHLEY: Right.
MR. SIEBER: And that's because they don't
have a lot of impact on the risk that scram reductions
had a far greater impact?
MR. RAUGHLEY: Yeah, that's the bottom
line. The biggest impact was the scram --
MR. ROSENTHAL: Let me just point out, I
mean this was anticipated transient, normal transient
without scram.
MR. SIEBER: Right.
MR. ROSENTHAL: It wasn't a
seismic-initiated event or a Hughes situation, so the
special conditions didn't apply. I think this was a
very reasonable thing to do to make them, a system
without all the pedigree, but it was always expected
that they would be -- and of course, they are, high
grade commercial.
But it does point out the importance of
getting voluntary data collection on the component
level with -- through INPO because if it's not
reported via an LER because it's not safety-related,
you need some other way of collecting the data and so
these other ways are important to us.
MR. SIEBER: Thank you.
VICE CHAIRMAN BONACA: The question I had
was why was 3200 psi used as a criterion for lack of
effectiveness? I mean you mentioned it above 3200 you
may have failures of some valves and so on and so
forth. But the RCS is designed to withstand much
higher pressures than that, I can see --
MR. RAUGHLEY: They considered ASME
service level D.
VICE CHAIRMAN BONACA: D, okay.
MR. RAUGHLEY: I think that got above --
I think the steam generator for 3600 psi is what
Westinghouse told us the limit was there. But I think
the D gets above that and then the D also gets into an
area where they really don't know if the valves are
going to deform or not where there's a lot of testing
really hasn't been done in that neighborhood.
MR. SIEBER: Actually, at that level you
get some component deformation, for example, tube
sheet bowing and so forth which is maybe not a
disaster as far as integrity and continued service,
but it's there, nonetheless.
MR. RAUGHLEY: Any other questions?
MR. POWERS: I guess I've got two or
three. One of the first questions is an element of
phenomenology. Does the appearance of an axial offset
anomaly affect significantly the response of the plant
to an ATWS condition?
MR. LANIK: I don't know. Do you know,
Jack?
I would say that probably that hasn't been
analyzed.
MR. ROSENTHAL: Years ago when I had hair,
I ran a 3D space-time kinetics calculations and those
were different than a 1D and clearly different from
point kinetics. So the axial offset would change,
would change the response in the calculational model.
Now I was recently sobered by Norm Laubin
who is sitting to my left because we just tried to do
some sensitivity studies with just relap with a simple
point model, but kinetics model and as -- just to get
some feel for this and as Norm did the calculations
and you know, you just turn the little knob on the MTC
or you turn the little dial on the relief capacity in
the primary system, you go from being, having steam in
the pressurizer to going solid, you do one thing, you
end up with 3100. You turn the knob a little bit
differently, you get 4,000 pounds and big differences.
And so that was sobering that the
calculational model, the thermohydraulic model had a
lot of questions for them and so I would get back to
the forte of the rule was it suppressed the concern in
these things.
MR. POWERS: I guess what I'm wondering is
if we aren't seeing a reimposition of uncertainty as
these phenomena associated with longer duty cycles
come up and we get these axial offsets.
MR. ROSENTHAL: And that's why research is
interested in doing a study of the synergistic effects
of all these changes, absolutely.
MR. SEALE: I think it's important to
remember that the effect of point kinetics is always
to inject a coherence of events into any calculation
and you will always over emphasize the simultaneity of
a pressure pulse or a radiation pulse or anything else
using point kinetics and if --
MR. POWERS: I don't think that's the
question here. The question is are they doing any
calculations on the neutronics at all here in response
to the axial offset anomaly?
MR. SEALE: I was going to say if there
was ever a justification for going into those issues
of computational capability, there it is.
MR. POWERS: I derive from your study that
a substantial amount of the evolution in ATWS
probability arose from the reduction in the scram
frequency that seemed to be correct.
MR. RAUGHLEY: Yes.
MR. POWERS: And I believe that we now
have a reactor oversight system in which scram
frequency, unplanned scram frequency is a performance
indicator?
MR. RAUGHLEY: Yes.
MR. POWERS: If a plant were to go from
the green to the white in its unplanned scram
frequency and for the purposes of the thought let's
say that they're all automatic scrams and none of them
were manual, how would the frequency of ATWS events
change?
MR. RAUGHLEY: If it were to --
MR. POWERS: If the frequency at a plant
for unplanned scrams -- I predicate it by saying
they're all automatic, were to go from green to white,
how does the frequency of ATWS events change?
MR. LANIK: I believe it's about an order
of magnitude.
MR. POWERS: Which would put it over the
Commission's goal or near the Commission's goal?
MR. LANIK: It would be close. It would
be right --
MR. POWERS: And if they went on to
yellow, they would definitely be over the Commission's
goal?
MR. RAUGHLEY: I don't know where the
white -- you may have to get down to the -- the red is
25 scrams and that's certainly within --
MR. POWERS: An enormous number.
CHAIRMAN APOSTOLAKIS: I think the white
is 3.
MR. POWERS: It seems to bring us back
where we were and so I'm wondering why is that white?
Why is that a little more extreme if you're
essentially undoing everything that the ATWS rule did
for you?
CHAIRMAN APOSTOLAKIS: You're right.
Which is the big question because it was always being
what was a rationale because green, white and yellow
and most importantly the action matrix.
MR. RAUGHLEY: I'm not aware that --
CHAIRMAN APOSTOLAKIS: I realize you're
not, but this is a good comment.
MR. POWERS: I think it's important that
this study relate back to the current oversight
process.
CHAIRMAN APOSTOLAKIS: Sure.
MR. POWERS: And ask the questions, have
we set these levels correctly in light of this
objective of the Commission and this finding that
those scrams make a difference.
CHAIRMAN APOSTOLAKIS: Yes, yes. And we
may even find that some of these have to be plant
specific, huh?
MR. POWERS: Well, that would be a
stunning revelation, wouldn't it?
CHAIRMAN APOSTOLAKIS: Surprise. Okay,
any other questions? I think we will have an
opportunity to review the oversight process again this
year, right? We have an SRM?
MR. POWERS: Do you think we'll ever get
into the SDP?
CHAIRMAN APOSTOLAKIS: There are hopes.
(Laughter.)
Tom, is this done?
MR. KRESS: I think so unless Jack wants
to make a few more comments?
MR. ROSENTHAL: Just that what we tried to
do was -- well, what we did do was publish a draft
report, went for public comment. By the way, we
always write to UCS with a letter requesting their
comments as well as the industry groups.
And then -- but still as a draft report,
we came before you with a near final product because
this gives you an opportunity to influence the final
product and some of the observations made on the table
when you said that we'll incorporate in the report.
So what I'd like you to do is tell me is this a good
way to go about it because we'll be back again in
another six months. Or, would you prepare a final
product or earlier input and then in terms of your
actions -- the choice is in terms of a letter or not
or whatever, is just yours.
MR. POWERS: I think this is just about
exactly right. The timing was just about exactly
right.
CHAIRMAN APOSTOLAKIS: Are we writing a
letter, Tom?
MR. KRESS: I am still debating.
CHAIRMAN APOSTOLAKIS: Debating.
MR. KRESS: I have thoughts on what a
draft might look like, but it's not --
CHAIRMAN APOSTOLAKIS: So we can discuss
this this afternoon.
MR. KRESS: We'll have to discuss it this
afternoon.
CHAIRMAN APOSTOLAKIS: So the staff is not
requesting a letter?
MR. KRESS: No sir.
MR. POWERS: Not even an "atta boy, Jack"?
Come on.
MR. KRESS: It will be sort of that
nature. That's why, I don't know, we sometimes are
reluctant to write "atta boy" letters.
CHAIRMAN APOSTOLAKIS: Especially to Jack.
Is there anything else of substance to be
discussed at this point? Thank you very much,
gentlemen. We'll recess until 10:15.
(Off the record.)
MR. KRESS: Can we come back into session,
please?
The next item on our agenda is an overview
of the mixed oxide fuel fabrication facility and with
some debate over who it's supposed to be. I'm going
to turn it over to Jack Sieber for introducing the
subject.
MR. SIEBER: Thank you, Mr. Chairman. The
licensing of a MOX or a mixed oxide fuel fabrication
plant is a relatively new endeavor for the ACRS and
the NRC. There is a new standard review plan that
covers the staff's responsibilities for that licensing
effort. This is sort of a kickoff meeting wherein we
learn a little bit about a MOX fuel plant and the
schedules and so forth that we will have to keep in
order to keep the licensing process for a MOX plant on
schedule.
With that, I'd like to introduce Tim
Johnson who will give the presentation.
MR. JOHNSON: Thank you very much. I'm
the backup project manager for the MOX fuel
fabrication facility project and I appreciate the
opportunity to brief you on the status of this
program.
Before I begin, I'd like to introduce
several people who are available to also help me
answer your questions: our Deputy Division Director
for the Division of Fuel Cycle Facilities and
Safeguards, Bob Pearson; my branch chief, Eric Leeds;
my Section Chief, Joe Gidder; Patrick Rhodes from
DOE's Office of Fissile Material Disposition and Peter
Hastings from DOE's Contractor, Duke, Cogema, Stone &
Webster who's going to actually build and operate this
facility.
(Slide change.)
MR. JOHNSON: What I'd like to do today is
go over a number of different areas. One is to give
you an overview of the MOX program and some of its
history. I'd like to talk about the NRC licensing
process, what we're doing with respect to the National
Environmental Policy Act requirements we have. Talk
about opportunities for public hearings, what we're
doing in terms of public participation, some of the
significant issues that we're dealing with and our
schedule.
Before I begin though, are there any
particular things that you wanted me to focus on as I
went through my discussion?
(Slide change.)
MR. JOHNSON: To begin an overview, I'd
like to talk a little bit about the history of this
project. The MOX project is part of a bilateral
plutonium disposition agreement between the United
States and Russia. This agreement was intended to
reduce nuclear proliferation. Discussions on this
agreement began shortly after the fall of the Soviet
Union and the initial agreements were prepared in
1993. And I believe you recall that this past summer
in June, President Clinton met with Russian Premier
Putin and the most significant thing that came out of
that summit was an agreement to go forward with this
MOX project. And the agreement was formally signed by
Vice President Gore and made effective September 1st
of 2000.
(Slide change.)
MR. JOHNSON: The objective of the
agreement is to take 34 metric tons of surplus
plutonium from the weapons programs and irreversibly
convert them to forms that are unusable for weapons.
In this approach, the U.S. is going to take 25 metric
tons of material and convert it into mixed oxide fuel
for use in commercial reactors and the remaining 9
metric tons would be immobilized with vitrified high
level waste.
The Russians are planning on converting
all of their material into mixed oxides fuel and under
the agreement both of the programs within the United
States and Russia are going to roughly precede and
parallel in terms of schedules and timing.
As part of the plutonium disposition
program, DOE prepared an overall programmatic
environmental assessment that was published in
November of 1999 and following that, there was a
record of decision in January 2000 and in this EIS and
record of decision, DOE evaluated a number of options
for dispositioning the excess plutonium and they
looked at what you could do with it and also the
locations of DOE facilities where these operations can
take place.
The record of decision makes a
determination that DOE would undertake what's called
a hybrid approach that involves making MOX fuel out of
a portion of the surplus plutonium immobilizing the
rest of it.
Under the approach of making mixed oxide
fuel, the whole program involves taking a weapons
pits, disassembling them, doing a chemical conversion
from plutonium metal into an oxide form. The next
phase would be to take that oxide, make fuel with it
and the next phase would be, of course, to use it in
commercial reactors.
For the mobilization project, what that
involves are materials that have significant
impurities that don't make it easily adaptable to
mixed oxide fuel and for this material DOE would
convert the plutonium which is in various forms to a
ceramic form. They would put this material in small
containers and encapsulate those containers in with
vitrified high level waste.
The record of decision also decided that
these operations would take place at the Savannah
River site. DOE investigated a number of facilities
throughout the country for it and settled on the
Savannah River site. DOE also decided to place a
contract with a consortium of Duke Engineering, Cogema
and Stone & Webster Engineering Corporation to do the
mixed oxide fuel fabrication and also be responsible
for using it in the reactors.
MR. SEALE: Excuse me, I probably missed
something earlier. The 34 metric tons that the U.S.
would be reasonable for taking care of here is matched
by another 34 approximately that the Russians will
retain?
MR. JOHNSON: Yes.
MR. SEALE: Where does this set in the
total of the amount of material that we either know or
think that the Russians have that might be --
MR. JOHNSON: I think it's a relatively
small amount.
MR. SEALE: I would think so too. So this
is sort of skimming the oxide slag off the top of the
crucible, I would imagine.
MR. JOHNSON: That's my understanding that
this is a small percentage of the total amount of
weapons material.
MR. SEALE: Yes. I just wanted to keep
the perspective.
(Slide change.)
MR. JOHNSON: This next slide kind of
diagrammatically shows what the overall process is.
The weapons plutonium will come into the Savannah
River site and under DOE jurisdiction and oversight
they will disassemble the pits and chemically convert
the plutonium into an oxide and that material will go
to the mixed oxide fuel fabrication facility which is
under NRC licensing responsibility and from there the
fresh MOX fuel will be used at the Catawba and McGuire
Stations in their reactors.
MR. POWERS: Do you have any insights on
why ICE condenser plants are chosen for this?
MR. JOHNSON: Why these two plants?
MR. POWERS: Yes, I mean they're ICE
condensers, aren't they?
MR. SEALE: Yes.
MR. POWERS: Why are ICE condensers
particularly suited for MOX fuel I guess comes to
mind.
MR. JOHNSON: I don't know if that was a
consideration in the selection of these plants.
MR. UHRIG: I suspect it's more related to
Duke. They operate those, one of the three partners.
MR. POWERS: They operate other things
too. I just wondered if ICE condensers had some
peculiarity about them that I didn't know other than
vulnerable containment.
(Laughter.)
MR. KRESS: You were reading my mind.
MR. POWERS: I saw you grinning over
there.
(Slide change.)
MR. JOHNSON: The fuel fabrication process
is going to involve two primary activities. The first
step is an aqueous polishing. The plutonium that
comes from weapons does contain some impurities,
primarily gallium and americium that are desired to be
removed and in the removal of these materials,
impurities, the proposal here is to use a liquid
process, an aqueous process based on a scrap recovery
process used at the La Hague processing facility that
Cogema operates in France.
MR. KRESS: Does that require you to grind
the plutonium up into a powder?
MR. JOHNSON: The plutonium will already
be in a powder.
MR. KRESS: You receive it in a powder
form?
MR. JOHNSON: Right, it will be received
in a powder. And the first step would be nitric acid
dissolution, a solvent extraction as an oxalate
dissipation step and calcination back into an oxide
form.
MR. POWERS: When you say it's received as
a powder is that because it's coming from the calcium
reduction process as particulates or is it a powder of
oxide?
MR. JOHNSON: Right. DOE is going to turn
over to the fuel fabrication facility an oxide after
they do their conversion.
MR. POWERS: Okay, so we've got some
serious criticality headaches here ahead of us.
MR. JOHNSON: Criticality is one of the
most important parts of our review.
MR. SEALE: Now, are they on the -- to
what extent are those headaches on the NRC side of the
fence and to what extent are they on the DOE side of
the fence?
MR. JOHNSON: Both.
MR. POWERS: If we're going to dissolve a
nitric acid solution and do stuff with it and you're
going to avoid the precipitation problem, you've just
got headaches because you got to control that nitric
acid pretty carefully.
MR. SIEBER: Is this a PUREX type process?
MR. JOHNSON: It's similar to the PUREX
process.
MR. SIEBER: Whose responsibility is it to
control the particle size at precipitation stage?
MR. JOHNSON: It will be --
MR. SIEBER: DOE?
MR. JOHNSON: It will be DCS's
responsibility. What these processes are are
processes that will come under the fuel fabrication
piece of it --
MR. SIEBER: So the polishing is part of
fabrication?
MR. JOHNSON: Correct. And again, this
process is a process that is taking place now in the
La Hague facilities so there is a good deal of
experience in using it and the La Hague designs are
basically going to be used at this facility.
MR. SIEBER: There is a PUREX plant in
Hanford and also West Valley used a PUREX process too.
MR. JOHNSON: Now this is different, a
little bit different than just reprocessing. This is
a scrap recovery process that is used at La Hague.
MR. SIEBER: Okay.
MR. UHRIG: Is the removing of these
impurities because it affects the fabrication of the
fuel or because it affects the operating
characteristics of the plant?
MR. SIEBER: They have a pretty tight
specification for the operator based on operational
use and they want to minimize obviously any impurities
that they can.
MR. UHRIG: It would affect the operating
characteristics of the plant, as well as the waste --
MR. JOHNSON: I think the concern is more
of the operating characteristics of the fuel than the
reactor.
MR. UHRIG: Okay. Americium has a pretty
good cross section, as I recall.
MR. JOHNSON: Right.
MR. SEALE: Could I ask -- the aqueous
polishing is part of the fuel fabrication process?
MR. JOHNSON: Yes.
MR. SEALE: Is it part of the fuel
fabrication process for which the NRC is responsible
for the licensing?
MR. JOHNSON: Yes.
MR. SEALE: So everything on this chart
here, ultimately the NRC is going to have as a
concern?
MR. JOHNSON: Right.
MR. SEALE: For licensing.
MR. JOHNSON: Right. We're going to be
responsible for the oversight of both of these
processes here on the slide.
The next phase after the impurities are
removed, the plutonium would go into more of a
standard fuel fabrication process and with the
exception of the fact that the use here is plutonium
and depleted uranium, rather than low enriched
uranium, the rest of this fuel fabrication process is
very similar to what takes place in a normal uranium
fuel fabrication. There would be mixing and blending.
The material would be pressed into pellets. The
pellets would be centered in a reducing environment.
They would be ground to a specification and then put
in fuel rods and ultimately into fuel assemblies. And
again, this process for fuel fabrication is based on
the existing process now at the MELOX facility in
Marcul, France.
In Cogema, one of the partners in the
consortium has been making MOX fuel for about 20 years
and MOX fuel is being used right now in 35 reactors in
Europe, 20 of which are in France.
MR. SEALE: Could I ask, is that process,
you say it's similar. Does the similarity go so far
as to allow hand contact, or is this a remote process?
MR. JOHNSON: This is a remote process
from the point of getting the plutonium canisters in
from the DOE facility to the point where the fuel rods
are taken and assembled into assemblies. But the
entire operation is done remotely in glove boxes.
MR. UHRIG: Is the enrichment comparable
to ordinary fuel?
MR. JOHNSON: The plutonium percentage
will be about 4 to 5 percent and the rest will be
depleted uranium.
MR. POWERS: In NRC's examination of this
facility, carrying out its regulatory
responsibilities, is fuel quality part of that or not?
MR. JOHNSON: Well, one of the steps in
the NRC program is to evaluate the qualification data
for the fuel. Part of the -- this is outside of the
fuel fabrication project, but in terms of the use and
the reactors, NRC is going to be evaluating that and
like I said it kind of opens up our next slide here.
(Slide change.)
MR. POWERS: Which is the depth of
darkness.
MR. UHRIG: That is a true Freudian slip.
MR. JOHNSON: Yes. One of the pieces in
our review is the reactor piece on the qualification
of the fuel. It's outside of the fuel fabrication
project, but it is something we're involved in and the
steps will be -- they'll be two lead test assemblies
that will be produced and they will be radiated at the
McGuire Station and data from that will be used in
qualifying the entire program and one of the issues
that I can talk about this a little bit later, but one
of the primary issues right now is who is going to
make those lead test assemblies. Originally DOE was
going to use the Los Alamos facility to fabricate the
lead assemblies, but that was changed and right now
the proposal is to use material, plutonium, from the
United Kingdom, have the fabrication done in France
and have that fuel shipped over here.
So yes, part of our program is to evaluate
the fuel use and qualify it for the whole program.
MR. UHRIG: Do you have estimates of the
burn up that would be allowed in fuel of this sort?
Is it 30, 40, 50,000 megawatts --
MR. JOHNSON: It will be on the order of
40,000.
MR. UHRIG: What would the plutonium
content at that point be? Do you have any --
MR. JOHNSON: It's about the same.
MR. UHRIG: Is it generated about as fast
as --
MR. JOHNSON: There are some numbers. I
don't recall.
Peter, do you recall what the numbers are?
MR. HASTINGS: I don't have those numbers
with me.
This is Peter Hastings. I don't have that
number off the top of my head, no. We can get it.
The final plutonium concentration of spent
fuel is about 2.5 percent. The IC topics are
dramatically shifted from 93 down to the 59 range.
MR. UHRIG: Thank you.
(Slide change.)
MR. JOHNSON: Again, the areas of the NRC
review involve the licensing of the fuel fabrication
facility and that is required by law. It was -- the
law was 1999 Defense Authorization Act that required
the NRC to license a plutonium fuel fabrication plant
where the fuel was going to be used in commercial
reactors.
We're also going to be involved in some
transportation aspects. The proposal is that there
will be a new package designed for transporting the
fresh fuel from the fuel fabrication facility to the
reactors and NRC will certify that package.
Again, for the reactors, we'll be
licensing the use of the fuel at the McGuire and
Catawba Stations and NRC would also be licensing the
disposal of the spent fuel at the high level waste
repository.
(Slide change.)
MR. JOHNSON: For the fuel facility, we're
going to be using a two-stage licensing process and
this process falls out of our regulations which
requires us to issue a construction approval prior to
construction. This is a little bit different from the
way normal uranium fuel fabrication facilities are
licensed. It doesn't require approval prior to
construction. And this process is also -- turns out
to be most convenient for the applicant. They have a
requirement to irradiate MOX fuel in 2007 and they
feel that they can best do this by submitting its
application in two pieces. One is a construction
application which is due at the end of this month and
the second would be an operating license application
and that's scheduled to be submitted in June of 2002.
(Slide change.)
MR. JOHNSON: For the construction
authorization, the regulations require that the
application include a site description, a safety
analysis of the design bases of the principal
structures, systems and components and also quality
assurance program. And in order for us to approve the
construction application, we're going to need to
conclude that the environment will be protected and
that the principal structures, systems and components
are going to provide reasonable assurance against
projection for natural hazards and accidents.
MR. SIEBER: When this facility is
finishing processing the 25 metric tons of heavy
metal, is that the end of the facility or would you
contemplate additional processing as time goes on?
MR. JOHNSON: The current program now is
the facility would operate for 20 years. At this
point, DOE hasn't decided what the future uses of the
facility will be, but I mean it is conceivable that it
could be used for additional processing, if that's
what the decision is or it could be deactivated and
perhaps used for other things. But as of right now,
DOE has not indicated what uses beyond the 20 years of
operation will be.
MR. POWERS: Does the disposal or
decommissioning of the facility, is that an NRC
oversight responsibility or does it revert to DOE's
responsibility?
MR. JOHNSON: Under the contract that DCS
has with DOE, the facility would revert to DOE and
DCS's responsibilities would be to deactivate it, to
place a facility in a safe, shutdown mode and then it
would be turned over to DOE and DOE could make
decisions on further use or dismantlement if they
wish.
MR. SIEBER: The EIS does not discuss
anything about decommissioning, I presume?
MR. JOHNSON: Other than what I just said.
MR. SIEBER: Okay.
MR. JOHNSON: Because there isn't a
decision yet that it would be decommissioned after
operation. The environmental report just indicates
that it would be turned over to DOE and final
decisions on its use would be made later.
MR. SIEBER: It seems to me that 25 metric
tons is not a lot of material. I presume that to
operate for 20 years, you're going to have to have
additional feed stock?
MR. JOHNSON: Right. But the project is
really intended to provide about a third of a core for
four reactors for 20 years, so you're correct, it's
not a great deal of material.
(Slide change.)
MR. JOHNSON: As I mentioned, there are
two parts to the whole licensing project. One is
construction authorization and the other is review of
an operating license application. And for the
operating license application, we would address the
overall safety analyses, the detailed design of the
facility, management measures, emergency plans,
physical protection plans and materials accountability
plans.
(Slide change.)
MR. JOHNSON: One the most important
things that's a part of our licensing process is the
preparation of the environmental impact statement.
And this, of course, is required for all major federal
activities and it's also explicitly required under
Part 51 for fuel fabrication facilities. So we are
going to be preparing an EIS for this activity.
One of the benefits we have though, as I
mentioned before, DOE has prepared a programmatic EIS
in a Record of Decision and we're hoping to be able to
use a lot of that material and not have to regenerate
material that's already been done by DOE.
MR. KRESS: In the EIS I'm familiar with,
the nuclear part uses a source term for fission
products.
MR. JOHNSON: Yes.
MR. KRESS: Will you use that same source
term for this fuel, you think, that's used in the
normal EISs?
MR. JOHNSON: Are you referring to Table
S-3?
MR. KRESS: Yes.
MR. JOHNSON: I don't really know the
details of Table S-3, but we'll try to use what's
already been used, if it's appropriate. If it's not
appropriate, we're going to have to generate our own
source term based on information on the design of the
facility.
And again, we're going to try to use as
much of the DOE EIS as possible, but because the DOE
EIS dealt with the facility and the impacts on a very
broad level, there will be a need to review it at the
detailed design level of our application.
(Slide change.)
MR. JOHNSON: The process that we'll be
using is the standard process that's described in Part
51. We've already received the environmental report.
Our next step will be to issue a Notice of Intent to
Prepare an EIS. We'll start a scoping process. Our
intent at this point is to have scoping meetings at
three locations, one in August, Georgia near the
Savannah River site; also in Savannah, Georgia and
Charlotte, North Carolina. The Charlotte, North
Carolina site is so that we can get public input from
people in the vicinity of the two reactors that will
end up using this fuel.
(Slide change.)
MR. JOHNSON: We'll do the coordination
with federal and state agencies and the product of the
scoping will be a scoping summary report upon which
we'll develop a draft EIS, receive public comments and
then issue a final EIS.
It turns out that for licensing, the EIS
is a critical part of our schedule development and our
goal here is to try to prepare a final EIS in 18
months and that's going to be a very aggressive
schedule, but the EIS people think that they can do it
primarily because we'll be able to use a lot of the
information from the DOE's prior EIS.
MR. SIEBER: That's 18 months from the art
of the NEPA process?
MR. JOHNSON: From the application date.
MR. SIEBER: Which is March?
MR. JOHNSON: Which is the end of this
month.
MR. SIEBER: Okay.
(Slide change.)
MR. JOHNSON: The next thing I'd like to
talk about are opportunities for public hearing and I
think you're aware that there's a great deal of
interest in use of MOX fuel and opportunities for a
public hearing are going to be an important factor in
our licensing process.
Basically, because of the two step
licensing in which we receive a construction
application and then an operating license application,
there will be two opportunities for a hearing, one at
the construction authorization stage and this hearing,
if it's -- if one takes place, will be limited to
issues related to our authorization of construction.
And likewise, for operating, those issues involved
with that hearing would be limited to those issues on
which we base a decision on issuing an operating
license.
The intent would not be to relitigate
construction authorization issues at the operating
approval stage. And under the requirements of Part 2,
the hearing proceedings would be the informal hearing
proceedings in Subpart L.
MR. SIEBER: Are NRC folks participating
in DOE's preparation for their part of the EIS?
MR. JOHNSON: Well, DOE's EIS has already
been prepared.
MR. SIEBER: And there's public hearings
going on?
MR. JOHNSON: Well, that's already been
completed.
MR. SIEBER: Everything is done?
MR. JOHNSON: Right, and the record of
decision was issued in January of 2000 on that, but
there were a whole series of public meetings that DOE
undertook in their overall programmatic EISs and those
meetings occurred across the country, primarily
because at that time they were evaluating where these
-- the plutonium disposition activities would take
place and ultimately the decision by DOE was to have
these activities take place at the Savannah River
site.
MR. KRESS: Is there any plants for PRA at
the Savannah River site?
MR. JOHNSON: I am not sure I completely
understand your question, but for the MOX facility,
one of the requirements in Part 70 is to do an
integrated safety assessment.
MR. KRESS: An ISA.
MR. JOHNSON: And that will be applicable
to the fuel fabrication project and it's our
expectation that the integrated safety assessment
would use both a qualitative and quantitative
evaluation as part of their integrated safety
assessment.
Another important activity is public
participation. I think you're aware that that's one
of the strategic goals of our Agency and in response
to that, we've prepared a project communications plan
in December and in there it describes a number of
activities that we will be using to encourage
participation. We obviously have the NEPA process
that involves scoping meetings and other meetings in
going through the EIS process. We'll have two
opportunities for hearings. We'll have periodic
public meetings. Last July, we did have a public
meeting. We had actually two of them. One was in
Augusta and the other was in Columbia, South Carolina
to introduce people to the NRC. People in the
Savannah River area are very familiar with nuclear
issues, but most of them aren't familiar with NRC
licensing activities because their involvements have
been primarily dealing with DOE.
So this was an opportunity for us to kind of explain
the differences in our roles with respect to DOE and
the program.
We've also established a website for the
MOX project. We're going to be publishing a
newsletter. The first issue will be out within the
next two months and of course, there's the normal
availability of ADAMS for other documents. Our MOX
site is intended to allow easy access to some of the
major documents that we produce, but it won't have all
of the correspondence and memorandum related to the
project, but that information can be obtained through
the normal public access to ADAMS.
MR. SIEBER: Who will be the recipients of
the MOX newsletter?
MR. JOHNSON: We have generated a mailing
list and we'll be expanding that as people want copies
of it.
MR. SIEBER: Yeah, but what types of
organizations or individuals are on that list right
now?
MR. JOHNSON: It will be internally within
the NRC. It will also be externally to the applicant,
to DOE and individual members of the public that have
been involved in the public meetings and other
activities and that have requested to be put on the
mailing list. But there are a number of intervenor
groups that have shown interest in this project and
they will be on the distribution list for the
newsletter.
MR. WALLIS: How does the website work?
Is it mostly a source for documents or is it an
opportunity for dialogue?
MR. JOHNSON: Both.
MR. WALLIS: Do you have experience with
the dialogue?
MR. JOHNSON: Well, no, the dialogue piece
isn't quite in place at the present time, but we're
working with our Office of -- our Chief Information
Officer to get that, but the overall objective is to
provide not only a place to go for information and
easy access to some of the significant documents, but
it would also allow comment on documents and allow
people to see the comments and others to comment on
those comments.
MR. WALLIS: It's not going to be a chat
room thing where conversations are carried on, is it?
MR. JOHNSON: Yes, it could be that.
MR. WALLIS: That kind of thing, okay.
MR. JOHNSON: But the Agency does have,
does use that in a number of other of their websites
and it's our intent to adopt that into this.
(Slide change.)
MR. JOHNSON: Some of the significant
issues that we're wrestling with at this point in time
involve a couple of areas. One is technical issues.
Since fall of 1999 we've been conducting a series of
technical meetings with DCS with the objective of
ensuring that we get an understanding between both
parties as to what the application should look like.
Our desire is to get a complete application that will
not require a large number of requests for additional
information.
And these technical meetings have, I
think, have been pretty good. We recently completed
one regarding design bases. As I mentioned, one of
the elements for making a determination on a
construction authorization is to evaluate the design
bases of principal systems, structures and components
and we wanted to make sure we had an understanding of
the level of detail that would be necessary for us to
do the review. And in early January we had a two-day
meeting to talk about that.
Other areas relate to seismic design,
safeguard security issues. We've had discussions on
glove box materials, accident analyses, how to define
the controlled areas and so on.
Another issue I talked about earlier was
the production of lead test assemblies. Again, one of
our jobs will be to review the qualification data that
comes from these lead test assemblies to ensure that
the actual MOX fuel can be used safely at the Catawba
and McGuire Stations.
With regard to security, there are a
number of overlapping areas of responsibility we found
between DOE and NRC on a number of security issues and
clearance issues. This facility is going to be done
under DOE contract. It's going to be done under DOE
site and in order to resolve some of these overlapping
security issues we're in the process of preparing a
Memorandum of Understanding with DOE to outline what
our responsibilities are and what DOE responsibilities
will be.
Another important consideration is this is
really the first application of the revised Part 70
requirements and the new Part 70 introduces integrated
safety assessments which haven't been required in the
past and this will be our first opportunity to really
put an application through the mill on this.
MR. WALLIS: Does that include
transportation?
MR. JOHNSON: Pardon?
MR. WALLIS: That includes transportation,
Part 70?
MR. JOHNSON: No.
MR. WALLIS: It doesn't.
MR. JOHNSON: Part 70 is for the fuel
fabrication facility itself.
Part 71 is the transportation
requirements.
MR. WALLIS: Okay.
MR. JOHNSON: And that will be used to
certify the package that will be used for fresh fuel
shipments to the reactors.
MR. WALLIS: Are you also concerned with
the shipment of the powder or is that DOE?
MR. JOHNSON: Well, DOE is going to be
principally responsible for transporting the powder
from their conversion facility to the fuel fabrication
facility, but once it enters the jurisdiction of DCS,
it will be part of our responsibility. But the
package that will be used will be developed by the
Department of Energy.
MR. SIEBER: I have a couple of questions.
Going back to the lead test assembly bullet there. To
use mixed oxide fuel in a commercial reactor in steady
state is not particularly challenging, but if you have
nuclear transients, particle size makes a pretty big
difference, for example, a reactivity pulse to a mixed
oxide fuel assembly creates a hot particle at the MOX
particle point which could, for example, perforate
clad.
What's the data base that will be used to
assure that specifications for the mixed oxide
materials are suitable to take care of these nuclear
transients and other effects?
MR. JOHNSON: The data base will be the
European experience of 20 years of operations and
also, the qualification data from the lead test
assemblies.
Again, I mentioned earlier that there are
currently 35 European reactors that use MOX fuel and
there is a substantial data base from that and DCS
intends on using that in their fuel qualification
program.
MR. POWERS: I think it is also true,
however, that the isotopic mixture used in the
European reactors is substantially different.
MR. JOHNSON: It is slightly different in
terms of the isotopics and that again is one of the
reasons for the lead test assembly program to verify
the similarities in the actual operation data.
MR. POWERS: In the past, a lot of the
lead test assemblies have been located in fairly
benign locations in the core. We perhaps learned from
high burn up fuel it's not a good idea to do that.
Are we going to locate these late test assembles in
more aggressive parts of the core?
MR. JOHNSON: I don't know the answer to
that, but -- is there someone else?
MR. CARUSO: This is Ralph Caruso from
NRR. Yes, for the retest assembles for MOX, we are
encouraging DCS to load these assemblies in, not
necessarily the limiting locations in the core, but
near the limiting locations so that they're burned in
a prototypical fashion.
MR. SIEBER: Getting back to the hot
particle issue, what comes to my mind is the work of
Battelle Northwest, did it at Hanford in the 1970s on
the plutonium utilization project where they actually
test fuel rods with mixed oxide fuel under some of
these conditions. Perhaps that should be a part of
the database that one uses in order to cite
characteristics the pellets should have.
MR. JOHNSON: A lot of people feel that
the United States just has never done anything with
MOX, but that's really incorrect.
MR. SIEBER: That's not true.
MR. JOHNSON: In fact, in the late 1960s
and early 1970s, there was a substantial mixed oxide
fuel program in the United States.
MR. SIEBER: That's right.
MR. JOHNSON: Although since the 1970s, it
hasn't been used. But you know, your particle size
question is a major concern and that's one of the
critical components in the development of the fuel is
to ultimately get the appropriate particle sizes and
homogenization in the actual fuel pellets.
MR. SIEBER: Right. An additional
question. When you talk about the security of mixed
oxide fuel, when you ship a new unburned fuel assembly
from the fabrication plant to the reactor, does that
follow the rules of shipping special nuclear material
or is it something greater than that since --
MR. JOHNSON: It would fall under the
transportation regulations.
MR. SIEBER: Well, it would seem to me
that some relatively simple chemical processing could
be used to concentrate the plutonium and separate it
from the depleted uranium just as it was put together
in the first place, say as opposed to slightly
enriched uranium where making a more fissile material
is virtually impossible without a diffusion plant or
centrifuge or something like that.
You see what I mean?
MR. JOHNSON: No, could you --
MR. SIEBER: Well, you could take this
fuel assembly, put it in nitric acid, again, run it
through an organic separation process and separate the
uranium from the plutonium.
MR. JOHNSON: This is after the radiation?
MR. SIEBER: No, this is at the point
where it leaves the fabrication plant, before it's
inserted into the reactor. So you end up with high
grade plutonium again after you do that which would be
an opportunity for somebody --
MR. JOHNSON: Right, well, the security of
that shipment will be an important consideration.
MR. SIEBER: Okay. You would take
something like that into consideration?
MR. JOHNSON: Yes. And the security plans
for use at the reactors, as well as the transport will
be a key thing for our review.
MR. SIEBER: Well, once it's installed in
the reactor and becomes irradiated, it actually has
all the same safeguards that normal uranium fuel wold
have. It's too hot to handle easily.
MR. JOHNSON: Correct, and I understand
that the time that the fuel, the fresh fuel is at the
reactor site, they're going to try to minimize that to
the extent possible because that is recognized as a
vulnerable period for that in terms of safeguards.
MR. SIEBER: Right.
MR. JOHNSON: Pete, did you have something
you wanted to say?
MR. HASTINGS: Yes, this is Peter
Hastings. Let me clarify. The fresh fuel shipment
from the MOX facility to the mission reactors will be
in a Part 71 certified shipping container in terms of
safety requirements, but it will be under DOE safe
secure transport and so it will be within the DOE
security provisions and then once it's received at the
reactors, the current plans are to load it directly
into the spent fuel pool and not into a dry, fresh
fuel storage.
MR. POWERS: If we look at this
transportation cask, do we have an understanding of
what happens in the event of an accident on these fuel
rods crushing or shattering?
(Pause.)
MR. RHODES: Yeah, the answer to that is
there's a series of tests for the packages. It's Type
B package and it will go through a series of tests
under Part 71 regulations.
I'm Patrick Rhodes. I'm the MOX program
manager for DOE.
MR. POWERS: That will contain some sort
of fuel rod mock up or an actual fuel rod?
MR. RHODES: The test is going to be done,
we'll have three assemblies, two of which are mock,
one of which is a realistic assembly, a paratypical
assembly and they'll actually measure the distortions
after the drop test.
MR. POWERS: And that's a drop test, how
about accident test?
MR. RHODES: Well, in the Part 71
regulations it specifies the series of tests one has
to do. By analysis, it's fire, it's drop, it's
perforation and puncture and maybe others and it will
by demonstration, testing or analysis demonstrate all
those requirements.
MR. JOHNSON: The remaining issue that is
kind of at the forefront has to do with the hearing
process. Under the regulations you would use the
informal Subpart L hearing proceedings. However,
there are some stakeholders that want to see the
formal Subpart G hearing proceedings used and so I
think that will probably end up getting sorted out as
a -- if there is a hearing.
Did you have a question?
(Pause.)
(Slide change.)
MR. JOHNSON: The next thing I'd like to
talk about is some of the things we've done and our
schedule for the rest of the process.
We've prepared a standard review plan for
review of the mixed oxide fuel fabrication project.
That was completed in August of 2000. I mentioned
that we have a MOX website on line. We've been having
a series of technical meetings with DCS and DOE. We
had the public meeting last July in South Carolina.
In December, we received the environmental report for
the fuel fabrication facility. We expect to get the
application for construction authorization at the end
of this month. We would expect that we can complete
the review for construction authorization in September
2000 so that construction can begin at that time. We
expect an operating license application in June of
2002.
On the reactor side, in order to use the
lead test assemblies, we're going to need to receive
an amendment. That is expected in August 2001. We
expect the irradiation of those lead test assemblies
to begin in October 2003. We expect the license
amendment for the use of the MOX fuel, other than the
lead test assemblies, at both McGuire and Catawba to
be submitted in January 2004 and the objective of DCS
is to begin fuel irradiation in September 2007.
MR. WALLIS: There must be a detailed plan
of what you can learn from this radiation of the lead
test assemblies?
MR. JOHNSON: Yes. NRR and Research are
very much involved with DCS and DCS's contractor,
Framaton in doing the fuel qualifications studies,
that program is -- Framaton had submitted to us an
overall qualification plan that is currently under
review by NRR.
MR. SIEBER: The capacity of the fuel
fabrication plant is such that you could actually
provide reload for four reactors?
MR. JOHNSON: It's intended to provide a
third of a core for each of four reactors over 20
years.
MR. SIEBER: So do you -- is there a
thought about who the other two reactors will be?
MR. JOHNSON: The four reactors are at
McGuire 1 and 2 and at Catawba 1 and 2.
MR. SIEBER: Okay.
MR. POWERS: I'm telling you, there's
something unique about a nice condenser of MOX fuel.
MR. SIEBER: It sounds like it should be
going in to cook.
MR. JOHNSON: Well, that concludes my
remarks. If you have any questions, I'll be happy to
try to answer them.
Basically, I tried to talk about the
history of the MOX program, our licensing process, how
we're going to deal with the EIS in preparation of
that, public hearings, public participation and our
schedules and if you have any additional questions,
I'll try to answer them for you.
MR. POWERS: I have a comment for -- not
for you, but for the rest of the Committee. If you
look at the schedule, you see that it goes out to 2007
which means that most of the Members on the current
Committee will not see the end of this process. So
we're going to have to establish some sort of a
procedure for continuity throughout this so that
people -- the institutional memory is going to atrophy
if we don't do something fairly formal in this
process.
We need to struggle with that, actually to
the extent of going through a documented plan to
assure that we have some continuity in this process.
MR. SIEBER: I think that that is a good
point. I think that we're going to have to have some
kind of a subcommittee meeting early this summer or
late spring and that certainly is one of the things
that we will need to address at that time.
I think the other one is the Standard
Review Plan. We should probably attack that the same
way that we addressed license renewal where we divide
up the section among the members so that each of us
has an expertise and a certain part of the review
process and I know that I have a copy of that SRP, but
I don't know if it's been distributed to -- everybody
has it.
MR. SIEBER: I think -- well, it's not
that big.
MR. POWERS: Are you going to be asking
the reactor fuels subcommittee to look at these LTA
amendments?
MR. SIEBER: I think that last week when
we redistributed the work amongst the various
subcommittees of the ACRS, the fuels folks actually
inherited a substantial portion of the overall
responsibility for completing ACR's work with regards
to the facility. On the other hand, at the same time,
fire protection is heavily involved and that's why we
got the assignment initially. So I see us working
together and perhaps even forming a special ad hoc or
special subcommittee just to handle issues here.
I also would point out to me the schedule
seems very aggressive, which means that there will be
a fair amount of work, both on the part of the NRC,
DOE, the applicant and the ACRS and so I think it's
important for us to keep that in mind so that we don't
end up impeding progress on this process.
Does anybody else have any comments at
this time?
MR. LEITCH: There's a sense here in the
Standard Review Plan that -- in the Executive Summary,
that I was just wondering if you could expand upon a
little bit. It says the NRC staff has attempted to
ensure that this SRP is consistent with the
requirements of on-going rule making. Could you say
a word or two about what that means?
MR. JOHNSON: Yeah, basically what that
means is our schedule for producing the standard
review plan was actually ahead of the promulgation
schedule for the revised Part 70. And we tried to
incorporate the thinking that was going into the
revised Part 70 as we went ahead, even though it
hadn't been finally promulgated.
MR. LEITCH: Thank you.
MR. JOHNSON: And it turns out, I think
the revised Part 70 was ended up promulgated a month
or two after publication of the SRP, so there wasn't
a great deal of time and change between the two
products.
MR. LEITCH: Okay, thanks.
MR. SIEBER: I guess at this time I'd like
to ask if since we have DOE representatives here, if
they have anything they would like to state or add to
the presentation?
MR. RHODES: Thanks for the opportunity.
My name is Patrick Rhodes. I'm the manager of that
activity. Let me first start with a couple of little
minor corrections.
Tim said the facility will operate for 20
years. Actually, that is its design operating
lifetime, but we're actually only expecting it to be
12 or 13 years. We're expecting initial production in
2007, final production in something like 2019.
Second one is this facility is designed
nominally for 70 metric tons, heavy metal throughput
per year which is more than enough for six or seven or
eight reactors. Realistically, if one wanted to push,
I'm sure we could even get more through it than that.
When this contract was originally awarded
to the DCS contract, the contractor, there were
actually two other plants, the North Anna plants were
also involved which are not ICE condenser plants, so
it just happened to be a coincidence if the ones that
were resolved, had returned, actually are ICE
condensers and consistent with the comment the fact
that ICE condensers had no bearing on the selection
per se.
The last thing I would like to comment on
is what the gentleman said, it seems aggressive and
indeed it is, but rightly so. This is something that
the National Academy of Sciences has dictated to be a
clear national, clear and present danger, both to the
United States and for the world. There are large
amounts of inventories in the United States and Russia
to get rid of. Nobody has really advocated or
suggested the U.S. materials are in any way, shape or
form going to be unsecure. However, people don't make
that same comment about the Russians and the way to
get the Russians to make their moves, to make their
stuff secure so it's not available for theft or
diversion, to give it to us first.
MR. POWERS: Let me ask you a question in
that regard. We have a cooperative agreement with the
Russians dealing with space stations and what not and
they have been consistently tardy in their
contributions on things. Will Russians be similarly
tardy in this?
MR. RHODES: Well, if you're relying on
the Russians to pay for it I think absolutely the
answer is yes, but the agreement that was signed in
September required the United States in concert with
the G-8 nations to secure funding and financing for
the Russians to do the activities.
The biggest problem for the Russians in
meeting their obligations under many nuclear
activities around the world really has been a lack of
resources. They're basically a bankrupt country when
it comes to finding funds for major activities. So in
this case, the Western nations are going to fund the
lion's share and perhaps all of the Russian activity.
VICE CHAIRMAN BONACA: I wasn't here
during the presentation, so I apologize for that, but
I had a question regarding in reviewing somewhat the
Standard Review Plan, there is an establishment of
quantitative guidelines for use with acceptance
criteria based on the highly unlikely and highly
likely frequency of events, etcetera. It is not a
probabilistic approach to this establishment, is it?
Or is it just the traditional approach that is being
used?
MR. JOHNSON: Well, the approach that will
be used will be consistent with the regulations in the
revised Part 70 and I mean we haven't gotten the
submittal yet, so I can't really say in detail how all
of that is going to be resolved, but the requirements
would be for the applicant to describe how they meet
the highly unlikely and likely scenarios in their
integrated safety assessment.
VICE CHAIRMAN BONACA: It seems more of a
standard approach.
MR. JOHNSON: Now we anticipate that
they're going to be using kind of a combination
qualitative and quantitative approach for this, so it
will -- it looks like it will involve both aspects.
VICE CHAIRMAN BONACA: Thank you.
MR. POWERS: You are allowed under the
Commission's policies to ask explicitly for risk
information. Are you going to do that?
MR. JOHNSON: I think we can ask for
information that we need to review the application
under the regulations. And I guess if that means
asking for specific risk information, I think it's
legitimate in asking that and requesting that.
MR. POWERS: But you don't have any plans
to do so right now?
MR. JOHNSON: I think it will be dependent
on when we see the application and what is in there.
I think it's a little premature to say exactly what it
is we're going to be asking for at this point.
MR. KRESS: I think you'll find that the
ISA process is a qualitative risk information.
MR. POWERS: And many of us feel that
qualitative risk information is an oxymoron.
(Laughter.)
MR. KRESS: Right. Let's go a little
further, it's semi-quantitative --
CHAIRMAN APOSTOLAKIS: Semi-oxymoron?
(Laughter.)
MR. KRESS: Semi-oxymoron.
MR. POWERS: I think Stan Kaplan had a
statement on that. If you're having trouble
quantifying things, go figure out a way to quantify
it.
VICE CHAIRMAN BONACA: But the guidelines
are quantitative. That's what it says here.
MR. LEITCH: At what point in time will
they be submitting the ISA?
MR. JOHNSON: Will they be submitting
that?
MR. LEITCH: The ISA.
MR. JOHNSON: The complete ISA will be
submitted with the operating license application. The
construction authorization does require a safety
analysis of the design bases, so there will be kind of
a partial, but not the finished product ISA. The
construction authorization will include a safety
analysis, will look at some of the ISA matters, but
the full, complete ISA will be submitted at the time
of the operating license application.
MR. SIEBER: Are there any other further
questions from the Members or comments?
If not, thank you very much for your
presentation.
Mr. Chairman?
CHAIRMAN APOSTOLAKIS: Thank you, Jack.
Thank you very much again. We will recess until 12:45
where we have the reception in the room there, but
several of us will be interviewing candidates.
(Whereupon, at 11:23 p.m., the meeting was
recessed, to reconvene at 12:45 p.m., Friday, February
2, 2001.)
. A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
(12:50 p.m.)
CHAIRMAN APOSTOLAKIS: It's a great
pleasure to welcome the Chairman of the Commission,
Dr. Meserve who is here to tell us what is happening
up there and what his priorities are, so maybe we can
adjust our priorities. So without much ado, I will
turn it to you, Mr. Chairman.
CHAIRMAN MESERVE: Thank you, George.
Actually, I arrived here with a little trepidation.
Usually, the circumstances are different. There are
five of us on the other side of the table and we get
the chance to ask all the questions and I could
realize that this is an opportunity to turn the tables
on me.
(Laughter.)
George had asked if I would come in, as
he's indicated, and give you some sense of my feelings
for the priorities of the Commission over the coming
year and I'm going to do that, although let me start
out by saying that what I said a few minutes ago in
connection with an event for Bob Seale is that we do
extraordinarily value your input. It's very, very
important to us in the process.
And in that context, we want you to give
us your best advice. Call them the way you see them.
Don't worry about the consequences of it. Your job
is to give us the best advice and we'll have to deal
with it. I recognize that on occasion that may mean
you're passing us a few hot potatoes, but that's
exactly what you're supposed to do and I am never
going to criticize you and I don't think my colleagues
are for giving us a straight shot on the issues that
you deal with.
As I go through a couple of the issues
that I see as ones that are important to the
Commission over the coming year and I would like to --
I will leave plenty of time for questions. I think
most of the things I'm going to mention are going to
be things with which all of you are fully aware and
are not going to be a surprise. I will try to give
you my sense of the context in which I think the
Commission is going to be dealing with some of these
issues in the hope that that might be of some interest
to you.
First, I mention license renewal. This is
a very high visibility issue for the Commission. As
you know, we all had some challenges that were being
presented to us by the Congress, a number of years
ago, and we had pledged that we were going to make
decisions with regards to these license renewal issues
within a designated time period. That doesn't
obviously preclude us from saying no to some. We may
find that to be necessary. But we are trying to abide
by the time lines for this in that people are
monitoring whether we are able to do the job within
the time that we've allowed ourselves.
I am concerned that that is going to be a
challenge for the Commission, particularly as the
queue of plants gets longer and larger. There is hope
in anticipation in NRR that efficiencies are going to
arise out of that process and the generic lessons
learned is obviously an effort to try to find a way to
take some issues off the table if that's possible, to
do that.
We'll see if that has been effective. As
all of you know, we've heard from, on some of that
that report may not be as effective in achieving that
goal as we might have hoped. We'll see.
It is essential in that process obviously
to look at the aging issues that we get strong,
reliable, technical input on matters there. I know
that you are involved in that. There's going to be a
continuing challenge for you as well as for us because
of the fact that as the queue gets longer, and the
number of applications in our process get larger,
that's going to increase the burden on you. I hope
that it gets something that is more routinized as time
goes on and that it will facilitate that, but I am
conscious of the challenge that we're presenting to
you. And this is an important area for uss, not only
because of the importance of doing the job, but also
because we're being assessed in terms, at least the
timeliness of our action in that area.
The second area I'd mentioned and I know
this is one that is an area within which this group
has been very helpful in its briefing to the
Commission and that is our efforts to risk-inform our
regulatory system. It is apparent to all of us that
we are feeling our way into that process and it is
proving, perhaps, to be a more intricate and
challenging task than some might have expected. You
might have had the wisdom to see what we were getting
into.
I'm not sure that all of us on the
Commission side of the table had an awareness of that,
but we clearly have a serious technical challenge in
order to think through our regulatory system,
particularly where the regulatory system is so
interconnected and to be able to make a change in one
area without having implications you haven't thought
through, at least, in another area in making sure that
you can do this in a sensible fashion. At one point
I think we had talked with this group about whether a
clean sheet of paper might be an alternative approach.
The problem is that would be such an immense task,
we'd be many, many years until we could make progress
on it. So I think that the incremental approach that
we're taking is the right one and we're learning as we
go through it.
But it's hard for me to tell at this
juncture how fast the pace is going to be, but this is
also a high visibility issue and it does seem to me it
is one that is very important for the Commission
because it provides us with a principled way to think
through our regulations and decide which ones can be
reduced for purposes of efficiency, give us confidence
that what we have is either adequate or needs to be
supplemented and there is the prospect here for sort
of a win-win situation for modifying the regulatory
system in a way that gives us improved confidence that
we're achieving our objective of protecting public
health and safety while simultaneously perhaps in some
areas, reducing the burden of licensees where it's
needless to have that burden.
And it gives us a principled way in which
to go through that analysis. Of course, we have had
the benefit of 25 years of work since the WASH 1400
and probabilistic risk assessment. We've always been
using it in some fashion in our efforts, but this is
a more systematic way to include it. And we should do
it. The learning is ripe enough to allow us to take
that step.
We're clearly going to encounter some
problems along the way. We have one that we have to
work through now with the fire protection standard,
for example, where we're headed off in a direction on
that with a standard in which it appears from the
letter we've received the Nuclear Energy Institute
that there may be no takers on our efforts to take a
different approach.
So that there are going to be those sorts
of pitfalls that we're going to encounter along the
way and we're going to have to work our way through
them. Again, this is an area where the insights that
this group can bring to bear and has brought to bear
in the past is going to be very important for the
Commission in trying to help us work our way through
the challenges that this effort provides.
This is going to be a continuing challenge
because I'm sure that this is going to be a decade or
more of work for the Commission as it does its job.
I say in the anticipation of at least the early
efforts are ones that we're going to view as
successful and therefore we should continue. But if
that's the case, then this is something that's going
to be a continuing challenge for us and one that --
which your help is going to be essential.
The third area I'd mention is the
challenges that we confront in reactor operations.
And there are many. We have issues with the steam
generators. I know that there's a report that you
have on that issue that at least I understand it's
headed toward EDO.
We have the revised reactor oversight
program and our evaluation of that and the development
of improved performance indicators. We have the spent
fuel risk study which is intended to provide a
foundation for rethinking recommissioning regulations.
We're going to have to grapple with that. We have a
whole series of things that relate to the interest of
operating plants to go to higher burn ups on fuel,
power-up rates and things of that nature.
We confront some near term challenges on
those and let me say that I think that the pressure on
us in many of these areas is going to increase and I
say that because I think that the political fall out
from the California situation is going to be one where
there is going to be great interest in assuring that
existing plants are in a position to contribute and
there will be great interest in power-up rates and
improvements in longer burnup capacity and so forth as
a result of that.
And so I would anticipate that this is
going to be an area in which there will be, if
anything, increased interest by the licensees. The
economic interest was already there, but there will be
increased interest as a matter of energy policy of
making sure that we can squeeze as much power from
existing power plants as we can in a safe fashion.
And so there is going to be, this is going
to be an area where I would expect there is going to
be a variety of influences on us to be looking at this
very carefully.
Obviously, none of us want to go beyond
any point at which we're comfortable with adequate
protection of public health and safety and we will not
do that, but we're going to have to look at the issue
very carefully and I anticipate some changes there.
And if anything, that's something that I think the
emerging situation in California may result in some
heightened interest in that area that may have some
spinoff effects for you, as well as for us.
The related issue as I go into the
political context, is something that I think would
have been unthinkable for anyone to mention a year ago
and that is the prospect that we may have some new
construction in the United States. We have had -- the
Commission has been visited by representatives of
PECO.
There was a meeting the other day that
Research held on the PBMR reactor and obviously
there's interest in that. It was a prospect that if
events go in South Africa as the utility hopes that
this may be something that will be advanced in the
United States. There obviously is interest in light
water reactors and upgrades in those of various types
that might also be pursued. And so I think that this
is something that would have been, I say, unthinkable
a year ago.
Nobody was talking about the prospect that
we might have new construction in the United States a
year ago and it's now being looked at seriously by
people who are thinking about the prospect they might
put some money in this. This, too, I would imagine
and would expect is going to be affected by the
California situation and that there will be no doubt
there's interest in the Congress and in an energy
policy that will encompass a large number of areas.
Nuclear, I would expect, if I don't know
any more than any of you on this, Nuclear is likely to
be a component in that and exactly what shape this
takes is of course uncertain, but one would expect
that there will be interest in the prospect of a
portfolio of energy technology and that may well
include nuclear interest, encouraging and creating an
environment where to exploit nuclear when and if it's
appropriate to do so.
I think that that is perhaps a longer term
issue for us, but it is something that obviously, ACRS
is going to have to be in the middle of.
We have made an offer to participate in
some fashion in the events in South Africa. We did
that originally with the idea that we would -- the
intention as we understood it was the South Africans
were trying to use the risk-informed approach to
thinking about this reactor. We thought that we would
gain from involvement in that exercise.
Perhaps at the initial stages we didn't'
realize that it might truly ripen into something that
might come home to the United States, but it's
premature to say that. But we are, at the staff
level, are going to be basically intensifying our
efforts on PBMR and alternative concepts with the need
to prepare today for the possibility that we may have
to be dealing with issues in the future and that will
include, of course, not only the technical side, but
also making sure that we have the regulatory apparatus
in place so we don't place needless impediments on new
ideas, but are able to regulate them in an efficient
and effective way and provide adequate assurance of
safety.
I'll just mention two other areas and then
throw this open to questions. One of the other areas
is research. When I came to the Agency, now about 15
months ago, one of the data points that I checked on
before I came here was to look at the research
situation at the NRC, at least in an aggregate form.
And I was concerned to see a program that had fallen
from a level of about $200 million in the 1980s down
to something that's about $40 millon today.
Even to deal with the existing fleet of
reactors and dealing with issues, embrittlement
materials issues and embrittlement type issues, higher
burnups, MOX fuel, it was clear to me there were a lot
of areas in which we were necessarily going to have to
tread in which we would need a technical foundation
for it being able to make decisions and I was
concerned about that.
We have two groups that are looking at
research. Ken Rogers is leading a group of outside
experts that has been examining the research
enterprise and I know that you have a report that is
headed in our direction this spring that is also going
to be directed at the research enterprise.
And let me say for my part in it I think
for the remainder of the Commission, I can say that we
are going to look at those reports very carefully and
to make some decisions as to what changes we should
make in that area, so let me suggest that that's an
area where -- I am thinking outside the box by this
group and by Ken Rogers' group is going to be very
welcome in that we are going to take that very
seriously and I anticipate that we will be holding a
Commission meeting that will be focused on the
research after we receive these two reports for the
purpose of our making, perhaps, making some decisions
for change in that area.
This is obviously of a different, sort of
broad public salience than the other issues I've
mentioned, but I think it's an underpinning for a lot
of our long-term success is our making sure that we
have the capacity to be able to answer the questions
that we're confronting today and even more importantly
that we have a research foundation to be able to look
at the issues that are over the horizon for us today.
I had been worried in our research
program, for understandable reasons, that over time
we've gotten increased emphasis on being a -- doing
confirmative research, what we cal lit internally here
which is basically being available to answer questions
as they're presented from NMSS or from NRR, rather
than the harder job of looking over the horizon and
seeing what's coming.
Having that capacity to do what they call
anticipatory research is an essential thing for us,
just because of the long lead time to be able to get
results in the research area. You need to have some
capacities to be able to ask the questions before the
people who are doing licensing decisions ask them, so
that you have some information in place that can guide
the decision process.
Your insights about this program are going
to be very important to us and I think that is,
summing it, is essential for the long term of the
Agency.
The final thing I will just mention
quickly and it's of a different nature than us is that
we have -- anticipate that we will be getting an
application for mixed oxide fuel fabrication facility.
I read in the Energy Daily that that may have some
environmental issues associated with it that are
different from those that we had, I guess, understood
were going to be the case and it's a lot more liquid
waste that we may have to deal with in that facility.
We are obviously, the purpose of that is
so that we can take surplused plutonium from weapons
and then turn it into mixed oxide fuel and then burn
that in some reactor so there is the counterpart issue
of using mixed oxide fuel in some reactors which
obviously is going to raise some technical questions.
We've been getting mail on that issue and
that is another area in which I anticipate that this
group is going to have to be providing us with some
insights and again it will be welcomed to us because
that's moving us into some territory and it's a little
different in the things that we've been regulating in
the past.
With that, I'll close. Again, I would
very much welcome your questions and let me say again
how much I appreciate your work.
CHAIRMAN APOSTOLAKIS: Thank you, Mr.
Chairman.
Do Members have any questions?
MR. POWERS: I have a couple of things i
would like to bring up. We are moving in the
direction of risk-informed regulation and this group,
of course, is enthusiastic about that. But I will
comment that one of the things that surprises us about
risk-informed regulation is how far we've been able to
get with so little risk information into the process.
One of the areas you mentioned was fire
protection and I'll remind you that I don't think you
were a Member of the Commission at the time, that when
we first looked at the performance-based ideas that
NFPA was advancing on fire protection, that we said
this is not meeting the NRC's needs and they really
need to start thinking about how to make fire
protection risk-informed as well. And I think it's
possible to do that because of the structure of the
regulations are well built for fire protection.
Another area that this continues to
interest this Committee is the area of risk during
operations other than normal operations. And
particular risk during shutdown operations. Our own
feeling is that if one is really going to look at this
risk informing the regulations in a unit by unit basis
because of the tendrils of any given regulation into
other regulations, you're going to need a
comprehensive risk assessment. And one can't help
wondering if it isn't useful to at least have a couple
of people sitting down and thinking what does it take
to do a clean sheet of paper approach while you're
carrying on this more incremental approach?
CHAIRMAN MESERVE: You may be right that
as to the -- doing something in parallel, there may be
insights that come from one that bear in the other
that could be useful. I think that this has been an
area in which we have been resource constrained and
therefore have, as much as anything, I think have
taken a path in order to not be duplicating effort and
maybe that's a wrong strategy. I'll raise it.
I am very much aware that all of you as I
think as all of our staff has got concerns about
making sure if we go forward on risk-informed
regulatory approach that we have PRAs on which we can
rely for doing that work. And you know, there has
been this effort in developing the ANSI standard for
PRAs, the NS has got its work underway and I think
that all of that is something -- it's unfortunate it's
been moving so slowly, but it is the -- it obviously
has to underlay what we're doing in this area.
You do mention the -- you did mention the
fact that we ought to be concerned about the risk at
all stages of operation and we have, as I think you
know that is particularly in the low power and
shutdown risk that that is an area that I share your
views, that this is something that perhaps we ought to
be looking at more seriously than we have in the past.
MR. POWERS: If I can just continue one
other step and then ask a little more controversial
question, but I'd appreciate, maybe you've got some
insights that I don't have.
You have spoken about the California
situation and it may be a renewed interest in the
potentialities that nuclear power offers for the
country and its energy mix and even spoken of the
potential of using commercial nuclear plants to aid us
in ridding ourselves of excess plutonium beyond any
logical defense needs.
Do you have any sense that there's any
interest in reprocessing fuel?
CHAIRMAN MESERVE: I'm not aware of any
one prepared to enter that debate. Right now we have
a narrowly focused effort on this MOX facility that is
to deal with the plutonium that you would like to be
able to put in a state where it doesn't present a risk
for generations. And that that is the objective.
I don't think that there is anyone who is
seriously considering the reprocessing option now and
of course that's largely driven, I think, at the
moment because uranium fuel is so inexpensive and
there seems to be such an abundant supply and an
overcapacity internationally, at least, in terms of
enrichment capacity, that the situation is one that it
would be economic reasons alone you'd have lots of --
you don't have any pressures to be thinking about
going to a plutonium fuel cycle.
MR. POWERS: Whereas, as you said, we have
an abundance of supply of the input to the process,
we're rapidly running out of supply of things to
handle the output of the process and that is a major
headache that you have ahead of yourself.
CHAIRMAN MESERVE: That's true. I mean
that's a much different fibrillated problem by dealing
with the back end of the process. And we're in a
situation where we await decisions that get made with
regard to Yucca Mountain on that.
CHAIRMAN APOSTOLAKIS: Any other comments,
questions?
MR. POWERS: I'd also like to kick in a
couple of other comments, least there be any -- maybe
we need to realign our wheels. You spoke of the
research report. We are preparing a research report
in which we did not plan to speak at all to the issue
of the way RES is organized. We would speak in this
report to the technical content of the work of
research and perhaps some of its relationship to the
line organizations, but not to anything about the
organization and feeling that if there were things to
be said in that regard, it might be better for the
Rogers committee to speak to that issue than
ourselves. We have addressed the issue in the past
and didn't plan to in this report. If you want us to
do something different, speak now or forever hold your
peace.
(Laughter.)
CHAIRMAN MESERVE: Let me say that I would
welcome this group, giving us advice, broadly as it
chooses on the research area. If whatever reason you
conclude that there are certain areas that you don't
want to intrude upon, be covered elsewhere or that for
whatever reason you think that might delay the report
significantly to get into other areas, I will
understand that.
We do have the benefit of the Rogers
effort and so we're going to have no doubt some
overlap and presumably some areas of nonoverlap
between the two reports. So I am not asking you to
redirect your report, but let me just say and repeat
again what I had said earlier is that we are prepared
to receive your recommendations in the research area
wherever you choose to provide them and if you have
views in areas relating to organization that you would
like to provide us, then that's fair game. But I'm
not asking you to redirect your effort.
MR. POWERS: Okay. We are trying to
coordinate loosely with the Rogers committee in the
sense of community with them over what they're doing
and what we're doing and I think I can say with some
confidence that the overlap is minimum.
MR. POWERS: Okay.
MR. SEALE: I think it's also true that
there's not anything in those earlier research reports
that we would disavow at this point.
MR. POWERS: Not a thing.
MR. SEALE: So to the extent that it's not
addressed in this report, if you go back and find it
in an earlier version, it's pretty much on mark as far
as we're concerned.
CHAIRMAN MESERVE: You might want to say
that in your report.
CHAIRMAN APOSTOLAKIS: Any other comments,
questions?
MR. LEITCH: Chairman, it's a little off
the topic, perhaps, but one of the things that
concerns in the broad sense is the aging of the people
in this industry and the technical skills that seem to
be leaving, perhaps by retirement. Maybe it's Dr.
Seale's retirement party that makes me think about
these issues, but do you sense any difficulty in
attracting the brightest and best people into this
industry today?
CHAIRMAN MESERVE: I think this is, I
didn't mention this as one of the issues to mention to
you, but as an Agency, this is clearly a very serious
issue for us. We have six times as many people over
60 in this Agency as we have people under 30. You can
-- you go to some important parts of the organization,
Research, NRR, there's an order of a quarter of the
people who are fully eligible for retirement, could
leave today, full retirement. And those numbers, of
course, are growing as time goes on.
This is, in part, the consequence of the
fact that our budget has been going down and
allocation of full-time equivalents has gone down.
Until the last year, we managed to get real growth in
both, very slight real growth in both. And we managed
that through attrition in that we have not had the
opportunity to bring in as much as fresh blood as we
would like to in terms of being able to strengthen our
capacity.
I have talked to people in the industry
and of course, they are confronting exactly the same
problem and that we're drawing from the same pool of
people. The data I've seen is that we're producing,
this was nuclear engineers alone, I've realized we
draw from broader communities, but the national
production of nuclear engineers -- if I have the
figures right, is in the order of about 240 a year and
the jobs from the industry are in the order of 600.
So that's without considering our demand. So we
confront a very serious challenge, both at the NRC and
the nuclear energy industry more broadly. It's a
pipeline problem.
I think that time may correct that in some
sense there's always a lag time is the problem in that
there are economic signals that are going out that
weren't there a year ago that if you go into this
field there are going to be jobs. And there's a
future with life extension of plants, as a possibility
you can go to work for a given utility and you may
have a career, rather than a plant that's going to be
terminated early.
So I mean the context is different, but
it's going to take a while until that builds into the
system. To try to deal with our problem, I have asked
for the EDO to provide basically a plan of attack for
us on this issue which has just arrived on my desk.
And it's going to start with trying to assess the
areas in which we have a perceived need, have
competency over the years and seeing where we are in
each of those and how we backfill and try to generate
a plan for being able to deal with that.
I am hopeful that we may be a beneficiary
of the fact that as a country we're going to start
looking seriously at energy issues again and that
there will be concern about this issue at the
political level that may make it possible for us and
other agencies to be able to address serious manpower
issues that we, as a society as a whole confronts in
this area.
I hope that's the case, but we're clearly
going to have a short term problem at the least.
MR. SHACK: Just in the context of our
research report, one of the issues that always arises
as we go through this is when does the NRC need to do
the work and when do we accept the data from industry?
Our plants are basically built and licensed on designs
and data from industry, but you mentioned, for
example, embrittlement of pressure vessels. If a
utility wants relief so it can go through a different
pressure temperature start up or use a master curve
approach, are you comfortable with them supplying the
data? Do you feel that there's a need for the NRC to
independently assess these issues? Do you have any
feeling for when we ask for independent verification
and when we don't, because it's always an issue in the
research area.
CHAIRMAN MESERVE: I can't give you an
informed view of that matter. It is clear that sort
of fundamental things that are essential for safety,
we need to have some independent capacity to be able
to judge, things that are longer termed efforts, more
generic than cooperative ventures with industry, for
example, would be something we ought to encourage
maybe more than we have in the past as it gets down to
more specific licensing issue than perhaps a little
more distance capacity to be able to look very
carefully and be able to confirm that information is
necessary.
I agree, it's a very tricky issue in it's
not one that I can -- I feel capable to provide very
much light to illuminate it for you. I think that --
I suspect that this is an area where you're going to
have -- I hope you will have some insights for us in
your report.
How's that for turning the table?
(Laughter.)
I'm sure we wouldn't let you get away with
that.
(Laughter.)
To answer this real quickly, no, we don't
need any more data on pressure vessel integrity.
(Laughter.)
CHAIRMAN APOSTOLAKIS: Robert Uhrig.
MR. UHRIG: You alluded a few minutes ago
to anticipatory research and yet we are getting the
signal, both directly through speeches and indirectly
by word of mouth that other Commissioners have a less
liberal view on this, specifically saying each
research project should have a very defined end
product, this type of thing. I wonder if you could
address this a little bit.
CHAIRMAN MESERVE: Well, let me say that
the background for all of our activities and the
thought process we have to follow is that for the most
part our budget is one that is paid by our licensees
and that puts pressure on us to make sure that above
and beyond the pressure that every Agency feels to be
efficient and effective in the expenditure of funds
and the danger is that the more the research is
anticipatory, the more vulnerable it is to being seen
as not being related to a real industry need. That
may not prove to be the case, of course.
The whole reason you're doing anticipatory
research is because you believe it's going to be an
important need that the Agency is going to have to
confront to deal with things that our licensees
present to us in the future, but the reason it's not
a present demand from NRR and NMSS is because it's not
one that's being currently presented to them. So
there is a vulnerability to the fact that why in the
world is the NRC involved in that area? We don't have
any requests to you in that area.
I think that this is an issue which I
talked to my colleagues about and I think that -- I
think there is a recognition of the need for
anticipatory research. There may be varying degrees
of enthusiasm for how far you get into it, depending
on the fiscal situation and let me say that this is an
area that one possible solution might be to try to get
at least some of the research that's funded out of
general revenues, rather than from fees. And I can't
speculate as to whether that's like, but that is one
way out of the impasse.
MR. UHRIG: Another related issue, we have
heated debates at times about who should do the
research. There's an argument that the utilities
benefit from it, they should do the work themselves
versus this is something that's important to the NRC,
therefore NRC should support it and then there's the
middle ground in between that's -- sometimes it gets
lost because nobody picks it up.
CHAIRMAN MESERVE: I think this relates to
the matter we were just talking about a moment ago
about the degree to which the NRC can rely on on
industry data that's very into that is who should be
the performer of the research. And I think it has a
lot to do with the extent to which the data is
critical to an individual license application and
obviously we need to have -- that's a cost that should
be born by the licensee initially.
We need to have a capacity to be able to
verify its accuracy and have to have a sufficient
knowledge of the field and of the data to be able to
do that, as opposed to something that's a much more
generic issue in which there is, that maybe no one was
prepared to pick it up. It's sort of a commons issue
in which there may be a -- might be appropriate for
the NRC, recognizing that the work has to be done to
play a role.
I don't -- there's a separable question
there as to who the performer is. They decide that
the NRC should support it, but then there's the
question of where the work should be done. I think
that with a wide variety of possible sources and
obviously, to my mind that depends very much on where
we can get the work done most effectively and the most
reliably. We should obviously use international
efforts to the extent we can. I believe, just because
of the cost savings that we can and they have
facilities abroad that we may not be able to replicate
here. So it's a complicated set of parameters you
need to consider in making a decision.
CHAIRMAN APOSTOLAKIS: I have a couple of
comments, too. We discussed earlier the issue of PRA
quality and the need to do PRAs for modes of operation
other than power. I think another related subject
that perhaps has not attracted as much attention is
the use of codes and tools that have been developed by
various industrial groups, consulting firms which are
being used and the agency really hasn't to my
knowledge reviewed them or used them in some way to do
make sure that what they do is reasonable.
The measure seems to be that if this code
is used by a lot of people it must be good and I think
it's important to have some mechanism to make sure
that what these codes produce is reasonable.
Now to go all the way and say that these
codes, the PRA codes should be blessed by the NRC the
way thermohydraulics codes have been in the past,
maybe that's not the answer either because then to
change something is a major headache, but I think we
need to find a way and of course, most of these are
proprietary, you really have to buy them to --
although some companies are wiling to give them to you
for free, but even then it takes some effort and
resources to run them and find problems.
I think that tools that we as an industry,
as a community are using to assess risks have to be
subjected to some scrutiny so that as a community we
will feel that yes, this particular computer program
produced something reasonable that can be used under
certain conditions. And right now we don't do that.
We just rely on reputation and number of users and so
on, so I think that's an important consideration and
the committee, I think, will say something about it,
at least in the research report and maybe in other
forms as just information.
CHAIRMAN MESERVE: George, on that point,
are there some specific areas for codes that you're
talking about? Obviously, we heard from you on the
thermohydraulic codes.
CHAIRMAN APOSTOLAKIS: Yes.
CHAIRMAN MESERVE: He have effort
development in PRAs.
CHAIRMAN APOSTOLAKIS: I think they do a
lousy job calculating importance measures and this is
the central part of option 2. And the utilities are
caught in the middle. They go out, they buy one of
the best according to reputation and so on and now
here comes the ACRS and says no, you have problems
with the code and they have invested a lot of
resources doing various things that are required by
the regulations and I think somehow we have to avoid
that in the future and make sure that the tools that
are out there are doing what they're claiming they're
doing.
CHAIRMAN MESERVE: You have something
coming to us in this area?
CHAIRMAN APOSTOLAKIS: If I convince my
colleagues at some point.
(Laughter.)
MR. POWERS: George, we may go on from
this to even build upon this, not only do we have
these peculiar importance measures that are somewhat
historic in their generation, we have alternatives
proposed by licensees that no one seems to take
seriously.
CHAIRMAN APOSTOLAKIS: That's correct.
MR. POWERS: And we have academic papers
which seem to make a fairly logical expansion type
argument that seem to get ignored. It's a real
problem here when we have set down in writing what the
division --
CHAIRMAN APOSTOLAKIS: You are putting me
in a situation of conflict of interest.
(Laughter.)
MR. POWERS: I happened to have read the
paper and liked it.
CHAIRMAN APOSTOLAKIS: Mr. Chairman, I had
another thing to say and I must have forgot it.
(Laughter.)
Any other comments from my colleagues?
CHAIRMAN MESERVE: Thank you very much.
I appreciated the opportunity to meet with you and let
me say that as issues arise that you'd like to talk to
me about, I am available to you. Please call and I've
sent -- George, in particular, please stop by and let
me know what's going on.
CHAIRMAN APOSTOLAKIS: I'd like to finish
by repeating something I told you the other day, that
this committee does know what an engineering approach
measure is. Don't believe it when people tell you we
don't. We really appreciate your willingness to come
here and spend some time with us. Thank you very
much.
CHAIRMAN MESERVE: My pleasure. Thank you
very much.
CHAIRMAN APOSTOLAKIS: We will recess
until 2:15.
(Off the record.)
Page Last Reviewed/Updated Monday, August 15, 2016