480th ACRS Meeting - March 1, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               480th Meeting

Docket Number:  (not applicable)

Location:                 Rockvill, Maryland

Date:                     Thursday, March 1, 2001

Work Order No.: NRC-097                               Pages 1-234

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                   480TH MEETING
                   MARCH 1, 2001
                ROCKVILLE, MARYLAND
                                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.
                           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
                           JOHN D. SIEBER, Member
                           ROBERT U. UHRIG, Member
                           GRAHAM B. WALLIS, Member
                           F. PETER FORD, Invited Expert
           NRC STAFF:
                           RALPH CARUSO
                           TIM COLLINS
                           NOEL DUDLEY
                           CHRIS GRIMES
                           BILL HUFFMAN
                           RALPH LANDRY
                           RONALD LLOYD
                           JOHN NAKOSKI
                           BOB PRATO
                           HAROLD VANDERMOLEN
           OTHERS PRESENT: 
                           LYNETTE HENDRICKS
                           ROBERT HENRY
                            480TH ACRS MEETING
                              MARCH 1-3, 2001
             THURSDAY, MARCH 1, 2001, CONFERENCE ROOM 2B3, TWO
                            WHITE FLINT NORTH, 
                            ROCKVILLE, MARYLAND
           1)              8:30 - 8:35 A.M. Opening Remarks by the ACRS
                           Chairman (Open)
                           1.1) Opening statement (GEA/JTL/SD)5
                           1.2) Items of current interest (GEA/SD)6
                           1.3) Priorities for preparation of ACRS 
                                     reports (GEA/JTL/SD)
           2)              8:35 - 10:00 A.M. RETRAN-3D Thermal-Hydraulic 
                           Transient Analysis Code (Open/Closed) (GBW/PAB)
                           2.1) Remarks by the Subcommittee 
                                     Chairman . . . . . . . . 8
                           2.2) Briefing by and discussions with 
                                     representatives of the Electric Power 
                                     Research Institute (EPRI) and the NRC 
                                     staff regarding the EPRI RETRAN-3D 
                                     thermal-hydraulic transient analysis 
                                     code, associated staff's Safety 
                                     Evaluation Report, and resolution of 
                                     issues previously raised by the 
                                     ACRS . . . . . . . . . . 9
                 [Note: A portion of this session may be closed 
                             to discuss EPRI proprietary information.]
           3)              Subcommittee Report (Open)(JDS/GEA/MWW)
                                           Report by the Chairmen of the Plant Operations
                           and Reliability and Probabilistic Risk
                           Assessment Subcommittees regarding the South 
                           Texas Project Exemption Request that was
                           discussed during a meeting on February 21, 2001
                            . . . . . . . . . . . . . . . . . . . . . . . . .36
           4)              10:15 - 11:45 A.M. Interim Review of the License 
                           Renewal Application for Arkansas Nuclear One, 
                           Unit 1 (Open)  (MVB/GML/NFD/SD)
                           3.1) Remarks by the Subcommittee 
                                     Chairman . . . . . . . .88
                     3.2) Briefing by and discussions with 
                                     representatives of the Entergy 
                                     Operations, Inc. and the NRC staff 
                                     regarding the license renewal 
                                     application for Arkansas Nuclear One, 
                                     Unit 1 and the associated staff's 
                                     Safety Evaluation Report92
           5)              12:45 - 2:15 P.M. Spent Fuel Pool Accident Risk 
                           at Decommissioning Nuclear Power Plants (Open) 
                     4.1) Remarks by the Subcommittee 
                                     Chairman . . . . . . . 111
                     4.2) Briefing by and discussions with 
                                     representatives of the NRC staff 
                                     regarding significant findings and 
                                     recommendations of the final report on 
                                     spent fuel pool accident risk at 
                                     decommissioning plants, new 
                                     developments, status of developing 
                                     proposed options, and related matters.
                                     Representatives of the nuclear industry
                                     will provide their views, as 
                                     appropriate. . . . . . 112
           6)              2:30 - 3:45 P.M. Management Directive 6.4 
                           Associated with the Revised Generic Issue Process
                           (Open) (TSK/AS)
                     5.1) Remarks by the Subcommittee 
                                     Chairman . . . . . . . 188
                     5.2) Briefing by and discussions with 
                                     representatives of the NRC staff 
                                     regarding Management Directive 6.4 
                                     related to the Revised Generic Issue 
                                     process, results of the case study 
                                     performed to determine the 
                                     effectiveness of using the Management 
                                     Directive to implement the revised 
                                     Generic Issue process, and related 
                                     matters. . . . . . . . 188
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                      8:30 a.m.
                                CHAIRMAN APOSTOLAKIS:  The meeting will now
           come to order.  This is the first day of the 480th
           meeting of the Advisory Committee on Reactor
                                During today's meeting the committee will
           consider the following: RETRAN-3D Thermal-Hydraulic
           Transient Analysis Code, Interim Review of the License
           Renewal Application for Arkansas Nuclear One, Unit 1, 
           Spent Fuel Pool Accident Risk at Decommissioning
           Nuclear Power Plants, Management Directive 6.4
           Associated with the Revised Generic Issue Process, 
           and Proposed ACRS Reports.
                                I would like to note some changes to the
           agenda.  RETRAN-3D and ANO-1 license renewal
           application were discussed by cognizant subcommittees. 
           As recommended by the chairman of the subcommittees,
           there will not be presentations either by the staff or
           by the industry groups on these matters.  Instead the
           subcommittee chairman will provide reports to the full
           committee.  Representatives of the NRC staff will be
           present to answer any questions from the members.
                                In addition, the subcommittee report on the
           South Texas Project Exemption Request scheduled
           between 1:00 and 1:30 P.M. on Friday, March 2, will be
           held today following the subcommittee report on
                                After completing the subcommittee reports,
           the committee will discuss the proposed ACRS report on
           the regulatory effectiveness of the ATWS Rule.  I hope
           these changes will not cause any inconvenience to the
           meeting participants.
                                This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Dr. John T. Larkins is the designated
           federal official for the initial portion of the
                                We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's 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 they can be readily
                                I will begin with some items of current
           interest.  We received from Dr. Powers draft one of
           the research report on February 26 and some additional
           sections yesterday.  The most recent version of the
           research report along with assignments for reviewing
           various sections will be provided to you this morning.
                                Members should not only review the sections
           assigned to them but also should review the entire
           report and be prepared to provide their views during
           the discussion of the report this evening. 
           Representatives from the Office of Research will
           attend the meeting to respond to questions from the
                                I would also like to bring the members'
           attention to this pink items of interest report, in
           particular items referring to management changes.  
           There have been some senior management changes.  
                                Also to the announcement that the NRC will
           hold a workshop on the initial implementation of the
           reactor oversight process on March 26.  Also the
           agenda and registration information for the NRC 13th
           Annual Regulatory Information Conferences included in
           this document.
                                I think we are ready to start the meeting. 
           The first item on the agenda is RETRAN-3D Thermal-
           Hydraulic Transient Analysis Code.  
                                Dr. Wallis, will you guide us through this
           and give the report to the committee.
                                DR. WALLIS:  Thank you, Mr. Chairman.  We
           met on the 20th of February, last week, with
           representatives from EPRI and from industry, the users
           of EPRI code RETRAN.  
                                Finally, with the technical folks who are
           consultants for EPRI who actually put together the
           code.  We actually this time had discussions of
           technical matters which had eluded us two years
           previously and for some time in between.
                                Mr. Swindelhurst from the users gave us the
           familiar story, RETRAN is being widely used, ACRS
           concerns have been addressed, and everything is fine.
                                We then turned to Mark Polson, the technical
           man.  He made a technical presentation.  Before long
           he realized that our critique had some merit.  He said
           things like, "Oh, I see where you're coming from," and
           expressions like that which it was quite nice to hear.
                                After this had gone on for an hour or two,
           the new program manager from EPRI who wasn't here the
           previous time, Jack Prahl, asked to make a statement
           and he essentially wished to admit that there were
           problems with this code and EPRI had something to fix
                                Then we went on with more technical details
           and more discussion with Mark Polson and he saw even
           more clearly some of the places from where we were
           coming.  It was decided from the results of these
           discussions that it would not be appropriate for EPRI
           to make a presentation today before the full committee
           which was originally planned.
                                That's a brief overview of what happened
           last week.
                                Now, I think it will be good for this
           committee to discuss quite a few points raised or
           lessons learned from all this.  I'm sure you have some
           other than the ones I wish to point out at this time.
                                First one is the ACRS role.  It seems that
           without the willingness of the ACRS to actually look
           at equations and question them, none of this might
           ever have happened.  One wonders if it really should
           have to come to the ACRS in order for this sort of
           review of equations to occur.
                                The staff has issues with the SER
           and one might wonder what the mechanism is now for
           closing the loop on these issues.  Will the
           documentation have to be changed since the code
           reflects the documentation?  
                                And since the problem with the RETRAN
           momentum equation is the supposed resolution, if the
           momentum flux turns in arbitrary direction psi which
           leads to peculiar results, this presumably is in the
           code.  Will the code have to be changed?  If the code
           has to be changed, the evaluations of the code will
           have to be rerun and so on.  There are a lot of issues
           about what should happen now.
                                The shorter-term issue for us is what should
           we do now.  I understand the latest proposal is that
           this committee write Larkins a very short letter --
           you may even have the draft of it here -- and append
           the two documents that I prepared, the tutorial on the
           momentum equation and the detailed critique of RETRAN
           which doesn't necessarily capture everything in there
           which might need examination and change.
                                I think my colleagues might consider at this
           point what we are aiming at as a resolution of these
           matters.  What do we hope to change?  Do we hope to
           change the way things are done around here?  Do we
           want to change the way reviews are performed?  Do we
           want to change substantially the standards required
           for code documentation?  
                                Do we want to change RETRAN code itself? 
           What is it that we hope to achieve by our actions
           today and in the future on this code and other codes? 
           There are several questions.  Maybe the chair would
           like to decide which ones to take up first.
                                CHAIRMAN APOSTOLAKIS:  I'm not sure this is
           the appropriate time to do this.  We will perhaps
           revisit these questions when we draft this short
           letter and decide what the attachments should be.
                                DR. POWERS:  I wonder why you think it's not
           the appropriate time.
                                CHAIRMAN APOSTOLAKIS:  This is supposed to
           be a short proposal.  The questions that Dr. Wallis is
           raising are require a lot of discussion.
                                DR. WALLIS:  The staff is or are here,
           depending on grammar.  There are members from the
           staff here and this is your chance to have a
           discussion with them about perhaps how we got here and
           where we go from here.  
                                CHAIRMAN APOSTOLAKIS:  It seems to me that
           regarding the code we have to make sure it's correct. 
           But the other questions you're asking, where do we
           want to go and whether we want to make proposals
           regarding the review process, I mean, I don't think
           this is the right time to discuss that.
                                DR. POWERS:  It seems to me that the review
           process itself is pretty good.  I mean, I am impressed
           at all the things that are going on, getting the code,
           running it, very carefully going through all the
           things like that.  
                                Now the question of the documentation and
           what not, it seems to me it's not a change.  It's
           simply exercising and reinforcing the standards in the
           technical community in general.  
                                The documentation simply has to accurately
           reflect what is done in the code and has to be
           technically correct.  You cannot have scalar
           quantities treated as vectors.  That's just
           unacceptable, or vice versa.
                                CHAIRMAN APOSTOLAKIS:  There are bigger
           issues here, though.  I think that's what Graham
           implied.  Why did it come to ACRS having to check the
           equations and find that they were not appropriate and
           so on?  That should have been done somewhere else in
           the process.  Is it the job of this committee to check
           equations and find mistakes?  
                                I think that is an issue that we certainly
           need to discuss and maybe try to come up with some
           recommendations to the commission that will correct
           the process because we should be reviewing whatever we
           like but it seems to me that, you know, this should
           not be the place where errors of the type that Dr.
           Wallis identified should be found.
                                In that sense I don't think it's appropriate
           to discuss these bigger issues.  But we definitely
           want to make sure that there is documentation of the
           concerns and so on.  This is simply intended to
           document these concerns.
                                Dr. Wallis has transmitted to us two reports
           that are in the handout No. 2, the first two, Comments
           on EPRI Response to RAI and Other Recent Submittals
           Concerning the RETRAN Code dated February 25 of this
           year.  The second one is Tutorial on Momentum
           Equations dated January and February of this year.
                                The thought was simply to write a short
           letter to the EDO transmitting these two documents at
           this time.  That's all the action we're going to take
           and wait for EPRI response.
                                Is that correct, Graham?
                                DR. WALLIS:  Maybe you don't want to do it
           now but I think we have to have some idea of where we
           think things are going and where they ought to go
           because if we wait, we don't know what we're going to
           get.  We may get off on some track which isn't going
           in the direction we would like things to go.
                                CHAIRMAN APOSTOLAKIS:  Like which way?
                                DR. WALLIS:  I don't know.  This committee
           needs to decide what its role is.  We could stand back
           and say we've given our input.  Now we'll wait and
           see.  Whatever comes back, we'll respond to that when
           we see it.
                                Or we could give more indication of where we
           would like things to go and what we would regard as a
           suitable resolution of the issues so that when folks
           come back to us, whenever they do come back to us, if
           they come back to us, with what they think is a
           resolution of the issues, that they don't find that
           our expectation was something different.
                                CHAIRMAN APOSTOLAKIS:  Would you raise these
           issues and reflect our thoughts on the matter in the
                                DR. WALLIS:  No.  I think we should probably
           discuss this at some other time, George, than in this
                                CHAIRMAN APOSTOLAKIS:  That's what I'm
           saying.  That would make a very difficult letter.
                                DR. WALLIS:  Since we have two members of
           the staff here, do we want to ask them about the
           mechanism for closing the loop?  
                                This is something that Virgil Shrock raises
           rather strongly in his comments is that we go through
           all these motions but the SER is out there and unless
           somebody follows up on these things the issues may
           just fade away and people get tired of them and
           nothing will happen.  What is the mechanism for what
           one could call closure on these issues?
                                DR. LANDRY:  Mr. Chairman, Ralph Landry, NRR
           staff.  As we discussed with the subcommittee, our
           position at this point is we have prepared an SER
           based on the documentation which we received on
                                Now, since we have been involved very
           heavily with the subcommittee in the review of the
           code, the errors in the documentation that was
           presented on the momentum equation, we've expressed
           our view that the approach that was taken in preparing
           this documentation was very difficult to understand
           and very difficult to follow through.
                                EPRI attempted to derive a momentum equation
           from basic principles and in that process ended up
           with material that was very hard to follow through
           and, quite frankly, we would agree with Dr. Wallis
           that it's highly suspect and there are errors in it. 
           We pointed out a number of errors to EPRI and their
           consultants ourselves in addition to the errors that
           Dr. Wallis pointed out. 
                                Our suggestion in front of the subcommittee
           was that the documentation should be retracted and a
           presentation should be made of what is in the code
           with regard to a motion equation, momentum equation,
           however you want to term it, what are the terms in
           that equation, what do they represent, and how can
           they be justified rather than a derivation from basic
                                EPRI in their presentation to the
           subcommittee indicated, as Dr. Wallis said, that they
           recognized the problems in what they had in the
           documentation.  They were going to go home and do some
           further work.  
                                At this point the staff is waiting to see
           what that further work is because we don't want to
           dictate to them what they should put in the
           documentation.  It's their job to come up with the
           documentation.  We want to see what is in that
           documentation, is it correct, and is it in acceptable
                                At that point we would entertain the idea of
           writing an addendum or a supplement to our SER.  We
           have done that in the past.  In the years gone by in
           code reviews there have been numerous SERs which had
           supplements and addenda written to them which
           explained further information or evaluated further
           information that had been received.  We would be more
           than willing to do so should they provide information
           that is reviewable that would correct what we see as
           shortcomings in the documentation today.
                                That's the approach that we're on on RETRAN. 
           Some of the other points that Dr. Wallis has brought
           out are a bigger picture discussion and those I think
           we need to discuss more fully and how we approach
           these reviews.  
                                From the perspective of the staff, the
           review that has been undergone in the code in the
           recent two years with the TH subcommittee has been
           very good and very fruitful.  We've had a very good
           relationship and very good interchange of information
           with one another and this has been a great benefit to
           the staff.
                                In this process we have been writing a draft
           standard review plan and draft regulatory guide on
           code and code review.  This has been in itself an
           educational process.  We've learned a great deal from
           these code reviews and from the interactions with the
                                DR. WALLIS:  Let me ask you about the code
           itself.  Just to pick one thing out of my critique
           here, they have an analysis of a bend.  If you throw
           out the friction turn and it's a smooth bend, it turns
           out the way they formulated it, there's a pressure
           rise across the bend for no cause. 
                                If you add these bends together, you've got
           a pump with no moving parts and no energy input which
           doesn't seem very desirable.  If these features are in
           the code itself, you have to after the code, not just
           the documentation.
                                DR. LANDRY:  That's correct and that is one
           of the problems that we also pointed out and point out
           in the SER, that you don't get an effect as their
           equations would indicate.  It would be a very creative
           piece of equipment.  It's almost a perpetual motion
           machine that they have created in their derivation. 
           It would be very nice to see if they could build one
           of these.  That's a little sarcasm.
                                DR. WALLIS:  They could have a dot com
           company which would flourish for a while.
                                DR. LANDRY:  Until they went bankrupt. 
           Typical dot com.  That gets back, Dr. Wallis, to the
           point I was trying to raise a few minutes ago.  The
           approach that we think would be far more fruitful and
           beneficial would be to show what is in the code,
           explain what is in the code, and why what is in the
           code is correct and acceptable. 
                                Right now we're going down one path with
           documentation and that may not match up with the code. 
           We keep saying to the applicant, "You should come back
           here and explain the code and why the code is
           acceptable.  What is in the code, not necessarily what
           is in the documentation.
                                MR. LEITCH:  Dr. Landry, could you explain
           what is the status of the SER now and what use would
           be made of the SER where we are at this point in time?
                                DR. LANDRY:  The SER has been issued to the
           staff and I believe the SER has been released into the
           public sector by the project's office.  That means
           that those who would like to use RETRAN-3D can come in
           and reference the SER.  
                                But that doesn't mean that anyone
           referencing the SER and RETRAN-3D is completely clean. 
           There are 45 conditions and limitations stipulated in
           the SER on RETRAN-3D which puts a severe restriction
           on anybody using the code in that they must come in
           and justify every option chosen.  
                                In most applications of the code provide
           adequate assessment because the assessment is so thin
           in the documentation for the application of the code. 
           That puts a great deal of onus on anyone who wants to
           use the code in that they must completely justify what
           they are doing.  They must justify the code.
                                MR. LEITCH:  But even with that
           justification there would still be another cloud over
           that work.
                                DR. LANDRY:  At this point there is in that
           we are very concerned about what is actually in the
           code now.  This issue has been raised and we are
           flagged when anything comes in referring to this code,
           that indeed we must understand what is in the code
                                MR. LEITCH:  I was just wondering if
           licensees might be spending a great deal of effort
           developing work in this regard only to find that it's
                                DR. LANDRY:  At this point we are not aware
           of a number of our licensees using the code for a
           licensing application.  There is one licensee that has
           submitted a reference to RETRAN-3D but that was to use
           RETRAN-3D in a RETRAN-02 mode as a substitute for the
           old version of RETRAN.  
                                We have put very strict stipulations on how
           that can be done within the SER.  Only one who has
           been approved for use of RETRAN-02 can use RETRAN-3D
           in a RETRAN-02 mode and then we specified what that
                                The applicant in question is not a licensee
           who is approved for use of RETRAN-02.  So that raises
           an issue in itself and we simply ask that licensee to
           demonstrate how they satisfy all conditions and
           limitations stipulated in RETRAN-3D SER.  When they
           get to the stipulation that they have to be approved
           for RETRAN-02 to begin with, they are going to run
           into a road block.
                                DR. BONACA:  I had a question about what are
           the genetic implications of these findings to other
           codes such as RELAP-5, such as TRACK, that are being
           used now for best estimate calculations?  I mean, do
           we expect to see the same kind of issues or problems
                                DR. LANDRY:  In this discussion a number of
           issues have come up with the formulation of momentum
           that point back to work that was done back in 1974 and
           even before.  The issues at that time that were
           brought up pertained to the formulation of momentum
           for the RELAP-3 and RELAP-4 codes which are the basis
           for RETRAN family codes which actually goes even
           further back.  It goes back to FLASH.  RELAP-3 came
           from FLASH.
                                This issue so far after looking at the other
           codes would not apply to the RELAP-5 and TRACK family
           because those codes started from a different
           derivation and different basis.  
                                They drew on the work on RELAP-4 but the way
           in which they constituted the continuity equations was
           different than was in the older versions of the RELAP. 
           We have not gone back and checked exactly what's in
           there but the formulation is different for the newer
           versions of the codes.
                                DR. BONACA:  I believe it would be
           appropriate at this time to look back into those codes
           and see if the same issues apply just because, I mean,
           clearly, I agree with you, there is a totally
           different formulation.
                                DR. LANDRY:  We did raise that issue when we
           were doing the Siemens S-RELAP-5 review for an
           Appendix K application to small break LOCA.  That
           question came up because of typos and other errors we
           found in the documentation.  
                                One of the lead engineers that they now have
           at Siemens came in and gave a cogent, very good
           explanation of what is in the code and justification
           for the way momentum is formulated in the S-RELAP-5
           which is going to be the same essentially as the
           RELAP-5 code.
                                Their explanation was far more justifiable
           and indicated that far greater support for the
           formulation of momentum that they have than we can
           point to at this point in the RETRAN codes.
                                We don't know absolutely that what is in the
           RETRAN family is wrong.  What we have in the
           documentation is not supportive of it.
                                DR. WALLIS:  Apparently the code is based on
           the equations and equations have this strange way of
           resolving momentum fluxes which led to this pressure
           rise around the bend which seems, since you have the
           code, you could look at how they model bends they made
           in piping, loop seals and things.  
                                We had a discussion with them which was
           inclusive of how they model the cold laid down comma
           transition which is a bend in there, we're looking at
           it, and they had some very strange terms in that one.
                                It is possible to look in the code and say
           what does the code actually have.  You may be
           surprised.  The code may have something else.  But if
           the code reflects the documentation, then presumably
           these bends are doing the same sort of thing that the
           bend in the documentation was doing actually in the
                                DR. LANDRY:  We would agree with you, Dr.
           Wallis, and that's why we've said that our
           recommendation to the applicant is that they explain
           what is in the code and justify it.  Generally when a
           code of this nature is used, you don't actually model
           bends and calculate angles and change in flow
           direction but you but nodes together with junctions
           where you have a farm lot.
                                DR. WALLIS:  RETRAN makes a big thing about
           not having that.  They actually have size and
           mysterious things which enable them to handle things
           like bends.
                                DR. LANDRY:  We've asked for this to be
                                DR. WALLIS:  It would be very strange if
           they have in documentation all this new theory about
           bends and the code is still the old straight pipe
                                MR. CARUSO:  Dr. Wallis, this is Ralph
           Caruso from the Reactor Systems Branch.  I think
           listening to all this discussion I would like to
           inject a little bit of, I'm going to say, brutal
           honesty here.  We don't really believe there's a
           problem with the RETRAN code itself.  We believe that
           the problem is the documentation.  
                                The RETRAN-3D is a transition code.  It's a
           new version of the RETRAN family and because the
           RETRAN community is trying to take the user community
           and bring it along to a new version of the code, they
           had to come out with something that they thought would
           be attractive to the existing users.  
                                We believe that unfortunately in developing
           the documentation they attempted to describe it in
           terms which give it more credence than it necessarily
           deserves.  They oversold it a bit.
                                DR. WALLIS:  This is a strange statement. 
           You mean the actual practice has no relationship to
           the theory?
                                MR. CARUSO:  We believe that the way the
           code is set up -- as Ralph said, the problem is the
           documentation does not reflect what's in the code. 
           The code and the documentation don't agree.  
                                The documentation attempted to derive the
           momentum equations from first principles and show how
           they were applied in the code.  Unfortunately, they
           are not applied that way.
                                DR. WALLIS:  It almost implies that the ACRS
           should recode.
                                MR. CARUSO:  Well, this goes back a little
           bit further to, I guess you could say, the strategy
           for doing this code review from the start.  
                                We understood that the underlying structure
           of the code was essentially the same as RETRAN-02 and
           we made a conscious decision at that point that we
           were not going to review that underlying structure and
           those underlying equations.  
                                The existing code, that structure, had been
           reviewed, had been approved, and has been in use for
           a large period of time and it generally seems to
           produce reasonable results that can be used by people
           to analyze the behavior of the plans.
                                DR. WALLIS:  How long is this reasonable
           comparative time?
                                MR. CARUSO:  Oh --
                                DR. WALLIS:  Is it 20 years?
                                MR. CARUSO:  Something on the order of 20
           years.  The documentation that's cited in RETRAN-3D is
           very much like the documentation.  RETRAN-3D is 20
           years old.  It's an old report from INEL, I think.  Is
           that what you're referring to?
                                DR. WALLIS:  No.  What I'm referring to is
           the documentation that you saw for RETRAN-3D as new
                                MR. CARUSO:  It's very much the same as was
           in the 20-year-old document from Idaho.  Same sort of
           treatments of bends and things there.  It hasn't
                                DR. BONACA:  What concerns me is that there
           was a departure from RELAP-4 when RELAP-5 was
           developed.  Unless the agency was totally wasteful
           with its money, it was done intently because it was
           recognized that RELAP-4 was not capable of being a
           good prediction code.  Is this correct?  
                                I mean, that's the history of that time. 
           That's why there was a departure.  My concern is that
           whatever you do to patch up RETRAN, which is a
           derivation of RELAP-4, you may not be able to achieve
           what you want, achieve in a prediction fashion for the
           very reasons that led the whole industry and the
           agency to go to RELAP-5 to develop all new formulation
           of these equations.  
                                My concern is that here we have -- I'm
           expressing this concern because this has been
           discussed with EPRI for 20 years, this attempt to
           bring RETRAN from RETRAN-1 to RETRAN-2 and now to
           RETRAN-3D.  Next maybe RETRAN will do neutronics or
           who knows what.  
                                I mean, is there something mentally wrong
           about attempting to take this code and make it do
           things it cannot possibly do?  The reason why I say
           that question is that Professor Wallis brought up some
           fundamental issues there.  I'm not sure that purely by
           changing somewhat the algorithm psi and putting some
           correction in terms will solve this issue. 
                                DR. SHACK:  Although I think it is true,
           what's unique about RETRAN is the introduction of the
           psi angle and the attempt to apply a one-dimensional
           momentum equation to a 90 degree angle.  
                                I think probably as long as the modeler
           avoids that option, it really does essentially
           adjunction the model.  Those applications are probably
                                What you worry about is the occasion when he
           actually tries to use that feature that he can take
           the momentum 90 degrees to the angle to which he
           thinks he's writing a one-dimensional equation.  I
           suspect that is largely why the code works is that
           people by in large don't use that feature.  
                                It kind of floats in there because, I mean,
           it's wrong.  They fixed up one set of terms but
           they're not the worse because the cosine squared term
           isn't the problem.  It's either zero or one so whether
           it's cosine or cosine squared doesn't make much
           difference.  They have a missing cosine.
                                DR. BONACA:  The problem with that --
                                DR. SHACK:  It's zero and one.
                                DR. BONACA:  The problem with that is this
           places the burden on the issuer and the issuer is not
           typically an expert in the code.
                                DR. SHACK:  I agree that is a problem, why
           one set of codes is really different.  I think that is
           the unique feature of RETRAN is to introduce this
           notion that you can apply a one-dimensional momentum
           equation 90 degrees.  That makes it different.
                                DR. BONACA:  I knew that.
                                DR. SHACK:  The reason it probably works
           much of the time is you don't try to do it too often.
                                MR. CARUSO:  It is also important to
           understand that we know that this situation exist and
           the question was asked, well, how does this get fixed
           in the future?  How do we know that someone doesn't
           make a mistake?
                                The staff process for approving the use of
           these codes has several steps.  The first step we've
           just gone through is to improve the generic topical
           report but then each application has to be reviewed
           and approved specifically by the staff.  We do ask for
           copies of the actual plant models as part of those
                                The staff will actually see the models that
           will be used by the RETRAN users when they want to
           apply them to their plants.  Now that we are aware
           that this situation occurs, we can be alert to it and
           say, "Well, wait a minute.  How are you modeling this
           1-D momentum through 90 degrees in your plant model?"
                                DR. WALLIS:  But you still have a problem. 
           Which psi will you accept?  No psi is really right.
                                MR. CARUSO:  Actually zero. 
                                DR. WALLIS:  No psi is really right.
                                MR. CARUSO:  From our understanding of the
           way the RETRAN users actually use the code, they don't
           use that factor.  They just put in form losses at the
                                DR. WALLIS:  But they have to.  You have to
           put in something for your momentum flux terms and
           something for your inertias terms.  The L1s and L2s
           themselves, there is a question about how they fit in,
           too, when you go around a bend.  
                                There are all of these questions about how
           this fundamental equation is used for various
           components.  Are you going to examine every component
           in the reactor to see if they use the psi and which
           one did they use, if they used L1 or L2, and how did
           they choose it and all that.
                                MR. CARUSO:  Actually, the EPRI people have
           also made a commitment to have the new users of
           RETRAN-3D submit their models to peer review panels so
           that there will be experienced users that look at the
           models that are developed to make sure they are not
           doing things in a too creative way.
                                DR. WALLIS:  I guess there was a concern
           that the consultants, particularly Novak Zuber, who
           has been around us for four years or so, if you don't
           go after some of these conceptual problems when you
           review the codes, errors get embedded and they go on
           for decades.  
                                I don't know how you fix that but if you
           back off or if you say we'll fix it when it comes to
           a given utility using and so on, then this blemish
           stays there and will resurface again.  You have to
           deal with it forever.
                                DR. LANDRY:  That, I think, is one of the
           points that Ralph Caruso was referring to a moment ago
           that, yes, RETRAN-02 was reviewed and approved.  The
           way we approached the RETRAN-3D review initially was
           we would look at the material that was new and
           different from RETRAN-02.  
                                Rather than expend resources on reviewing
           the old code, we would only look at the new material. 
           During the course of this review in all these
           discussions we've had, we found that we had to go back
           and look at the old material also.  
                                This is part of the learning process we've
           been going through in these reviews in the past two
           years.  Perhaps what seemed like the expedient thing
           for use of resources to only look at new material is
           not the way we should approach the reviews.  
                                We should be a little more sensitive to a
           code of this nature looking at the older material, the
           older version of the code also and take into
           consideration that perhaps there are things in the
           review of the old code that need to be re-reviewed as
           we move into the new version of the code.  
                                That's quite different than when we receive
           a brand new code that we haven't reviewed because
           there we would want to look in detail at the entire
           code.  This is a way we have approached reviews in the
           past.  We have continued doing this code looking at
           only the new material.  
                                Now we realize that perhaps that isn't the
           best way and that we do have to look at old material,
           too, so we don't perpetuate a problem from version to
           version simply because it's been grandfathered in.
                                MR. CARUSO:  And to be honest with you,
           these problems exist in the plants.  We have plants
           now that were licensed back in the '60s and the way
           they did things back then is not the way we would have
           them do them now.
                                When we have new license issues come in for
           those plants, we don't restart the entire review of
           the plant from ground zero.  We make a conscious
           decision to limit the scope of our review.
                                I understand the problem of grandfathering
           in decisions which seem to be a good idea at the time
           but which in 20 years hindsight may not be appropriate
           for current times.  We don't have the resources to
           review everything from ground zero every time we have
           a change to it.  We just can't do that.
                                DR. BONACA:  But even for all the plants if
           you find a fundamental problem, you reopen the issue,
                                MR. CARUSO:  The issue is what is a
           fundamental problem?  In the case of RETRAN it does
           model the behavior of the plant reasonably well, well
           enough to make a decision.  The question is is it
           doing for the right reason.  Is it doing it for a
           technically defensible rigorously defensible reason or
           is it a simplification?  How simplified can these
           equations be before they become undefensible?
                                DR. BONACA:  But isn't a determination you
           have to make before you make a decision?
                                MR. CARUSO:  But it's a judgment decision
           and right now what we've been going on is do the
           results look reasonable.  Can somebody who is
           reasonably knowledgeable use this code to produce an
           analysis of the plant behavior.  
                                Although there is a problem with the
           documentation, we believe that the code as used by
           those users still gives reasonable results.
                                DR. WALLIS:  Maybe we've said enough at this
           time on this issue.
                                CHAIRMAN APOSTOLAKIS:  Now, regarding the
           other issue you raised, which direction we want to go,
           maybe we ought to discuss this at another time after
           perhaps you give us some options based on your
           experience.  You obviously have thought about it. 
           It's always good to have a structured discussion,
           especially among 10 people to have some structure,
           some starting point.  Would you be willing to do that?
                                DR. WALLIS:  Do you think we would do it
           this Saturday if we're still here?
                                CHAIRMAN APOSTOLAKIS:  We may start this
           Saturday because let's not forget we have huge task to
           complete at this meeting, namely the review of the
           research report.  I'm not sure we will be ready by
           Saturday.  Again, all I'm asking is two or three
           lines.  It's not a major understanding.
                                Any other comments on this issue from any
                                Thank you very much, gentlemen.
                                We can proceed now with the chairman's
           report on the South Texas Project Exemption Request.
                                It was a joint meeting of the plant
           operations and reliability and risk assessment
           subcommittees.  Mr. Sieber, chairman of the plant
           operations subcommittee, will take the lead on this
           and I will jump in as necessary.
                                MR. SIEBER:  Actually, since these 10
           members were present for the joint subcommittee
           meeting, all this will be sort of a review as opposed
           to new material.
                                I guess I viewed this whole process from an
           operating standpoint as opposed to a PRA standpoint. 
           The meeting that we had on the 21st involved the
           process, the element of categorization.  We all got a
           packet of material on February 8 which most of my
           remarks are based on that packet of information.
                                My approach to doing these things is
           actually to first look at the plan itself and try to
           compare the numbers and logic that they use versus my
           memory of how these plants actually go together.  I
           used the NRC database to look at the characteristics
           of the plant.  
                                There are two units there.  They are 4 loop
           PWRs.  They are large united rated at 1250 MW
           electric.  It's owned by Houston Power and Light. 
           It's about 80 miles from the city of Houston.  It's a
           lake cooled plant and it does have some unusual
           features that affect its risk profile.  
                                One is that it has three safety trains
           including three diesel generators which most plants
           have two safety trains.  The safety trains starting
           from cold shutdown going up to the high pressure
           systems includes three RHR systems, three low-head
           safety injection systems, three intermediate head
           safety injection systems and what you would ordinarily
           think of as high-head safety injection there is
           actually charging pumps.  
                                There are three of those even though from an
           accident standpoint I would discount one because it's
           a positive displacement pump 35 gallons a minute which
           I don't think help you much in an accident situation.
                                DR. POWERS:  It's worse than that, Jack.  It
           would probably hurt you in an accident situation.
                                MR. SIEBER:  It's there and drawing power
           and doing nothing.
                                DR. POWERS:  And it's putting the reactor
           into hot clad.
                                DR. UHRIG:  Jack, am I correct in
           remembering that this is sort of a unique plant that
           has a longer core than the standard Westinghouse 4
           loop plant?  This is different than almost all other
           4 loop plants?
                                MR. SIEBER:  I think it's another foot
                                DR. UHRIG:  Yeah.  Yeah.
                                MR. SIEBER:  It has more elements, for
           example, by about 32 elements than a 3 loop plant
           which has about 157 elements in it.
                                DR. UHRIG:  You know, the SNUPS design was
           the standard plant of that era.
                                MR. SIEBER:  Right.
                                DR. UHRIG:  I believe this one was supposed
           to be the next generation plant.
                                MR. SIEBER:  Right.  And it is lake cooled
           which is not unique in the United States.  There are
           an awful lot of lake cooled plants.  It has large dry
                                Now, the exemption request itself, as I see
           it, it's purpose is to identify components that are
           important to safety from a risk standpoint and
           eliminate components not important to safety from the
           requirements of Title 10 CFR, Part 50, Appendix B and
           Special Treatment Requirements.  I see 50 isn't on
                                The other thing is that it is also designed
           to identify components which are risk significant but
           don't end up on the Q-list so that they can be added. 
           This process actually goes both ways.
                                I tried to look at the number of components
           that they had.  Of course, they listed their totals as
           for both units and specifically for 29 systems.  A
           typical PWR might have anywhere from 50 to 60 systems,
           but there is no point in trying to categorize safety
           related or nonsafety, things like drinking water,
           building ventilation and so forth.  
                                The ones that have some significance at all
           are the 29.  If you look at this in a typical BWR, a
           single unit, it will have about 17,000 valves, another
           17,000 circuit breakers or electrical components,
           motors and so forth, about 300 pumps and about six
           other heat exchangers, and a myriad of other things
           which for two units would be about 70,000 total
           components in the plant that are assigned mark numbers
           of one sort or another.
                                In the 29 systems there are 43,690
           components in the two units.  If you would look at
           their Q-list, those items falling under the
           requirements of Appendix B, there are 16,715
           components listed there.  These are the ones that are
           initially identified either by the nuclear steam
           supply system vendor or the architect engineer for the
           interfacing systems.
                                CHAIRMAN APOSTOLAKIS:  These are safety
                                MR. SIEBER:  These are safety related
           components as originally determined when the plant was
                                CHAIRMAN APOSTOLAKIS:  And there are no
           other safety related.  This is it.
                                MR. SIEBER:  This is it.
                                DR. WALLIS:  This is the total for two
                                MR. SIEBER:  That's total for two units.
                                DR. WALLIS:  So 16,715 is an odd number. 
           That means that something is gone?
                                MR. SIEBER:  Yeah.  For example, some
           systems are shared and some are not.  I know of no two
           units regardless of how they were built that are
                                DR. SHACK:  The Inside NRC article on this
           made a comment that South Texas dumped more stuff on
           the Q-list than the typical plant does.  They sort of
           hit this thing at the peak.
                                MR. SIEBER:  Well, Appendix B come out in
           the early '70s and ours was one of the first plants to
           have to adopt Appendix B after construction was
           underway and the design was done.  Our Unit 1 had
           something like 4,000 or 5,000 items on the Q-list.
                                Unit 2, which was built a year before South
           Texas and went commercial, had the broad range and had
           about 7,000 items.  There was a growth in what ended
           up on the Q-list of about, I would say, 35 percent
           over that time period.
                                DR. POWERS:  I believe South Texas in the
           time it was in construction was one of those plants
           that benefitted from increased management attention.
                                MR. SIEBER:  Don't we all.  
                                Now, based on what I have learned, a typical
           PRA really covers about 2,400 components per unit. 
           That leads to some interesting things.  When you try
           to re-categorize all these items that are on the Q-
           list, you actually find out that you can only do that
           on the basis of PRA results for 5.7 percent of those
                                If you want to do the remainder, the only
           choice that you have is to do it by expert panel
           elicitation which amounts to 94.3 percent.  I guess
           that makes my eyebrows go up a little bit when I think
           about the fact that categorization is "risk informed"
           based on PRAs.  In my mind, less than 6 percent of the
           items are based on the PRA.  Everything else is based
           on the expert panel.
                                CHAIRMAN APOSTOLAKIS:  No, but I think that
           is some additional elaboration that is required here.
                                MR. SIEBER:  Okay.
                                CHAIRMAN APOSTOLAKIS:  I don't think you
           mean that because it's not just the numbers.  I mean,
           it's not the 5.7 percent of SSC in the PRA and the
           remaining 94.3 are not.  The 5.7 percent are there
           because they are important to the CDF and LERF.  I
           mean, there is a reason why they are there and the
           others are not.
                                MR. SIEBER:  Well, you've got to go beyond
           that because the others may, one way or another, be
           implicitly a part of the ones that are specifically
                                CHAIRMAN APOSTOLAKIS:  Very good point. 
                                MR. SIEBER:  On the other hand, you can't go
           back and do a Fussel-Vesely or RAW for an item that's
           not there.
                                CHAIRMAN APOSTOLAKIS:  Exactly.  Exactly. 
           I think, in other words, we should not be talking only
           in terms of the numbers.  We should elaborate a little
           bit on that.
                                The other point is that, yes, it does appear
           that the remaining 94 percent are really categorized
           not using risk information but it was pointed out by
           the STP folks when they were here that the reason why
           they called it risk informed is because the whole
           context within which the characterization takes place
           is risk informed.  
                                The fact that these are not in the PRA is
           already useful information to the panel because there
           is a reason why they are not in the PRA.  You're
           right.  I mean, it's not as formal as using the
           importance measures, for example, because you can't do
                                DR. POWERS:  But, George, I think what he's
           saying is something more important there.  There is
           not a case that there is a reason they are not in the
           PRA.  There are two reasons, two general categories of
                                One, it's not important, and the other one
           is that it's implicitly present and the PRA analyst in
           order to simplify his model didn't call it out.   I
           mean, that seems to me that's a very significant
                                MR. SIEBER:  Well, and I think you have to
           go a step beyond that, too.  When we get finally to
           the explanation of how the expert panel does its
           business, there is actually risk information in the
           questions that they ask and the weighting factors.
                                In a way it's risk informed but as I still
           see it, it's less than 6 percent come directly from
           the PRA.
                                CHAIRMAN APOSTOLAKIS:  It's not risk
           informed if you interpret risk informed using strictly
                                MR. SIEBER:  That's right.  These are the
           numbers here related as --
                                DR. BONACA:  Just before you go past that,
           all that I've heard here is true.  The only thing I
           want to point out is that there has been a focus on
           two measures of performance and if some other measures
           were used, probably some other components will have
           ended up there.
                                DR. KRESS:  Yeah, I'm glad you said that.
                                CHAIRMAN APOSTOLAKIS:  That's true.  That's
           very true.
                                DR. BONACA:  There is no doubt in my mind
           some of the components we probably question.  For
           example, the assumption that since it is not an early
           release, you don't have to worry about it.  
                                Therefore, you know, small failures of less
           than one inch penetrations could affect later releases
           in containment and are not considered because that's
           not significant to the public.  That includes the full
           characterization of penetrations.
                                DR. KRESS:  And late releases in general.
                                DR. POWERS:  It's also true that the crucial
           systems for shut-down operations aren't going to make
           this list here unless crucial equals well under normal
                                DR. BONACA:  You mean for intermediate
                                CHAIRMAN APOSTOLAKIS:  I think --
                                DR. BONACA:  I am making this comment
           because I believe that there is an issue, at least in
           the generic fashion, for ranking we have to derive
           which is the issue of having a well-reflected on set
           of acceptance criteria.  I mean, our CDF and LERF are
           the only criteria to use.  I mean, we have discussed
                                CHAIRMAN APOSTOLAKIS:  The question really
           is, I mean, it is a legitimate question in a sense
           but, on the other hand, you might say, "Well, gee, you
           guys have approved regulatory guide 1.174 and all this
           licensee does is follow 1.174 and that guide says LERF
           and CDF."  Shall we raise the issue of what is risk
           informed regulation every single time there is a case
           before us?
                                DR. KRESS:  Yes.
                                CHAIRMAN APOSTOLAKIS:  Then that throws the
           process --
                                DR. KRESS:  We've approved a lot of
           regulations in the past that have proved to have flaws
           in them.  I view this as a flaw of 1.174.  You see,
           1.174 was meant for very specific things.  I think
           we've carried it well beyond what it was intended for
           when we try to make it a generalized way to risk
           inform the regulations.
                                CHAIRMAN APOSTOLAKIS:  The next time the
           issue of revised or updating 1.174 comes up, I think
           this is a legitimate issue.  Put yourself in the
           situation of a licensee.  We have these new regulatory
           guides, they want to use them, and then the issue
           comes back and they say, "No.  Look."
                                DR. KRESS:  Put yourself in the place of the
           public and the concern of late releases and land and
           sees that NRC is not dealing with that.
                                DR. BONACA:  But they have an expert panel,
           too.  The expert panel makes judgments that remove
           components from a list and may even add them.
                                All I've got to say is to make this
           statement that has been made, that you're going to
           have to consider late containment failure because by
           the time evacuation has taken place, it defeats
           everything we have done in this industry from day one
           which is simply you are not going to mess around with
           the public issues.
                                CHAIRMAN APOSTOLAKIS:  And why when we look
           at license renewal we say the regulations dictate that
           we look at it in a deterministic way.  All this stuff
           about risk and PRA over the last 25 years is not
           relevant, all of them.  
                                Why don't we say, "Gee, if you've got that
           much frequency above the goal, maybe you ought to do
           something more."  I would say no because the
           regulations say this.  I mean, at some point you have
           to go by the rules.
                                DR. SHACK:  In this case, George, we don't
           have a rule yet.  Option 2 is trying to figure out how
           to do this.
                                CHAIRMAN APOSTOLAKIS:  They are following
                                DR. SHACK:  Nothing says that has to be cast
           in concrete.
                                CHAIRMAN APOSTOLAKIS:  I'm not saying it
           should be cast in concrete.  The issue should be
           raised but I don't think it's fatal because then
           nobody is going to try these things.  They are going
           to say, "Wait for 10 years and until those guys in
           Rockville decide what's important.
                                DR. KRESS:  I think all we're asking for is
           a question and an expert panel to look at it and say
           does this particular SSC impact light containment
           releases or late containment failure.  If the answer
           is yes, you give it a weighting factor on the scale
           but you put that particular component in with the list
           that you have.  I maintain it would probably only add
           about five or six.  Maybe more than that but the
           question ought to be asked is my point.
                                DR. BONACA:  And the point again, the
           latitude that the expert panel has is very large. 
           Clearly, they --
                                DR. SHACK:  They don't drop things.  If the
           PRA says it doesn't get dropped --
                                DR. BONACA:  If a system is rated
           significant but has multiple trains to support it,
           they are calling them, for example, a lower
           significance because they have it on their system. 
           Now, they are taking quite a latitude.
                                CHAIRMAN APOSTOLAKIS:  That's the same
                                DR. BONACA:  No, no, it's not the same
           issue.  I'm saying that the expert panel has a
           significant decision making they have established and
           I support it.  I can question the decision but I agree
           that they have the capability.
                                I think they should also reverse capability. 
           I think that the issue with these guys here is one
           that looking at the generic process we would have to
           reflect on and understand.
                                CHAIRMAN APOSTOLAKIS:  I'm having problems
           with 1.174 myself.  I think when we make comments like
           this, we should be aware of the other guy's problems. 
           If we throw 1.174 out the window --
                                DR. KRESS:  1.174 has a statement in it that
           in addition to the CDF and LERF you will comply with
           all the deterministic requirement.  Those
           deterministic requirements deal with things like late
           containment failure releases.  
                                Here we have an exemption that says we don't
           have to do light containment because it doesn't affect
           CDF or LERF, but it is in all these other
           deterministic requirements that you are supposed to
           comply with.
                                CHAIRMAN APOSTOLAKIS:  Well, if you put it
           that way, I think it's a more legitimate concern in my
           view because you're doing it in the context of an
           approved guide.
                                DR. KRESS:  I think that was the reason they
           left that kind of statement in the 1.174 is to
           recognize it wasn't just CDF and LERF.
                                CHAIRMAN APOSTOLAKIS:  In that context,
           though, I mean, when you talk about these kinds of
           things, the question is whether you should limit
           yourself to these big items like core damage and
           releases from containment.  
                                A lot of these other requirements are there
           to really address the cornerstones of the oversight
           process.  I mean, we don't want to see initiating
           events.  We don't want the integrity of the primary
           look to be compromised.
                                A lot of the requirements are there to make
           sure that these cornerstones are satisfied.  Now if we
           come in with a risk approach that says we are going to
           look at CDF and LERF and late containment failures,
           are we consistent?  
                                I don't think we are because there may be
           some requirements there, you know, the staff has made
           it very clear we just don't want to see initiated even
           though they may not progress to something very severe.
                                DR. BONACA:  The issue of late containment
           failure, I don't think they use the PRA for that. 
           They use some of PRA regarding the fact that the
           highest risk is LERF.
                                MR. SIEBER:  When you look and see how they
           classify based on RAW and Fussel-Vesely, that is
           really CDF and LERF without those extended effects. 
           I could do it but I don't think as I read the
           methodology that they have done it.
                                CHAIRMAN APOSTOLAKIS:  Do you think, though,
           that if there was an issue regarding one particular
           component that came from the PRA or from the questions
           that it was really in risk 2, category 2, and it was
           important to late containment failures, do you think
           the panel would not be aware of that and perhaps move
           it to something else?
                                DR. KRESS:  From what I read in the report,
                                CHAIRMAN APOSTOLAKIS:  Which may be a matter
           of documentation again, the same as it was with the
           other thing.  If you put it in writing, then the staff
           will stop asking questions about that.
                                DR. KRESS:  All I have to go on is what I
           have in writing.
                                CHAIRMAN APOSTOLAKIS:  I know.
                                DR. BONACA:  They ask questions.  We ask
           questions and the answer was because it's a small
           leakage so it is minor and there will be no impact.
                                I mean, it really undermines somewhat my
           faith in that expert panel because although you may
           rationalize that, dealing with issues that have to do
           with the last barrier of the tail end of a major
           accident is something that is totally new in this
                                DR. KRESS:  And their statement, George,
           that large early releases prompt fatalities dominate
           the risk to me is an unproven assumption.  When I say
           that, what they mean is if you meet that goal, you
           will also meet the latent fatality goal but it says
           nothing about land contamination, total injuries,
           total deaths.  I don't know whether it dominates the
           risk because we do not have appropriate risk metrics
           for these other things to compare it with.
                                CHAIRMAN APOSTOLAKIS:  But, Tom, we proposed
           to the commission to do that and they said no.
                                DR. KRESS:  I know, but I'm a persistent son
           of a gun.
                                CHAIRMAN APOSTOLAKIS:  There has to be --
                                DR. BONACA:  All that we have to do is say
           this stays in the list because they are significant
           and they could affect releases.  The whole issue of
           performance measures from PRA would be moot if they
           had made the call.  They didn't.  That's why I'm
           questioning the call.  
                                I'm not questioning the structure of the
           regulation.  I'm questioning the call.  Maybe then on
           a generic basis if those calls can be made, then there
           has to be a need for more structured guidance.
                                CHAIRMAN APOSTOLAKIS:  But it's pretty
           clear, to me anyway, that when you consider affects
           that go beyond CDF and LERF, that the expert panel
           probably wouldn't know how that component actually
           affected the late release or land contamination or
           injuries, I think it's beyond what information the
           expert panel would ever have.
                                CHAIRMAN APOSTOLAKIS:  But in terms of the
           cornerstones, though, I think the expert panel will be
           very much informed.  In other words, you know, on an
           initiating event that's something that is within the
           experience of people.
                                MR. SIEBER:  Does the staff have a comment?
                                MR. NAKOSKI:  This is John Nakoski.  I'm the
           project manager overseeing South Texas.  I would just
           like to remind the ACRS members that the staff shares
           a concern regarding late containment failure.  We have
           an open item with South Texas on this issue.  We have
           asked them to evaluate their categorization process
           and consider methods to address that.  
                                One of the alternatives we suggested they do
           was to look at their PRA specifically for conditional
           containment failure probability with doing a
           sensitivity study where they increase the failure
           rates of those components important to protecting the
           containment by a factor of 10, similar to what was
           done for the broader sensitivity study.  
                                For each component really, or system, come
           up with an evaluation that says why it's not necessary
           to protect a containment.  We share the concern that's
           being expressed here and we are working with the
                                CHAIRMAN APOSTOLAKIS:  Why only the
           containment?  Why not the other cornerstones?  I
           thought the whole idea of special treatment was to
           make sure that this totality of the deterministic
           regulations protect us from public unhappiness.  It's
           not just health and safety.  It depends upon how you
           interpret health.
                                DR. KRESS:  What this process will do,
           George, is -- what this process will do is focus on
           only risk dominant sequences when they do what they
           talked about.  
                                If you look at conditional containment
           failure probability, I think that's probably an
           appropriate way to deal with this late containment
           issue because you dealt with the other phase on your
                                CHAIRMAN APOSTOLAKIS:  I'm not clear.  CDF
           is in full sequence.  I mean, now the initiating event
           itself is something we don't want.
                                DR. KRESS:  Yeah, but it gets involved in
           the CDF and they've dealt with it to some extent.
                                CHAIRMAN APOSTOLAKIS:  In some sense but it
           doesn't get the same importance.
                                DR. KRESS:  Perhaps.  Perhaps.  
                                CHAIRMAN APOSTOLAKIS:  The objectives, it
           seems to me, have not really been settled.
                                DR. KRESS:  But, you know, if the thing is
           not important to CDF and SSC, then it's likely not
           real important to the initiating event frequency.
                                CHAIRMAN APOSTOLAKIS:  No, because you may
           have an initiating event that has been mitigated with
           very high probability.
                                DR. KRESS:  Of course.  
                                CHAIRMAN APOSTOLAKIS:  I think we are going
           to come back to these things.  Right?
                                DR. KRESS:  Right.
                                DR. WALLIS:  I had a question about that. 
           You have 5.7 percent in the PRAs but 8.78 percent turn
           out to be safety risk significant.  Presumably the
           expert panel added quite a few.
                                MR. SIEBER:  Right.
                                DR. WALLIS:  I just wonder about the
           overlap.  Are there perhaps things that the expert
           panel considers which are really more important than
           are in the PRA?  There's an overlap there.
                                MR. SIEBER:  I think there are some things
           in the PRA that are of low risk significance.
                                DR. WALLIS:  So you might argue that --
                                MR. SIEBER:  So not all 2,400 items that
           were in the combined PRAs for those units necessarily
           made it to the --
                                DR. WALLIS:  I was just telling you
           something about completeness of the PRA.  The expert
           panel adds things which really are more significant
           than some of the things in the PRA.  Perhaps those
           things should have been in the PRA in the first place.
                                MR. SIEBER:  When we get to the
           classifications scheme that the expert panel used, you
           can see how, for example, some components would have
           ended up being risk significant as far as their scheme
           is concerned and not necessarily been in the PRA when
           we get to that.        
                                DR. WALLIS:  Maybe you could address that
                                CHAIRMAN APOSTOLAKIS:  The panel used
           criteria out of CDF and LERF.  They actually did.
                                DR. KRESS:  If PRAs were complete and dealt
           with uncertainties and dealt with all the modes of
           operation such as shutdown or low power, then you
           would expect PRA to kick out all the important things.
                                CHAIRMAN APOSTOLAKIS:  That's right.  On the
           other hand --
                                DR. KRESS:  It's not complete and there are
           parts that are highly uncertain, then it doesn't deal
           internally with shutdown and other things it doesn't
           deal with very well so, you know, you would expect
           other questions to be asked.
                                CHAIRMAN APOSTOLAKIS:  It's not just
           incompleteness.  It's also --
                                MR. SIEBER:  You could not write a PRA that
           covered all of these components in my opinion.  I
           mean, that would be lifetimes worth of work to try to
           model all of these subcomponents.
                                DR. POWERS:  I'd like to point out that a
           lot of people are making PRA their lifetime's work.
                                MR. SIEBER:  I understand that.  
                                The reason for me putting this slide up is
           just to show that there's two different methods of
           arriving at determination of risk significance.  As
           Dr. Shack pointed out, these are additive.  You go
           through the PRA portion of it to cover the 2,400
           components.  Then the expert panel does the remainder.
                                Interestingly enough, they also use the
           expert panel as a way to check by doing some of the
           PRA components also.  It turns out that there was some
           consistency there between when they were evaluated
           both ways.  One way by PRA and the other way by the
           expert panel.  I would like to talk about the PRA
           components first and then the expert panel components
                                From the PRA results, classification for the
           ranking that they got was high, medium-R, which means
           that they want to consider it as high so that sometime
           in the future if it became reclassified as high, they
           wouldn't be stuck without documentation, without
           adequate maintenance, without inspections and
           surveillance, and all the other things that Appendix
           B requires because these things can shift as the plant
           is modified.  There is additional operating experience
           as far as failure rates and so forth are concerned.
                                Then medium and then lastly low.  These are
           all based on risk achievement worth and Fussel-Vesely
           criteria.  That is one of the reasons why the PRA
           subcommittee was a part of this to assist to the plant
           operations subcommittee.  
                                It's not clear in my mind.  These look a
           little arbitrary to me.  It's not clear in my mind if
           these are the right numbers and the right criteria or
           not.  Perhaps I could ask for comments on that from
           anyone who feels --
                                DR. KRESS:  Associated with that question is
           if the RAW is 99 --
                                MR. SIEBER:  Right.  What do you do?
                                DR. KRESS:  -- take it down to the medium
           where the other things are met.
                                MR. SIEBER:  That's where the expert panel
           comes in again.  We shouldn't take these as rigid
           boundaries and so on.  I mean, the expert panel does
           evaluate the results of this, too.
                                I think the whole approach here should be to
           put things in context.  There is a decision that is
           made by the panel.  In order to make that decision,
           they collect information from analysis.  One is the
           PRA with these kinds of things, the high, medium, and
           so on.  
                                They collect information from the five
           questions that Jack will talk about in a little bit,
           the rates and so on, doing it different ways.  They
           can decide looking at the individual categories and
           then they deliberate.  This is really a structured
           deliberation.  In that context if RAW is 99 is
           irrelevant because they will look at it and they will
           not say, no, it's not high because it's 99 and the
           boundary was 100.  The other thing is --
                                CHAIRMAN APOSTOLAKIS:  What would they do
           with 90?
                                MR. SIEBER:  Well, they have to make a
                                DR. SHACK:  Once you've made the decision,
           you do have to check with the sensitivity study.  I
           claim that's the real decision.
                                CHAIRMAN APOSTOLAKIS:  Exactly.
                                DR. SHACK:  This is the way to select a
           group of components to examine that way.  If you can't
           meet the sensitivity study, then you have to go back
           and you'll throw out components that hit 90.  You'll
           have to go back and keep throwing stuff out until you
           can get through the sensitivity analysis.
                                DR. KRESS:  RAW is the sensitivity study.
                                CHAIRMAN APOSTOLAKIS:  Yeah, but the big one
           at the end where they increase the federal rates by
                                MR. SIEBER:  I have some questions about
           that, too, which maybe I would like to address.  First
           of all, this classification puts things on the list. 
           On the other hand, when the expert panel did evaluate
           components, they evaluated not only the ones that
           didn't show up in the PRA but also ones that did.  
                                It could end up on this new Q-list more than
           one way.  It could end up there because of the PRA and
           this classification scheme, or it could have ended up
           there because of the expert panel which is independent
           but serves as a check, one against the other.
                                CHAIRMAN APOSTOLAKIS:  No, but this was
           input to the panel.  There was no categorization
           independently of the panel.
                                MR. SIEBER:  That's right.
                                CHAIRMAN APOSTOLAKIS:  The panel has the
           final word so this goes to the panel for evaluation.
                                MR. SIEBER:  Right.
                                CHAIRMAN APOSTOLAKIS:  Jack asked where the
           numbers come from.  It's really experience and
                                DR. KRESS:  Let me ask you a question.  I
           would expect that the value of, say, RAW or Fussel-
           Vesely that's important would depend on absolute value
           in the CDF and LERF.  It doesn't show what they want. 
           Why doesn't it?
                                CHAIRMAN APOSTOLAKIS:  It's relative. 
           That's one of the problems with these things, that
           whether you are at the 10 to the -3 CDF.
                                DR. KRESS:  I understand that.  I'm saying
           that the cutoff, the threshold ought to depend on the
           absolute value and I don't see that reflected.
                                CHAIRMAN APOSTOLAKIS:  It was in the paper
           by Geoak, Perry, and Sherry that these numbers and the
           actual delta CDF don't relate.  Why should you have
           the same cutoff value for all plants?
                                DR. KRESS:  If I had a CDF 10 to the -6, why
           would I worry about the RAW and the 100.
                                CHAIRMAN APOSTOLAKIS:  Because it can still
           make it 10 to -4 which is still acceptable.
                                DR. KRESS:  That's why I think I worry.
           These might be plant specific values and I worry about
           getting them locked into a system for every plant that
           we review.  I might not like those numbers for some
           plants but I might like them very well for, say, South
                                CHAIRMAN APOSTOLAKIS:  I still think we have
           to have things in perspective here.  I don't think
           that any single method they use can withstand the kind
           of scrutiny we are giving it here.  We expressed a lot
           of concerns last time at the subcommittee meeting.
                                Let's see what we're trying to do here. 
           Again, this is structured deliberation.  The panel
           puts them in categories.  Then you have two major
           things that I think save the day.  One is the
                                They say, "Okay.  Forget about all these
           things.  We made mistakes.  Let's raise all the
           failure rates by 10 and see what happens."  Then they
           find that nothing much happens.  That's a very
           powerful argument.
                                DR. POWERS:  I wonder how powerful it is,
           though.  The challenge you always have with these
           things is they are one at a time kind of variation and
           they are not really partial derivatives.  
                                You tell me that you've raised all these
           numbers by a factor of 10 it's a little difficult for
           me to put that into perspective.  Has anyone ever
           taken one of these assessments for any plant, I don't
           care which one, and looked at partial derivatives and
           second partial derivatives?  
                                CHAIRMAN APOSTOLAKIS:  No.  This is a very
           new idea.
                                DR. POWERS:  Why not?  Why shouldn't
           somebody do that?
                                CHAIRMAN APOSTOLAKIS:  Because they haven't
           thought about it.  Nobody's thought about it.
                                DR. POWERS:  You see, it all boils down to
           the question of where did the factor of 10 -- I mean,
           factor of 10 sounds big but it's not really big.  I
           mean, we're working in long space here.
                                CHAIRMAN APOSTOLAKIS:  That's my point.  The
           sensitivity study is one.  The second, let's not
           forget what the decision is here.  It seems to me you
           are relaxing some of the special treatment
           requirements.  What's going to happen?
                                If you have an impact at all, it's going to
           be gradual.  You're not going to have a catastrophic
           failure tomorrow to 15 components and they will have
           a monitoring problem.
                                DR. KRESS:  In reality what you're saying is
           special treatment requirements are not very risk
           significant in the first place.
                                CHAIRMAN APOSTOLAKIS:  That's exactly right.
                                DR. KRESS:  That's a saving grace made for
                                CHAIRMAN APOSTOLAKIS:  Exactly.  That's my
                                DR. KRESS:  But that's an assumption,
                                DR. SHACK:  No.  If you pick a different set
           of components and change the failure rate, you get a
           very different answer.  This factor can only work
           because you're doing it to a selected set of
                                CHAIRMAN APOSTOLAKIS:  That's correct.  But
           there are several issues here.  First of all, to save
           that relaxing the requirements will lead to an
           increase in factor of 10 is ridiculous.  It's utterly
                                Second, you are increasing the failure rate,
           not the event itself.  It's not going to happen
           tomorrow.  You're not going to have a huge common
           cause failure where all sorts of things fail.  I mean,
           if these things happen, they will catch them.  They
           will have a monitoring program.
                                DR. SHACK:  But, George --
                                MR. SIEBER:  This is one of the elements of
           this classification scheme, the feedback system, which
           comes from the corrective action program.  On the
           other hand, I guess when I thought about this, I think
           of different kinds of plants with different risk
           profiles and how this sensitivity study would reflect
           itself in those plants.
                                For example, the South Texas project has a
           pretty good risk profile and it comes about because of
           the three safety trains.  When you increase a
           competence failure rate by a factor of 10, is it
           really going to show up as being significant in the
           profile for that plant?  
                                I would think it would not be as significant
           because of the redundancy that is already built into
           that plant with the three trains.  But if you had two
           trains, it may be more significant.  For a different
           plant, you may reach a different conclusion.
                                The other kind of plant that I consider is
           there are some plants that have relatively high but
           acceptable risk profiles and are dominated by a
           particular sequence.  
                                If you change the failure rate of a
           component not involved in that sequence, it gets
           swamped out by the dominate sequence so you may not be
           able to draw a conclusion from that either.  I think
           sensitivity works better for some plants than for
           other plants.
                                DR. KRESS:  I'll tell you what bothers me
           about the whole process is I have this intuitive
           feeling, like George said, that this is not very risk
           significant, but my intuition has been wrong a lot. 
           I don't see a coherence to this process where you
           start from the top level.  
                                Our objective is to meet these regulatory
           limits on certain things.  They are going to be things
           like containment failure, total deaths, maybe CDF. 
           I'm not even sure I would include that.  Most people
           would but we want to achieve certain frequencies which
           you exceed land contamination.  Those are all
           regulatory objectives.  Those are what we're trying to
           achieve by the systems and components we have in the
                                I don't see starting from those things we're
           trying to achieve looking at how the plant already
           meets those, and determining how each system and
           component affects that and whether or not if I put one
           in one category or another, whether or not I step over
           the balance or get too close to the balance depending
           on the uncertainty.  
                                That coherence is just not there for me and
           that's what bothers me.  It just doesn't hold together
           because, you know, you look at this and I don't know
           why RAW of 100 is a good number for this plant.  Why
           is it a good number?
                                DR. SHACK:  This is just a preliminary
           screening value.  There is a misplaced precision here. 
           We're talking about numbers that just don't have that
           kind of exactitude.
                                DR. WALLIS:  I think they should have some
                                DR. SHACK:  What you really look at is you
           get to these numbers and do you get a change in CDF
           and LERF that is significant by the standards of
           1.174.  It may well be that for other plants when you
           go through that final assessment you'll have to use
           different numbers.  Maybe you could have changed these
           numbers and still met that assessment in South Texas.
                                DR. KRESS:  That's the part that's missing.
                                DR. SHACK:  No.  That's the consistency
                                DR. KRESS:  It doesn't say how these numbers
           were derived from the 1.174 requirements.
                                DR. SHACK:  The question is is it good
           enough that when you use these numbers, you meet the
           1.174 requirements?
                                DR. KRESS:  I don't know.  That's the part
           that's missing.
                                DR. SHACK:  No.  They do.  That's what they
           check at the end.  They mask their categorization. 
           Then they do their sensitivity analysis to make sure
           they meet the 1.174 requirements.  Could they have set
           the numbers at 110 and still met it?  Maybe.  Could
           they set them at 90 and still met it?  
                                DR. WALLIS:  Maybe for some plants it should
           be 1,000 or 10 or something.  Maybe it's really
           different for some plants.
                                DR. SHACK:  The answer is as Jack said,
           you'll get different answers for different plants. 
           Maybe if you use these numbers and you go to a plant
           with two trains, when you make the sensitivity
           analysis you'll find out that you don't meet the 1.174
           requirements.  You'll have to come back and change
           these values.  You'll have to be more restrictive. 
                                MR. SIEBER:  In fact, I see this as an
           interactive process.  If you applied this methodology
           from one plant to another, you would have to go to the
           end, do the sensitivity analysis to determine whether
           you picked the right numbers in the first place.  
                                As Dr. Apostolakis said, it's basically
           experience.  I don't have enough experience to say
           whether 100 or 110 or 90 is the right number for the
           upper boundary.  On the other hand, the proof of the
           pudding comes from the sensitivity analysis as long as
           you understand what that really means because
           different plants are going to respond in different
           ways to the outcomes of that analysis in my opinion.
                                DR. KRESS:  So we're being asked to believe
           that a sensitivity of 10 varying one component at a
           time --
                                DR. SHACK:  No, no.  All together.
                                DR. KRESS:  All together.
                                DR. SHACK:  All together.  They raise them
           all by a factor of 10 all at once.  It's not one at a
           time.  Bang, all the non-risk significant components
           go up by a factor of 10 all together.  To do what you
           want to do, you would really have to know how the
           special treatment affects the failure.
                                DR. KRESS:  Which I agree is impossible.
                                DR. SHACK:  If we want to stay here until
           hell freezes over, we can do it.
                                MR. SIEBER:  There is a more subtle question
           buried in that.  If you maintain surveillance and have
           a good corrective action program and so forth, it
           probably doesn't change the failure rate very much.
                                When I think about it where you don't have
           diversity, you may change the common cause failure
           rate which I think is perhaps more significant than a
           single failure or an increased probability of single
           failure.  That's my intuitive feeling as opposed to
           any proof that that would occur.  
                                It seems to me if you eliminate certain
           portions of a consideration for a group of identical
           components, if they're going to fail, they're all
           going to fail in that mode sooner or later.  So that
           may have a barring on it.  On the other hand, their
           treatment of common cause appears to be conservative
           in the way they have approached it.
                                In any event, this is the --
                                MR. SIEBER:  There's a typo in there
           somewhere.  It cannot be .001 on the top because the
           Fussel-Vesely of .002 and a RAW of 1 would be both
           high and low at the same time.
                                DR. WALLIS:  There probably is and I'll look
           that up and tell you what it is.
                                MR. NAKOSKI:  This is John Nakoski again. 
           It is on the high value Fussel-Vesely greater than
           equal to 0.01.
                                DR. WALLIS:  There are too many zeros.
                                MR. SIEBER:  Okay.  
                                Well, this takes care of the 5.7 percent. 
           Let's take a quick look at what the expert panel does
           with the 94.3 percent.  They ask five critical
           questions and they rank each component by the
           component's sensitivity to frequency of occurrence,
           which is demand, and/or the perceived risk impact. 
           Let's take a look at the five questions.
                                These are evaluated basically two different
           ways.  These are the questions that they chose to ask. 
           I guess one of the observations one could make is that
           there is some overlap from one question to another. 
           It's not totally clear as to how great the answer is.
           On the other hand, these seem to be reasonable
           questions in my own mind to ask for the purpose of
                                Does the loss of this function cause an
           initiating event?  
                                Does the loss of this function directly fail
           another risk significant system?
                                Is the function used to mitigate accidents
           or transients?
                                Is this function directly called out in EOPs
           and ERPs?
                                Does this function directly affect safe
           shutdown or mode changes?
                                Now, they have assigned a specific weight to
           each of these questions.  If you want to make notes,
           "Does the loss of this function cause an initiating
           event?" is weighted as three which seems to me a
           little odd but that's the way they weight it.
                                "Does the loss of this function directly
           fail another risk significant system?" is weighted as
                                "Is the function used to mitigate accidents
           or transients?" is weighted as five or most important.
                                "Is this function directly called out in
           EOPs and ERPs?" is also weighted as five.  At least
           for the confidence of the operator, it would be nice
           if he knew that everything that was in the EOPs or the
           ERPs was operable and would work.
                                "Does this function directly affect safe
           shutdown or mode changes?" is rated as a three.
                                Now, for each of the questions the component
           is rated basically two ways.  One is what is the
           demand and what is the risk significance in the
                                Then it is weighted by a scale of one
           through five with five being the most risk
           significant.  You multiply the five times five points
           for the question itself times by the weighting factor
           which is five and you end up with a maximum 25 or a
           minimum of five.
                                DR. WALLIS:  So if they weighted them one,
           two, three it would have been just the same.
                                MR. SIEBER:  Well, they --
                                DR. WALLIS:  They all got three for writing
           their name on the paper.
                                MR. SIEBER:  That's right.
                                DR. UHRIG:  Jack, this isn't as a yes, no,
           zero, one which is then multiplied by three and then
           multiplied by five?
                                MR. SIEBER:  No.  Actually, the --
                                DR. UHRIG:  The question is is it or is it
                                MR. SIEBER:  The expert panel is actually
           instructed by their procedure to rank.  Okay?  And
           that's on the basis of frequency of occurrence or
           demands and risk significance.  Is that not correct? 
           It's not a zero one proposition.
                                For example, and let's go back, if I asked
           the question, "Is the function used to mitigate
           accidents or transients."  When the demand is high and
           the risk significance is high, I would rank it as
           five.  Five times the weighting factor of five is 25
           so you get 25 points.  Okay?
                                On the other hand, does the function
           directly affect safe shutdown or mode changes, the
           weighting factor is three.  Even though it may be
           important and risk significant, the total score of
           five times three is 15.  Okay?
                                DR. WALLIS:  Who fills this out?  Does the
           STP fill this out or does the expert panel fill this
                                MR. SIEBER:  The expert panel who is
           employed by STP.
                                DR. WALLIS:  They have to answer all their
           own questions?
                                MR. SIEBER:  That's right.  You end up, by
           the way, as part of the process a different feudalist
           than the original one which is part of the submittal.
                                DR. WALLIS:  So they have to do all the work
           of finding out if this function is called out in EOPs
           and all that?
                                MR. SIEBER:  That's right.  It's pretty easy
           to do.  The EOPs are on the computer and all the mark
           numbers are in there.  All they have to do is a word
           search and out comes all this --
                                DR. WALLIS:  Yeah, but if it's a kind of
           secretarial job, we really don't need to have an
           expert panel do it.
                                MR. SIEBER:  No.  The clerical function of
           arranging all this I'm sure is done by clerks.  The
           panel actually has a pretty demanding qualification
           requirement as I see it.
                                MR. LEITCH:  Jack, are there two answers,
           one based on frequency and the other based on
           perceived risk impact or are they somehow merged
                                MR. SIEBER:  They are merged together so
           that you end up with a single number.  These are the
           risk impact and the frequency and this is the way it's
           phrased.  If you look in your package, there would
           have been -- you weren't there but there is a document
           called "ACRS Backup."  
                                If you look at that, and these pages aren't
           numbered, but about halfway through where it says
           "weighting scale," it explains how the questions are
           asked, how the match is done, and how the scores are
           determined.  They are actually determined two
           different ways.  One of them is you determine the
           total score based on all the questions.  
                                As it turns out, the combination of two
           fives, a four, and two threes when multiplied by five
           equals 100.  That's where the weighting factors
           actually came from as opposed to getting 25 points for
           putting your name on the paper.
                                So then they look at the ranges in which
           these answers came out and they said if it's between
           71 and 100 it's high-risk significance.  If it's
           between 41 and 70 it's medium-risk significance. If
           it's 21 to 40, it is low-risk significance.  Zero to
           20, it is not risk significant at all.  
                                This is one of two methods that they use to
           categorize.  The other method actually looks at the
           answers to individual questions.  If you get an answer
           for an individual question with this weighting factor
           that is greater than 20, then any one question
           automatically high-risk significance.
                                If it's between 12 and 20 it's medium-risk
           significance.  If it's between six and 12 for any
           single question, it's low-risk significance.  If it's
           below six, it's not risk significant at all.
                                These are additives.  You can either achieve
           the score this way or the answer to a single question
           could put it into a category, the components up in the
           highest category of whatever method is used.
                                Now, I have to ask myself a few questions
           when I think about this whole process.  The question
           that come to my mind is when we just stick with CDF
           and LERF, which to me is implied when you use RAW and
           Fussel-Vesely, are these -- that's not true?
                                DR. KRESS:  No.  You can do a RAW or Fussel-
           Vesely on anything.
                                MR. SIEBER:  Okay.
                                DR. KRESS:  But the RAW and Fussel-Vesely
           they use were for --
                                MR. SIEBER:  For CDF and LERF.  Well, the
           question is are these the right criteria and are they
           the only criteria that should be used which, in fact,
           CDF and LERF --
                                DR. WALLIS:  Let's go back to what's
           happening here.  There's the PRA results which form
           one package.  Then there's the 94 or 96 percent.
                                MR. SIEBER:  Right.  Another box.
                                DR. WALLIS:  This is the other box.
                                MR. SIEBER:  And they overlap.
                                DR. WALLIS:  The experts don't evaluate the
           stuff that's in the PRA using their matrix?
                                MR. SIEBER:  Yes, they did.
                                DR. WALLIS:  Ah, so you can compare one
           versus the other.
                                MR. SIEBER:  In fact, that's one of the
           checks used during the process.
                                DR. WALLIS:  Okay.
                                MR. SIEBER:  That's one of the checks.
                                DR. SHACK:  That's how you decided that the
           binning was reasonable.
                                DR. WALLIS:  Is there some evaluation of the
           reasonableness of the binning when you look at this
                                MR. SIEBER:  Yes.
                                DR. WALLIS:  Okay.
                                MR. SIEBER:  And to me that's one of the key
           saving graces of this process, at least from the
           standpoint of what the staff has to deduce out of the
           process to say, "Yeah, this is reasonable."  Or, "No,
           it is not."  That is one of them.  The sensitivity
           studies is another one.  To me I think it's pretty
           important that they did that overlap and came up with
           a reasonably consistent answer because that tells you
           something about the effectiveness of the panel.
                                DR. SHACK:  I seem to recall numbers like
           PRA gave me 800 and the expert panel on the same set
           of components gave me 840 so they were somewhat more
           conservative which you would sort of expect.
                                MR. SIEBER:  Okay.  The next question that
           I asked in my own mind, which we have discussed at
           length here, is are RAW and Fussel-Vesely the correct
           measures of importance of the component in this
           context and also the numbers.
                                DR. WALLIS:  You shouldn't use the term
           correct.  You say appropriate or something.
                                MR. SIEBER:  Appropriate.
                                DR. WALLIS:  Correct implies some sort of
           absolute standard which is the reason for these
                                MR. SIEBER:  That's right.  Okay.  And the
           third question, I think, that I asked of myself, which
           I came away with based on the outcome of the
           comparisons as being okay, is do these deterministic
           questions and the weighting factors make sense.
                                I guess you can ask any questions that are
           pertinent to risk and assign any weighting factors. 
           The proof of the pudding is when you compare that to
           the PRA studies, do you end up with consistency?  The
           answer is yes.  These are reasonable questions to ask
           except, in my opinion, there is some overlap
           associated with them.
                                I scratch my head.  For example, does a
           failure of this component create an initiating event,
           and they weighted it only as three.  I thought, gee,
           if you don't have any initiating events, your risk
           goes way down.  It wasn't clear to me why that was the
                                On the other hand, there's a lot of
           initiating events that don't proceed beyond the fact
           that the plant shuts down safely and 9,999 out of
           10,000 is probably the right number for that because
           we've only had in commercial plants one accident.
                                DR. BONACA:  You are close to the end,
                                MR. SIEBER:  Yes, I am.  We'll move rapidly
           to the end.  I just have two more slides to do.  
                                The process of doing this comes up with a
           two-by-two matrix which looks at safety related and
           risk significant components, non-safety related but
           risk significant which covers the two categories that
           I listed first as the purpose, and then safety related
           non-risk significant and non-safety related non-risk
                                Of course, they end up with 8.7 percent as
           compared to 5.7 which is one way or another identified
           by the PRA as being important.  There is some overlap
           so the expert panel actually added approximately 1,200
           components to the process.  Non-safety related and
           risk significant, 372.  
                                Now, the question here is these were not on
           the original Q-list but it turns out that they are
           important from a safety and risk standpoint.  So the
           question is do we now have a safety question that
           perhaps STP has answered by using this process.  
                                But maybe there are other plants out there
           that have similar original classifications schemes
           where they haven't gone through this process and
           perhaps there are components in other plants that have
           more risk significance than is reflected in the
           application of Appendix B.  To me, that's a site
           benefit to STP but a question for the staff to think
           about in the process.
                                Safety related and non-risk significant is
           12,905 which would be the items where special
           treatment requirements could be relaxed to one extent
           or the other.  And non-risk significant and non-safety
           significant is all the remainder of the components in
           the 29 safety systems that were analyzed.
                                DR. POWERS:  Jack, I never understood
           exactly why in the safety related non-risk significant
           category we don't just treat them the same as the non-
           safety related, non-risk significant.  I relax it down
           to industrial use or whatever it is that you specify
           for --
                                MR. SIEBER:  I think that when you go back
           to the slide, and I may not be able to remember it,
           but there was four classifications from high, medium 
           or --  
                                DR. POWERS:  I understand that.
                                MR. SIEBER:  So in some cases components,
           the application of special treatments, was not fully
           relaxed so that in the event that --
                                DR. POWERS:  I know what they've done.  What
           I don't understand is why they've done it.
                                MR. SIEBER:  Why they did it the way they
           did?  I think it is a conservative approach in my
                                MR. NAKOSKI:  This is John Nakoski if I
           could address Dr. Powers' question.  In option 2 one
           of the restrictions that we have is that we need to
           maintain a design basis of the plant, which is what
           the plant was licensed to.  
                                Completely relaxing all the controls without
           having any confidence that these components would be
           able to perform their functions would essentially be
           a change in the design basis which would be a change
           in the licensing basis which is not where we wanted to
           be in option 2.  That's the short answer, sir.
                                DR. POWERS:  See, I come from the viewpoint
           for these non-safety related non-risk significant
           items when they acquire them, they basically acquire
           things that actually work and do their job so your
           confidence here, if you did the same thing for these
           things in the lower left-hand corner, it's not that
           you would have zero confidence.  You would not have
           maybe as much as you would for the upper left-hand
           corner but it's not zero.  
                                I think there's a nice term or phrase for
           industry practice or something like that for the kind
           of confidence you have.  It just strikes me as
           timidity for the reason of being timid.  That's what
           it strikes me as.
                                MR. SIEBER:  I think the kinds of things
           that are relaxed are some of the pedigree
           requirements.  Is that not the case?
                                DR. POWERS:  Sure.
                                MR. SIEBER:  You buy a valve and the valve
           cost you $1,000, but the bill you get is $10,000 and
           the paper that you get weights three times as much as
           the valve.
                                DR. POWERS:  It should because --
                                MR. SIEBER:  You have to ask yourself how is
           that used for safety?
                                DR. POWERS:  It's nine times more expensive. 
           I mean, the paper is nine times as expensive as the
           valve so it should weigh more.
                                MR. SIEBER:  That's right.
                                DR. POWERS:  It's a trouble I have with
           option 2 to begin with.
                                MR. SIEBER:  I think what you're telling us
           is it's as much a legal requirement as anything else.
                                MR. NAKOSKI:  Specifically for South Texas
           and the exemption space, yes.  In rule making there
           may be other alternatives.
                                MR. SIEBER:  Now, just to finish up here, on
           February 8 we got a package which listed basically
           open items.  I think there were 18 open items -- or
           22.  In any event, when we actually had the
           subcommittee meeting, we only talked about three open
                                The difference is because at the
           subcommittee meeting we are only talking about the
           categorization process.  The list that we had on
           February 8 included all open items on the option 2 
           process.  A lot of those have gone away.  
                                Let's see.  Actually, on that list there
           were 16, four of which were closed, one of which was
           confirmatory, one which is before the risk informed
           licensing panel for some kind of a confirmation or
           final resolution or approval, and seven still remain
           open for the whole process.  Is that correct?
                                MR. NAKOSKI:  I can give you some more
           updated information.  We met with South Texas on
           February 15 and 16.  There were currently five open
           items that were closed without exception based on the
           licensee's response.  
                                Three open items that with some editorial
           changes that were agreed to during the meeting would
           be closed.  Six have some level of success path
           identified and agreed to into varying levels of detail
           and agreement.  
                                Three require, I think, further interactions
           between the licensee and the staff and those deal
           primarily with the seismic and environmental
           qualification issues.  There is one on controlling
           changes to the processes that the staff has not yet
           finalized its position on.
                                MR. SIEBER:  Okay.  Thank you.  
                                That concludes the presentation if anybody
           has any comments.  This is where we stand at this
           point.  I was sort of under the impression that what
           we ought to do is wait until the process is completed
           before we write a letter but we may want to reconsider
           that because, I guess, in my opinion this is a pretty
           complex subject and to leave everything until the end
           might cause a setback from the staff's standpoint on
           their timely resolution of things.  That's something
           we have to decide this week.
                                DR. BONACA:  What are the thoughts of the
           staff regarding the report at this time?
                                MR. NAKOSKI:  I think your insights on
           categorization at this time would be valuable for us
           to move forward recognizing that you haven't gotten
           any substantial feedback on where we are with
           treatment.  I think there would be value added now to
           get this behind us.
                                MR. LEITCH:  I have one question regarding
           weighting.  If I understand correctly, zero to 20 they
           call non-risk significant.
                                MR. SIEBER:  That's right.
                                MR. LEITCH:  That would then put it in the
           lower left-hand box, safety related.
                                MR. SIEBER:  If it was on the Q-list and it
           was zero to 20 and confirmed by the expert panel as
           belonging there, it would be in the lower left-hand
                                MR. LEITCH:  I can understand how it would
           get to the very low risk-significant but not non-risk
           significant.  In other words, if you ask these
           questions, say is the function used to mitigate
           accidents or transients, and even if it's a three as
           far as risk, I tend to get a 15.
                                MR. SIEBER:  I think what happens is a lot
           of times in the original classification of what
           belongs on the Q-list and what does not, they would
           take it either as functions or systems.  
                                There are things in a system that might
           require some pedigree because it originally fell under
           the requirements of Appendix B who really doesn't
           serve any function whatsoever as far as accident
                                It's not called out in the EOPs.  It can't
           cause an initiating event.  It's just there.  It's in
           that system because of the way it was classified the
           first time around.  I suspect there are a fair number
           of items that are like that.
                                MR. NAKOSKI:  Mr. Leitch, if I could answer
           that.  An example at South Texas, for example, a gauge
           in a safety related system that's just used to collect
           data.  It doesn't perform any function.  Answer does
           it initiate an event, you're going to say no so it's
           zero.  There's a lot of times when you answer those
           five questions you can have a zero.
                                DR. UHRIG:  Then you do have a zero one type
           thing multiplying.
                                MR. NAKOSKI:  It's a zero if it's no and it
           can be one through five if it's yes based on --
                                DR. UHRIG:  Okay.
                                MR. SIEBER:  Mr. Chairman.
                                DR. BONACA:  With that, any other questions? 
           I think we will have to make a decision later.  I
           think we should have also the chairman here to make a
           decision on whether we should write a report.  We
           heard the request and that may be appropriate at this
                                If there are no further questions, at this
           point we'll take a break for 15 minutes and resume
           again at 20 of 11:00.
                                (Whereupon, at 10:26 a.m. off the record
           until 10:40 a.m.).
                                DR. BONACA:  Let's resume the meeting now. 
           I wanted to start on time because we have Mr. Grimes
           here who came to help us and Mr. Prato who is the
           present manager for the Arkansas One License Renewal
                                The intent here for me was to provide you
           with a summary of the meeting that took place last
           week on this subject.  We decided not to have a full
           presentation to the committee because, you see, this
           application is very similar to the Oconee applications
           and we felt there were no issues that deserve at this
           time to have a full presentation from the applicant
           and the staff or the full committee.
                                The intent right now is not to write an
           interim letter at this time and distribute to you a
           two-page summary that I put together for my own use to
           keep a memory for the final report we'll have to write
           when the open issues are closed.
                                This summary that you have in front of you
           does not contain information on the open items.  I
           will provide it to you as I walk through these
                                Also, this two-page summary.  On the second
           page at the bottom has Jack Sieber written in.  For
           some reason his name got into it but he doesn't belong
           there so disregard it.  As you can imagine, I was
           surprised when I saw that but somehow it got there. 
           This is to do with some of the intricacies of
           computers I guess.
                                DR. SHACK:  Of all the random things to type
           Jack Sieber seems pretty far down on the list.
                                DR. BONACA:  So let me just walk through a
           little bit this summary.
                                On February 22 we met with the
           representatives of the applicant from Entergy for
           Arkansas One and presented to the staff to review the
           Arkansas One license renewal application and the
           interim SER.  
                                The SER we just call interim because the
           open items are now closed.  Arkansas One is a B&W-type
           PWR designed to generate 2568 megawatt thermal or
           about 836 megawatt electric.
                                Now, the reactor is very similar to the
           Oconee units that we recently reviewed and for which
           have approved those who participated in the approval
           of the SER and of the application.
                                Because of the similarity Arkansas One has
           utilized a lot of the lessons learned from the license
           renewal of Oconee.  In order to benefit from these
           similarities, we asked the staff to provide us with a
           presentation that would highlight the differences
           between the applications for Oconee and for Arkansas,
           as well as the differences in the solutions which
           means specifically age and management programs that
           they have chosen if there are differences.
                                The reason is this will allow us to benefit
           from previous experience.  I would rely on your
           judgment for future applications if that's the right
           approach.  I believe it is the right approach because
           it allows us to keep our memory of where we're going,
           even for the BWRs we are going to review with the
           exceptions of the reactor vessel and other components
           which relate to that.  
                                There is so much similarity in the
           applications from PWR and BWRs simply looking at
           passive components so the staff provides us with an
           informative presentation which was really based on the
           formative comparison.
                                The second observation I would like to make
           is that the application which appeared at the
           beginning quite condensed was quite effective, I
           think.  I'm giving this feedback because it really was
           easy to review it for a number of reasons.  One is it
           contained in the back a number of appendices which
           condensed the information we needed.  
                                For example, Appendix B contained a full
           summary of all the problems that are being credited
           for a license renewal and also segregated the first
           seven problems and new problems.  The rest were
           existing problems.  That really helps understand where
           the new issues are, where the new problems are.  That
           was, in my judgment, a very good format.
                                Appendix C described the approach that was
           chosen to manage aging effects.  Also that was very
           helpful because, again, you have a full dedicated
           appendix where you can go to look for those solutions.
                                I just bring up these issues because I don't
           know to what extent the next applications will reflect
           this format but maybe there is some chance because of
           the NEI.
                                MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes.  I would comment that I think you'll find
           Arkansas is very close to the standard form and
           content that we are recommending in the standard plan
           and the NEI guide that we would endorse with the
           regulatory guide.
                                DR. BONACA:  Thank you.  With that, in
           general the subcommittee had the following
           observations or questions regarding scoping and
           screening.   The scoping and screening methodology
           devised by the applicant identifies components appear
           to be well structured and comprehensive.
                                This methodology we know is consistent
           within the I-9510 and also with the NRC SRP.  The
           Arkansas One FSAR was facilitated in many ways because
           the definition that Arkansas has used for safety
           related is the same definition that the license
           renewal rule uses for safety-related components.
                                Also, the Arkansas One Q-list include all
           the support systems of the safety-related component or
           those systems which are not safety-related but whose
           failure would cause safety-related systems not to be
           effective.  Therefore, because of the definition that
           they have used for actual list, it was easy for them
           to pull those lists out and say these are the
           components which are in the scope of license renewal.
                                Actually, in addition to that, the Arkansas
           application included a number of systems and
           components which were included in the Q-list purely
           because they could have interference with safety-
           related systems by physical interaction, for example.
                                That expanded somewhat the scope and the
           feeling you get when you look at the application is
           that the scope in general is pretty conservative.  It
           went beyond the requirements of the rule in my
                                DR. WALLIS:  Can I ask you about electrical
                                DR. BONACA:  We'll get there.
                                DR. WALLIS:  This may look like Oconee but
           the cables can be quite different.  We know that there
           is degeneration of cables.  I was looking at the hatch
           which is a different one all together.  I couldn't
           quite figure out why some of the cables got screened
           out and some of them were considered because we know
           the cables do deteriorate.  Do they pay proper
           attention to the cables?
                                DR. BONACA:  I think for the EQ medium
           voltage cables they are going to be subjected to the
           requirements that result from the generic issue
                                MR. GRIMES:  Dr. Bonaca, I would like to
           clarify there are three points that are raised by Dr.
           Wallis.  The first is with regard to scoping and
           whether or not particular cables are screened out
           based on function.
                                As I recall Arkansas uses a spaces approach
           so they would only screen out cables if there aren't
           any in the space.  We were confident that the scoping
           will capture all of the requisite cables whether they
           are subject to EQ under 5049 or not.  We rely on the
           process for compliance with 5049 to maintain the
           qualified life for EQ cables.  For non-EQ cables the
           applicant has proposed to --
                                Is this an open item?
                                MR. PRATO:  An open item on medium voltage
           cables -- this is Bob Prato -- that are inaccessible
           and that can be exposed to underground conditions.
                                MR. GRIMES:  And we would expect the same
           form of resolution that we achieved on Calvert Cliffs
           and Oconee.
                                DR. BONACA:  I never thought about the
           medium voltage cable because it's an open item.
                                Regarding scoping and screening again, I
           said before that it seemed to me it was quite
           comprehensive and went somewhat beyond the narrow
           interpretation of the rule.  
                                There are two open items on that.  They have
           to do with the flow orifice that brings in the sodium
           hydrazide and the question is why is it not included
           in the scope.  The other issue is why are a number of
           fire protection systems and components not in the
                                My sense is those are good questions.  I
           understand the reason for the resistance on the part
           of the applicant about his issues.  It's simply that
           they need to provide more information to bring closure
           to these issues.  We felt that we agreed with these
           questions and they need to be addressed.
                                These are the only open issues on scoping.
                                Now, the subcommittee also raised a number
           of specific questions on scope.  We made an effort of
           raising questions regarding systems that have the
           appearance of having been in the scope and they were
                                To all those questions we raised during the
           subcommittee we got answers from the licensee on the
           staff that said that either there was a good reason
           why they were not scooped and we accepted the reason,
           or they indeed were in scope.
                                Often times the reason why there was a
           disconnect in the understanding is that the
           application included in scope, the SER included in
           scope because there had been already communication
           between the staff and the licensee and that brought
           the component in scope.
                                Now, we asked questions regarding these
           issue.  Would the application be modified to include
           those changes which were negotiated in the
           federalization of the SER and the answer was no but
           the FSAR update will include those commitments.
                                Regarding the process used by the applicant
           for defining aging effects requiring aging management,
           that process appears to be comprehensive and
           effective.  They used a new approach where they have
           a set of tools in what they call Appendix C.  
                                In our review we found that the application
           has considered the aging effects we have seen in
           previous applications.  They really have applied the
           lessons learned from previous applications.  That's
           pretty obvious.
                                There are some open issues regarding some of
           this aging management programs.  They have to do, all
           of them in my understanding, with additional
           information to better understand why they are
           effective enough to deal with the aging management
           issues.  Is that correct?
                                MR. PRATO:  This is Bob Prato.  What they
           need to do is they need to add additional description
           to the FSAR supplement.  There are 11 of those items
           where the description that they provided in their
           application was inadequate and they needed to provide
           more information in the supplement itself.
                                DR. BONACA:  So I understand in that sense
           there is no contention there except you want to have
           more information and detail on what they are
           committing to.
                                MR. PRATO:  That's correct.
                                DR. BONACA:  In the section that has to do
           with limited aging analysis, there also seems to be a
           pretty comprehensive inclusion of all the issues
           they've seen for other plants.  There are a number of
           open issues on this.  
                                One has to do with the -- well, one has to
           do with additional information also regarding TLAA in
           the addendum to the FSAR.  
                                Second has to do with buried medium voltage
           cables for which the staff is contending that similar
           cable not in similar environment is not indicative of
           the status of the one which is buried and, therefore,
           cannot be used as an indication and they are
           requesting a program for that and we fully agree with
           that kind of perspective and we are going to see that
           there is closure on this issue.
                                There is another TLAA which is still open
           regarding the specific criteria to be used for forces
           of the Arkansas One containment.  That's also, it
           seems to me, reasonably similar to the Oconee
           questions that we had.  I would expect to have a
           similar closure on that.
                                There is finally an open issue of the aging
           of boroflex.  During the presentation we are told that
           the applicant has agreed that is a problem even for
           the current life and, therefore, they will provide a
           solution that doesn't address specifically the
           extended life but specifically boroflex now.
                                I guess the question I have for the staff is
           are you looking for a commitment at this stage?
                                MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes.  The controversy evolved primarily because the
           applicant chose to challenge the definition of a time-
           limited aging analysis to put this into the context of
           a corrective action.  
                                We don't want to argue about whether it's a
           time-limited aging analysis.  We believe it is.  What
           we're trying to focus on now is establishing
           confidence that there are program attributes
           associated with the corrective action that can be
           relied on in a programmatic way.  
                                We don't necessarily need to know exactly
           how the life-limiting aspects are going to be fixed,
           but we want to know that there are the 10 program
           elements in place that will ensure that before there's
           a loss of function corrective action is taken.  I
           think we'll be able to work that out with the
                                DR. BONACA:  The only surprise I had
           somewhat there is that for initial the nature I know
           that other licensees have already developed plans to
           deal with what is the criteria which you've cited at
           some point you cannot operate any further so some of
           them assume that they have certain split open spaces
           or assume that you have large gross formation of
           boroflex.  I was somewhat surprised that Arkansas did
           not have a problem with the nature. 
                                MR. GRIMES:  Actually, I think Arkansas was
           also surprised.  I think they had envisioned that this
           was an issue that they could deal with in the future
           and they had originally, and Bob can correct me if I'm
           wrong, it originally said that, "This is a time-
           limited aging analysis and we can manage it."  
                                Then they were surprised to discover that
           the inspection results did not support the current
           licensing basis.  They were trying to get positioned
           so that when they deal with the future of their spent
           fuel capacity and the maintenance of that facility,
           that they would decide how to deal with it.  I imagine
           that it was for timing more than anything else for
                                DR. BONACA:  Okay.  I already spoke about
           the effectiveness of Appendix B.  Having this summary
           listing of problems has allowed us to really get a
           sense of the extensiveness of the problems.  
                                Appendix B is formatted in a way where you
           have this seven new problems.  Then you have all the
           other problems which already exist but some of them
           are modified to deal with some of the issues which
           will be raised in the context of license renewal.
                                In my review of the SER, it was apparent
           that the staff had performed an effective review of
           the Arkansas One application.  We asked questions
           regarding the process that was used and there were two
                                Certainly the first one is a lesson learned
           also for the subcommittee licensing ACRS.  They
           specifically take systems of components which are not
           in scope and test why they have been left out.  Now,
           that's a guidance which is also given in this SRP, but
           I think this time I use it personally and I found I
           had a lot of questions.  
                                Each one of us has a sense of what really
           should be a safety system.  For example, the Fussel-
           Vesely measurement device does not have any other
           function than the safety function.  The question of
           why it's not in scope is a good question.  The answer
           is provided and so it was acceptable but I think that
           was an effective review that the staff performed.
                                Another question we asked was regarding the
           staff visits to the site.  They were performed by the
           staff and clearly they had done a reasonably extensive
           process of V&V, validation and verification.  I
           believe there were two trips to the site involving
           several days and several people. 
                                MR. PRATO:  This is Bob Prato.  There was
           actually three.  There was an audit for the
           methodology review.  Then there was a scoping
           inspection to verify the implementation of the
           methodology.  Then there was a two-week aging
           management review.  
                                The last two, the scoping inspection and the
           aging management review, involved seven spectors and
           the scoping methodology, the week that we spent on
           site, involved three engineers from the site -- from
           headquarters.  I'm sorry.
                                DR. BONACA:  The second visit was for what
           you said?
                                MR. PRATO:  For verifying that they
           implement the scoping methodology correctly.  It was
           a scoping inspection.  During that inspection we
           actually looked at systems that were excluded and
           verified that they had good justification for
           excluding them.  Then we looked at the structures and
           the components individually and made sure they
           included them correctly as well.
                                MR. GRIMES:  This is Chris Grimes.  Just to
           make sure that we keep the process clear, we refer to
           an audit of the methodology.  That is the team from
           headquarters that goes down and gathers information
           first hand that they use to prepare their safety
           evaluation of the methodology.  
                                The other two pieces are the scoping
           inspection and the aging management program
           inspection.  Both of those are conducted under
           inspection manual chapter 2516.  
                                Those inspection reports then support the
           recommendation by the regional administrator.  That is
           when we go back to the path that shows all the
           contributors to the evaluation findings.  We try to
           keep the product lines distinguished.
                                DR. BONACA:  Okay.  The subcommittee noted
           that a number of new problems and one-time
           inspections, seven in total, have decreased
           significantly from the first application.  The first
           application had 30 odd one-time inspections and this
           one has two.   
                                We asked questions of the staff and the
           reason clearly is that a lot of the open issues have
           been addressed now.  I would like Mr. Grimes to
           describe the reason.
                                MR. GRIMES:  Dr. Bonaca, as we've reflected
           on our ability to explain to the ACRS the consistency
           and the treatment of our review process, we discovered
           as time as gone on we've learned some lessons.  We are
           going to explain those to the committee when we
           present the generic aging lessons learned report.  
                                One part of this is evidence that lessons
           have been learned and applied.  A second part is that
           the numbering system, the accounting system has
           changed from plant to plant.  If you recall, for
           Calvert Cliffs we counted some 436 programs.  We were
           actually counting individual procedures.  
                                On Oconee we had roughly the same number
           that Arkansas reports and that is about 30 programs. 
           Also, there is a reflection here that Arkansas was
           much more aggressive than Calvert Cliffs or Oconee or
           even the industry in general in their GALL approach. 
           Arkansas has leaned forward and they are taking on a
           number of these routine inspection activities.  
                                I think the best example is by going to a
           risk-informed service inspection program they captured
           small bore piping which is a one-time inspection in
           GALL and it is still a controversy with the industry
           in terms of whether or not license renewal should be
           solving that problem or some industry initiative
           should be credited for that problem.  
                                I do think that is appropriate that we
           should give recognition to Entergy's aggressiveness in
           treating these areas.  That accounts for part of the
           reduction, too.
                                I have also committed that when we come to
           explain GALL to the committee, we will provide a
           cross-reference of what was done for Calvert Cliffs
           and Oconee and GALL in order to show the evolution of
           the learning.
                                DR. BONACA:  I believe that's really very
           useful to the committee if we can get this perspective
           of how those one-time inspections have evolved.  I
           looked at some of the one-inspections which were in
           Fussel-Vesely terminals and they are, in fact,
           included in the program here and there was no specific
           identification separately of the one-time inspection.
                                It was simply folded in the problems as some
           of the other applicants have done, too.  I did it not
           under duress but still under some kind of negotiation
           and had to choose how to do it.  
                                Clearly, Arkansas came in and I believe that
           as the industry accepts this kind of resolutions,
           these will facilitate the next applications and
                                During the subcommittee meeting we noted a
           number of apparent inconsistencies between the
           application and the SER information already assembled
           when we were talking about scoping but we found it
           mostly in the problems.  
                                Typically, again, discrepancies were tied to
           the fact that the applicant proposed some program, for
           example, visual inspection of some piping.  The staff
           said, "Visual is not enough.  You should have
           ultrasonic examinations."  
                                The applicant agreed so the SER documents
           ultrasonic testing as the program used to deal with a
           particular issue while the application still quotes
           visual so there wasn't really a discrepancy there. 
           The discrepancy had been either solved.  
                                Typically the discrepancy resulted in an
           augmented program in the SCR than was presented in the
           original application.  I understand that the addendum
           to the FSAR will contain all the commitments anyway so
           there will be commitments as reflected in the SER. 
                                In conclusion, the feeling we got as a
           subcommittee was that the staff has performed an
           effective review of the Arkansas One application.  The
           Arkansas One application is an aggressive application
           that went, from what we can see, beyond the minimum
           requirements of the license renewal rule.  
                                Therefore, we felt confident that we
           understood enough to stay with the process right now. 
           We recommend the committee that we do not at this time
           write a letter.
                                We also would not conduct a subcommittee
           meeting to review the closure of the open items
           because there are very few.  Are intent is they want
           to bring in now the staff back the applicant for a
           full committee meeting when the open items are closed. 
           Hear a presentation by the applicant at that time and
           hear a presentation by the staff and we will write a
           report at that time.
                                Any questions from members or staff?
                                DR. WALLIS:  The CD that we have with the
           application, nothing has changed from that so if I go
           back to that to look at things, that is the key
           document to review before our next meeting?
                                MR. GRIMES:  That's correct.  The CD
           contains the application as submitted and it also
           provides the FSAR.  Dr. Bonaca has made the point that
           when you review the safety evaluation, the safety
           evaluation will articulate the paper trail from the
           application to a resolution.  All the correspondence
           that has occurred in the intervening time should be
           clear in the safety evaluation.
                                MR. PRATO:  This is Bob Prato.  All that
           correspondence is identified by dates and each of
           those letters that were provided by the staff and the
           applicant are on the docket.  There is a complete
           paper trail on the docket.  If you need anything
           specific, though, feel free to call us and we'll make
           sure you get a copy of whatever you need.
                                DR. BONACA:  Tomorrow, I believe, we will
           also talk about the Hatch application.  The SER is
           coming to come for our review.  Well, you probably
           already received it at home.
                                With that also we have two subcommittee
           meetings, one that will lead us to review the guidance
           documents, the final changes to those.  A second
           meeting on the BWR VIP which support in some form the
           Hatch application.  
                                We have talked about having a presentation
           of the Hatch application and the SER in the same
           format by emphasizing the similarities with even PWRs
           given the fact that there are so many classes of
           components or commodities that are similar
           irrespective of the type of reactor that is being
                                MR. DUDLEY:  This is Noel Dudley.  I do have
           those documents in house.  I can send them out either
           express mail if you want to start working on them
           Monday, or I can send them regular mail and you'll get
           them Wednesday or Thursday next week.
                                DR. BONACA:  These are the SERs?
                                MR. DUDLEY:  These are the SERs.  These are
           four BWR VIP reports, associated SERs, and all the
           proposed final draft of guidance documents.
                                DR. BONACA:  Guidance documents.  Okay.
                                MR. DUDLEY:  Well, say the March 1 draft of
           the guidance document.
                                DR. BONACA:  So all the members of your
           choice.  You can take it with you.
                                MR. LEITCH:  It's 1,700, 1,800 pages.
                                DR. BONACA:  What we thought of doing was to
           send to you only those sections that you are asked to
                                MR. DUDLEY:  I think the document is small
           enough.  The actual GALL report now is only a couple
                                DR. BONACA:  It's small enough you can
           memorize it.
                                CHAIRMAN APOSTOLAKIS:  Is anyone dying to
           have it in his hands by Tuesday or Wednesday?
                                DR. WALLIS:  I would love to have a CD
           rather than a big pile of paper.  That means someone
           has to scan it in presumably which is a pain.
                                MR. DUDLEY:  Disks for the guidance
           documents are not available yet.
                                MR. GRIMES:  This is Chris Grimes.  We had
           envisioned putting them together on a compact disk
           after they are approved.  I'll explore the possibility
           of having the files loaded onto a CD-ROM.  
                                You wouldn't have the benefit of the
           electronic book features with tables of contents and
           so forth but if you're more comfortable in working in
           electronic forms, we can have Word Perfect files
           assembled on a CD for portability.       
                                DR. SHACK:  How about PDF?
                                MR. GRIMES:  I hesitate to say that because
           we would have to pull the PDF files out of ADAMS and
           I would rather not.
                                DR. SHACK:  When I get Word Perfect
           documents from Paul my computer thinks they are PDF
           files anyway.
                                DR. BONACA:  So we'll do that.  I just want
           to ask if there are anymore questions from members. 
           No further questions.  With that, Mr. Chairman, I give
           you this 32 minutes of time.
                                CHAIRMAN APOSTOLAKIS:  The Chair expresses
           deep gratitude.
                                We were hoping to go over the ATWS letter
           because we have a new version of it.  No, we don't
           need the description now.
                                (Whereupon, at 11:14 a.m. off the record for
           lunch to reconvene at 12:46 p.m.).
                     A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                     12:46 p.m.
                                CHAIRMAN APOSTOLAKIS:  We are back in
           session.  I neglected to mention this morning that we
           have Dr. Peter Ford sitting with us at the table as an
           invited expert.
                                The next session is on Spent Fuel Pool
           Accident Risk at Decommissioning Nuclear Power Plants.
                                Dr. Kress, you are the leader on this. 
                                DR. KRESS:  Yes.  It's a simple,
           noncontroversial subject.
                                CHAIRMAN APOSTOLAKIS:  We should be done in
           five minutes then.
                                DR. KRESS:  As you all recall, there was a
           technical study on this issue intended to give
           guidance on how to develop a rule or exemptions to
           relax requirements at spent fuel pool, requirements on
           emergency preparedness, and perhaps insurance
           requirements and security requirements.  
                                We reviewed that technical study and give it
           fairly good grades, I think.  They determined that the
           risk after a certain amount of time was low enough
           that you could do without the emergency preparedness
           and still meet the safety goals and this risk was done
           a fairly conservative basis.
                                They also noted that previous exemptions for
           these sort of things were based on the concept that
           you couldn't have a zirconium fire after a certain
           time because the heat generation rate was too low.  It
           was balanced by the cooling rate so that you weren't
           hot enough to start a fire.
                                The staff to some extent backed away from
           that concept and said they couldn't exclude the
           zirconium fire, whatever that means.  I think there
           was some differences of opinion between the industry
           and the staff on these things.  There have been some
           further correspondence and some discussions.
                                I think today I view this as more or less a
           status report or an update on where we are with
           respect to publications on possible rule making
           options.  I don't think we are ready for a letter
           again this time.  I don't know.  It depends on what we
                                With that as a sort of vague introduction,
           I'll turn it over to Tim Collins of NRR to get us
                                MR. COLLINS:  As a status report this will
           be a real quick meeting.  The status report is that
           the study is done and we're starting to do the
           thinking on the policy options.
                                There are a couple of things, though, I
           would like to provide a little clarification on.  When
           we started out the study, the charter was not just
           aimed at EP and insurance.  It was to provide a broad
           basis for rule making relative to decommissioning
           plants as a whole.
                                There was some emphasis in the report on EP
           because of the number of exceptions that had been
           granted in the past and the most recent actions in
           decommissioning were requests for exemptions in
           decommissioning or insurance.
                                Another thing I would like to make a
           clarification on.  The finding in the report with
           regard to not being able to preclude a zirconium fire. 
           The finding in the report was really that we couldn't
           define a generic time without numerous constraints,
                                The original exemptions were granted on the
           basis of an unobstructed airflow calculation, those
           previous exemptions which said after a certain number
           of years you wouldn't get to a temperature that would
           lead to a fire.  
                                When we originally tried to do the study, we
           started out with the unobstructed airflow cases.  In
           the course of public comment there was questions
           raised with regard to partial uncovering of the fuel
           which would obstruct airflow.  
                                We also in trying to do our own calculations
           we were trying to decide how much airflow we should be
           using.  We ran into problems with different rack
           configurations, different spent fuel pools, the
           relationships between the building airflow and the
           flow in the racks.  
                                Then when we looked at our results, we said
           the most likely events that could get you into trouble
           were major seismic events and major cast drops, all
           catastrophic events.  We finally threw up our hands
           and said we can't define the geometry which will allow
           us to do as calculation which will give us a generic
           decay heat time.  
                                I think the characterization that the study
           concluded that you could never preclude it is a little
           bit of an alarming characterization.  It's more a
           matter of, well, there are so many uncertainties and
           so many unknowns in trying to do a generic analysis
           that we couldn't come along and say after five years
           we're sure there's not going to be a fire.  
                                As far as where we go now, I mean, as far as
           any technical work goes, it's at a standstill.  We
           believe that the results of the report were -- the
           staff is comfortable that we are below the safety
           goals.  We think that additional technical work could
           be quite expensive if it's going to really
           significantly reduce uncertainties further.
                                We're not sure what goal we would be
           shooting for if we started to do that work so we're in
           the position of developing policy actions for the
           commission.  The policy actions are aimed at questions
           like how important is factors like public confidence
           in your decision making process.  
                                I mean, we believe that the risks are very
           low and below the safety goals for reactors, but there
           is a very significant question in areas like emergency
           preparedness, how important of a factor is public
           confidence and how does that weigh into decision
           making.  These are the types of things we are going to
           address in our May paper to the commission.  There is
           also questions of how do we use risk in security
           related --
                                CHAIRMAN APOSTOLAKIS:  I'm sorry.  This
           issue of public confidence, maybe we can clarify it a
           little bit.  You see, you believe that the risk is
           low.  When you say that, you mean the whole
           distribution is below the goals or the mean value is
           below the goal but there is a tail that goes perhaps
                                I'm trying to understand the meaning of the
           statement and why some other groups might differ, I
           mean, with the issue of confidence.  When the staff
           says the risks are low --
                                MR. COLLINS:  When we did our analysis, we
           tried to use a range of sensitivities.  For example,
           in the seismic analysis we used the Livermore curves. 
           We used the EPRI curves.  We did source term
           sensitivities to include large amounts of ruthenium
           release, what we thought was a reasonably large
           fraction of fuel finds.  Using those bounds, we
           believe that the risk is still below the safety goal.
                                CHAIRMAN APOSTOLAKIS:  You did not quantify
           the uncertainty?
                                MR. COLLINS:  We did not quantify the
                                CHAIRMAN APOSTOLAKIS:  Just sensitivity
                                MR. COLLINS:  That's correct.
                                CHAIRMAN APOSTOLAKIS:  And what you thought
           were bounding analysis?
                                MR. COLLINS:  Yes.
                                CHAIRMAN APOSTOLAKIS:  Okay.
                                DR. POWERS:  It must surely be if the risks
           are low and you use high source terms, that is, just
           the frequencies were low.  That's the only reasons.
                                MR. COLLINS:  Sure.  I mean, the frequencies
           were very low.
                                CHAIRMAN APOSTOLAKIS:  The frequencies of
                                MR. COLLINS:  The frequency of -- what we
           calculated in the report was the frequency of uncovery
           of the fuel.  We didn't try to do a calculation of the
           conditional fire probability.  We went from uncovery
           of the fuel to consequence analysis.
                                DR. KRESS:  And it was driven by seismic.
                                CHAIRMAN APOSTOLAKIS:  So why would someone
           else then have less confidence in what you did?
                                MR. COLLINS:  Let's find that someone else
           and ask them.
                                CHAIRMAN APOSTOLAKIS:  I mean, how can you
           take into the decision making process the fact that
           others have less confidence in your results unless you
           understand why?  You raise the issue of how do we make
           a decision if the public doesn't agree with us.  Who
           is the public anyway?
                                DR. POWERS:  I think we have to go back and
           look at what some of the other speakers had to say. 
           We had several speakers at our meetings and some of
           them -- the universal sentiment was that the issue
           deserved more attention.  
                                When you looked at the more attention that
           they were asking for, in general each person said that
           there are design specifics at each site that make a
           generic conclusion difficult to draw.  You have to go
           look at those design specifics and they make a
                                Now, the difference they were asking for, of
           course, depended on point of view a little bit.  So
           one of the questions that comes out of that is does
           the generic analysis give you the answer or is it
           always the site specific analysis that you have to do?
                                The other distinct point of view was that
           looking at this strictly from an accident probability
           is the wrong way to do it.  In fact, there is a
           security element of this as well so you have to take
           into account both misadventure and deliberate actions
           here in making decisions about these pools.  Those
           were the alternatives.
                                The one I think the staff is in a position
           to address is the one can you get any mileage out of
           a generic analysis or are all things so site specific
           in the phenology affected by that site specificity
           that you just don't derive any answer. 
                                MR. COLLINS:  I mean, certainly in the
           development of a rule if we were depending upon
           generic analysis, one of the elements of the rule
           would have to be demonstrating consistency with the
           generic analysis, or that you were bounded by the
           generic analysis, or you would do your own plant
           specific analysis.  That's typically what we do with
           rules anyway.  
                                We review topical reports all the time where
           generic analysis are submitted and then we get a plant
           specific submittal which references the generic report
           and just demonstrates why it's founded by the generic
           analysis or where it's not and why it's still okay. 
           The rule would have to be structured in such a fashion
           if it's going to depend upon --
                                DR. POWERS:  You can do that in a rule but
           I would think you would come into the rule saying, "My
           generic analysis is going to be pretty good or 90
           percent of 90 percent of the site specific things." 
           Do you have any feeling for that?
                                MR. COLLINS:  This analysis?
                                DR. POWERS:  Yes.
                                MR. COLLINS:  I think this analysis would be
           applicable to most facilities, yeah.
                                DR. POWERS:  Okay.  That gives the answer
           the chairman was looking for.  It's contrary to what
           speakers on both sides of the issue have said.
                                MR. COLLINS:  Well, I understand that.  In
           some cases on one side of the issue speakers would say
           that the risk is so much lower.  That's fine.  That's
           okay.  If they want to do analysis which shows it's
           lower, we'll find that just as acceptable.
                                CHAIRMAN APOSTOLAKIS:  Are you done?
                                MR. COLLINS:  I think I'm pretty much done. 
           I mean, there's not much more to say.  We just started
           developing the policy paper.
                                DR. KRESS:  That's going to the
           commissioners in May?
                                MR. COLLINS:  Yes.
                                DR. KRESS:  Near the end?
                                MR. COLLINS:  I expect it will be about May
                                DR. KRESS:  We could probably here a draft
           version of that in our May meeting, you think?
                                MR. COLLINS:  Well, a different group is
           responsible for the development of that paper.  I
           don't want to commit them.
                                DR. WALLIS:  So have you concluded the
           better understanding of the physics, chemistry, and so
           on of fires is not to be sought because the risk is so
                                MR. COLLINS:  Staff is not recommending that
           we do additional analysis at this point.  If the
           commission decides that we need it, we'll do it.
                                DR. KRESS:  I think there are broader
           applications or needs for such stuff.  For example,
           with respect to pressurized thermal shock, which may
           be an iron ingression type accident also.  There may
           be other reasons other than for decommissioning for
           such research but you're not excluding that in
                                MR. COLLINS:  No.
                                DR. KRESS:  Just for the decommissioning?
                                MR. COLLINS:  I'm talking about for
           decommissioning rule.
                                DR. KRESS:  I think you probably have enough
           for a decommissioning rule maybe.
                                DR. POWERS:  I guess I have a couple of
           questions on that.  One of them I would like to come
           back to is the statement that things are dominated by
                                I have been given a sheet of paper which,
           unfortunately, I don't have right here with me, in
           which initiating events for fires in the pool were
           listed down and the percentage contribution was
           provided.  That list of seismic only is 13 percent. 
           It wasn't even top on the list and there were several
           comparable to it.  
                                Naturally enough, I can't remember what the
           others were but they certainly involve station
           blackout, loss of cooling capabilities.
           Is it true that this thing is totally dominated by
                                MR. COLLINS:  We believe the seismic clearly
           dominates it.  We took into account events where you
           had loss of cooling to the pool.  You can look at it
           as two basic types of events.  You have a catastrophic
           draining of the pool or you have a slow boil off or a
           very slow leak, those two types. 
                                Now, the second type of event, the slow one,
           is dominated by human error and there's hundreds of
           hours for recovery actions in the secondary.  We
           looked at that very carefully.  We had several back
           and forths with the industry and I think with the
           committee even on the human error assessment.  When we
           were finished, we found that the seismic events were
                                DR. WALLIS:  Well, human intentional error
           like deliberately turning on pumps which would drain
           pools or something like that?
                                MR. COLLINS:  Errors of commission as
           opposed to errors of omission.
                                DR. WALLIS:  It might well be that your risk
           levels are so low that the unexpected wayward
           performance of one individual might have --
                                MR. COLLINS:  Still the recovery time was
           important more than the initiating event frequency if
           it was started by someone turning on a pump.
                                DR. WALLIS:  So they cannot drain the pool
           rapidly?  It takes many days or something?  I don't
                                MR. COLLINS:  It depends on how big the pump
           is, I supposed.
                                DR. WALLIS:  That's right.  That's an
           obvious statement.  How long does it take?
                                MR. COLLINS:  I'm not sure if we looked at
           someone deliberately pumping the pool out.
                                DR. WALLIS:  But you may have risk levels so
           low that that sort of event is the thing you have to
           worry about.
                                DR. POWERS:  You are ham strung.  You have
           no way of estimating the probability of that
                                DR. KRESS:  That's right.
                                DR. POWERS:  That's the fundamental problem. 
           The ground rules on any kind of risk is that risk is
           going to be taken out.  That, of course, means that
           somebody has to say those kinds of risks are handled
           some other way or are small enough that I don't need
           to worry about them.  
                                We have the same problem with sabotage,
           somebody from the outside attacking the pool.  We try
           to handle that by putting fences up and a few guards
           and things like that.  
                                Similarly the kinds of people that you hire
           have some sort of screened background and don't have
           a predilection for sticking pumps into spent fuel
           pools or something like that.  Those kinds of measures
           are taken.  You can't put it into a probalistic frame
                                DR. KRESS:  You cannot put it into a
           probalistic frame work?
                                DR. POWERS:  People certainly haven't found
           any way.  What they have found is I can produce an
           estimate of the probably of an error commission.  What
           I can't do is produce an estimate that I can persuade
           Tom is correct.
                                DR. KRESS:  That's correct.
                                DR. POWERS:  I can do it.  
                                DR. KRESS:  It can be done.
                                DR. POWERS:  But I can never persuade you. 
           Now, one could imagine that you could sit down and
           have a panel of experts persuade each other what it
                                The problem is no one ever felt like they
           could take that product and put it forward and
           convince anybody that these people were so profound in
           their expertise on people sticking pumps in spent fuel
           pools that their estimate was better than anybody
                                MR. LEITCH:  In terms of error by omission,
           it seems to me, and my memory is a little fuzzy, but
           in Dresden about four or five years ago there was a
           freeze up and I think a line had ruptured in an
           attempt to drain the spent fuel pool.  Did you think
           about things like that?
                                MR. COLLINS:  Yes, we tried to look at all
           the operating events that we were aware of that could
           have led to a pool draining.  It's considered in the
           likelihood of the initiating event.
                                DR. KRESS:  We went over all these questions
           when we reviewed the technical study.  We convinced
           ourself that they did a pretty good job.
                                CHAIRMAN APOSTOLAKIS:  Do you want to say
           something about the options?  Please identify
                                MR. HUFFMAN:  My name is Bill Huffman.  I'm
           with NRR and I'm the project manager for the policy
           paper.  I think your question was would it be ready
           for a briefing the first week of May.  I would hope it
           would be in a draft stage at that time.  
                                However, I would say that it would certainly
           have to be a closed meeting.  It's predecisional. 
           It's not something that we want to have the public
           privy to before we went to the commission on.  Plus,
           there would probably be safeguard information.
                                CHAIRMAN APOSTOLAKIS:  I don't understand. 
           Don't we always review things that are predecisional?
                                DR. KRESS:  Yeah, but he also brought up the
                                CHAIRMAN APOSTOLAKIS:  Okay.  Okay.
                                MR. HUFFMAN:  My schedule right now did not
           factor in briefing ACRS and I'm not sure exactly what
           a lead time you would want on the draft.    
                                DR. KRESS:  About a week.
                                CHAIRMAN APOSTOLAKIS:  Thirty days.
                                DR. KRESS:  In this case we'll make an
           exception.  Two weeks.
                                CHAIRMAN APOSTOLAKIS:  How big is it going
           to be?
                                MR. HUFFMAN:  Fifteen pages.
                                CHAIRMAN APOSTOLAKIS:  Two weeks then is
                                MR. LEITCH:  Are there not certain
           decommissioned plants now that have spent fuel pools
           where they have backed off on emergency preparedness
           and security?
                                MR. COLLINS:  Yes.  We've granted exemptions
           to several plants for emergency preparedness,
           insurance, and security.
                                DR. KRESS:  And those were generally based
           on the problem that they couldn't have a fire after a
           certain amount of time?
                                MR. COLLINS:  It seems each exemption was
           granted for a different reason.  Generally, though,
           often a part of the basis was the fact that you
           couldn't have a fire anymore based on an assumption of
           unobstructed airflow calculation.
                                DR. KRESS:  Then you don't feel like you
           need to revisit those because the risk is low.
                                MR. COLLINS:  No, we intend to go and
           revisit them.  We believe that the risk is low enough
           there's not a safety concern with those.  We were
           maybe in a situation where the basis is not correct
           for the exemption.  We plan to revisit those.  In all
           cases, I think the most recent -- the freshest fuel is
           almost four years old in the facility with the hottest
                                DR. KRESS:  Long time.
                                MR. COLLINS:  A long time.
                                DR. KRESS:  I think we are also scheduled to
           hear from the industry.
                                Lynette, are you going to take the lead on
                                This is Lynette Hendricks with NEI and our
           old friend Bob Henry with Vaski and Associates.
                                MS. HENDRICKS:  We appreciate the
           opportunity to revisit this issue with you.  We see
           it, I guess, in maybe a little more of an evolutionary
           stage than maybe the staff views it.
                                We would like to basically talk about two
           issues today.  One are some of the little touch on the
           phenology questions that were raised last time.  Some
           information on the basis for the cask drop.  Then
           finally with great boldness I would like to have a
           short discussion and get some input on the seismic
                                With that, I'll turn it over to Bob.
                                MR. HENRY:  As Lynette said, we would like
           to offer some suggestions because we think there are
           some issues that can be dealt with a little more
           crisply in the report and take advantage of a lot of
           the experimental data that has been acquire by both
           the NRC and the industry over a number of years.
                                I would like to be constructive in that
           regard and offer some suggestions of things that could
           be incorporated in the report.  As Lynette said, at
           the end she has some comments on seismic.  The issues
           I would like to particularly address to start with
           would be the experimental basis that we could
           subscribe to catastrophic events to get a somewhat
           better perspective of the potential damage that could
           really cause.
                                The last time we had the opportunity to
           visit with you we talked a little bit about fission
           product release, particularly ruthenium under those
           conditions where the pool has been assumed to be
           drained rapidly.  
                                The at the end also talk perhaps a little
           about suggested peer review to make sure that all of
           the data that people have at their disposal gets input
           into these kinds of documents that do get used for
           policy making.
                                I should also say we're talking about the
           cask drop here just as Tim was just saying.  We are
           focusing on the likelihood that could be a mechanism
           whereby the pool would be rapidly drained.  There is
           some data that I'll share with you here that I think
           the study could benefit from by incorporating and
           suggest that this is a pretty difficult thing to do.
                                To start with, we feel that the status is
           that this provides a good start for quantifying the
           risk for significant fission product releases.  We
           think it's certainly a good basis.  Tim was just
           talking about all the field information they went
           through to provide quantification of the likelihood of
           losing pool cooling.
                                We also believe it should incorporate these
           experimental results, I was mentioning, that one could
           use to evaluate the likelihood that a cask drop could
           indeed cause rapid draining of the pool.
                                Also, we believe that there is a technical
           basis to be incorporated into the report to at least
           give a best estimate in addition to the bounds that
           are already in for fission product releases and,
           therefore, health consequences.
                                I think if we do a little bit more than just
           provide the bounds, we provide some additional
           insights on how people might be using this to make
                                To start with, let's start with the
           experimental basis for assessing cask drop.  I've
           listed four references I was able to dig up.  The
           first two being with full-size casks dropped onto
           concrete pads where they were principally there to
           measure the damage to the cask, but they also recorded
           the damage to the concrete.  We can certainly use that
           to assess our ability to determine how tough the
           concrete really is.
                                The third one is an NRC study using steel
           billets dropped onto concrete surface that is very
           useful.  However, the first two I'll use this
           afternoon because the information for the compression
           of the concrete in the locality impact is reported.
                                The last one are some experiments that were
           done quite a while ago for high velocity impacts that
           really relate to tornado missiles but from a practical
           point of view they are just as usable, as we'll see,
           as the first two in terms of assessing what the
           implications would be for impacts on concrete.
                                DR. WALLIS:  When you talk about a pool,
           what part of the pool is being hit by this cask?
                                MR. HENRY:  Conceptually, just think that
           the cask has been lifted up and is somewhere around
           the top of the pool, the rigging breaks and it comes
           down through the pool.
                                DR. WALLIS:  Through the pool of water?
                                MR. HENRY:  Goes through the water.
                                DR. WALLIS:  Doesn't that slow it down quite
           a bit?
                                MR. HENRY:  It does a little bit.  We'll
           talk briefly about that.  To give you a feel for it,
           the terminal velocity of water is maybe in the range
           of 20 meters a second if you just use a drag
           coeffision of one.  You'll see this has fins on the
           side and maybe that slows it down a little bit more.
           The 20 meters a second --
                                DR. WALLIS:  In your picture, it goes
           through the pool and hits the bottom of the pool.
                                MR. HENRY:  Correct.
                                DR. WALLIS:  It's not knocking off a piece
           of the sidewall or anything?
                                MR. HENRY:  In what I present today, no, but
           this fourth set of experiments here do have
           experiments where the projectile was at a 45 degree
           angle also.  I didn't include those here because this
           is a fairly quick thing but you could certainly use
           those.  What they did observe in those is that it
           principally just grazed along the side and didn't do
           anything to cause a large rupture of the wall.
                                I apologize for the simplicity of this. 
           There are correlations for this.  I chose not to get
           into correlations but to just use it from a very
           fundamental point of view in terms of the mass and how
           far it's going to fall, plus the strength of the
           concrete and the dent it will make in the concrete
           delta and the kinetic energy.  
                                All this does is equate the change in
           kinetic energy to the work done and the work is just
           the force of compressing the concrete times delta. 
           This delta is the dent that it would make in the
           concrete or how far it has to go into it before we
           finally can get something that actually opens up a
           hole that could drain the pool very quickly.
                                DR. WALLIS:  The biggest uncertainty is A. 
           I mean, how does it fall.  Does it fall in a corner. 
           We have to put in an A here.  That's the biggest
                                MR. HENRY:  Again, I didn't focus on that
           today.  I wanted to make sure the database was
           available to everybody and understood and discussed. 
           Again, going back to the tornado missiles, they used
           As which were very small like rebar.  
                                The part that I'm going to give you here is
           a very simple approach I'm going to use.  As you start
           making A smaller and smaller, this thing starts giving
           you far too deep of a penetration.  
                                If you think of a corner going in first,
           then it's very quickly going to spread to something
           which is, let me say, is just half of the A of the
           total cask.  Again, we're not close to any kind of
           cliff where you would almost break the pool as we'll
           see here.
                                DR. WALLIS:  You are assuming that energy is
           absorbed by the concrete where it's hit.
                                MR. HENRY:  Right.
                                DR. WALLIS:  I think sometimes when you hit
           concrete on one side the concrete comes off on the
           other side but the shockwave goes through the wall,
           hits tension, comes off the far side of the wall.  It
           hits the wall here and the plug of concrete goes out
           into the next room.
                                MR. HENRY:  Right.
                                DR. WALLIS:  But that wouldn't be reflected
           by this kind of mechanism.  Would it?
                                MR. HENRY:  It is in the way I'm going to
           use it as you'll see because we're going to go back to
           data where actually what did it take for something to
           fly off the opposite side.
                                DR. KRESS:  The compressive strength, that's
           force per unit area it takes to compress concrete a
           certain distance?
                                MR. HENRY:  Yeah, if you want to use a
           simple kind of thing, it's like the yield point.  Once
           it starts giving, it essentially has almost the same. 
           Also there is a rate of strain that gets involved in
           all these, of course, but that's also not in here.
                                When I talk about the calculated delta, it's
           going to be this very simple thing of just equating
           the kinetic energy to the work done.
                                DR. WALLIS:  That's an interesting one, too,
           because if you want to bust concrete, it depends on
           the size of your sledge hammer.  Having the same
           amount of kinetic energy with a sledge hammer that
           weighs a ton isn't the same as having one that weighs
           nine pounds.  It makes quite a difference.
                                MR. HENRY:  That's correct.  That's
           obviously all in the equation.  If you do go back to
           this part of it and if you want to scale it then
           you've got this thing and here is the mass and the
           area that you've been focusing on.  
                                If you want a scale from one to the other,
           my mass and area might be different and can I make up
           for it with a different velocity to get the right kind
           of energy.  We'll get back to that in a minute.
                                These are the full scale tests and the
           results of these tests for the cask drop experiments
           that were done by BNFL at Sandia and also at AEA
           Winfrith.  As you can see, this is a pretty big
           hammer, 64.5 tons.
                                The concrete's compressive strength was 22
           MPAs with something in the range of like 3,500 or
           3,600 psi.  The drop itself -- excuse me for a second
           because I do have color photographs that aren't in
           what you have.  I have six of each here if you want to
           pass these around and share a little bit with each
           other.  There's three different photographs.
                                DR. WALLIS:  This is a big flat hammer. 
           Isn't it?
                                MR. HENRY:  Yeah.  
                                DR. WALLIS:  You're really spreading the
                                MR. HENRY:  That's why it's also --
                                DR. WALLIS:  It's a pretty expensive hammer.
                                MR. HENRY:  This is the apparatus.  It
           weighs 64.5 metric tons.  In this case it's held 60
           inches above the surface of this reinforced concrete
           block and about to be dropped.
                                When it is dropped, this is the dent, the
           impression that's made on the concrete from the
           highest drop of 60 inches.  Here you can see the ring
           that's left in the concrete.
                                Then also this is the measurement of the
           deepest part of the ring which shows that the
           impression is eight millimeters.  As we talk through
           this, it's that impression I'm talking about. 
           Obviously for the first set of tests --
                                DR. WALLIS:  Great care has been taken to
           spread the load as much as possible here.
                                MR. HENRY:  I think that's why you have to
           look at all the databases and not just this one.  
                                On the first case it was dropped 18 inches. 
           If you go through the simple analysis you calculate a
           value of eight millimeters and it measured at the
           deepest point four millimeters of imprint and
           obviously some cracks in the concrete.  But nothing
           was -- I mean, this is sitting on soil so nothing was
           broken off the other side.
                                In the third test it was dropped 40 inches. 
           Here you can see that the simple way you look at
           things begins to fall apart a little bit but it still
           gives you a perspective.  You calculate that you would
           make a dent about 17 millimeters deep or 1.7
           centimeters and they measured six millimeters.
                                The last one, which is the picture I showed
           you, they dropped it 60 inches, they calculated 26
           millimeters and they measured, as we saw in the
           measurements in the figure, eight millimeters.
                                DR. WALLIS:  Doesn't the whole business of
           impact impedance come into this, that if the concrete
           mass is -- it's not infrared mass so you actually set
           it in motion when you hit it.  It's a fairly
           complicated problem.  It's not just a question of
           absorbing energy and a distance.
                                MR. HENRY:  Obviously the basic thing you
           have to do is absorb the energy somehow.  How it all
           gets absorbed is more complicated than what this
           simple explanation shows.
                                DR. WALLIS:  When you hit a base ball, it's
           different from hitting a wall.  The baseball moves.
                                MR. HENRY:  Right.  From a practical point
           of view, the same thing is true in a plant.  I mean,
           if it does hit the wall, the wall will bend and push
           it back up again.  
                                This, at least, gives us a perspective.  We
           can go to these other tests where it is much more
           focused in terms of the load.  The first thing here is
           you see it takes a big wallop to put a hole in the
                                The next one, I have taken three of those
           tests and shown them here.  I've taken the tests which
           are the same missile all the time which is a 12-inch
           pipe and propelled at different velocities.  
                                They also have a three-inch pipe and a one-
           inch pipe but there's only a couple of tests of each
           where this gave us a number of tests to look at
           different velocities, three of which I've just showed
           you here.  
                                If we go through the same kind of analysis,
           now the missile is at much higher velocity, as you can
           see, upwards of over 200 feet per second when it hits
           the concrete.  I put three of them in here because the
           first one is with 12 inches of concrete and this is a
           velocity which is big enough to drive a hole right
           through the whole thing.  
                                If you look at the next sheet, that's a
           picture of the front and backside.  The frontside
           still has the pipe sticking in it and the backside you
           can see the concrete that's blown off the back.  
                                You want to make sure you understand what
           does it take to do this because these experiments tell
           you that it takes a certain amount of kinetic energy
           for a particular thickness of reinforced concrete.
                                The first one I have on test No. 10 is
           sufficient to penetrate the entire wall.  Test No. 12
           then is 18 inches.  This is 203 feet per second, same
           kind of missile.  Now you would calculate something
           that's in the range of almost a foot of penetration. 
           The real penetration is about 7.5 inches but it is
           enough to start pushing some material off the back.
                                This again now is what the frontside looks
           like.  You can see it's removed all the concrete right
           down to the first row of rebar.  The backside you can
           see that it has spalling or scabbing off the back and
           you can see the exposed rebar.  Maybe you would have
           a reasonable leak through that.  You wouldn't know for
                                Then the last one is 18 inches at 143 feet
           per second.  This one I use, and we'll come back to it
           again, because there's no spalling off the back face
           at all on this one.  Here you would calculate a
           penetration depth by the simple approach of 18
           centimeters and the actual measured value was more
           like five inches.  Reasonably close.  
                                This one is important because it gives you
           a frontside which looks like this again, very similar
           to the others, but the backside -- I apologize.  This
           is very dark but it's the best copy at the time --
           there's just some minor cracks.  This is not something
           that would drain the pool rapidly.
                                Again now we can work backwards and say what
           is the criteria now that we ought to be using to
           determine whether or not we have an impact that can
           push something off the backside and open up a whole.
                                I took all the information that was
           available on the 12-inch pipe so each one of these is
           the same missile.  I oriented them in terms of
           increasing velocity here but you have to realize there
           are also some other things changing.  
                                A minor thing that changes is the strength
           of the concrete because that depends upon the pore and
           what they were trying to do for a particular test. 
           The concrete thickness is also changing.  That goes
           all the way from 12 to 24 inches.
                                I've listed here the measured penetration,
           the calculated penetration, and then the ratio of the
           calculated penetration to the total thickness.  Then
           the results over here on the right-hand column.  These
           two I've highlighted halfway through the table and at
           the end so test No. 10 and 18 had complete
                                Here you can see that the calculated value
           is over half of the thickness of the wall.  That's
           when you can begin to think that, just as Graham said,
           you've got enough reaction on the back surface that
           you would open that up and then you would not be able
           to convince yourself that you did not have a complete
           path to drain the pool.
                                But these others that are very slight, 
           0.20 - 0.25, thirty percent of the calculated
           thickness, hardly anything was observed on the
           backside at all.
                                DR. WALLIS:  If I really wanted to drain the
           pool, I would drop something on the pipe.
                                MR. HENRY:  Most of them have pipes that the
           suction is on the inside.
                                DR. WALLIS:  Penetration is on the bottom,
                                MR. HENRY:  I don't know about all of them. 
           The older ones may.  Some may have that.
                                This is now what I use to formulate a basis
           to say, okay, if we have enough energy that we could
           penetrate something that begins to approach half of
           the wall, they would have to think that we could force
           a leak through the entire wall.  That's just
           summarized on this.  
                                It says first we have the large-scale tests
           which give us an idea of how well the simple
           representation characterizes what was observed in the
           concrete within a factor of two or three so that's a
           good start.  As I say, there are correlations for
           these things.  I don't want to confuse it with
           correlations and get right down to the gut physics of
                                DR. WALLIS:  You would be extrapolating.  If
           you dropped a cask, it could well drop more than 60
                                MR. HENRY:  Yeah, I'm going to get to that,
                                DR. WALLIS:  You've got to use some kind of
           correlation to go up to that.
                                MR. HENRY:  That's also why those high
           velocity pipe tests give you kinetic energy a specific
           loan that is greater than what you have even if it was
           the terminal velocity in the cask.  
                                The observations from the high velocity
           missile tests, I think, are quite important and they
           give you an idea of how you can scale up to the things
           that are of interest because we do have to consider
           dropping from things in the range of nine meters.
                                We find that only relative small cracks
           appear on the backside as long as the calculated
           penetration is less than half of the wall thickness. 
           If we don't have spalling off the backside, we
           wouldn't expect any large leakage from the pool.
                                Therefore, we ought to have something that
           is relatively easy to make up and slow drainage of the
           pool, which I think are some important insights to put
           into the physics side of the study because that is, as
           Tim said earlier, one of the mechanisms for rapid
           draining of the pool.  It's in the study.
                                Now, what does this mean for the actual
           cask?  The height that has to be used in the spent
           fuel pool is something like nine meters.  I use nine
           meters here.  Maybe it's 10 meters or whatever the
           particular event is.  
                                It should include obviously the buoyancy and
           the drag of the water and the buoyancy reduces the
           acceleration by about a meter per second.  If you just
           take a dry coefficient of one, as Graham was asking
           earlier, you get to something in the range of 20
           meters per second is the terminal velocity.
                                The impact through water of a nine meter
           drop gives you a velocity of about 12 meters per
           second.   That's only twice what you observed in this
           one that I passed around.  Kinetic energy wise, you're
           only talking about a factor of four up from that
           particular experiment.
                                If I go to the experiment and say I might
           expect something that's about four times as deep as
           what I saw, I'm only talking about maybe three
           centimeters whereas the calculated value would be in
           the range of 12.5.
                                DR. POWERS:  Bob.
                                MR. HENRY:  Yeah, Dana.
                                DR. POWERS:  Maybe some stupidity on my
           part.  You drop the cask and it's going at some
           velocity and hits the water.  How long does it take
           for that velocity to full up to the terminal velocity?
           I presume that the terminal velocity in the air is a
           lot higher.
                                MR. HENRY:  Oh, terminal velocity in the air
           is a lot higher.
                                DR. POWERS:  Yeah, so that when it hits the
           water, it's going faster than the terminal velocity.
                                MR. HENRY:  It's barely above the water pool
                                DR. POWERS:  Okay.  So you're saying it has
           almost no velocity when it hits the water?
                                MR. HENRY:  Has almost no velocity.
                                DR. POWERS:  Okay.    
                                MR. HENRY:  The acceleration is principally
           through the water.
                                DR. POWERS:  Okay.
                                MR. HENRY:  Just to answer your question to
           the extent that you asked it, you're at 12 meters.  It
           would take quite a bit longer obviously to get to 20. 
           At this point the drag is roughly half of the
           acceleration.  So now if --
                                DR. WALLIS:  It also has an added mass.
                                MR. HENRY:  You mean the divirtual mass?
                                DR. POWERS:  Yeah, but, Graham, give him a
           break.  Yeah, Bob, correct that in your calculations.
                                MR. HENRY:  Sure.
                                DR. POWERS:  He doesn't have any decimal
                                MR. HENRY:  Everything we have comes out of
           one dimensional and two-faced.
                                DR. KRESS:  The added mass is taken care of
           in the terminal velocity.
                                MR. HENRY:  When you get to terminal
           velocity it's just equilibrium.
                                DR. POWERS:  Tom, you're correct if he
           measured the terminal velocity on the cask but since
           he's just calculating it, it doesn't take the added
                                MR. HENRY:  The chairman told me to move on
           here.  The pool itself -- the bottom of the pool is
           anywhere from 1.5 to 2 meters thick.  My point here is
           even the calculated value is an order of magnitude
           less than the full thickness so putting all the
           database together whether -- I apologize.  
                                I took the rebar out because in essence it
           has even less penetration than the pipe does for the
           same kind of specific impulse.  I could have put that
           in also as a low.  
                                When you put in the total database, you come
           to the conclusion that it's going to be extremely
           difficult for dropping a cask the full height of the
           water pool to end up with something that's able to
           open up the backside of the pool even if it's not
           sitting on soil.  
                                Some of these are sitting on either bedrock
           or soil.  Others are elevated.  This tells you, I
           think, that this concrete is very, very tough against
           these kind of impacts.
                                DR. KRESS:  What contribution did the staff
           have for cask drops and draining the pool in their
           technical study?  Was it significant enough to worry
                                MR. HENRY:  It was significant enough to
           worry about.
                                MR. COLLINS:  Two times 10 to the -7, the
           likelihood of a uncovery of the pool due to a cask
           drop, two times 10 to -7.
                                DR. WALLIS:  Bob Henry is saying it's zero?
                                MR. HENRY:  I've been accused of saying that
           in the past.  I think what's really important when we
           do these risk studies is to make sure we represent the
           available technical basis.  I would like to see this
           kind of information in there.
                                DR. WALLIS:  What did the staff use for the
           mechanical probability with this scenario of the whole
           development with most of your risk number probability
           of the cask dropping at all?
                                MR. COLLINS:  Most of the number was the
           probability of the cask dropping at all.
                                DR. WALLIS:  If it did drop, you're assuming
           it went through the bottom?
                                MR. COLLINS:  No.  
                                MS. HENDRICKS:  It was factor 1.
                                MR. COLLINS:  No, it was not.  It was 1 in
                                MS. HENDRICKS:  One in 10 was for the wall. 
           It was a factor of 1 if it hits the floor.
                                DR. WALLIS:  So you and Bob disagree on the
           maximum amount possible.  You say it's 1 and he says
           it's zero.
                                CHAIRMAN APOSTOLAKIS:  So what's the factor
           of 1 in 10?
                                MS. HENDRICKS:  It's .1 if the cask is
           presumed to hit the wall and it's a factor of 1
           probability of failure if it hits the pool floor.  At
           least that's what in the appendix.
                                DR. KRESS:  So you're saying instead of this
           being 2 times 10 to -7 it ought to be 2 times 7 -8?
                                CHAIRMAN APOSTOLAKIS:  Neglectfully small.
                                DR. WALLIS:  It ought to be 2 to -14 or
           something like that.
                                MR. HENRY:  I would say the conditional
           probability ought to be less than 1 in 100 for sure.
                                CHAIRMAN APOSTOLAKIS:  Because in this
           analysis that you have done something that might be
           wrong or why not zero?
                                MR. HENRY:  Every time I used zero in the
           past you guys jumped all over me.
                                CHAIRMAN APOSTOLAKIS:  That's the fun in it. 
           If I look at this and I don't have any other
           information, I would say zero.  Why shouldn't I say
                                MR. HENRY:  I would say zero.
                                DR. KRESS:  But that doesn't change anything
           because it was already low enough that they didn't
           have to worry about it.
                                MR. HENRY:  There's a couple things.  I
           won't speak for the conclusion of the study but I will
           say in writing the study that cask drop failing the
           spent fuel pool shows up a number of times as a way
           that you could rapidly drain the pool. 
                                DR. KRESS:  Okay.  It's a perception.
                                MR. HENRY:  Plus the fact I would like to
           see these things referenced so that we know the
           database that is used in the physical part as well as
           the probability part has got a good strong foundation.
                                CHAIRMAN APOSTOLAKIS:  So it's a matter of
                                MR. HENRY:  Yeah.
                                MS. HENDRICKS:  I think what it also does,
           too, is you end up going from it's dominated by
           seismic to it's only seismic.  I think that makes you
           want to look a little more closely at what you're
           doing to the seismic.
                                CHAIRMAN APOSTOLAKIS:  I'm a bit confused
           now.  Dana, you keep telling us there is this table
           where seismic appears as --
                                DR. POWERS:  I showed the committee the
                                CHAIRMAN APOSTOLAKIS:  Yeah, I remember that
           so why is it only seismic?
                                DR. KRESS:  I don't remember the source but
           it came out of AEOD.
                                DR. POWERS:  The table was given to me.  It
           was repeated to be part of the staff study.  
                                DR. KRESS:  I don't know what that means.
                                DR. POWERS:  It was part of the staff study
           and it got corrected later or it was part of the staff
           study and nobody believed it or what, but clearly it
           would be erroneous to say that it is only seismic.
                                CHAIRMAN APOSTOLAKIS:  If the table is
                                DR. POWERS:  No, no, no.  I don't have to
           say if the table is correct.  I don't have to put that
           codicil in because there are clearly things that cause
           pools and concrete things to fail other than seismic
           event.  There are clearly drain-down events that
           occur.  They are just small compared to the seismic is
           what the staff is saying.
                                MS. HENDRICKS:  E to the -8 to E to the -9
           if you go through the report.  The question is whether
           you keep adding up a lot of small numbers.
                                DR. POWERS:  You can add either the -9 for
           a long time before you get any change of probability
           here.  I mean --
                                DR. KRESS:  I can buy the argument for the
           need to be consistent and have the right perceptions
           and important stuff even though it probably doesn't
           make any difference to the bottom line on how you
           write the rule.  I think there is some value in having
           a technically sound argument.
                                DR. POWERS:  One of the things is you would
           have to worry about it seems to me in thinking about
           these pools is they thermally cycle and they are going
           to thermally cycle a lot during recommissioning.  
                                If you don't have stress relief for that,
           then we're cycling concrete dose fatigue.  If you do,
           then you have to worry about compression of the stress
           release on them.  I mean, there are lots of things you
           can worry about.
                                DR. KRESS:  Thermally cycled because of the
           outside temperature change?
                                DR. POWERS:  Yeah.  Actually, it's not the
           outside temperatures.  It's the ground temperature
           that's going up and down.
                                DR. WALLIS:  Bob, did you do the seismic
           calculation too?
                                MR. HENRY:  No.
                                DR. WALLIS:  I'm kind of intrigued about the
           mechanism of failure under seismic loads of such a
           massive concrete.
                                MR. HENRY:  No, I didn't.    
                                DR. WALLIS:  You can shake a big mass of
           concrete quite a bit without busting it.
                                DR. POWERS:  You can look at the news
           pictures of the concrete abutments from the 1994
           earthquake and see it doesn't take much to bust up
                                DR. WALLIS:  It depends what it's connected
           to and a lot of things. 
                                MR. HENRY:  One of the things I should
           mention here that I didn't is in all these things I
           didn't credit the liner strength which obviously all
           the new pools have a significant liner on the bottom.
                                Last time we were here we talked a little
           bit about fission product release so I won't belabor
           this point.  
                                DR. POWERS:  I wish you would belabor it
           enough to tell me why you didn't put the Chernobyl
           incident on your list here.  And explain to me a
           little bit why we got so much ruthenium release so
           early in the Chernobyl accident.
                                MR. HENRY:  Which was metallic.
                                DR. POWERS:  Say again?
                                MR. HENRY:  Which was metallic.
                                DR. POWERS:  It was metallic afterwards. 
           The release itself almost surely had to be as a oxide. 
           There's just no way to do it any other way.  By your
           own calculation the vapor pressure is diddly squat at
           temperatures two times what Chernobyl ever had.
                                MR. HENRY:  Yeah, but the temperature of the
           fuel at the time of the actual --
                                DR. POWERS:  Even at that, Bob -- 
                                MR. HENRY:  It's pretty hot.
                                DR. POWERS:  If we had, we would have been
           boiling U02.  I mean U02 will boil off before your
           ruthenium will boil off.
                                MR. HENRY:  One of the reasons I left
           Chernobyl off of here was just because of these I see
           as a lot more technically scrutable that we can get in
           and exactly better understand the releases and the
           relationship to zirc.
                                DR. POWERS:  There is a little tiny test,
           Bob, that don't allow the zirc to go up to
           temperature, melt, and drain away.
                                MR. HENRY:  I'm aware of that.  I'm not
           saying these are the final answers.  I'm only saying
           these are an important part of the technical basis.
                                DR. POWERS:  Things can happen.
                                MR. HENRY:  These type of things can happen. 
           It's just the rate at which it happens.  As you know,
           nobody really knows what the temperature was of the
           fuel observed at the Chernobyl event.  
                                Plus the fact that nobody is still quite
           sure what the initial event actually looked like in
           terms of how it was released because obviously there's
           an explosion.  It's a nuclear explosion and that also
           scattered the fuel.  All those things would influence
           the rate at which things could be released.  
                                These hit home to the issue of having air
           there and steam which is an important part which is
           particularly this Oak Ridge test, VI-7, and the CANDU
           test because they tell us the relationship with these
           cases where we have oxidation ongoing over a long
           period of time, what's the role for competing of
           oxygen with all these reactive metals.
                                DR. POWERS:  That's not even close.  I mean,
           they are not even close.  The reactive metal is so
           reactive it will suck the oxygen out of anything
           before you get to the ruthenium.  I mean, I don't
           think that's an issue.  I mean, I don't anybody doubts
           that ruthenium is an excellent getter.
                                MR. HENRY:  Ruthenium or zirc?
                                DR. POWERS:  I'm sorry, zirc is an excellent
                                DR. WALLIS:  Tell me about the melting of
           the cladding.  Why doesn't the cladding flow?
                                MR. HENRY:  I was going to get to that in a
           second but certainly the upper part of the cladding in
           this kind of an event is the thing that oxidizes
           first.  The more it oxidizes the stronger it gets in
           terms of these events because it has a higher melting
           temperature.  The zirc oxide could sit around for a
           much longer time and even support the zirc on the
                                DR. KRESS:  Yeah, but it's apparently
                                MR. HENRY:  It is.
                                DR. KRESS:  It cracks.
                                MR. HENRY:  If you give it any kind of --
                                DR. POWERS:  You want to be careful about
           drawing experiences from steam because you get a much
           higher energy input for unit of oxygen reacted and you
           get a much less compact oxide.
                                MR. HENRY:  I understand.  Realize this is
           steam and air in this.
                                DR. POWERS:  A little bit of air wins the
           battle every time because it's the nitrogen component
           that is causing the problem.
                                MR. HENRY:  I understand.
                                DR. POWERS:  It doesn't take much.
                                MR. HENRY:  My only point here was we
           finally get back to analyzing it in a pool especially
           for those systems that are only partially boiled down
           so you've got a "blockage" at the bottom.  
                                That's also steam and air because you've now
           cut off your air supply except for whatever small kind
           of curve flow you have from the top.  That's why I put
           both of these on here.  I think they are very relevant
           to the database and they are in the report that the
           staff wrote.  They didn't forget about these.  
                                Our only point here is that we think it
           would be very helpful instead of -- I shouldn't say
           instead of -- in addition to the two boundaries that
           they have for what the ruthenium release would be
           let's use this information and also put a third curve
           on that gives a best estimate.  
                                When people look at these two boundaries
           they have some idea of these two orders of magnitude,
           whereabouts we think things are most likely to be.
                                DR. KRESS:  It generally takes a lot of data
           to get a best estimate.  I'm not so sure we have
           enough data to call anything a best estimate.
                                MR. HENRY:  I would always use the data for
           something because that's what you know.  The bounding
           parts you've kind of more or less pitched in and said
           it's got to be between zero and 1.  I realize that,
           Tom, and that's why the two things we're going to come
           down to.  
                                First off, these are recommendations.  And,
           more importantly, we think this would be a study that
           should have a peer review because it's not my opinion
           and it's not any individual opinion around here.  We
           ought to make sure that what's known in the technical
           community gets shown in this report.
                                DR. POWERS:  I guess what I'm struggling
           with is you're saying let's use these data for a best
           estimate.  I think what you're saying -- I think I may
           agree with you.
                                MR. HENRY:  It's time to go home.
                                DR. POWERS:  That what you're saying is that
           the staff merely needs to model the dynamics of the
           clad because the data show that dynamics is of
           overwhelming importance.  
                                If it's there and it can oxidize, you not
           only are not going to get any ruthenium release,
           you're not going to get a decrepitation release.  If
           it's not there, then you've got another problem so you
           have to mode the dynamics of the clad.  That's the
           best estimate you're talking about.
                                MR. HENRY:  In essence, yeah.
                                DR. POWERS:  Okay.  I'll go along with that. 
           I mean, you can't argue with that.
                                DR. KRESS:  I can't argue with that either. 
           Clad dynamics is a very tough problem.
                                DR. POWERS:  It will attract your attention,
           yeah.  On the other hand --
                                DR. KRESS:  I wouldn't mind doing some
                                DR. POWERS:  Well, on the other hand, I
           think you may have the experimental base to do it
           because they did a test in which they put enough
           specific energy input into them to get the clad to
           flow between the two oxide crust, one on the outside
           and one between it and the fuel so that you would have
           enough information to give yourself a criterion for
           when the clad would flow down those things.  
                                You probably would struggle with when the
           clad would rupture and allow flow but, for an
           unruptured case, I think the data exist.
                                MR. HENRY:  A lot of things I think the clad
           does that is shown on here and certainly the geometry
           is influenced by the details of the pool, whether they
           have boroflex or bural for PWR systems or nothing at
           all.  They just chose to control it with borax acid.
           Obviously, for BWRs fuel assembly cans.
                                If you get to this issue of where the system
           is partially drained down, it begins to look, except
           for the decay power and the fact of atmospheric
           pressure the whole time, just like the kind of
           analyses that have been done for large break LOCAs for
           BWR systems.  
                                You can go do that calculation to see just
           how much oxidation you're going to get with that
           because it's being limited by how much water you have
           in there.  You get in the range of 10 or 15 percent
           and from then on it's just accumulating molten metal. 
           Obviously where that goes is down to the bottom of the
           pool and after a long period of time you start having
           concrete attack, etc.
                                But the cladding itself controls how the
           material begins to relocate because the first part
           that melts is actually inside the cladding because, as
           Tom said, the zirc oxide could be brittle but unless
           you give it some kind of a privation, the molten
           material drains down in the inside of that Zr02 to
           begin with and it starts dissolving U02.  
                                All those things are relatively complicated
           but what they tend to do is give you melt relocations
           and start blocking everything off.  Especially when it
           finally breaks through the cladding there's a lot more
           molten material to go out than just the cladding by
                                All those things are part of what you have
           to be concerned with if you go to detailed
           representation.  But I believe if you look through the
           various things that have been done.  Dana just
           discussed the CODEX experiments.  That's part of the
           technical basis.
                                TMI is part of the technical basis.  It's
           not exactly what we're talking about here but it has
           all the issues related to cladding dynamics and melt
           relocation and even having the potential for some of
           the fuel to be declad from the top part of the fuel
           assemblies that's left on top of the debris.
                                These tests we just talked about certainly
           you need to consider the fact that there can be a
           small fraction of the material left on top of the
           debris and that should also be assessed in terms of
           it's temperature because it by itself is hard for it
           to get very hot because it is cooling.  
                                Unless the debris bed gets real deep it's
           cooling by radiation.  That has a very long -- if you
           keep temperatures below 1,000 Kelvin it takes quite
           awhile to release the material.  Those are only
           recommendations for expanding the technical basis.
                                DR. POWERS:  Would you go over that debris
           bed a bit for me?  I just didn't follow you.  I mean,
           debris beds get hot pretty easily actually.
                                MR. HENRY:  Debris beds can get hot pretty
           easily depending upon their decay power.  Of course,
           we are dealing with things that are fairly small here.
                                If this material that collapses down and
           accumulates a continuous mass and it's having a hard
           time getting energy out of it, which it will, then all
           the particulates sitting on top isn't receiving much
           from below and it's only going to reach a temperature
           that it by itself is able to power.  
                                You have circulation through that bed and
           you have radiation off the surface.  An example, 10
           percent of the material is going to cool very
           effectively in the range of about 950K.  
                                You can translate that back to what the rate
           of release is that you again get from experiments that
           have unclad fuel.  That's a very slow release rate
           given from ruthenium exposed to the air.
                                DR. POWERS:  1,000 degrees?
                                MR. HENRY:  950K.
                                DR. POWERS:  You might want to go back and
           look at the Oak Ridge disk.  Their top temperature in
           their test series was 950, I believe, and they got
           quantitative release.
                                MR. HENRY:  You mean this Oak Ridge test
           here, VI-7?
                                DR. POWERS:  No, no, the Lorentz tests that
           were done back in the '60s.  They ran a series of
           tests that -- Tom, correct me if I'm wrong -- 450,
           650, 750, 850, 950 and the 950 they got quantitative
           release in less than 20 minutes.
                                DR. KRESS:  That meets my recollection also.
                                DR. POWERS:  They also got the tellurium and
           a couple of other things were high at that
           temperature.  I can't remember what they were but
           nothing is important except the ruthenium and the
           decrepitation release.
                                Ah, that's a point.  At that temperature
           they did not get decrepitation release at that
           temperature because the U308 that was forming was
           centering almost as fast as it was spalling.
                                DR. KRESS:  Decrepitation happened at lower
                                DR. POWERS:  Yeah, they got decrepitation at
           low temperatures but not at high temperatures.
                                DR. WALLIS:  Dana, I think you should keep
           all these results up your sleeve and have him do his
           analysis and then see if it works.
                                DR. POWERS:  He just has to do the Chernobyl
                                DR. WALLIS:  I know but I'm just suggesting
           that to verify or validate his approach.
                                DR. POWERS:  I'm going to give him every
           parameter in the world that he can adjust.  He can
           adjust the flow rate through it.  He can adjust the
                                I mean, I'm giving you all kinds of fudge
           factors here, Bob.  Just calculate Chernobyl for me.
                                MR. HENRY:  I'll be happy to go back and
           look at Lorentz' data.  I based mine on the data that
           the Canadian people did.  That's all why we should
           have some kind of peer review here to make sure that
           not only is the database known but used in a
           consistent manner.
                                In conclusion, the evaluations for the cask
           drop event we think should incorporate this database
           which is significant, which is full scale.  It also
           takes advantage of things that are done with very high
           specific loadings.  
                                We think that if you use that quantitative
           approach, in essence that one is virtually impossible
           or zero, George, because, again, that's why you have
           a peer review, to make sure you get a cross section of
                                I think you could take that one off of the
           list.  We think the risk that is shown in here should
           also represent a third curve -- should include a third
           curve to give some idea of what we think the best
           estimate is because we did these experiments.  
                                While we may not have the kind of database
           there we have with other parts of the analytical
           spectrum, it sure would be nice to give some
           perspective in the integral sense what this really
                                Lastly, we think that things like this, that
           peer review cuts across the board of both industry and
           academia as well as the regulator is essential because
           then we make sure that whatever the technical basis is
           gets surfaced, gets at least reported so people know
           what is sitting out there they can use to make some of
           these decisions.
                                DR. KRESS:  Let me ask you about the second
           conclusion.  The technical study did use a relatively
           high ruthenium releases.  Yet, they found the risk to
           be acceptable.  Why should they go any further if they
           already have acceptable risk?
                                MR. HENRY:  A lot of it is the perspective
           that comes from it.  Then there is also some
           conclusions drawn in the back about what that means in
           terms of issues related to EP and others as well and
           that comes from those studies where the risk is
                                DR. KRESS:  Do you think there are other
           considerations that might come into play eventually
           because ruthenium has melted and land contamination
           might be an issue if you use these bounding
           calculations as opposed to best estimate?
                                MR. HENRY:  I guess I'll beg on that one
           until I knew exactly how they were going to be used in
           the land contamination evaluations.  I mean, it's hard
           to compete with cesium in contamination.
                                DR. KRESS:  I agree with you.
                                MR. HENRY:  After five years ruthenium is
           not much of an issue.
                                DR. KRESS:  I agree.
                                MR. HENRY:  Some of these pools are pretty
                                DR. KRESS:  If the risk was already found to
           be acceptable, I was wondering if you thought maybe
           when they get down to plant specific considerations
           that they might find some that weren't acceptable by
           the bounding calculations.  Therefore, you might need
           this best estimate as a basis for specific plants.
                                MR. HENRY:  Lynette probably wants to say a
           few things about this.  I think the best estimate also
           gives you a good idea of where you need to focus your
           attention in the future as you do come across other
           issues.  That's why we would really like to see it.
                                MS. HENDRICKS:  I would like to pick up
           there.  By definition, if you have studies out on
           different aspects of the plant operation and one is a
           bounding estimate and the other is a best estimate, in
           doing your plant PRAs and all this stuff how are you
           going to treat this risk?  
                                There's no basis other than best estimate or
           mean estimate with the understanding of the
           uncertainty to apply this in a risk informed
           situation.  I think you are going to be hard pressed
           to do that.  Yet, it's on the books as something that
           is by its bounding nature implies a lot of risk.  I
           think the best estimate is really critical.
                                Another reason it's really critical is
           because, and this was actually captured in the study,
           when you say the risk is acceptable, they actually
           went so far as to say, "We're not thinking about
           saying that you need a containment for the spent fuel
                                That is different than asking those
           questions about do you need EP financial protection. 
           Those questions, I think, you may need to look more to
           what is a negligible risk.  For that, again, you need
           a best estimate.  That is the tool the commission
                                Ultimately it will be a policy call because
           there is no magic number associated with financial
           protection or EP.  But certainly a best estimate would
           allow them in a more absolute sense to say, "Okay, we
           have EP over here for the plant and should we
           determine on the basis if this risk is somewhat
           negligible compared to this that we can justify
           terminating those requirements."
                                Although the staff mentioned the stuff is
           intended to be broader than just looking at those
           requirements, the gist of the study was to address
           three ongoing rule makings for these requirements. 
           The reason those rule makings are predominate is this
           is the only opportunity to save money or conversely to
           spend a lot of money unnecessarily in the
           decommissioning phase.
                                DR. KRESS:  When people say best estimate,
           I'm never quite sure what they mean.  I'm wondering if
           you could tell me what you mean by best estimate?
                                MS. HENDRICKS:  What the safety goal says is
           you use mean values with a clear understanding of what
           the uncertainty is.
                                DR. KRESS:  So a best estimate is a full
           distribution because in order to get a mean you have
           to have a distribution.  Sounds like a tough job to
           get a best estimate for this particular issue.
                                DR. WALLIS:  Could we put this in some
           perspective?  We heard from the staff that no further
           physical chemical studies are needed because the risk
           is so low anyway.  What's to be gained by learning
           anymore about this phenomena?
                                MS. HENDRICKS:  I think what's to be gained
           is the commission has to make harder decisions.  You
           know, is it safe enough compared to the safety goals.
                                Obviously it is but the harder decisions to
           make are do you need the extra protection, expensive
           protection, very expensive especially if it goes on
           forever because you can't determine a configuration at
           which point you can determine a heat removal that
           would imply that you don't need to worry anymore.
                                Twenty years or so of EP and financial
           protection are going to be grossly expensive compared
           to how we look at funding for decommissioning today.
                                DR. WALLIS:  So you're worried about the EP
           cost and sort of custodial cost.  You would like to
           just leave the thing after a while?
                                MS. HENDRICKS:  You don't leave it.
                                DR. WALLIS:  Close it up or something.
                                MS. HENDRICKS:  You don't leave it.  There
           are still people there.
                                DR. WALLIS:  Not so many people.
                                MS. HENDRICKS:  Stuff to be done.  We have
           an operator on site 24 hours a day with nothing to do
           but focus on this pool.
                                DR. WALLIS:  It must be the most boring job
           in the world.
                                MS. HENDRICKS:  Well, it may be boring.
                                DR. KRESS:  But you don't feel you could
           make those reductions and requirements on the basis of
           risk alone?
                                MS. HENDRICKS:  Not with the bounding
           estimate.  Another thing that concerns me about the
           bounding nature of the study was we talked about what
           will it mean.  Okay, it's bounding because we just
           couldn't do much better with all the conservatism
           stacked up on a generic basis, but we imply that we
           can do more on a plant specific basis.  
                                But if it's done within the constraints of
           the study, you're not going to get a different answer. 
           You're going to have it driven by seismic.  You're not
           going to be able to predict the configuration and you
           are going to assume maybe avaticia conditions.  I
           don't see much relief going from this bounding to a
           sight specific, unless I'm misunderstanding the way
           the study is put together.
                                Do we have time to talk a little about
                                CHAIRMAN APOSTOLAKIS:  There's 10 minutes
                                DR. KRESS:  Ten minutes.
                                MS. HENDRICKS:  Given the depth of my
           understanding of seismicity, I don't think we have to
           worry about this going too long.
                                This is a curve that we shared at the
           commission briefing that shows the distribution of the
           risk by peak ground acceleration.  I'm going to flip
           a couple up here quickly just to show that --
                                CHAIRMAN APOSTOLAKIS:  What is this figure
           now?  Let's understand the figure.  If you put it up
           there, you have to understand it.  You have the peak
           ground acceleration on the horizontal axis.  The
           percent contribution.  What does that mean?
                                MS. HENDRICKS:  The percent contribution at
           the different seismic bands of damage to the pool. 
           This represents convuling the hazard of the pool
           fracturing on top of the seismic hazard on a plant
           specific basis.
                                CHAIRMAN APOSTOLAKIS:  This is conditional
           on this peak ground acceleration so given that I have,
           say, .9G, right?  Or .8G, I go up and I see that there
           is the probability of .2 of causing damage.  That's
           what that means.
                                MS. HENDRICKS:  I don't know that it can be
           interpreted that way.  It's a percent of the total
           contribution.  It's more a way to show a distribution. 
           What percent of the seismic failure.
                                CHAIRMAN APOSTOLAKIS:  It says condition to
           spent fuel pool structure or failure probability. 
           That's what it says.
                                DR. WALLIS:  There must be a frequency in
           there somewhere because you would expect 2G to be more
           effective than 1G.
                                MS. HENDRICKS:  Well, the probability goes
                                DR. WALLIS:  That's right so probability is
           in this, too.
                                MS. HENDRICKS:  Right.  Yeah.  When you
           convulve the risk on top of the seismic hazard.
                                CHAIRMAN APOSTOLAKIS:  On the horizonal axis
           you count accelerations.
                                MS. HENDRICKS:  Right.
                                CHAIRMAN APOSTOLAKIS:  Not frequency.  This
           is .8G, for example.  If I go to the left, this is a
           percent contribution to failure of the pool.  That's
           what it says.
                                MS. HENDRICKS:  Right.
                                CHAIRMAN APOSTOLAKIS:  So 20 percent of the
           failures are due to .8G.  Is that what it means?  Then
           I have to multiply by the frequency of .8G to get the
           absolute frequency of the damage.  That's the way I
           understand it.
                                MS. HENDRICKS:  No, that's already in there. 
           You took the hazard curve where you've already
           convulved the risk of failure on top of the
           probability of the event as well as the magnitude of
           the event.  This is just taking that curve and
           parceling it out to show you the distribution.  
                                I think Gary Hollihan's comment on this was
           it's not surprising.  You have a very robust structure
           that even though the frequency of the seismic events
           are larger, the probability of failure is small.
                                CHAIRMAN APOSTOLAKIS:  So let me rephrase it
           then to make it consistent with what you said.  .8G
           and I go up and find .2.  .2 times 1.4 to the -6 will
           give me the failure frequency of the pool that's
           caused by a .8G acceleration.  It's unconditional,
           right?  It's unconditional.  It says it includes the
           frequency of .8G.  Who came up with this diagram?
                                MS. HENDRICKS:  Our EPRI seismic experts
           did.  I was looking for a way.  We all say --
                                CHAIRMAN APOSTOLAKIS:  A way to confuse us.
                                MS. HENDRICKS:  No, no, no.  We all agree
           it's all driven by uncertainty and that we just go on
           and use the curve.  I think this will help you
           understand what it means when you use that curve. 
           I'll show you the other soon or you can just flip.
                                DR. SHACK:  this is basically telling us
           that most of the risk is coming from this far tail
           with the big acceleration.
                                MS. HENDRICKS:  Right.  The median is in
           excess of -- the median is at 1G so more than half
           this risk that we're applying.  The question obviously
           is does this make sense.
                                CHAIRMAN APOSTOLAKIS:  It's the same with
           reactors.  I mean, the seismic contribution comes from
           accelerations of three or four times a safe shutdown 
           earthquake which is what you're saying here.  The safe
           shutdown earthquake is .15G and you're stuck seeing
           the significant import from .5 and so on.  It's
           consistent I think.
                                MS. HENDRICKS:  It's consistent to a point. 
           It's consistent to a point.  What makes this different
           and in some cases worse is just to look at damage for
           this very rigorous structure we extended the curves. 
           The Livermore and EPRI curves that we use for plants
           stop at a lower return frequency.  They stop at, I
           think, 10,000 years.  We specifically took this out to
           a million years which is going to influence the
                                The rest of the curves, as you can see, you
           get the same basis distribution and the same basic
           conclusions which are that --
                                DR. WALLIS:  This structural failure
           problem, doesn't this thing leak before it breaks?
                                MS. HENDRICKS:  This is looking for a
           catastrophic failure because leaks you can replace. 
           Then you get your human error.
                                DR. WALLIS:  Doesn't it leak?  Even after an
           earthquake it's full of rebar.  Doesn't it just leak
           in a few places?  It doesn't just fall apart.
                                DR. SHACK:  I think it's a question of
           whether it leaks or it leaks like a sieve.
                                DR. WALLIS:  That's got to come into the
                                CHAIRMAN APOSTOLAKIS:  I think we understand
           it now.
                                MS. HENDRICKS:  Okay.  So the point is the
           mean is about 1G.  At this level between about .5 and
           .7 if you go to the next curve is where you pull off
           at least for surry.  We'll go surry to surry numbers.
                                What this curve shows is that at the 50
           percentile to get into this range where you get into
           the real risk contribution between here and here, the
           frequency is about E to the -6.  
                                You are really reaching out to grab very
           improbable events.  You may do it in the context of
           reactors but it isn't going to have the same effect. 
           I think you need to ask questions about how
           appropriate it is to do here and potentially in other
           areas of regulatory space where it's going to be the
           sole contributor.  
                                Are you going to drive all protection
           requirements, all costs based on this seismic event? 
           It will be the issue for passive plant designs and it
           could be the issue for the new plant design.
                                CHAIRMAN APOSTOLAKIS:  I guess I don't
           understand quite what the issue is.
                                MS. HENDRICKS:  The issue is --
                                DR. KRESS:  The issue seems to me is you
           don't believe the seismic hazard risk.
                                CHAIRMAN APOSTOLAKIS:  Why not?
                                DR. KRESS:  I don't know.  I mean, that's
           what --       
                                CHAIRMAN APOSTOLAKIS:  The issue is you
           don't want to use it.
                                DR. POWERS:  I would say that she absolutely
           believes the seismic hazard risk studies.  She thinks
           that they tell you that this is something beyond the
                                MS. HENDRICKS:  Exactly.
                                DR. POWERS:  I understand.  Can I ask you a
           question about your slide?
                                MS. HENDRICKS:  Sure.
                                DR. POWERS:  Which really has nothing to do
           at all with spent fuel pools.
                                MS. HENDRICKS:  No, it has everything to do
           with spent fuel pools.
                                DR. POWERS:  The figure does but the
           question doesn't.
                                MS. HENDRICKS:  Oh, right.
                                DR. POWERS:  The question is you plotted the
           15th and 85th percentiles.  About the mean, why those
           particular ones?  There's nothing devious about the
                                MS. HENDRICKS:  Right.  I don't know.  It
           wasn't the 5th and 95th.
                                DR. POWERS:  Those are just numbers you had.
                                MS. HENDRICKS:  That's what was provided.
                                DR. POWERS:  Nothing devious.
                                MS. HENDRICKS:  No.  I know you're not
                                CHAIRMAN APOSTOLAKIS:  Aren't you saying
           though --
                                MS. HENDRICKS:  I would never say that.
                                CHAIRMAN APOSTOLAKIS:  Is this the -- I
           mean, are you expressing different words the old
           argument that if I have designed a thing against .15G
           SSE, and I see that my damage occurs four times that,
           three times high earthquake, I shouldn't just do
           anything and just say it's good enough.  
                                Is that what really you're saying which is
           the argument that why to use a PRA.  PRA doesn't
           recognize this design basis thing and just goes all
           the way until it fails the thing and what really
           matters is the frequency.  Is that the same argument
           you're bringing up?
                                MS. HENDRICKS:  It's real close but I think
           what I'm trying to say is part of doing PRAs is
           understanding the uncertainty when you understand that
           the uncertainty is really completely driving you.
                                Another thing I wanted to point out on this
           curve, and I don't have it marked, but if you look at
           the delta or the decrease in probability of occurrence
           between .1 and .3 because the air bands are fairly
           narrow, you get a factor of 10 decrease.  
                                Between .3 and .6 because your bands are
           diverging, you have to go that much further to get a
           factor of 10.  And to go from .6 to 1 you don't get a
           factor of 10.  You get a factor of 5 decrease in the
           probability of exceedence.
                                What that tells you is even if you were to
           say it makes sense to design at these higher levels,
           you wouldn't even get credit for it in the
           uncertainty.  It makes you ask what basis is that for
           doing what this agency is supposed to be doing which
           is determining what is appropriate to apply in terms
           of additional requirements.
                                If you're looking at a curve that wouldn't
           give you any credit for extreme redesign of your
           plant, does that really seem like a logical basis to
           regulate with?  
                                CHAIRMAN APOSTOLAKIS:  Well, I don't
           understand this credit business.  I mean, the
           frequency of occurrence of this acceleration would not
           go down significantly but you would certainly get a
           hell of a lot of credit because you have built a
           stronger facility.  This is not the probability of
           failure.  It's just the frequency of exceedence of the
           acceleration which is modern nature.  I think we are
           getting into a debate here.
                                MS. HENDRICKS:  Yeah.  Yeah.  I think --
                                CHAIRMAN APOSTOLAKIS:  Your point that we
           should really understand better the details are going
           to the analysis is well taken.  Beyond that maybe we
           shouldn't debate it more.
                                MS. HENDRICKS:  Okay.  Well, let me kind of
           close out here.
                                CHAIRMAN APOSTOLAKIS:  Okay.
                                MS. HENDRICKS:  I think the way the study
           progressed is nobody completely ignored this
           phenomena.  They came up with a number for the
           seismic.  They said seismic predominates.  Very, very
           conservatively is 3 or 2E to the -6.  
                                Everybody recognized that was highly
           conservative because of the conservatism in this and
           the conservatism in the furgility estimates.  They
           even went so far, the experts, to say the risk is
           acceptable and it's much lower probably than E to the
                                I think it begs a fundamental question if it
           gets that close to negligible, does it make sense from
           a public communication point to go ahead and do the
           math.  You know, risk times consequence and show these
           health effects.  
                                I mean, we say that negligible probability
           is in the E to the -7 range and we are probably very
           close and we have qualifiers and we have the ability
           to show significant capacity beyond earthquakes that
           would even be expected on the east coast.  
                                I mean, it seems -- and what I'm leading to
           is the question has come up in discussions with the
           staff and it came up in discussions with the
           commission of, well, then should we go back since we
           have this process and resolve the differences between
           the EPRI and the Livermore curves.  
                                I think there is even a more fundamental
           question here of how to treat seismic risk than just
           can we bring the experts together and get them to
                                CHAIRMAN APOSTOLAKIS:  The difference
           between Livermore and EPRI is not that great anymore. 
           I understand Livermore updated their curves in 1993.
                                MS. HENDRICKS:  But it makes for good
           agreement in areas where you expect earthquakes but
           the tails diverge significantly.  For the spent fuel
           pool study it made a factor of 10 difference which is
           only a factor of 3 if you look at cask drop but if you
           take cask drop out, you're back to --
                                DR. SHACK:  And your last slide says we
           should just truncate these suckers.
                                MS. HENDRICKS:  I think there should be some
           consideration of truncating.  There should also be
           consideration to come up with analysis which looks
           more deterministic.
                                DR. POWERS:  If my objective is solely to
           look at the bottom line risk in these things, I think
           I agree with you since you're trying to communicate to
           people.  Taking outlandishly high numbers and then
           claiming very low probabilities to them is probably
           not really communicating.  I mean, taking an
           infinitesimal probability with a big high spike
           doesn't communicate.  
                                If, on the other hand, I was doing this to
           say, now, what kinds of things should I be doing and
           what things have risk achievement worth and risk
           reduction worth, then don't I want to go ahead and do
                                MS. HENDRICKS:  You may want to do it for
           that reason.  I think NUREG 1150 did it for large
           seismic events.  They looked at core damage frequency
           but they showed some restrain and didn't go ahead and
           do the multiplication to show these consequences.  The
           maddening thing about --
                                DR. POWERS:  It was a lack of money.  I know
           those guys.
                                MS. HENDRICKS:  They're cheap.
                                DR. POWERS:  No, their sponsors are cheap. 
           They're profligate.
                                CHAIRMAN APOSTOLAKIS:  Who is communicating
           with whom here when we say communication?
                                MS. HENDRICKS:  With the public.  With the
           public.  When you go --
                                CHAIRMAN APOSTOLAKIS:  This agency is
           supposed to be doing good technical work so, I mean,
           they have to communicate it to the public.  I don't
           know what else can they do.
                                MS. HENDRICKS:  I think it's inflammatory to
           take events of very, very low probability and multiply
           times consequences.
                                DR. KRESS:  I don't understand that.  That's
           what risk is, frequency times consequence.
                                DR. POWERS:  Yeah, Tom, but let's be
           practical.  I'm very sympathetic to this point of
           view.  If you come out and tell me there is a
           probability that 100,000 people are going to die in
           Russia as a result of the Chernobyl accident, that
           gets the headlines.  
                                Now, the fact that the probability is 10 to
           the -8 somehow doesn't ever make the headlines or
           anybody's reading.  If it was just the headlines, I
           would probably say that's not the only thing the
           public --
                                DR. KRESS:  But I don't want to cook the
                                DR. POWERS:  I think she has a good sound
           point here depending on what you're going to do.  If
           what you're going to do is look at the risk for this
           pool, then I think truncation has its merits.
                                If I'm going to do it to then derive
           something from the risks based on differentiating
           them, risk achievement and risk reduction worth,
           should I have a guy come by and check the pool once a
           week, once a month, once a year, that kind of
           question, then I think you shouldn't truncate it.
                                CHAIRMAN APOSTOLAKIS:  Anyway, I wouldn't
           want the staff to come here and tell us we did this
           calculation but it would scare the public so we're not
           going to tell you about it.  I don't think that's
           where you're going but --
                                MS. HENDRICKS:  At some point, though, we do
                                CHAIRMAN APOSTOLAKIS:  That's nature.
                                MS. HENDRICKS:  We don't do the
           multiplication.  I mean, your number that you gave at
           the commission briefing, Dana, was 10 to the -7. 
           Maybe there's a point where you don't do the
           multiplication, not that you deny the risk.
                                DR. POWERS:  I think you've got good sound
           reason to pick that number because what did we do with
           the VANRs?  (A) We don't put them in the PRAs and the
           reason we don't is 10 to the -7.  Hence, we don't even
           put them in.
                                This "I don't want to scare the public" sort
           of argument has merits to it.  I understand that sort
           of thing.  I understand the purists.  What I worry
           about is when we say there's a probability of 100,000
           people dying in Chernobyl -- or the Ukraine because of
           the accident at Chernobyl, even though that's 10 to
           the -8 probability, it does provoke people to do
                                We get massive studies of radiation effects
           that can't possibly ever yield a useful number because
           of the background chance of deaths but they are in
           response to these kind of flamboyant numbers.  I
           appreciate the point that's being made.
                                MS. HENDRICKS:  I think, too, to look at it
           from the reverse perspective, it's inflammatory, one,
           but then also I think it sets up an expectation of a
           level of protection that's unreasonable.  I mean, are
           you telling the public that they should expect the
           next facilities to be built and to withstand --
                                CHAIRMAN APOSTOLAKIS:  No.  I don't.
                                DR. WALLIS:  It's like asteroid collisions.
                                MS. HENDRICKS:  Exactly.  Everybody knows
           about the big asteroid in the back of their mind but
           if we did the numbers and showed how many people were
           going to die, you may end up in a situation where
           people would demand research into how to protect us
           from the asteroid.
                                DR. WALLIS:  And it will happen twice in the
           age of the earth.
                                MS. HENDRICKS:  As a result, money would be
           taken away from our real risks in things that we can
           more readily mitigate.
                                CHAIRMAN APOSTOLAKIS:  This is a much bigger
           issue than can be resolved in the next few minutes. 
           Are there any other comments you would like to make?
                                MS. HENDRICKS:  We always end up on the same
           note.  Peer review.  Maybe we could do some sort of a
           peer review on the seismic.  I'm not sure it's the
           seismic experts because I don't think these curves
           will ever change but maybe they shouldn't but peer
           review about the appropriate use.
                                DR. POWERS:  You know, I guess I realize you
           are kind of insulting the committee.  We were asked to
           do a technical review and apparently what we did was
           inadequate, I guess, in your mind, but we are not
           peers.  I mean, some of us think -- at least one of us
           thinks he's a lord.
                                CHAIRMAN APOSTOLAKIS:  I don't think we
           should get into that.  Any other comments?
                                DR. POWERS:  How much more peer review do
           you want?
                                CHAIRMAN APOSTOLAKIS:  The commission has a
           history of establishing external peer review.  When
           they did the 1150 review they did not intend to insult
           the ACRS so I don't know why -- in this particular
           case if they want to have a peer review, they want to
           have a peer review.  I mean, if they weren't happy
           with an ACRS review, they wouldn't probably ask for
                                MS. HENDRICKS:  Nor does ACRS have the
           resources to look at -- I mean, this study portrayed
           many questions that would take a lot of resources to
                                CHAIRMAN APOSTOLAKIS:  Any other comments
           from the staff?  The public?  Thank you very much.
                                MS. HENDRICKS:  Thank you.
                                CHAIRMAN APOSTOLAKIS:  We'll recess until
                                (Whereupon, at 2:26 p.m. off the record
           until 2:46 p.m.).
                                CHAIRMAN APOSTOLAKIS:  The next subject is
           Management Directive 6.4 Associated with the Revised
           Generic Issue Process.  Dr. Kress again.
                                DR. KRESS:  I'm busy today.
                                CHAIRMAN APOSTOLAKIS:  Boy.  Go ahead.
                                DR. KRESS:  Well, just to remind the
           committee, the ACRS has had misgivings about the whole
           generic issue process for some time and had expressed
           it in a series of letters.  The staff decided to look
           at the GSI process and see how to make it better, I
                                They came to us back in '99 with the revised
           GSI process.  As far as I can tell from reading your
           letters and my recollection is we liked what we heard. 
           It sounded like a comprehensive way to do it and an
           improved way.  I think what we asked was could they go
           out and do a pilot assessment of it and tell us how it
           worked in practice.  
                                I think that's what they did and today I
           think we're supposed to hear about the results of that
           pilot assessment.  I'll turn it over to Harold
           VanderMolen, I guess.
                                MR. VANDERMOLEN:  Thank you, Dr. Kress.  My
           name is Harold Vandermolen.  I have sometimes the
           dubious distinction of being manager of the generic
           issue program.  On my left is Mr. Ronald Lloyd who is
           our person in charge of management directive 6.4.  
                                Yes, we're going to tell you about our
           experiences with the trial application of the draft
           management directive.
                                MR. LLOYD:  Our first slide kind of recaps
           some of the things that Dr. Kress has alluded to.  We
           initially had a draft version of 6.4 that was issued
           back in early '99.  We had an ACRS presentation at
           that time talking about what was in that particular
                                We did go through it by the end of July as
           is shown on the slide.  We actually produced an entire
           version of management directive 6.4.  There was a very
           minor change to it that was proposed by OGC to add in
           some lawyerese to the document on October 21 of '99. 
           Then we are here today, March 1, to provide some
           lessons learned on what we actually found and
           discovered as we tried this out on some reactor issues
           and also some material issues.
                                We also have a tentative schedule that will
           be on another slide.  The purpose of our being here at
           this time is to seek approval to go through and update
           that management directive based on the lessons learned
           we have to date.
                                DR. KRESS:  Are you looking for a letter
           from us then?
                                MR. LLOYD:  We would be looking for a letter
           probably at your convenience in the April/May time
           period to tell us to proceed.
                                DR. KRESS:  Okay.
                                MR. LLOYD:  We'll go over that schedule
           which is on a slide further back in the presentation.
                                Our next slide, please.
                                The process that existed earlier was
           referred to as RES office letter No. 7.  It basically
           had three different steps in it:  Identification which
           was basically what is the issues.  It had a
           prioritization phase where we would go through and do
           an assessment, a PRA type assessment.  
                                We would then categorize so there's a high,
           medium, low or a drop situation.  Then comes the
           resolution phase.  I know this caused some problems in
           the past with ACRS, you know, what does resolution
           mean, what does resolve mean, and so on.
                                Beyond coming up with basically an available
           solution which was the resolution phase of the old
           procedure, nothing was really procedurized which was
           one of the concerns, I believe, of several people.
                                The draft management directive, as you can
           see on the left side of the table, currently has eight
           stages to it which takes it through from the very
           beginning to complete close out which is
           proceduralized to verify the corrective actions have
           been taken by licensees on some sort of audit basis
           and a closeout inspection that would have to be
           documented to do that with several steps in between.
           To date we have experience of going through stage one,
           two, and three of the management directive.
                                Next slide, please.
                                The next one here shows the issues that we
           actually tried it out on.  We had six candidate
           generic issues, three reactor, and three materials
           issues.  The material issues we'll go through kind of
           briefly now and then we'll talk about the reactor ones
           on subsequent slides.
                                The material issues were basically all
           identified in the October 2000 time period.  As you
           can see by the current status on the block to the
           right of that, these issues were received by the panel
           and an in depth discussion as to what the issue really
           was and its risk significance and what should be done. 
           We are subsequently dropped from any further review by
           the generic issue program in January and then again in
           February of 2001.
                                They were basically dropped because of a
           couple of reasons.  They ended up being isolated
           cases, i.e., not generic, where their risk
           significance was lower, or there was already existing
           regulatory guidance that was sufficient to maintain
           whatever needed to be maintained as far as inspections
           and verification that things were being done
                                MR. LEITCH:  Were these dropped at step 2,
           that is, the initial screening level?
                                MR. LLOYD:  Yes.  That's correct.
                                Next slide.
                                MR. VANDERMOLEN:  Now, we are going to speak
           about our experience with each of these issues in a
           moment.  In addition to those six, we felt that we
           should have one issue that we sent to the old process
           just for comparison purposes for this use, generic
           issue 185 which had just come in.
                                The old process has been in place for about
           20 years now and it has had over 800 issues processed
           through it.  Although it's been modified a few times,
           it has essentially been unchanged in all of that time.
                                It was one of the first uses of
           probabilistic risk techniques in agency decision
           making.  We did not feel that we could really evaluate
           experience with the new process unless we had at least
           one that we sent through the process with some
           examination and oversight to be able to compare the
                                Now, getting into the specific issues, we'll
           start out with 186.  Ron.
                                MR. LLOYD:  186 was one that I was
           personally involved in as far as gathering data and
           information.  This was one that was proposed by NRR
           and they had worked it for some period of time.  They
           figured that we needed -- they needed to have
           additional technical basis for making decisions so
           they wrote a letter and forwarded it over to research.
                                Then it came in a time period when we were
           just starting to work with management objective 6.4 so
           it got picked up under the new procedure.  The panel
           met successfully.  We had a very good panel that did
           get together.  We had a couple of different meetings
           with the panel to discuss additional information. 
           There are a few lessons learned out of that.
                                Initially when the panel looked at all the
           information and the data it was classified as a
           compliance issue and the recommendation would be that
           the issue should be dropped from any further
           processing through the generic issue program.
                                At that NRR requested that we actually do a
           risk significance and gather some operating data that
           they could use.  It was decided we would continue on
           with the generic issue program and continue to process
           that issue.
                                After which time NRR then complained so much
           that too much time was being burnt up by their people
           coming to the panel meetings and so on and they
           actually didn't budget sufficient amount of time in
           their own budget for the entire year.  Harold will
           talk about that a little bit later.  These were some
           of the lessons learned that we came up with.
                                We actually ended up going out and visiting
           eight different facilities of different design types
           to get a good broad spectrum of what would be out
           there from a risk perspective.  We hit all the various
           kinds of BWRs with different containment type designs. 
           We also did different PWR designs by different NSSS
           ventures and so on.
                                DR. KRESS:  Is there a record of drops that
           end up in the LERs or somewhere?
                                MR. LLOYD:  Yeah.  What we did was we went
           through new docs and went back to the beginning of
           time and looked at all the different drops or problems
           that had been recorded some place, either by vendors
           themselves, crane vendors, licensees, inspection
           reports, where we could find them.
                                Then we went out and actually gathered data
           going back to the time that NUREG 0612 was generated
           which was 1980 which then required licensees to kind
           of beef up their crane program and come up with a lot
           of different sorts of procedural requirements and
           training requirements, electrical interlocks and so on
           to make them more reliable, I would guess.
                                We got that data and we extrapolated to the
           other different kind of design types and looked at the
           number of refueling outages that they had had and came
           up with a number of problems and also the number of
           lists that you had.  We had a frequency of failure to
                                We've got some good data on that.  That has
           been put into a couple of different databases and we
           expect to turn out a report on this probably within
           the next month or so.  That's 186.
                                187 is one that Harold will cover.
                                MR. VANDERMOLEN:  Yes, 187 is not as far
           along as 186.  186 has actually gone through initial
           screening and is into technical screening, the third
           stage of the process.  The next two are newer and
           haven't gotten quite as far.  187 is nearing the end
           of initial screening.
                                This is one on cesium concentration.  All of
           these are interesting in their own light technically
           but I would like to concentrate on the experience we
           had with the procedure.
                                We learned all the lessons that we learned
           in 186 and a few more.  Difficulty encountered in
           arranging panel meetings.  Well, what did we learn? 
           What we learned was that the panel members that you
           really want are people who are very much in demand. 
           It's not always easy to get their time.  They are
           often already busy and booked up.
                                This contrast would be management directives
           requirement that we try and get initial screening done
           in 30 days.  This particular one, one of the
           principals was called out to testify at an ASOB
           meeting right in the middle of that period and we were
           pretty well stuck.  Not an impossible problem but it
           did mean a delay.
                                We also learned that it is very wise to give
           guidance early in the process on how the panel is
           going to decide things.  The management directive is
           silent on this but the question is should a panel come
           to its decision by unanimous consensus.  Should it be
           by a majority vote?  If you do go by majority vote,
           you have to talk about whether or not you are going to
           allow descending opinions to be written.  
                                These are not new questions for this
           committee I'm sure.  But in this particular case the
           panel decided right at the beginning that it would try
           and achieve the full consensus.  Then what we
           discovered was that even if everyone agrees on the
           conclusion, it is possible to disagree on exactly how
           you are going to get there.  We are still resolving
           this one, although we are pretty close to getting it
                                DR. KRESS:  Suppose you had -- how many
           members are generally on the panel?
                                MR. VANDERMOLEN:  Anywhere from six to --
           what was the biggest one we had?
                                MR. LLOYD:  Five to seven or eight. 
           Something like that.
                                DR. KRESS:  Suppose you had four of them
           that said drop the issue and two that said go on with
           it?  Do you have a binary system that says pick the
           highest, the most problematic one?  That is, send it
           on and not drop it?
                                MR. VANDERMOLEN:  Well, we really don't have
           an answer to that one yet.  This is one of the things
           we have to resolve.  There is always the oath that is
           administered to a jury here in Montgomery County.  
                                If any of you live in this area, you may run
           into it, where the jury is sworn by the judge to keep
           the jury with neither meat nor drink until a decision
           is rendered.  Fortunately, we're not too serious about
           it.  Although, I am tempted on some days, I don't mind
           telling you.
                                We'll talk more about this when we come to
           our recommendations.
                                Next slide, generic issue 188, also in the
           initial screen stage.  This is one on resonance
           vibrations of steam generator tubes following a main
           steam line break event.
                                Again, this is a very complex issue
           involving inspection of disciplines that wound up with
           a somewhat larger panel still.  We had all the same
           difficulties of getting an expert panel together. 
           Then when we got the panel together, the staff member
           who raised the issue was unavailable because he was
           involved in still other activities, some of them
           involving the ACRS.
                                DR. KRESS:  Is the issue that you might fail
           the steam generator tubes by these vibrations?
                                MR. VANDERMOLEN:  Yes.  That's exactly it. 
           Strongly related to similar issues that I know you've
           been considering.
                                DR. KRESS:  Yes.
                                MR. VANDERMOLEN:  Also, the principal person
           that we wanted to talk to wound up having some
           significant medical problems at the time and was
           unavailable.  We have to allow for these things.
                                One thing I should point out is when we
           started this issue and, again, I think people around
           here will be sympathetic to this, it is amazing how
           much briefing material you sometimes have to provide
           to committee members.  This was a stack that was about
           six inches high.
                                What did we learn from the process? 
           Obviously the panel preparation is not easy.  Also we
           learned in the discussion that it was not easy to tie
           down the scope of the issue.  
                                In any of these generic issues you have to
           at a very early stage just decide where the scope is
           and not change it once you start because otherwise you
           will never come to consensus.  We went through all of
           this on this issue.
                                Having said that, I want to make a few
           overall comments.  When I say that there was
           difficulty in panel preparation, I did not mean that
           there was anything inadequate about the technical
           discussion of the panel.  
                                What this translated into was that people
           had to spend a lot of time preparing for the meeting. 
           I have to say having been on these panels and feeling
           a little skeptical when the whole thing started, the
           technical discussion that I observed was of extremely
           high quality.  
                                I've been here for a while and I've been on
           a lot of committees and panels and things like that
           and I've observed many more.  These were very
           professional.  There was a lot of good discussion not
           only at the meetings but in between meetings as
           members would discover new facts or documents that
           were relevant.  
                                They were sharing them with the entire panel
           by e-mail and so forth and people arrived at every
           meeting well prepared having read all the material. 
           It was quite a good focused discussion.
                                DR. KRESS:  Who selects these panels?
                                MR. VANDERMOLEN:  We recommend panel members
           to our management but ultimately the office director
           sings a memo after negotiating appropriately and
           actually nominating the members.
                                DR. KRESS:  You picked the panel and their
           candidates by their expertise related to a specific --
                                MR. LLOYD:  It could be based on their
           expertise and also be different depending on whether
           it was a reactor issue or a materials issue, whether
           Research would make that move or whether NMSS would
           make that move.
                                DR. KRESS:  When you decide I would like to
           have this guy here, do you check with him to see if
           he's willing to serve?
                                MR. VANDERMOLEN:  Yes.  And we have to check
           with his boss, too.  The management sometimes has
           strong opinions about this.
                                I should also say that we had some
           difficulty in this issue and some of the others.  Once
           the people got going they were all set to go ahead and
           charge in and try and solve the issue.  We had to keep
           it just on the purposes of the initial screening.
                                Next slide, Ron.
                                We also, as we mentioned, had an experience
           with the generic issue we processed under the old
           system.  This is generic issue 185, control of
           recuracality following small-break LOCAs and PWRs. 
           Again, this is a rather complex technical issue
           requiring quite an in depth review.
                                Now, let me explain something here, the
           difference in procedures which is why we were doing
           this, of course.  In the original procedure, the one
           that we've been using for 20 years, there is no
           initial screening panel.  What happens is usually a
           single analyst here sits down and investigates and
           then writes up the issue doing a probabilistic
           analysis and puts a package together describing all
           the findings.
                                Then it goes out for a concurrence review. 
           Now, concurrence is nothing new to anyone here but
           this is a little bit more than usual office
           concurrence.  It does go through our management, yes,
           then the write up under the old procedure.  
                                Parallel copies are sent.  One copy is sent
           to whatever person or group originated the issue. 
           This person may not agree with the analysis and
           usually gives it a pretty thorough looking over. 
           Another copy goes to whoever, be it a single person or
           a group, usually group, is going to have to work to
           resolve the issue.  That person may have very
           different opinions from the first one.
                                Thirdly, we would send one to an independent
           analyst, usually a PRA expert, just as a quality check
           on the work.  And there may be more.  If you have
           special technical areas we would try and get a review
           by an expert in whatever technical discipline was
           involved.  They have all been collected together.  The
           comments are resolved and then it goes back to the
           management review.  
                                In this particular case the prioritization
           write up was completed in six rather intensive weeks. 
           The concurrence review then lasted 197 days.  I might
           add also that this is not 197 days of benign neglect. 
           This is 197 days with gentle reminders, not so gentle
           reminders, sometimes more forceful reminders.  
                                I was often reminded many years ago when I
           was in college and I worked in a public library and
           had to remind people, sometimes professors at a local
           university, that it was time to bring back the books. 
           It's not always easy to get this.
                                Well, why did it take so long?  We all
           agreed this was too long a period.  Speaking to people
           in retrospect it was probably pretty obvious.  This is
           a 20-page write up, one with a lot of meat in it, well
           marbled with figures, tables, drafts, and equations. 
           It was not the sort of thing that you could just read
           and pass on.
                                In fact, I think this is characteristic of
           any generic issue write up.  It's usually not the sort
           of thing you can read a few pages one day and as time
           goes by the next day pick up a few and so on.  
                                This is something where you have to set
           aside a few days and read it, ponder it, and
           understand it, which people wanted to do.  They were
           very well motivated but these are busy people so in
           retrospect I can't say that it's that surprising. 
           Clearly you've got to do better than this.
                                Moving on to materials issues which Ron will
                                MR. LEITCH:  But if I'm reading the data
           correctly, it looks as though using the new system you
           would be pretty pleased with 197 days.
                                MR. VANDERMOLEN:  These thoughts have gone
           through my mind.  We'll talk about that in just a
                                MR. LLOYD:  The next slide, No. 9, has to do
           with the candidate materials that were presented
           through the materials area, NMSS.  As I mentioned
           before, none of the candidate issues had specific
           comments as they went through each one of those issues
           but we did have some generic sorts of comments on the
           process itself.
                                Recapping a little bit, going back to that
           table that was presented earlier on slide No. 4, each
           of the issues I thought NMSS did a really outstanding
           job.  These were brought up in, like I said, October
           of 2000.  There were panel meetings that came up very
           soon after that.  
                                I think they were very well prepared.  They
           looked through the issues and came to the appropriate
           conclusion, each of those being dropped because of
           situations that led them outside of the generic issue
                                The leaking pools which was the first one
           was initially a B&W issue with casks where they had
           radioactive material in it, where they had water that
           was leaking, and there didn't appear to be any
           regulatory requirement to go out and track water that
           was seeping out and measure the radioactivity and so
                                They found subsequent to that that this was
           an isolated case and the water never really got
           outside of the bounds where it would do any problem
           anyway so that one was eliminated.
                                The second one, unlikely events, I guess
           would be parallel.  You would look at kind of a duel
           train system and a reactor situation.  The ANSI
           standard 8.1 allows them to take unlikely events and
           say, hey, that's not going to happen and that sort of
           fills the second train criteria.  
                                Therefore, you don't have to worry about it. 
           Inspections realized that even though certain
           licensees were taking advantage of this classification
           of unlikely events, they actually had failures in
           those systems where they were saying this was an
           unlikely event.  This was the key that got them into
           maybe they had other problems and other sorts of
           situations where we have unlikely events and different
                                I looked at that one and that came back and
           it was determined that once again this was an isolated
           case.  It was with the Portsmith gaseous diffusion
           plant that the issue was at.
                                There were some changes made that came out
           of that so there was a positive part of this.  This
           was the subpart H of 10 CFR 70 that got changes.  That
           was also a letter that was sent out to licensees
           reminding them they should look into these areas and
           fix those things.
                                The third one that was tracked through NMSS
           was the gammaknife.  That's the gamma stereotactic
           radio surgery.  There were several misadministrations
           where they actually got the coordinates of where they
           wanted the dose distributed incorrectly.  In some
           cases they got the two axis backwards.  
                                Out of this rather than continuing on with
           the generic issue process and calling it a generic
           issue, they then processed it in a lower level format. 
           It was IEN generated.  It was 2000-22 which told all
           those types of licensees of the kinds of problems that
           were generated, the human errors that were generated,
           and so on.  
                                This was an example of how the new procedure
           would tend to go.  You would have a quick analysis of
           where's the risk and is it generic.  Go through your
           panel and come to a consensus with the panel hopefully
           on whatever that decision would be.  
                                If the answer is not let's process it as a
           generic issue but let's call it some other form of
           generic identification, then let's do it with the
           easiest possible pathway.  That's what NMSS did here. 
           It was done through the IEN or the genetic
           communications process.
                                Next slide, please.  I have some positive
           things about the process itself.  Several of these are
           kind of interrelated as you look down through the
           bullets.  Most of them have to do with saving staff
           resources at various stages of in the game.
                                The first one would be to save resources
           obviously for those issues that would be proposed that
           were of low risk that would never meet the thresholds. 
           Therefore, why waste your time doing analysis if
           you've already got a very good idea from a group of
           experts that would say, "If we don't need to do that,
           we're smart enough to determine that we're not going
           to meet that threshold so let's drop the issue
           entirely or possibly go and do it under some other
           sort of a format like the generic communications
                                When you get down to the compliance issue,
           if you actually determined there was a compliance
           issue and you did some analysis on it, at least you
           would have some sort of a technical basis to give back
           to NRR or give back to NMSS or whoever is working the
           issue that would help them in that compliance arena.
                                NMSS felt that the formality of the process
           gave it visibility.  At their meetings I was very
           impressed that their panel was quite large.  There
           were a lot of people that attended the meeting, not
           only the panel people themselves but other people who
           were interested.  
                                I think a lot of discussion took place at
           that time so there was a lot of visibility given to
           the process so they got some respect, I guess, is what
           we're saying here.
                                They also thought that the flexibility of
           the handbook, which is a guidance document, was
           written not to be a verbatim compliance document where
           you had to do step one, two, three in order and check
           off all the blocks.  It is a guidance document.  
                                They use it as a guidance document and took
           those things out of the handbook that best fit them in
           addressing the issue at hand.  In that way, they had
           flexibility to do what they did based on what the
           generic safety issue was.
                                The next bullet down, the processing time
           may be shortened.  I already mentioned that, that you
           could eliminate unnecessary analysis because of
           whatever the thresholds might be that you're not able
           to meet them.
                                They also thought there was a consensus on
           the scope of the generic issue early on.  This was
           perceived by many as something that the old process
           possibly needed some fine tuning on and that was to,
           as Harold mentioned earlier, too, try and define what
           the scope of the issue is quickly so it's something
           that everybody can get arms around that you can
           define, that you can see what the analysis should be,
           and then go ahead and work it as opposed to something
           that is foggy and too broad.
                                Next slide, please. 
                                I did all the good stuff.  Harold can do the
                                MR. VANDERMOLEN:  I get to do the
           shortcomings and limitations which also exist.  The
           first one I think we've already discussed quite a bit. 
           It's been administratively cumbersome.  That's party
           because, as I said before, it's not hard to get
           people.  It is very hard to get certain people.  The
           people you really want for these things are often
           people who are very much in demand, very heavily
                                What makes it even worse, particularly for
           reactor issues, you're dealing with two offices and
           all the implications that would imply.  It's not easy. 
           You have to get memos back and forth on a high level. 
           It takes a while.
                                Also, the initial screening stage, which is
           the panel meeting, may not provide a sufficient basis
           for decision making.  At this point you haven't done
           a quantitative or any semi-quantitative analysis, just
           looking at the issue.
                                One of the outcomes the panel can vote on
           according to the management directive is to drop it
           based on it having very little -- I'm trying to quote
           it as exactly as I can -- very little chance of
           meeting the threshold criteria.
                                That's not so easy to do in practice.  In
           fact, it's not always easy to make conclusions based
           on an actual quantitative PRA analysis.  When you're
           trying to do it before you even do the analysis it
           gets a little bit more difficult still.
                                The threshold for processing candidate
           issues is not clearly defined for materials issues. 
           What that means is there is an Appendix C attached to
           the handbook of the management directive that gives
           the criteria for reactor issues in terms of LERF and
           the usual PRA parameters.  We don't have an analogous
           one for materials issues.  We really need to develop
           something like that.
                                The documentation of "closed" issues for
           materials issues could be enhanced.  The existing
           process is in an RES office letter.  It only applies
           to RES but there is a very definite process we go to
           when we finally decide we're done with a generic issue
           how do we close it out.  The answer is a resolution
           package is written and, as I'm sure you all know, it
           comes down here for review.
                                After that, assuming all you gentlemen give
           us a positive letter, the letter is attached to the
           package, a cover letter goes on top.  There is
           definite guidance on who concurs on it but it's signed
           by our office director and goes to the EDO.  A similar
           thing had not been developed for NMSS and that's not
           really specified in the management directive.
                                Finally, we need a clear link between
           management directive 6.4 and GIMCS.  GIMCS stands for
           generic issue management control system.  It's our
           tracking system for all of the generic issues.
                                There is no requirement to use that
           specifically in the management directive.  It just
           says that you want to have quarterly reports, although
           it's no problem when you're doing everything within
           research because research administers the system. 
                                In fact, we are upgrading the system event. 
           It used to run for many years under quarterly
           publications and we are trying right now to put it on
           the World Wide Web as well.  It is public.  Having
           gone through all that, we would like to keep GIMCS as
           our agency-wide tracking system and have everything on
           all generic issues in one place.
                                Moving on to the next slide, these are more
           observation.  The last slide had shortcomings.  These
           are observations.  Not all of them are problems.  The
           issues are complex.  They do result in a significant
           amount of review time and some conflicts with other
                                The fact of the matter is nobody -- nobody
           puts a simple problem into the generic issue process. 
           If you run across a simple question, you just go ahead
           and solve it.  You don't go through all this.  The
           ones we get are virtually guaranteed to be thorny.  
                                I think if I did this over again I would
           strike that word often.  If you have a generic issue,
           count on it.  Actual practice says that it's not going
           to be simple or straightforward.  It's going to take
           a little bit of effort to investigate and make these
                                DR. KRESS:  What's the incentive or
           motivation for staff to serve on this panel?  Because
           it's their civic duty?
                                MR. VANDERMOLEN:  For reactor issues we
           provide them free donuts.
                                DR. KRESS:  Okay.
                                MR. VANDERMOLEN:  Other than that, they have
           to get all of their work done.  Even with the free
           donuts we didn't always get everybody quite as eager
           to serve as we want.
                                Issues can involve several disciplines.  In
           just the issues we've talked about, we've had to
           consult people who had expertise in metallurgical
           sciences, expertise in reactivity, thermal hydraulics
           and thermal hydraulic phenomenon, post-accident
           phenomenon maintenance practices, the engineering of
           motor operated valves.  
                                All of these things and you inevitably are
           going to wind up with a fairly large number of panel
           members.  The higher the number of panel members, the
           harder it is to get everybody together.
                                I say that in the context of the next four
           bullets which manage to pull us in four orthaganol
           directions, hard to do in a Euclidian space.  The key
           is that third bullet from the bottom.  
                                It's difficult to establish a panel and
           complete initial screening stage within the required
           30 days.  Now, for one thing, it can take you at least
           a week and more likely two weeks just to get the metal
           out establishing the panel.  Going through all of this
           in 30 days, it's just not realistic.
                                Backing up to the bullet right above it,
           greater commitment from NRC staff will be required to
           establish panels.  What we ran into here is that we
           discovered some of the offices were budgeting
           something like $100 for the year for these panels.
                                That would be fine if they gave us
           perfunctory things to do but you give us stuff where
           we're going to have briefing packages that are this
           big and then have a combined total of $100 for all
           issues.  That's not realistic.  I'm not complaining. 
           The offices had to budget something and we didn't have
           the experience back then to find out.
                                When we finish this up we are going to check
           how many hours were spent on these panels and we'll be
           able to budget more appropriately.
                                Going on, there is still a desire by NRR for
           a more in depth risk based evaluation prior to
           drafting an issue from the generic issues program. 
           When you get a generic issue somebody really believes
           in it.  Now, some of these come from DPOs and we don't
           discourage this.  This is how we handle a lot of them. 
           Most of them actually come with the full backing of
           NRC management.
                                If the panel votes the thing into a drop,
           possibly that makes some people happy but someone
           thought enough of this issue to send it and it just
           doesn't work just to have a panel vote.  You have to
           have some basis.  The panel has to document it as well
           and it's clear we have to have good guidance on how we
           do that documentation.  It's just not going to wash
           just to say they voted.
                                Finally, as Ron mentioned earlier, if you
           have an issue that is voted to be a compliance issue,
           in theory that was supposed to say, okay, it's a
           compliance issue.  It's not a generic issue.  Give it
           back to NRR or NMSS.  You've got the tools you need
           already to fix it.  Just tell them to go do what they
           are supposed to do.  Tell your licensees to do it.
                                Well, the people who have to enforce them
           want to be risk informed as well.  What happened in
           reality with the heavy load issues, they came right
           back and said, "Tell us how important it is."  That's
           an honest question and deserves an honest answer so we
           wind up doing the problemistic evaluation anyway.
                                Going on to the next slide, a few other
           observations.  The previous generic issue process did
           not work so well either.  I think it's pretty clear
           that we can't just go back to the old process.  We do
           need some improvements.  But we do feel that this
           whole process we've gone through comparing the two
           issues, although it had its frustrations, and I think
           Ron and I have more opportunity to be frustrated than
           anyone, we do feel it was worthwhile.
                                I do want to add one more caution before we
           get into the recommendations and that is these lessons
           learned are not all inclusive.  We haven't gotten
           anything all the way through the process.  We probably
           have gotten most of the differences by going through
           the first three stages.  At this point we haven't had
           any issue get past stage 3 of the management
                                Stage 4 when you get into technical
           assessment, then you are going to contractors and
           spending big money.  You are really working the issue
           and you'll have task action plans and all this sort of
           thing.  That takes a lot longer but that's what needs
           to be done to fix these issues.
                                Going on, Ron.
                                MR. LLOYD:  The next slide has to do with
           the recommendations based on our lessons learned from
           taking a look at both reactor and materials issues. 
           The first thing kind of going through in chronological
           order as to really clarify the information that's in
           Appendix A.
                                Right now Appendix A is basically a table
           that list a whole bunch of items.  It says to the
           person that wants to submit one of these things
           whether it's outside the agency, with the industry, or
           inside the agency, "Here are a whole bunch of things
           that you need to put down which would include what you
           think the issue is, what you think the basis for the
           issue is, whether there's a regulatory problem.  
           Also, what you think might be a solution to this
                                When it gets to the panel, they would have
           a good idea of what the scope should be of that issue
           and that there should be some sort of direction for
           the panel to take from which to go out and do
                                I think Appendix A, or the documentation
           that would surround A, ought to be kind of flushed out
           a little bit.  I think there would be much time, I
           think, spent in trying to figure out the scope.  I
           think that needs to be clarified so everybody knows
           what the scope is.  I think the appendix could be made
           more user friendly so better information could be put
           down.  Another thing would be to actually enforce the
           fact that whoever wants to submit a generic issue and
           actually fill out Appendix A and provide that
           information rather than saying, "Yeah, I've got a
           bunch of information for you.  Go do your thing," and
           then not follow the procedure in its entirety.
                                Another one was the initial screening stage. 
           As Harold mentioned, it was difficult sometimes to
           limit the scope there.  If you've got a bunch of
           engineers together, they want a lot of data upon which
           to make a decision.  
                                Consequently, the initial screening state,
           which was really supposed to be kind of a basic look
           at the background, what was on Appendix A, and some
           basic kinds of information, really got into doing the
           kinds of things that were in subsequent stages within
           the management directive.  
                                We had proposed here to limit some of the
           scope and make sure that people that were on that
           particular stage understood exactly what they were
           supposed to do.         
                                Which gets us down to the third bullet.  We
           felt that collapsing either stage three and four into
           one stage or stage two into three, and most likely
           stage two and three together would save some time and
           cut back on the amount of administrivia you would have
           to go through in order to process an issue.
                                Right now stage one is identification which
           is basically here's my background information as to
           why this might be a generic issue.  The second stage
           is the initial screening which is basically to review
           the preliminary information.  
                                When you get to stage three, it's technical
           screening and that is supposed to be sort of a quick
           look based on expert opinion and analysis of what the
           situation is.  
                                Then by the time you get to stage four, you
           are more of an in depth look.  The in depth look would
           include things like going out to licensees, gathering
           data, doing PRA studies, getting a contractor, and
           other kinds of things to get more hard data upon which
           to make a decision.
                                We felt there were some similarities in
           here.  Most likely the best thing to do would be to
           collapse stages two and three and make one that would
           best benefit the needs of everybody.  It would save
           time and cut back on the administrivia that really
           isn't necessary.
                                Another issue that we had a problem as we
           did our very first one which was on the heavy loads
           area.  We had our panel together and there were some
           questions as to what adequate protection really meant
           and what substantial --
                                CHAIRMAN APOSTOLAKIS:  Did you answer it?
                                MR. LLOYD:  You guys have answered that,
                                MR. VANDERMOLEN:  I have every confidence in
           all of your deliberations.
                                MR. LLOYD:  We went through and I took a
           look at all the documentation and everybody trying to
           figure out what adequate protection means.  Of course,
           we are still trying to figure that out today.  We did
           have a guest speaker come.  Joe Murphy came and talked
           with us and he gave us his best interpretation of what
           all that meant.  At least we had some input there.
                                As far as where the thresholds are, where
           your safety goal fits in, we tried to explain what
           that was.  What we ended up doing was basically using
           the guidance that we have in Reg Guide 1.174 and that
           was just basically copied right into Appendix C of the
           management directive.  We used the best guidance that
           we have to date.
                                If somebody here in the ACRS panel or in the
           agency is able to come up with a good definition of
           what adequate protection means with thresholds in
           there, we would gladly put that into the management
           directive and use some better information.  Right now
           we're using the guidance that is provided by Reg Guide
                                Next slide.  For the materials issues, as
           Harold brought out, we really don't have any
           thresholds that are out there that would give them a
           good idea as to whether this is an adequate protection
           issue or whether it's a safety enhancement issue or,
           to a lesser extent, a burden reduction issue.  
                                We ran into the same problem when we were
           going through the inspection program trying to figure
           out under each one of the basic categories how much
           should we inspect, when should we inspect, what the
           frequency should be, what the impact on core damage
           frequency is.  
                                If you're looking at an inspection issue
           from a reactor standpoint, how should you interpret
           that when you get over into the HP areas, the
           safeguards areas, the materials issues, the
           irradiators, those other kinds of things where you
           have different consequences of did things go bad.  
           We really need to come up with something that NMSS and
           others could live with that would provide better
           guidance than what we've got right now.
                                The documentation, as Harold mentioned, we
           really need to add some additional information in
           there on actually how to close things out as we come
           to conclusions from the panels and other things that
           we know what we should do.
                                That means what is the proper format for
           closing these things out.  What's the proper
           distribution for closing these things out.  What is
           the level of detail that is really needed.  Can you do
           this in a three or four-page memo or do you need
           additional information that would attach some sort of
           small report in order to make it go on to the next
           step or to make the decision to drop that issue
           completely.  Those things could be clarified. 
                                The other one is on GIMCS.  It's not
           mentioned in management directive 6.4 right now.  At
           the time we wrote the draft we thought that we
           wouldn't be using GIMCS and so what's in the
           management directive is NUREG XXX. 
                                What we've really decided to do, I believe,
           is to continue on with GIMCS but we are going to
           update it and it will be put on the Web so people will
           be able to get access to it.  That change will have to
           be made.
                                Clarify the level of technical analysis that
           would be done within the scope of the MD.  I think
           this should be more explicit at some of the early
           stages, once again to eliminate wasted time at
           addressing some of the issues that are of low risk
           significance and wouldn't meet any threshold.
                                The next slide we've got is a tentative
           schedule for the next few months.
                                DR. KRESS:  In your recommendations I didn't
           see anything to do with the problem of getting a panel
                                MR. LLOYD:  Those kinds of things, as Harold
           mentioned, those would exist with the old system.
                                DR. KRESS:  Those exist no matter why.
                                MR. LLOYD:  Those exist no matter why.
                                DR. KRESS:  No way to help that process?  Do
           you have your own separate budget for generic issues?
                                MR. VANDERMOLEN:  No, we do not.  Generic
           issues process is no contract dollars whatsoever.
                                DR. KRESS:  It's a stepchild.
                                MR. VANDERMOLEN:  And a fairly small team,
           exactly half of which is sitting up here at the table
           at the moment.  The other two, I see one in the
           audience.  That's it.
                                MR. LLOYD:  We're a small group.  I think
           that was one of our issues from the administrative
           standpoint.  We need to really raise this to a level
           of where people could be made available and that they
           would also realize what the approximate time
           commitment would be.  
                                I think that ought to be put in the memo. 
           I think offices should then be encouraged to stick
           that in their budget.  Assuming if we get the same
           amount of generic issues coming in, if we got four to
           six of these things in the period of a year, that
           equals X number of hours and then the different
           offices would just budget that amount.
                                DR. KRESS:  Just getting that guidance to
           the offices might help.
                                MR. LLOYD:  We should be able to provide
           guidance to the offices as to what to expect so it
           wouldn't be a surprise to them.  Good point.
                                Slide 16 shows what we would like to do is
           to make some basic revisions based on lessons learned
           by the end of this month.  That would then go through
           management review and research for a couple of weeks
           and then try to get it from the Office of Research by
           April 10.  
                                We would also notify the EDO as to what
           we're doing in a memo that would basically forward our
           lessons learned.  Then we would give everybody
           approximately a month to go through and do their peer
           review, get comments back to us by about mid-May, and
           then take the following six weeks to address those
           peer review comments, make the changes, and then get
           it once again out of Research by the end of June. 
           It's an aggressive schedule.
                                DR. KRESS:  It looks like May 11th time
           frame might be a good time for us to look at your
           changes and maybe make our comments then.
                                MR. LLOYD:  Sure.  You bet.
                                MR. LEITCH:  I have a couple of questions.
                                MR. LLOYD:  Sure.
                                MR. LEITCH:  On the average how many of
           these issues are being identified per year?
                                MR. LLOYD:  I think we are probably looking
           at right now maybe four to six.
                                MR. LEITCH:  Four to six.  And what is the
           average age of the open issues?
                                MR. LLOYD:  It depends on what time period
           you're looking at.  Some of these if you go back in
           time, we were looking at 15 to 20 years on some of
           these issues.
                                MR. LEITCH:  I mean currently the ones that
           are open.
                                MR. LLOYD:  Currently that ones that are
           open we've got --
                                MR. VANDERMOLEN:  We've had some that go
           back 20 years.  Having said that, I realize also that
           they go through a priority order based on these
           quantitative estimates, not on their chronological
           age.  The ones that tend to be left are the ones that
           were either very difficult to do or weren't of top
           safety significance.  I'm not trying to apologize that
           they are that old.
                                MR. LEITCH:  How many are open at the open?
                                MR. VANDERMOLEN:  Ron Emerette, how many are
           open right at the moment?  How many generic issues are
           open right now?
                                He'll tell you in a moment.
                                MR. EMERETTE:  About 12. 
                                MR. VANDERMOLEN:  About 12 right now.  We
           are also working these generic issues and we're
           getting for or six of them done.
                                DR. SHACK:  Are you working them all with
           the new process or half?
                                MR. VANDERMOLEN:  No, the older ones, the
           ones that are already in process, are still under the
           old process.  What really makes them move is that we
           report to Congress every month on our progress and the
           end date of our task action plan goes to the Hill.
                                They don't pay too much attention to our
           intermediate milestones but if we don't make the final
           one, we don't like to think about that possibility
           because we try making deadlines.
                                MR. LEITCH:  Are the goals of the new
           process to reduce the time or improve the quality? 
           What was the problem with the old process?  Is it a
           quality issue or a timeliness issue?
                                MR. VANDERMOLEN:  That's a little bit
           difficult for me to answer for two reasons.  One is 20
           years ago Tom Cox and I together wrote the old process
           so I guess I have a vested interest in it.  The other
           reasons is that this management started based on about
           three years ago. 
                                After the first draft had completed the
           office reorganized and I came in one day and
           discovered that I was once again in the generic issues
           process and the other people were not.  The day
           ironically was April 1 of 1999 which I thought was a
           most appropriate date.
                                I can't completely answer the question.  I
           think candidly people were having problems getting the
           probabilistic analysis done.  I think part of it was
           they weren't following the old process that closely
           either.  It wasn't that the old process was so bad but
           it was sufficiently difficult to use it and people
           were not following it.
                                MR. LEITCH:  Is the prioritization step in
           the old process?  I don't see a similar step in the
           old process.
                                MR. VANDERMOLEN:  It's the technical
           screening stuff. 
                                MR. LEITCH:  I see.
                                MR. VANDERMOLEN:  At this step it comes in
           and we do a probabilistic analysis of it using what
           resources we have in house.  That is, although we once
           had a contract on it, we don't go to licensees for
           information.  We don't spend major dollars on it.
                                What we found is that at least 80 percent of
           the time based on the information we have in house we
           can say that this is a drop.  If there's any doubt,
           that is, if we have unknown information, we put down
           a conservative figure.  
                                This is how it differs from most PRA
           calculations that you'll see here.  PRAs are supposed
           to be completely realistic.  Then if there's doubt, we
           continue with it and then we go over to the next stage
           and spend money and do it right.
                                DR. BONACA:  Just as an answer, if I
           remember, one of the major concerns was that because
           the first screening was not -- didn't have sufficient
           probabilistic analysis at the time, an issue was
           classified as potentially generic significance, would
           get there and then sit there for a long time and then
           years later would be evaluated and then dropped.  You
           had a lot of potential GSIs.  If I remember, that was
           one of the issues.
                                MR. VANDERMOLEN:  There was a significant
           backlog.  It depends.  When you get a reactor event
           happening, even one that is a precursor and wasn't
           really directly any kind of major threat, but we try
           and learn as much as we can.  Every time that happens
           a flurry of generic issues comes.  These do not come
           in on a regular basis.  I'm almost afraid to say this,
           but they tend to be somewhat stochastic in their
           occurrence.  You never know if you'll get none for a
           long time and then you've got three or four together
           all at once.  That's one reason why the backlog
                                I have to say also that doing the
           probabilistic analysis we read them after the fact and
           they look very straightforward but they look very
           differently when you start out with what I call NRC
           Form 0, a blank sheet of paper.
                                It's not always easy.  Sometimes it takes a
           bit of thought, consultation, and work to actually do
           the issues and we can't do all of them.  We can do
           most of them but we can't do all of them.
                                Other questions?
                                DR. WALLIS:  You have a new process in draft
           form and you want to assess it but nothing so far has
           got beyond step three, technical screening.  The real
           work is done when you do technical assessment and
           develop regulations and guidance.  No one has done
           that yet.  It's a new process.  How can you come up
           with a well-developed process when you haven't tested
           it yet in the main part?
                                MR. VANDERMOLEN:  It is quite possible that
           we would have to go back and revise it again.  The two
           aspects that I can say in partial reply, one is that
           when you get into the later stage of the issue,
           there's not that great a difference between the
           existing and the new process.  They run much more in
           parallel.  It's more that we track them further down
           rather than at a certain stage turn them over to
           another program.
                                The other is most issues don't make it that
           far.  It's a fairly rare occurrence but a very
           significant occurrence when an issue makes it all the
           way through.  In most cases, even when we go into
           complete technical assessment and really investigate
           the issue, it becomes a major research program and we
           may well find when we have all the information that
           this does not meet the criteria for any kind of
           regulatory action.  It's pretty rare that things go
           all the way through.  We have to allow for that
           possibility, of course, and we have to do it with some
                                MR. LLOYD:  I would say that the old process
           went through those same set of phases as far as if you
           had rule making to do or some other kind of thing to
           do.  You had corrective actions to come up with.  
                                You had to figure out whether or not
           licensees actually implemented those corrective
           actions and verified that they were acceptable, that
           they would, in fact, solve the problem at hand.  Those
           kinds of things were done under the old process.  The
           difference was is there wasn't a procedure.  They
           tried to track it.  
                                I think all we really did in that whole
           formulation process was to go through NMSS, go through
           NRR, and get that process that was being used, give it
           our best shot at how to make it smooth, and go as
           smoothly as possible, and then we put it down on a
           piece of paper.  
                                That's what you see under stages five, six,
           seven, and eight, the backend of the entire management
           directive.  The frontend, as Harold mentioned, is
           really the part where you try to resolve the issue. 
           After you've made a decision whether or not you're
           going to drop it, most of these would end up in the
           drop category.  
                                It was perceived, I think, by the agency and
           by Arthur Anderson, that helped us out on this, was
           that if you had a committee of experts looking at it
           initially, that you could come up with a pretty good
           fix on whether or not this would pass risk thresholds
           and, therefore, if we can get a real good fix on that,
           why should we go through and expend all of the
           resources to do that which we could do in a much
           shorter period of time.  
                                If, in fact, we decide to move it on to
           another stage and to go out and do a real in depth
           analysis from a PRA standpoint, then we would go ahead
           and do that and there would be very little difference
           between what we would do under this procedure than
           what was done under the old procedure.  
                                You might have one person doing it under the
           old procedure as opposed to a committee doing it under
           this procedure.  We were looking basically for
           efficiencies and then also some staff reduction time
           because you've got to realize that we are cutting back
                                DR. WALLIS:  Do you have measures of those
           efficiencies and staff reduction times?
                                MR. LLOYD:  We don't.
                                DR. WALLIS:  Do you have measures of these
                                MR. LLOYD:  As Harold mentioned, we are
           going to try to go back through and based on the
           timekeeping situation look at what was actually spent
           on these issues because we do have codes to charge
           against and we'll take a look at that.
                                CHAIRMAN APOSTOLAKIS:  Okay.  Any other
           comments?  Thank you very much, gentlemen.
                                (Whereupon, at 3:46 p.m. the meeting was

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