483rd Meeting - June 11, 2001

                       UNITED STATES OF AMERICA
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                               JUNE 11, 2001
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                            ROCKVILLE, MARYLAND
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                       The Advisory Committee met at the Nuclear Regulatory
           Commission, Two White Flint North, Room T2B3, 11545 Rockville Pike,
           Rockville, Maryland, at 8:30 a.m., George Apostolakis, Chairman, presiding.
                 GEORGE APOSTOLAKIS, Chairman
                 MARIO V. BONACA, Vice Chairman
                 F. PETER FORD, Member
                 THOMAS S. KRESS, Member
                 GRAHAM M. LEITCH, Member
                 DANA A. POWERS, Member
                 STEPHEN ROSEN, Member
                 WILLIAM. J. SHACK, Member
           COMMITTEE MEMBERS PRESENT (Continued):
                 JOHN D. SIEBER, Member
                 ROBERT E. UHRIG, Member
                 GRAHAM B. WALLIS, Member

                              C O N T E N T S
           Opening Remarks, Chairman Apostolakis  . . . . . . 4
           Proposed Risk-Informed Revisions to 10 CFR
           50.46  and Proposed Revisions to the Framework for Risk-Informing the
           Technical Requirements of 10 
           CFR, Part 50 . . . . . . . . . . . . . . . . . . . 5
           Presentation by Louis Ward . . . . . . . . . . . .84
           Policy Issues Related to Safeguards, Insurance,
           and Emergency Preparedness Regulations at
           Decommissioning Nuclear Power Plants Storing Fuel
           in Spent Fuel Pools  . . . . . . . . . . . . . . .98
           NEI Presentation . . . . . . . . . . . . . . . . 161
           Need to Revise 10 CFR, Part 54, Requirements
           for Renewal of Operating Licenses for Nuclear
           Power Plants . . . . . . . . . . . . . . . . . . 196
           NEI Presentation . . . . . . . . . . . . . . . . 206
           Control Rod Drive Mechanism Cracking . . . . . . 212
           NEI Presentation . . . . . . . . . . . . . . . . 280
           .                           P R O C E E D I N G S
                                                    (8:32 a.m.)
                       CHAIRMAN APOSTOLAKIS:  -- and he's being replaced by
           Sher Bahadur, who is joining us as Associate Director for Technical Support.
                       Also, Mr. Steve Rosen now is a member of the Committee
           officially.  Welcome, Steve.
                       DR. SHACK:  We don't have to quit being nice to him?
                       CHAIRMAN APOSTOLAKIS:  Not anymore.  You can be ask
           nasty as you want.
                       And finally, you have this pink thing, "Items of Interest."  There
           are four speeches by the Commissioners, three by the Chairmen, and one by
           Commissioner Merrifield.  The second one, the evolution of safety goals and
           their connection to safety culture, is of particular interest, I think, to the members
           or should be, but the others are very interesting, too.
                       And so members have any issues they would like to raise?
                       (No response.)
                       CHAIRMAN APOSTOLAKIS:  Okay.  We can begin then with
           the first subject:  proposed risk-informed revisions to 10 CFR 50.46 and
           proposed revisions to the framework for risk-informing the technical
           requirements of 10 CFR, Part 50.
                       Dr. Shack, would you lead us through this?
                       DR. SHACK:  We discussed this as a subcommittee meeting
           on Monday.  So this is deja vu all over again.
                       CHAIRMAN APOSTOLAKIS:  Today being Wednesday.
                       DR. SHACK:  And I think Mary will be leading us through this. 
           Why don't you just go ahead and start?
                       MS. DROUIN:  My name is Mary Drouin with Office of
           Research.  Also at the table with me is Alan Kuritzky.
                       We did meet on Wednesday --
                       CHAIRMAN APOSTOLAKIS:  No, Monday.
                       MS. DROUIN:  Monday.  Sorry.
                       We were trying to go through the presentation, and we did a
           little reordering of it based on how the discussion went so that we would go
           through it a little bit more smoothly.
                       Again, just quickly the points that we want to try to get to
           today; again, the purpose of what we're seeking out of the meeting; a quick
           background on Option 3 to emphasize some of the points; what our tentative
           recommendations and schedules are; and then based on that, to get into the
           detail then for each of our proposed recommendations; and then, again, wrap
           up with what your current status and schedule is.
                       Just briefly, again, here we're to report on where we are on
           50.46, in particular.  I want to remind the committee that the paper that they
           have currently is still pre-decisional.  It's still at the EDO's office, and has not
           been signed off.
                       Hopefully, you know, within a week it will get up to the
           Commission and become public, but right now it still is pre-decisional.
                       We did have in the paper noting that we have requested a
           letter from the ACRS, and that hopefully it would follow shortly after the July
           meeting.  But based on that, you know, we would particularly appreciate, you
           know, comments on our options, any comments on implementation issues,
           whether we've noted them all, if there's something missing, and then looking at
           the feasibility, the things that we think are feasible in the short term and things
           that we think are perhaps feasible, but are longer term efforts, and we will get
           into each of those.
                       Again, on the background, this is just a reminder and a
           refresher that in looking at Option 3, there are two phases to Option 3.  The first
           phase is what we call the feasibility study, and at the end point of the Phase 1
           is where we have our recommendations to the Commission.
                       In going through the Phase 1, we identified, you know, what
           are the candidate requirements, which are those that are amenable to being risk
           informed.  We prioritized them.  The prioritization does look at not only the
           resources and costs, but the desirability of doing it, which of course feeds in the
           resources and costs, and you know, how much safety benefit would come out
           of it.
                       And then the third part once we have done the prioritization
           is to take and look at the feasibility and provide recommendations.  But I want
           to emphasize again it's a feasibility study.  The Phase 2 is getting into the
           detailed technical work to support the rulemaking.
                       It could turn out that when we get into Phase 2 something that
           we thought was feasible isn't feasible, but we do go into it with a lot of
           confidence that it is doable.
                       Based on that, we'll get right into 50.46.  We wanted to quickly
           give an overview of what we're talking about.  We use the term "50.46," and
           when we talk about 50.46, we always mean in that context Appendix K in GDC
           35.  All three of these entities go hand in hand.
                       And when you look at it, we're going to be going through what
           we call these four topical areas here:  the ECC reliability; the acceptance
           criteria; the evaluation model; and the LOCA size definition.
                       When you look at the requirements that are stated in the
           50.46, Appendix K, and 35, they divide up into these four topical areas or four
           categories, classes, whatever word you want to use.  But, in essence, they
           establish the reliability and what your acceptance criteria is and what evaluation
           model you need to be using in analyzing your ECCS, and then looking at the
           LOCA sizes.
                       So when we look at those four topical areas and looking at
           information that we have that we've learned over the years and our knowledge,
           and looking at the top three, we do feel that it's feasible right now in the short
           term to do things to the requirements that are associated with the reliability, with
           the acceptance criteria, and with the evaluation model.
                       When we look at the fourth one, we haven't completely
           established the feasibility.  We feel we need to do a lot more work in that area,
           and that's a longer term effort.
                       I don't know if you want to add some stuff to this, Alan.
                       MR. KURITZKY:  Just mainly for this last one, I think the
           important thing is that we need to improve our state of knowledge of LOCA
           frequencies.  I mean, right now our current estimates of large break LOCA
           frequencies, we know or we feel that right now they're not low enough that we
           could rule out a large break LOCA as a classroom design basis.
                       As we go and look into more and improve our state of
           knowledge of LOCA frequencies, we may decide that there are further
           relaxations that we can afford large break LOCAs.  That's just something that
           will have to be determined as we continue the feasibility study.
                       DR. POWERS:  Let me just understand that a little bit better. 
           You're defining large break LOCA in this case as something like a six inch break
                       MR. KURITZKY:  Yeah.  In this example, using the PRA
           definition, which for PWR would be greater than six inches.
                       DR. POWERS:  Do you think that you could rule out some
           larger size break?  Would you feel comfortable that, you know, you can argue
           that that frequency is low enough at this point?
                       MR. KURITZKY:  Well, the point is that right now what we
           don't have is data for LOCA frequencies versus pipe size.  The current data, the
           best data we have right now is for the group in the PRA, which is six inches and
                       DR. POWERS:  You're not likely to get data on breaks, you
           know, of larger pipes.
                       MR. KURITZKY:  Well, right, right, right.  Well, not data, but
           you can do analyses, and you're going to have some consideration of service
           data to help fashion your end -- the frequency you come up with.
                       But the bottom line is that we recognize that a double ended
           guillotine break of the large pipe in the RCS is a very low frequency event, but
           if we're going to eliminate that one from the design basis, we have to set a new
           point of where we're going to -- the maximum that can be considered.
                       And right now we don't feel that we have enough information 
           to be able to confidently say what that point should be.  So what we will be
           doing in the next few years as part of this effort will be to try and improve our
           state of knowledge of LOCA frequencies; maybe to come up with some kind of
           curve of LOCA frequency versus pipe size; and at that point, we may feel that
           at a certain point we can either say these LOCAs -- and it doesn't have to be at
           the six inch point, but at any point -- that LOCAs above this size don't need to
           be considered at all in the design basis; LOCAs in this interval need to be
           considered, but not to the full extent they are right now.  You know, there could
           be some graded approach.
                       But all of that hinges on our improvement of the state of
           knowledge of LOCA frequencies, which is fairly rudimentary right now.
                       DR. KRESS:  Does that assume that the frequency is only a
           function of pipe size?  It seems like there's some other variables in there.
                       MR. KURITZKY:  Yeah.  In fact --
                       DR. KRESS:  You would hide those in the uncertainty
           distribution some way maybe?
                       MR. KURITZKY:  Well, if you had the metallurgical people
           here, they could give you a whole bunch of other things, the locations, and I
           don't know whether it would be -- I don't want to speak in those areas because
           Dr. Shack can do a lot better job at this than I could, but whether it be like
           number of wells and, you know, the --
                       DR. KRESS:  In any given plant, there's not a continuum of
           pipe sizes?  There's a set of discrete sizes?
                       MR. KURITZKY:  For the most part, yeah.
                       DR. KRESS:  So you go from six inches to what?  The next
           size up is?
                       CHAIRMAN APOSTOLAKIS:  If you had a guillotine break of
           the largest pipe, what is the equivalent diameter?
                       DR. SHACK:  Twenty-four to 36.
                       MS. DROUIN:  Yeah, on that order.
                       MR. ROSEN:  I would make a simple point that we are getting
           data on large break LOCA frequency every day.  Every day that we don't have
           one is another day that we add to the database.
                       DR. KRESS:  It's going to take a long time.
                       MR. KURITZKY:  Right.
                       CHAIRMAN APOSTOLAKIS:  I guess you are proposing that
           the first three boxes of the previous slide -- maybe you can put it back -- the
           reliability, acceptance criteria, and evaluation model for the ECCS.  We can do
           something about these in the short term, right?  Whereas the size will have to
           wait for later.
                       I wonder what the dependence of the first three boxes is on
           the fourth one.
                       MR. KURITZKY:  It's a good point.  Specifically the first box --
           the second and third, not as much, but there could be some dependence
           especially on the third, but the first one very much so could be dependent on the
           same thing.
                       CHAIRMAN APOSTOLAKIS:  Well, I mean, the third, too.  I
           mean --
                       MR. KURITZKY:  The third to some extent also.
                       CHAIRMAN APOSTOLAKIS:  Realistic assessment of
           uncertainties, doesn't that depend on what kind of size of break you have?
                       MR. KURITZKY:  Right, and you could adjust that.  The
           current model is looking at all of them.  So it's not as important.
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MR. KURITZKY:  If you want to try to scale back what your
           requirements would be for that model for different sizes, which is something
           we're also looking for in the long term.
                       In the graded approach I was referring to, you may have
           something where certain size LOCAs, it doesn't mean you take them out of the
           design basis, but you may lessen the degree of conservatism as defined in the
           modeling for those, in the performance calculations.
                       But particularly in the first one, too, I mean, the frequency of
           LOCAs would be very -- you know, improved state of knowledge on LOCA
           frequency would be very useful to that first one.  What we were trying to do in
           the short term, just to kind of rehash what we discussed on Monday, is we're
           coming up with two options under there, and I don't want to jump the gun too
           much, but one of them would be more prescriptive where the NRC would set
           what boundary conditions you would have to consider for your ECCS
           performance calculations, and we would do that based on our current
           knowledge of large break LOCAs.
                       We would also have an option where a licensee could do plan
           specific calculations to further fine tune what needs to be considered in those
                       One of the areas where they could help them fine tune --
                       MS. DROUIN:  I think we're getting way ahead of our
           presentation here.
                       CHAIRMAN APOSTOLAKIS:  I understand that.
                       MS. DROUIN:  We've got slides on all of this.
                       CHAIRMAN APOSTOLAKIS:  But the point is that ideally the
           size of the LOCA should be critical to the evaluation of all boxes, right?
                       MR. KURITZKY:  Un-huh.
                       CHAIRMAN APOSTOLAKIS:  The reliability of response and
           so on.  The reason why perhaps -- I'm trying to understand now -- the reason
           why the first three boxes are easier to handle in the short term is because they
           are deterministic.  You are really looking at the availability of on-site power and
           this and that, and you say, "Gee, I can do something about it, even though I
           don't know the exact size of what a large LOCA is."
                       MS. DROUIN:  That is correct.
                       CHAIRMAN APOSTOLAKIS:  Right?  But if I were to do a
           detailed reliability calculation in the sense of PRA, I would have to know, but the
           criteria are deterministic due to tradition.  So you say, "No, no, no.  I can do
           something about it because what I can do is independent of the size."
                       MR. KURITZKY:  Right, though we try to assume --
                       CHAIRMAN APOSTOLAKIS:  Okay.  So that's a correct
           understanding then.
                       MR. KURITZKY:  We still have to assume a LOCA frequency
           of the --
                       CHAIRMAN APOSTOLAKIS:  Sure, but whether it's six inches
           equivalent in diameter --
                       MR. KURITZKY:  Right, exactly.
                       CHAIRMAN APOSTOLAKIS:  -- or ten, it doesn't affect the
           first three boxes.
                       MR. KURITZKY:  Exactly.
                       CHAIRMAN APOSTOLAKIS:  Does it?  I mean, because if it
           does, we need to know.
                       DR. SHACK:  The first box, the proposal is going to certainly
           depend on their ability to discriminate from break sizes, but that's getting ahead.
                       MR. KURITZKY:  I understand.  There's something we can do
                       CHAIRMAN APOSTOLAKIS:  Which is independent of size.
                       MR. KURITZKY:  Right, and then more could be done with --
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       DR. SHACK:  Size matters.
                       MS. DROUIN:  We're going to come back and revisit this as
           we get into it, go into the presentation.  But just quickly, you know, when we just
           talk about that, the first three boxes are in the short term, the fourth box in the
           longer term.
                       What do we mean by that?  And you heard on Monday that
           in the short term we have this A and this B.  Well, the A is looking at making
           changes to the current 50.46, and that's looking at changes that would be made
           to the acceptance criteria in the evaluation model, and this is stuff that is not so
           much risk informed as clean-up, and we're going to get into each one of these
           in more detail.
                       The only thing I want to point out is that we have two things
           that we're doing in the short term, and that's changes to the current 50.46 and
           also developing here a voluntary risk informed alternative.
                       DR. POWERS:  This I don't understand, why you're making
           these changes.
                       MS. DROUIN:  Excuse me?
                       DR. POWERS:  Why are you making these changes?
                       MS. DROUIN:  If you will hold off, we're going to get into what
           the changes are and why we're --
                       DR. POWERS:  Why don't you tell me now?
                       MS. DROUIN:  Can I -- can we skip to that slide, then?
                       I guess I don't understand the why.
                       DR. POWERS:  So you're making changes to the tech.
           requirements of the current 50.46 related to the acceptance criteria in the
           evaluation model.  I just wanted to know why.
                       MS. DROUIN:  I guess we have --
                       DR. POWERS:  If you don't like them --
                       MS. DROUIN:  We have better knowledge.  We're trying to
           address the conservatisms that we think are unnecessary.
                       MR. KURITZKY:  I think that is the previous slide is where you
           want to go.
                       MS. DROUIN:  Make it more up to date.
                       MR. KURITZKY:  Option 3 is directing us to look at regulations
           that we can make changes to technical requirements, to reduce unnecessary
           burden, to enhance safety.
                       DR. POWERS:  So you've got some measures of burden?
                       MR. KURITZKY:  Yes, we do.
                       MS. DROUIN:  Yes.
                       MR. KURITZKY:  That have been supplied by industry.
                       DR. POWERS:  And you're going to tell me about those?
                       MS. DROUIN:  Yes.  I'm sorry.  I wasn't -- I just didn't
           understand what your why -- where you were coming from on that question.
                       DR. POWERS:  Yeah, I just want to understand why you're
           making these changes.
                       DR. SHACK:  It says for improved safety and to reduce
           unnecessary burden kind of a question.
                       MS. DROUIN:  Yes.
                       DR. SHACK:  But A is primarily an unnecessary burden
                       MS. DROUIN:  Absolutely.
                       DR. SHACK:  And B, we could argue --
                       CHAIRMAN APOSTOLAKIS:  And improved knowledge of,
           and improved knowledge.
                       MS. DROUIN:  I also want to point out that in both the short-
           term and the long-term considerations that we're trying to do, is that we are
           following the guidelines of our framework.
                       And on the last one, in following the guidelines of the
           framework, again, to reinforce that this is not risk based.  It is risk informed.  So
           if we go back to the framework, we had those six principles of defense in depth,
           and those always have to be met.
                       Just schedule-wise, in looking at the proposals that we have
           under consideration, the short-term one we're looking at in terms of develop the
           proposed rule that the 12 months after the issuance of the SRM or two months
           after the completion of the technical work.
                       Then when you look at the technical work, if you're looking at
           changes to the current 50.46, we're going to continue.  We aren't going to stop
           right now.  We're going to continue doing the technical work.  We feel we can
           have the first one done by July of 2002, and then in terms of the risk informed
           alternative option, that's in April of 2002.
                       DR. POWERS:  Proposing in this is work to be done in July
           2002?  Is that why you're proposing changing Baker-Just to Cathcart-Pawel?
                       MS. DROUIN:  Yes.
                       DR. POWERS:  Can you explain to me the rationale behind
           that change?  In particular, what I'd like to understand exactly is Cathcart-Pawel
           kinetics are based on plant sheds exposed to steam, and how do you apply flat
           surface data to curved surface fuel clad?
                       And the issue of spallation at high oxidation extents.
                       MS. DROUIN:  Okay.  We're going to ask Norm, who's the
                       MR. LAUBEN:  I don't want to represent myself as the expert
           in this.  I think Ralph Meyers, our fuels expert, but the idea of changing -- the
           idea of the change here is to get a more realistic heat generation rate.  When
           it comes to cladding embrittlement and that sort of thing, that's being handled
           in the criteria part, not the change to Cathcart-Pawel.
                       Well, there are two things.  First of all, as far as embrittlement
           is concerned, the current rule addresses zircaloy and ZIRLO fuels, and the idea
           of the change there is to look at embrittlement for all zirconium based claddings.
                       But the purpose of this is the known fact that the parabolic
           rate laws that govern all of these things are probably pretty conservative, well,
           is known to be quite conservative by using Baker-Just at the higher
                       So to use another rate equation for heat generation is
           certainly justified by the data, and the data is taken from cylindrical cladding. 
           At least it is for Cathcart-Pawel, and Baker-Just is the one that's based on
           dropping pieces of metal in water and things like that.
                       So I think that --
                       DR. POWERS:  What I'm really asking is how do you handle
           the deviation from parabolic kinetics due to spallation of the oxide.
                       MR. LAUBEN:  Okay.  That's going to be -- there is no
           deviation.  All of the rate equations now are parabolic, Cathcart-Pawel, Baker-
           Just and all of them.
                       DR. POWERS:  -- all of them parabolic.
                       MR. LAUBEN:  Right.
                       DR. POWERS:  The question is how the metal behaves.
                       MR. LAUBEN:  Right, and there is ongoing work that's being
           done by industry and our group of people who's at Argonne and so forth, who
           are looking at other information on oxidation, including the long-term pre-
           oxidation prior to the accident and so forth.
                       Is that kind of what you were asking about?  There's a lot of
           pre-oxidation that might be affected during the accident and so forth?
                       DR. POWERS:  There's a lot of deformation in the material --
                       MR. LAUBEN:  Okay.
                       DR. POWERS:  -- that takes place prior to accident.
                       MR. LAUBEN:  Yes, right.
                       DR. POWERS:  And so what you're going to look at is kind of
           optimal material that Cathcart and Pawel used, and then you're going to say
           that applies to something that is beaten, folded, and manipulated before it's
                       You also bring up the pre-oxidation.  That clearly occurs, too,
           and I'm wondering how do you justify this.  The one thing we knew when we
           used Baker-Just is we were definitely bounding things.
                       MR. LAUBEN:  Well, it doesn't take into account any of these
           other factors either that you're talking -- excuse me?
                       DR. POWERS:  We knew that it was giving us an upper
           bound on things.
                       MR. LAUBEN:  Okay.  Well, you  know, beyond the fact that
           all indications are that it's very upper bounding when it comes to heat
           generation rate, this is the only reason we were going to change this.
                       DR. POWERS:  Now are you going with something that is
           more realistic, or is it a lower bound?
                       MR. LAUBEN:  Oh, no.
                       DR. POWERS:  Cathcart and Pawel takes this nice, pristine
           material, hasn't been zapped by a single neutron.  It hasn't been deformed,
           hasn't been cold worked, and oxidizes it.
                       Okay.  Is that going to give you correct kind of reaction
           kinetics, remembering, recalling that there is nothing about zirconium oxidation
           that predisposes it to be exactly parabolic.  It's just what we do to fit the
           equations, and sooner or later, it's going to fracture.
                       MR. LAUBEN:  Yes, but the idea is that in the criteria itself,
           which are embrittlement criteria, the idea is that you -- well, let me put it this way
           then.  Maybe this will help.  In terms of embrittlement, for instance, Baker-Just
           would still be used.  You can always carry along two equations in your code,
           one to calculate oxygen update, equivalent oxygen or ECR as they call it,
           equivalent clad reacted, which is related to the embrittlement criteria.  You can
           carry along Baker-Just for that and still use Cathcart-Pawel to calculate the heat
           generation rate due to the oxide -- due to a parabolic oxide thickness equation.
                       So that's my feeling at this point, but that goes into a lot of
           detail that we haven't really studied a lot, but I've discussed it with our fuels
           people, and this is what we think that we would do at this point.
                       So Baker-Just would still be there to calculate embrittlement. 
           Cathcart-Pawel would be there to calculate oxidation rate or -- excuse me --
           heat generation rate due to an oxide thickness diffusion.
                       DR. SHACK:  I thought you had a rather good discussion in
           the framework document of this problem of you're trying to introduce some
           conservatism somewhere that are covering uncertainties and non-
           conservatisms in other elements, and that you have to be careful when you're
           reducing known conservatisms that you're not leaving yourself vulnerable to the
           things that you were non-conservative about and uncertain about elsewhere.
                       MR. LAUBEN:  But that's also a somewhat dangerous thing
           to do because that says that you can use one conservative phenomenology to
           offset another non-conservative phenomenology, and that's sort of subtracting
           apples and oranges, and I'm not sure that that's a very effective way to do it.
                       DR. SHACK:  Well, it seems to me dangerous to just go
           around reducing conservatisms on one element without looking --
                       MR. LAUBEN:  Absolutely.
                       DR. SHACK:  -- at what those conservatisms were covering
                       MR. LAUBEN:  Absolutely.
                       DR. SHACK:  But I thought this is, again, a feasibility
                       MR. LAUBEN:  Yes.
                       DR. SHACK:  What we were talking about here is your current
           judgment is this can be done, but you will be doing the detailed technical work
           to support that.
                       MR. LAUBEN:  Yes, and also I think that that are things in
           50.46 that we are not changing that say that errors and changes need to be
           assessed and reported, and so forth.  So I think that that provides a basis to
           assure yourself that acknowledged non-conservatisms are not now going to
           become dominant in a way that you would not like.
                       And, therefore, I think the regulatory guide could take care of
           a lot of this to make sure that you don't allow that to happen.
                       DR. SHACK:  Now, when you say you're going to do this
           proposed rulemaking, that would have the accompanying reg. guide as part of
           that when the package is ready?
                       MS. DROUIN:  Yes, that goes with it.
                       DR. KRESS:  This whole discussion seems to me to scream
           out for a real good uncertainty analysis to be accompanying the Appendix K
           type things.  I just thought I throw in --
                       MS. DROUIN:  I agree.
                       DR. KRESS:  -- my favorite subject here.
                       MS. DROUIN:  I agree.
                       DR. POWERS:  I guess the question that comes to my mind,
           Tom, is why would you call out a kinetic expression at all if your objective is to
           get wider utility of cladding without exemptions.  Why not just say, "Look.  I want
           you to calculate in a reasonable fashion the amount of heat generation of the
           chemical reaction, and I want you to estimate the loss of ductility"?
                       DR. KRESS:  Oh, definitely.  In fact, I thought actually that
           was the direction they were going in in rewriting the rule.  Yeah, I think you're
           absolutely right.  That's the way to express it.
                       DR. POWERS:  They write out Cathcart-Pawel.  You've got
           a problem.  First of all, there's not a specific --
                       DR. KRESS:  Yeah, yeah.  I think that's --
                       DR. POWERS:  So the generality is now suddenly suspect. 
           Plus they're hanging onto the concept of old parabolic reactions, a material that
           inherently doesn't want to be parabolic and geometries that don't inherently
           want to be stable.
                       DR. KRESS:  Yeah.  I think it's the old problem of what do you
           put in a rule and what do you put in a reg. guide.  I certainly wouldn't put it in the
           rule, but in the reg. guide I would allow a lot more flexibility, but you know, the
           tendency is to say this is one way that's acceptable to us, and I don't know if
           they want to make that judgment or not.
                       See, that's a judgment that --
                       DR. POWERS:  It seems to me that following your tact, that
           they have to scrutinize the reg. guide very closely because if they're enamored
           with parabolic kinetics, which are nice and simple, on a material that itself is not
           nice and simple --
                       DR. KRESS:  And you know, they're trying to loosen it up to
           allow other types of clad, and I don't think we know what those other -- those
           other types of clad may very well depart more from parabolic.  So I would have
           written it more generally also.
                       DR. POWERS:  I mean, we're looking at what they're fixing
           to do, and they seem to have a strategy that inherently has a difficulty in it in
           that it's simply replacing one set of determinisms with another set of
           determinisms and saying, "Ah, but these are risk informed."
                       They're no more risk informed now than they were, or no less,
           than the original ones were.
                       DR. KRESS:  Yeah.  I think that's almost a good description
           of the nature of everything they're doing under A, and that's why we're more
           interested in what they're going to do under B, I think.
                       MS. DROUIN:  I agree with your statement, and one of the
           points that we did make on Monday is that when you look at the A and the
           changes that we're considering to the current 50.46, that we wouldn't call this
           risk informed.  We were looking at this more as just a clean-up in terms of we've
           got newer information, and that's why we were in terms of this one modifying the
           current --
                       DR. WALLIS:  This isn't a clean-up.  This is a change in
           philosophy.  I mean it's moved away from prescriptive to performance based. 
           That is a change in approach, and I think we supported that idea, I mean, when
           you were here a couple of days ago.
                       MS. DROUIN:  Yes.  That is correct.DR. WALLIS:  And that's
           the thrust of the previous discussion we just had, is that don't be prescriptive. 
           Don't replace one prescription with another, but replace it with a really well
           thought out performance based requirement.
                       Now, we talked a bit about whether or not these requirements
           were worded in a suitable way, I remember, and we have to be very careful
           about how we define the requirements that the cladding must satisfy.
                       I don't see this as a clean-up.  I see it actually as a change in
                       MS. DROUIN:  For this part of it, that would be true.
                       MR. KURITZKY:  Yes.
                       MS. DROUIN:  But this is the first part of A.  There were two
           parts to A, and I just --
                       DR. WALLIS:  I think we were supportive generally of this
           approach on Monday.
                       MS. DROUIN:  Yes, you did.  Yes, you did.
                       MR. KURITZKY:  Okay.  Actually so let me go right here. 
           Under A, as Mary said, there are two sets of changes we're looking at on A and
           B, for lack of a better discrimination, but the A is the changes to the current
           regulations and whether you consider it to be clean-up or more performance
           based; really the purpose of this first part to make it more performance based
           is to make it more flexible, allow it to apply to more than just the zircaloy and
           ZIRLO cladding.
                       So we have A, which is the changes to the current
           requirements, and B is the more risk informed piece.  So first to discuss the
           changes to the current requirements, there are two pieces to that really also. 
           The first is this one that Dr. Wallis was just mentioning about the performance
           based requirement for the acceptance criteria, and the second one is going to
           be changed to the Appendix K required features, which Dr. Powers was
           bringing up some questions on.
                       So first we'll touch base with the acceptance criteria.  What
           we're considering doing is replacing the current five prescriptive acceptance
           criteria which are in Paragraph B of 50.46 over the performance based
           requirement, and just as a quick rehash, those current five acceptance criteria
           are the peak cladding temperature limit of 2,200 degrees F. and the 70 percent
           total oxidation, and those two are really surrogates for embrittlement, for an
           embrittlement criterion.
                       And then there's a limit on hydrogen generation.  The fourth
           one is to maintain core geometry which deals with the ballooning and
           swallowing of the fuel to make sure that you have adequate core fold area
                       And the last one is the need to maintain long-term cooling,
           and what we were proposing here, we would have a performance based
           requirement to demonstrate adequate post quench cladding ductility and
           adequate core flow area to insure that the core remains amenable to cooling,
           and what that would do is that would really cover us for the first two, like one,
           two, and four of the original five criteria, the two embrittlement criteria, and the
           one to make sure that the core geometry remains amenable to cooling.
                       But in the second part of our performance based
           requirements after the duration of the accident, we maintain calculated core
           temperature at an acceptably low value, and we move to K heat, and that's
           essentially just copying the fifth one, the long-term cooling one from the current
                       DR. WALLIS:  On Monday we discussed these, and I think we
           encouraged you to think again about how you define these because adequate
           cladding ductility is a pretty vague expression.
                       MR. KURITZKY:  Right.
                       DR. WALLIS:  And then you can always cool things, but then
           the question is what are the consequences of the way you cool.  So you have
           to be very careful about how you define these performance based
           requirements, and I think we felt that that particular one you've written there
           needed some work.
                       MR. KURITZKY:  Right, and in fact, I have noted that there
           were comments on what we talked about as far as remaining amenable to
           cooling and also, you know, maintaining the temperature and acceptably
           evaluate.  We did note those comments.
                       MR. LEITCH:  Would you then leave unchanged the hydrogen
           generation specification?
                       MR. KURITZKY:  No, actually as was mentioned, the
           hydrogen one was actually being dropped from the performance based
           requirement because it's not found to be controlling, and the hydrogen
           generation is covered by the 50.44, the hydrogen rule.
                       MR. LEITCH:  Okay.
                       MR. KURITZKY:  The combustible gas rule.  So it would have
           the hydrogen piece left in the ECCS rule.
                       MR. LEITCH:  So this would be silent then on --
                       MR. KURITZKY:  On the hydrogen generation, yes.
                       DR. POWERS:  If your objective is to have a coolable
           geometry, why do you bring up cladding ductility and flow areas?  Why not just
           say be able to cool this core?
                       MR. KURITZKY:  Well, again, this is not my expertise, and if
           Ralph Meyer, had he been here probably could fill you in better, but I think you
           try to start at the highest level possible.  Obviously, what you just mentioned
           would be the highest level, and so there could be some argument of why we
           would want to maintain it there, but I guess you want to also go down to a level
           you feel you can have some metric or some way of measuring your
           performance, and so it's at that level, it's my understanding, that that's where
           we're comfortable and where we can measure something.
                       DR. WALLIS:  Well, I think we said you could cool a rubble
           bed, too.  I mean you've got to be more specific than just you can cool it.
                       MR. KURITZKY:  Right, right, and demonstrating adequate
           post quench ductility kind of maintained -- is telling you that you're going to keep
           the basic structure of the core.  So you're not --
                       DR. WALLIS:  Why don't you say something about release of
           fission products?  I guess we said this on Monday.  That seems to be what
           you're trying to prevent.
                       MR. KURITZKY:  Right, right, and that kind of goes, I think,
           along with what Dr. Powers said, but I think the same reason was it was hard
           to specify a limit if we looked at that high level, and this was the next level down
           where it felt comfortable, and it could become established criteria or measurable
                       DR. POWERS:  Well, you way it's hard to establish a limit on
           fission product release.  Actually it's easy to establish a limit.  You can pick one.
                       What you're saying is it's hard to pick one that easy to justify.
                       MR. KURITZKY:  Exactly.
                       DR. POWERS:  Now, doesn't risk have a role in trying to
           make that justification?
                       MR. KURITZKY:  Risk may have a role.  We actually had
           considered some risk informed changes here.  We didn't feel that at this time
           that we were in a position to make recommendations along those lines.  So we
           were sticking with just the so-called clean-up aspects of these requirements.
                       I mean as part of the long-term work when we're looking at a
           greater approach, there may be some other changes we would consider.
                       DR. WALLIS:  I'm not sure risk helps you at all because you
           talk about core damage frequency.  A different number of kinds of core damage
           doesn't tell you how much is tolerable, and LERF just says your large release
           doesn't tell you.  It asks about the frequency.  It doesn't talk about how much. 
           So I'm not sure those measures help you.  You need some other kind of
                       DR. KRESS:  Yeah, you need an FC acceptance curve.
                       MR. KURITZKY:  So anyway, in the short term -- 
                       DR. POWERS:  He never gives up.  He never gives up.
                       MR. KURITZKY:  In the short-term, just to recap, for this part
           of the changes to the current requirements, we're just looking at making --
           replacing the existing criteria with the performance based criteria, which gives
           you a little bit more flexibility.
                       The main point is right there in that last bullet.  This is really
           just to allow use of cladding materials besides zircaloy and ZIRLO, without
           requiring the licensees to submit an exemption request, which is what currently
           would be the case or is the case.
                       DR. POWERS:  I guess, I mean, that's the one I just want to
           ground on.  Every time I see the words "Cathcart-Pawel" and then I see this
           line, why?  Why call out the kinetic expression?
                       MR. KURITZKY:  Well, are you discussing the changes to
           Appendix K now, the Cathcart-Pawel replacement?  Because that's going to be
           the next piece we're going to talk about.
                       This line here applies to only these changes which apply to
           the acceptance criteria, not to the evaluation models, is where we're going to
           discuss Cathcart-Pawel.
                       DR. POWERS:  Okay, but I can't separate those two.
                       MR. KURITZKY:  Well, I think, and again, it's not my area, but
           as Norm had mentioned, really in the modeling my understanding is that you
           can actually separate those two or you can use Cathcart-Pawel just for the heat
                       DR. POWERS:  It applies to a particular material.  It happens
           to be a zircaloy.  It doesn't apply to ZIRLO.  It doesn't apply to M-5.  Why call it
           out?  Why not say you've got to evaluate this stuff, whatever kinetic expression
           you use?
                       MR. KURITZKY:  Unfortunately I can't respond to that
           because that's no my area.
                       DR. POWERS:  Well, I mean, it seems remarkable that you've
           got a strategy here in which each is an isolated fiefdom and there's no contact
           between the two.
                       MR. CUNNINGHAM:  If I might, this is Mark Cunningham from
           the staff.
                       I think it's important to go back to a point, I believe, that Dr.
           Shack made a little while ago, is that the context of what we're talking about
           here in these changes is that this is the results of a feasibility study, and there's
           more work to be done to develop the technical basis for a rule change and to
           develop the language in the rule or the rule changes.
                       And we've got a year's worth of work in front of us in order to
           do that.  In the paper, I think we tried to be very explicit that possible changes
           to the current 50.46 could involve a number of things, including the changes
           from Baker-Just to Cathcart-Pawel.  It doesn't mean it's done, but we think it's
           something that makes -- based on a feasibility study, it makes sense to do.
                       DR. POWERS:  And I think what I'm telling you is that's not
           the right way to go at this.
                       MR. CUNNINGHAM:  Okay, and that's fair.
                       DR. POWERS:  The way to go is to say, "Look.  We want to
           include chemical reaction, heat, into these calculations.  When you do it,
           recognize the following things," and don't call out parabolic kinetics.  Any
           kinetics you want to that you can justify, but recognize that the surface is not
           going to be flat.  It's not even going to have constant radius curvature anymore,
           and address these questions.
                       There's the technical feasibility to do this.  The French have
           done some very nice things looking at the stability of the oxide coating as a
           function of the oxide thickness and deformations of the surface.  So you're not
           asking people to invent new technologies here.
                       MR. CUNNINGHAM:  Okay.  That's fair.  thank you.
                       DR. WALLIS:  When you get down the road a bit, you've got
           to think about how you actually administer.  Probably the NRR folks are going
           to decide when they've got an application and somebody comes in with some
           new way of trying to show that the core remains cooled; without using the old
           criteria, how someone is going to decide whether this is an acceptable
                       You've got to think it through all the way to how is the person
           who's actually got to make the decision going to be helped by the new rule.  If
           it's not specific enough, it's going to be difficult.  Everything is going to be
           debatable to the nth degree.
                       MS. DROUIN:  If I'm understanding -- maybe I'm still a little bit
           confused by Dr. Powers' statement -- but is your objection that we're taking
           specific criteria in Appendix K and replacing it with other specific criteria, or that
           we should take what's specific and replace it with more performance?
                       So if I look at the example here, the Baker-Just, don't take the
           Baker-Just and replace it with something else prescriptive --
                       DR. POWERS:  Replace it with what you're trying to achieve,
                       MS. DROUIN:  But take the Baker-Just, for example, and
           replace it more with a performance criteria.
                       DR. POWERS:  Well, tell the people what you --
                       MS. DROUIN:  Not prescribe another -- another --
                       DR. POWERS:  What you want to achieve is you want to take
           into account, for instance, in connection with your Cathcart-Pawel, as I
           understand now that's strictly a heat generation.  You want them to calculate for
           chemical reaction heat generation.  Okay.  That's a reasonable thing to do. 
           There's a lot of heat here.
                       Okay.  As soon as you say use this this kinetic expression,
           you're taking a whole set of physics and you're saying this is not important. 
           You're saying that it's parabolic at the beginning.  It's parabolic at the end. 
           Nothing ever happens.  Nothing ever spoils, no new information, no radiation
           effects on this oxidation process that are important to the calculation of heat.
                       That may or may not be true for every kind of clad that you get
           in.  So you're far better off to say -- to give them something that says what your
           objective is and let them figure out how they're going to do it, and put in your
           reg. guide all of the things that you're going to take into account.
                       DR. WALLIS:  Even so, you still haven't got to a performance
           criterion.  I mean, the real performance criterion has to do with the integrity of
           the clad and the nonrelease of fission products and all of that, which is affected
                       DR. SHACK:  But this is an evaluation part here.
                       DR. WALLIS:  -- which is affected by temperature and the
           temperature is affected by anything that raises or lowers the temperature,
           including chemical reactions and so on.  So the chemical reactions are a means
           to an end.  They're not a performance based criteria.
                       It's just that in order to properly achieve that performance, you
           have to consider all of the things that affect it.
                       MS. DROUIN:  Absolutely.
                       DR. WALLIS:  So you think about briefly what are the
           performance goals and how you define them clearly, and you've got to consider
           all of the physics and chemistry and everything else that goes into evaluating
           that performance.  That's what you need to do.
                       MS. DROUIN:  I guess, you know, just to reiterate what Mark
           said, you know, we're just in the feasibility, and I will admit that in terms of the
           evaluation model and prescriptive requirements in Appendix K associated with
           it, we had not looked at that in terms of taking those, as you can see, very
           prescriptive requirements and replacing them like we did on the acceptance
           criteria with more performance based.  That's not something we had thought
                       I think, you know, it is a good comment and something we
           should pursue and look at in more detail.  It's just a very good comment.  We
           just hadn't gone down that road.
                       So why don't we get over to --
                       MR. KURITZKY:  I guess since you flipped on the second
           side, this is just basically the changes that we had looked at as far as Appendix
           K.  We discussed them on Monday.  We would certainly take into account the
           comments today about looking at something more, specifying a performance
           goal or working along a performance goal as opposed to just replacing one
           prescriptive criterion with another one, and that can be looked at under our
           Phase 2 work.
                       And again, just to reiterate, the last bullet there which goes to
           the issue that was actually discussed a little bit already this morning, but that
           when we go about --
                       DR. WALLIS:  Now, those performance items -- excuse me --
           those performance goals, if you really wanted to be risk informed, should be risk
           informed in some way.
                       MR. KURITZKY:  Right.
                       DR. WALLIS:  Use the risk information to determine the goals,
           and then you say you've got to use whatever physics, chemistry, and so on is
           justifiable to achieve those goals.  Isn't that where the risk informed comes in?
                       MR. KURITZKY:  Yes.
                       DR. WALLIS:  That doesn't come in at the level of Cathcart-
                       MR. KURITZKY:  These were not supposed to be risk
           informed changes, but you're right.  To do that risk --
                       DR. WALLIS:  Yeah, but how do you know what your
           performance goals are until you actually look at the consequences of the
           accident and do some evaluation of risk?  Isn't that where the risk informed
           comes in?
                       Otherwise you're just picking something.
                       MR. CUNNINGHAM:  Yeah, this is Mark Cunningham.
                       I think we agree, Dr. Wallis, that in effect what we're saying
           is we can make these changes and have confidence from a risk assessment
           standpoint that we're not changing the risk to the public by making these
                       So it comes in as a metric at that level as opposed to saying
           whether or not it's Cathcart-Pawel versus Baker-Just.
                       DR. WALLIS:  But I think you don't know.  You see, you're
           asking for some requirement on cladding ductility.  Unless you make the link
           between cladding ductility and public safety, you don't know what sort of
           cladding ductility to require.
                       MR. CUNNINGHAM:  But I think we have some confidence
           at the end where you could make these changes and know that it's not going
           to change your risk assessment results.
                       DR. WALLIS:  Well, that's a kind of litany though.  You've got
           to make the analysis to show that's the case.
                       MR. CUNNINGHAM:  Yeah, yeah.  But that's the underlying
           presumption here, and I think we can justify that.
                       DR. WALLIS:  I think we're trying to be helpful.  We seem to
           be slowing down your enthusiasm, but we don't want to do that.
                       MS. DROUIN:  No, no.
                       DR. WALLIS:  I don't want to do that.
                       MS. DROUIN:  It's not that.  You've just raised a good point
           we hadn't thought about, and you caught us off guard.
                       DR. WALLIS:  I'm a little bit disturbed because on Monday you
           seemed to be so full of enthusiasm, and we seem to have slowed you down. 
           I don't want to do that.
                       MS. DROUIN:  I don't think that's occurred.
                       DR. WALLIS:  Okay, good. 
                       MR. KURITZKY:  You've just given us more things to look at
           under our Phase 2.
                       MS. DROUIN:  Shall we go to B?
                       MR. LEITCH:  Just before you move to B, in your discussion
           of A, I see a lot of discussion about acceptance criteria and evaluation model,
           but I thought that A was also going to address ECCS reliability.
                       MS. DROUIN:  No, that's B.
                       MR. LEITCH:  That's B?
                       MS. DROUIN:  That's B.  So why don't we go ahead and get
           to B?
                       MR. LEITCH:  Okay.
                       MS. DROUIN:  A was the changes to the current 50.46, and
           that was just strictly changes to the acceptance criteria, and the evaluation
                       MR. LEITCH:  Okay.
                       MS. DROUIN:  Changes to the ECCS reliability, which Alan
           will get into, that is developing risk informed.  Now we're really starting to bring
           in risk information.
                       MR. KURITZKY:  In fact, it's so different than the last one that
           we actually call it 50.466 so that there's no confusion with 46.
                       MR. KURITZKY:  The B changes, the risk informed changes
           that we're looking at apply to the ECCS reliability requirements.  If you
           remember the figure that Mary put up in the beginning, we subdivide the
           requirement into four categories, and the one that we're looking specifically at
           risk informed are those that deal with the reliability of the ECCS system, and we
           wanted to make those reliability requirements commensurate with the frequency
           of challenge to the system.
                       And we have come up with two options to accommodate --
                       DR. POWERS:  Why do you choose frequency of the
           challenge to the system and not the consequences of system not being
                       MR. KURITZKY:  Well, I guess you would probably get -- you
           see, actually the two options that we have, what we're going to come up with
           there is going to be based on a metric -- in our case, we're currently using core
           damage frequency, but you are looking at the consequence of what happens
           with system failure.
                       It's just that in looking at -- I think it was like an equation that
           we had things multiplied by each other, and so you want to make A times B
           equal something.  You know, you're going to want to make them consistent.
                       If A is much lower, you can let B be higher, you know, and
           vice versa.  So that's what we mean when we say commensurate with the
           frequency of challenge.  If you multiply them together, you get the consequence,
           but in looking at what we're going to allow, where we can allow flexibility, you
           know, if you have two variables, if one goes higher, if you fix the one point, then
           you can let A get higher and B gets lower, et cetera.
                       DR. POWERS:  That's too abstract for my brain this morning.
                       MR. KURITZKY:  All right.  Well, let me go through --
                       DR. POWERS:  It seems to me that an accident that results
           in lots of consequences, even if it has a fuller frequency than one that results
           in zip consequences is what am I going to focus on.  So I would look at
           consequences and not on frequencies.
                       MR. KURITZKY:  Let me see if I understand your question. 
           Instead of focusing on, let's say, core damage frequencies are metric, you're
           saying we should actually look at release.
                       DR. POWERS:  Sure.
                       MR. KURITZKY:  That's something that could be considered. 
           In fact, we had to make a determination at least according to how we feel we're
           going to approach it, whether we're going to try to tie it to core damage
           frequency; if it would just be on the frequency of the accident or LERF, which
           would be on the frequency of obviously release from, you know, containment,
           or you could go all the way as you suggest, Dr. Powers, and look at essentially
           a Level 3 and have numbers.
                       But I think the reason -- and Mary or Mark will correct me if I'm
           wrong -- but I think the reason why we kind of were thinking of sticking with core
           damage frequency as I mentioned was just because that was one that had the
           best understanding and had the best, you know, peer raised (phonetic) in
           existence, the level on peer raised, and there are a lot more, and there's a little
           more accomplished, and the results from the Level 1 that we have and some of
           the Level 2 and Level 3 peer raised.  So it was kind of a --
                       DR. POWERS:  You've done a lot in looking at some of these
           consequences.  So you have information that could use at least in your design
           of the regulation studies.
                       MR. KURITZKY:  Yes, there is information there, and it's
           something that we can consider whether or not we should make the metric CDF
           LERF or actual release.
                       MS. DROUIN:  You would not do this in absence without
           considering your consequences.  The primary measure that we are thinking
           about is CDF, but that wouldn't mean that we would not give any consideration. 
           That violates the basic premise of our framework where we said you will be
           balanced between your prevention and mitigation.  So --
                       DR. KRESS:  The problem with the framework partially, Mary,
           is that the column on conditional containment failure probability has .1 in it, as
           best I remember.
                       MS. DROUIN:  At the lower level.  There's levels to the
                       DR. KRESS:  Yeah, but we're writing a set of voluntary rules
           for existing plants, and not all of those plants have .1 conditional containment
           failure probability.
                       MS. DROUIN:  That's correct.
                       DR. KRESS:  In fact, some of them have .5, and I'm not sure
           how -- if one of those plants wants to voluntarily use this new rule, do they have
           to improve their containment down to .1 or are they just excluded from being
           able to make use of this rule?
                       MS. DROUIN:  No, that wouldn't be the case.
                       DR. KRESS:  Well, how --
                       MS. DROUIN:  Because that's where you could back up to
           your CDF.
                       DR. KRESS:  So you are saying focus on maybe a LERF, and
           they could back down on their CDF.
                       MS. DROUIN:  Yes.
                       DR. KRESS:  But then your guidelines and your framework
           document are not hard and fixed.  You're saying that they could -- as long as --
                       MS. DROUIN:  The primary guideline of the quantitative
           guidelines and the framework starts with a LERF.
                       DR. KRESS:  See, what I'm getting at is what George brought
           up in the subcommittee meeting, that why not just say in words that the LERF
           will not exceed a certain level, and you must also have a CDF that doesn't
           exceed a certain level.  Why not word it like that rather than put those numbers
           in the framework boxes that you have?
                       MS. DROUIN:  I guess I don't see the difference.  To me the
           framework, in essence, does say that because it starts out with the LERF and
           then the next consideration that we have there is the CDF.
                       DR. KRESS:  But I don't think it gives much guidance for
           those plants that have a conditional containment failure probability that's .5 or
           .8.  I mean, what do those people do?  I don't think it gives any guidance there
           and doesn't seem to say, "All right.  If you've got" -- 
                       MS. DROUIN:  But let's remember the framework is not for the
           licensees.  The framework is for us in formulating the regulation and how we
           want to do it.  This is an internal document.
                       The framework is not something that licensees have to meet. 
           That is, those are guidelines for us.
                       DR. KRESS:  But you're going to use it to write the rule, and
           they'll have to meet the rule now.
                       MS. DROUIN:  Yes.
                       DR. KRESS:  So there's a nexus between them.
                       MR. CUNNINGHAM:  This is Mark Cunningham.
                       If you look at Item 2 here, ECCS functional reliability
           requirement, we talk about it in terms of a CDF, but in effect, it's a CDF and a
           LERF that would have to come into play here, and a plant that has a high
           conditional containment failure probability, given core damage, is not going to
           get as much benefit out -- wouldn't get as much benefit out of Item 2 than a
           plant that would have a very low conditional containment failure probability
           because they'd be constrained more by LERF than by CDF.
                       MS. DROUIN:  Right.
                       MR. CUNNINGHAM:  And that's going to have to come into
           play as we develop the details associated with one and two there.
                       MS. DROUIN:  Correct.
                       MR. KURITZKY:  In fact, this original option had LERF in there
           instead of CDF, which we changed later, and so Mark's point that LERF is some
           aspect to be considered also.
                       DR. WALLIS:  We talked on Monday about what you mean
           by reliability.  It seems to me there are two areas here.  One is that you've got
           an ECCS system.  The requirements like the 2,200 degrees are really based on
           the idea that you've designed the system so that there's no core damage
           frequency if it works.  And then you can talk about reliability.
                       Do you have one train or two trains and all of that?  That's in
           the PRA space, but there are almost two worlds, and I don't quite know how to
           bring risk information into the first world, about how to define the criteria for
           whether it works or not, the 2,200, the technical criteria for it's supposed to work
           if all of these things happen.
                       You, I think, claim that reliability covered both the question of
           whether there's one train or another, and also there's the technical questions. 
           If it works as designed, then there will be no core damage.  Is that also in the
           area of reliability or is that something else?
                       MR. KURITZKY:  Like I said on Monday, when I think of
           something as being reliable, it only has to, you know, turn on or run, but it also
           has to meet the safety --
                       DR. WALLIS:  Yeah, but if you think deeper than the 2,200,
           well, what's the reliability or the rationale that we went through in our thermal
           hydraulic analysis to pick 2,200?  You know, that's also reliability in a sense.
                       MR. KURITZKY:  I guess the 2,200 was more a safety margin
           type of thing, but again, the point being when we talk about being reliable, those
           performance calculations have to show that what one pump or two pumps or X
           pumps, you're going to be able to keep your --
                       DR. WALLIS:  That's PRS/PRA space and you aren't allowed
           to do that.
                       MR. KURITZKY:  Well, I was trying to show you that it's below
           2,200.  Then the PRA space says, okay, given that that calculation showed I
           needed one or two or three pumps, now how reliable -- or I need some set of
           pumps -- how reliable do I have to make that set of pumps be?
                       DR. WALLIS:  Yeah, but then there's model uncertainty that
           we talked about, and we don't know how to put that into the PRA space.
                       MR. KURITZKY:  Right, and it kind of almost has to be
           addressed in the hydraulic space.  But I guess, again, I don't want to dive into
           a whole discourse on uncertainty.  I'm not expert on that.  Everybody here
           knows a lot more about it than I do, but it does have to model uncertainty.  You
           know, data uncertainty, I think we have a fairly good way of handling.  Model
           uncertainties are obviously a trickier beast to deal with, but it's obviously
           something that has to be considered.
                       I mean, that's true, and that's going to be part of our brain
           scratching for that second phase.
                       DR. WALLIS:  That's what we talked about under A, I think.
                       MS. DROUIN:  Right.  I mean, when you get into your model
           uncertainty, that's where you're getting into your acceptance criteria and your
           evaluation, and that would be taking care of that part.  You have designed that
           ECCS system, and that's where you're also getting into, as Alan said, the
           thermal hydraulics.
                       Whether or not you're going to be providing enough coolant
           and the uncertainties of that would be taken care of under your acceptance
           criteria and the performance you have to meet.
                       DR. WALLIS:  Well, then you have to bring some sort of risk
           criteria into the performance criteria, and we discussed how difficult that might
                       MS. DROUIN:  Yeah.  I don't mean to allude that it's going to
           be easy.
                       MR. KURITZKY:  Yeah, I think Dr. Wallis' point is well taken. 
           That is, that's just one of the areas that we have to -- that interconnection or
           connection, whatever you want to call it, you know, that passover, that's
           something that has to really be thought out to make that seamless connection.
                       DR. KRESS:  Does that bullet under two imply that you may
           have different CDF thresholds for different plants?
                       MR. KURITZKY:  No, actually that is supposed to -- that the
           NRC would prescribe a CDF threshold, and then --
                       DR. KRESS:  For all plants?
                       MR. KURITZKY:  -- has to be required to meet that.
                       They could use plant specific information on LOCA
           frequencies or ECS reliability to --
                       DR. KRESS:   To arrive at it.
                       MR. KURITZKY:  -- to arrive at it.
                       DR. KRESS:  But the threshold itself will be --
                       MR. KURITZKY:  Right.  It is one across the board, and
           essentially it's going to be -- you know, it's only specified in a reg. guide or
           whatever for the licensees to use in Option 2.  Under Option 1 the NRC is going
           to give prescriptive requirements.  We're still going to be using that same --
           whatever we arrive at,  that same threshold will be used in our thinking  to come
           up with what we're going to prescribe.
                       And again, as Mary said in the beginning, you know, right now
           we've done Phase I work, the feasibility study.  There's a lot more technical
           work to be done under Phase 2, which would be to support the rulemaking.
                       Specifically for the risk informed, the voluntary risk informed
           alternative, there's a number of things up there.  We've been discussing a lot of
           them in the list.  I don't know if the list is necessarily growing, but we have some
           more ideas under these bullets that we have to consider that we're going to put
           emphasis on.
                       But coming up with acceptable methods and assumptions for
           performing these CDF or LERF analyses or system reliability analyses and also
           coming up with the appropriate thresholds, making -- you know, giving due
           consideration of uncertainties and both coming up with the thresholds and how
           the calculations are done to meet those thresholds, something Mary's staff has
           put a lot of work into.
                       Also we have to identify features or conditions at the plant that
           would tend to decrease the conditional probability of losing off-site power, given
           a LOCA, and determine acceptable methods and assumptions for estimating on
           a plant specific basis what that probability would be.
                       And I think that third bullet really goes to the first option on the
           previous slide, which is the prescriptive one, where we would say, yes, you
           don't need to consider loss of off-site power for this set of LOCAs if your plant
           has this feature or that feature, for instance, the ability of the plant to
           communicate with their transmission system operator, which would tend to
           decrease the probability of loss of off-site power after a LOCA.
                       So there would be a certain feature that maybe a plant would
           have to meet in order to be able to qualify, to not consider the fountain pen as
           loop (phonetic).
                       In the second case, the fourth bullet really applies to the
           second option from the previous slide where the plant would be doing plant
           specific calculations, and licensee would be doing plant specific calculations,
           and so therefore, they would need to consider in their analysis of the reliability
           of the ECCS -- they'd have to consider the probability of losing off-site power
           after the LOCA.  And so they'd have to do some kind of plant specific calculation
           in that regard.
                       That's what's going to keep us busy through April 2002.
                       MS. DROUIN:  July.
                       MR. KURITZKY:  July.  No, this is the April one.  This is the
           April one.
                       DR. WALLIS:  I'm still sort of thinking.  Suppose that you in
           the prescriptive world were to say or were to consider the possibility of raising
           its reliable temperature to 2,300 from 2,200.  Could you calculate the change
           in CDF resulting from that?
                       MR. KURITZKY:  If there would be a change in that peak clad
                       DR. WALLIS:  Right.  Is there a mechanism?  Does PRA
           enable you to bring in that sort of information and calculate a change in CDF?
                       Undoubtedly there is a change in CEDF if you do that.
                       MS. DROUIN:  Yes, it does.  That's for your success criteria.
                       DR. WALLIS:  It does enable you to do that?
                       MS. DROUIN:  Yes, because that goes to your definition of
           your core damage.
                       DR. WALLIS:  So you assume that if you get over 2,300 you
           get core damage?  That's the definition of core damage?
                       MS. DROUIN:  Well, I mean, when you go to the PRAs, you
           know, the definition of core damage will change.  I mean, for example,
           somebody might define it as top of the active fuel uncovered, the bottom of the
           active fuel.  Some people define it as the peak cladding temperature, but my
           point is that that gives directly to the definition, and as you change the definition,
           then you change your success criteria.
                       DR. WALLIS:  So you can change the CDF by changing your
           definition of core damage?
                       MS. DROUIN:  Absolutely.
                       DR. WALLIS:  Just by words?
                       MR. KURITZKY:  Well, not --
                       MS. DROUIN:  It's not by words.  I mean, then you have to go
           and you do your calculations to see which systems.   If, for example, I look at
           a boiler, and if I define my core damage as top of active fuel versus a little bit of
           uncover versus GP above the bottom of the active fuel versus my peak cladding
           temperature --
                       DR. WALLIS:  How do you make those choices?
                       MS. DROUIN:  You do a lot of calculations to see, you know,
           where you're going to start getting your releases.
                       DR. WALLIS:  Oh, so you get back to releases, yes.
                       MS. DROUIN:  You always go back to releases.
                       DR. WALLIS:  Thank you.  Good, good.
                       MS. DROUIN:  But you will get different systems available.
                       MR. KURITZKY:  Or the number of trains required.
                       MR. LEITCH:  The third bullet there concerning loss of off-site
           power following a LOCA, you used as an example there the ability of the plant
           to communicate with the system operator.  I'm just having trouble figuring out
           how --
                       MR. KURITZKY:  That would help?
                       MR. LEITCH:  Well, first of all, who wouldn't have the ability
           to do that?  And how would it help?
                       In other words, what I'm picturing is some kind of a seismic
           event that causes a LOCA and brings down the transmission line
           simultaneously.  So how does talking to the system operator help that?
                       Maybe I'm not following exactly what your thought is there.
                       MR. KURITZKY:  Well, I think you bring up a couple of good
           points.  The issue of the seismic event that would bring down the grid at the
           same time that it, you know, tripped the large break LOCA is definitely in that
           case talking and isn't really doing you any good.  I mean that's got its own
           problems, and that's one piece that goes into the calculation.
                       That would be a case where the conditional loss of power is
           one for that event.  I mean, there's nothing you can do about that.
                       However, in other types of situations -- and I'm not the
           electrical engineering expert, and I don't see the gentleman that we've been
           working with on that -- but the idea being that if you have -- in a lot of cases you
           have the grid tends to -- the area grid will have bolted sags and may have a
           degrade of voltage there, which would increase your chance of causing a
           separation to grid when you have the plant trip and the ECCS pump start.
                       Communication with the transmission system operator would
           allow you in certain situations, I think, to allow the operator to readjust the flow
           of current in the grid to may be beef up, you know, voltage to the plant so that
           you're not as susceptible to having that going to the trip point, going to the
           under voltage relay set points trying to separate you from the grid.
                       So you're getting the area grid managed where the
           transmission system operator in communication with you, you know, in sync
           with you to help you ride out, you know, that electrical transient, can help reduce
           your transient having a separation from the grid.
                       And my understanding is that far from all plants actually, you
           know, have procedures in place to routinely, you know, contact the transmission
           system operator under such conditions.  Some plants do, but some plants don't.
                       MR. LEITCH:  I would just think they all would.  I'm surprised
           at that.
                       MR. KURITZKY:  I guess, they all have the capability
           obviously.  I guess it's more of whether it's proceduralized, I guess, is maybe
           the issue.
                       MR. LEITCH:  Yeah.
                       MR. ROSEN:  There are INPO requirements that have been
           in place for several years to have good communications with the grid operators,
           and I think I would be very surprised of any plant has not already complied.
                       MR. KURITZKY:  Then that would help for all plants to take
           advantage of if that's the case.
                       DR. SHACK:  But, again, just coming back to that, I mean, you
           would work out a sort of statistical analysis of the likelihood of loss of off-site
           power, and then you'd modify that in some way by features.  Is that the kind of
           thing that's envisioned?
                       MR. KURITZKY:  Yes, that' the type of thing we're looking at. 
           We'll build out some of the work that was done for generic Issue 171 and try to
           identify, and some of the work that has been done since then and try to see if
           we can identify features that can have some measurable impact on that
           conditional loss of off-site power probability.
                       MR. LEITCH:  Coming into that, again, is this issue that we
           always have a lot of trouble with, and that is assessing how well the operator
           would perform under those circumstances.  In other words, he's just has a
           LOCA.  Although he has procedures to contact the system operator, you know,
           is he going to do the right thing?  Is he going to --
                       MR. KURITZKY:  And that's the error of probability, right.
                       DR. BONACA:  And I had the same thought, but my
           understanding will be that from more credible break sizes you would still
           preserve LOOP and single failure requirements.
                       MR. KURITZKY:  Yes.
                       DR. BONACA:  You would relax those for break sizes which
           right now seem to be so unlikely, like the double ended guillotine break.  You
           don't have the basis to eliminate that from the rule right now, but you have the
           basis for utilizing that inside till it lacks something like the LOOP or -- okay.  So
           that's the context of that.
                       MS. DROUIN:  What you've heard to date is the proposed
           considerations for the short term, and now looking at what we're considering for
           long term, our long-term effort.
                       MR. KURITZKY:  Okay.  That goes to the fourth box.  That
           was in the figure Mary put up before, the definition of large break LOCA sizes. 
           Additional changes to 50.46 may also have some merit, including possibly
           change in the definition to inspection of breaks and locations.
                       The extent of the potential changes to 50.46 is dependent on
           our state of knowledge of LOCA frequencies as we discussed before, and
           here's an example of how we might use that information.
                       If we could feel confidence, considering uncertainties, that we
           have a collecting infrequency of occurrence below let's say ten to the minus four
           a year for a set of LOCAs, then we may believe that some regulatory relief is
           appropriate for those, that set of LOCAs, which is pretty much what we're doing
           right now with the changes we discussed under Item B.
                       If, for instance, we could also or in addition we could feel
           confident that the LOCAs were at frequencies below ten to the minus five, we
           may feel that we could go even further and possibly remove these from the
           design base, but as long as there was maintained some plant mitigated
           capability to address those accidents.
                       And further, if we could feel confident that we could -- that
           there was a set of LOCAs whose collective frequencies were below ten to the
           minus six per year, we may say that's so low we can take them out of the
           design basis completely and they don't have to be addressed at all.
                       So that's kind of how as we improve our state of knowledge
           of LOCA frequencies we could, you know, further change what would be the
           regulatory requirements associated with those set of LOCAs.
                       DR. POWERS:  You'll never get somebody to come in and
           say probability of LOCA is definitely absolutely less than ten to the minus fifth
           per year.  I just know how people are.  They'll say, "Well, I'm not too certain
           about this, but it's the mean value maybe is less than ten to the minus fifth," or
           some confidence level or something.
                       What kind of confidence level are you looking for?
                       MR. KURITZKY:  Okay.  That will have to be decided as we
           go through.  This is long-term work, and so that's something that will have to be
           considered, but you're right.  You consider uncertainty analysis.  You have to
           consider, you know, would it be something that we want the 95th percentile to
           be below that level?  Would it be the mean?  You know, do we feel the mean
           would be sufficient?
                       If you used the mean, you would probably want to have a
           more -- maybe a little more strict on what the professional guy would be.  If you
           used the 95th percentile, then you may be a little more or less concerned
           exactly what that threshold is.
                       But all of that has to be figured out as part of that as long
                       DR. POWERS:  Yeah, I guess I'm wondering how you do that. 
           I mean, you said if you use the mean you'd be a little more restricted.  You're
           doing something when you say that, doing some mental integration there.  Can
           you tell me what that mental integration is?
                       MR. KURITZKY:  Well, again, I guess you're tying it to release
           or, you know, core damage frequency or LERF or actual fission product release,
           but you're going to have some metric that you're going to run up against, and
           then you're going to back out, you know, frequency that you're going to --
                       MS. DROUIN:  We're in the very early stages here on this. 
           I mean, we know we're going to have to deal with the uncertainties.  That's a
           given.  How we're going to incorporate that into this, it's a blank sheet of paper
           almost at this point.  We just know it's an issue we've got to address, and when
           you look at the time frame that we talked about where this is up to three years,
           this is one of the factors that comes in there because it's not a trivial issue.
                       So there's a lot of work that's going to have to be done here,
           particularly when it comes to the uncertainties.
                       DR. WALLIS:  Well, thinking about long term, there's a certain
           CDF allowed by the present rule due to LOCAs and LOCAs contribute a certain
           amount to CDF, right?  We know that.  We know that LOCAs contribute.
                       It may be plant specific, but you can evaluate the contribution
           of LOCAs to CDF now, and presumably that's tolerable because we license
                       Now, we talked on Monday about optimizing the ECCS
           system.  Why don't you in the long term think about allowing the licensee to
           simply optimize the ECCS system in any way, response to break sizes,
           reliability of this?  I mean whatever it is as long as some CDF value criterion is
           met.  Then it's up to the licensee.  I mean, you don't specify all of this stuff.  You
           simply say, "Evaluate all of your LOCAs, and the total CDF contribution is not
           to be more than a certain amount."
                       MR. KURITZKY:  I mean that's --
                       DR. WALLIS:  Isn't that really risk informing the whole thing
           in the long term?
                       DR. BONACA:  Well, I must comment that people can be very
           creative in telling you that single failures can happen, and yet you know, TMI
           had many failures happening, you know.  They happen, I mean, and I agree that
           as a general principle I think -- but you've got to be very careful.
                       DR. WALLIS:  This is long term.
                       DR. BONACA:  Yeah.
                       MR. KURITZKY:  The risk-informed in that respect --
                       DR. WALLIS:  Well, that's a little bit of a --
                       MR. KURITZKY:  We don't want to put all of our eggs in the
           CDF basket.
                       DR. WALLIS:  You can always quibble about it.  Whenever
           you want to do something really logical say, "Oh, don't do that because it's risk
           based," you know.
                       DR. BONACA:  With this, you know, I had a question
           regarding it a little bit.  Are we going to have at some point in the future a menu
           driven LOCA requirement such that this plant will have this criterion and this
           plant will have relaxed large break LOCA based on -- you know, simply that
           won't relax it, but simply that it assumes still double ended guillotine break, but
           only one train above a certain size break, and others will come in and in the
           future use -- I'm trying to understand what's going to be.  I mean, you know,
           these plants are so different from each other already.  I mean one of the issues
           have always been lack of standardization.
                       Are we going to have a future where we're going to even less
                       MR. KURITZKY:  Well, I think if you just even look at the
           changes under B, that first option with the NRC would specify.  Everybody
           would either pick that or something else.
                       But the second option under B, even there plants would -- you
           know, that's the change we're considering if it should go to implementation.  You
           would have plants that could -- if they wanted to go through the analysis, they
           could demonstrate that they could adjust their --
                       DR. BONACA:  Okay.
                       MR. KURITZKY:  -- that different plants would, in fact, have
           different requirements for LOCA.  I mean, you're right.  It flies against
           standardization, but it allows for more use of risk information.
                       DR. BONACA:  Okay.  Plant specific relaxation, yeah, right.
                       MR. KURITZKY:  Okay.  Again, as part of this long-term work,
           one of the main things that we're really trying to strive at is to improve our state
           of knowledge of LOCA frequencies.  In that vein, the staff is continuing to meet
           with representatives of the nuclear industry in public meetings to try and
           address a set of technical issues.
                       For example, the initial fall distributions, degradation
           mechanisms, uncertainty analysis, et cetera, that would go into those
           calculations of LOCA frequencies.  As has been --
                       DR. POWERS:  That seems to address the regulatory guide
           aspects of this.  Those meetings don't seem to address, discussing earlier, your
           ten to the minus four, ten to the minus fifth business.
                       MR. KURITZKY:  Yes.  I was just going to point out that the
           next set of means that we have set up with the industry are to address this
           particular topic, but in order to actually carry through these changes to their
           implementation, there are many issues as were discussed here at these
           meetings today as well as other issues that would all have to be considered.
                       We currently have plans to meet with industry because this
           is one hurdle that has to be dealt with to move forward, but it is certainly not the
           only hurdle that has to be jumped over.
                       DR. POWERS:  This seems to address the question of
           whether LOCAs occur at all.
                       MR. KURITZKY:  Well, or whatever frequency they occur at.
                       DR. POWERS:  Maybe it addresses what happens when you
           see that they reflect knowledgeables (phonetic) and things like that.
                       MR. KURITZKY:  In other words, all of those issues need to
           be -- that all falls into those metallurgical concerns.
                       And just to sum up, if something -- if large break LOCA
           redefinition, the size redefinition is found to be feasible, the staff would
           recommend, you know, additional changes potentially involving additional
           rulemaking to change the wording in Part 50 to allow the licensees to select an
           alternate pipe size as their pipe size for the design basis subject to some level
           of NRC approval.  So that's a potential carrot out there if this can be done.
                       MS. DROUIN:  So far what we've covered is what our plans
           are in both the short term, what we're considering in both the short term and the
           long term for 50.46.  In terms of just the global look at Option 3 activities and
           some things that are on the plate, we had talked about, you know, the ECCS
           reliability.  That gives directly to GDC 35 that talks about the single failure
                       Right now what is proposed in the short term is just fixing that
           as it pertains to the ECCS, but as you look at Appendix A, there are a lot of
           other GDCs that also address the single failure criterion.
                       So one of the things that we are considering that do think that
           it is a generic change to the single failure criterion to take it beyond just as it
           applies to ECCS.
                       Another Option 3 activity also that we had started was looking
           at the special treatment, at the technical requirements of the special treatment. 
           Now, when we mentioned this, we mentioned this in terms of Option 3.  Option
           2 is moving forward, and that is looking at the scope of your components, your
           structure systems and components that are under the special treatment.
                       But if you look at the actual requirement, for example, your
           QA requirements, are those the correct requirements when you start bringing
           in risk information?
                       So changing the actual technical requirements is an Option
           3, but in both of these in terms of looking generically at the single failure
           criterion, looking at the special treatment, both of those efforts for right now
           have been deferred because we want to take our resources and focus them in
           getting 50.44 and 50.46 through the system first.
                       So for the next couple of years, that's where our focus is
           going to be.
                       DR. POWERS:  If I change the reliability of the ECCS systems
           and risk assessment, is the CDF linearally related to that change?
                       MS. DROUIN:  It is certainly related.  Is it linear related?
                       MR. KURITZKY:  Yeah, I would be hard pressed -- that one
           I'm trying every --
                       MS. DROUIN:  I would be hard pressed to say that.
                       MR. KURITZKY:  -- every core damage sequence in the PRA
           has ECCS failure in it, and there could be things at risk that may be not --
                       DR. POWERS:  I don't think so.  They would just treat those --
           all those other things would be constant contribution maybe, nd so all you'd do
           is just increase the contribution due to LOCAs.
                       DR. SHACK:  But you have a reliability that depends on the
           frequency, right?  Doesn't that make it non-linear?  They're proposing that the
           reliability essentially be a function of frequency.
                       DR. POWERS:  Maybe that's what they are proposing.  I was
           asking a simpler question.  What's the situation now?
                       MS. DROUIN:  I would not say that it's a linear relationship
                       MR. KURITZKY:  Because, first of all, the reliability of the ECS
           now is different.  I mean it's different for a small break LOCA versus a large
           break LOCA.  You have different success criteria.  So you already have some
           disconnect there that, you know, wouldn't tend to lend itself to being linear.
                       So, yeah, I would have to tend to -- without having actually
           looked at it, you know, I would guess that it probably wouldn't be unless you
           somehow couch your definition to account for the differences in success criteria
           for different cases.
                       DR. SHACK:  Just coming back to a slightly different question,
           you know, we always make the assessment of the risk impact of these things
           based on the existing PRA, and if we change this rule, somebody is going to
           make changes, and that presumably could impact the PRA in ways that you
           don't -- but when you make this rule, somebody is going to have to make a --
           you know, if he wants to change his tech. spec., you will then come back and
           be able to assess all of the risk implications of changing that tech. spec.
                       So you really have a second chance to look at all of the risk
           implications that you're introducing by changing the rules.
                       MR. KURITZKY:  Yeah, I think that's the way to do it because
           you can't a priori identify every single possible change a plant could make and
           come up with what would be the impact to risk because it's different for different
           plants.  So I think you need to have some -- the rule change can be made, but
           then when it goes -- a plant can choose to take advantage of that or a licensee
           can choose to take advantage of that, but when they want to actually make a
           change in their plant, then because of that you need to have some, you know,
           reg. --
                       DR. BONACA:  Oh, so you would require something like that?
                       MR. KURITZKY:  I don't know.  We haven't thought that all of
           the way through, but I mean --
                       DR. SHACK:  But he doesn't have to come back in in 1.174
           space.  He comes back in now in, you know, I'm following the regulations.
                       MS. DROUIN:  That's right.  In 1.174, he doesn't have to meet
           1.174.  He chooses the alternative rule.
                       DR. SHACK:  But you presumably now -- it comes back again
           to this threshold of when you can come back and ask him for risk information.
                       MS. DROUIN:  That would be dependent on how we write this
           and how the reg. guide -- I mean it might not necessarily be --
                       DR. BONACA:  Well, sine it is a plant specific change --
                       MS. DROUIN:  -- that way.
                       DR. BONACA:  -- and since there is plant specific options,
           wouldn't you want to have an analysis like that?
                       MS. DROUIN:  I'm sorry.  I couldn't hear you.
                       DR. BONACA:  It seems -- I mean, this I raised earlier, that
           plant specific changes and they're based on some risk informed consideration. 
           Wouldn't you want to know that?  The point that --
                       MR. KURITZKY:  The total risk  impact at that plant.
                       DR. BONACA:  Yes.
                       DR. SHACK:  I would.  The question is whether the
           regulations --
                       DR. BONACA:  That's right.
                       MR. KURITZKY:  And I think it goes back to it depends on
           how much -- when we look at it ourselves and start to assess what we think the
           changes would be and what would be the risk impact, it depends if we feel
           confident that all other possible changes for the different plants all fall within
           some band, and that band is acceptable, maybe we're not as concerned.  If we
           can't get that comfortable feeling, you know, then I guess the reg. guide or
           whatever would have to be worded in such a way that you'd have some kind of
           way of assessing that.
                       MR. ROSEN:  I think any competent utility PRA practitioner
           group which was intending to take advantage of the provisions of new rule as
           a very first step would run a "what if" calculation through their PRA based on the
           changes that they would make in their modeling and see what the impact is and
           see in which sequences it's important and make a judgment based on that, very
           first level judgment.
                       Do they want to proceed with it?  And that would reveal a lot
           of things to the utility, and I'm sure they'd share them with the staff.
                       MR. KURITZKY:  But the question is if they would be required
           to share with us.  I think that's what Dr. Shack and Dr. Bonaca are getting at.
                       DR. BONACA:  Well, yeah.  The reason I was asking is you
           had on this slide a number of bullets regarding, for example, single failure
           criteria, and I agree that it may be over burdening in some cases.
                       It has served well the industry in other cases.  I mean,
           anybody who lives close to a plant knows there are a lot of valving problems at
           time.  Systems are left out by accidents.  I mean, there are errors taking place
           out there.
                       The fact that you had single failure capabilities oftentimes
           save the day because you have --
                       CHAIRMAN APOSTOLAKIS:  Well, they are not eliminating
                       DR. BONACA:  I understand.  I'm only saying that we are
           asking these questions for that very reason, that you may try to put together a
           rule in place -- let me finish --
                       CHAIRMAN APOSTOLAKIS:  Yeah, sure.
                       MS. DROUIN:  Okay.
                       DR. BONACA:  -- and then -- and then -- okay.
                       MS. DROUIN:  I'm sorry.  I thought you were --
                       DR. BONACA:  I just was trying to complete the statement. 
           I think the message got there.
                       MS. DROUIN:  Thank you.
                       Just to wrap up again, to go over our schedule, again, the
           paper is pre-decisional.  We do hope that it will get up to the Commission within
           the next week.  We are requesting a letter from the ACRS.
                       In looking at our short-term changes that we have proposed,
           development of the proposed rule in the short term, 12 months from the
           issuance of the SRM or two months after the technical work is complete,
           whichever is later.  A very important point there.
                       In terms of performing the technical work, we will not wait for
           the SRM.  We're going to continue proceeding forward.  In terms of modifying
           the current 50.46, we feel we can have that done by July 2002.
                       In terms of looking at the ECCS reliability requirements, which
           is the alternative to 50.46, to have that complete by April of 2002.
                       Looking at the feasibility to complete the feasibility of
           redefining the large break LOCA, we feel that could take up to three years.  A
           lot of issues involved in that one.
                       MR. LEITCH:  It seems to me that a lot of the benefits that
           industry could see from this program may be in the longer term options, and I
           guess I wonder if in the short term options, particularly in the part that you've
           called A, are there any -- do you think there would be sufficient benefit that there
           would be any takers?  In other words, is there a danger that we are spending
           a lot of money here to throw a party and nobody will come?
                       MS. DROUIN:  I can't speak for industry, but we do feel there
           is some benefit there.  Otherwise we would not be pursuing it.
                       MR. KURITZKY:  Yeah, I think to keep the reduction at the K
           level --
                       MR. LEITCH:  I'm talking about for the current generation of
           plants.  I mean --
                       MR. KURITZKY:  Yes.
                       MS. DROUIN:  Yes.
                       MR. KURITZKY:  Under A where we have -- the part on
           acceptance criteria is not meant to provide unnecessary burden reduction.  I
           mean it may, but that's not what is intended.  It's intended to allow other types
           of cladding materials to be used without having to -- 
                       DR. SHACK:  You're also not intending to give them a choice.
                       MR. KURITZKY:  Right.
                       MS. DROUIN:  No, no, no, no, that's not true.  They will be
           allowed to stay with what they have.
                       MR. KURITZKY:  But the decay heat one particularly, our
           understanding is that there could be a fair amount of benefit for some plants
           under that second part of A.
                       DR. SHACK:  Under the second?
                       MR. KURITZKY:  Yeah, the reduction of the decay heat level.
                       DR. SHACK:  That certainly seemed to get some enthusiasm
           on Monday.
                       MR. KURITZKY:  Yeah, particular BWR.  We heard from the
           BWR owners group.
                       MS. DROUIN:  But the answer is, yes, we do think there's
           benefit to be had.  And that concludes our presentation unless there are
           anymore questions.
                       DR. SHACK:  We have a representative of the Westinghouse
           Owners Group if he'd like to make some comments.
                       MR. WARD:  Come up here or --
                       DR. KRESS:  It would be better if you'd come up.
                       MR. WARD:  Good morning.  I'm Lewis Ward.  I'm the
           Chairman of the Westinghouse Owners Group, large break LOCA redefinition
           project.  I work with Southern Nuclear Operating Company with the Vogtle
                       I missed the Monday meeting, but I did get several reports
           from the occurrence from here from the people who were here Monday.  
                       We did meet yesterday and last night with NEI and some
           WOG (phonetic) representatives, and we believe that the priority that we just
           saw is reversed from what we would really like to see.  
                       The large break LOCA redefinition for us has by far the most
           benefit down the road with plant changes and core changes and analysis
           changes that we can get some benefit out of fairly immediately and some of
           them much longer term.
                       So that's what we want to focus on within the Westinghouse
           Owners Group.  I know that the BWR owners are fishing for the loss of off-site
           power option with this, and I don't want to take away from that at all, but within
           the Westinghouse Owners Group, the only thing that I remember are interested
           in and have put a significant amount of money on the table to support is the
           LOCA redefinition.
                       The other two owners groups, B&W and CE, are very
           interested in that, and we've had presentations here with them also.
                       So I think it's safe to say where our money is right now if you
           want to judge from that is on large break LOCA redefinition.
                       There is a meeting in progress right now down at NEI to lay
           out the risk informed task force, you know, what they want to present as a
           strategy, and I'm not there obviously.  So I may be speaking a little bit out of
           turn.  They could come back with some different conclusions, but I kind of doubt
                       Presuming this recommendation goes forward and gets
           Commission approval, our tendency right now is to petition for rulemaking for
           the redefinition, and we have started that effort already.  We have started a draft
           of a rule with statements of considerations, and our time frame would be to
           submit that possibly in about six months.
                       The one technical issue that was presented this morning that
           we do want to focus some more on is the pipe break frequency.  We get some
           indications that there may need to be more rigorous work done to support a
           frequency curve, depending on how you want to use that curve, and I think that
           is pure science.
                       A pipe break curve ought to be good.  If it's a sound curve, it
           ought to be good for however you're going to use it, and so we want to meet
           with the staff, and we're trying to set up a meeting with the staff hopefully early
           next month to go over some of those issues and see if we can get them at least
           on the table so that we can get our technical people, Warren Bamford and the
           other experts in the reactor mechanics group in Westinghouse working on that.
                       They are already addressing the issues that we know of, and
           you know, we plan to put together a paper probably in the form of a WCAP
           (phonetic) that will be part of the technical support behind the petition.
                       Some of the other issues that came up this morning, just very
           briefly --
                       DR. POWERS:  Well, could we pursue just a little bit this
           LOCA redefinition?
                       MR. WARD:  Certainly.
                       DR. POWERS:  I take it what you're coming in -- they had a
           slide there, ten to the minus fourth, ten to the minus fifth, ten to the minus sixth. 
           You're saying that the frequency of these large break LOCAs is small enough
           that we don't need to include them in the design basis.
                       MR. WARD:  Yes.  Yes, sir, and I think we need to come to
           a very, very good consensus, understanding of where the break-off of that curve
                       One of the questions earlier, our pipe sizes are incremental. 
           At least in the Westinghouse fleet, they go from six to eight to ten, up to 14 in
           two inch increments, and then the next largest size is the RCS.  So, you know,
           it's not a continuous spectrum of pipes in there.
                       The calculated frequency of the large LOOP breaking double
           ended guillotine is on the order of ten to the minus ninth or ten to the minus
           11th.  So if you integrate that curve down, which is not a continuous curve, and
           you throw in a 14, the total combined frequency of those is more, ten to the
           minus eight.
                       DR. POWERS:  How do you know these frequencies?
                       MR. WARD:  How do I know that?
                       DR. POWERS:  I mean, I'd like to see this database that gets
           these frequencies.
                       MR. WARD:  And I'm not a mechanics expert at all.  So I --
                       DR. POWERS:  That means there can't be any data at all,
           right?  I mean, if it's ten to the minus 11th, that's a little longer than the age of
           the universe --
                       MR. WARD:  Right.
                       DR. POWERS:  -- by a factor of ten years or by a factor of ten.
                       MR. WARD:  Right.
                       DR. POWERS:  So what makes you think that this is -- I
           mean, this must be the products of calculations.
                       MR. WARD:  Yes, that's right.
                       DR. POWERS:  I mean, is this like F equals MA?  I mean,
           these calculations, there's no question about them?  They're known absolutely?
                       MR. WARD:  There are questions in there, and I think that's
           what needs to be agreed to, that all of the known uncertainties and
           conservatisms --
                       DR. POWERS:  Has there never been in the history of the
           universe a large pipe break?
                       MR. WARD:  Yes, there have been large pipe breaks.
                       DR. POWERS:  Oh, well, so the frequency is ipso facto
                       MR. WARD:  There has never been a large pipe break on the
           type of material in a nuclear reactor of the grade and type and pedigrees that
           are in nuclear reactors.
                       DR. WALLIS:  There have been through wall cracks.
                       MR. WARD:  Yes.  But,  for example, one of the things we're
           wrestling with is not only just the pipe size, but possibly a flow criteria instead
           of a pipe size criteria.  For example, at full pressure, the six inch break is
           equivalent to about 30 to 40,000 GPM flow.  That's a huge crack that would
           produce that amount of flow, and whether it's a severance of a small pipe or a
           smaller split in a weld of a larger pipe, you know, it would encompass all of that.
                       But you know, it may turn out that this curve that we're talking
           about is a flow based curve instead of a pipe size break, but that to me is one
           of the key technical pieces that we really need to get nailed down, and we're
           working with the staff, and we would like to have a meeting fairly soon to at least
           get on the table all of the issues that we need to address.
                       And a fair part of our money is allotted to addressing a
           technical issue in coming up with a common standard.
                       I guess the next piece is how do you use that.  You know, say
           we did get a rule change, and what we're going to propose in the guide is that
           we have or in the statements of considerations is basically to put some bounds
           on how we would like to use the rule and how we would propose that it not be
                       For example, we don't want to degrade containment
           requirements in any form.  We do not want to allow ourselves to even work on
           throwing out imported ECCS equipment, like the charging safety injection or
           RHR pumps or accumulators, but there may be some relaxation in the
           requirements on some of those, in particular accumulators.
                       Some of the other ECCS equipment, particular room coolers
           that are there just peripherally for the long-term operation of the ECCS
           equipment, we may see some relaxation in those, and that's where we get
           some benefit.
                       But what we would like to do in this, what we're going to draft
           is to try to put some bounds on maintaining some mitigation capability, but try
           to put a bound on what is off limits for future changes.
                       So I heard your question earlier about are we going to have
           to come in and ask for a license change on every change or do we have the
           liberty to run off and do anything we want to, and I don't think you're going to let
           us do that, for number one.
                       But I'd like to have some boundaries on what we can do and
           what we cannot do under 50.59.
                       DR. POWERS:  It seems like a lot of things that you've
           mentioned specifically, you've said requirements on accumulators,
           requirements on room coolers, a couple of other things like that, that those can
           be addressed in risk based without getting into arguments over the pipe break
                       MR. WARD:  They can be, but they cannot be done across
           the board.
                       DR. POWERS:  Well, I'd like to just see one of them dealt
           with.  I mean, I'm listening to a performance on risk informing 50.46, and I
           haven't seen a risk number yet.
                       Has anybody tried to do these things, to look at how you can
           adjust success criteria and stuff like that around and see what impact it has on
           CDF or LERF or some more reasonable FC curve?
                       You can react, but it seems like that would be a good context
           to look at these thing because I'll bet you can.
                       MR. WARD:  We probably can.  It requires each example that
           you come up with to go do a detailed analysis to justify that change and then
           justify a change to your design basis, you know, one piece of equipment at a
           time, and that does not at all lead to any uniformity within a unit, for example.
                       We just cut out a cooler, a room cooler, at Vogtle temporarily
           for a cycle.  We based it on deterministic calculations as well as PRA, but in
           order to keep our design basis consistent between two trains and both units,
           we're going to go replace a cooler.  It's minor, $100,000, but if I had this rule
           change, that cooler is really inconsequential and doesn't need to be there, and
           I could go remove all four of them from my design basis and be done with it.
                       DR. POWERS:  Suppose you said you did the risk analysis
           and said, "Okay.  The cooler means nothing."  And I could show that based on
           risk.  Couldn't you do it under 1.174?
                       MR. WARD:  I could justify it.  I would probably -- I may need
           to do a 50.92 license change to get it permanently removed from the design
           basis anyway.
                       CHAIRMAN APOSTOLAKIS:   Bill, when do you think we're
           going to roughly stop?  We're 20 minutes --
                       DR. SHACK:  We're just about finished.
                       MR. WARD:  Yes.
                       CHAIRMAN APOSTOLAKIS:  There's a lot to do this
                       MR. ROSEN:  Could I ask one quick question, George?
                       I'm surprised, Lou, not to hear you express any interest in the
           replacement of the 1971 ANS decay heat curve with a more updated version. 
           That seems like a simple thing.
                       MR. WARD:  There is interest in that.  I believe NEI is
           planning to -- and I can't speak for NEI again -- but I believe they're planning to
           petition for a rule just on that part, to go from 71 to 94 fairly soon, a couple of
                       MR. ROSEN:  So your silence on that matter doesn't imply
           that you're not interested in it.  You're just letting that be handled by NEI.
                       MR. WARD:  Yes.  Now, the LOOP part of it, I've got some
           serious questions about that, but I'm not going to sit up here and try to
           undermine interests for other people, you know, with the issues going on in the
           utility today on the grids and newspaper articles every day on power blackouts
           in California.  The PR end of that bothers me as much as anything, but that will
           have to be addressed, and I guess the staff has got a plan on how to deal with
                       CHAIRMAN APOSTOLAKIS:  Now, you said that you think
           that the staff's approach places priorities the wrong way.
                       MR. WARD:  Yes, sir.
                       CHAIRMAN APOSTOLAKIS:  But they didn't really say, as far
           as I recall, that they think Plan A is more important than B.  They just created
           A and B on the basis of what can be achieved real quick and what can wait a
           little later.
                       So it's not a matter of they are thinking that A is more
           important than B.  It's just that they feel that in 12 months they can do certain
           things, clean up the regulation and so on, and so you disagree with that?
                       MR. WARD:  I don't disagree with that, and I think if the staff
           wants to work on that, that's fine.  I think we would like to not wait for three
           years or however long the long-term program is to get to the last element.
                       CHAIRMAN APOSTOLAKIS:  They believe it will take that
           long because there will be issues to be address, is a different issue now.  Do
           you believe that the issues are not such significance or they will not be so time
           consuming so it can be done in a year and a half?
                       I mean, that's a different kind of disagreement.  It has nothing
           to do with priorities now.
                       MR. WARD:  Right.
                       CHAIRMAN APOSTOLAKIS:  It's a matter of assessing what
           it will take to do it.
                       MR. WARD:  I believe the issues on the redefinition should be
           able to be addressed in the next year if we work on it.
                       CHAIRMAN APOSTOLAKIS:  Mark?
                       MR. CUNNINGHAM:  Just to clarify one point, the staff is not
           suggesting in the paper that it will take three years to do that.  It could take up
           to three years.
                       CHAIRMAN APOSTOLAKIS:  Up to three years.  I was aware
           of that.
                       MR. CUNNINGHAM:  And the discussions that Mr. Ward
           alluded to earlier about between us and the staff will have a strong element in
           defining whether it's one year or two years or three years.  So we're not a priori
           saying that it's going to be three years.
                       CHAIRMAN APOSTOLAKIS:  But it's not really a matter of
           priorities though.  It's a matter of, you know, what can we do immediately and
           what can we do a little later.
                       MR. CUNNINGHAM:  And the way we think of it is that these
           are three parallel activities.
                       CHAIRMAN APOSTOLAKIS:  Yeah, that paragraph.
                       MR. CUNNINGHAM:  The work on the large break LOCA
           redefinition is not being slowed down, if you will, because of a lack of resources,
           a reallocation of resources to the other parts.  I think it's intended to go on, and
           you couldn't tell it from the presentation, but in the paper, I think it makes clear
           that the staff is committing substantial resources to the third part of this.
                       CHAIRMAN APOSTOLAKIS:  Very good.
                       Bill, where are we?
                       DR. SHACK:  We're through at this point unless there are any
                       CHAIRMAN APOSTOLAKIS:  Thank you.
                       DR. SHACK:  -- further comments or questions.
                       CHAIRMAN APOSTOLAKIS:  Well, I'd like to thank the
           presenters, and we are 20 minutes behind.  I want to remind the committee that
           we have a large number of letters we have to complete this month.  So I'm very
           sensitive to the timing here.
                       So we'll break until 10:40, and we'll come back.  We're
                                   (Whereupon, the foregoing matter went off the record at
                       10:24 a.m. and went back on the record at 10:40 a.m.)
                       CHAIRMAN APOSTOLAKIS:  Our next topic is policy issues
           related to safeguards, insurance and emergency preparedness regulations at
           decommissioning nuclear power plants, storing fuel in spent fuel pools.  Dr.
           Kress is the cognizant member.
                       DR. KRESS:  Thank you, Mr. Chairman.
                       Just to remind you, the staff was considering some generic
           rulemaking related to decommissioning plants, particularly with respect to the
           possible requirements for insurance and emergency preparedness and other
           things, and in order to guide their thinking on this rulemaking, they developed
           a technical study which we reviewed and wrote a letter on, had some opinions
                       They used this technical study then to identify some policy
           issues associated with possible rulemaking and rule changes, and it's these
           policy issues that we're going to hear about today, and the options they've
           identified to deal with policy issues and what their preferred options are.
                       We do expect to have a letter on this because I suspect the
           Commission will want to know what our opinion is on the policy issues
                       So with that, I guess I'll turn it over to Bill Huffman of NRR.
                       MR. HUFFMAN:  Thank you very much.  
                       I am Bill Huffman.  I'm a project manager at NRR, and I
           helped push this paper through, and I'm going to present a series of slides
           basically that overviews the paper and hopefully give you an opportunity to ask
           and probe as we go through the presentation.
                       The very last issue I'm going to turn over to a colleague of
           mine on the EP area.
                       Dr. Kress summarized this, and so I don't know if we need to
           go over it again, but the three areas -- there are certainly a lot of areas that we
           want to improve in the decommissioning regulations, but the three that have
           significant burden to the industry that looks amenable to reduction and also
           directly tied to the zirconium fire issue are insurance, security, and emergency
                       And there's a long history in trying to fix these, and it's failed
           several times, and we're going to try again.
                       We're starting from a technical study that was recently issued,
           NUREG 1738.  It was a technical study.  There were findings in the study, but
           in reality it just reports the risk, but it doesn't make any specific
                       And as the project manager dealing with that study and trying
           to develop rulemaking, we felt that we needed some further clarification and
           direction from the Commission because some of these areas are new and
           unique in rulemaking, especially an application of risk informing.
                       And so we have the technical study.  The risk is very low.  It
           meets the quantitative health objectives and safety goals.  If you agree that the
           safety goals are applicable to decommissioning plants with fuel stored in a
           spent fuel pool, then it develops a methodology that you can apply, use reg.
           guide 1.174.
                       And it also concludes that taking a thermal hydraulic approach
           to eliminating or precluding the possibility of a zirc fire is difficult to do, and
           therefore, we do have to look and see if maybe the risk argument is the best
                       MR. LEITCH:  Is the operative way there generic?  If you went
           plant by plant, could you define a time?
                       MR. HUFFMAN:  The study says generic, but if there's
           someone who wants to take a gander at that, I don't believe a plant specific
           thermal hydraulic analysis would be any easier because the problem is the
           configuration after these dominant events, like a seismic event or some other
           event that might rupture a spent fuel pool or drain it rapidly.  You just don't know
           what it's going to be in.
                       So even on a plant specific basis, in the past when we
           approved exemptions in these areas, we assumed a normal design basis
           configuration for the fuel.  We assumed that air flow was unobstructed.  In some
           analyses, I think we assumed building ventilation existed.
                       It's not likely in a seismic event that those conditions are going
           to exist.  So don't know that you could even do it on a plant specific basis.
                       DR. FORD:  Excuse me.  I'm new to this group.  So I don't
           know anything at all about background.  Can you just tell me very briefly in one
           sentence or paragraph what physical instances go into the first bullet, what
           physical processes?  What happens there, a leak in the pool or what?
                       MR. HUFFMAN:  Well, we have this report that looks at
           various accident scenarios, looks at slow drain-downs, evaporations.
                       DR. FORD:  Okay.
                       MR. HUFFMAN:  Those take hundreds of hours.  There really
           has to be a breakdown in the safety culture of the plant to have those kind of
           things occur without mitigation.
                       What you're looking at is a very, very low frequency event,
           such as a -- in fact, the dominant event that the report concludes would cause
           this rapid drain-down of the pool would be a very large, low frequency, seismic
                       DR. FORD:  So it would be seismic events primarily?
                       MR. HUFFMAN:  Yeah.  The second dominant event,
           although there's some industry disagreement with that, might be a cask drop,
           a 100 ton cask drop moving spent fuel.
                       DR. FORD:  Okay.
                       MR. HUFFMAN:  It might punch a hole.
                       DR. FORD:  Okay.  Thank you.
                       DR. WALLIS:  And your assumption is that if this happens, a
           fire happens.
                       MR. HUFFMAN:  That's the assumption.
                       DR. WALLIS:  -- is one
                       MR. HUFFMAN:  There is no conditional -- yeah, your answer
           is correct.  It's one.  There's reason to believe that there can be mitigated
           actions taken, that it probably wouldn't be one, but the assumption was that if
           the pool is drained, the fire occurs.
                       MR. ROSEN:  Now, when you say spent fuel pool accident
           risk is low, do you have a number on that?
                       MR. HUFFMAN:  We have a bounding number, again, pretty
           much dominated by the seismic frequencies of the plant locations, but it's on the
           order of two to three times ten to the minus sixth, is the upper limit.  It's less
           than that.
                       DR. POWERS:  There have been a number of instances
           within the zirconium production industry of zirconium fires, spontaneous fires. 
           Have you looked at those at all?
                       MR. HUFFMAN:  The technical group did look at that. 
           George, do you want to answer that?
                       MR. HUBBARD:  George Hubbard from the Plant Systems
                       The individual who looked at the thermal hydraulics in NRR
           and also in research, they did look at the information available regarding fuel
           fines for the zirconium fines, and I believe, you know, that is addressed in there.
                       I know we did take a look at it in the 1738.
                       MR. HUFFMAN:  Okay.  I'm going to proceed on.  One
           clarification -- oh here.
                       MR. GILLESPIE:  Frank Gillespie from NRR.
                       In the report there were really two conditions to get to the
           zirconium fire which were listed.  One was a drain-down of the pool, but then
           you had to violate what you already said, and that's our previous assumption of
           the design basis configuration.
                       So, one, the pool has to be drained down, and, two, the fuel
           has to somehow be reconfigured to allow the heat build-up that you need to
           start the zirconium fire.
                       MR. HUFFMAN:  It's not necessarily reconfiguration.  For
           instance, if the roof of the spent fuel pool fell and capped the top of the spent
           fuel pool and prevented air flow circulation.
                       MR. GILLESPIE:  Going out in the longer term, the report
           assumed an adiabatic situation.
                       PARTICIPANT:  Well, we did both.
                       MR. GILLESPIE:  Okay.  Because a simple drain-down is not
           going to lead to one for one to a fire.  That's all I'm saying.
                       PARTICIPANT:  Right.  We looked at a situation where there
           was 80 there to heat up, and we also looked at a situation where there was full
           air cooling, and even with full air cooling for short decay times, you can have a
           fire situation.  It depends on the amount of decay heat that was still present.
                       So there are situations.  Even with the normal channels
           available for air flow, if it's soon enough after the last off-load, you could get to
           a fire temperature.
                       DR. WALLIS:  So I think you're wrong, Frank.
                       MR. GILLESPIE:  Well, when I think of five to ten years after
           fuel load --
                       DR. WALLIS:  Oh, yes.  Maybe that's the case.
                       MR. GILLESPIE:  And that's what I mean.  We're in
           decommissioning space, and the question implied that you could have a fire
           going out to infinity, and that's really the problem we're trying to deal with, is this
           finding that we cannot preclude the fire ever.
                       DR. WALLIS:  But no one is smart enough to tell where the
           time is, where the scenario just described stops.
                       MR. GILLESPIE:  Yeah, right.  But it becomes more
           complicated as it goes out.
                       CHAIRMAN APOSTOLAKIS:  Would you go back to Slide 2? 
           Would you explain a little bit the third bullet?
                       MR. HUFFMAN:  All right.  In the report -- and then I might let
           Bob Palla (phonetic) speak a little bit more detail on this, but in the report they
           applied the principles of the methodologies in reg. guide 1.174 to EP.  They
           looked at what would happen if you removed or significantly reduced off-site EP
           shortly after a reactor permanently shut down.  They chose 60 days as the
           threshold where you don't have to worry about decay gap release of iodine.
                       So they did a study with EP in effect, without EP, early
           evacuation, late evacuation, and they showed that there is a small increase in
           risk in terms of early fatalities, but it meets the criteria of reg. guide 1.174.
                       DR. WALLIS:  Does normally 174 refer to fatalities or does it
           refer to LERF?
                       MR. HUFFMAN:  It doesn't, but they quantified it by the -- I
           may be digging myself in a hole.  They turned it into a probabilistic
                       CHAIRMAN APOSTOLAKIS:  You converted the delta CDF.
                       DR. KRESS:  They have a fraction of LERF that's permissible,
           and so they say, "Well, we'll have a fraction of change in early deaths," which
           is basically equivalent application of it.
                       MR. HUFFMAN:  Okay.  The first policy issue is a pretty
           simple one, but we had to ask it because we're relying in the report, the
           technical study, saying that it complies with the safety goals, but the safety goal
           policy statement doesn't address a decommissioning reactor.  It talks only about
           operating reactors and core damage.
                       So simply we wanted to clarify with the Commission that, you
           know, we can use the safety goal policy statements and the quantifications for
           this application.
                       DR. WALLIS:  These are the safety goals that one strives for,
           but never hopes to achieve or are these the safe goals one actually enforces?
                       MR. HUFFMAN:  I'm not sure I understand what you mean.
                       DR. WALLIS:  Well, I keep being told that safety goals are
           things that we should strive for, but not go beyond, and if we don't quite get
           there, it's because we're trying to get there eventually.  There's no kind of
           assumption that you ought to get there.
                       And so I'm just asking the question again that I always ask. 
           Are they things you try to get?  Are these the safety goals you actually use to
           say you've got to get there or are they something which is out there as an ideal?
                       MR. HUFFMAN:  Well, again, the safety goals are qualitative
           statements on cancers and on early fatalities.  At a decommissioning plant
           especially, if you get there, you've got some serious problem, but --
                       DR. WALLIS:  So you're saying you must not step over these
                       MR. HUFFMAN:  Well, you would hope that the only accident
           we're talking about here is a zirc fire.  You would hope that you would never
           even come close to challenging it, but for making risk informed decision making,
           again, going back to reg. guide 1.174, which is an implementation of this long
           train of logic, you know, ultimately its roots lie in the safety goals.
                       So we just wanted to get a blessing from the Commission that
           it was okay to use those safety goals, but we visualize that there will be other
           regulatory areas just besides these where we may want to apply reg. guide
           1.174 in making our decisions.
                       DR. WALLIS:  Well, what you're really meaning is it should be
           used on 174.
                       DR. KRESS:  Well, it's hard to use 1.174 since it deals with
           CDF and LERF.
                       MR. HUFFMAN:  Yes.
                       DR. WALLIS:  Just explain how you --
                       CHAIRMAN APOSTOLAKIS:  Well, we just derive delta risk
                       DR. KRESS:  Yeah.  So they use the concepts in 1.174.  Plus
           1.174 calls for other things like defense in depth and margins and compliance
           with other rules and things of that nature, and I think you tried to apply that
           thinking also.
                       MR. HUFFMAN:  Yes.
                       CHAIRMAN APOSTOLAKIS:  You would have a problem with
           the monitoring, particularly with emergency planning, how you monitor.
                       So your recommendation is one?
                       MR. HUFFMAN:  Yes, do it.
                       DR. KRESS:  Before you leave that slide, your rationale for
           saying, yeah, go out and use the safety goals is because the consequences
           from a zirconium fire could be just as bad as --
                       MR. HUFFMAN:  the consequences are similar to a core
           damage accident with a large release or can be worse if you're talking about
           multiple cores.
                       DR. KRESS:  Okay.
                       MR. ROSEN:  It seems to me you're asking the wrong
           question about this.  Is there any evidence that the Commission didn't intend
           safety goals and the safety goal policy statement to apply to the whole life
                       MR. HUFFMAN:  Yes.  It says specifically, and I thought we
           stated so in the paper, that it doesn't apply to anything other than -- we've
           quoted things out with the safety goal policy statement.  It's clear it doesn't apply
           to fuel cycle areas.  Just operating reactors.
                       MR. ROSEN:  it applies to operating reactors only.
                       MR. HUFFMAN:  Yes.
                       MR. ROSEN:  And it says that very clearly.
                       MR. HUFFMAN:  Yes.
                       MR. ROSEN:  It doesn't apply to decommissioned reactors.
                       MR. HUFFMAN:  Yeah, it doesn't mention decommissioned
           reactors, and in reality most people would probably say a decommissioned
           reactor, if it weren't for the zirc fire issue, is more of a material site rather than
           a reactor.
                       DR. WALLIS:  So these goals could be applied to a pool
           which is connected to an operating reactor, but as soon as you shut down the
           reactor and decommission it, it becomes something else?
                       MR. HUFFMAN:  The goals are applied to the entity of the
           reactor operating.  It's my interpretation.  I didn't look at it before I got involved
           in this paper.  I'm not an expert here, but it's my interpretation based on reading
           it that it was pretty clearly applying the core damage of an operating reactor.
                       I don't think -- again, this is speculation, but no one visualized
           that fuel would be kept in these reactors for eternity.  They'd be moved off site
           to Yucca Mountain by now.
                       DR. KRESS:  And the safety goals also explicitly excludes
           issues of safeguards.
                       MR. HUFFMAN:  Yes, it does.  It does explicitly exclude
           safeguards considerations.  That's a good point.
                       Speaking of safeguards considerations, when SRM from the
           Commission asked us to try to resolve this zirc fire issue a couple of years ago,
           you know, using a risk informed approach, one of the things that probably
           wasn't thought out real thoroughly at the time was safeguards, and it really turns
           out that it's difficult, if not -- it's just not within the state of the art right now to
           characterize the probability of an adversarial attack on a site, the probability of
           radiological sabotage. 
                       There are limited, I guess, methods used once you assume
           the attack takes place that might be able to characterize the probability of
           success, probability of interdiction, but the initiating event we just don't have a
           handle on, and therefore, a lot of --
                       DR. KRESS:  Is it so much that the methods don't exist or the
                       MR. HUFFMAN:  Does someone from NMSS want to take a
           shot at that?
                       MS. WARREN:  There are many databases available to us,
           including ones that we have available to us here in the Commission that involve
           the intelligence community.  However, it's the methodology that at this time does
           not exist.
                       You know, we have looked into that area very thoroughly, and
           the state of the art is that we don't use this type of method in determining
           probability for these type of events.
                       DR. WALLIS:  Well, the problem is that it's not based on
           science.  It's based on human behavior, and I can think of historical events and
           changes in society which would make the likelihood of sabotage either minute
           or much larger than today.
                       MS. WARREN:  Well, we certainly have all of this type of
           activity under continuous evaluation.
                       I'm Roberta Warren.  I'm the team leader for our threat
           assessment team, and I think we've spoken before to your group about, you
           know, the program that we have in place for threat assessment.
                       MR. HUFFMAN:  So what motivated us to ask this policy
           question is, well, we can try again.  It's going to be a deep hole, throwing a lot
           of resources and money and effort into, and there's no guarantee to success. 
           That's option one.
                       We can just give the Commission an update, a kind of a paper
           as to where the state of the art is now without actually committing to try to do it,
           or we can continue our current practice and with an open mind as, you know,
           the PRA methodology is developed.  If something comes up, we'll revisit this,
           but our recommendation is Option 3.
                       DR. KRESS:  Well, what then is your judgment about the
           associated risk?
                       MR. HUFFMAN:  Well, I was trying to articulate that in the
           paper, and our judgment is the risk is kept low.  Hopefully it's not greater than
           the risk of these other dominant events, but the risk is kept low by a rigorous,
           deterministic program for safeguards.
                       DR. KRESS:  Is that an assumption or do you have some way
           of validating that?
                       MR. HUFFMAN:  Well, we do have things like OSRES, but I
           don't want to get any further than that.  I, again, would like somebody from our
           safeguards group or NMSS if they want to.  You know, OSRES tests the
           capability of plants and able to defend against DBTs, other inspections,
                       MR. TRACEY:  Bill, Glenn Tracey.
                       OSRES are at operating reactors, however, not
           decommissioning sites.
                       MR. HUFFMAN:  Right.
                       MR. TRACEY:  And we don't conduct OSRES at those sites,
           and essentially you have safeguards in place at decommissioning facilities.  Of
           course, the next policy question is what level of protection and what level of
           safeguards should be maintained, and Bill will get to that in a second.
                       MR. HUFFMAN:  Well, I think the gist to your question was,
           well, if there's so much uncertainty, you know, how do we know that the
           frequency of these events and the risk isn't greater than the others, and I don't
           think I can say.
                       DR. KRESS:  Well, I guess my question is if you want to try
           to decide on what level of safeguards is necessary and even what level of
           emergency preparedness is necessary, it would be predicated on what level of
           risk you're trying to protect against.
                       And my question was what do we know about that risk and do
           we know enough to make judgments on those things.
                       MR. HUFFMAN:  You know, that exists in all PRAs.  I guess
           most PRAs, the expert judgment would be that the risk of sabotage is in the
           grass compared to the other dominant events.
                       MR. GILLESPIE:  Bill, let me help you out here.
                       MR. HUFFMAN:  Yeah.
                       MR. GILLESPIE:  Twice a year Bobby's staff actually
           prepares a briefing, and Mike Webber I saw here earlier, prepares a briefing for
           the Commission which addresses the design basis threat and what they feel the
           credible threat is.  And that goes in every six months, the deterministic view of
           what it is is revisited by the Commission.
                       So her staff does do that, and I don't want to get into any 
           more detail because all of a sudden I'll creep into something that's classified.
                       DR. KRESS:  I have the same problem.  You know, we have
           a set of design basis accidents for operating reactors, and then when I ask
           myself, well, what does that -- being able to meet those design basis accidents
           by the design and operation, what does that mean in terms of the risk status of
           the plant?
                       And nobody can ever answer that unless they go and say,
           "Well, we'll do a PRA then."
                       And then you do the PRA, and it tells you the risk status, and
           it tells you something about the correlation between those design basis events
           and the risk status, but here all we have is the design basis event.  We don't
           have a PRA.
                       So I don't know how to make that correlation.  How do I know
           that the design basis threat and being able to meet it results in an acceptable
           safeguards risk status with respect to decommissioning plants?
                       I don't know how to make that jump, and I was wondering how
           you guys are making it.  That's the nature of my question.
                       MR. ROSEN:  And the other side of that is how do we know
           that the resources we're committing both at the staff and at the utilities is in any
           way commensurate with the risk.
                       DR. KRESS:  Yeah.  I don't know.
                       MR. ROSEN:  It may be way too much.
                       DR. KRESS:  It may be too much.  It may very well be too
                       MR. ROSEN:  Not too little.
                       CHAIRMAN APOSTOLAKIS:  At the same time though the
           problem here is not of the same nature as risk due to accidents.  I'm not even
           sure that the policy issue is phrased the appropriate way.  Using probabilistic
           risk assessments for quantifying the likelihood of sabotage, I mean, here you
           have somebody who's intentionally trying to damage, and PRA doesn't deal with
           that.  PRA deals with accidental failures.
                       There are other ways of attacking this.  So I'm not even sure
           that the whole question is meaningful, although I do agree with you guys that
           some sense of what are the numbers we're talking about is needed.
                       Also, I'm bothered by the loose use of language like
           assessing likelihood in a qualitative manner.  I really don't know what that
           means, although I understand what you're trying to say, but I mean the
           language is not the right one.
                       So, I mean, you will never attempt to develop PRA methods
           to estimate the likelihood of sabotage because it's a different thing, a different
           question.  You know, you are playing games now.
                       DR. KRESS:  That's like an initiating event frequency.  You
           don't use the PRA.
                       CHAIRMAN APOSTOLAKIS:  It's not initiating.  I mean here
           the guy is some smart fellow who's trying to do damage.
                       DR. KRESS:  That's an initiating event.
                       CHAIRMAN APOSTOLAKIS:  Yeah, but it's not like pipe
                       DR. KRESS:  Well, it's not stochastic.  
                       DR. POWERS:  It could be exactly a pipe break.
                       MR. HUFFMAN:  I guess what we were trying to get at was
           that there may be vulnerabilities that could cause -- you know, responding to
           Mr. Ford's question, you know, how do you rapidly drain down the pool?  That's
           one of the ways to do it.  And that's an incompleteness in the study.
                       DR. WALLIS:  Or how you change the geometry that you were
           talking about.
                       MR. HUFFMAN:  That would do it.
                       CHAIRMAN APOSTOLAKIS:  I think you still have the
           problem of how likely is it that somebody would try to do it.
                       MR. HUFFMAN:  That's the answer we can't --
                       CHAIRMAN APOSTOLAKIS:  Maybe we can separate that.
                       MR. HUFFMAN:  That's a question we can't answer.
                       DR. WALLIS:  Well, obviously if you took the fuel away, which
           is the sensible thing to do, the problem would disappear.
                       MR. HUFFMAN:  That's one way to solve the problem, is to
           put it in the dry cask storage.
                       MR. ROSEN:  I think you're formulating the problem in a
           manner that makes it too hard to solve.  You're talking about trying to use PRA
           to assess the likelihood of an initiating event, and I don't think that's something
           we could touch.
                       But, on the other hand, you could assess the likelihood of the
           mitigation of an event with the systems that remain in operation, successful
           mitigation of a radiological sabotage event with the systems that remain in
           operation in decommissioning plants, and PRA would be a tool that could
           potentially be used for --
                       DR. KRESS:  As a function of the level of the threat.
                       CHAIRMAN APOSTOLAKIS:  But you would not be
           addressing the question of quantification of the likelihood of sabotage.
                       MR. ROSEN:  Of successful sabotage because you wouldn't
           have a number for the initiating event.  You'd only have a number for the
           mitigation potential.
                       CHAIRMAN APOSTOLAKIS:  But is Option 3 using this kind
           of input from PRA right now?
                       MR. HUFFMAN:  No.  Option 3 is not.  Option 3 is the status
                       CHAIRMAN APOSTOLAKIS:  Why nothing?  I mean, it makes
           sense to me.
                       MR. ROSEN:  Well, it makes perfect sense to me.  I mean if
           we were willing to talk about conditional containment probability, conditional
           core damage probability given an initiating event yesterday at some of the
           subcommittee meetings and we argue about whether it should be one or some
           number less than one, it seems to me you could apply exactly the same logic
                       Forget about the initiating event.  We know so little about it. 
           It's not under our control anyway, and how robust is the existing
           decommissioning plant and its systems and facilities and its people and its
           management against an initiating event?
                       CHAIRMAN APOSTOLAKIS:  And then perhaps a third
           observation there, that it would take substantial resources to develop these
           methods, would not be applicable, right?
                       That's 34 PRA, isn't it?
                       MR. ROSEN:  I think it is.
                       CHAIRMAN APOSTOLAKIS:  In a much simpler system.
                       MR. ROSEN:  Yeah, and applied to a very simple system
           compared to what we now apply PRAs to, which are much more complex than
                       DR. KRESS:  Well, it's more comparable to the Level II, where
           you don't have the phenomenological things to go into your model.
                       MR. ROSEN:  Well, you have a spent fuel pool, and you have
           fuel in it.  Now, that's what you're trying to protect, and you have cooling to it,
           and with air conditioning, and so you look at all of those kinds of systems and
           see how robust.
                       DR. BONACA:  What's the complexity involved in developing
           a PRA methodology?  I don't understand the methodology word.  The
           methodology is there.  It's more like --
                       CHAIRMAN APOSTOLAKIS:  I think it's more like two. 
                       DR. BONACA:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  The methodology you have
           now to identify its uses in the sabotage question, which is, I think, what Steve
           and Tom just told us.  There are places where you can use it.  So two would
           seem to be a reasonable option.
                       MR. ROSEN:  It won't give you the whole answer, George, but
           it will give you some of the answer, and that's better than nothing.
                       CHAIRMAN APOSTOLAKIS:  Not after a complete answer
                       MR. GILLESPIE:  George, the staff has actually been
           grappling with this for several years, and we're kind of doing what you're saying. 
           Let me just go to operating reactors and your OSRE program, and one of the
           major questions we had when we ran exercise is if you run four scenarios and
           you fail one out of four, does that mean you fail security?  If you fail two out of
                       So conceptually in the OSRE program already, in fact, in the
           significancy determination process for evaluating drills is the concept of we're
           not striving for perfection; we're striving for reasonable protection, and there is
           a consideration that if you fail one out of three scenarios, did you fail it because
           of a programmatic failure that could be repetitive.
                       And those kinds of questions are built into the current
           significancy determination process so that the risk concepts that you're talking
           about are there in the security area, but they're not articulated in mathematical
                       CHAIRMAN APOSTOLAKIS:  But I repeat.  I think the
           language in this slide is not the right one, and I think what you just said supports
                       MR. GILLESPIE:  Yeah, the potential, the probability of
           success is, in fact, right now a qualitative consideration in what's being done in
           security, and in fact, DOE has computer programs that actually do that
           mathematically for them when they run similar exercises.
                       CHAIRMAN APOSTOLAKIS:  But even in the significance
           determination process, when you decide it's a green, I mean there is some sort
           of quantitative evaluation, although you're not saying it's 1.2, ten to the minus
           four or five or whatever.
                       MR. GILLESPIE:  Oh, yeah.
                       CHAIRMAN APOSTOLAKIS:  And there is some element --
                       MR. GILLESPIE:  For operating reactors it's a little easier.
                       CHAIRMAN APOSTOLAKIS:  It's a qualitative assessment of
           a likelihood, right?
                       MR. GILLESPIE:  Yeah, that's what it really is, and in the
           second paper, which unfortunately we haven't gotten to you, which is the
           safeguards addendum kind of to this paper, it does talk about the consideration
           in safeguards terms of systems and walls and how much reinforcement bar is
           in and what's the likelihood of the design basis threat doing something to the
           systems that are inherently there already and how you might go about looking
           at that.
                       CHAIRMAN APOSTOLAKIS:  But what's wrong with
           proposing, recommending Option 2?  I mean, it seems to me from the whole
           discussion that this is really -- and some of the evaluation has already been
           done because you're already using the methodologies, right?
                       MR. GILLESPIE:  I think what you're doing, you've switched. 
           This was written really, and you got it in a different -- the context of this was in
           the return frequency of the event, in the likelihood of what armament that event
           would pertain to.  So you have to understand these words and the idea of how
           they were written, and they were really written in the context of return frequency
           of a particular threat, and what is the size of that threat.
                       So it wasn't written in the idea of coming up with the
           probability of success on a conditional level, which we're kind of doing already.
                       CHAIRMAN APOSTOLAKIS:  But the way it's written now, if
           I take it literally, it says for assessing sabotage, and that probably is out of the
           question.  But if you say, "Evaluate current state of the RPRA methodologies,"
           or "evaluate the role that current state of the art RPRA methodologies can play
           in this issue of sabotage," then it's a different story, isn't it?  Because then the
           role is clear, what is conditional on the threat.
                       MR. GILLESPIE:  Yeah, and that is --
                       CHAIRMAN APOSTOLAKIS:  And you're doing some of it
                       MR. GILLESPIE:  We're kind of doing it qualitatively right now,
           and DOE does it in a very -- they have handbooks that say if a soldier runs X
           number of yards carrying a weapon loaded so much, the likelihood of his shot
           being successful is this percent.  They have it down -- yeah, they have
           handbooks down to that level of detail.  
                       I don't know that we want to get there.
                       CHAIRMAN APOSTOLAKIS:  That's not what I had in mind.
                       MR. GILLESPIE:  No, I didn't have that in mind.
                       MR. ROSEN:  I have the feeling I'm not being understood. 
           What I'm talking about is using PRA in almost a traditional way to talk about how
           robust are the mitigating systems if someone were to take and break a pipe
           somehow.  We're not talking about whether it's a soldier or with explosives or
           whatever.  Forget about all of that.  Just assume the pipe is broken and how
           robust is this system.  Is it two trains, three trains?  How big a pipe do you need
           to break?
                       CHAIRMAN APOSTOLAKIS:  I understand that.
                       MR. ROSEN:  It's like use the PRA methodologies we now
           use to assess the capability of the decommissioning plant to mitigate potential
           sabotage, and forget about -- forget completely about the probability of --
                       DR. KRESS:  They actually did that in the technical study.
                       MR. HUFFMAN:  I guess this goes a little bit beyond that
           though, and I don't want to get into any safeguards information, but just say
           theoretically that you could put a very large hole in the bottom of a spent fuel
           pool.  There are no mitigating systems for that.
                       DR. KRESS:  It's going to go.
                       MR. HUFFMAN:  There's no mitigating system.
                       MR. ROSEN:  That's one of the events that you say is going
           to go --
                       DR. BONACA:  But I think that's the issue.
                       MR. HUFFMAN:  Yeah.
                       DR. BONACA:  If I understand it, on the mitigation side there
           isn't every much.
                       MR. HUFFMAN:  We're not talking about pool cooling here.
                       DR. BONACA:  On the initiation side it's a very complex issue,
           the different sequences you have, potential initiator of sabotage that is difficult
           to estimate, and that's really probably what the complexity is.
                       MR. HUFFMAN:  Absolutely.
                       DR. BONACA:  That's what it is, and there isn't much you can
           describe as a mitigation.
                       CHAIRMAN APOSTOLAKIS:  But still you would not be
           developing PRA methods for estimating the likelihood of sabotage.  You would
           be doing something else because this is not accidental anymore.
                       MR. HUFFMAN:  No.
                       CHAIRMAN APOSTOLAKIS:  A different story.
                       MR. HUFFMAN:  Okay.  So you agree that number one would
           be a waste of time.
                       CHAIRMAN APOSTOLAKIS:  Number one would be a waste. 
           Wait a minute.  
                       CHAIRMAN APOSTOLAKIS:  "Commit resources."
                       DR. WALLIS:  Are you saying this is something like aircraft
                       CHAIRMAN APOSTOLAKIS:  I think it's not phrased well.
                       DR. WALLIS:  I mean it doesn't make sense to do a PRA to
           study what happens to the aircraft if the bomb explodes in it.
                       MR. HUFFMAN:  I would agree.  That would be a similar
                       CHAIRMAN APOSTOLAKIS:  I guess what you're saying,
           Steve, would apply more to the reactor.
                       MR. ROSEN:  No, I don't agree.  I don't agree to that.  It
           seems to me that number two, if you constrain it and phrase it properly,
           constrain it properly, then you can get some sense of the relative robustness of
           the barriers to eventual successful radiological sabotage, absent discussion of
           the initiating event.
                       Now, I recognize, and I think I agree with Bill Shack, that you
           can envision an initiating event which no existing mitigating systems can do
           anything with, but that's true in the reactor, too.
                       DR. BONACA:  Well, I think what we were saying is that whole
           PRA here would be driven by a number of initiating events which dominate the
                       MR. ROSEN:  Right.
                       DR. BONACA:  And the mitigation portion is probably not a
           very complex thing because there isn't much that you can do, even initiate it to
           deal with it, but are limited so that you are still missing most of the insights that
           you expect from the PRA, which are coming from in this particular case from
           initiators that you can't quantify.
                       MR. ROSEN:  If you don't do the work and you don't put some
           people who know how to do PRA to work on this thinking about it, you'll never
           get the insights that would allow you to assess the capability and perhaps
           enhance the capability of the mitigating systems.  You're simply foregoing any
           of that.
                       So my feeling is a properly structured Option 2 would be of
           some value.
                       DR. KRESS:  Looking for vulnerabilities maybe.
                       CHAIRMAN APOSTOLAKIS:  I agree.
                       DR. KRESS:  That you can detect.
                       CHAIRMAN APOSTOLAKIS:  I think Option 2 is rephrased.
                       MR. ROSEN:  Yes.
                       DR. WALLIS:  So design changes could make a difference. 
           I mean you could probably require, if it were desirable, that the fuel should be
           stacked in a way so that if the pool drains it cannot catch fire.
                       MR. ROSEN:  Well, that's one possibility.
                       DR. WALLIS:  That's one possibility as an extreme measure.
                       CHAIRMAN APOSTOLAKIS:  No, but I think Steve is right. 
           Unless you look --
                       DR. WALLIS:  There are physical things you can do to make
           a big difference to the probability of a major accident.
                       DR. BONACA:  I understand from Mr. Gillespie that, hey, look.
                       CHAIRMAN APOSTOLAKIS:  That isn't what the --
                       DR. BONACA:  Yeah, I understand.  I understand.
                       CHAIRMAN APOSTOLAKIS:  I think we -- policy issue three.
                       MR. HUFFMAN:  Thank you.
                       All right.  That question goes well beyond decommissioning. 
           We just decided to tackle it because we are trying to address the more specific
           issue of how do we address what safeguards requirements are appropriate for
           the spent fuel pool.
                       And we have three options.  The slides are on this.  The third
           opinion is on the next page, but Option 1 would be essentially the requirements
           that now really exist at a decommissioning plant because it is still a Part 50
           licensee, which should be the operating reactor requirements, you know, with
           the full response force, you know, being able to interdict the DBT.
                       It seems excessive.  Certainly if it's good enough for an
           operating plant, there can be little argument that it's good enough for a
           decommissioning spent fuel pool, but that's one of the options.
                       Option 2 is something that you may or may not be familiar with
           since it went in parallel with this paper, is staff's proposed rule changes to 73.55
           to make it less prescriptive, more performance based, and in addition, put a
           performance standard associated with it.
                       This is basically look at where the DBT can do damage and
           see what you have to do to prevent that damage from occurring, you know,
           such that you don't exceed radiation doses  at controlled area boundaries that
           exceed five rem.  In a spent fuel pool situation, the only situation that's going to
           get you to that radiation level is a zirc fire.
                       So if, for instance, licensees were given Option 2, you know,
           depending on the plant specific configuration in the fuel pool, say it's a seven
           foot thick pool, high seismic area, a lot of rebar buried in the ground.  It's
           probably not too difficult for them to demonstrate that you can't poke a hole in
           it to drain it.  And they may have to do a very minimal amount to be able to
           demonstrate that they can meet that criteria.
                       DR. KRESS:  Would the design basis threat be the same one
           you use --
                       MR. HUFFMAN:  Yes.
                       DR. KRESS:  -- in operating the reactor?
                       MR. HUFFMAN:  Yes, the same design basis threat, a slightly
           different approach, and you don't have to interdict it.  You don't have to stop
           them at the fence.  You don't have to worry about defending something
                       DR. WALLIS:  Aren't you coming around to Steve's argument? 
           There are a lot of things you can do with design to change the problem.
                       MR. HUFFMAN:  Absolutely.  But, again, we're going to use
           judgment, engineering, and perhaps PRA can play a role here, but this is a
           broad based recommendation right now.  You know, the details, reg. guides,
           how we figure that out in regulatory space is not what we intended to do.
                       DR. WALLIS:  Proposing to redesign fuel pools in some way
           or modify existing fuel pools in some way then?
                       MR. HUFFMAN:  That would not be our recommendation, but
           that would be an option.  If they wanted to build a cage around the pool, and
           believe me, this is not what we're recommending, but pursuing your thought, it
           might make it impossible to put an explosive charge close to the wall, and that's
           cheaper than maintaining additional guards 24 hours a day, 365 days a year.
                       DR. WALLIS:  This is the option you're --
                       MR. HUFFMAN:  That would be an option to take.
                       DR. WALLIS:  -- recommending.
                       MR. HUFFMAN:  Yes.
                       DR. WALLIS:  Is to make the thing impregnable or whatever
           you want to call it or robust, robust.
                       MR. GILLESPIE:  Graham, what we're offering is a
           performance criteria that leaves to the licensee the method.
                       MR. HUFFMAN:  The licensees would make that decision,
                       MR. GILLESPIE:  So if they want to trade off design features
           for manpower costs, that should be their economic decision, not ours.  So this
           is a rule that would set a limit at the site boundary, and the licensee figures out
           how to do it.
                       And this also brings into harmony with Part 72.
                       DR. WALLIS:  Are there licensees who think this is feasible?
                       MR. HUFFMAN:  We'll find out within a --
                       DR. WALLIS:  Well, I mean, it doesn't seem to make much
           sense to suggest an option that if it's not feasible.
                       MR. HUFFMAN:  I agree.  We would not want to propose a
           rule if nobody was going to be able to utilize it to reduce burden, if it made no
                       DR. KRESS:  As time went on in decommissioning,
           presumably the probability of a zirconium fire gets less, although you know
           there's some question about that.  Would the level of protection then be variable
           with time rather than a fixed something?
                       MR. HUFFMAN:  Does Glenn Tracey -- would you allow me
           to speculate on this?
                       MR. TRACEY:  Yes, speculate.
                       MR. HUFFMAN:  Okay.  Again, since this is a performance
           based rule, mitigation time is certainly a consideration in the argument a
           licensee may make.  If you're Humboldt Bay and you've been shut down for 30
           years and it would take even in an adiabatic thermos, you know, weeks to get
           there, you could certainly argue; a licensee, I think, could make a pretty darn
           valid argument that they could do something ad hoc to mitigate the results of the
                       DR. WALLIS:  Enclose it in a block of ice 100 foot thick and
           it slowly melts away.
                       MR. HUFFMAN:  Or in Humboldt Bay's case, the water will
           probably leak in anyway.  
                       MR. HUFFMAN:  So maybe that was a bad choice.  Anyway,
           I think that's what we're getting at.
                       DR. WALLIS:  Well, seriously, is this something that's going
           to find some takers?
                       MR. HUFFMAN:  I can't answer you right now.
                       MR. TRACEY:  It's very consistent with current Part 72, which
           NMSS has pools and also has dry casks.  So since it's consistent with what the
           industry is practicing from the materials side, I would think it will have takers.
                       MR. HUFFMAN:  There is the third option, and the third option
           is to apply what we currently apply at dry cask storage storage facilities.
                       DR. SHACK:  How is it different?  My criteria seems to be the
                       MR. HUFFMAN:  Dry cask storage, the facilities aren't
           required to meet the DBT.  So it's significantly different.  That's why it's a policy
                       DR. POWERS:  It seems to me that that's not an exactly
           equivalent option, is it?
                       MR. HUFFMAN:  Well, I don't think that a dry cask is
           equivalent to a spent fuel pool.  So, right, I don't, and I hate to confuse the
           issue, but there is one wet storage facility out there, G.E. Morris, and the same
           regulations apply there.
                       DR. POWERS:  So all you're saying is we may have made a
                       MR. HUFFMAN:  May have, but that's a policy decision that
           the Commission has to make.
                       DR. POWERS:  Well, it seems to me that in thinking about
           Option 3, you need to be very clear that dry casks, a little bit of the fuel per
           cask; spent fuel pools are a whole bunches.
                       MR. HUFFMAN:  I agree that they're apples and oranges.
                       MR. GILLESPIE:  Also, Dana, it's not quite as clear cut as
           even it was just made to sound.  Within Part 72, if you have a dry cask storage
           under a general license at a reactor, the design basis threat does apply, but if
           you have a specific license, it doesn't.  So there's even an inconsistency there
           within the same rule.
                       So there's some clean-up here that needs to take place.
                       DR. WALLIS:  Well, I'm concerned about this really
           performance.  Some design that assures no fuel damage that exceeds off-site
           dose limits?  No idea what it might be?
                       MR. HUFFMAN:  The design -- I hope we're not being thrown
           off by the word "design," because that includes security plans, and it's not just
           a physical design.  It's the security system.
                       DR. WALLIS:  You're going to trade off.  You said you're going
           to trade off sort of people versus physical things.  How do you do that if you
           can't assess the sort of risk associated with people performance?  I don't know
           how you do the tradeoff in a logical way.
                       MR. HUFFMAN:  Anybody out there want to answer that
                       MR. GILLESPIE:  You've got a design basis threat.  You could
           make certain decisions.  For example, if putting a hole in the pool drains the
           pool, but you decide to put -- I don't know -- a spray system of some kind in to
           put a fog spray over this thing, you could --
                       DR. WALLIS:  For a long time.
                       MR. GILLESPIE:  -- that could become a consideration.
                       I don't know what the tradeoffs could be.  The idea of having
           a performance criteria was to allow licensees to make that decision and not
           have the regulator making it for them.
                       So the system, the design of the system, it's the pool; it's the
           security system; it's the number of guards; it's how close the LLEA is to come.
                       If the LLEA can be there in 15 minutes versus 30 minutes,
           that could make a significant difference, particularly if you have older fuel, which
           is the point I was making earlier on having to reconfigure the fuel if it's older fuel
                       DR. WALLIS:  It's amazing.  Maybe we should have the same
           rule for reactors.
                       MR. HUFFMAN:  Well, that's what we're proposing.  That rule
           is for reactors right now proposed, and we're suggesting that --
                       DR. WALLIS:  No fuel damage?
                       MR. HUFFMAN:  No.  That's --
                       MR. GILLESPIE:  No core damage.
                       MR. HUFFMAN:  -- no core damage.
                       MR. TRACEY:  No spent fuel sabotage which would exceed
           five rem, 100 meters.  So the 72106 standard.
                       DR. WALLIS:  No damage?
                       MR. TRACEY:  That would exceed.
                       DR. WALLIS:  You're going to get probabilities in there.
                       MR. HUFFMAN:  No damage that exceeds five rem.  If you
           threw acid in the pool, that definitely would damage the fuel, but that's not what
           we're talking about.
                       DR. WALLIS:  You'd have to talk about probabilities.  You
           can't go with no damage.  You're going to have to do a PRA for this new design,
           whatever it is.  You're going to have to do something like a PRA.
                       MR. HUFFMAN:  You would have to have some kind of a
           justification that demonstrates that it doesn't exceed the performance criteria of
           five rem at the controlled area boundary.
                       DR. WALLIS:  You can never do nothing.  You've got to have
           a probabilistic measure.  You cannot say you'll never have.
                       MR. GILLESPIE:  I think we have to agree.  The thought is
           that it will likely not exceed.  We have to have reasonable assurance it won't
           exceed because the right words may be yet to be selected, but we're looking for
           reasonable assurance, which gives a sense of we're not dealing in absolutes. 
           We're not looking for the absolute assurance.  We agree.
                       DR. KRESS:  I think we need to move on to the next policy
                       MR. HUFFMAN:  Okay.  Policy Issue 4 is what do you do
           about insurance.  There's two types of insurance in the facility, and our
           recommendation would probably be applicable to both, but we're primarily
           concerned about Price-Anderson, and when do you reduce Price-Anderson
           insurance coverage from limits and allow these decommissioning facilities out
           of the secondary retrospective premium?
                       We looked at it, had a lot of debates, and this is probably the
           closest you're going to get to a risk based recommendation, number four,
           because it doesn't directly impact public health and safety, and frequencies are
           very low, and our recommendation is to allow them out of the insurance limits
           for operating reactors very shortly after they permanently shut down and off-
                       MR. ROSEN:  This is Price-Anderson?
                       MR. HUFFMAN:  Yes, Price-Anderson.
                       MR. ROSEN:  Not 50.54(w)?
                       MR. HUFFMAN:  We would also recommend changes to
           50.54(w).  We would recommend in the details of this -- again, this is the broad
           scope for the Commission -- to say, "Okay.  We agree that you can use a
           frequency based argument on this one."
                       But the details were proposed back to the Commission in '93,
           SECY 93-127, where we would let them out of the secondary retrospective
           premium.  We would lower the primary limits on Price-Anderson to 100 million,
           and probably reduce 50.54(w) to around 50 to 25 million.
                       MR. ROSEN:  From its current --
                       MR. HUFFMAN:  From it's current, yeah, exactly.
                       DR. KRESS:  Now, how did you arrive at those particular
                       MR. HUFFMAN:  We endorsed the same -- there are other
           things that can cause, you know, exercising of insurance.  Even if, you know,
           somebody thought that there might be an accident and suffered mental anguish,
           they can sue for insurance.
                       You could have a tank with radioactive liquids spill and there
           would be off-site liability associated there.  Ninety-three, one, twenty-seven
           went into detail what those appropriate limits might be in those situations, and
           we see nothing in 93-127 that's been superseded, and so we thought those
           limits were still appropriate.
                       DR. KRESS:  That's where they came from.
                       MR. HUFFMAN:  Yeah.
                       DR. KRESS:  Okay.
                       MR. ROSEN:  Fifty, fifty-four (w) covers property insurance,
           minimum requirements of property insurance.  What you'd be covering is the
           radiological to clean-up on site, not off site; on site.
                       MR. HUFFMAN:  Right, on site.
                       MR. ROSEN:  Clean-up of a --
                       MR. HUFFMAN:  With a tank spill.
                       MR. ROSEN:  -- tank spill.
                       MR. HUFFMAN:  Right.
                       MR. ROSEN:  Or some other accident that resulted in some
           radioactive contamination of the fuel handling facility.
                       MR. HUFFMAN:  Yeah, right.
                       MR. ROSEN:  And that would be in the range of 25 to 50
                       MR. HUFFMAN:  Twenty-five to 50 million, yeah.
                       MR. ROSEN:  That seems consistent.
                       MR. HUFFMAN:  Yeah.  That concludes my part.  Randy
           Sullivan from the EP Branch is going to come up here and finish it off.
                       MR. SULLIVAN:  Hi.  Thanks.  Randy Sullivan from NRR.
                       I wanted to talk about emergency preparedness, and as it
           relates to this SECY.
                       Option Number 5 is to determine policy of what level of
           emergency preparedness would be appropriate, and the options are fairly
           simple.  It's just a logical step through.
                       Do little.   Do most everything we're doing now, or do
           something in between.  We suggested that the something in between is
           appropriate.  That's Option Number 3.
                       DR. KRESS:  The policy issue stated with the qualifier on it
           is given the low likelihood of a radiological release large enough to exceed
           protective action guidelines.  That's based on, since it's a likelihood -- is that
           based just upon the earthquake PRA that they did in a technical study or does
           that include safeguards?
                       MR. SULLIVAN:  We feel that it envelopes the safeguards
           issue.  Actually in emergency preparedness space, we feel that that issue is
           enveloped by the emergency planning that this would propose.  So it doesn't
           matter what the initiator is.
                       DR. KRESS:  You're making a judgment that the safeguards
                       MR. SULLIVAN:  Yes, we are.
                       DR. KRESS:  -- risk is low enough --
                       MR. SULLIVAN:  Yes, we are.
                       DR. KRESS:  -- that it probably is the same order of
           magnitude of the earthquake.
                       MR. SULLIVAN:  Well, you know, I'm glad you brought that
           up actually.  It's a little more -- I want to address that in a little more depth.  In
           emergency preparedness, we're not working simply against risk.  Our obligation
           is against defense in depth, you know, as stated in the '86 Commission policy
           on the safety goals.  It reiterates a couple of times that emergency
           preparedness is an element of defense in depth.
                       So while we want to risk inform this process, you know, as is
           appropriate and in accordance with Commission guidance, what we're
           attempting to do here is maintain the appropriate level of defense in depth.
                       Now, --
                       DR. KRESS:  So you'd have to answer a question, and that
           is:  what is the appropriate level of defense in depth?
                       MR. SULLIVAN:  Exactly, and we think we can do that in the
           rulemaking process; that there be a level of emergency preparedness we
           believe is appropriate, and we have technical arguments for that.
                       Now, what we would base these decisions on are not only
           risk, but the four bullets in the middle of the page.  There's the physics of the
           situation.  You know, you cannot get a rapidly evolving accident with the spent
           fuel pool.  There is --
                       DR. KRESS:  Even if you rapidly drain the pool.
                       MR. SULLIVAN:  Right.
                       DR. KRESS:  It still takes a long time.
                       MR. SULLIVAN:  Well, even with fairly new fuel, it takes a
           couple of hours.  You know, in a reactor, our emergency plans are poised for
           immediate action.  I mean within 31 minutes.
                       DR. POWERS:  It seems to me that when you make these
           arguments about it taking a long time, you're presuming that the decay heat is
           going to be responsible for raising the temperature to the point that you get
           some rapid reaction.  It's not evident to me that that's necessarily true as we
           move to high burn-up fuels where we have zirconium hydrides inclusions
           distributed in the clad.
                       MR. SULLIVAN:  Well, we're basing our path forward on
           1738.  So I'm using the technical analysis.
                       DR. POWERS:  Well, I would hope that we include in that
           looking at the issues of ignition by spontaneous combustion of zirconium
                       MR. SULLIVAN:  As part of the emergency preparedness
           rulemaking process or as part of the technical --
                       DR. POWERS:  In general.
                       MR. SULLIVAN:  Okay.  Certainly.
                       DR. KRESS:  I think there's a significant of zirconium hydrides
           even without high burn-up fuel in the spent fuel pool fuel.
                       DR. POWERS:  I think most of those, Tom, though -- until you
           get to high burn-up, those hydrides are distributed.  It's only when you start
           getting inclusions where you have real microscopic quantities that you need to
           worry about them as ignition source it seems to me.
                       DR. KRESS:  Because they concentrate near the surface of
           the --
                       DR. POWERS:  They concentrate near various points that are
           a little lower in temperature, and it's incrementally lower, but they concentrate
           as nodules, big, and so if you get just a casual fracturing, they get exposed to
                       But what I don't know, and we've not had any discussion from
           the staff on this, is the pyrophoricity (phonetic).  Is the pyrophoricity on these
           things equivalent to uranium hydride, in which case they'll ignite things, or are
           they more like magnesium hydride, in which case maybe they won't?
                       MR. SULLIVAN:  Well, that's clearly an issue that's going to
           have to be dealt with, but we're basing it on the accident as described in 1738,
           and we're assuming that we've got, even at the very shortest time that we're
           talking about, you know, less than a year, a number of hours before this
           accident can begin.
                       That would allow certain -- that would change the focus of
           emergency preparedness from the way it is at operating plans in some
           fundamental ways.
                       There are some other angles.  Potassium iodide wouldn't be
           relevant, you know, because you don't have iodine.  So there is a series of our
           regulations that --
                       DR. POWERS:  It just wouldn't be radioactive.
                       MR. SULLIVAN:  Right.  So there's a series of our emergency
           preparedness regulations that are obvious that would no longer be applicable.
                       DR. POWERS:  That would be a health benefit to the
                       DR. WALLIS:  This ten hours doesn't make any sense to me,
           and suppose that an event happens, and then ten hours later you know there's
           going to be a fire, and there's going to be a large release of radioactivity, a very
           large release of radioactivity.  Ten hours?  What can you do in ten hours that's
           going to make much difference?
                       You can get people out of there.  You may get them to hunker
           down or something, but --
                       MR. SULLIVAN:  I don't want to confuse you with what we're
           proposing here.  We're proposing that emergency preparedness in Option 3,
           what we're proposing to the Commission, is that emergency preparedness be
           maintained as is at the operating plant for some period of time.  That period of
           time is less than a year, but it will be determined in rulemaking.  All right?  We
           don't know what the exact time is.
                       Then there will be a decrease in requirements commensurate
           with the physics of the situation, these four bullets in the middle here, the
           physics of the accident, the ease of mitigation, the ease of protective actions,
           and the low risk.
                       MR. ROSEN:  And paying attention to Dana's point about
                       MR. SULLIVAN:  Yeah, well, apparently, yes.
                       Now, at some time in the future when the fuel is sufficiently
           decayed such that the physics of the situation dictates under worst case
           conditions, minus what you mentioned, at least ten hours, but probably no more
           than 24 hours to take action we would propose making the EP regulations
           similar to that for a spent fuel storage facility.
                       DR. WALLIS:  So you're assuming that someone is going to
           prevent the fire occurring in that ten hours?
                       MR. SULLIVAN:  No, and the basis of this is that we've looked
           at a study of evacuations in the United States, and in fact, there's an -- this is
           1980s data, I'm afraid to tell you, but it was the best data that I could find --
           there's an evacuation about every two weeks.  They are largely successful, and
           they are largely ad hoc, and yet, indeed, there are cases where 12,000 people
           are moved in six hours without a nuclear grade emergency plan to do it.
                       There are cases when 6,000 people are out and back in in 11
           hours.  Now, we are using that historical evidence to base --
                       DR. WALLIS:  But now you've eliminated the EP after this
           situation.  So what's going to get them out when the fire is waiting to happen for
           ten hours?  What's going to happen to them then?  Are they just going to sit
           there and wait for the fire?
                       MR. SULLIVAN:  No, not at all.  The emergency plan would
           always require off-site notifications, that there be an on-site emergency
           capability.  The issue really is the level of off-site emergency.
                       So we're expecting notifications to be made, and we're
           expecting there to be off-site agencies that are capable of acting on those
           notifications, and there's a good reason to assume that.  You know, there's a
           good, historical record that these evacuations take place.  They're done
           effectively, et cetera.
                       DR. KRESS:  So the technical issue is how long do you have
           to decay before you reach some ignition temperature that's currently ill defined
           for ten hours.  So that's the technical issue that has to be determined.
                       MR. SULLIVAN:  We came to consensus with FEMA on 24
           hours being an absolute maximum.
                       DR. KRESS:  Well, whatever the time is, you still have to
           decide what the ignition temperature is, and you'll have a pretty good handle on
           the decay heat..
                       MR. SULLIVAN:  Yeah.
                       DR. KRESS:  I guess you'll let it be adiabatic just to not have
           to deal with the --
                       MR. SULLIVAN:  We're proposing using the graphs in 1738
           and not doing a site specific analysis.  So if it's a BWR, it's X number of hours
           and X number of years and off you go.
                       DR. KRESS:  For a fixed ignition temperature.
                       MR. SULLIVAN:  Yes.
                       DR. KRESS:  That somebody has specified.
                       MR. SULLIVAN:  That's right.
                       DR. KRESS:  But that has to be put on a pretty good technical
           basis in view of, say, Dana's hydride.
                       MR. SULLIVAN:  This determination is based on 1738.  If
           1738 needs to be informed by Dr. Powers' question, then so be it.
                       DR. WALLIS:  Well, Bill Huffman said you cannot predict
           when the zirconium fire is not physically possible, and now you're going to
           predict how long it takes to occur when it is possible.
                       MR. SULLIVAN:  Yes, 1738 does exactly that.
                       DR. WALLIS:  Well, it just seems to me there's some
           inconsistency here.
                       MR. SULLIVAN:  It's assuming there --
                       DR. WALLIS:  You can't predict when it's possible, and yet
           you can predict how long it takes to occur.  Well, you've got to first know if it's
                       MR. SULLIVAN:  No, you can't predict when it's not possible.
                       DR. WALLIS:  Well, then you can't predict when it is possible. 
           That's the logics.
                       MR. SULLIVAN:  No, I think 1738 would say that it is possible.
                       DR. WALLIS:  If you can't predict when it's not possible, you
           can't predict when it is possible.  It's sort of if A, then B, and if not A, not B. 
                       MR. SULLIVAN:  Well, why don't we let somebody who
           helped write 1738 address that rather than me?
                       MR. HUFFMAN:  I'm not the one who did the thermal
           hydraulic analysis, and I'm not an expert in that area, but I guess 1738 on the
           most conservative approach, the adiabatic approach, it is a fairly simple thermal
           hydraulic calculation of how long it will take if there's no energy leaving the
           system to reach the assumed zirconium ignition temperature.  Okay?  That's not
           a complicated equation calculation, and that's the number that Randy is talking
                       On the other hand, it's very difficult to prove that you won't
           reach that zirconium ignition temperature when you don't know what the
           configuration is and what the cooling and heat removal from the system is. 
           That's the difference.
                       DR. KRESS:  And the problem there is deciding what that
           ignition temperature ought to be, and they fixed a number, you say, in this other
           one, and that's the one that I think we're saying may be in some doubt.
                       MR. SULLIVAN:  Well, yeah.  When 1738 was presented to
           the Commission, it was presented as a bounding.  In a sense, you could
           interpret the way it was presented was that it was an adequate bounding
           analysis, and that if we worked off this, you know, reasonable assurance that
           public health and safety could be insured.  So that's --
                       DR. KRESS:  Do you recall what the ignition temperature
           was?  Was it about 1,500 degrees C. or something like that?
                       MR. SULLIVAN:  I think it was 900.
                       DR. KRESS:  Nine hundred.
                       MR. SULLIVAN:  Is there a thermal hydraulicist?
                       MR. TINKLER:  When we evaluated the criteria that we
           consider to be appropriate for ignition, we considered a range of different
           possible thermal hydraulic boundary conditions, and we specified ignition
           temperatures for a long-term operation as low as 600 C. up to about 900 C.,
           depending on the age of the fuel, whether or not we thought there was a
           significant ruthenium inventory remaining the fuel.
                       And as I recall, the lower temperatures of 600 degrees C., we
           did address the issue of hydride reactions and considered that they would not
           be limiting at such low ignition temperatures.
                       Now, the concentration of hydrides and inclusions in the fuel,
           the extent to which we have data on whether or not that would lower an
           effective ignition temperature, I don't recall exactly, but the general conclusion
           was that those temperatures as low as 600 would cover the effects of hydriding.
                       Now, I wanted to also just say briefly, too, that was when we
           were considering things like the break-away oxidation and the range of different
           temperatures and the low temperature.
                       No matter what ignition temperature was selected, we
           recommended that the calculation had to be done to show that you could
           maintain an equilibrium condition, you know, regardless, and whether or not a
           particular calculation is conservative, that judgment can't be reached unless you
           are considering the effects of reactions, the chemical energy.  It may be slow,
           but now you're competing against a decay heat level, which is low.
                       So reaching a judgment as to whether or not oxidation energy
           is important or unimportant can only be made relative to the magnitude of decay
           heat and the heat losses.  So we recommended that a calculation be done
           actually addressing heat generation and losses.
                       DR. WALLIS:  Well, I go back to my point.  You're going to
           predict here when it reaches a temperature for at least ten hours and maybe it's
           24 hours, and then you can also predict reaching a temperature for 100 hours,
           but predicting when it can reach an ignition temperature for any number of
           hours is just a thing which we were told you couldn't do.
                       So something just doesn't seem consistent.
                       MR. SULLIVAN:  Well, from an emergency preparedness
           point of view, we think that somewhere we'll come down with our stakeholders'
           FEMA states and decide what's a reasonable number.
                       DR. WALLIS:  So you're going to negotiate by words rather
           than by technical analysis.
                       MR. SULLIVAN:  Well, the technical analysis will give us some
           indication of when this ignition temperature is possible between the ten and 24
           hours time frame, and that's in the report.
                       The infinite time frame is not in the report.  The 100 hours is
           not in the report.  I suppose it could be.
                       DR. WALLIS:  You've got equations.  Presumably you can run
           them for any number of hours.
                       MR. SULLIVAN:  Yeah, the equations could be run, but --
                       DR. WALLIS:  We're told you can't do that.
                       MR. SULLIVAN:  Not by the EP guys.  The EP guys are
           simply telling us 24 hours would be more than adequate to take protective
           measures off site, and so if you'll give me chart that will go up to 24 hours, I can
           write an emergency preparedness regulation that will assure public health and
           safety reasonably.  That's kind of what we're saying here.
                       MR. LEITCH:  Can I probe a little bit as far as what you mean
           by emergency preparedness?  Full scope, I assume, you know, initially after
           shutdown, full scope is full scope, including sirens, emergency response
           organizations, ELF, Technical Support Center, all of that, Media Center, all of
           that kind of thing.
                       MR. SULLIVAN:  All of that stuff.
                       MR. LEITCH:  And in the last category, the eventually
           eliminate EP, I guess what I'm picturing is once you get down to that situation
           where you have ten hours before you reach ignition temperature, what you have
           at that point is no sirens, no requirements for sirens at any rate, no off site
           facilities.  What you really need at that point is one guy who's still standing who
           can call the local --
                       MR. LEITCH:  -- and his instructions are if for any reason that
           water goes down, call the local law enforcement agencies and tell them they've
           got ten hours to evacuate.
                       Is that it?
                       MR. SULLIVAN:  Somewhere more than one guy is still
           standing, I think.
                       No, I hope i Haven't confused you.  We're really talking about
           off-site EP requirements.  The on-site program would look a lot like an ISFS on-
           site program.  There's training; there's drills; there's people; there's pagers;
           there's call-outs.  You know, there's a --
                       MR. LEITCH:  Even an eventually?
                       MR. SULLIVAN:  Yeah, yeah.  If you have spent fuel under
           ISFS regulations, 72.32, there's a whole program.  It just doesn't involve off-site
           folks much.  The off-site folks are invited to training.  They're invited to
           participate in drills.  They're invited to an annual meeting, but that's about it. 
           There's no sirens.  There's no funded EOC.  There's no mandatory off-site drill.
                       But on site there's a fairly, you know, reasonable level of
           emergency preparedness.  It's not inconsequential.
                       MR. LEITCH:  So when we say eliminate EP, you're talking
           about eliminating off site.
                       MR. SULLIVAN:  It should have said eliminate off-site EP.
                       MR. LEITCH:  Okay.  So --
                       MR. SULLIVAN:  And really it's not totally eliminated, but that
           the requirements are very much reduced.
                       MR. LEITCH:  And on site would be similar to the ISFS
                       MR. SULLIVAN:  Yes.
                       MR. LEITCH:  Okay.
                       MR. SULLIVAN:  Which doesn't have a TSC and an EOF and
           all the stuff you're used to at power plants, but it's not inconsequential either. 
           It's a fairly robust program.
                       DR. KRESS:  Okay.  At this time I think we'd like to hear from
           NEI.  I think Lynette Hendricks and Bob Henry are here.
                       MR. SULLIVAN:  Thank you very much.
                       DR. KRESS:  Thank you.
                       PARTICIPANT:  Do we know how long?  Till 12:30?
                       DR. KRESS:  This will probably last another 20 minutes or so
           or half an hour.  Half an hour.
                       MS. HENDRICKS:  Good morning.  It's a pleasure to be here
           again, and thank you for the opportunity.
                       This is an overview, upside down overview, of what we'd like
           to cover today.  I'd like to talk -- I guess we're showing our hand here, is that
           we're going to return a little bit to our premise that we had the last time we were
           here, that the study is in large part an excellent compilation of outstanding work,
           but we think in a few critical area it isn't complete, and that the benefits, cost-
           benefit of the completion is definitely there and definitely worthwhile.  
                       I'm going to begin briefly to talk about some of the impacts
           that we see if the study is not completed, and I'm going to turn it over to Dr.
           Henry to go over a summation of what he believes would be necessary to
           complete the study, and then I'm going to briefly cover our views, industry
           views, on the options that are presented.
                       DR. POWERS:  And I know you'll include zirconium hydride
           ignition in your things that need to be completed.
                       MS. HENDRICKS:  That's right.
                       DR. POWERS:  Bob will cover that one, right?
                       MS. HENDRICKS:  Let's see.  Where am I here?
                       Here's some of the impacts that we view for failure to
           complete the study, and again, to sort of revisit where we are on that, and Bob
           will go into detail, but we think best estimate is possible with existing data for
           percent of ruthenium release, and we question whether the cask drop has the
           energy necessary to catastrophically fail the pool.  That's sort of where we're
           coming from here.
                       Failure to address these deficiencies in our view -- and I'll get
           into the discussion specifically when I talk about the options, but it definitely
           impacts the options shown and associated value impact and cost benefit of
           those options.
                       Also, going forward, these things once on the shelf, this issue,
           zirconium fires, is going to essentially be with us forever, and without completing
           the study and getting a sort of best estimate with a quantification of the
           uncertainties, you end up with a less than number, that the risk of the zirconium
           fires much less than 3E to the minus six, it's not going to be feasible to deal with
           a less than number in the context of PRAs, and yet we're already seeing that
           the number is -- you know, we are taking actions.  The example was for
           safeguards for operating plants based on this zirconium fire.
                       DR. WALLIS:  Excuse me.  I'm sorry.  I'm lost here.  Are you
           talking about NUREG 1738?
                       MS. HENDRICKS:  Correct.
                       DR. WALLIS:  Well, we were told it is complete, and you're
           saying it should be completed.  What's the truth here?
                       MS. HENDRICKS:  Well, we're suggesting that it be recalled,
           if you will, and completed subject to peer review.
                       DR. WALLIS:  Oh, you're saying it's a bad study and it should
           be revised.
                       MS. HENDRICKS:  It's a very good study to a point, and we
           think --
                       DR. WALLIS:  Yeah, I know.  That's what we always say when
           we want to criticize someone's work.
                       DR. POWERS:  I think that in my understanding, and correct
           me if I'm wrong, is that in doing this study there were several points that they
           reached a conclusion that said they were happy with that conclusion, but now
           they're taking things that would be logically follow-ons to that and using that in
           formulating their strategy here.
                       In addition to that, we have this question which Dr. Henry
           addressed to us last time about whether one of the initiating events was, in fact,
           a feasible initiating event or not.
                       I mean, I think the staff would admit to you that they cut off
           work at various points when they thought they had reached their risk
           assessment conclusions, but we already saw today, as you so deftly pointed
           out, that trying to draw conclusions about what the follow-on work would have
           shown to design their other strategy.
                       So it's not completed.  There needs to be a follow-on to get
           the technical data they need to draw these conclusions.  That's my
           understanding of it.
                       MS. HENDRICKS:  Yeah, and I agree with you completely, Dr.
           Powers, and to say that definitely I think the staff has stated that this less than
           three to the minus six number is well within the safety goal.  So good enough.
                       And maybe, well, I'd like to suggest as we look at the options
           later that maybe it's not good enough, and you have the question of how does
           it then relate in PRA space to relative risk of core damage.  How accurate are
           your value impact assessments going to be when you need to look at the delta
           in risk for cost spent if you are dealing with, again, a less than number, and it's
           going to be difficult, I think, to accurately quantify benefits.
                       One final issue is that when studies like this sit on the shelf,
           they are going to be used for other applications.  We had some indications
           talking to the staff, for example, that the cask drop results were going to be
           pulled directly into a PRA that's being done from the dry cask standpoint.
                       We cautioned them about that, and I'm sure they're going to
           look carefully at it, but I think the point is that pieces of this study will be used
           outside the context that it's, you know, as a very bounding number less than the
           safety goal.
                       With that I'd like to turn it to Dr. Henry.
                       DR. HENRY:  Thank you, Lynette.
                       I'd just like to touch on a couple of points.  As Graham just
           said, this is not a complete study so the second word up here can't possibly be
           correct in terms of a draft study, but we do believe it provides a good summary
           of the much needed information related to this, and it is a good foundation for
           evaluating the probability of losing cooling to the pool.
                       I think our biggest difficulties arise when we then get to using
           this for risk informed type of decisions as is discussed in the issue and options
           paper.  We believe that when you do this, it certainly would be very helpful to
           people when assessing issues and options to have a best estimate evaluation
           for the different types of initiators that are considered.
                       As Lynette said, the last time we had the pleasure of
           discussing with you, talking with you, we presented a technical database related
           to whether or not the cask drop could actually be something that would cause
           catastrophic leakage from the pool, and we surely don't find that to be the case,
           and we think that that should be put into the study in a very mechanistic way so
           that people truly understand what this risk is or is not.
                       The same thing is related to the issues that Dana has been
           talking about earlier with respect to oxidation, ruthenium release, et cetera. 
           There is a technical basis out there.  We suggest that that technical basis be
           formulated in a way that we could make use of it through the current evaluation.
                       In particular, if we look at the screen criteria, which I think are
           very well founded, the two that got my attention is would a risk informed
           approach help to effectively communicate a regulatory decision or situation, and
           of course, here you want to have the best technical foundation that you can
           have, and that, of course, trips to the success criteria number five  or screening
           criteria -- excuse me -- that says if you have information or analytical models
           that exist or are of sufficient quality or could be made of sufficient quality to
           really support that kind of decision.
                       Certainly in the term of the cask drop, I think that's clearly
           there.  In the term of zirc oxidation and the release of ruthenium, I believe that
           it's there.  That's my opinion, but I think that it should be put in the form where
           it's a sound technical basis, and it's made use of instead of we just can't use
           hand waving in this type of assessment.  It's too important.
                       In particular, I won't use all of these in the interest of time
           because I know you're running a little bit behind time, but a couple of things
           here that I find of particular importance is once the study is done, it's amazing
           how many different ways these things get used.
                       I think it is certainly as it says here, difficult to provide the
           necessary foundation for risk informed decision making without having
           something, without having an analysis, which is a best estimate.  I mean, what
           is it you're really talking about?
                       The best estimate also needs to represent the uncertainties
           involved, and without using the technical basis in something in a quantitative
           manner, then you're really not sure what it is you're coping with.
                       DR. WALLIS:  Why don't we have the only CRS?
                       DR. KRESS:  Sounds like something we've said before.
                       DR. WALLIS:  We've been saying that for years.
                       DR. HENRY:  Well, I already travel enough.
                       After a study is completed, the results are likely to be used for
           other tangentially related studies, and if you don't have a sound description, you
           know, well informed basis that you've drawn from that people are forced to then
           live by when they use those studies, you have no control over how those
           numbers get used.
                       DR. WALLIS:  I guess you're saying all of this with the
           implication being that these guidelines have not been followed in some way by
           the NRC?
                       DR. HENRY:  Well, I think particularly with the cask drop.  I
           think that's one that should be very clearly -- the technical basis should be put
           out there.  I think it relates to issues of EP that we were just talking about
           because that is the issue unless you're talking huge seismic events.  We're not
           talking about EP related items here.
                       So we want to make sure that we're communicating what's
           really known in a technical community.
                       One of the places where I had a small part of how the number
           got generated, I remember why it got generated.  I also saw how it got misused,
           and I just put this example down, is in the Swedish reactor safety study, which
           the people that did that had their own bent on what they wanted to accomplish
           in that study, but it was paid for by the Swedish government.
                       And they say in the study that they are using WASH-1400
           methodology.  One of the places where I thought they grossly misrepresented
           what was done was in the area of steam explosions.  WASH-1400 used a
           number of ten to the minus two because at that level, that issue was no longer
           risk significant, and we didn't have to go through all of the weeping and
           gnashing of teeth from then on.  So it was a compromise, and it's all the further
           the number had to be taken.
                       They turned this number around and said, "Well, it's ten to the
           minus two.  Those are the experts.  We're not the experts, but they gave us the
           number, and we have three places instead of one where it applies.  So we'll
           make it three times ten to the minus two."
                       And just forced it into something which now was risk
           significant because they wanted it to be that way, and then when they showed
           the consequences of all over northern Europe, that was one of the first grains
           of sand in the oyster that brought down Barseback, and so there was no control
           of how it got used.
                       And I think we have to be concerned about that because we
           didn't really say at the time we're just going to make this number the way it is
           because from here on it's not risk significant, and below that number maybe
           people disagree, but the disagreements don't matter.
                       This next table is just abstracted from that Swedish reactor
           safety study, and you can see this is the WASH-1400 number, and they merely
           said, "We're going to use something three times that because we have three
           different places in the RCS and the containment where this could happen."
                       The next you've already seen before, but this is just things
           that we believe are strong parts of the technical basis, things that are well
           known that should be included in the study, and in the interest of time, I know
           Lynette has a few other things to say, too.  I won't take you through that
           because we talked about it the last time, but the real issue is we strongly
           recommend that the technical basis be formulated and used to the best ability
           that we can use it now.
                       So in conclusion for this part, we believe that a best estimate
           evaluation is essential to communicate what we really know about the subject
           here, the cask drop being the one that we think there's a very clear basis on,
           and even thought it's a completed study now, I think a peer review of that would
           still be most helpful, and it certainly would be very helpful in the public arena,
           which these types of studies get reviewed and used.
                       MS. HENDRICKS:  I'd like to go now to our analysis on the
           specific options.  For the safeguards option, the way we read the -- and I'll
           always be referring to the option that the staff indicated a preference for, and I'll
           characterize it and then give some insight on what I think issues are with the
           option as proposed.
                       For safeguards, the way I read the option, and I think it's still
           correct after listening to the discussion earlier, is that you will start out having
           to protect against the design basis threat analogous to what is existing for
           reactor operations with the difference that you'll have a specific five rem at the
           site boundary standard that you're working against.
                       A number that the staff put in the options paper that I think is
           very important is that they equate that to a need for five armed guards, and the
           point I'm going to try to be conveying throughout these options is when you're
           decommissioning cost is people.  Cost is the number of staff that you have to
           carry forward is a good way to think of it, and for these five armed guards for the
           first part of the option, it's not really five because you have to go around the
           clock.  It may be 15 to 20, and when you do that, you're talking about an amount
           of, let's say, a low estimate would be $2 million a year.
                       So just to kind of put a bound around the costs, that's what
           we're talking about.
                       The "or" I think is the option that the staff indicated that you
           could demonstrate through plant specific analyses if the fire is, in fact,
           precluded, and so your standard then doesn't become one of defend against
           the frontal assault by these adversaries in the design basis threat.  You've
           precluded it, and then you're in more of a standard that's a little more equivalent
           to this, but not quite the same.  It's more lost of control, call the local law
           enforcement.  So that's the difference.
                       The specific indication that they gave on how you could
           demonstrate that the fire was precluded, we talked earlier about design
           features, heat up analysis.  They also referred to mitigating actions, including
           response by law enforcement before the fire commences, and this makes a real
           important point that I wanted to emphasize.
                       The timing is very different for this event compared to a
           reactor, and even in the worst case situation, the two or thee hours, the thing
           with the safeguards option is you regain control of the facility essentially
           immediately.  So your opportunity to mitigate is there. 
                       It's not like the seismic event where you can still claim some
           mitigation capability, but it can be questioned on the basis that the magnitude
           of the seismic event may render some of your mitigation uncertain.
                       And I'd also like to point out that one of the industry
           commitments that's referenced in the study is we do have a commitment for
           capability for remote access such that if the pool was drained without undue
           concern for the radiation hazard, you could have a mechanism to try to reflood. 
           I think it was pointed out this morning it's not so important to reflood as much as
           it is to spray the core in the pool such that steam cooling will remove the heat
           as it's generated and prevent you from getting to the critical temperature for the
           zirconium exothermic reaction.
                       DR. POWERS:  Have we ever done that?
                       MS. HENDRICKS:  Pardon?
                       DR. POWERS:  Have we ever done that experimentally, take
           a bunch of fuel rods, let them get warm, and then spray some fog or something
           like that over that and see if that, in fact, keeps -- the steam cooling actually
                       MS. HENDRICKS:  No, I guess I'd have to say I haven't.
                       DR. WALLIS:  But it's predictable.
                       DR. POWERS:  Well, you know, I wonder how predictable it
           is because the things I'm familiar with, it's steam and steam, but now we have
           steam and air, and I don't know what happens in steam and air.  I don't know
           what happens with irradiated clad.
                       DR. WALLIS:  Yeah, the cooling isn't so bad.  It's the
           chemistry, I think.
                       DR. POWERS:  Yeah, I'd like to know what kind of chemical
           reactions actually do occur.
                       DR. HENRY:  I can't remember the exact references now, but
           there are references out there, Dana, which are steam and air sprayed in their
           overheated surfaces.  Condensation is obviously much more susceptible to
           small air concentrations than evaporation is.  Evaporation just depends upon
           local contact.
                       But as Graham says, the chemistry obviously is a little more
           complicated with steam and air.
                       DR. POWERS:  I just don't know what it would be because,
           well, irradiated clad, especially high burn-up irradiated clad, and quite frankly,
           that's the ones you're worried about, is the more recent off-loads, which are
           going to be more highly burned than the things in the pool right now, and I have
           no idea what exactly happens in those kinds of circumstances.
                       DR. HENRY:  Obviously if you're going to have to spray
           anything, you'd like to spray at the lowest temperature possible. 
           Thermomechanically it's much better, but there are data taken with sprays on
           surfaces in air that effectively remove heat.  That's not an issue.  The chemistry
           is, again, more complicated.
                       DR. WALLIS:  You're also getting the droplets into the interior
           of a bundle.  That's not a trivial matter.  You're going to spray somewhere.
                       DR. HENRY:  You want to spray somewhere, and the best
           thing you could have is to begin to at least accumulate some films that drain
           down on the surfaces.
                       DR. POWERS:  I had another question on your previous
           viewgraph.  You began that with a discussion of the cost, and until we have
           provided adequate protection to the public health and safety, we really can't
           consider costs.  So you must have some idea in your mind in bringing up costs
           what adequate protection to the public health and safety is.
                       Can you kind of equate that?
                       MS. HENDRICKS:  Well, I don't think it's an absolute number,
           but I think when you do a cost-benefit, you look at the delta.  If you're going to
           spend $2 million, can you demonstrate that there will be some increase in
           protection of the public as you take it all the way out through, you know,
           eventual exposure to the public?
                       DR. POWERS:  Okay.  So you would come back in saying
           you really do need this probability of sabotage.
                       MS. HENDRICKS:  I don't know whether it's wise to go there. 
           Probably not, but here I go.  Whoever said I was wise?
                       DR. POWERS:  I was definitely leading you to a trap.
                       MS. HENDRICKS:  I think actually that the issue earlier about
           whether you can apply probability to the probability of the event happening, I've
           never understood really why not.  I mean, you have crime statistics.  You have
           a certain number of these events of any type that have happened, let alone
           have they happened to facilities that are hardened targets where the probability
           of these people going for those targets is admittedly low.
                       So I can't help but think even if you didn't have a perfect value
           and perfect methods, that you could do an awfully law in that area in addition
           to the mitigation potential and some of the other things that were talked about.
                       But in terms of sort of giving an absolute indication of our
           industry views on the options, I think it's difficult to do so because we haven't
           had any opportunity to comment on the safeguards analyses paper that's being
           prepared which will give us, I think, a sense of how feasible it will be to get to
           the "or preclude" part of the options such that you could potentially reduce your
           staff significantly, which is where the savings would be; get rid of some number
           of the armed guards, and that's where the cost savings would be.
                       And then some of these other things are sort of the comment
           that any change to the adversary could invalidate the entire program.  That's
           sort of just a constant whenever you talk about safeguards, but I think it's
           always important to reinforce that.  We're always on sort of a tightrope when
           you come to the safeguards area from that perspective.
                       And then just to note that the standard does say preclude a
           zirconium fire, and you know, there's no such thing as zero, but I would like to
           see when we talk to the EP option of getting a little more acknowledgement of
           that approach, that we do have -- you know, the word "preclude" is used, and
           it doesn't seem to be reflected in the EP analysis when you start talking about
           difference in depth.
                       The insurance option, I think it was covered pretty clearly.  We
           may question the $100 million, and we did when the SECY was originally put
           out, that even 25 million is probably excessive.  It's more than has ever been
           spent on clean-ups that would involve a truck spill or some other local
                       But it doesn't get to really in the end matter that much from
           what I've gleaned from talking to folks because your premiums aren't
           necessarily going to go down that much ironically if your coverage goes down
           from 100 million to 25 or 50 million.
                       DR. WALLIS:  What is the premium for 100 million?
                       MS. HENDRICKS:  It's difficult to quote a number.  I think if
           you're a single unit facility in decommissioning, it's a couple million dollars.  A
           good part of that -- if you're a multi-unit facility, it's an increment, and it's --
                       DR. WALLIS:  So they're charging you two million for 100
           million coverage?
                       MS. HENDRICKS:  No, no.  That's what you'd be going down
           from.  You'd get a significant reduction, plus you wouldn't have to have the
           liability of potentially participating in the secondary pool.
                       DR. WALLIS:  So we don't know how much the premium
           would be.
                       MR. ROSEN:  The premium is not going to be two million 
           year for primary coverage if that's what you meant.  I don't think you did, but --
                       MS. HENDRICKS:  No, I'm saying as an operating plant,
           when you had --
                       MR. ROSEN:  Yes, as an operating plant, it could be that
           much, but for a shutdown --
                       DR. WALLIS:   In other words, there's no quotes yet for
                       MS. HENDRICKS:  It would go down significantly.
                       MR. ROSEN:  Well, we're talking for property coverage, two
           million a year.  Primary coverage at an operating plant is much less than that. 
           I think the coverage we're talking about here, your first bullet, this is Price-
           Anderson primary coverage you're talking about, right?  Would be in the order
           of tens of thousands of dollars per year, not millions.  Very inexpensive because
           it's so unlikely that would be called upon.
                       MS. HENDRICKS:  It's obviously very different than the
           number I was quoted, but I certainly accept your first-hand experience.
                       But anyway, the bottom line for insurance is we don't have
           any issues with the option the staff is proposing.  It seems very rational and risk
                       The EP option, as Randy, I think, deftly explained, you get
           some reduction in the first year, and the vision is complete elimination of off-site
           EP at five years.  Again, this is a bit like safeguards analyses.  It's difficult to
           quantify the benefits.
                       EP is very analogous to safeguards cost, as the number of
           people.  So until you get into the specifics, as they had indicated through the
           regulatory guide of exactly what you would be exempted from in the reduced
           period, and ultimately it's hard to put a benefit in terms of cost savings on what
           they're talking about here.
                       In terms of, you know, EP space, you're obviously not in the
           position of feeling comfortable going completely on a risk basis, and so you
           acknowledge up front that you are in defense in depth space, but I think having
           said that, even though defense in depth is a great concept, I think it's incumbent
           upon the agency to demonstrate that you really have defense in depth, that you
           have something quantifiable that you can point to for the cost of maintaining the
           off-site EP in limited form until the five-year period.
                       The reason I question whether you can actually quantify
           defense in depth is it may be nonexistent if ad hoc EP is just as effective shortly
           after shutdown.  That was discussed at, I think, great length in the technical
                       And finally the technical report also acknowledges that it's
           optimally of limited effectiveness and causes delays if you're talking about an
           earthquake of .6 G, and it goes on to say if it's in excess of .6 G, evacuation is
           virtually -- I think they come down and say it's virtually not going to happen. 
           You get no credit for it at all.
                       When we were here last time, we had a graph that tried to
           break out the percent of the risk of pool failure by seismic magnitude, and what
           the graph showed was in excess of 90 percent of the risk is attributed to
           earthquakes in excess of 1 G, and that's really not hard to come to intuitively
           because of the robustness of the pool.
                       The HCLPF based on very conservative analyses that the
           staff did is .5 G.  So it's logical that the biggest contribution of the risk is going
           to come from enormous earthquakes, and when you have then the
           acknowledgement that you are going to get basically zero benefit, zero
           evacuation is going to be possible, again, I bring the question back to defense
           in depth is a good concept to explore, but can you actually point to it and say,
           "We have.  We can provide defense in depth"?
                       Otherwise you may be misleading the public to talk about a
           concept when, in reality, it's not going to really materialize.
                       Another thing that I guess leads us to that question is the fact
           that, again, to reiterate, we don't believe the cask drop is a realistic event, which
           leaves essentially seismic and sabotage as the issues that you're talking about,
           and sabotage, again, you're using the standard of preclude and potentially --
           and again, unlike the seismic event, you have recontrolled the facility in very
           short order, and unlike the seismic event, your mitigation capability should
           remain intact.
                       So I guess to summarize, we would recommend that the risk
           study be completed and peer reviewed, and that efforts be made to derive a
           best estimate using existing data on ruthenium release and also cask drops,
           with an effort, of course, to quantify the uncertainties.
                       I've mentioned under EP and also insurance that in order to
           get these benefits, you have to meet the industry commitments as well as the
           staff assumptions.  One of these staff assumptions is that you will fulfill the
           requirements of the seismic checklist, which because of the -- it wasn't based
           on a large number of plant fragilities, is acknowledged to be rather conservative. 
           The net effect of that is that our experts indicate that to comply with the checklist
           you're getting into sort of an engineering evaluation of the seismic
           considerations around the pool, and we estimate that's going to cost about 50
           to $100,000.
                       And then certainly if you failed the checklist and get into any
           kind of a situation where you're going to go back and ironically maybe do any
           engineering to improve the situation when you're going to, you know, a few
           years down the road tear it apart anyway, but it certainly gets into real money
           very quickly if you have to go back and do much structural work to comply with
           the checklist.
                       And finally, the recommendation that the EP reductions be
           commensurate with risk and some quantifiable assessment of the defense in
           depth that you actually get with EP.
                       DR. WALLIS:  If we could quantify defense in depth, that
           would be a wonderful thing.
                       MS. HENDRICKS:  Well, I think in this case you can quantify
                       CHAIRMAN APOSTOLAKIS:  Isn't that what PRA does?  It
           quantifies defense indefinitely.  Am I missing something?
                       DR. POWERS:  That's what it misses a great deal.
                       CHAIRMAN APOSTOLAKIS:  Huh?
                       DR. POWERS:  It misses it a great deal.  Your PRA does not
           address the sabotage issue at all.
                       CHAIRMAN APOSTOLAKIS:  No, no, no, no, no.
                       DR. POWERS:  Defense in depth does.
                       CHAIRMAN APOSTOLAKIS:  It says quantifiable defense in
           depth.  If you want to quantify defense in depth, that means you want to do a
                       DR. POWERS:  No.
                       CHAIRMAN APOSTOLAKIS:  How else would you quantify
                       DR. POWERS:  Well, certainly not with PRA because you --
                       CHAIRMAN APOSTOLAKIS:  How else would you quantify?
                       DR. POWERS:  We're going to ask her how to do that here
           in a second.  I think that's what Graham just asked, as a matter of fact.
                       MS. HENDRICKS:  I think it's a very fair question.  I think you
           can do it qualitatively or quantitatively.  Qualitatively you can ask --
                       DR. WALLIS:  But you can't qualitatively quantify.  Now, wait
           a minute.
                       MS. HENDRICKS:  Well --
                       CHAIRMAN APOSTOLAKIS:  Yeah, because I mean that's
           exactly what PRA does.  It quantifies the level of defense you have.  So if you
           want quantification, that's what you are calling for.
                       Now, that doesn't mean you're going to do a small LOCA.  I
           don't mean PRA the way we do it for -- I mean the philosophical approach. 
           That's exactly what it does.
                       Now, whether it's incomplete, that's a different story.  Whether
           you don't believe it.
                       MS. HENDRICKS:  The example is if you acknowledge that
           you're looking at the primary risk from an enormous seismic event and you can't
           evacuate people, then you can quantify that defense in depth from fancy
           evacuation procedures aren't going to do you much good.
                       DR. POWERS:  I think what you really said there, to avoid
           provoking the Committee, you would have said quantify the benefit --
                       MS. HENDRICKS:  Thank you.
                       DR. POWERS:  -- derived from these measures, which I think
           you've made the point.  We ought to look and see if there's some benefit there.
                       MS. HENDRICKS:  Thank you, Dana.
                       DR. POWERS:  Because otherwise defense in depth is a
           difficult thing to do for quantification, and that's why I was trying to put it in the
           context of fire.  You know, we're certainly going to try to prevent the events from
           occurring.  That's the first step in fire protection.  We're going to suppress the
           effects of a pool drain-down or something like that.  That's why you've got fog
           nozzles and things like that.
                       And then we're going to protect the vulnerable components,
           which in this case is the public, from the effects of fires that we failed to
           suppress, and what you're saying is you may not be able to do very much there. 
           And you ought to know how much you're going to do before you spend a lot of
           money on it. 
                       That seems fair.
                       MS. HENDRICKS:  Exactly.
                       DR. POWERS:  It seems fair.
                       MS. HENDRICKS:  Thank you for your mentoring.  That's a
           wonderful skill, to learn how to not provoke the committee.  I will learn.
                       DR. POWERS:  We spend a lot of time discussing defense
           in depth here.
                       MR. BAGCHI:  Mr. Chairman, can I quickly share a
           perspective on cask drop?
                       CHAIRMAN APOSTOLAKIS:  Can you identify yourself to us?
                       MR. BAGCHI:  Yes, sir.  My name is Goutan Bagchi.  I'm the
           Senior Advisor in the Division of Engineering.
                       I understood from previous discussions that there were some
           comparisons back 20 years ago based on every (unintelligible) missile studies,
           which in the report itself concluded that the analytical predictions were way too
                       The basis for the conclusions that were presented in the NEI
           slide today and the previous time was perhaps this, that the (unintelligible)
           comparisons were too conservative and, therefore, the implication is that the
           cask drop is now going to lead to some kind of a failure of the pool slab.
                       There are clearly some kinds of pools where the pool slab is
           supported by the soil medium where the failure is not very likely, but there are
           other cases where the slab is way up in the air, as in some or most of the BWR
           spent fuel pools.  A 100 ton cask falling through maybe 30 feet depth is going
           to produce a significant amount of impact force that is, in my opinion, going to
           lead to a failure, and I'm going to tell you why.
                       Because, you know, the 20 year analytical capability, 20 year
           old analytical capability has now been substantially improved, and our
           colleagues in NMSS have undertaken a study where drops were made and then
           comparisons were made by using more recent techniques, and they have
           plotted various deceleration diagrams based on those studies, actual studies
           and comparisons with analytical tools.
                       And based on that I got a deceleration force and applied that
           to the full slab, not supported by soil or anything, but the slab by itself, and there
           is no way that kind of a deceleration force will be withstood by a pool slab,
           which is, you know, not supported by anything else.
                       So when you say that the cask drop is way too conservative,
           please take a look at more recent data, more facts that have been substantiated
           by even NRC initiated studies.
                       DR. HENRY:  My response to that, I think the last time that we
           had the opportunity to talk to the committee we did look at at least the most
           recent data, and we asked if there was anything that we didn't have, we would
           sure like to know about it because the data that we had -- give me a second
           here.  Let me find the right one -- included the studies that BNFL did here up
           through 1993, and they were with full size casks dropped from heights at least
           up to five feet, and those just barely made a dent in the concrete.
                       We're not here to argue which is right or wrong.  What we
           really would like to do is make sure that the technical basis is clearly spelled out
           in the report and where the conclusions come from because I didn't even see
           any of these tests referenced in the report.
                       Now, if there were calculations behind the report that we didn't
           know about, we'd be more than happy to hear about them, but all we're really
           here to plead for is let's have the technical basis clearly defined, especially the
           experimental basis.
                       MR. BAGCHI:  Those studies, those study reports came from
           the NUREG CR that was developed, and comparisons were made. 
           Deceleration forces were given.  You can take that and apply to the slab.
                       I don't know that you have had any of your structural experts
           look at that.  I am a structural expert as a professional engineer, and I looked
           at that.  My conclusion has been that pool slabs that are not supported by any
           soil are not going to withstand that kind of a drop.
                       DR. HENRY:  I'm not here to impugn your capabilities, you
           know.  All I'm saying is if you've done those analyses, I didn't see those
           referenced in the report and anything I could really point to.
                       I mean, this is a very important part of the study.
                       MR. BAGCHI:  I'm confused about what you're implying here
           by this slide.
                       DR. HENRY:  Give me a second then.  I mean this is the test
           that was done.
                       DR. WALLIS:  Which is what you talked about last time.
                       DR. HENRY:  The last time, and this is the damage that was
                       MR. BAGCHI:  That's not my point.  These are not one-to-one
           comparisons to what I was referring to, a slab purely unsupported by anything
                       My point was whether or not those references were included
           in our report.  The answer is, no, we didn't because we had a very specific study
           done on a pool,  Vermont Yankee pool, and the results are available in the
           NUREGs here.
                       DR. HENRY:  They are?
                       MR. BAGCHI:  Yes.  There was a finite element study, and I
           think your implication was that that study used rather conservative assumptions.
                       DR. HENRY:  But where were those in the report?  The
           conclusions may have been there.
                       MR. BAGCHI:  It was a reference in our report, 1738.
                       DR. HENRY:  It may have been referenced, but I mean, that's
           all that was there.
                       MR. BAGCHI:  It is based on that finite element analysis in
           that report.
                       DR. HENRY:  I'll be more than happy to -- if you can send me
           that, I'd be more than happy to look at it because I'm most interested in it, but
           the other aspect is did you conclude from that that it's a catastrophic leakage
           of the pool?
                       MR. BAGCHI:  If there is a drop of 100 ton cask on a pool that
           is high up in the air and not supported by soil, my personal conclusion is that,
           yes, it's going to fail catastrophically.
                       DR. HENRY:  And in that analysis, did you include the water
           and the other fuel that's already there as any kind of shock absorber
           mechanism, regardless of what its configuration?
                       MR. BAGCHI:  It was -- in that analysis it was assumed to fall
                       DR. HENRY:  But since this is an initiating event, there would
           be fuel there.  There would be water there also because your whole basis was
           on rates of deceleration.  So the more you slow it down in advance of hitting the
           concrete, the more you spread out the load, right?
                       MR. BAGCHI:  If in the path to fall to the floor there is no
           intervening fuel, then you cannot assume any resistance from that.
                       DR. HENRY:  Or the water.
                       DR. WALLIS:  It seems we have a technical debate going on 
           with the results somewhere else.
                       DR. KRESS:  This seems like something you guys could
           debate --
                       MR. BAGCHI:  I just wanted to say that there was a study that
           updated the analytical methods and compared that against the drops, and
           deceleration values are clearly relevant.
                       DR. POWERS:  I thought the exchange was helpful, by the
           way, because it puts context on two different analyses that we've seen.
                       DR. KRESS:  Yeah.
                       DR. POWERS:  And it's a fairly -- I mean it's a non-trivial issue
           to resolve as whether this is an initiating event or not.
                       DR. KRESS:  Are there any other questions or comments
           from the committee?
                       (No response.)
                       DR. KRESS:  Well, thank you very much. 
                       MS. HENDRICKS:  Thank you.
                       DR. KRESS:  We appreciate the input, and we'll turn it over
           back to George.
                       CHAIRMAN APOSTOLAKIS:  Thank you, Tom.
                       Yeah, I'd like to thank also the presenters today, the staff, and
                       How about if we have a 45 minute lunch break?
                       DR. KRESS:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  So 1:30, 1:30.
                       (Whereupon, at 12:40 p.m., the meeting was recessed for
           lunch, to reconvene at 1:30 p.m., the same day.).                             AFTERNOON SESSION
                                                    (1:30 p.m.)
                       CHAIRMAN APOSTOLAKIS:  Our next topic is the need to
           revise 10 CFR, Part 54, requirements for renewal of operating licenses for
           nuclear power plants.  Dr. Mario Bonaca is the leader.
                       DR. BONACA:  All right.  Good afternoon after lunch.
                       All right.  On August 1999, the Commission requested the
           staff to provide internal analysis and recommendation to the Commission on
           whether it would be appropriate to resolve generic technical issues raised by
           the industry in many cases through rulemaking, and we are at the point where
           the staff has concluded its own evaluation, and we're going to hear from them
                       So I'll turn over the meeting to Mr. Grimes.
                       MR. GRIMES:  Thank you, DR. Bonaca.
                       My name is Chris Grimes.  I'm the Chief of the License
           Renewal and Standardization Branch.
                       And rather than repeat the purpose of the meeting too many
           times because the staff presentation is going to make the purpose of the
           meeting clear and our message, hopefully, will be clear to you, and we request
           that the committee support our view at the conclusion of this presentation, that
           there's no need to revise the license renewal rule at this time.
                       And with that I will turn over the presentation to Dr. Sam Lee. 
           Sam was the team leader who headed up the development of the regulatory
           guidance and standard review plan for license renewal, and he's going to
           explain the extent to which we've explored the possibility of rulemaking.
                       DR. LEE:  Yeah, my name is Sam Lee.  I'm from the License
           Renewal and Standardization Branch, NRR.  And with me here today I have
           Greg Galletti, Brian Thomas, and Steve Koenick coming up here from the NRR
           staff so that they will be here in case your questions they can answer.
                       About two years ago in response to SECY 99-148, the
           Commission directed the staff to prepare the improved license renewal
           guidance document that used the generic lessons learned, the core report, the
           standard review plan, and the reg. guide for license renewal.
                       In the same SRM, the Commission also directed the staff to
           prepare a recommendation on whether the license renewal rules should be
           revised.  And we have held a public meeting to get comments on whether
           there's a need to review the rule, and we plan on providing our recommendation
           to the Commission by the end of August.
                       The ACRS has previously provided their comment in a letter
           responding to the improved generic guidance documents, and the ACRS
           indicated that the staff should encourage applicants to provide scoping process
           results in the application, and that would have the review process and to make
           the information more transparent.
                       The staff agrees with this committee.  The initial license for
           new applicants have provided this information for staff review, and also the
           standard review plan and industry guidance NEI 95-10 indicate that such
           information should be provided.  The staff recommendation is that we will
           continue to work with industry to clarify the guidance document that address
           these comment.
                       MR. GRIMES:  Excuse me, Sam.
                       I would like to point out that we're making a distinction here
           between acting on a recommendation to provide the information in a voluntary
           way as opposed to codifying a requirement for the results of the scoping
           process in more detail as a requirement in the rule.
                       So all of these comments relate to possible changes to the
                       DR. LEE:  Okay.  The Union of Concerned Scientists originally
           planned to attend the public meeting.  However, they were not able to.  So they
           provided comment and a letter, and they have three comments.
                       The first comment, and the Union of Concerned Scientists,
           UCS, indicated that the license renewal rules should be revised to add the rad
           waste system into the scope of license renewal because the failure of such
           systems can cause excessive release of radioactivity into the environment.
                       The UCS had previously provided this as a rulemaking
           petition to establish regulating this separately under the petition process.
                       The second comment is that the UCS cited cases where the
           equipment had failed because of aging and caused plant shutdown since last
           year.  Since the beginning of last year they cited about eight cases.  So their
           comment is that we should define the minimum standards for an effective aging
           management program.
                       We have looked at the eight cases that were cited by UCS. 
           Only one case that relates to the Indian Point 2 steam generator degradation,
           related to passive component, and that's already been addressed in the Gall
                       The other cases relate to active components, such as
           transformers, sonar (phonetic) valves and breakers.  Active components are
           addressed by the current regulatory process, and they are not subject to the
           additional requirements of license renewal.
                       And regarding the effective aging management programs, the
           guidance documents, the improved guidance documents evaluates programs
           using ten program elements, such as the scope of the program, the problem
           with this monitor acceptance criteria, corrective action, operating experience.
                       The staff recommendation is that we'll clarify the guidance
           document to address this problem, and in particular, relate to the element of
           operating experience.
                       The last comment is that the staff is accepting applicant
           commitments to perform one time inspections many years from now, to confirm
           that either aging is not occurring or it's occurring at such a slow rate that you do
           not need an aging management program.
                       UCS comment is that should the one time inspection be real
           aging degradation, the licensee at that time of renewal license would cite back
           the protection if the program need to be changed.
                       The staff believes that if aging degradation is detected by one
           time inspections, the plant's QA program would identify the appropriate
           corrective action, and should the staff consider changing previously approved
           aging management programs, back-fit is the appropriate regulatory process to
           evaluate the needed changes.
                       And again, we will consider clarifying the guidance document
           to address the one time inspection comment.
                       Okay.  The industry through NEI provided the comment and
           letter, and NEI indicated that rulemaking is not necessary at this time, similar to
           what Chris had indicated earlier, and NEI is going to make a separate
           presentation after the staff.
                       Our conclusion, the staff recommendation.  Based on the
           experience of renewing license renewal applications and developing the
           improved license renewal guidance document, the staff believes that
           rulemaking is not necessary at this time.
                       The improved license renewal guidance documents are living
           documents, and we plan on clarifying and updating them to address these
           comments and also additional experience from future license renewal reviews
           and the ongoing NEI demonstration project in which industry is using these
           documents to prepare sample application sections.
                       And the staff will continue to monitor the license renewal
           process and experience and other rulemaking activities done by license
                       That concludes our presentation.
                       DR. BONACA:  On slide number four under the first comment
           by UCS, your recommendation was to address rad waste systems under
           rulemaking petition process.  Could you expand on that?
                       MR. KOENICK:  Yes.  What we do is in accordance with some
           interim guidance that NRR issued in February, we have a petition for rulemaking
           process.  As part of this process, this is also consistent with NUREG ER-53,
           which is NRC regulations handbook, and what we do is we have a working
           group with disciplines represented, and we come up with a recommendation
           that goes through a Petition Review Board, and then we document our
           resolution, and then follow up with the necessary actions.
                       DR. BONACA:  This is not inconsistent then with your
           recommendation of not changing the rule right now?
                       MR. KOENICK:  Well, the petition is pre-dispositional now.
                       MR. GRIMES:  This is Chris Grimes.
                       I'd like to point out that if the petition review process should
           conclude that the rule should be reviewed to address rad waste systems, and
           that would go to the Commission then for approval of the rulemaking plan, and
           if that should occur as Dr. Lee pointed out, that would be an opportunity to
           change the rule and perhaps do some of these other things that we've
           recommended clarifying in the guidance.
                       But right now we are not taking on that, the decision for the
           petition.  That's going through NRR's process.
                       DR. BONACA:  Okay.  Thank you.
                       DR. UHRIG:  I have a question.  Could you comment on how
           monitoring rulemaking activities will provide opportunities to improve the license
           renewal process?  This is the last statement on page 6.
                       DR. LEE:  I guess some of the rulemaking activities, for
           example, okay, like ongoing there's a proposed rulemaking on  POP 2
           (phonetic), on the formal hearing process, to quote the informal hearing
           process, and if that would happen, we'll make the conforming changes in POP
           4 (phonetic) to go into an informal hearing process.
                       And also there are other rulemaking activities, such as 55(a)
           on in-service inspection.  That's the referencing ASME code.  If the ASME code
           decides to take up certain aging activities and goes through 55(a), then we'll
           probably make the conforming changes in POP 54 (phonetic).
                       DR. UHRIG:  Thank you.
                       DR. BONACA:  Any other comments for Dr. Lee?
                       MR. GRIMES:  Dr. Bonaca, this is Chris Grimes.
                       I would like to sort of add as a postscript that when the
           Commission issued the staff requirements memo, I think at that time there was
           some -- we had mentioned some possibility of trying to incorporate generic
           aging lessons learned into Part 54 in much the same way that the generic
           environmental impact statement for license renewal is incorporated in Part 51.
                       We also discussed that at the public meeting, and we
           concluded that the need to maintain GALL is a living document and continue to
           fold back experience and expand and clarify GALL as a tool does not lend itself
           to rulemaking.
                       And so implicit in this recommendation was a specific
           consideration of whether or not to codify GALL in Part 54, and we similarly
           concluded that that would not be appropriate at this time.  We may want to
           consider that later if GALL matures to the point where we think it's sufficiently
           stable to codify it in rule, but we don't believe that it's right for that opportunity
                       DR. POWERS:  I wonder, Sam, if you can explain a little bit. 
           The Commission asked you to do this what they called a detailed analysis and
           report back to them.  We really haven't done a license renewal study completely
           through for BWR.  Why don't you just ask them for a little more time on this
                       DR. LEE:  For PWR?
                       DR. POWERS:  BWR.
                       DR. LEE:  Oh, BWR.
                       MR. GRIMES:  I'll tackle that.
                       DR. POWERS:  Sure.
                       MR. GRIMES:  We think we're sufficiently far along with the
           Hatch review that we haven't seen anything that makes the system distinctions
           any different from what we've learned in GALL as treatment of aging effects.
                       DR. POWERS:  Do you think you're in a position now you can
           go ahead and answer the Commission's question?
                       MR. GRIMES:  That's correct.  I don't think that we're going
           to learn so much more in the back end of the Hatch review or even the start of
           the Peach Bottom review that would change our view about the immediate
           question of whether or not rulemaking is going to substantially improve the
                       DR. BONACA:  Okay.  Any other comments from members?
                       (No response.)
                       DR. BONACA:  If not, thank you for the presentation.
                       I understand we have a brief presentation from the industry.
                       MR. NELSON:  I don't even know if I need to sit down.
                       MR. NELSON:  My name is Alan Nelson.  I'm a senior project
           manager with NEI.  
                       When they asked me if I'd like to give some brief remarks, that
           was before I knew that they were going to say they agreed with the industry and
           no rule was needed, but just the same, we'd like to go on the record today.
                       Basically you're aware we had sent some correspondence
           into Mr. Grimes on June the 4th.  Industry met with the Commission on June
           14th, Mike Huffman, and we met with the staff on June 28th, all expressing our
           interest in seeing that the no rule be forthwith in the near future.
                       Actually, we've watched three approved re-licenses, six units. 
           We have some experience under our belt.  We feel that the process is stable. 
           It's reasonable, and it's predictable.
                       As was stated by Dr. Lee, we're in the process of evaluating
           a demonstration project which would -- four applications which would determine,
           you know, the most efficient and effective way to provide applications looking
           at the year 2002 and beyond.
                       We don't believe even through that demonstration process
           that there would be a need for a rulemaking change, and essentially we agree
           with the presentation that was made previously.
                       So I appreciate the time you've given me, and it's less than
           a tenth.
                       MR. NELSON:  You're not going to let me off the hook that
                       DR. POWERS:  Maybe not quite that easy.  I wonder if you
           care to address the comments that have been made by the Union of Concerned
                       MR. NELSON:  As I stated, I've only been on this project
           about 30 days.
                       DR. POWERS:  Oh, okay.  It might be a little difficult.
                       MR. NELSON:  Yes, I'm not in a position to address that, and
           we certainly addressed it in -- I think we may have made comments on it before,
           but I'm not sure what they are.
                       MR. GRIMES:  This is Chris Grimes.
                       Just to make sure that the record is clear, first, Mr. Nelson
           said that no rule is necessary.  I want to make sure that it's understood there is
           a rule, and we're not proposing to change it, but in terms of the UCS petition to
           include rad waste systems was sent out for public comment, and I believe that
           NEI commented on behalf of the industry, and I think that we received
           comments from the industry related to clarifying the staff's expectations for
           aging management programs, for which NEI and UCS both, I think, have
           encouraged us to more clearly articulate the standards of acceptability for
           effective aging management programs.
                       So I think that the industry's comments would direct us
           towards pursuing that improvement in the guidance.
                       DR. BONACA:  And we have noted, too, you know.  We made
           some remarks in the last letter we wrote regarding, for example, small bore
           piping and lessons learned from Arkansas, whether that would justify changes
           to GALL.  We received a response that essentially GALL is, in fact, a document
           which is not completed in a certain way.  I mean, it is going to be updated to
           reflect this kind of experience and insights.
                       And I think it's appropriate not to have it codified.  That's just
           a personal judgment.
                       DR. UHRIG:  Chris, I noticed in the document handed out this
           morning that the comment period on the Turkey Point license extension
           application had been extended.  Is there a reason for this that's unique to
           Turkey point or is it something that's going to be done on all?
                       MR. GRIMES:  That was a direction that applies to all license
           renewals.  We had suggested that we were going to shorten the public
           comment period on the draft environmental impact statement from 75 days to
           45 days, which is what the law requires or what the regulations require, and we
           were doing so for reasons of process improvement efficiencies.
                       But the Commission felt that shortening the public comment
           period would damage public credibility of the process, and so they directed us
           to revert to the 75 days.
                       DR. UHRIG:  Okay.  Thank you.
                       DR. BONACA:  Any other questions?  If not, I thank you for
           your comments.
                       MR. GRIMES:  Thank you.
                       DR. BONACA:  Amazing to see such an agreement between
           the staff and industry.  It's good.
                       DR. POWERS:  There must clearly be something wrong,
                       DR. BONACA:  No, but I think that considering the amount of
           technical work that took place and so many issues that were debated, it's
           encouraging to see that there has been a real process of resolution.
                       And with that I wonder if any of the members have additional
           comments to provide.  We are going to write a letter, a report to give our
           perspective, too.
                       And with that I give it back to you.  I note that --
                       CHAIRMAN APOSTOLAKIS:  Excellent job, Dr. Bonaca.
                       DR. BONACA:  -- the meeting in --
                       CHAIRMAN APOSTOLAKIS:  Excellent job.  You run us back
           to schedule.
                       PARTICIPANT:  Perhaps he should run the rest of them there.
                       CHAIRMAN APOSTOLAKIS:  Oh, oh, oh.
                       CHAIRMAN APOSTOLAKIS:  What a mistake to welcome you
           this morning.
                       Well, the next presentation is scheduled for 2:15 on control
           rod drive mechanisms, and I think we should not start before the scheduled
                       DR. SHACK:  Especially since no one is here.
                       CHAIRMAN APOSTOLAKIS:  Yeah, that might make it a little
           difficult.  So we shall recess until 2:15.
                                   (Whereupon, the foregoing matter went off the record at 1:52
                       p.m. and went back on the record at 2:14 p.m.)
                       CHAIRMAN APOSTOLAKIS:  Okay.  We're back in session.
                       We have lost Dr. Shack.
                       The next item on the agenda is control rod drive mechanism
           cracking.  Dr. Ford, please lead us through this.
                       DR. FORD:  We had a joint meeting of the Plant Operations
           Subcommittee yesterday, the 10th of July, and a brief by NRR and the industry
           on CRDM housing cracking at Units 1, 2, and 3 and ANO.  This is the first time
           we've had such a briefing.
                       As you probably know, there have been many similar
           incidences of large diameter penetrations due through pressurized water at the
           heads in the last ten years abroad.  It was the first time in this country.
                       The objective of the meeting was to be briefed by the NRR
           and research and industry on these incidences with the specific request that we
           issue a letter giving our comments on the timeliness of issuing a bulletin on this,
           on these incidences, and also about the timeliness and appropriateness of the
           actions that are going to be taken.
                       And Jack Strosnider is going to lead the presentations.
                       DR. POWERS:  Let me understand a little better, Peter.
                       DR. FORD:  Yeah.
                       DR. POWERS:  It seems to me several years ago the French
           had some cracks in the --
                       DR. FORD:  That's what I was referring to.
                       DR. POWERS:  And it seems to me that at that time, the NRC
           reacted to that finding and went through and looked at all of -- asked the
           licensees to look and gave them all a clean bill of health.
                       DR. FORD:  They started at Bujay 3 (phonetic) in 1991 in
           France, Framatome.  I'll let Jack respond to the question about the NRC's
           response to those particular instances.
                       MR. STROSNIDER:  Good afternoon.  Is the microphone
                       My name is Jack Strosnider.  I'm  Director of the Division of
                       I appreciate the opportunity to talk to the committee this
                       The industry went first yesterday.  So I guess the staff will go
           first today, but hopefully you'll keep me from going into their time.
                       Anyway, but do you want me to start off to respond to some
           of the history there?
                       DR. FORD:  Yes.
                       MR. STROSNIDER:  Just briefly, if you go back to the
           discovery of cracking at Bujay and then additional operating experience leading
           into the mid-'90s, we staff did interact with the industry, and the industry
           provided an assessment of that issue, and we issued a generic letter in '97, 97-
                       The thrust of that generic letter basically was -- the response
           from the industry was what I'll characterize as an integrated industry program
           to monitor this situation, and they came up with a susceptibility ranking, and
           they indicated that the more highly susceptible plants would do examinations
           of the CRDM penetrations.  And they have been conducting those since that
                       And the idea was that the more susceptible plants could serve
           as leading indicators for what was going on with the fleet.  So that's why those
           inspections, actual eddy current examinations, have been going on.
                       In addition, licensees were committed under some prior
           bulletins back in the late '80s to do boric acid walk-downs and look for that on
           the head.
                       One of the things that was addressed in the safety evaluations
           supporting that activity was that axial cracks, you know, did not constitute a
           significant safety concern.  It was partially a matter of leakage, and it would be
           something that could be detected.  That was the expectation at that time.  It
           could be dealt with.
                       However, it was acknowledged that a circumferential cracking
           or cracking that could lead to a failure of a penetration were it to occur, that that
           would be a different situation.  That was addressed in the safety evaluations,
           and there was an expectation that the industry would inform the NRC if that sort
           of thing occurred, which is what has now happened.
                       So that's a little bit of the background.  Does that answer your
           question with regard to that?
                       DR. POWERS:  Yes.
                       MR. STROSNIDER:  Good.  I wanted to talk about actually
           five different things today.  I guess first of all, I just wanted to give a very general
           summary, a safety perspective on this.
                       Then yesterday we had some discussion.  The subcommittee
           focused on some specific technical issues that we were asked to address at
           today's briefing.  So I'm going to talk about those technical issues.
                       I also want to take a little bit of time to contrast the difference
           between what the industry has proposed to do and what the NRC, what the
           bulletin, in fact, is proposing, and that's something we didn't talk about
           yesterday, but I felt at the end of yesterday's discussion that it would be
           important to provide that perspective.
                       I want to talk a little bit then about some of the risk
           perspectives, and then about additional work that's planned either ongoing or
                       And finally, I'd like to talk about how this issue fits into the
           agency's four performance goals.
                       So just to start off with a summary, and I'll talk in a little more
           detail in a later slide about the risk aspects of this, but just to give a general
           safety perspective, the failure of one of these nozzles, the circumferential crack
           leading to failure of the CRDM penetration and ejection from the vessel head
           would constitute a loss of coolant accident and also a control rod ejection
           accident, and like I said, I'll talk a little bit more about what that means from a
           risk perspective in a later slide, but --
                       DR. POWERS:  What does it mean from a neutronic --
                       MR. STROSNIDER:  -- just to say at this point in time that
           when we look at the existing PRAs without doing a lot of additional work to try
           to tailor them to this specific issue, but just taking what's readily available, it tells
           us that there's a level of risk associated with this event that requires increased
                       Having said that, I think we should note that the worst crack
           found to date at one of the more highly susceptible plants in accordance with
           the industry plant ranking, the remaining ligament had a factor of safety of
           approximately six to failure.  So it's about 165 degrees around the
                       The bad think about inconel (phonetic)  is that it cracks in
           these sorts of environments.  The good thing about it is that it's very flaw
           tolerant.  All right?
                       This assessment does not address the issue of continued
           crack growth rate.  We'll talk about that in the next slide.
                       DR. POWERS:  Well, I mean, that's a non-trivial point, isn't it?
                       MR. STROSNIDER:  It's a very important point.
                       DR. POWERS:  I mean you've got a factor of six to failure
           right now, but if that goes to a factor of zip in two months, that's not a very
           comforting thing.
                       MR. STROSNIDER:  Right, and I'm going to talk a little bit
           more about the crack growth rate in the next slide.
                       I want to make the point that there's no reason to conclude
           that cracking won't occur in other units and in other nozzle housing.  The
           expectation is that it will.  You know, the environment stresses, the material, it's
           all the wrong combination to support this sort of thing.  It's a matter of time then.
                       With regard to the bulletin, we believe that timely and
           effective, and I'll talk a little bit more about what we mean by effective in terms
           of qualification, inspections should provide additional information on the extent
           of the problem and provide confidence that safety is maintained and regulatory
           requirements are satisfied.
                       We'll talk a little bit more about the bulletin.  You know, we're
           asking if people are not performing inspections by certain dates to provide
           additional justification for that, which would get into some of these other
           technical issues.
                       I think also it's important to note, and we added this bullet
           since yesterday.  There was not a  whole lot of discussion on this yesterday,
           although I think Dr. Kress brought it up.  If you look at this size loss of coolant
           accident in terms of the existing risk assessments, it's not expected to provide
           a challenge to containment integrity.
                       So from an overall risk perspective, if you look at risk to public
           health and safety in terms of Part 100 dose consequences, we wouldn't expect
           a significant challenge there based on the existing calculations.
                       MR. ROSEN:  Jack, on your fourth bullet you say there's no
           reason to conclude that cracking won't affect additional units.  Would you also
           be able to say that there's no reason to conclude that cracking won't affect
           additional housings at the plants that have experienced this cracking?
                       MR. STROSNIDER:  Yeah, there's no reason to conclude that
           additional housings would not experience cracking.
                       Now, if the people had additional information with regard to
           the heats of those materials and the fabrication and their susceptibility, you
           might be able to make some arguments about the timing and that sort of thing
           or susceptibility, but that sort of information isn't available, and we can't
           conclude that it's not going to occur.
                       DR. POWERS:  I'm trying to understand a little better on your
           last point.  You're saying that CRDM nozzle failure, not expected to challenge
           containment integrity given no additional failures.
                       MR. STROSNIDER:  Yes.  Well, no, what I'm saying is if you
           look at the existing PRAs, if you go to the IPEs as an example and you look at
           the size breaks that we're talking about, they do not provide a significant
           challenge to containment integrity.
                       Now, I'll talk later.  Okay?  When we talk some of the
           discussion yesterday with regard to risk insights about collateral issues and
           other damage that might occur that haven't been specifically considered in this
           sort of evaluation at this point.
                       DR. POWERS:  Well, I guess I'm still missing something
           because a large break LOCA clearly can challenge containment.
                       MR. STROSNIDER:  It clearly can't?
                       DR. POWERS:  Can challenge containment.  An unmitigated
           large break LOCA accident will definitely challenge containment.
                       DR. ELTAWILA:  Dr. Powers, this is Farouk Eltawila from
           Division of Engineering, NRR.
                       You're correct.  Yeah, small break LOCA can lead into a core
           damage if you have a multiple failure.
                       DR. POWERS:  That's right.
                       DR. ELTAWILA:  I think Jack is going to get into that.  So I'm
           trying to not steal his thunder, but for that particular scenario, if you look at small
           LOCA, it occurs at the top of the vessel.  So really if you would -- management
           of the inventory, the operator would be able to extend, prolong the injection
           phase and does not switch to the collision phase, and that's when most of the
           core damage happens in that situation.
                       DR. POWERS:  So he has to have an additional failure.
                       DR. ELTAWILA:  Absolutely.
                       DR. POWERS:  Okay.  So it's a conditional statement.  Given
           no additional failures.  Okay.
                       And also on your control rod ejection, can you explain what
           the neutronic effects are?
                       MR. STROSNIDER:  Well, only -- and I was going to get into
           this later, and I've got a slide on some of the risk considerations.
                       DR. POWERS:  Okay.  Whenever.
                       MR. STROSNIDER:  Okay.  We'll see if we can address that
                       As I said yesterday, following yesterday's discussions, the
           subcommittee actually toward the end of the meeting provided a list of technical
           issues that they asked us to talk about today.
                       Susceptibility model uncertainties, effectiveness of visual
           inspections, evaluation of crack growth rate.  Some risk assessment issues
           were also on that list, and like I said, I'm going to address those on a separate
                       I think the industry did a good job yesterday of explaining the
           operating experience and explaining what we know from a technical point of
           view that would help us to assess this issue, and also explaining what we don't
           know.  And I think the subcommittee did a good job in zeroing in on some of
           those issues and they are listed here.
                       So when we were asked to address this today, the one thing
           I've got to tell you up front is we don't have the answers.  We don't know, for
           example, what crack growth rates are because there's uncertainty about the
           chemistry or crack initiation rates because we don't know what the annulus
           chemistry looks like, and so there's some questions there.
                       And that's one of the reasons that we're going out with the
           bulletin, is the request for information, and what I wanted to focus on is how we
           consider these technical issues in crafting the bulletin and our expectations with
           regard to the information we're going to get.
                       We recognize that the susceptibility model certainly has
           uncertainties in it.  We have a lot of experience with trying to put these kind of
           susceptibility models together, and they're not perfect.
                       However, we do think that it's a reasonable basis for the
           graded approach that we've laid out in the bulletin, and if you've looked at that,
           what you see is that we're recommending different information requests and
           justifications based on the level of susceptibility.
                       We've broken the plants into four different categories.  For
           example, the plants that have actually identified leakage and cracking, they
           need to do -- need to provide justification why they wouldn't do additional
           volumetric examinations.  Plants that are in the first four effective full power
           years away from being equivalent to a CONY (phonetic), we'd need to provide
           justification for not doing examinations by the end of this calendar year.
                       So we think that this is a reasonable model for laying out that
           sort of graded approach, recognizing that the intent here is to collect additional
           information to determine what additional actions may be necessary or
                       DR. POWERS:  I guess I'm trying to understand why you use
           the word "reasonable" associated with this, and maybe I almost need to see
           something quantitative from your model because if you've got a very uncertain
           -- that's fine.  Things can be very uncertain, and you've broken it up into a
           bunch of blocks in there, but I don't have a feeling for how relative to the size of
           those blocks -- how big your uncertainties are.
                       If you say four effective power years away from a CONY, it
           could be four or as small as six months?
                       MR. STROSNIDER:  Yeah, and unfortunately, we don't have
           the information to quantify that uncertainty.  When you look at what drives the
           susceptibility here and you look at the variables that are important, you start off
           with time and temperature, and those are the two variables that were used in
           this susceptibility model, and they clearly are the dominant factors.
                       DR. POWERS:  Okay.
                       MR. STROSNIDER:  Then you get into issues like the
           microstructure of the material, you know, carbide distribution of the grain
           boundaries, that sort of thing.  That information is not available.
                       Fabrication history, you know.  What did it take to get this
           particular penetration inserted?  Did it have to be straightened?  What sort of
           chemicals might have been used in cleaning, et cetera?
                       And that sort of information just isn't available in some cases
           or in other cases, you know, it just hasn't been pulled together yet to be put into
           the sort of quantitative assessment that you're looking for.
                       So we know there's uncertainties in it.  We have experience
           from the earlier susceptibility ranking, which, in fact, was off by several years,
           okay, ten years or more in the case of predicting some of the cracking.  All
                       So we know that uncertainty is there, but the ability to quantify
           it doesn't exist, and what we're proposing in the bulletin is that we've just looked
           at the data in terms of some natural breaks with regard to how the plants are
           grouped and said, "Here's some higher and medium ranked plants," and you
           know, tailored the information request based on that.
                       The idea is to get additional information which will help us
           then to better understand what those uncertainties are, but right now there's not
           a quantitative model that I can tell you that you've got this sort of standard
           deviation or something like that.
                       DR. POWERS:  I mean, I guess what I'm fishing for is why
           you call this a reasonable basis then.
                       MR. STROSNIDER:  Well, we think it's reasonable because
           it considers the primary parameters and temperatures.
                       DR. POWERS:  Time and temperatures, things like that.
                       MR. STROSNIDER:  And another way I could say it is it's the
           best available we have at this point if you want to look at it that way, but we
           definitely need better information to understand how good it is.
                       DR. POWERS:  I guess it would be interesting to understand
           why you broke it into four groups instead of just two.
                       MR. STROSNIDER:  Okay, and I can start with the first group
           were plants that have actually experienced cracking.  All right, and so they have
           the disease.  
                       The second grouping basically, and I don't know if we have
           the plot available, but this was pretty simple.  There's just some judgment
           involved here where we looked at the plants and how they stacked up in terms
           of time to where they would be equivalent to Oconee, where the cracking was
                       DR. POWERS:  Yeah.
                       MR. STROSNIDER:  We looked for a natural break, and we
           said for effective full power use, there appears to be a natural break in the
           ranking of the plants.  Again, it would be based on time and temperature.  We
           said these plants that are above four effective full power years looks like the
           group of most highly susceptible.
                       Then we went from that break back to another break in the
           data which went out to I think it's 40 -- 30 full power years.  Okay.  So there's
           nota  whole lot more to -- okay.  What you're looking at here, again, these are
           effective full power years to where the time and temperature would be
           equivalent, and using a Errhenius relation to what Oconee had, and we just
           looked at this break and said, "This is the group of more highly susceptible
           plants, and we think if we understand what's going on at those plants, you
           know, we will have information that will help us to understand more about the
           uncertainties in this assessment."
                       I should say that when you go beyond here out to 30 effective
           full power years, we're also asking these people to do examinations.  All right? 
           But it's different.  This could be a VT-2 visual sort of examination.
                       DR. POWERS:  Yeah, well, we'll get into that, whether that's
           effective or not.
                       MR. STROSNIDER:  Yeah.
                       DR. POWERS:  I'm just trying to understand why you grouped
           them as they are, especially since if I had put error bounds on these things,
           which you couldn't really do because you can't even quantify your uncertainties,
           but presumably they're big, that you would not see any such breaks.
                       MR. STROSNIDER:  Yeah.
                       DR. WALLIS:  We went through that yesterday, and they were
           reluctant to put the error bands (phonetic) on, but it's obviously true that if you
           put the error bands on, the points move  around a lot.
                       DR. POWERS:  It has real implications, it seems to me, on the
           bulletin because it says why have four groups.  Why not just have two?
                       DR. WALLIS:  I think we felt there would be a big enough
           sample or something like that, 25 plants or something by the time you've done
                       DR. KRESS:  One of my points, which I'm not sure I made
           very well, Dana, was that these are relative to a CONY.  Now, if they could go
           to a CONY and look at all of these other parameters that they expect to affect
           this susceptibility and somehow identify that the cracked parts of a CONY have
           attributes of these parameters that they would expect to be high with respect to
           shortening the justification time, if they could somehow make a judgment, then
           they can say that the error bounds on all of these other things are -- that you
           don't really need this error band because these things are relative to Oconee
           and Oconee is already on the high side.
                       And I don't think I made that point very clear, that you don't
           have to do the pool uncertainty.  You have to go look at Oconee and see if you
           could make a judgment that it's likely to be on the high side of the uncertainties.
                       DR. WALLIS:  But isn't it normally on the high side?  They
           inspected nine tubes and had no cracks.  So it's not all on the high side.  It's
           only some of Oconee that's on the high side.
                       DR. KRESS:  Well, this is relative to the cracks that were
           there at Oconee.  So I'm saying look at the attributes of the ones in Oconee that
           cracked and see if you can make some judgment about whether or not you
           caught the most susceptible ones, and then I think you can make some
           judgment that this susceptibility curve is probably a reasonable basis.
                       MR. STROSNIDER:  I understand the desire to see a more
           quantitative evaluation and to see these sort of uncertainty bounds.
                       DR. POWERS:  I'm just trying to understand the reasoning.
                       MR. STROSNIDER:  We don't have it, and quite frankly, we
           don't have all of the information, couldn't do it if we sat down to do it.  You could
           make some assumptions on some of the parameters, but some of these
           variables we don't have.
                       DR. KRESS:  And you really don't know how the parameters
           affect the thing, too.  You don't have the model.
                       MR. STROSNIDER:  We don't have the model?
                       DR. KRESS:  Yeah.  I don't think you can have a relationship
           between the micro structure and --
                       MR. STROSNIDER:  Well, there's that, too.  You can go back
           and look at the susceptibility ranking that was put together to support 97-01, and
           in fact, its initial attempt was that to be a more sophisticated model, it did where
           they had information try to include microstructure and some other variables.
                       I mentioned earlier it was off.  If you look at Arkansas where
           the cracking was detected early this year, by that original model, that plant was
           predicted to be 11 or more years away from a condition where you might expect
           to see that.
                       So interesting though when you take this model, which is a
           much more simplified model, just looking at time and temperature.  Arkansas
           moves up, and it moves into this more highly susceptible categorization.
                       DR. POWERS:  See, now, that's very useful information.  I
           mean that explains a lot when you tell me that.
                       MR. STROSNIDER:  I'm sorry.  I didn't hear.
                       DR. POWERS:  That explains a lot when you tell me that,
           okay, you had a model.  It was off demonstrably by a lot, its prediction, but now
           you're using a model which may well be more simplified, but the impact kicks
           it up.
                       MR. STROSNIDER:  But I want to be very careful here
           because this is not intended to be a predicted model in terms of how many  --
           you know, at what point in time you're actually going to see cracking.  It's a
           relative ranking, and there's uncertainties in there.  I mean, there's the
           possibility that there could be plants out there that are cracked, you know --
                       DR. POWERS:  Right now.
                       MR. STROSNIDER:  -- like Oconee or worse, yeah.
                       DR. POWERS:  Oh, yeah.
                       MR. STROSNIDER:  The whole point of the bulletin is to go
           out and get information, and then when you talk about reasonableness, you
           say, "Well, you know, the bins that we've grouped the plants into, does it look
           reasonable for getting that sort of information?
                       DR. KRESS:  And, once again, if you could show somehow
           that Oconee is somewhat the worse case, then you can make this statement
           that this ranking is a pretty doggone good way to do it.
                       MR. STROSNIDER:  If you could, but you need more
           information to make that --
                       DR. KRESS:  Yeah, you need some more information about
           Oconee, like what is the -- you need some information about those things you
           think affect the susceptibility to cracking, and I don't know how you get there,
           but I thought perhaps there might be a chance for one plant of getting some of
                       MR. ROSEN:  So what this adds up to, Jack, in my mind is
           you're telling us that you would not be greatly surprised if the plants in the four
           to 30 year range, some number of them reported cracking.
                       MR. STROSNIDER:  There's a possibility that when they go
           out and do leakage monitoring that they're going to find some leakage, yeah. 
           Based on the last susceptibility model, there's a plant that was 11 or more
           years, and it found --
                       MR. ROSEN:  So there could be some in the four to 30 that
           end up reporting some leakage and some in the earlier group that don't.
                       MR. STROSNIDER:  That's correct.
                       MR. SIEBER:  Well, I guess when I listened yesterday and
           considered all of the uncertainties that appeared to be in the data and the
           analysis, it seemed to me that the cutoff point would have been better set at ten
           years rather than four years.  That's 25 plans.  So all of the cold head plants
           would be in the latter category.
                       MR. STROSNIDER:  And there's a matter of some judgment
           and then the timing that's associated with that.
                       MR. SIEBER:  Right.
                       MR. STROSNIDER:  And in the next viewgraph I'll compare
           some of the industry proposal to what the --
                       DR. BONACA:  Well, one thing that at least for some of us
           stopped the questioning was that you have approximately 24 plants that are
           going to perform inspection between now and next spring in the group.  It's a
           large number, if I remember.
                       MR. STROSNIDER:  We're getting into the next viewgraph.
                       DR. BONACA:  No, but I'm just saying, however, that that was
           the reason why I felt comfortable with what you had because I think we'll gather
           a lot of information over the next few months, and then the focus of our attention
           then became the effectiveness of the visuals because, you know, hopefully if
           they're effective, then we'll learn a lot about what's taking place, much more
           than we know right now.
                       MR. STROSNIDER:  Yeah, and I'll talk about some of those
                       DR. WALLIS:  Are you going to talk about the visual
                       MR. STROSNIDER:  Yeah.  If I could talk about effectiveness
           of visual inspections, there was a lot of discussion yesterday about
           effectiveness.  Basically, to put that in regulatory terms, how would you qualify
           this sort of examination?
                       And in the bulletin, and we presented yesterday we have
           some specific criteria or issues that need to be considered when the industry
           goes to qualify these sorts of examinations.
                       The first thing is the availability of deposits on the head, and
           this gets to the issue of understanding what the interference fit is, the size of the
           crevice between the penetration and the reactor vessel head, and what we've
           suggested in the bulletin is that for those plants that are highly susceptible, if
           they're going to do a visual examination, they need to convince themselves and
           then have a basis to say that you're actually going to get leakage up out of the
           crevice, and that you're going to have deposits on the head.  That's the first
                       Now, we know that some plants have actual as built
           dimensions on those interference fits, and they can do analyses, you know, to
           measure those fits, and there was discussion yesterday about the ability
           perhaps to do some calculations and understand the deposits and how that --
                       DR. WALLIS:  But I think the key point was how does the
           deposit correlate with the crack you're worried about.  If the deposit is due to an
           axial crack in the weld which squirts stuff through and eventually it makes it up
           to the head, but you don't foresee it.  First it creates this aggressive chemical
           environment around the highly stressed bottom just above the weld, bottom of
           the guide tube, and there's a race between the beginning to form circumferential
           cracks there and the emergence of this deposit on the top, and we don't really
           have a good basis for deciding how quickly these two processes occur and
           whether the deposit is really visible before all the cracks got big enough and all
           of that.
                       That's sort of really --
                       MR. STROSNIDER:  And as you describe it, it really is a race
           between getting that deposit on the head and detecting --
                       DR. WALLIS:  I mean, the assumption seems to be that if you
           don't see the deposit, there isn't a crack which you worry about, and that's not
           necessarily so.
                       MR. STROSNIDER:  Well, a ;couple of observations.  One is
           that if you look at the experience to date where these deposits have been
           identified, we noted Oconee was the worst situation.  There are other situations
           where there were axial cracks that have led to leakage, and that's been
                       So the experience to date would suggest that those deposits
           can deposit, but on a plant specific basis, you need to understand whether that
           mechanism is really going to work or not.  If you have a very tight interference
           fit or if you have some different conditions, then it may not happen.
                       So what we talk about in the bulletin is for each licensee to
           provide a basis to say, yes, we think that, in fact, those deposits would
                       DR. WALLIS:  But they have to do this correlation between
           the time where you can actually see the deposits and the time where the crack
           has grown to the point where you worry about it.  They have to do all of that
           analysis.  Do they have a basis for that?
                       If you wait long enough, you're going to get deposits because
           other things may be happening while you're waiting for the deposit to be visible.
                       MR. STROSNIDER:  Yeah, it's not specifically addressed.
                       DR. WALLIS:  And that seems to be a weakness of relying
           only on visual inspection.
                       MR. STROSNIDER:  Well, let me go through the rest of the
           logic because there's more there.
                       Once a plant, one of the higher susceptibility plants, if they
           convince themselves that, yes, they will get deposits on the head, then you've
           got the issue of being able to discriminate those deposits possibly from
           preexisting deposits. 
                       We saw some photos yesterday.  There are leaks from other
           sources, from flanges and seals that are up above, and depending upon what
           the history of the plant is in terms of cleaning those or perhaps what their
           photographic documentation is, there's questions about can you discriminate
           new deposits from old deposits.
                       And the other issue that comes up here is the insulation
           because there are various types of insulation.  At least we heard yesterday that
           the B&W units, the insulation is raised off the head.  So there is access.  For
           some units it conforms to the head, but it's lifted off, access, but perhaps more
           difficult, and there's other units where it lays and it's, in fact, glued right to the
           head, and there's other issues associated with that.
                       So in order to qualify visual exam, you have to address those
           issues, and that's addressed in the bulletin.
                       So our expectation is that the industry would come up with
           methods for doing those sorts of qualifications.
                       Now, with regard to growth rate and annulus chemistry, all
           right, and this is an issue that got a lot of attention yesterday, and as was
           pointed out, it is important to understand and what is a factor of safety of six
           mean in time.  All right?
                       We don't have data to help us understand that, particularly
           because of understanding what the environment and what the chemistry in the
           annulus might be and how that could impact us.  We've got some work going
           on and the industry is doing some work to try to understand that better.
                       But what we're telling the industry in the bulletin is if you don't
           plan on doing inspections by a certain time, either by the end of the year,
           depending on your susceptibility or your next outage, you need to provide a
           basis, and that basis would have to address this issue.
                       All right.  So we don't have the answer right now.  That's the
           purpose of the bulletin, is to basically force that sort of evaluation, if that's the
                       DR. WALLIS:  I guess what I was saying just now is that in
           order to assess the effectiveness of visual inspections, you may also have to do
           some of that.
                       MR. STROSNIDER:  Well, when I come back to that, you
           know, in assessing the effectiveness of the visual exams in this race between
           the crack growth and whether you're going to see the deposit, the best thing we
           have to point at at this point is like you said the operating experience, where
           when you see those deposits and you go in and actually look at the crack sizes,
           they have had margin.  And that's the best logic I can offer right now.
                       MR. ROSEN:  But you don't know how many other cracks
           there are.
                       MR. STROSNIDER:  That's right.  Well, you have this whole
           question of will, in fact, some of these penetrations leak or not.
                       MR. ROSEN:  I'm just saying that we found a lot of cracking
           from looking at boron deposits. It doesn't give me a lot of comfort that there isn't
           cracking going on because it's not going to call you up and tell you, "We're
           cracking down here."  It's just going to keep on cracking until one of two things
           happens, one very bad, and the other which is detectable.
                       MR. STROSNIDER:  Which supports the basis for a need for
           an assessment, and if you can't provide the data and assessment to support
           that you don't have this problem, that you need to do timely inspections.  That's
           the logic we're trying to build into the bulletin.
                       MR. ROSEN:  You know what they say about absence of
                       MR. STROSNIDER:  Excuse me?
                       MR. ROSEN:  You know what they say about absence of
           evidence, not evidence of absence.
                       MR. STROSNIDER:  One other comment I wanted to make
           on this is, again, if you look at the logic we're laying out in the bulletin, it goes
           along the lines of if you're not going to do an inspection by the end of this
           calendar year, for example, for high susceptibility plants, and I just point out,
           you know, with this uncertainty in the growth rate, we're saying you need to do
           a timely inspection, and again, there's some judgment involved here, but we're
           saying at the end of the year for high susceptibility plants is reasonable.
                       But the other point I wanted to make is that the bulletin offers
           the opportunity for the licensee to provide a basis for not doing that inspection
           by the end of the year and doing it on some other schedule, and they need to
           address these and a number of other issues that were raised in requests for
           additional information that we provided in response to the industry report on
                       And the point I wanted to make is that the information that was
           provided in that report and in the responses to those requests for additional
           information was not sufficient to answer this question.  If it had been sufficient,
           then we wouldn't be talking about this bulletin.
                       So there needs to be additional information provided to
           provide justification for why these inspections could not be done sooner.
                       So as I said, there are a lot of good questions.  We would like
           to understand in a quantitative sense these issues better, and actually there is
           work going on to try to do that, but at this point in time when we don't have all
           of those answers, the intent is to try to address them through the bulletin.
                       Now, I wanted to summarize perhaps briefly if I can the
           difference between what was proposed by the industry and the logic in the
           bulletin, and let me start with the industry approach.
                       If we talk about the examination method, the recommendation
           that the industry made was a visual examination capable of detecting small
           amounts of boric acid deposits for plants that are within ten effective full power
           years of Oconee 3 and continued boric acid walk-downs for others.
                       Now, this is basically the extent of the recommendation.  In
           the generic letter, we've laid out a graded approach, but it talks about the issues
           that need to be addressed as part of the qualification, and I talked about some
           of that on the last viewgraph.  You know, what's the interference of it at your
           plant?  What's the history of deposits?  Can you really discriminate or can't you? 
           What's the insulation situation?  Do you have to remove insulation?
                       Those are all issues that would have to be addressed in
           response to the bulletin.
                       DR. WALLIS:  These are small amounts.  Has anyone tried
           to quantify this?  You have to have a certain amount before you can see it.
                       MR. STROSNIDER:  Well --
                       DR. WALLIS:  Some sort of quantification of how much that
           implies by the time you see it it's been going on all that time while it's been
           building up and so on, or you just sort of assume that by the time you can see
           it, you've got enough information or something?
                       MR. STROSNIDER:  The discussions to date have been a
           small amount.  The example being given is Oconee, which is our understanding
           was less than one cubic inch, and when you look at the photo of the head, you
           see a lot of white deposits on there.  Some of that is residue from prior cleaning,
           et cetera, but what we were informed is that what actually came from the
           leaking nozzles was less than a cubic inch.
                       So it is a very small amount, and in fact, it's a change in mind
           set, if you will, I think, for the industry perhaps.  When we talk about these boric
           acid walk-downs where people have in the past found hundreds of bounds of
           boric acid, and now the focus has to be on a much smaller amount because
           that's the expectation, the sort of thing we would expect to see addressed in
           qualification of these visual exams.
                       DR. WALLIS:  Do you see it because it reflects differently from
           the steel?  It has a different color from the steel or something?  It's something
           you detect  which is --
                       MR. STROSNIDER:  Different color from the steel.  There's
           been discussions with the industry about different morphology, if you will, of
           what the texture of it looks like, depending upon whether it's bubbling up with
           a crevice or running down from someplace else, but I think the point here is that
           all of those sorts of things need to be assessed and qualified.  You need some
           sort of quantitative method for saying that this examiner can actually identify --
                       DR. WALLIS:  Perhaps 180 degrees around the tube, too. 
           You mustn't just look at it.  You've got to look around the back of it and look as
           well because it might be building up there.
                       MR. STROSNIDER:  Okay, and when we talk about this
           graded approach, again, to come back to the examination method, what we're
           asking for in the bulletin is for plants that have identified leakage, unless they
           can provide some other basis, a volumetric examination, the point being here
           that the intent is to avoid a recurrence of reactor coolant pressure boundary
                       They've actually had this.  They've had leakage.  They've had
           through wall cracks, and we want to see an examination that's capable of
           maintaining the sort of  criteria that exists in the ASME code, which would say
           you're not supposed to have through wall cracks in the reactor coolant pressure
                       In order to do that, you basically need some sort of volumetric
                       DR. WALLIS:  What does volumetric mean here?
                       MR. STROSNIDER:  It means being able to interrogate not
           just the surface, but actually the volume of material.
                       DR. WALLIS:  Look for cracks throughout the whole volume.
                       MR. STROSNIDER:  And I want to be a little careful here, you
           know.  I guess that could suggest there's the possibility of using surface exams,
           like a penetrant exam or something like that.  Even the eddy current that was
           done is a very shallow exam, and depending upon what a licensee would do if
           they find something, an analogy might be steam generator tubes where --
                       DR. WALLIS:  Well, you know what --
                       MR. STROSNIDER:  -- if you find an eddy current indication
           and you can't size it, you repair it.
                       DR. WALLIS:  You know what the most susceptible place is
           for the centrifugal -- the circumferential crack, right?
                       MR. STROSNIDER:  Yeah.
                       DR. WALLIS:  And you know that's not on the surface.  So
           you're going to have to look inside quite a way.
                       MR. STROSNIDER:  Plant specific visual examinations for
           plants that are within a less than four effective full power years, and that's what
           I was talking about, the qualification there, you know, providing a justification
           that they will, in fact, see deposits, that the deposits will exist, and that they will
           see them.
                       And it goes on to talk about if you do see a leakage, you
           know, what's the follow-up.  And you know, without some additional justification,
           and if you look at the regulations it would appear to drive you into a volumetric
                       A visual examination for these moderate susceptibility plants,
           that's what's in the four to 30, and that requires something more than what's
           stated here.  You still need to be able to discriminate.  You've got issues with
           regard to insulation, but it might not require quite as much as for high
           susceptibility plants.
                       DR. POWERS:  Could you explain a little bit about the
           phenomenology of the cracking here?  We have a stress corrosion cracking
           process going on.  So we get some initiated cracks.  Did they go through wall
           before they propagate farther in distance or can they propagate along before
           they go through wall?
                       MR. STROSNIDER:  The possibility exists for multiple
           initiation sites.
                       DR. POWERS:  Right.
                       MR. STROSNIDER:  All right?  Which could lead to what we
           call complex crack geometry.
                       DR. POWERS:  Right.
                       MR. STROSNIDER:  You might get one part growing through
           a wall and part through a wall at others.  To my knowledge, what was found at
           Oconee was more a simple through wall crack.  I don't know that they -- you
           know, we didn't have reported any other initiation sites, but the possibility is
           there, and it's going to be driven, again, by the environment, the residual
           stresses, you know, what the residual stresses look like and how they relax as
           the crack rose, and that could depend upon different initiation sites.
                       There's a lot of questions there, more questions than I have
                       DR. POWERS:  It seems to me that your visual inspection
           depends on it going through wall, doesn't it?
                       MR. STROSNIDER:  Well, let me back up a second and make
           sure that -- because I'm not sure if you understood this part of it.  The residual
           stress distribution on the inside of the penetration tends to drive axial cracks. 
           That's pretty well demonstrated by the analyses and by the operating
                       There's also the possibility for cracks to initiate on the outside
           of the J groove weld and grow up behind them, but the mechanism appears to
           be that you first grow a crack of that type such that you provide a pathway for
           coolant to get into the crevice between the tube and the shell, the vessel.
                       Once that crevice or annulus has an environment in it that will
           support stress corrosion cracking, the residual stresses on the outside support
           the circumferential crack growth.
                       So the race that was discussed earlier is from the time that
           you get coolant into that annulus, presumably from an axial flaw, all right?  And
           it works its way up to where you can see a deposit.  How much circumferential
           crack growth would you expect to see?
                       So but there is at least the notion that you're going to have
           this axial crack through wall that's going to begin leaking.  Now, there's
           questions about once you get that axial crack does it require an independent
           initiation site with a circumferential crack or can the axial crack turn.  That
           becomes important because initiation times can be significant.
                       DR. WALLIS:  The initial axial crack can be just through weld
           and give you deposits.  It doesn't have to go through any wall at all.  It doesn't
           have to affect the wall at al.
                       MR. STROSNIDER:  That's true.
                       If you look at what's involved in these different categories,
           plants that have actually experienced leakage, there's four of those.  Other
           plants that would be in this high susceptibility ranking, there's another ten, and
           there's in the medium susceptibility another 31 plants, which the generic letter
           is asking those licensees to tell us if they're not planning inspections to provide
           a basis for that, and that's a total -- it's a different type of inspections, but it's a
           total of 45 plants compared to the industry proposal which would capture those
           plants in the first ten EFPY, which is 25 plants.
                       DR. POWERS:  And the first 14 of yours are totally
           encompassed in the first 25 of theirs?
                       MR. STROSNIDER:  Yes.
                       The other issue that come sup here is with regard to the
           timing of the inspections, and again, we're asking for justification for not doing
           inspections before the end of this calendar year.  Six of those 14 high
           susceptibility plants are not scheduled for outages before the end of the year.
                       Actually I wanted people to understand that, compared to the
           industry proposal, which would be at the next refueling outage.  So some of
           these 25 plants would go out to next spring, and I think a few of them until next
           fall, based on the industry proposal.
                       DR. POWERS:  When I think about timing the issues of
           quantitative measures of risk, I mean, that's almost my first question.  When you
           discuss risk, are you going to go into something more quantitative on this?
                       MR. STROSNIDER:  No, not much more.  You raised a
           question right at the beginning about crack growth rates, and as I said, we really
           don't have a good handle on the initiation times and the growth rates.
                       The point we're making here is that we're looking for what we
           consider an appropriate sample of plants to look or just why they're not looking
           at what we think is a fairly timely manner, by the end of the year.  The question
           is:  are you willing to go off an additional six months or if you'll look at the
           proposal here, are you willing to go off an additional year and a half with this
           unknown parameter of growth rate?
                       DR. POWERS:  Well, I'm going to say, "Look.  That's a
           known."  But Farouk just told me that we really don't get into a CDF situation
           until I have some additional failure.
                       Okay.  Additional failures I've got some handle on in my risk
           assessments.  That's where I would start asking the PRA --
                       MR. STROSNIDER:  Well, let's try to -- when we get to that
           slide, which I think it might be the next one, let's see if we can't address that.
                       DR. POWERS:  Okay.
                       MR. STROSNIDER:  Sample size is another issue that comes
           up here, and talking about 100 percent of the head penetrations.  That's similar
           to the industry for visual examinations.
                       When you get into doing volumetric examinations, however,
           we're also asking for justification why 100 percent shouldn't be looked at.  I think
           the industry approach was really silent on this, although you could look at the
           ASME code, which indicates that you basically double your sample size, which
           at a CONY, for example, found nine leaking penetrations.  Then they went and
           looked at another nine beyond that.
                       Our basis for this is when you look, if you try to approach this
           from a statistical point of view and you ask yourself, you know, if success is not
           having one penetration with an unacceptable crack in it, define that however
           you want to define it; you know, the statistics are the sampling, so you basically
           need to go look at all of them.
                       Now, you want to temper that a little bit with engineering
           judgment.  All right.  But if you go look at Oconee and you look at the distribution
           of penetrations that experience cracking, there were some on the outer
           periphery, which is expected to have higher residual stresses because of the
           geometry, but there were some that were just a few rows from the center that
                       All right.  So it's very difficult even to construct an engineering
           argument that says look at these first based on the operating experience.
                       MR. LEITCH:  Jacks, just before you leave that one, could you
           differentiate under the examination method between Group 2 plants and Group
           3 plants?  What's different about a plant specific visual qualification between the
                       MR. STROSNIDER:  The major difference that we discuss is
           providing an assessment that says that the boric acid deposits will really find
           their way up the crevice --
                       MR. LEITCH:  Okay.
                       MR. STROSNIDER:  -- and deposit themselves on the head.
                       That may not be a trivial thing to do.  For plants, we know from
           the public meeting we had that at least the B&W units do have some as built
           dimensions that they could use to put into an analysis to do that.  We don't know
           if all the vendors have that sort of information.
                       Absent being able to demonstrate that, you basically have to
           justify why you wouldn't do a volumetric examination.
                       MR. LEITCH:  So absent that data, that means that some of
           that family of plants might have to take the head off.  The volumetric exam
           means take the head of basically.
                       MR. STROSNIDER:  Yes.  And again, that reflects the graded
           approach where for these moderate susceptible plants as we've characterized
           them, and we are not looking for quite as stringent a qualification, but depending
           upon what comes out of -- you know, what information we get between now and
           the end of the year, we'll have to look at that.
                       DR. POWERS:  Can I ask you about the volumetric
           examination and into reliability?  It seems to me in the 1997 time frame some
           examinations, volumetric examinations, yielded fuzziness that indicated there
           might be something and there might not be something.  Is that a problem here?
                       MR. STROSNIDER:  Well, there's a significant issue here,
           and it's a significant challenge for the industry in that for some portions of this
           penetration, for the welds in particular, there aren't any qualified examination
           methods right now.
                       Okay.  Now, when we talk about qualified, there's various
           levels of qualification.  You know, Appendix 8 code talks about a PDI,
           performance demonstration initiative type qualification.  Frankly, from a practical
           point of view, there's not going to be enough mock-ups built in order for them
           to do that between now and the end of the year.
                       There are some examination methods, and we've asked some
           of the experts instead of being contracted by research, Steve Docteur in
           particular, to tell us what sort of capabilities, you know, might be possible.
                       So looking at that, but there is a challenge in terms of
           qualifying these methods, and I think we're going to have to work with the
           industry to understand what they can do.
                       The volumetric exams are not perfect.  In fact, if you go back
           and look at the Oconee experience, the volumetric exam did not detect the
           circumferential cracking.  All right?  That was detected actually when they went
           in to do the repairs, and they had to do some penetrant examinations as part of
           the repair process.
                       So there needs to be work done in this area.  It is a challenge,
           and the industry will tell you we don't have a qualified method at this point.
                       MR. SIEBER:  Well, it depends on the plant, too.  B&W plants
           have cylindrical CRDMs so you can shoot through it with a UT probe and find
           the weld, except the geometry is real complex.  It's not clear what it is you're
           looking at.
                       MR. STROSNIDER:  There's different geometries with
           different access.  Some plants may have thermal sleeves in here.  Some may
           not.  There's --
                       MR. SIEBER:  Well, the Westinghouse plants have a thermal
           sleeve.  So there's no way to get the transducer in contact with the cylindrical
           portion unless you get one thin enough that you can slide down between the
           thermal sleeve and the actual base metal of the CRDM housing, and so under
           those circumstances, I don't know how you would do a volumetric exam, but --
                       MR. STROSNIDER:  So I want to make it clear when we talk
           about an information request.  That may sound somewhat benign, but it really
           isn't.  There's a significant challenges to justifying why a plant wouldn't do
           inspections, and if a plant get into inspections, depending on the time, there's
           some challenges being able to --
                       DR. WALLIS:  Well, are you in some cases asking them to do
           things beyond the state of the art?
                       MR. STROSNIDER:  Some of the things that they might be
           driven into here are going to require additional development between now and
           the fall.
                       Now, I would point out that regardless of what goes out in the
           bulletin, there is the potential for people to finally -- with the current
           examinations and have to deal with these issues, all right, and if you look at the
           Oconee experience and other experience, there should be a real motivation to
           develop this technology because the exposures and the costs associated with
           these inspections and repairs can be very high.
                       DR. FORD:  Excuse me.  Could I just have a sanity check
           here?  Larry, we're supposed to finish this whole meeting at quarter to four.  We
           do have the presentation by -- could I ask, Larry, approximately how long would
           you need?  I notice you've got pretty well the same presentation you had
                       MR. MATTHEWS:  As long as they ask questions --
                       DR. FORD:  I just wanted to know.  They identify nine leakers
           at Oconee, and they understand that nine additional ones were inspected, right,
           of the  nozzles?
                       MR. STROSNIDER:  Right.
                       DR. FORD:  And typically do an inspection of that type to
           verify that there isn't further leakage.  I understand the difficulty of inspecting,
           but given the number, the number grew from zero to nine.  Why didn't we have
           100 percent inspection of the other nozzles?
                       MR. STROSNIDER:  I think the licensee's action at the time --
           and they'd have to speak to this -- but I'm assuming that they were looking at
           ASME code requirements which say, you know, double your sample size, and
           they didn't find anything in that additional sample.  But I point out in developing
           this communication, we went back and did some statistical analyses and said,
           "What does that really tell us?"
                       And statistical evaluation says it doesn't really give you a high
           level of confidence that there aren't other cracks out there.
                       DR. BONACA:  Because it's hard to believe that, you know,
           there were only nine there, and they evolved over the years until they all came
           up at the same time, and now they're all Scott free.  I mean, but that's
           considerations for the next inspections.
                       DR. WALLIS:  Well, it didn't happen at the same time.  I think
           Oconee told us that probably they've been occurring over several years.  They
           happened to be detected at the same time.
                       DR. BONACA:  I understand that, but I'm saying that so why
           not affect the other nine the next outage.
                       DR. FORD:  Could I make, again, a sanity check request? 
           Larry, would it be acceptable to you to cut down your talk and address quite
           specifically the areas where you might disagree with what Jack is saying?  
                       None of the background slides that you have --
                       DR. FORD:  Would that be okay, Larry?
                       MR. MATTHEWS:  Yeah.
                       DR. FORD:  Good.
                       MR. STROSNIDER:  Let me try to move through the rest of
           this a little bit more quickly if I can.  A lot of discussion about risk, right insights
           yesterday.  Some questions have already been raised today.
                       The failure or ejection of one of these housings, there's two
           different issues or events you can look at here.  One is a loss of coolant
           accident, and the other is a reactivity insertion, loss of the rod.
                       Let's talk about the LOCA for a second.  As I understand this,
           if you look at existing risk assessments, okay, they include small or medium --
           excuse me -- this would be medium in PRA space, medium break LOCAs as
           one of the initiating events, and then you go on from there with additional
           failures and you figure out what the probability of the core damage might be.
                       The point here is that if you just take that break and you look
           at the reliability of the mitigating systems, you look at the operator's ability to
           configure the system into the recirculation mode, which is an important aspect
           that tends to drive some of the risk numbers, but that's pretty well understood
           in terms of, you know, there's an existing analysis that tells you how it's going
           to work.
                       Now, those analyses aren't necessarily, in fact, probably
           aren't for this specific location.  Some people will characterize this as if you're
           going to have a medium LOCA, this is one of the better places to have it.  All
                       It's more forgiving.  There's a longer depressurization time,
           which gives the operator more time to align the system.  Okay?  So you could
           go back and look at this and try to understand better the specific thermal
           hydraulics in this event with this break location and understand is there more
           time and can you credit operator action as being more reliable.  So that's on the
           plus side.
                       All right.  Now, I'll get down here and talk about some
           collateral issues in a minute.  Now, the other issue is the rod ejection which
           could cause an insertion, a reactivity insertion event, right?  Now, if this occurs
           at full power, the rods are out in most plants the way they operate today.  So
           there's no real activity issue or reactivity issue there.
                       If you look, however, from the hot zero power condition, all
           right, it could be a more significant event.  Now, there was some discussion
           yesterday about the fact that that event is analyzed as part of the licensing basis
           for the plant, and those license basis analyses show that you could have some
           fuel damage, as I understand it.
                       However, we had some discussions yesterday, and we
           wanted to point out there's some additional, more recent work that's been done
           and is ongoing in the Office of Research using more realistic assumptions,
           which might be appropriate from a risk assessment perspective that say that
           you would not experience core damage in that event.
                       So that's just sort of an understanding of, you know, what
           exists in the licensing basis evaluations and what you might conclude from
           looking at existing risk assessments.
                       Now, again, if we look at this specific situation, there are some
           questions that can come up which we categorize as collateral issues, and
           what's the potential for multiple rod ejection?  If one rod comes out, can it
           damage another to the point where it might fail or where it might render it unable
           to insert, in which case you get something that's beyond what's been evaluated
           to date?
                       DR. POWERS:  Well, I guess I would ask the question as do
           we understand the kinds of loads placed on the other CRDMs when we have
           the depressurization associated with one fracturing?  And does that lead to
           other cracks, cracked housing, having the crack propagate?
                       MR. STROSNIDER:  And the answer is that we've initiated;
           we're working right now to get information on what the configuration, the design
           looks like, the missile shield, the supports.  There's seismic supports up there,
           which I think provide mainly lateral support, but we're collecting information to
           understand what those structures look like so that we can provide some
           assessment of that.
                       But that's work that has been initiated.  We don't have the
           answer at this point.  
                       There was a discussion yesterday about pressurization
           effects and that sort of thing.  The industry is initiating some risk assessment. 
           We're going to be discussing with them some of these areas.
                       DR. POWERS:  Your statement that core damage is unlikely
           based on some of the more modern reactivity analysis for the hot zero power
           event, but it seems to me that I recall a test in France where there was a
           reactivity insertion on a fuel rod, and they got fuel damage at relatively modern
           insertion energies.
                       MR. STROSNIDER:  I'm not the person to answer that
                       DR. POWERS:  Farouk is.
                       DR. ELTAWILA:  Dr. Powers, as you know, the Office of
           Research has an extensive fuel program, and what we are trying to utilize here
           is a snapshot of the information that we have.  We know that research is going
           on.  So from the neutronic point of view, if you look at the amount of energy, the
           U-3D neutronic (phonetic), the amount of energy inserted for the high worth rod,
           you will find that the amount of energy in the order of about 15 calorie per gram,
           and if you look at the worst situation, can go all the way up to 50 calorie per
                       Now, I'm aware of the test in the A-1 debt field (phonetic), and
           there is a lot of disagreement about that, and I think there is a consensus that
           test might be an anomaly and not representative of what really might happen
           in the reactivity insertion accident.
                       The third point that I would like to make is that if you look at
           all the tests in A-1, you found that we never had any dispersal for a pulse with
           greater than 20 milliseconds.  All of them have a very small pulse width.
                       If you look at the actor itself, the pulse width is in the order of
           .29 to .5 millisecond.  So, again, as a snapshot we're utilizing the best
           information that we have and say, "Okay.  We're continuing the research, but
           based on the collective information that we have, we really don't think that it's
           an issue that is going to lead into core damage at this time."
                       MR. STROSNIDER:  Thank you, Farouk.
                       One other point I'd make with regard to this failure under this
           particular condition, is that plants are in that condition for a very short period of
           time.  So you're going to start off with a window of vulnerability that's fairly small,
           and it's going to drive down the initiating event frequency.
                       But, you  know, these are areas -- I guess the other point that
           was made here, just one thing is recirculation issues.  I think you heard
           something this week about some blockage issues.  That's an issue that's being
           developed, that's being looked at now.  These are things that would probably
           need to be considered in some additional work.
                       Probabilistic fraction mechanics analysis.  The subject came
           up yesterday.  We talked about everything pretty much that we're talking about
           up here is the consequences of an event should it occur, and we had quite a bit
           of discussion yesterday about what assumptions do you make on the frequency
           of that initiating event.
                       The answer to that will come up through some probabilistic
           fraction mechanics assessments.  The industry is working on that now.  
                       I wanted to make a point with this, with regard to this.  The
           NRC was involved in some of the -- in fact, developed some of the original
           computer codes and models that are used to do this, and so we're fairly familiar
           with this.  The point I want to make here is that like any other computer model,
           it's only as good as the information that goes into it.  All right?
                       So there's a real challenge again here because you get back
           to some of the same questions we were talking about earlier.  What do you
           assume for growth rates?  What do you assume for the environment?  What are
           the material properties, et cetera?
                       People often fall into the trap of saying, "Well, I don't have
           enough information to do a deterministic analysis.  So I'll do a probabilistic
                       Well, the fact of the matter is you need more information to do
           a credible probabilistic assessment than you need to do the deterministic
           assessment.  All right?
                       And I make this point just to emphasize that if you're going to
           look at numbers that come out of this sort of analysis in a quantitative sense,
           you need to have some good confidence on the input parameters.
                       All right.  Now, having said that, these models can also
           provide very good sensitivity insights to understand where the most important
           parameters, and you know, that can help you to just decide how to manage an
                       But we're going to see some calculations like this which are
           going to be driving it, trying to establish an initiating frequency, and we're going
           to have to look real hard in terms of do we have confidence in the inputs to that
                       Again, we talked briefly on my first slide with regard to if you
           want to take this risk assessment all the way out about, you know, what
           challenge there might be to the containment.
                       MR. ROSEN:  About that probabilistic fraction mechanics
           analysis, when you get it, it's going to be time dependent.  It will be a snapshot
           in time for a nozzle at this much time and temperature, with these properties,
           but the time and temperature will change, of course, as it continues to operate. 
           So you'll need as a function of time and temperature.
                       MR. STROSNIDER:  If temperature changes, yes.
                       MR. ROSEN:  Well, time is going to change.
                       MR. STROSNIDER:  You need to modify the model.
                       In regard to time, these models have the capability of
           incorporating crack growth rate, and if you've got the distributions to put in
           there.  All right?  So they --
                       DR. POWERS:  Don't worry, Steve.  That will show ten to the
           minus 11th, your return frequencies.  They always do.
                       MR. STROSNIDER:  Okay.  Additional work.  You know,
           we've talked about information that we don't have, we'd like to have to better
           quantify some of these issues.  The first thing is I want to acknowledge the
           support we've had from the Office of Research.  They've contracted some
           experts in the area of NDE, fracture mechanics, and nondestructive testing, and
           they've also been providing support in this risk assessment.  We've asked them
           to independently look at our assessment of the existing risk analyses, and
           they've been helping us out there.
                       So that work needs to be completed.  It will be documented,
           and that will be made available.
                       In addition to that, I want to point out that we have back in
           June actually -- the Office of Nuclear Reactor Regulation provided the  Office
           of Research with a user need to address issues associated with cracking of
           inconel.  I'm not going to go through this whole list, but you'll see that a lot of
           issues we're talking about in terms of NDE growth rate, et cetera, is on this list,
           and you know, we've already started to initiate work in that area.
                       Similarly, and nuclear reactor regulation is working with
           research in these areas of understanding risk and systems evaluation.
                       I want to emphasize the additional work here of continued
           review of industries activities.  It's industry's responsibility to address these
           issues, and we're working with the Office of Research.  We're doing our own
           evaluations in nuclear reactor regulation to understand it and to be in a position
           to do a review, but this is a responsibility of the industry.
                       The bulletin, I think, is intended to make that point.
                       DR. POWERS:  On this general subject of additional work,
           everywhere we seem to use Inconel 600 it seems to crack.  Other than job
           security, are there other places that we should be looking where Inconel 600 is
                       MR. STROSNIDER:  Well, in fact, we do have piping issues,
           and there's another industry initiative underway by the Jules (phonetic)
           Reliability Project, and we've been interacting with the industry.  VC Summer
           had a crack in the pipe last year, and so we are in fact -- this work that I just
           described is not limited to control rod drive mechanisms, but -- and our
           interactions to the industry is not limited to that either.
                       So if we're looking to understand where in the system inconel
           was used, where it is susceptible, and you know, a lot of the work, however,
           when you start talking about some of these different things, it does overlap. 
           You can apply it, and so  -- but we're not restricting this just to control rod drive
                       DR. POWERS:  I guess I was looking for a little more
           specifics, and you certainly mentioned the Summer issue.  You probably just
           assume I'd never brought up the word "steam generators" again.  Now we've
           got control rod drive mechanisms.
                       Are there any other particular locations in the plant that we
           should be concerned about?
                       MR. SIEBER:  Don't some plants have inconel pressurizer
           heater thimbles?
                       MR. STROSNIDER:  Yeah.  Well, in fact, we've asked the
           industry, and they're working through their initiative to identify various locations,
           various susceptibilities.  You can get into issues like were the inconel welds
           shop fabricated or field fabricated, which can have some influence, and they're
           doing an assessment of that now.
                       I would point out with regard to the Summer pipe cracking that
           in our assessment of that we don't see the risk or the safety significance at this
           point in time associated with that that we see with the CRDMs.  The crack was
           axial.  It was limited to the width of the weld.
                       One of the issues that we're working to understand is the
           potential for circumferential cracking, which of course would again change the --
                       DR. POWERS:  Ten to the minus 11th, I know.  It's a constant
           in these calculations.
                       MR. STROSNIDER:  Then I wanted just briefly to, if I could,
           conclude with summarizing this issue in terms of the NRC performance goals. 
           In terms of maintaining safety, we talked a little bit about the risk perspectives
           that we have based on existing analyses, and clearly, you know, there's a
           number of issues there that can be -- that need to be worked, but based on
           what we understand for this issue and based on existing PRA analyses, you
           know, we conclude that this is an issue that required additional attention.
                       That's reflected in the fact that we're proceeding to issue a
                       With regard to reducing unnecessary burden, I want to
           emphasize the word "unnecessary."  All right.  There will be burden.  The
           industry is going to have to spend resources to deal with this issue.
                       All right.  Having said that, we have challenged ourselves and,
           in fact, as part of our process in developing this bulletin, we've been challenged
           by our various review committees to try to minimize the information requests,
           to focus it on the information that we really think is necessary to understand this
           issue, and make sure that, in fact, we can maintain safety.
                       Some of that is reflected in the graded approach, and if you
           look at the information that we're requesting.
                       Improved efficiency and effectiveness.  First, to deal with
           efficiency, I think it's important to understand in previous issues like that the
           industry has chosen to go out and try to develop generic responses to the
           extent possible.
                       Now, the bulletin goes out on a plant specific basis, but there
           may be some aspects of this that can be dealt with by those plants referencing
           generic evaluations, showing that they're applicable to their plants, and we're
           certainly amenable to that process.  It tends to be more efficient.
                       With regard to effectiveness, we have had good
           communications with the industry.  Those communications need to continue
           right through this issue.  We need to have good understanding between the
           staff and the industry as to these responses and what's acceptable and what
           isn't acceptable in terms of addressing the issue.
                       It's not going to serve anybody well if these responses come
           in in early September, in late August or early September time frame, and I think
           that the industry has missed the mark.  So from an effectiveness point of view,
           we need to continue the communications.
                       DR. WALLIS:  What would be an effective ultimate conclusion
           of this issue?
                       MR. STROSNIDER:  Well, you have to go back to the logic
           in the bulletin.  The industry needs to provide additional information --
                       DR. WALLIS:  Are you just going to keep inspecting forever
           and gathering information forever?
                       MR. SIEBER:  For a new reactor head.
                       MR. STROSNIDER:  Well, let me first address the short term,
           which is the bulletin recognizes a snapshot in time.  So the options that are in
           there provide additional information, as I noted earlier, beyond what's been
           provided to the staff to date, to provide a justification for not doing inspections
           on the sort of schedule that we've --
                       DR. WALLIS:  Well, eventually it's not replacing your head.
                       MR. STROSNIDER:  -- that we've suggested.
                       DR. WALLIS:  Eventually it's not replacing the head.
                       MR. STROSNIDER:  Or doing inspection.  In the longer term,
           okay, and I come back to the comment I had on the first viewgraph, there's no
           reason to expect that this cracking is not going to continue to occur and to affect
           more plants.  So there needs to be a long-term program.  They include
           inspection, head replacements.
                       The industry needs -- that's their determination based on the
           finances, et cetera.
                       The ASME code has recognized this issue.  They have a
           group that's off already looking at augmented inspections, and we want to
           encourage that effort.  This just gets us through the first -- you know, the near
           term here.  There needs to be a longer term program to manage the issue.
                       Finally, with regard to increased public confidence, one of our
           main efforts here is to keep the public informed.  It's the industry and other
           stakeholders.  We have a Web site where we're trying to get information on
           there as rapidly as we can.  So I just want to make sure that everybody
           understands that that's available.
                       We've had some feedback that people find it pretty useful.  If
           there's any comments on how to improve it, let us know.
                       DR. FORD:  Thank you, Jack.
                       MR. STROSNIDER:  That concludes what I planned on
                       DR. FORD:  Thank you very much.
                       Any last minute questions for Jack?
                       DR. POWERS:  I guess what I'm still wrestling with a little bit
           is the effectiveness of the inspections you're proposing people to do.  Have you
           given any thought to the advantages that might accrue to having an improved
           inspection method if you gave them more time to develop one perhaps
                       Is there any way in the, say, reasonably short term between
           now and the end of the next or the following refueling outage to have a better
           way of inspecting?
                       MR. STROSNIDER:  My expectation based on experience
           with these sort of issues is that the inspection technology would improve with
           time.  You mention steam generators.  You can see the changes in the
           technology that existed there.
                       We understand that there are limitations to what's available
           today, and that there's a challenge for the industry, but we have to balance that
           against maintaining safety of the plants, and we put that challenge out there that
           they need to be able to do effective inspections.
                       Bolton, you know, puts that responsibility, I think, squarely on
           the responsibility of the industry.
                       DR. POWERS:  I'm struggling trying to understand your timing
           because I don't have this conditional probabilities for core damage in mind on
           these things.  I mean, you've told me you're not going to threaten containment
           integrity, but I know you can if you have other failures.
                       What I don't understand right now is what the probability,
           conditional probability of having these other failures is.
                       MR. STROSNIDER:  We had a prolonged discussion on that
           yesterday.  At the risk of repeating it, I'll just tell you that we did present
           yesterday -- we asked that question.  What's the conditional probability of core
           damage, given this event occurs?
                       And I want to emphasize because it came up yesterday we're
           not saying that we think the initiating event has a probability of one, but we're
           trying from, as I characterized it yesterday, a decision making under uncertainty. 
           You know, can we get any insights?
                       The conditional core probability, damage probabilities that you
           get out of looking at existing PRAs, and I think that's basically the IPEs, ranges
           from like ten to the minus third to as high as actually a little higher than ten to
           the minus second in some cases.  It's driven largely by the ability and the
           configuration the plant needs to go to to get to the recirculation mode.
                       But when I said that when we look at this issue from a risk
           perspective, based on what we know today, okay, we look at those numbers
           and say, "This issue needs additional attention."
                       All right.  Now, we need to take into consideration what the
           initiating event frequency is, and we don't have a good estimate of that now, and
           that's why we want to go out and get more information.
                       But those were the numbers that if you look at the range from
           the IPEs.
                       DR. WALLIS:  So you would want to get the initiating event
           frequency down to ten to the minus three as a result of better understanding
           and regulation.
                       DR. FORD:  Jack, thank you.  We appreciate it.
                       I'd like to ask Larry Matthews from the Materials Reliability
           Program at NEI to give a presentation.  
                       Larry, do not feel confined by the quarter to four.  I've been
           told that I'm not supposed to tell you that.
                       DR. FORD:  Go as long as you want, but recognize most of
           the panel have already heard your presentation of yesterday, apart from Dana.
                       MR. MATTHEWS:  Yes.
                       DR. FORD:  Was I correct in saying that?  No?  Five minutes? 
           Four o'clock.
                       MR. MATTHEWS:  Maybe I can get through in time for some
                       DR. FORD:  Good.
                       MR. MATTHEWS:  I'll start with Slide 76 if you want to thumb
           through there from yesterday's presentation.  I didn't realize I needed to bring
           a separate package today, so what we passed out yesterday.
                       Basically the industry feels there's reasonable assurance that
           the PWRs don't have circumferential cracking that would exceed the structural
           margins based on a few things.  Oconee and ANO-1 says here in the highest
           grouping these four units are the four highest units in America on time at
                       These leaks that were found at these plants were discovered
           by careful visual examination.  We recognize, everybody recognizes we're
           looking for something different than we probably were looking for a year ago.
                       Oconee-1, when they found out a very small amount of
           leakage, everybody recognizes that that's what we have to be looking for now.
                       Volumetric exams that were done at Oconee-1 and 3 on a
           scope expansion or whatever you want to call it, extent of condition examination
           of the other nozzles that were not leaking, and only found minor craze cracking,
           which they've been seeing in other nozzles and tracking for years.
                       These leaks were discovered in time with plenty of structural
           margin remaining at the time they were discovered and repaired.
                       DR. POWERS:  Could I ask you what the significance of that
           second bullet is or maybe it's the third one?  Volumetric examination, minor
           craze cracks.  Are you saying the volumetric examination is not a reliable --
                       MR. MATTHEWS:  No, that's not what I'm saying.  I'm saying
           -- I'm not talking about the nozzles that were leaking.  I'm talking about the
           nozzles that were leaking.  I'm talking about other nozzles.
                       The volumetric examination did not, and we have to admit this
           right now, a priori pick up the circumferential flaws, et cetera, that were found
           in Oconee.  Going back and looking now at the data, you know, NDE's hindsight
           is great, but now we have the lessons learned.  They call it lesson learned. 
           Now those things are available to the people as we move into the future.
                       DR. POWERS:  What you're saying is the volumetric
           examination for those that crack, the volumetric examination detected nothing,
           not even minor craze cracks?
                       MR. MATTHEWS:  No, no, no, no, no.  The volumetric exam
           could pick up the cracking, and when they go back and look at it, they could find
           all sorts of cracks in those nozzles that did crack.  The one thing they missed
           was the circumferential flaws.
                       Then when they go back and look at the data after they
           discover those circumferential flaws in the process of repairing the nozzle and
           look at the data, they say, "Oh, yeah, there was evidence."
                       And we're working with the industry  right now and with the
           NDE Center and with the vendors to refine those techniques so that we've got
           a better shot at finding those kinds of things when we do volumetric.
                       DR. POWERS:  Well, I guess I'd come back.  What's the
           significance of only minor craze cracks?
                       MR. MATTHEWS:  Oconee units and several other units have
           seen this kind of very, very shallow, multi-initiation sites, axial flaws on the ID
           of the nozzle that don't grow, and they've tracked those for years at Oconee. 
           They call it craze cracking, and they haven't grown, and they've tracked those
           for, I think, three examinations, three outages at Oconee, and just there they
           are.  They don't grow.
                       The significance is when they look at the other nine nozzles,
           they found no significant flaws.  That was the significance of that.
                       DR. POWERS:  They looked at the nozzles the first time
           around and they found no significant flaws either.
                       MR. MATTHEWS:  Which ones?
                       DR. POWERS:  The ones that were cracked.
                       MR. MATTHEWS:  On Oconee-1 that's true, on Oconee-1. 
           They were looking -- on Oconee-1, the detection, I mean, the NDE was
           different.  They used eddy current.  Eddy current would not see the OD flaw. 
           Now that's not what we're talking about on volumetric exams here.
                       DR. FORD:  You're talking about ultrasonic?
                       MR. MATTHEWS:  Ultrasonic and/or I heard someone today
           talking about complete with the surface eddy current, which is where you come
           down all the way back up the OD of the tube and the weld, do eddy current on
           all of that.
                       And if you've got no initiation sites and no cracks there, you
           don't have anything in the annulus, but, yeah, UT also for the volume of the
                       PARTICIPANT:  You find a lot of stuff that isn't there.
                       MR. MATTHEWS:  Okay.  The other point, several other
           plants this past spring after they knew about Oconee-1 and Oconee-3, several
           other plants and some of those in the highest group went and did top of the
           head, under the insulation visual inspections and found no evidence of leakage.
                       DR. POWERS:  So license renewal is the key here.  If you get
           your license renewed, then you get cracks.
                       MR. MATTHEWS:  I hope not.  Hatch is up next, but Hatch
           cracked a long time ago all over the place.
                       DR. POWERS:  Short parameters come to mind here.
                       MR. MATTHEWS:  I hope Calvert isn't in that list.
                       The schedule for some of this stuff, we weren't going to get
           some revised inspection recommendations by the end of this month, but due to
           the pending bulletin, we decided to hold off and see what we could work out.
                       We have convened an expert panel to look at the crack
           growth issue both in annulus and normal, and their first meeting is next month.
                       DR. POWERS:  Since the experts never anticipated this kind
           of a cracking to occur, why are they experts?
                       MR. MATTHEWS:  They're the guys from all over the world
           who have been doing this lab work on crack growth data and --
                       DR. POWERS:  But in 1997 we have everybody in an uproar
           looking at this stuff, and they gave us a clean bill of health, I mean.
                       MR. MATTHEWS:  Well, this is a new -- the OD initiated
           clause is new.  
                       We were planning numerous inspections during the fall 2001
           outage.  The final RPV penetration safety assessment was scheduled for the
           end of this year, and reassessment of the inspection results that come out of the
           fall outages, we were going to get that in time to give some help to the spring
                       We have other activities ongoing.  We're working on the risk
           assessments.  That's going now.  We're going to try and get something here
           very shortly to work with the staff and make sure we're kind of in agreement on
           what the risk of this event is.
                       We're initiating some probabilistic fraction mechanics as part
           of our risk assessments.
                       NDE demonstration, that's ongoing now or not the actual
           demonstrations, but discussions with the vendors about what kind of NDE
           capabilities they have, what kind of sabers they can throw up, the
           Westinghouse or any of them.  That's under technique development.
                       We're designing a block with OD initiated flaws to get that
           thing available so that these vendors -- and it won't be a PDI qualification.  It will
           be an open demonstration, but at least we can take a look at what the
           capabilities are before we throw this under a head.
                       We're developing an information and training package for
           those people who will be doing the visual examinations, will be using lessons
           learned from the plants that have already done them, including Oconee and
           some of the other plants that did them this spring.
                       They're working on flaw evaluation guidelines and review and
           repair of mitigation strategies would be a longer term approach.
                       DR. POWERS:  In the material that the staff has put together,
           they make quite a point about training people to distinguish old boric acid
           crystals from new boric acid crystals or something like that.  What are you telling
           people in this training package?
                       MR. MATTHEWS:  We're going to show them what old looks
           like.  We're going to show them what new looks like.
                       DR. POWERS:  I'm fascinated.  They have different wave --
           different vibrational frequencies, different -- I mean, what is different about an
           old crystal and a new crystal?
                       PARTICIPANT:  Color.
                       MR. MATTHEWS:  This is what a leak looks like.
                       DR. POWERS:  That's 100 percent of every leak that will
           possibly occur, is going to look like that?
                       MR. MATTHEWS:  Everyone we've seen has had something
           that's similar.  Here's the Oconee-1 one.  This was one at Oconee-3.  This was
           another one at Oconee-3.
                       DR. POWERS:  That tells me about Oconee.
                       MR. MATTHEWS:  Yes.  The only other one we've got is
           ANO, and it looks pretty similar.
                       DR. WALLIS:  So you look for white stuff appearing around
           the --
                       MR. MATTHEWS:  Yeah, white stuff right around, and every
           one of them has had downhill -- on the downhill side, if there is a downhill side,
           that's where the stuff has accumulated.  Basically there's an annulus that's kind
           of angled here, but it's flat on the bottom, and this is the low point, and so
           anything that liquid got in there would run out down here.
                       DR. WALLIS:  Well, liquid is available because the acid
           changes the boiling point so much that you don't boil off all the water.  It is a hot
                       MR. MATTHEWS:  Yeah, it's hot.
                       DR. WALLIS:  You expect the water to disappear.
                       MR. MATTHEWS:  It could be leaking when it's cold, too.
                       DR. WALLIS:  When it's cold it leaks?
                       MR. MATTHEWS:  I don't know.  I don't know where this stuff
           is coming from.
                       MR. MATTHEWS:  It's coming from down there, and it leaks
                       MR. SIEBER:  It's not leaking when it's cold because you can't
           pressurize the vessel when it's cold because of brittle fracture.
                       MR. MATTHEWS:  That's true.
                       DR. POWERS:  It seems to me that I would be very
           suspicious of using color as an indicator because that says something about
           how dirty or not dirty the head was at the time the material came out.
                       DR. FORD:  Radiochemistry -- when we asked this question
           yesterday and had your E-mail, we asked this question.  There was an answer
           to do with radiochemistry.  I don't know if they --
                       DR. POWERS:  F centers?  F centers and boric acid crystals
           or something?
                       DR. FORD:  All I'm doing is just repeating what the answer to
           it was.
                       MR. MATTHEWS:  Looking at the activation and the decay,
           they can tell to some extent.
                       DR. FORD:  Can tell the age of the --
                       MR. MATTHEWS:  How old the boron deposits are, if they got
           irradiated in the vessel, picked up neutrons.  They can look at the ratios and
           figure out is this new boron or old born.
                       DR. WALLIS:  That means you actually grab the boron and
           do tests of it?
                       MR. MATTHEWS:  Yeah.  You got up there, and you scrap
           some off, and you take it to the county lab.
                       DR. WALLIS:  That's very different from relying on visual
                       MR. MATTHEWS:  Yeah.  
                       DR. POWERS:  Well, I mean, it sounds like fairly fuzzy --
                       MR. MATTHEWS:  But they didn't do that until they had the
           leak and they were trying to figure it out how long it had been leaking.
                       DR. POWERS:  I mean, quite frankly, it sounds preposterous. 
           The crystal forms only when the boric acid solution gets outside of the vessel,
                       MR. MATTHEWS:  Right.
                       DR. POWERS:  Okay.  Is it the irradiation there that does
           something to --
                       MR. MATTHEWS:  No, no, no, no, no.  It was when it was
           whipping through the core over and over.
                       DR. POWERS:  When it was whipping through the core, it
           was in solution.
                       MR. MATTHEWS:  Yeah, and then it leaked out and formed
           a crystal, but the boron didn't change a lot from the time it was inside the core
           until the time it leaked out, but --
                       DR. POWERS:  Yes, it did.  It crystallized.
                       MR. MATTHEWS:  Okay.  We're looking for the -- 
                       DR. POWERS:  -- absorbed the neutron or something like that
                       MR. MATTHEWS:  It did.
                       DR. POWERS:  -- and changed its --
                       MR. MATTHEWS:  It did.
                       MR. SIEBER:  There's plenty of neutrons on the outside of the
           head, I think.  So you look at the ratio between boron and whatever it turns into,
           lithium, and from that ratio you can get some sort of an estimate sa to how
           many neutrons this stuff absorbed.
                       DR. POWERS:  Once it's outside and crystallized.
                       MR. SIEBER:  Once it's outside, yeah.
                       DR. POWERS:  Nothing to do with what it was inside.
                       MR. SIEBER:  Well, the same process goes on, but there's
           a different removal process.
                       DR. POWERS:  How do you distinguish the lithium form by
           transmutation from the lithium that was formed because they put lithium in the
                       MR. SIEBER:  Well, at hot zero power, the boron
           concentration is 1,800 ppm, and the lithium that's added provided that you have
           a plant where you add it is at 2 ppm.  So, you know, I would suspect that the
           lithium --
                       DR. POWERS:  That's good.  Two ppm of lithium represents
           how much neutron absorption?  A bunch.
                       MR. SIEBER:  Yeah.  That's right.
                       DR. POWERS:  Okay.  All taking place on the outside of this
                       MR. SIEBER:  Some, and it's not a very good method.
                       MR. MATTHEWS:  Sine we don't know much about the
           driving forces here, like Jack said, he did a pretty good job of describing the
           model.  What we've done is an effective time and temperature model to rank the
           plants, the point being not to try and predict that this plant is going to leak in 15
           years, but to try and decide where we should concentrate our resources as an
           industry to try and learn more about this issue.
                       And it's an effective time at temperature because these plants
           don't all have the same head temperature, and it's very driven by the
           temperature.  So we normalized everything to 600 degrees and ranked them up
           here.  The three Oconee units are right at the top of the heap.
                       One of the things is will it leak.  These are the interference fits
           of all the leakers, and even nozzles that have interference fits as tight as 1.4
           mLs here leaked when they developed the through wall cracks.
                       This is a cold, as manufactured.  We have calculations which
           I thought --
                       DR. WALLIS:  You were telling us that they opened up when
           they're actually --
                       MR. MATTHEWS:  Yeah, they do tend to open up when you
           pressurize the head because the dilation of the head, and I could put that up. 
           I think I'll skip it.
                       Several plants did inspections.  These are the ones that did
           inspections this spring.  Robinson-2, Salem-1, Farley-2, Prairie Island-1.  Prairie
           Island has a configuration not exactly like, but similar to the --
                       DR. WALLIS:  You're talking about this interference fit opening
           up, and it opens up essentially an enormous area compared with the size of the
           -- it's a huge flow area compared with the little crack area.
                       MR. MATTHEWS:  The flow area.
                       DR. WALLIS:  That's what we need to think about.  The area
           of the annulus interference is enormous compared with flow area.
                       MR. MATTHEWS:  Well, the PWSCC cracked.
                       DR. POWERS:  -- will crack, which is supplying it.
                       MR. MATTHEWS:  Yeah.  Most of these heads on these
           plants which are all Westinghouse units except SONGS are reasonably free of
           any kind of masking, boric acid deposits.  These deposits have a tendency to
           be much more evident on the B&W plants because of their flanged CRDM
                       Basically the industry believes that most, if not every single
           one of these, penetrations would leak if you -- and show boric acid.  This is
           something that the staff says we need to prove or at least those high
           susceptibility plants need to prove it.
                       This is just another way of looking at the histogram.  These
           plants that come out here that show hundreds of years to being equivalent to
           a CONY are actually co-head plants.  Their heads are running in the 560 range. 
           Most of these heads are hot or warm head plants.  "Warm" might not be a right
           term, but it's pretty hot.
                       DR. POWERS:  "Hot head" is probably not the right term
                       MR. MATTHEWS:  Yeah.  Well, the Oconee head is pretty
           hot, and all of the B&W units.  These are the Oconee units.  I believe this is the
           A&O unit.  These histograms were on preliminary information, but this is the first
           ten years.  This is where we proposed as an industry that all of these plants do
           a visual of the top of their head at the next refueling outage.
                       And what we were showing here is that this plant here  and
           that one and that one would be the only three that would not have done a visual
           inspection by the end of the spring outage season, and they would be into the
                       DR. WALLIS:  The thing I've been dying to ask is when you've
           done all this, is there some sort of idea of how you interpret the data when you
           find something, or are you just going to figure that out when you find it?
                       MR. MATTHEWS:  When we find a leak, you know, we start
                       DR. WALLIS:  Anyway, you start thinking again?
                       MR. MATTHEWS:  Pardon me?
                       DR. WALLIS:  You haven't thought about -- you're doing an
           experiment here.  So you want to think about how you interpret the data when
           you get it.
                       MR. MATTHEWS:  Yes.
                       DR. WALLIS:  I haven't seen any of that.  It's all just when we
           get the data, then we'll think about what it might mean.
                       MR. MATTHEWS:  Well, when we get the data and we find
           a leak, we go find out what it is.
                       DR. WALLIS:  It makes a big difference whether it's one on
           the left of that curve or one on the right.
                       MR. MATTHEWS:  Yes.  If it's one over here, then that brings
                       MR. ROSEN:  I didn't see your -- if it's one over?
                       MR. MATTHEWS:  If it's one over here or out there
           somewhere, then that's a totally different scenario than if this plant here or that
           plant there finds a leak.
                       And recognize that all of these plants that do have leaks so
           far are B&W design units.  We don't know if that means anything or not, other
           than the fact that they typically run with fairly high --
                       DR. WALLIS:  It's a very interesting drama.  When you find
           the next leaker, everyone is going to scurry around saying, "What does he
           mean?  What does he mean?  What do we do?"
                       MR. SIEBER:  Well, if you found one that was half way --
                       MR. MATTHEWS:  If we found one here.
                       MR. SIEBER:  -- on the right-hand side of this particular curve,
           it would destroy the theorem upon which susceptibility is based.
                       MR. MATTHEWS:  Yeah, if one of those cold head plants
           finds a leak and it is a PWSCC leak, et cetera, then you know we've got a lot of
           rethinking to do and so does the standard and everybody else.
                       DR. POWERS:  I mean before I would trash the whole theory,
           I would say that right now they're operating on the basis of temperature and
           time being their two dominate variables and residual stresses which they can't
           really estimate as being something that's secondary in the effect.  If you found
           one off in the other group, you'd probably just find that that other variable was
           very important.
                       MR. MATTHEWS:  Yes.
                       DR. POWERS:  And so it's not clear to me that everything is
                       MR. MATTHEWS:  Stress is a very important factor in
           PWSCC also, and you can override a lot of stuff if you put enough stress on it,
           but you can't get much beyond yield.
                       MR. SIEBER:  I think the problem is there aren't enough
           records, for example, what heat, what solvents, what the fit was, the welding
           technique.  You can probably find in your lay records welding rod records.  You
           might have copper intrusion or some other phenomenon.
                       MR. MATTHEWS:  I guess the thing I really wanted to say --
           oh, somebody had mentioned about will it leak before or the rates between leak
           and a circ crack, and basically we've had 15 nozzles in the U.S. to leak so far,
           and three of those have had circ cracks, and 12 of them have had only axial or
           through wall cracks in the axial direction and no circ cracks.  And one of the circ
           cracks was a very shallow on the OD of the tube that had not propagated
           anywhere near through wall.  It was only an inch or so long.
                       So the horse race seems to be won by the leakage over the
           circumferential crack growth at this point in time based on those 15 leakers that
           we've had to date.
                       MR. SIEBER:  Yeah, but you can't detect that leakage until
           you do the visual inspection.
                       MR. MATTHEWS:  Exactly, and if it's all going to happen
           within two months, you know, we're --
                       MR. SIEBER:  You can't pick it up while the plant's operating.
                       MR. MATTHEWS:  Right.
                       MR. SIEBER:  Leakage instruments just aren't sensitive
                       MR. MATTHEWS:  I guess the reason I was putting this up
           was because I wanted to just address the fact that these are analyzed events. 
           The rod ejection accident is an analyzed event, but it was selected as the
           bounding reactivity insertion event that's possible, and you blow the rod out in
           100 milliseconds.  The transient is over before the rod gets out of the core.  It's
           already turned around, and the reactor is subcritical again before the rod is
           completely withdrawn in the ejection event.
                       Another ejection, very unlikely in our opinion.  These are very
           heavy tubes.  This is a very tolerant material.  We haven't done the calculations
           yet.  We're going to have to.  It's a four inch diameter tube with a five-eighths
           inch wall.  It's going to take something else to knock that thing off of there.  It's
           going to take a lot of force and --
                       PARTICIPANT:  Well, we have to go figure all of that.  We
           don't know what it is yet.
                       DR. POWERS:  If it's intact.
                       MR. MATTHEWS:  If you've got a bunch of them sitting there
           that are already cracked all the way to where they're just barely staying in there,
           yeah, we don't think that's very likely either.
                       DR. POWERS:  Well, I mean, you had how many of them
           cracked in your 20 plants?
                       MR. MATTHEWS:  We had only two on Oconee-3 that had
           circumferential flaws.  We had one that was a partial through wall on Oconee-2. 
           Those are the only three circ flaws that have been discovered.  That's the only
           thing that threatens an ejection.  Axial flaws will not threaten an ejection.
                       DR. POWERS:  So if I -- what you're saying is at Oconee we
           could have had two ejections.
                       MR. MATTHEWS:  No.  If we'd have buried our head in the
           sand for a long time, there was plenty of structural margin there, plenty of
           structural margin there, a factor of six to ejection, I think.
                       DR. POWERS:  Yeah, and two much how much of a factor?
                       MR. MATTHEWS:  Well, we think, you know, if you assume
           reasonable crack growth rates, I believe they had years, but if you assume that
           the crack growth rates just from Alloy 600, the crack growth rates that we've
           been using in other arenas, it was four to five years before they had got to the
           ASME code margin, which has a factor of three in it, and it was more years than
           that before they would have ejected the rod.
                       DR. POWERS:  Yeah, but we have just given it a 20 year
           extension of license.  We've got lots of time here.
                       MR. MATTHEWS:  Well, the Oconee units have committed
           to replace their heads. I'm not saying the rest of the industry is going to do that
           by any stretch, but --
                       DR. FORD:  Larry, could you put Slide 18 up?
                       MR. MATTHEWS:  Eighteen?  I'm not sure we have 18.
                       DR. ELTAWILA:  Then can I try to answer the issue of
           multiple ejection?
                       This is Farouk Eltawila.
                       Really all what you need is a period the distance between the
           multiple ejection greater than the .5 millisecond.  So because they are not
           relative, you know, by the time the first policy goes and you decay immediately
           in about .5 second, even if the second policy started, they are not going to add
           together, and it could be a different deposition.
                       So you really -- it's not the summation of the individual
           policies.  It would be -- so all what you need is .5 seconds between policies, and
           you can accommodate that.
                       DR. POWERS:  So anything over a half a second --
                       DR. ELTAWILA:  If they are delayed by over half a second,
           I really think the first pulse will completely disappear before the second one
           takes effect.
                       DR. POWERS:  So it's not coherent in that.  Now let me ask
           the next question.  How many do I have to eject before I have a recriticality
                       DR. ELTAWILA:  We need to do this analysis.  There is no
           doubt.  I just tried to answer, you know, that even if you have them more than
           one, you know, that -- that's to say they are not having in a sense continuously
           at the same time.
                       DR. POWERS:  One of the things you worry about is suppose
           you eject one.  Now you've got coolant blowing out of here, and you propagate. 
           You cause a crack in the next one, and that one becomes coherent with the
           three next to it, for instance, in this map that I'm looking at here.  They have a
           problem there.
                       I mean it's a little tricky thing, but what you're saying is the
           time constant you're looking for is a half a second less.
                       DR. ELTAWILA:  A half a second.
                       DR. POWERS:  And that's good information.  The criticality
           would be a good information, too.
                       MR. MATTHEWS:  Well, if you get into multiple ejections,
           you're going to have SI going.  You're putting high concentration boric acid in
           there.  So, you know, that's going to help to keep the thing shut down.
                       All of the cores are designed with between one and two
           percent shutdown margin with the strongest rod shut out.  I mean out, and that's
           at the cold condition.  So, you know, if you took the thing from hot to cold and
           left the strongest rod out because you blew it out, you've still got one to two
           percent shutdown by the time --
                       DR. POWERS:  And I wonder if the safety injection would
           have time to have any influence in your time schedules that we're looking at
                       MR. MATTHEWS:  I Understand.
                       DR. FORD:  Well, your risk assessment would be taking into
           account, for instance, the groupings of those, all those circle point and housings
           there presumably had circumferential cracks.  They had boron deposits.
                       MR. MATTHEWS:  Oh, absolutely not.  The only ones that
           had circ cracks, there were only two.
                       DR. FORD:  Oh, okay.
                       MR. MATTHEWS:  It was 56 and 50.  These are the only two
           that had circ cracks anywhere, and this is an agglomeration of Oconee-1 and
           3.  So --
                       MR. ROSEN:  Show me again which ones.
                       MR. MATTHEWS:  Fifty-six and 50.  Those are peripheral
           penetrations, and those are the only two on Oconee-3 that had circ flaws.  I'm
           not sure which one -- I don't have Oconee-2.  Yeah, the four leakers on
           Oconee-2 I don't think I have on here.  So I'm not sure which one is leaking.
                       DR. UHRIG:  The fact that that is circumferential is not there
           related to the steeper slope?
                       MR. MATTHEWS:  I don't know.  You know, that's something
           we'll have to figure out.  We used to think these are the only ones that are
           really, really susceptible before of the stress, the residual stresses, but maybe
           it means that because of the residual stresses, they crack first and they've had
           longer to grow a circ crack.
                       DR. FORD:  Any last minute questions for Larry?
                       DR. POWERS:  Well, I guess one.  The bulletin proposes
           some fairly prompt inspections and whatnot, and certainly you have outlined
           both in your oral presentation and in looking through your slide package quite
           a lot of activities going on.  I wonder if you could speak to the issue of how
           much better of a job you could do if you had a little relaxation, especially for
           those units that are not in your very highest susceptibility category.
                       MR. MATTHEWS:  Well, the ones that aren't in the highest
           susceptibility category, what the staff is proposing is the VT-2, qualified VT-2. 
           That's not a cheap exam.  In some plants it could be a million and a half dollars
           depending on their inspection -- I mean they insulation packages.
                       But the improvement on the VT exams is probably not going
           to grow tremendously.  The volumetric exams, I think we're on the leading edge,
           and we are scrambling to develop technology, and the vendors are working to
           try and get it in the field and get it demonstrated for those plants that may wind
           up doing volumetric in the fall, and that's a scramble.  It's a real scramble, and
           the demonstration that we're going to pull off, we hope, before the fall for those
           vendors is not -- it's not a qualification like we did in the 97-01 response.  It's an
           open test.  Here's the sample; here's what's there.  Can you find it?
                       DR. POWERS:  I understand what you're going to do.  I'm
           trying to understand how much better could you do if you had a little more time.
                       MR. MATTHEWS:  Well, I think we could do better.  How
           much better I'm not sure.  They could refine what ducers to use, what angles to
           use.  They could be refining, and maybe the eddy current technology, and
           especially the delivery technology might be improved significantly over the next
           few months as we move toward trying to make this a cheaper, better, faster
                       DR. UHRIG:  But you would lose the opportunity for those
           plants to refuel in the fall if you delayed it.
                       MR. MATTHEWS:  If we delayed the volumetric, yes.  But I'm
           not sure how many of them are going to do volumetric, and you know, it's been
           proposed by the staff for the ones that are leakers or have leakers, those four
           units, only one of which is coming down this fall.  I suspect the other three are
           going to try and put together some alternative, and I'm not sure.  You know,
           they're going to be working with the staff to figure out what that is.
                       DR. FORD:  Thanks so much, indeed.
                       MR. MATTHEWS:  Thank you very much.
                       DR. FORD:  Sorry we pushed you at the end there.
                       MR. MATTHEWS:  It's okay.
                       DR. BONACA:  Okay.  Thank you very much, and we'll take
           a break now for half an hour, and I guess we'll get together again at 25 of five. 
                       (Whereupon at, at 4:04 p.m., the Advisory Committee meeting
           was adjourned.)

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