485th Meeting - September 5, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Wednesday, September 5, 2001

Work Order No.: NRC-004                       Pages 1-132/196-303

                   NEAL R. GROSS AND CO., INC.
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                                 + + + + +
                               485th MEETING
                                 + + + + +
                             SEPTEMBER 5, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
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                       The Advisory Committee met at the Nuclear
           Regulatory Commission, Two White Flint North, Room
           T2B3, 11545 Rockville Pike, Rockville, Maryland, at
           8:30 a.m., Dr. Mario V. Bonaca, Acting Chairman,
                       MARIO V. BONACA, Acting Chairman
                       F. PETER FORD
                       THOMAS S. KRESS
                       DANA A. POWERS
                       STEPHEN L. ROSEN
                       WILLIAM J. ShACK
           PRESENT (Continued):
                       JOHN D. SIEBER
                       GRAhAM B. WALLIS
                       JOHN T. LARKINS, Executive Director
                       SHER BAHADUR
                       PAUL A. BOEHNERT
                       SAM DURAISWAMY
                       CAROL A. HARRIS
                       HOWARD J. LARSON
                       AMARJIT SINGH
           .                              C-O-N-T-E-N-T-S
           Opening Remarks, Dr. Bonaca  . . . . . . . . . . . 4
           Proposed Resolution of GSI-191, Dr. Rosen  . . . . 7
                 Michael Marshall . . . . . . . . . . . . . . 9
                 Art Buslik . . . . . . . . . . . . . . . . .42
           EPRI Report on Resolution of Generic Letter
           96-06, Waterhammer Issues, Dr. Kress . . . . . . .69
                 Jim Tatum  . . . . . . . . . . . . . . 83, 132
                 Vaughn Wagoner . . . . . . . . . . . . . . 101
           Reactor Oversight Process, Mr. Sieber  . . . . . 214
                 Michael Johnson  . . . . . . . . . . . . . 215
                 Mark Satorius  . . . . . . . . . . . . . . 221
                 Doug Coe . . . . . . . . . . . . . . . . . 257
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:30 a.m.)
                       CHAIRMAN BONACA:  Good morning.  The
           meeting will now come to order.
                       This is the first day of the 485th meeting
           of the Advisory Committee on Reactor Safeguards. 
           During today's meeting the committee will consider the
                       Proposed resolution of genetic safety
           issue, GSI-191, assessment of debris accumulation on
           PWR sump pump performance;
                       EPRI report on resolution of generic
           letter 96-06, waterhammer issues;
                       Reconciliation of ACRS comments and
                       Reactor oversight process; 
                       Proposed ACRS reports.
                       A portion of this meeting may be closed to
           discuss EPRI, information applicable to EPRI report
           and resolution of waterhammer issues.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Dr. John Larkins is the designated
           federal official for the initial portion of the
                       We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's sessions.  
                       A transcript of portions of the meeting is
           being kept, and it is requested that the speakers use
           one of the microphones, identify themselves, and speak
           with sufficient clarity and volume so that they can be
           readily heard.
                       I will begin with some items of current
           interest.  First of all, a list of topics for the
           meeting with the Commissioner Merrifield tomorrow
           morning has been distributed to you and also has been
           E-mailed to you.  The expectation is that the
           subcommittee chairmen responsible for the individual
           items which are in the list will take the lead in the
           discussion during the meeting with the Commissioner.
                       A second item, I'm sorry to announce the
           death of an ex-ACRS member, Mr. Jeremiah Ray.  He was
           an ACRS member between 1978 and 1983.  He served as
           Vice Chairman in 1982, and as Chairman in 1983.  He
           retired in 1984 due to health reasons.  He passed away
           on August 2001.
                       We will, I think, prepare a card and
           circulate it for signature from individual members and
           then mail it to his wife.
                       With regard to the items we have in front
           of us, the first presentation is going to be on the
           proposed resolution of GSI-191.  The staff does not
           have yet the proposed resolution.  So the intent here
           is to listen to the presentations and then make a
           decision on our part whether or not we want to write
           a report at this time.
                       Okay.  So we'll decided after the meeting.
                       Another item, you have in front of you
           items of interest.  In the first page you'll see there
           is a list of five Commissioners' speeches, and also
           under miscellaneous items, you'll see the last item is
           the announcement of the 29th Nuclear Safety Research
           Conference in October 22nd-24th, 2001, and the result
           of the registration form are attached.
                       I also believe that there is an
           introduction we want to make, and for that I turn to
                       DR. LARKINS:  Yes.  I'd like to introduce
           our latest member to the staff, Scott Sunn, and Scott
           is a senior computer science major at the University
           of Maryland.  He's going to be co-oping with the ACRS
           ACNW staff for the next four or five months. 
           Hopefully he'll have an opportunity to learn
           something, but if anybody needs any help in the
           computer or ADP area, Scott --
                       DR. LARKINS: -- is more than willing and
           quite capable of helping out.  So I'd like to
           introduce him.
                       Thank you.
                       CHAIRMAN BONACA:  Welcome aboard.
                       With that we'll move to the first item on
           the agenda is the proposed resolution  of the generic
           safety issue, GSI-191.  Steve Rosen is responsible for
                       DR. ROSEN:  Thank you, Mario.
                       It's an important issue that we heard a
           briefing on in July, and I understand this briefing
           will follow onto that perhaps with a slightly
           different slant.
                       Please go ahead.
                       MR. MAYFIELD:  Mr. Rosen, if I might, I'm
           Mike Mayfield from staff.  
                       I just wanted to touch on a couple of
           points before we started.  Since the July meeting,
           staff has been fairly busy trying to finalize the
           parametric evaluation that we briefed you on in July 
           and completing the risk and cost benefit analyses.
                       And Art Buslik is with us this morning to
           describe those analyses.
                       The other thing that we did since the July
           meeting was reached a management decision to
           transition this GSI from the old process under a
           particular office letter to the Management Directive
           6.4 process.
                       The committee has been briefed previously
           on that process, and we felt like this was a good time
           since the staff is getting ready to make 6.4 the
           accepted process for handling genetic safety issues. 
           We're at a point in the management of GSI-191 where
           the old process and the new process most closely
           align.  So instead of the resolution step, this is now
           the technical assessment step, but it's fundamentally
           the same thing, although there are some substantive
                       One of the things Mike is going to
           describe for you today is the difference between those
           two processes and the benefits, such as they are, in
           making the transition at this time.
                       This was a management decision that we
           reached in August, and we apologize for not having
           gotten this to you sooner, but it was something that
           we felt like this was the appropriate time to make the
                       Now, under Management Directive 6.4, there
           isn't an explicit request for a letter from the
           committee at this juncture.  However, that is an
           issue, as we discussed this with Mr. Thadani
           yesterday.  this is an issue that he feels like needs
           to be revisited in the management directive.  He
           doesn't think that it is in the best interests of the
           staff, the committee, or the public to move forward
           from the technical assessment step to the -- I've
           forgotten what they're called.
                       MR. MARShALL:  The regulatory guidance.
                       MR. MAYFIELD:  The regulatory guidance
           step without having some explicit feedback from the
           ACRS on whether or not you believe the proposed
           approach, as this moves from research to NRR.  He
           feels like it is appropriate to request a letter from
           the ACRS at this juncture.
                       So that's a step in the management
           directive we are going to be revisiting in the very
           near future, but it is something that we would request
           a letter from the committee if you're so inclined to
           write one at this juncture.
                       With that, I'd like to turn the
           presentation over to Mike Marshall and Art Buslik.
                       MR. MARShALL:  Good morning.  My name is
           Michael Marshall.  I'm the project manager for Generic
           Safety Issue 191, and Art Buslik and I will be making
           a presentation today.
                       I will be talking about the change from
           the old process to the new process:  how does it
           affect Generic Safety Issue 191?  I'll describe the
           proposed recommendation we'll be sending to NRR for
           resolution of Generic Safety Issue 191.
                       And Art will build on our technical basis
           for that, for our recommendation, and at the July
           meeting we talked about the work that LANL did for us
           with the parametric evaluation.
                       Here in Research, we had Sid Feld do our
           cost estimates for us.  Art did our benefits estimates
           and the core damage frequency contribution estimates,
           and he'll be covering that at the latter of the
           presentation today.
                       And this is just to reiterate.  Almost
           everybody is familiar with Generic Safety Issue 191
           since we are looking to see if debris accumulation on
           sump screen strainers causes problems for long-term
           recirculation.  From our last briefing we've
           concluded, yes, there's a possibility.  Well, yes,
           that's a credible concern.
                       But because of the variations, large
           numbers of variations from plant to plant, we can't
           say specifically if a particular plant has a problem. 
           So our recommendation -- I'll give a little bit of it
           away -- is that plant specific analyses are required
           to make that determination.
                       But before going on to our recommendation,
           talk about the change in the generic safety issue
           process.  Under the old process, and the status of new
           process essentially is the management directive
           administration essentially are checking to make sure
           it's in the right format, and so it should become
           final very soon.
                       And under the old process, the first three
           stages of both processes line up very nicely, and
           after the third stage they don't line up as nicely
           again, and so we thought this was a fine time to move
           Generic Safety Issue 191 from the old process to the
           new process for a couple of reasons.
                       Because Management Directive 6.4 has been
           receiving a lot of circulation within our office
           reviews and such, a lot of managers and staff actually
           might seem a little bit more familiar with the process
           that we're about to implement than the older process,
           and some of the discussions we're having between the
           offices we found out we would end up losing a number
           of time because we're talking one process and the
           other parties, assuming this management directive is
           what is going to be guiding the agency's generic issue
                       And so we found out we were talking past
           each other even though we agreed on technical details
           and how things should follow after that, and so that
           was one reason for switching processes, was just
           clarity internally.
                       Another reason is Generic Safety Issue
           191, at this point we are not going to close it with
           no new actions or no new requirements with saying that
           there's no additional actions.  So it's going to go on
           for another couple of years possibly, and under the
           old process, at this point we would have resolved
           Generic Safety Issue 191 and officially on the books
           it would have been closed.
                       In reality, we would have still been
           working sump block, again, for maybe a couple of
           years, where under the new process -- and this is one
           of the things we think we're taking advantage of -- is
           that they'll be tracking all the way through the
           verification so that it will be clear that the safety
           concern, the concern 191, was addressed then from
           outside the stakeholder's point of view.  They can
           look at it and track 191 to see how it was fully
                       DR. WALLIS:  You mentioned the word
           "closed."  Now, when is the issue closed?  It used to
           be closed around the resolution point in the old
                       MR. MARShALL:  Right.  Under the old
           process, it would have been closed under the
           resolution, at the resolution process.  Now an issue
           is closed when we determine that no further action is
                       For instance, we went through our analysis
           and determined that there's nothing here.  There's no
           need for backfit.  There's no safety benefit with this
           issue, and we'll close it with that finding.
                       For issues that at the end of the
           technical assessment stage, where we say, "Hey,
           there's something here.  There's something that needs
           to be addressed," we won't close it at that point
           because it was truly before never closed, and then
           we'll keep working the issue.
                       And if you're interested in the Generic
           Safety Issue 191, you won't have to grope around for
           finding what's the new identifier.
                       DR. WALLIS:  Would you then close it at
           the verification stage if you had to take action?
                       MR. MARShALL:  Well, any point along -- it
           will be closed any point along here if it was
           discovered.  For instance, let's say NEI and the
           Westinghouse Owners Group, they do additional work and
           decide, hey, we've found out that this isn't as big of
           a concern as you thought.  We don't need to do any
           additional action, and they provide that to us.
                       And we might close it saying, "Hey, the
           industry says, has proven to us that this isn't a
           legitimate concern," or we begin.  It goes all the way
           through where there's hardware modifications, and at
           that point it would be at the verification where we go
           back and check either through inspections or audits of
           selected utilities that it was implemented as we
                       CHAIRMAN BONACA:  But, you know, if I
           compare those two tables, I could be drawn to conclude
           that before you reached a resolution without
           performing a technical assessment, of course, you need
           to perform a technical assessment, right?  I mean, a
           technical assessment was part of the resolution
                       MR. MARShALL:  Yes.
                       CHAIRMAN BONACA:  And all you did, you
           expanded.  I'm still confused about what is new about
           the new process, I mean.
                       MR. MARShALL:  Well, what's new if we go
           to the next page, the key differences between the new
           process and the old process is not giving the
           perception that something has been closed when it's
           actually still being worked.
                       CHAIRMAN BONACA:  Okay.
                       MR. MARShALL:  That's the biggest
           difference, and I believe that was probably rooted
           more as a public confidence type of concern.
                       CHAIRMAN BONACA:  Okay.
                       MR. MARShALL:  Another one is just, again,
           for ease of tracking.  The generic safety issue
           designation will live on with the issue all the way
           through verification, where in the current process at
           the end of the resolution stage, the generic safety
           issue designation is no longer used as it goes through
           the remaining stages of imposition, implementation,
           and verification.
                       In the past usually that was turned into
           what's termed a multi-plan action.
                       CHAIRMAN BONACA:  Okay.
                       MR. MARShALL:  Now, the practical impact
           on us from moving from the old process to the new
           process, and it boils down to two things.  At the end
           of the technical assessment stage we won't have a
           resolution that's the agency position on this is what'
           going to be done.  
                       What happens here is Research will send a
           recommendation to NRR with our proposed recommendation
           for resolution, and that will be the next slide.  So
           instead of the consensus that we're sending to the EDO
           saying, "Hey, this is how Generic Safety Issue 191
           will be resolved," or sending a recommendation over to
           NRR, and so instead of -- and the couple  I'd already
           mentioned it -- there's no longer a memo to the EDO at
           the end of the stage.  It's an interoffice memo.
                       DR. WALLIS:  What is the driving force for
           finishing the job?  These things in the past have hung
                       MR. MARShALL:  Right now the driving
           force, I would say, for finishing the job is a couple. 
           There's a lot of oversight for generic safety issues. 
           Internally there's a lot of office level attention
           given to our deadlines.
                       Working these, there's a lot of emphasis
           on finishing them in a timely manner.
                       DR. WALLIS:  So there's some incentive for
           some manager to say it's being done or there's some --
           what's the --
                       MR. MAYFIELD:  If I might, this is Mike
           Mayfield from the staff.
                       There is a congressional oversight group. 
           Senator Dominici receives a monthly report on the
           status of each and every generic safety issue, and
           this is something that at very senior levels in the
           agency has taken quite seriously.
                       So there is significant impetus to
           continue and not lose momentum on pursuing these
                       MR. MARShALL:  And by going to the new
           process, it keep sit in that.  It keeps that
           visibility on this generic safety issue.
                       Okay.  I just want to cover the last
           bullet on page 5.  I think we've addressed the first
           two already, and so at the end of this month, by the
           end of September, we plan on sending our
           recommendation via memo to the office director of NRR,
           and at that point, in addition to closing the
           technical assessment stage, we will also be
           transferring the lead for Generic Safety Issue 191
           from the Office of Research to the Office of Nuclear
           Reactor Regulation.
                       And the proposed recommendation we plan on
           sending to NRR is on page 6, and there's two parts to
           our recommendation.
                       There's two parts to our recommendation. 
           The first part is to conduct the plant specific
           analysis, determine whether debris accumulation will
           impede or prevent ECCS operation during long-term
           cooling, during recirculation.
                       And the second part is if you discover a
           vulnerability during that assessment is to implement
           appropriate corrective actions.
                       DR. KRESS:  Now, since the staff was
           unable to actually do this on its own, do you think
           the licensees have the capability to make this
                       MR. MARShALL:  Well, we think they have
           the capability.  Yes, we do think they have the
                       DR. KRESS:  Do you think they can actually
           track, determine the source of this debris and track
           its transport and end up with how much and what the
           characteristics of the debris is that reaches their
           sump?  Do you think they have that capability?
                       MR. MARShALL:  Yes, I do.
                       DR. KRESS:  Is there guidance that is
           given to --
                       MR. MARShALL:  Not specifically for PWRs. 
           We had issued guidance for BWRs, and there's quite a
           bit of overlap in the guidance, considering it's
           usually done at a performance base level.
                       And essentially the guidance boils down to
           identify the debris, estimate how much transports, and
           then estimate what the head loss would be.
                       DR. KRESS:  Yes, of course.
                       MR. MARShALL:  And that's more or less it. 
           Now, the specifics of what particular debris they have
           in there is something we would leave up to the
           licensees to determine or whoever is conducting that
           analysis would determine.
                       DR. KRESS:  That's probably a plant
           specific issue anyway.
                       MR. MARShALL:  Right.  That's true.
                       DR. KRESS:  When each licensee makes this
           look to see if they're vulnerable, what happens then? 
           Do they come back to you with a report or do they fix
           it and you review the fix or what is the next step?
                       MR. MARShALL:  That hasn't been decided
           yet.  That's where NRR will enter in the next stage of
           the process.  They'll map out how it's implemented.
                       DR. KRESS:  Okay.  That's up to NRR to do.
                       MR. MARShALL:  So that's still to be done.
                       DR. POWERS:  Let me ask more about this
           debris, and some aspects of it certainly could be
           plant specific, I imagine.  Different types of
           insulation get torn off in the blow-down process, but
           I would suspect that some of it is very generic in
                       Do we have guidance on what that generic
           component of it is?
                       MR. MARShALL:  Let me answer your question
           slightly differently.  I think we would look at the
           debris from the way it's created, not at a specific
           material.  For instance, debris would be created by
           direct impact from the jet.  The possibility debris
           would be created by the environment in the
           containment, and that will include chemical reactions
                       And that's where we would direct probably
           our guidance if we started assembling guidance. 
           That's what we would probably recommend.  Then we
           could say specifically what jet impact would have to
           look at different types of materials.
                       The main one we focus on a lot because
           it's a large source is thermal insulation.  Then,
           again, we would recommend fire barriers possibly,
           especially if there's any fibrous content with that.
                       And then we could point out what would be
           the more problematic debris types.  Again, that would
           be a fibroblast, your calcium silicate.  So be very
           careful when you're doing your assessment of sources
           that you identify these types of debris because they
           tend to be the worst actors.
                       And coupled with that would be
           particulates.  Again, that would be generated possibly
           from the environment of the containment.  During
           normal operation you might have some of that material
           generated and also with the jet impact.
                       DR. POWERS:  There's been within this
           general field a lot of discussion of gelatinous
           material.  Do you give them any guidance on that?
                       MR. MARShALL:  Yeah.  Well, specifically,
           we would recommend that people look at right now --
           this is Michael Marshall if I'm sitting taking notes 
           back from the guidance.
                       DR. POWERS:  Okay.
                       MR. MARShALL:  Again, point out chemical
           reactions, then give examples of where this has been
           seen, and then again, leave it up for licensees in
           case we miss something to look for similar type of
           debris generation, or whoever is doing the analysis.
                       DR. POWERS:  Gee, I wonder how you look
           for that.  I mean, can you go to the Journal of
           Chemical Phenomena during reactor accidents and say --
                       MR. MARShALL:  What we did was we did our
           literature search, and we started looking for just
           chemistry following a LOCA, and there was a number of
           things we found, such as zinc precipitates, and we
           started collecting that information.
                       So there's some things that wasn't done
           specifically for debris clogging, and again, if you
           just start out with a broad literature search, you
           start finding work, and we found work that the Finnish
           regulators had done in this area that was very
           beneficial.  We shared that with industry on the 26th
           and 27th of July of some of the sources that you can
           look at.
                       And again, some of it when we went through
           it, we didn't use everything we discovered during our
           literature searches and our reviews, and so that's
           another area where we'll probably have to do a little
           more documentation than we planned to so that people
           will be fully aware what we learned during this
                       Because as we mentioned in the July
           meeting, we didn't use everything we learned to prove
           our case that this is a concern that we need to worry
           about.  So we know we might have collected a few more
           bits of information that we haven't shared, and that's
           one of the major comments we get from industry is,
           "Please tell us what you know.  Please tell us what
           you know.  Please tell us what you know."
                       And so in order to facilitate that, we've
           accelerated our documentation of the work we've done,
           and we right pretty much have tried by the end of
           November to distribute everything we've collected.
                       DR. POWERS:  Rain dump.
                       MR. MARShALL:  Yes.
                       CHAIRMAN BONACA:  Now, one thing I
           remember when this issue was raised in 1995, '96, or
           whatever, a number of plants did a calculation which
           were plant specific, and one of the findings was that
           they really had marginal NPSH and was not an uncommon
           condition to have the situation, which tells me if you
           have any degree of blockage, you could have no NPSH at
                       So isn't there some sense of urgency
           behind this resolution of this issue?
                       MR. MARShALL:  Well, I speak for the
           Office of Research.  There's a strong urgency from my
           office director down with regards to this issue.  Yes,
           there is a sense of urgency.
                       DR. WALLIS:  Now, thinking back to your
           presentation last time and the report that your
           consultants did, there seemed to be a lot of
           assumptions made about how the debris got to the sump. 
           I mean, you can get a sense of understanding of how
           jets affect -- steam jets and so on -- affect fibrous
                       But then the transport mechanism, I think
           there was a lot of almost hand waving, UI mean, sort
           of assumptions and so on.  So there's a lot of
           potential here for some licensees to hire some smart
           consultants who will do some other kind of an analysis
           with fancy transport equations and solving and proving
           that never gets to the sump because we don't really
           have a very good basis for knowing how the material is
           transported to the sump.
                       So there's going to be a lot of debate
           perhaps, and I'm wondering how that gets resolved.
                       MR. MARShALL:  Well, after the last
           presentation, I was taken aside by my colleagues and
           lectured that I didn't give enough credit for the
           amount of work we did with transport.  There are
           certain areas of transport we're pretty sure once
           we've published our results, especially once the
           material gets in water.  There's a very strong case
           that it will make it to the sump spring if it's of a
           particular size.
                       We've also done work in trying to estimate
           what that size is, and we believe we're going to get
           debris of that size, and then we rely a little bit on
           our work we did with BWRs on estimating how debris
           transports in a dry well to the wet well, and we use
           that to estimate how much would actually get into the
                       So there's enough work we've done out
           there not just on this study, but when we're working
           on BWRs which demonstrates that the plausibility of
           debris getting into the pool of water on the
           containment floor, then transporting to the sump
           spring, and in this analysis we made it even easier on
           ourselves by we essentially at the very beginning
           excluded debris that could transport and just focused
           on the smallest debris that would accumulate uniformly
           on the sump screen.
                       So, again, some of the stuff that would
           transport sliding on the floor we didn't include in
           our analysis to make it simple, but even without that
           debris, with the stuff that's more transportable
           because it's very fine and accumulation formally on
           the screen.
                       So in our analysis we didn't actually
           include all the different debris.
                       DR. WALLIS:  So you don't anticipate some
           real technical issues coming up where the licensees
           have a different analysis.  You think your technical
           basis is so sound that they will essentially do the
           same thing.
                       MR. MARShALL:  I'm not going to assume
           they're going to do the same thing.  Some licensees,
           for instance, the plant that we got some of our cost
           estimates from, they did things differently because
           they had different licensing constraints that they
           weren't willing to change, and so they made
           assumptions that whatever was destroyed got there.
                       And as a regulator, I don't think we would
           argue with that, and the same thing with the BWRs. 
           There's a whole different range of ways that
           individual plants handle this.  I doubt there will be
           a lot of uniformity as this goes forward.  There might
           be three, four, maybe five different approaches, and
           then there will be variance on those approaches, but
           for a BWR experience, everybody kind of did it based
           on a little bit of what they thought was right and
           what was their licensing basis and how much did they
           want to deviate or try to request changes from that.
                       It's the only fixed increase in the screen
                       MR. MARShALL:  No, there's a combination. 
           One reason we picked the increase in the screen area
           as a fix that's one not only with regards to the BWRs,
           but through other countries, that was the favorite
           solution.  Other solutions were minimizing your
           debris, and there's a couple ways to do that.
                       When we're doing debris generation testing
           with the Canadians, with Ontario Power Generation, one
           thing they started considering was essentially put
           another sheet of jacket over top of some of their
           insulations, and that significantly in our testing
           reduced the amount of debris generated.
                       Another approach is to switch from -- and
           this was an approach used, I think, by the Finns a
           good bit -- was they looked at the fiberglass and the
           more problematic materials, and they decided, let's
           switch to the RMI.
                       One thing from our parametric evaluation,
           the cases that were predominantly RMI, they didn't
           show up as -- they weren't ones labeled very likely. 
           They were mostly either unlikely or at the most
           possible for a large LOCA.  So changing your debris,
           minimizing your debris is one solution.
                       Other things I would expect that seem
           reasonable measures to take is to reevaluate your net
           positive suction head margins.  I would assume people
           would do that, see if they have credit for containment
           over pressure, if that's allowed or if they think
           that's defensible.
                       Another one might be operational changes. 
           There's a couple of things.  You've got your debris,
           and then you have the flow rate, and so if you were to
           use flow rate, you actually would decrease the head
           loss across the screen, but some people might not want
           to attach that because it attaches a strong philosophy
           with regards to how to respond to an accident.  You
           probably don't want to start off by cutting off pumps.
                       CHAIRMAN BONACA:  Are we looking at some
           scenarios that might be more likely than others?  For
           example, the CRDM housing breaking and debris from the
           location and could happen, just understand.  You know,
           obviously later on in the presentation there are
           evaluations of initiating event frequencies and so on
           and so forth, and they would be interesting to
           understand.  For example, debris generation from an
           event of that type, there may be something more likely
           than others.
                       MR. MARShALL:  During the study we didn't
           consider the CRDMs, and I think the bulletin that went
           out, they were asking for the type of materials in
           that area.  So at least we would have a feel for what
           type of materials we would consider.
                       CHAIRMAN BONACA:  Yeah, that's what I was
           looking for.  I mean the kind of debris that you would
           get from the kind of break.
                       MR. MARShALL:  Just to go back to the
           presentation for a moment, our technical basis boils
           down to two things:  the presentation we gave you last
           July, which is the parametric evaluation, and the work
           that Art will be presenting today on the risk and cost
           benefit considerations.
                       Now, we've shared all of this work, except
           for the cost estimate, with the industry on July 26th
           and 27th.  Actually over two days we were able to get
           a lot more detail, and unfortunately -- not
           unfortunately -- we actually covered more detail than
           we actually had published in the report we released
                       That was one of the comments that we got
           back from NEI, the industry in general through NEI,
           and they provided several other comments we plan to
                       But if you're interested, I could cover
           the first -- just recap the parametric evaluation or
           we could jump straight into the benefit and cost
           estimates.  I would recommend doing that.
                       DR. WALLIS:  Well, let me ask you.  Is
           there agreement from the industry with your
           conclusions?  You made this presentation.  Did they
           say, "Gee, whiz, you're right," or, "no, you're
           wrong," or what?
                       MR. MARShALL:  They haven't told us we're
           wrong.  I think that's a fair statement.
                       With regards to whether we're right or
           not, they would like, again -- their major comment
           would be, "We know you did more than you shared with
           us in writing so far.  Please give us the rest of it
           so we could make a better determination if we agree
           with you or disagree with you."
                       So their position -- well, I'm going to
           speak for them -- their position right now is we
           probably don't have enough information to say if we
           agree with you or disagree with you.  We don't see
           anything on the surface that seems obviously wrong,
           but again, we don't have all of the information.
                       I think that Kurt Cozens is coming up to
           answer us.
                       MR. COZENS:  This is Kurt Cozens, from
                       In all fairness to Mike, was it just
           Friday that we sent you the letter with the comments?
                       MR. MARShALL:  Yes, right.
                       MR. COZENS:  So he's just received those
           probably about the time he was wrapping up his
           presentation material here, and we would be happy to
           provide a copy of this letter to the staff.
                       Mike has properly characterized our
           overall findings that we do not have enough of the
           specific data to agree or disagree with the findings
           that the staff has done.  They have provided us a lot
           more information in the meetings that we had at the
           end of July that were not in the draft report that
           they had put together, and you know, we are continuing
           to look at that, and we'll do that once that's
           publicly available.
                       And we would be happy to provide ACRS a
           copy of that letter today.
                       Mike, do you have a copy that they could
                       MR. MARShALL:  I have a copy with me if
           you'd like to.
                       MR. COZENS:  Okay.  So that will help you
           guys, and you can see the full range.
                       DR. WALLIS:  So that means that you folks
           didn't have an assessment of your own to compare with
           the NRC assessment?
                       MR. COZENS:  We do not have the technical
           details that the staff has, and we were asked to
           comment on the --
                       DR. WALLIS:  You must have some technical
           evaluation from your engineers as to whether or not
           this is a problem.
                       MR. COZENS:  We are still in the process
           of seeing the data.  We have not seen the data yet. 
           So it would be inappropriate for us --
                       DR. WALLIS:  You haven't seen anybody's
           data but your own.  You must have some sort of a
           position as to whether or not you think it's a
           problem, or has it just been something that no one has
           worried about at all?
                       MR. COZENS:  We are continuing to look at
           it, and we've had questions about it, but we have not
           finalized it to make a formal industry position.
                       DR. WALLIS:  Well, that's a little
           disconcerting if this is a real technical problem and
           industry has no position.
                       MR. COZENS:  There is an industry group
           working on this, but until we have the technical data,
           we are not able to finalize our conclusions.
                       MR. BUSLIK:  Okay.  I'll start on the --
                       DR. KRESS:  Well, before you start,
           Michael if we wanted any more information on the
           parametric study since we had previously reviewed it. 
           I'd like to have you refresh my memory on just what
           parameters were varied and why -- not the actual
           ranges of those, but why -- what was the basis of
           choosing the ranges of the parametric variations?
                       MR. MARShALL:  Well, I'll go ahead and
           leave that up.
                       In the parametric evaluation, we varied a
           number of things, and usually the basis for the range
           we chose was the industry survey we collected.  NEI
           helped us with collecting information on, let's see,
           sumps, sump screen area size, height of debris curves
           in containment, times that licensed plants would
           expect to switch from RWST to the sump.
                       Sump water height was another factor we
           considered, and again, that was all based on responses
           to the survey.
                       DR. KRESS:  Did you vary the -- does your
           parametric variation include the source of debris?
                       MR. MARShALL:  The only variation we had
           with the source of debris was usually the amount of
           debris, and we varied the combinations of debris
           depending on how we -- on the varieties we saw at
           different plants, but we didn't vary the debris types
           beyond fiberglass, reflective metallic insulation, and
           calcium silica.
                       And then we had a reasonable amount of
           particulate debris, but the amount of those varied
           from different cases, and so we had cases that were
           mostly RMI, which again would show up as -- in most of
           the cases showed up as not being a -- showed up as
           being unlikely.
                       Then we had cases where the plants were
           cases where 100  percent fiberblast, and again,
           depending on the net positive suction and margin, size
           of the sump screen area, that ranged from probably
           possible to very likely.
                       DR. KRESS:  So you took plant specific
                       MR. MARShALL:  We took plant specific
           information.  We coupled that --
                       DR. KRESS:  And then coupled that with --
                       MR. MARShALL:  We coupled that with
           information we collected from two volunteer plants. 
           So from the volunteer plants we got the piping
           configurations, and so we assumed for all 69 cases
           they had one of these two piping configuration.
                       Now, both of those configurations were
           four-loop Westinghouse units.  Again, so when you look
           at a two loop, as far as the capacity of the screen to
           accumulate debris, we did a really, really good job
           there, and that's something I would recommend industry
           take because it doesn't require you to know how much
           is just transported and how much is generated.
                       You can sit down and do a calculation of
           if you have this type of material in your containment
           and you assume how much of it do you need to get on
           your sump screen to exceed your net positive suction
           margin.  That's one thing I liked about the approach
           we used, is regardless of transport amount of
           generation, you can always go back and look at what we
           call the threshold value.
                       And is that threshold value 100 cubic feet
           or is it just two cubic feet?  And I would say those
           of us that worked on the evaluation are very confident
           with that point of the evaluation.
                       And then, of course, there's the box.  I'm
           assuming people remember the presentation from last
           time when I referred to the box.  
                       Then there's that box where we had the
           unfavorable and favorable assumptions, and that sort
           of gave a feel for how much we actually thought would
           get transported to the sump screen, how much would be
           generated, and then we compared that to the minimum
                       DR. KRESS:  Thank you.  That helps.
                       DR. ROSEN:  Mike, do I understand that in
           this transition to NRR that's coming up, that NRR will
           make a determination at that point or after they get
           it and study the issue for some time as to whether or
           not they're going to issue a bulletin?  Did you say
           something about an NRR bulletin that I didn't
                       MR. MARShALL:  No, I was referring to the
           bulletins on CRDMs that went out.
                       DR. ROSEN:  Okay.  So there is no bulletin
           planned on this yet.
                       MR. MARShALL:  No.  Right now what -- and
           I'll speak for NRR, and please correct me if I'm wrong
           -- right now we're going to send over our technical
           basis in this information, and NRR wants time to
           consider again input from other industry groups with
           regards to our work, and then they'll decide on what's
           the appropriate regulatory path to take.
                       Is it a generic communication?  If it's a
           generic community, is it a bulletin generic letter? 
           Is the industry going to step up and propose something
           which would, again, that the agency might not have to
           issue a formal -- take formal regulatory action?
                       DR. ROSEN:  Okay.  I understand that. 
           That will be decisions made by NRR.
                       MR. MARShALL:  Right.
                       DR. ROSEN:  Now, let me just ask again
           about the approach of not issuing detailed guidance. 
           I know this is a little early, but that was probed a
           moment ago by some of the members, and your response
           was, no, we would not issue detailed guidance on how
           to do the analysis, the plant specific analyses.
                       MR. MARShALL:  What we would avoid doing
           is issuing prescriptive guidance.  It would probably
           be performance, and as a debate of whether how quickly
           we can get guidance out there.
                       MR. MAYFIELD:  This is Mike Mayfield.
                       The issue of guidance, do you issue a reg.
           guide or is there some other vehicle?  A reg. guide,
           regulatory guidance, that specific kind of document
           takes about two years to get out the door in a final
           form, and there was some, I think, a question earlier
           about some sense of urgency on this.  
                       We think it's not in anybody's best
           interest for the staff to take two more years to
           promulgate a regulatory guide.  So if we set aside a
           regulatory guide is something that we're probably not
           going to pursue at this stage.
                       What kind of guidance would the staff do
           presumably if we were going to issue some sort of
           generic communication?  That would provide some
           information , the collection of reports and analyses
           that Mike and his colleagues have worked on would be
           available and could be -- we could point to that as
           one method that could be followed.
                       So it's not to just go out to the industry
           with a suggestion they might go do something.  We have
           some --  you know, a fairly specific set of analyses
           and approaches that will be published and in the
           public domain and that could be used, and I think in
           that body of reports, there's a lot of information and
           a lot of guidance on what -- at least how we did the
                       So we're not asking people to just embark
           on something in a blind fashion.  As the same time, we
           don't see publishing a regulatory guide, at least not
           in a time frame that would support the industry going
           off and doing something on this issue.
                       DR. ROSEN:  Well, there clearly is a need
           for prompt action on this.  I think everybody thinks
           that there is some urgency here.  
                       There is also a need for putting out
           enough guidance so that you don't get apples and
           oranges responses that are not into comparable.
                       MR. MAYFIELD:  Yes, we agree.  And, again,
           if the staff chose to go down a path of some sort of
           generic communication, a combination of information
           that would be included in that document as well as
           references to the reports that Mike and his colleagues
           are getting ready to put out would provide the level
           of guidance to provide the kind of consistency you're
           talking about.
                       DR. WALLIS:  Sorry to go back to this, but
           I've just read this NEI letter which we see here which
           was sent on August 31st, and all of the comments are
           critical.  It seems to me that  we've been talking
           here as if your conclusions are acceptable, but it's
           not at all clear that that is the industry position.
                       I think you may have quite a fight on your
           hands, in which case it's not clear that things are
           going to be quite as smooth as has just been
           discussed.  You just sort of go ahead, and now I was
           going to accept your conclusions, and you know, some
           regulatory action will be taken.  You may have quite
           a debate going on in the next year or so.
                       That's my sense of the NEI letter.
                       MR. MAYFIELD:  This is Mike Mayfield.
                       Based on some other dialogue we have had
           with members of the industry and some of the staff at
           NEI, we think that while there are many questions and,
           indeed, the comments you see in the letter tend to the
           critical or questioning side of the spectrum, we
           weren't surprised by those.  In fact, that's pretty
           much what we would have anticipated.  I think that's
           what we were looking for is where they saw soft spots
           or areas that they thought should be expanded.
                       This is an issue that will require, I
           suspect, some extensive dialogue and a fair bit of
           interaction.  It is -- the piece of work we did is not
           all that conclusive.  It was a parametric evaluation. 
           It was a scoping evaluation to decide if there's
           something there that should be pursued.  We think that
           the piece of work makes that case.
                       We will have some discussions with the NRR
           staff and management as we go forward.  If we were all
           in complete lock step on this, then I'm not quite sure
           what presentation we'd be making to the committee or
           how it would differ, but the fact is there's a
           process, and we've embarked on it.
                       To suggest to you that, like I say,
           everyone is in lock step  would be incorrect.  At the
           same time, we think there is a good case that's been
           made to pursue the activity.
                       MR. COZENS:  This is Kurt Cozens from NEI.
                       With regards to the letter that we
           provided staff, the letter was provided in response to
           a specific request that we provide them comments on a
           draft research report that had been written.  The
           draft research report had been accelerated, and it
           appeared that many of the assumptions that were taken
           in it and the analyses that were performed to provide
           the more conclusions and the underpinnings of that
           were not provided in that particular report.
                       The letter that we submitted identified
           specific areas where we wanted to see more detail as
           to how those were arrived and the logic behind those
           selections.  We had the process of very thorough
           evaluation and have not been able to go over those in
           detail as of yet. 
                       However, I will note that on the was it
           July 26-7th meeting we had with the staff?  Many of
           those details were, indeed, discussed at that meeting,
           but they are not in the report at this point in time,
           nor are they in a format that we can actually review
                       So, you know, I would like to compliment
           staff on its efforts to coordinate its activities with
           industry.  We've gotten a lot of benefit out of that. 
           We have provided the staff with a great deal of
           information to make this study possible, everything
           from the basic survey of where industry is through the
           effort of identifying volunteer plants to give very
           explicit detail which made the study even possible.
                       So we have been an active participant in
           this.  You know, we are still evaluating the data,
                       MR. BUSLIK:  Concerning the risk and cost-
           benefit analysis, the work that I did had to do with
           calculating the decrease in the core damage frequency,
           and doing the benefit analysis as per the reg.
           analysis guidelines.  Sid Feld did the costs
           associated with fixing the problem, and there was an
           uncertainty analysis.
                       An outline of the approach, I'm going to
           calculate the difference in the core damage frequency
           given before the fix and after the fix, and basically
           you would have to look at the event sequences on an
           event tree where it matters whether the sump clogs or
                       And these basically are given as follows. 
           You have a LOCA.  You're not able to cool down and
           depressurize and use your RHR system as you would in
           a normal shutdown.  The sump clogs to the point where
           you fail emergency coolant recirculation, and
           emergency contingency action type recovery actions
           fail.  These are, for example, in the emergency
           response guidelines of Westinghouse, ECA-1.1.
                       There are various size LOCAs.  There are
           also very small LOCAs and stuck open pressurizer
           safety valves which are not considered here because,
           as I'll indicate later, they don't contribute.
                       The initiating event frequencies I used
           came from NUREG CR-5750, and the large LOCA frequency
           comes from assuming that from taking the number of
           leaks in large piping that have occurred and
           estimating the probability of going to a rupture from
           a leak.
                       The means and the five percent/95 percent
           bounds are given there.  For the reactor coolant pump
           seal LOCA basically there's an error factor of three
           so that the lower bound is 5.60 minus four and the
           upper bound is 5.4 E minus three, according to the
           table in NUREG CR-6750.
                       As far as the control rod drive mechanism,
           whether it would be important or not would depend on
           the kind of plant and how big a LOCA would be.  
                       Also, the type of insulation may tend to
           be more reflective metal, metallic insulation in most
           plants.  That would be the most benign, but you would
           have to look at each plant.
                       I did look at the seismic contribution to
           the initiating event frequencies for Surry using
           fragilities from the old NUREG 1150 study and also
           using the revised Lawrence Livermore hazard curves. 
           They were smaller than the initiating event frequency
           listings, although there was some contribution for
           large LOCA.
                       However, since we have arrived at the
           conclusion that it's cost beneficial without seismic,
           it won't make any difference if we include it.
                       For recirculation and nonrecovery,
           basically you're going to have to go to sump
           recirculation for large and medium LOCAs as I indicate
           later.  So these are only important for small break
           LOCAs and reactor coolant pump seal LOCAs.
                       And it depends -- how successful you'll be
           will depend on the kind of plant you have.  If you
           have a large, dry containment, emergency fan coolers,
           and large refueling water storage tanks, then the
           chances of being able to cool down and depressurize
           before you've exhausted your -- you've gotten to the
           point on the refueling water storage tank level where
           you're forced to switch is fairly good.
                       For a subatmospheric plant, the RHR at
           least at Surry, it's inside containment, and it's not
           environmentally qualified.  So there would be
           questions as to whether you could actually go on
           residual heat removal there.
                       And plants with ice condensers, the
           containment spray goes on at a very low pressure, and
           you would exhaust the refueling water storage tanks. 
           So again, there's no chance.
                       Some of this material in the next slide
           I've already covered.  For medium and large LOCAs you
           have to go to sump recirculation.  For very small
           break LOCAs, the chances of needing to go to
           recirculation was negligible.
                       I mean, it was pointed out to me that, for
           example, if all your charging pumps failed, then you
           probably would be forced to, but that's a low
           probability event, and I just didn't consider it.
                       CHAIRMAN BONACA:  And I want to let you
           go.  You know, you're presenting us with the cost-
           benefit analysis, and I'll be very interested in
           seeing this, but I'm trying to understand the whole
           logic now.
                       The FSARs or these power plants state that
           you have high pressure injection and low pressure
           injection.  You run through half of your RWST.  Then
           you switch to recirculation and you depend on that
           recirculation for preventing core damage.
                       Now, it is a commitment of the FSAR.  Now
           we have doubt that the analysis provided in the FSAR
           is adequate, I mean, and there is reasonable -- there
           are reasons to doubt because the analysis does not
           address sufficiently debris or because we find that in
           some cases MPSH was very marginal, and so on and so
                       So there is a reasonable position that the
           NRC is raising here that is basis from the analysis
           done at some plants that there is a concern.  I'm
           trying to understand why would you need a cost-
                       MR. BUSLIK:  The reason is, and I can't
           quote the exact document, but even for issues of
           compliance, which is what you're talking about --
                       CHAIRMAN BONACA:  Yes.
                       MR. BUSLIK:  -- compliance with
           regulations, we're supposed to do a cost-benefit
                       CHAIRMAN BONACA:  Okay.
                       MR. BUSLIK:  This has been for a couple of
           years now.  I think there was some SECY paper where it
           was mentioned, and there was an agreement with
           industry, the idea being that if the issue really
           doesn't have any safety significance, that you may
           want to avoid -- you may want to basically have a
           waiver of some sort.
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       DR. WALLIS:  It's a way of risk informing
           the regulations.
                       MR. BUSLIK:  Yes.
                       DR. WALLIS:  Without definitely changing
           them, you know; modifying them.
                       MR. BUSLIK:  That's right.
                       CHAIRMAN BONACA:  But in any case you
           would perform a cost-benefit.
                       MR. BUSLIK:  Yes.  I don't think it has to
           be as elaborate as a cost-benefits analysis for a
                       Now, stuck open pressurizer safety valves
           are a special case because the discharge from a safety
           valve would be routed to the quench tank, and if it
           got into containment, it would be through a rupture
           valve there, and I am told that because of the
           location of a quench tank and other things, there's
           very little likelihood that that would cause a
           clogging of the sump.  So that was neglected.
                       Now, as far as the probability of some
           clogging is concerned, the LANL draft report, which
           you've has a presentation on, assigned -- I believe
           you did -- assigned qualitative, very likely, likely,
           possible, and unlikely designations for whether the
           sump would clog on various size LOCAs, separate for
           different size LOCAs.
                       After consulting with Mike Marshall and
           D.V. Rao at Los Alamos, I assigned these
           probabilities.  More recent probabilities are possible
           as .4 instead of .3.  It will not make any difference,
           and the direction that it would go, it's small, but
           the direction that it would go would be to make it
           even more cost beneficial.
                       I considered three aggregates of the
           plant.  The idea here is for any individual plant
           there may be uncertainties because of lack of plant
           specific information, but you consider the fact that
           if you consider an aggregate of plants, these
           uncertainties will somewhat cancel.
                       So we consider a case which at that time
           had 23 plants, and according to more recent
           information has 25.  There are some clogs on all size
           LOCAs, and there are 18 large drives and five
           subatmospherics there.
                       The 32 plant case --
                       DR. WALLIS:  Excuse me.  That means that
           they clog with any kind of a LOCA?
                       MR. BUSLIK:  Even the reactor coolant pump
           seal LOCA, yes.
                       DR. WALLIS:  The reactor pump seal
           actually --
                       MR. BUSLIK:  I mean, they're relatively
                       DR. WALLIS:  -- actually produces jets
           which remove enough material?
                       MR. BUSLIK:  That was the question which
           Westinghouse asked, and I don't really know.
                       PARTICIPANT:  We're still collecting
                       MR. BUSLIK:  Yeah.  I mean, it will come
           out the top of the shaft, I guess, and so the 32 plant
           case, there are some clogs with fuzzy certainty for
           large LOCA and medium LOCA, and it can or cannot clog
           with various probabilities for small break, and in the
           40 plant case, it had a probability of one for large
           LOCAs and either one or .6 for medium LOCAs.
                       Now, the change in the core damage
           frequency, the mean change in the core damage
           frequency associated with the 23 plant item is all
           about one E minus four, and that indicates that
           there's a substantial safety benefit, but we still go
           on with the cost-benefit analysis.
                       DR. WALLIS:  But it seems to me that
           industry could easily come back with numbers which
           instead of probability one, one, and one were
           probability .2, .2, .2, and it would turn out that
           nothing matters at all.
                       MR. BUSLIK:  Yeah, I know, but if you look
           at -- I mean, you need really D.V. Rao or somebody to
           answer that, but if you look at some of the curves,
           you have a little box which has the range of
           particulates, and you have a place where if you're on
           the right side there's failure and on the left side
           there's not.
                       In some cases there's such an extreme
           difference that --
                       DR. WALLIS:  There's one or nothing?
                       MR. BUSLIK:  Yeah, in that case for that
           plant it would be the one.
                       DR. WALLIS:  Okay.
                       CHAIRMAN BONACA:  I mean, certainly an
           argument could be that, you know, a large LOCA, it's
           clear it can break and it is unlikely and so on and so
           forth.  So you would want to have some realistic
           estimation of debris accumulation for break sizes that
           are not going to be in contention.  It would be
           interesting to have some.
                       So it would probably have some sensitivity
           as a function of break size.
                       MR. BUSLIK:  Well, the --
                       CHAIRMAN BONACA:  You have a meeting.
                       MR. BUSLIK:  These probabilities are by
           break size.  That came from the report.
                       CHAIRMAN BONACA:  Yeah, I understand.
                       MR. BUSLIK:  So I didn't do any
           sensitivity on the probability of some clogging,
           except for you'll see later that it's easy to see that
           it's cost beneficial even if for the ones where it
           wasn't one, it was zero instead of .6 and .3.
                       CHAIRMAN BONACA:  Okay.
                       MR. MAYFIELD:  Art, excuse me, if I could. 
           Just to pursue that point, the break frequencies that
           Art used came out of the NUREG 5750.  One of the
           points that we've talked about, without trying to
           insult my colleagues that did that piece of work, I
           don't think there's any question they did their sums
                       The problem with those frequencies is they
           can only capture experience up to the point in time
           when they did the analysis.  It can't capture new
           degradation phenomena.  It doesn't capture new aging
           phenomena that we haven't seen yet, and there's no way
           it could.
                       So the frequencies that Art has used, they
           reflect service data up to a point what, four or five
           years ago?
                       He noted on the one slide that they made
           an attempt to include the recent V.C. Summer
           experience and just a one crack in a largish pipe made
           a significant difference in that break frequency, but
           there's a lot of additional analysis that goes into
           that.  So we wouldn't want to put forward these break
           frequencies as the definitive statement the staff is
           making on break frequency, but it's something to work
           with for this kind of analysis, and it reflects
           service experience, perhaps except the most recent
                       MR. BUSLIK:  And, of course, if we used
           higher numbers like I've been using in the past in
           PRAs, it would be even more cost beneficial.
                       DR. WALLIS:  So you are not using those
           PRA numbers?
                       MR. BUSLIK:  For the initiating event
           frequencies.  Instead I was using these, the
           initiating event frequencies from NUREG CR-5750, which
           are smaller basically.
                       DR. WALLIS:  One would expect PRAs which
           are evolving to be more reliable.
                       MR. BUSLIK:  But the initiating event
           frequencies, my guess is that they're originally from
           -- for LOCAs, originally came from expert judgment. 
           It hasn't been changed that much.
                       Okay.  So to go into the monetized
           benefits, the kinds of things you have to consider
           according to our regulatory guidance are expected
           averted population dose to 15 miles, monetized at
           $2,000 per person-rem, expected averted off-site
           financial cost, expected averted on-site cost, and
           expected averted on-site occupational dose.
                       The largest contributor is the on-site
           cost, clean-up and decontamination and replacement
           power.  It's about 80 percent of the benefits.
                       The expected averted population dose to 15
           miles is about 17 percent.  If you look at -- if I --
           it would not be cost beneficial if this were a
           backfit, now, if we only consider the expected averted
           population dose, but it's not a -- I mean, that's not
           what our guidance is.
                       And of course, in a sense, the expected
           averted on-site costs should be subtracted from the
           cost that the utility has to make anyway, even if you
           have to consider it.
                       DR. WALLIS:  This simply gives you dollars
           per CDF, doesn't it?
                       MR. BUSLIK:  This --
                       DR. WALLIS:  Average plant.  
                       Do you have to do this calculation every
           time?  Don't you have a sort of rule of thumb of
           dollars per CDF?
                       MR. BUSLIK:  What I did was dollars per
                       DR. WALLIS:  Yeah, but eventually you're
           going to relate it to CDF.
                       MR. BUSLIK:  Oh, yes, yes.  The CDF is
           included there.
                       DR. WALLIS:  So it is dollars per CDF.
                       MR. BUSLIK:  That's right.
                       DR. WALLIS:  What is the dollars per CDF
           number, just so that I can sort of -- 
                       MR. BUSLIK:  Well --
                       DR. WALLIS:  Do you have it?  If you don't
           have it, it doesn't matter, but it seems that's what
           eventually --
                       MR. BUSLIK:  Yeah, I have it.
                       DR. WALLIS:  -- it comes down to, doesn't
                       MR. BUSLIK:  Well, first of all, it would
           depend, in general, whether it's a core damage
           frequency, which has a large contribution, a large
           early release fraction or not, but early containment
           failure basically.
                       But for this study 23 plants gave a
           benefit -- I mean, I don't have the numbers right in
           front of me.  I think maybe I do, as a matter of fact,
           but -- 
                       DR. WALLIS:  It's just very useful for the
           future when we're making these assessments if we have
           a rule of thumb that we can think about.
                       MR. BUSLIK:  Okay.
                       DR. WALLIS:  Maybe at the end of the talk
           or something.
                       MR. BUSLIK:  Yeah.  I mean, I have a slide
           that I could compute it from, but --
                       MR. MAYFIELD:  Why don't we take that as
           something that we can get back to you on, Professor
           Wallis, if that's acceptable?
                       DR. WALLIS:  All right, and there's no
           need to do it now.
                       MR. BUSLIK:  Yeah, okay.  Because the
           numbers I have depend on the number of years of
           operation of the plant and things like that.
                       We can skip this slide, I think.
                       The cost analysis, the data, of course,
           that's used are given on this slide, and the cost
           elements consisted of three parts:  up front
           analytical activities; the physical modification; and
           other cost elements.
                       The up front analytical activities, each
           plant would have to do them.  So it's independent of
           the number of plants that have to make the fix.
                       Physical modifications are proportional to
           the number of plants that have to make the fix, and it
           was assumed that audits and inspections were also
           independent of the number of plants that had to make
           the fix.
                       So that --
                       DR. WALLIS:  How big are the up front
           activities as a fraction of the cost?
                       MR. BUSLIK:  Okay.  You'll see it on the
           next --
                       DR. WALLIS:  It will come?
                       MR. BUSLIK:  -- the next slide.
                       DR. WALLIS:  I was wondering if the
           analysis doesn't cost more than the --
                       MR. BUSLIK:  Well, it depends.  If no
           plant had to make fixes, then obviously it would, but
           it's a linear function, and this is taken down to 2001
           dollars.  The assumption is made that the analysis is
           done in two years from now and the fix is made in
           three years from now, and it's discounted to the
           present at a seven percent discount rate, which is the
           value we're supposed to use.
                       And so you have six times ten to the fifth
           dollars, in other words, $612,000, for making the fix
           at each plant, and an up front cost of $9 million.
                       DR. ROSEN:  That's aggregate for the whole
           industry or is it per plant?
                       MR. BUSLIK:  The aggregate for the whole
           -- the nine million is an aggregate for the whole
           industry, but you get an idea here.  When this was
           done, it was assumed that 50 percent of the plants
           would go to license renewal, and there were some rough
           assumptions.  Really the way you should do it is you
           should look at every plant, know how many more years
           left, and make some decisions as to whether it is
           going to go to license renewal or not, and do that.
                       But we did it in a rough way, which is
           probably okay, but I'm told that industry may plan to
           have much more than 50 percent of plants go to license
           renewal.  That would make it even more cost beneficial
           because there would be more years with the fix in
                       DR. ROSEN:  So the hardware fixes are
           about 600,000 per unit.
                       MR. BUSLIK:  Per unit, that's right.
                       DR. ROSEN:  And the aggregate analysis
           costs for the industry are about $9 million.
                       MR. BUSLIK:  That's right.
                       DR. ROSEN:  And what are you expecting
           that $600,000 to buy in the plants?  Is there a
           specific fix that that is supposed to be the cost
           estimate of?
                       MR. MARShALL:  What we assume is that the
           fix would be is increasing your sump screen area, and
           the costs were based on estimates of one utility that
           already did that.  Then estimates we got from other
           vendors on how much they would charge the utility for
           doing that type of work.
                       MR. BUSLIK:  Yeah.  What was the plant
           that was -- Diablo Canyon?  
                       MR. MARShALL:  Yes.
                       MR. BUSLIK:  Yeah, Diablo Canyon had
           actually done such a fix.
                       What you get is for the 23 plants where
           there was a probability of one of the LOCA on every --
           for every size LOCA, the benefits were about $50
           million, and the costs, 23 million.  You can see that
           if I considered only those 23 plants in a sense, that
           has enough benefit to take care of the 32 plant case
           and, in fact, the 40 plant case using mean values.
                       So basically even if every case where it
           is possible or likely for the sump to clog, you set it
           equal to zero, you would still be cost beneficial for
           all of the three cases.
                       DR. WALLIS:  But if I'm NEI, I'm going to
           come back and say you've made conservative
           assumptions.  The benefit is really, you know, half of
           that and the cost really twice that.  So it's not
           worth doing.
                       MR. BUSLIK:  Well, right.  And it all
           hinges on the probability of the sump clogging and
           whether they can argue --
                       DR. WALLIS:  Except I wonder if it's
           really -- any prediction is within a factor of two. 
           So it's going to be --
                       MR. BUSLIK:  Aside from that probability
           of the sump clogging, and I think probably for some
           plants the probability of the sump clogging being one
           is fairly robust just because of where the little box
           is compared to the failure line, and that's my own
           opinion, but --
                       DR. WALLIS:  Probably nothing in nuclear
           is ever one, is it?
                       MR. BUSLIK:  No, it isn't one, but if it's
           .99 it doesn't matter.
                       DR. WALLIS:  Well, it seems to me a bit
           surprising that these things have operated all this
           time and engineers have looked at things and now
           you're coming up with something with a probability of
           one which hasn't been considered before.
                       MR. BUSLIK:  Well --
                       DR. POWERS:  It must have been considered
           or it wouldn't have been screened.
                       DR. WALLIS:  Well, if it's been considered
           before, then we must consider the probability to be
           very small.  Otherwise they would have done something
           about it.
                       DR. POWERS:  Well, I think the discovery
           was that that at Barseback they could produce a lot of
           debris from the process itself.
                       MR. BUSLIK:  That's right.
                       DR. POWERS:  I mean, I think it's the
           magnitude of the debris.
                       DR. WALLIS:  So it's a new piece of
           knowledge which changed this assessment from
           negligible to one.
                       MR. MARShALL:  Yes.  When it was
           considered before, there's a few changes. 
           Barseback -- well, yeah, there's a few things we knew
           from Barseback that we didn't know back in 19 --
           actually the agency addressed this explicitly back in
           1980, 1985, that time frame.
                       And what Barseback showed us was that our
           amount of transport, the type of debris we were
           considering, not the type, but the shape and size of
           it was in error.
                       And so when we went back from what we knew
           with Barseback and applied it and a few more things we
           learned along the way, such as filtering of
           particulate debris, we end up with drastically
           different --
                       DR. WALLIS:  Was Barseback some event that
           actually happened?
                       MR. MARShALL:  Yes.
                       DR. WALLIS:  When did it happen?
                       MR. MARShALL:  A Swedish BWR in 1992.
                       DR. WALLIS:  '92?
                       MR. MARShALL:  yes.
                       DR. WALLIS:  So it's going to take ten
           years before anything is done?
                       DR. POWERS:  It'll take more than that.
                       DR. WALLIS:  Well, there are going to be
           no hardware modifications.
                       DR. POWERS:  I understand you're talking
           about --
                       MR. MARShALL:  Well, actually the NRC did
           this in two steps.  We addressed our BWRs first, and
           all those had made modifications.  The agency has
           audited those modifications, have closed out,
           essentially went through -- if the BWRs was handled as
           a GSI, that would have been concluded probably
           beginning of this year.
                       So we took it in two steps.  We took the
           BWRs first, and then we went back and looked at the
           PWRs, and so we've been active sine Barseback, and
           we've addressed our BWR population, and we're in the
           process now of addressing our RPEs.
                       DR. WALLIS:  Thank you.
                       MR. BUSLIK:  I guess it was less clear
           that there was a problem with BWRs, and yes, there are
           some screens, but the assumption was that they would
           get to be clogged only 50 percent, and in some cases
           it's much more than that.
                       DR. POWERS:  Also in fairness, Graham, the
           first four years that I was on this committee, I got
           to listen to just about every meeting a request from
           Mr. Carroll on when was the staff going to do
           something about the Barseback incident.
                       DR. WALLIS:  So you're seeing in back in
           person again.
                       MR. BUSLIK:  Okay.  These are the
           uncertainties of the large and medium LOCA frequencies
           here.  They were on an earlier slide as well, except
           for the median values, which are given there.
                       The values for the reactor cool pump from
           sealed LOCA are not there.  They were given.  The
           upper bound is 5.3 minus three.  The lower bound is
           5.6 E minus four, and I think the error factor is
           three.  So that the difference between the mean and
           the median for reactor cool pump sealed LOCA would be
           about 25 percent.
                       Okay.  In some cases the probability of
           the sump clogging may be conservative.  I mean, they
           use the licensing criteria for loss of net positive
           suction, but in some cases it probably wouldn't make
           any difference at all, but I don't know on the average
           how it would affect it.
                       DR. WALLIS:  Excuse me.  There's one
           screen or something?  Are the screens in different
           places?  There are several intakes for pumps, aren't
           there?  There isn't just one.
                       MR. MARShALL:  It depends on the plant. 
           There's one plant that has three distinctly separate
           sump screen -- sumps with three separate sump screens. 
           More typical would be two sumps per plant, and then
           that will vary between two distinctly separate sump
           screens or two sumps that share a sump screen area.
                       I don't believe there's any -- no, there's
           no single sump plant.  So most of them have two, and
           it's whether they have two physically separate sump
           screens or --
                       DR. WALLIS:  Doesn't it help you -- isn't
           there a preference for debris from a particular
           accident to be in a particular place, or is it
                       MR. MARShALL:  Again, this would be one of
           the plant specific things.  Depending on the break, it
           could be preferential in one location versus another,
           and also depending on --
                       DR. WALLIS:  Does that come into your
           analysis, the LANL analysis, or do they just assume it
           goes everywhere?
                       MR. MARShALL:  We pretty much assume it
           goes everywhere.
                       MR. RAO:  My name is D.V. Rao.  I work at
           Los Alamos.  I'm the principal investigator.
                       Actually sump screens changed quite --
           sump screen designs are unique to each plant, I guess. 
           They vary quite much. 
                       In our analysis we did take into
           consideration sump screen location as relates to how
           close it would be to the pipe locations where the
           insulation is.  In some plants it's in the remote as
           packed away in some parts, and in some it could be
           feet away from, literally under a recirculation line.
                       So we tried to take that into
                       Also, another aspect that we took into
           consideration is whether the sump screen is above the
           floor or below the floor.  In some plants, the sump
           screen just looks like a storm drain of such where
           it's in a pit in which the sump screen is.  So the
           debris actually tends to go into the pit and,
           therefore, deposit, and in some plants, on the other
           hand, it is a vertical screen located on the floor. 
           Therefore, the debris had to go up and build.
                       We tried to take some of these factors
           into consideration and be very -- and we still have
           some other experimentation and others going on on
           those issues, but I do believe we tried to address
                       DR. WALLIS:  Thank you.
                       MR. MARShALL:  I didn't go into that kind
           of detail, but there's essentially no two sumps alike
           between different sites.
                       DR. WALLIS:  Which indicates that every
           plant is going to have to do its own analysis and
           someone is going to have to review that for technical
                       MR. MARShALL:  And that led us to our
           recommendation of plant specific.
                       DR. ROSEN:  I think that's absolutely
           true, Graham, and my comments earlier were about every
           plant has to do its own analysis, and every plant is
           different.  Then the need for guidance, it seems to
           me, is absolutely clear in the sense that you will get
           analyses that you won't -- that will look -- the
           answers will be very different, and the configurations
           may be the same.  And then what do you do with that?
                       MR. RAO:  Actually, may I say one other
           point?  It is true that every plant may have to do
           separate analysis, but depending on the fix, you know,
           a lot of our discussions that I've been seeing here
           are going on what the status is right now.  
                       It is, in fact, true that the sumps are
           designed differently, but that doesn't necessarily
           mean that the new sumps that are to be replacing the
           present ones, as in the screens and others, could not
           be generic or could not be more -- they share features
           common to different plants, in which case it is not
           necessary that you have to do analysis to that level
           for each plant.
                       We need to think about that, that is, that
           at the present time they're different from each site
           or each plant, doesn't necessarily mean in the future
           analysis that they have to do will have to be the same
                       I don't know if I made my point clear.
                       CHAIRMAN BONACA:  Just a note.  We have
           less than ten minutes left.  So we should --
                       MR. MARShALL:  If you don't mind, I would
           like to skip to just --
                       CHAIRMAN BONACA:  Okay.
                       MR. MARShALL:  Just finish a couple of
           slides there.
                       MR. BUSLIK:  All right.  I did an
           uncertainty analysis, and using Sapphire (phonetic),
           and to get some idea on the core damage frequency,
           this was only for large, dry plants.  And you get 6.7
           E minus five per year for the mean and 1.8 E minus
           four per year for the upper bound.
                       And if you go to -- now, this is for one
           plant, one large dry.  Presumably if you're
           considering the average core damage frequency for a
           set of, say, the 18 large dry -- this, by the way, was
           for a case where the sump clogged in all size LOCAs --
           presumably there the uncertainties would tend to
           cancel out.  The uncertainty in an average is less
           than the uncertainty in an individual sample.
                       And that's to be indicated here.  So it
           looks like it's very highly likely that it's cost
           effective.  The only problem is, of course, if the
           probability of some clogging instead of one is .2 or
           something like that.
                       CHAIRMAN BONACA:  I just want to ask you
           a question about it.  You know, when I look at the
           cost-benefit analysis here, the benefit is all coming
           from averted costs.  Assume that for the case where
           you have sump blockage and you give the probability of
           one.  That means that all the money that is going now
           in supporting high pressure injections, sit tanks
           (phonetic), testing, everything that a tech. spec.
           requires and everything else; so much is driven by the
           requirements of LOCA in the power plant.
                       All of these costs are totally lost, is
           being wasted today because you're saying that --
                       MR. BUSLIK:  It is all plant protection.
                       CHAIRMAN BONACA:  Yeah.  So wouldn't the
           costs also have to be considered or it's just simply
           simplification you don't consider that?
                       I mean, it seems to me that that's --
                       MR. BUSLIK:  I don't understand what
           you're saying.
                       CHAIRMAN BONACA:  What I am saying is that
           there is a lot of cost associated with running all of
           the other ECCS systems in the expectations that they
           will be successful.  If you are telling me that when
           you go to recirculation, you will not have success,
           then why bother with everything else you have for
                       And I'm saying that all that is being
           invested there, which is --
                       MR. BUSLIK:  Well, in a sense, this is
           included in the -- in the -- well, I'm not sure how
           that's included.  It's the plant which makes power,
           and if you lose the plant, you lose the replacement
           power.  I mean you need to replace the power.
                       CHAIRMAN BONACA:  Sure, I understand.
                       MR. BUSLIK:  And there's decontamination. 
           I'm not quite sure how you --
                       DR. WALLIS:  Well, that cost has already
           been --
                       CHAIRMAN BONACA:  I'm only saying --
                       DR. WALLIS:  -- is gone.   You've spent it
           already.  If you had to build the LOCA system today
           and you had to figure that in, then you might well
           figure out it wasn't worth doing it.
                       CHAIRMAN BONACA:  Well, that's --
                       MR. BUSLIK:  Well, at least for -- yes,
           you might figure that for large break LOCAs you don't
           need as elaborate a system or something like that.
                       DR. ROSEN:  You know, Mario, I'm a little
           troubled by the emphasis both in the analysis and in
           the committee's time on the cost-benefit analysis.  If
           a plant has a high likelihood of sump clogging, it
           would seem to me to be irrelevant whether or not, you
           know, there's a two to one cost-benefit ratio or three
           to one cost-benefit ratio.
                       They should simply verify that they do and
           take appropriate measures to fix it.
                       CHAIRMAN BONACA:  I agree with you, and I
           think actually, you know, I recognize we have had
           previous presentation here that was quite informative
           on the generic analysis done.  So but you're right. 
           I mean the focus today has been on cost-benefit, and
           I agree with you that if there is a problem, the issue
           of compliance is significant in that case.
                       MR. BUSLIK:  Yes.  I think as long as you
           know there's a significant safety benefit, you don't
           really -- they've figured that that's sufficient.
                       DR. ROSEN:  Well, I take it even one step
           further than you do, Mario, and you brought to the
           issue of compliance, and I bring it to the issue of
           responsibility for the nuclear --
                       CHAIRMAN BONACA:  Of course.
                       DR. ROSEN:  -- safety of the public and
           the plant workers and the investment.  Responsible
           management faced with the finding that their plant has
           a high likelihood of sump blockage, I think would take
           prompt action to remedy the situation.
                       CHAIRMAN BONACA:  Sure.  That's why I
           spoke before of urgency.  I mean, there is some
           urgency here, and --
                       MR. MARShALL:  One reason we presented the
           risk and the cost-benefit considerations is even
           though this would have been very important for safety
           enhancement, even if this was treated as a safety
           enhancement, it still bolsters the case that this is
           something that merits attention. 
                       Even based, if this was a safety
           enhancement, we would still have a case of moving
           forward with it, and again, as Art pointed out, we're
           required to consider or at least prepare the cost
           estimate for the decision makers to look at also.
                       So we're presenting all of the information
           we're going to be presenting to NRR as they take
           action on our recommendation.
                       DR. ROSEN:  Don't take my comments that
           this work was not required, but I think we look at it
           and then we get past it.
                       MR. MARShALL:  Okay.
                       DR. WALLIS:  Well, I like your sentiment. 
           It seems to me that responsible plant management ought
           to figure out what to do no matter what the NRC does. 
           Now that there's a problem that seems to be there,
           they ought to respond with the appropriate action no
           matter the NRC may be doing in the meantime.
                       And it may be that their response will be
           to show that it's not a problem, but no matter what it
           is, they can't do nothing.
                       CHAIRMAN BONACA:  And even -- I mean, I
           think the lack of specific guidance should not be an
           obstacle either.  They know what the configuration of
           the plant is.  They know what the installation is, and
           they have AEs that have done the original analysis. 
           They can be repeated with certain considerations.
                       And so I think that I agree with you.
                       MR. ELLIOTT:  Can I mention something from
           past experience?
                       My name is Rob Elliott, and I had the lead
           for the Bulletin 96-03, which was issued to implement
           the modifications to resolve the issue for BWRs.
                       At the time we issued the bulletin, there
           wasn't detailed guidance out for the BWRs either.  The
           BWR owners group took the lead, prepared that
           guidance.  We reviewed and approved it after the
           bulletin had been issued.
                       And licensees managed to implement all of
           their hardware modifications within two and a half
           years of the bulletin being issued.
                       So, I mean, if we get everybody working on
           the issue, we can be working on the detailed guidance,
           you know, almost immediately if there's agreement that
           we need to address the issue.  That's what we need to
           get to.
                       MR. MARShALL:  The important thing I think
           Rob mentioned was the detail guidance was actually
           prepared by the BWR's owners group.  It wasn't
           prepared by the NRC.  We prepared, again, like a very
           performance type guidance, but some people didn't feel
           that was detailed enough to work from, and so they
           took it upon themselves to provide their members
           detailed guidance to follow, and it provided options
           on A, B, C, D, on how to address debris generation.
                       MR. ELLIOTT:  And transport.
                       MR. MARShALL:  And they submitted that to
           our office for NRC review, got an SER on it.  So the
           individual utilities had confidence if they followed
           this and submitted it to the NRC, it would be
                       Just in closing because I think I ran out
           of time a minute ago --
                       CHAIRMAN BONACA:  That's okay.
                       MR. MARShALL:  -- I just want to reiterate
           our proposed recommendation:  again, plant specific
           analysis, and if a problem or vulnerability is
           determined, implement an appropriate corrective
                       And that's what we'll be sending to NRR
           during this month.
                       DR. ROSEN:  And for the committee's point
           of view, what I understand from this is that you do
           want an ACRS letter --
                       MR. MAYFIELD:  That is correct.
                       DR. ROSEN:  -- on the basis of what we've
           heard today.
                       MR. MAYFIELD:  That is correct, sir.
                       CHAIRMAN BONACA:  What's the sense of the
           membership?  I think we should have one.
                       DR. WALLIS:  Well, I'm a little concerned
           because we only have one side of this.  We have this
           one report which does have assumptions in it.  So we
           don't have any kind of other view that says -- it
           seems to have a vague statement that these assumptions
           are conservative.  We don't have a basis for knowing
           what's really realistic.  We just have to either
           believe that LANL report or we have nothing to go on.
                       CHAIRMAN BONACA:  Well, we received the
           presentation here and read a report.  It was quite
           detailed and had a generic treatment of the issue. 
           There were representations of certain types of sumps,
           one that would flush and then stepped up and different
           heights of those, and they were pretty detailed
           insofar as the generic representation of sumps.
                       I was left at the time with the sense that
           all that could be done generically was done, and we
           had to move into plant specific already.  That's why
           today I was surprised at the beginning that we were
           not facing that kind of recommendation immediately.
                       Then I saw it coming through, but it seems
           to me that we know enough to justify this
           recommendation.  Now, you had a different sense from
           it, Graham?
                       DR. WALLIS:  No, I just am saying I'm
           anticipating that there will be another view of the
           problem when eventually industry gets around to it. 
           It may look rather different.
                       CHAIRMAN BONACA:  And on a plant specific
           you might find that there are no problems or there are
           problems, and that will be --
                       DR. WALLIS:  And then it will come to us
           again presumably.  We may have to arbitrate between --
                       CHAIRMAN BONACA:  I think we'll have to go
           away from genericity and go to specificity for the
                       DR. ROSEN:  Well, I think we clearly have
           to make a choice.  I think anything we write now would
           have to be an interim letter.  It will not be our
           final word on it.
                       So we have to choose whether we want to
           say something on the interim, on the basis of the
           interim work we've heard about and seen so far or hold
                       DR. KRESS:  There's not much chance this
           committee will get a chance to look at all of the
           individual plant specific analyses that come in.  We
           need probably to make this our final letter, probably.
                       CHAIRMAN BONACA:  Yeah, I think so, too. 
           I mean, do we believe that this is an issue that would
           deserve, in fact, this recommendation?
                       DR. KRESS:  That's the issue, I think.
                       CHAIRMAN BONACA:  That's the issue, and
           you know, I personally believe that.  So I'm
           supporting of a  letter that will recommend that.
                       But I accept that the studies that we've
           done to date may have limitations and you know.
                       DR. KRESS:  Yeah, I think I would support
           that conclusion also.  I think the point of debate for
           our letter might revolve around the need for guidance
           and what that might take.
                       DR. ROSEN:  Certainly that will be a point
           of debate and how clear we come out on that point will
           be important.  But I think also, as Graham suggests,
           we haven't heard the industry reaction yet, and we may
           get some important input that could cause us to revise
           what we might say this week.
                       DR. KRESS:  If we get such input.  We're
           quite often faced with that situation though, and we
           go ahead and make our judgments based on what we know,
           and that's more likely to be the case here, I think. 
           We've got the final work probably before we write a
                       So I suspect we ought to resolve ourselves
           to making our judgment based on what we've already
                       MR. MAYFIELD:  If I could, this is Mike
                       As part of the generic communication
           process, there are opportunities for the committee to
           be briefed on and comment on generic communications
           that might issue from this.
                       DR. KRESS:  Yes.
                       MR. MAYFIELD:  So as the process proceeds,
           there will be another look at this potentially.
                       CHAIRMAN BONACA:  Any other comments from
           members or points of view?
                       (No response.)
                       CHAIRMAN BONACA:  Okay.  If not, I think
           we are done.  So we will recess the meeting for 15
           minutes and take a break until 10:20.
                                   (Whereupon, the foregoing matter went off
                       the record at 10:03 a.m. and went back on
                       the record at 10:21 a.m.)
                       CHAIRMAN BONACA:  Okay.  Let's resume the
           meeting now with the next item on the agenda.  That's
           the EPRI report of resolution of generic letter 96-06,
           waterhammer issue.  I believe Dr. Kress is the
           responsible individual.
                       Dr. Kress.
                       DR. KRESS:  Thank you, Mr. Chairman.
                       We had a Thermal Hydraulic Phenomena
           Subcommittee meeting on this issue August 22nd and
           23rd of this year.  Not many members were there.  So
           we have quite a bit of time on today's agenda to try
           to cover the issue.
                       To refresh your memory, there is a report
           on the subcommittee meeting, handout 311, that you 
           may have already read, but to refresh your memory
           anyway, this is a compliance issue for a design basis
           event.  A large break LOCA combined with the loss of
           off-site power or a main steam line break combined
           with the loss of off-site power sets up a condition in
           which you're likely to get a waterhammer event in the
           fan cooler units of containments.
                       And such an event could give you the loss
           of the function for the cooling and might even set up
           a bypass path from the containment.
                       So the generic letter in 96-06 requested
           that plants evaluate their vulnerability to this
           issue, and the work that was done by EPRI and industry
           in a collaborative effort was to provide guidance to
           licensees to do an individual plant evaluation or a
           specific plant evaluation of their vulnerability to
           this issue.
                       And the work they did was to develop a
           methodology for making the determination, and this
           methodology has in it a component of determining the
           amount of air and steam that makes a pocket in this
           event, and it's very important to know how much, what
           size this pocket is, and what its constituents are
           because it's a major factor in ameliorating the
           intensity of the waterhammer.
                       So we previously had a subcommittee
           meeting on this in which we looked at their
           methodology, and we had basically three issues with
                       One of them was the determination of our
           release fraction that made this void region as the
           event occurred.  We felt the experiments that the
           release fraction was based on was apparatus dependent
           and might be difficult to scale to the FCUs that are
           actually in the plant.
                       The other one is --
                       DR. POWERS:  Can I ask -- I sent you an E-
           mail asking some specific questions about the details
           of the experiment on that air release fraction.  Did
           we ever get any clarification on that?
                       DR. KRESS:  I was hoping we could ask that
           question at this meeting and get it clarified.  I've
           not --
                       DR. POWERS:  And there's a lot of problems
           of nucleation and whatnot in trying to get gases out
           of water in dynamic events.
                       DR. KRESS:  Yeah.
                       DR. POWERS:  There just didn't seem to be
           enough discussion on that to me.
                       DR. KRESS:  Yeah.  I definitely think when
           we get to the discussion of the termination of the
           release fraction that you need to bring that up again,
                       The other problem that we had previously
           was to determine the amount of steam that gets
           condensed and its effect on the amelioration.  It was
           experiments to determine an hA term for condensation
           where condensation was hA delta T, and so we thought
           that might also lack enough technical basis to be
           scalable, and in general, scalable for the test data
           to the full size was our problem.
                       So at the subcommittee meeting, the EPRI
           group attempted to address these issues, and I think
           they will also address them further in this meeting.
                       So with that as a preliminary, I guess
           I'll turn it over to Jim Tatum of NRR.
                       MR. HUBBARD:  This is George Hubbard,
           Acting Branch Chief for Plant Systems Branch.
                       Before Jim gets up or Jim can go ahead and
           start going forward, just Dr. Kress mentioned this
           methodology.  I wanted to bring in focus a couple of
           things is this is not for the entire industry, as Jim
           will point out in his slide.  This is for about 24
                       I think most of the other plants have
           addressed this issue, and they have satisfactorily
           accepted their resolution of the issue, but for these
           plants that EPRI is focusing on is they decided to go
           into a group to develop this methodology.
                       The other thing that I'd like to point out
           is that this is a low pressure system.  It's probably
           up to about 100 psi so that we're not dealing with the
           high pressure waterhammers that we generally think of
           with the, you know, 800,000 or, you know, high
                       So I wanted to bring those two points out,
           and then I'll turn it over to Jim, and he'll bring us
           up to speed on the issues, a brief introduction, and
           then EPRI.
                       Thank you.
                       MR. TATUM:  Good morning.  My name is Jim
           Tatum.  I'm from the Plant Systems Branch.
                       What I'd like to do, I think, just to make
           sure everyone is on the same page here on this issue
           is to provide a brief introduction as far as what the
           issue is, and then defer to EPRI.  I think they have
           additional explanation that they would like to give
           us, and upon completion of that, go ahead and discuss
           the staff perspective on this thing.
                       Let's see.  Now, in the way of
           introductions, Generic Letter 96-06 was issued just
           about five years ago.
                       DR. WALLIS:  Excuse me.  Do we have copies
           of your presentation?
                       MR. BOEHNERT:  You should have it in front
           of you there.
                       MR. TATUM:  Hopefully.
                       MR. BOEHNERT:  It's a single page.  If you
           don't, I have copies for you here.
                       MR. TATUM:  Okay.  About five years ago we
           issued the generic letter in response to some work
           that was done at Diablo Canyon and Westinghouse in
           looking at the fan cooler system and an issue that was
                       The specific scenario that we're talking
           about has to do with a LOCA, large enough LOCA to
           provide significant heat input into containment and
           transfer that heat to the cooling water system.
                       Typical fan cooler units, this is a pretty
           good schematic I borrowed from the EPRI document.  I
           think it came from Volume 2, but typically what
           happens is you have a loss of power.  You lose the
           service water pumps or the cooling water pumps,
           whatever the case may be, that is providing flow
           through the fan cooler system, and at the same time,
           the fans that are blowing air through the fan coolers
           are winding down.
                       There is a timing difference, however. 
           The pumps will coast down much more rapidly than the
           fans will coast down, and so what you have is a
           situation in the containment where you have the heat
           from the LOCA that's released rather quickly, and you
           have the fans continuing to wind down, transferring
           that heat into the fan coolers through the fan
           coolers, which are very efficient heat exchangers. 
           They're designed to transfer heat, typically have
           copper tubes that have fins on them, and so you get a
           rather rapid, immediate heat transfer into the fan
           coolers themselves.
                       As you get the heat transfer in there, the
           concern was whether or not you would have a
           significant amount of steam formation, and if that
           steam formation could lead to some significant
           condensation induced waterhammer event, thinking back
           to the days when we were looking at the waterhammer
           events associated with steam systems, steam
           generators, feed rings, that sort of thing.
                       And not knowing a whole lot about the
           response of low pressure systems and whatnot, we
           thought for a level of comfort, make sure that these
           systems wouldn't be compromised during the event, that
           licensees really should take a look and see if their
           systems were robust enough to be able to handle the
                       DR. WALLIS:  Jim, this is a very idealized
           picture, and in reality, as we've said before, these
           fan coolers are connected with all sorts of piping
           that goes up and down.  It goes into big headers, and
           each plant has very specific piping.
                       MR. TATUM:  That's true.
                       DR. WALLIS:  Very specific connections,
           very specific ups and down, and this sort of gets lost
           in all this work and the connection between this
           reality and some idealized view is being lost to some
           extent throughout this work.
                       MR. TATUM:  That's true, and I think EPRI
           can talk a little bit about what they've done in the
           way of the participating utilities.  I mean, they have
           surveyed and tried to get a pretty good feel for what
           the specific piping arrangements are for the plants
           that are involves with this particular study that's
           been done.
                       But you're right.  I mean, the plant
           designs are very plant specific.  There's not a
           standard design.  You can have the fan coolers at a
           high point.  You can have them at a low point.  
                       Typically I think it's more common that
           you see them at a high point in the system.  You do
           have headers that feed into the fan coolers, and off
           of those headers then you have small tubes that form
           the majority of the fan cooler itself where the heat
           is transferred.
                       But you're right.  There are different
           turns, maybe different systems that are cooled by the
           cooling water system in containment.  It may not just
           be the fan cooler.  So there are some complications
           that have to be considered in all of this.
                       MR. SIEBER:  Let me ask a question.  When
           you have a LOCA, the containment temperature and
           pressure changes pretty rapidly, but not
           instantaneously.  Did you take into account the
           profile of containment temperature with time and
           compare it to the time that that the service water is
           not flowing?
                       MR. TATUM:  Yes.  Typically what the
           plants have done is they have looked at their
           containment profiles for the design basis LOCA, and
           based on those profiles, they've maximized the heat
           input typically to get the maximum steam volume that
           you might be able to get from the heat that's in
                       That's a little bit idealized because
           obviously there's difficulties in determining where in
           containment the heat is being disbursed.  You know,
           there's going to be some complications with just
           getting down to how rapidly it is going to be
           transferred through the fan cooler.
                       So the process that utilities have
           typically used is to look at worst case type
           conditions, take a look at the profile, assume that
           heat is there available to the fan coolers, transfer
           the heat into the cooling water systems just kind of
           as an approach to try to get past, well, yeah, you
           have the LOCA.  How is that heat being conveyed
           through the containment?  How long does it take to get
           to the fan coolers?
                       I mean, there are questions that can be
           asked that we really didn't go -- it wasn't the
           purpose of this generic letter really.
                       Our feeling when we issued the generic
           letter was that the bounding case, the limiting case
           would be maximum steam formation with the potential
           for a condensate induced waterhammer event.  That's
           really what our concern was going into the generic
           letter, this aspect of it.
                       MR. SIEBER:  Well, if the licensee would
           respond to the generic letter by doing an analysis
           that's time dependent, I presume you would accept that
           kind of analysis.
                       MR. TATUM:  If it were justified.  I mean,
           from the staff's perspective though, it would be
           difficult because we look at design basis scenarios,
           and so as design basis we look at the temperature
           profile, and we go by, well, at this point in time you
           have this temperature in containment, and we assume
           that it's disbursed uniformly throughout containment.
                       So you know, we don't get, and I think it
           would be very difficult to try to model exactly where
           that heat would be at any point in time.  So we have
           to make some simplifications.
                       I put up another diagram here to --
                       MR. HUBBARD:  Jim, let me add one comment
           on that.  This is George Hubbard.
                       I think part of the reason the utilities
           went together is they all realized that for their
           situation, that there would be this input, and they
           could have the problem, and therefore, they went to
           form this group to address it.
                       So from their own evaluation they felt
           they had the problem, and they, you know, wanted to,
           you know, approach it with this methodology.
                       MR. TATUM:  I've put this slide up to
           illustrate a little bit more of what Dr. Wallis was
           speaking to.  The header configuration that you could
           expect to see for a fan cooler unit, you have the
           pipes, the main pipes that bring the water into the
           fan coolers, but then those pipes transition into
           individual unit boxes that make up the cooler, and the
           cooler itself is composed of copper tubing typically
           with fins and very long lengths and winding, making
           several paths through each box.
                       That's kind of the arrangement that we
           were looking at.
                       DR. WALLIS:  Even this figure is a bit
           strange because your left-hand one shows a supply
           coming in presumably on the left, going out on the
           right, both at the bottom.  But on the right-hand
           picture the return is  at the top.
                       Now, where is the return?  Is it at the
           top or the bottom in the fan cooler?
                       MR. TATUM:  Well, typically I believe this
           is -- if you look at the diagram, I think the larger
           diagram over on the side there, you have a header that
           comes in, and this is very plant specific.  I mean,
           this isn't meant to be generally applicable to all
           plants, but for this particular case, I mean, it's
           showing the return coming in at the bottom and going
           out at the top.
                       I wouldn't say that that's the case --
                       DR. WALLIS:  They both go out at the
           bottom on the left, right?
                       MR. TATUM:  Well, if you look on the left
           side --
                       DR. WALLIS:  They both go out at the
                       MR. TATUM:  -- it's probably hard to tell.
                       DR. WALLIS:  They come in and go out at
           the bottom, don't they, on the left?
                       MR. TATUM:  Well, I mean it's hard to tell
           from the isometric, I think, really, but it should be
           showing it coming in similar to what you have here. 
           I mean, coming in at the bottom, going out at the top.
                       DR. WALLIS:  And in the EPRI experiment,
           they have a pipe, and then it all comes out and
           bubbles up into something.
                       MR. TATUM:  Yeah, well, they show -- and
           I'll defer comments on that.  I think EPRI --
                       DR. WALLIS:  Maybe they will tell us how
           their experiment is related to this sort of picture.
                       MR. TATUM:  Right.  I think they'll be
           prepared to discuss the experiment and how it relates
           to the actual header configuration and that sort of
                       But I just wanted to make sure everyone is
           familiar at least generally with the system that we're
           talking about.
                       DR. WALLIS:  The headers, the big headers
           that go around containment are at about the same
           level.  So that return if it's up has to come down
           again to go into the header.
                       MR. TATUM:  That's correct.  That's
           correct.  If it's in a high point, typically the
           piping will come back down to where the main header
                       DR. WALLIS:  It comes down.  It doesn't go
                       MR. TATUM:  Right.  Now, in those cases,
           and I think there may be a couple where you have the
           fan coolers at the low point in which case the piping
           would go up to go back to the header.
                       DR. WALLIS:  All right.
                       MR. TATUM:  So it can be very plant
           specific that way.
                       DR. FORD:  Could I just ask another
                       MR. TATUM:  Sure.
                       DR. FORD:  I'm assuming SS is stainless
           steel.  Stainless steel tubes with copper fins; does
           it change from plant to plant?  Do you have copper all
           the time -- sorry -- stainless steel tubes all the
           time, or do you have carbon steel headers?
                       MR. TATUM:  Well, no, the piping -- the
           headers themselves would typically be some sort of
           carbon steel.
                       DR. FORD:  Okay.
                       MR. TATUM:  Typically.  Service water
           system, that kind of an arrangement.  The tubing
           itself typically, they would be what you'd find in a
           heat exchanger, copper tubing, possibly fin.  
                       This one, this particular example from the
           EPRI manual is for a particular plant, and in this
           case, they're talking about stainless steel, but it
           varies from plant to plant.
                       DR. FORD:  Okay.  So you could have just
           plain carbon steel tubes.
                       MR. TATUM:  Well, not the tubes so much. 
           The header that goes into the fan cooler.
                       The fan coolers themselves, I think, are
           typically originally commercial type units for
           transferring heat.  There wasn't anything special
           about the design of the fan cooler itself.
                       DR. FORD:  Okay.
                       DR. WALLIS:  Now, while this release is
           occurring, is there flow through the system or is it
           stagnant pretty well?
                       MR. TATUM:  Well, typically what we're
           looking at for the Generic Letter 96-06 scenario is
           that you have a stagnant cooling water system.  The
           pumps stop, loss of power, and you have the air
           continuing the containment atmosphere continuing to
           blow through the heat exchanger as the fans wind down.
                       DR. WALLIS:  But in this part, in the
           water supply here --
                       MR. TATUM:  Right.
                       DR. WALLIS:  -- there's no flow through
           there during this event or the pumps are coasting
           down.  So there is a flow through here.
                       MR. TATUM:  Well, they coast down very
           rapidly.  So essentially it's no flow, yeah, no flow
           through on the water side.  And so you may have column
           separation, you know, if you have a system that's high
           in the containment and, you know, would expect boiling
           to occur rather rapidly, that sort of thing.
                       DR. KRESS:  Now, what's the general source
           of this water supply?
                       MR. TATUM:  Well, it varies.  I mean, the
           open loop systems, you can have the source from a
           reservoir.  It can be from a river, a lake.  You know,
           the pump service water system basically, it's that
           kind of a system.  It would take a suction from a body
           of water, whatever is available.
                       DR. KRESS:  So it very well could be
           fairly dirty water.  It's not --
                       MR. TATUM:  It could be fairly dirty
           water, and in fact, we've acknowledged that and
           recognized that previously by issuing Generic Letter
           89-13.  So there are -- you know, problems with dirty
           water systems have been addressed.  I don't expect
           that to be a complication for this issue per se as far
           as degrading the system, aging, and that sort of
                       DR. KRESS:  Yeah.  Well, I had in mind how
           that might affect the higher release fraction.
                       MR. TATUM:  The heat transfer and whatnot.
                       DR. KRESS:  Yeah, and the heat transfer.
                       MR. TATUM:  Right.  Yeah, the quality of
           water varies, and you can have silting and different
           things going on there with the water supply or marine
           growth, organisms, that sort of thing.  But those
           issues for the most part I think we've addressed with
           Generic Letter 89-13.
                       Getting back here to just basically
           introductory comments, let's see.  I wanted to just
           back up now with the EPRI initiative that was proposed
           in August of '98.  As George has already mentioned,
           there were a group of utilities that were interested
           in trying to come up with a less conservative
           methodology than what was suggested by Generic Letter
           96-06, that being NUREG CR-5220.  That's a very
           bounding approach that was offered in that NUREG. 
           Typically it goes straight from Joukowski, does not
           credit air or recognize air and cushioning, that sort
           of thing.
                       The industry felt like they could take
           advantage of some of the margins and conservatisms and
           maybe reduce the amount of modifications that would
           have to be done to address the issue, saving the
           industry money and whatnot and still providing
           confidence to the staff that they had adequately
           addressed the issue.
                       And, of course, we were very interested in
           proceeding with that effort.  It was really a
           cooperative effort with the NRC.  We observed much of
           the testing that was done.  
                       We've had discussions with them at many of
           the meetings.  We were involved with the development
           of the PIRT analysis that was done and whatnot.  So
           we've provided guidance and suggestions along the way,
           but the work that was done, the analysis and whatnot,
           that's strictly EPRI's, and we're going to defer to
           them to discuss that part of it.
                       DR. WALLIS:  Did you ask the kind of
           technical questions that we've been asking?
                       MR. TATUM:  Yes, we have been asking those
           kind of technical questions.  Unfortunately the staff
           has evolved.  You know, this has been kind of a long-
           term project, and originally we had Al Serkiz who was
           working with us, and of course, he was a key player
           from our side, making sure the right issues were being
           addressed at least from his perspective for
           waterhammer, and he was our expert at the time for
                       Now we have Walt Jensen in Reactor Systems
           Branch and Gary Hammer doing the review.  So we've
           transitioned in personnel, but we've tried to maintain
                       We've all looked at the same documents,
           and we have asked the technical questions.  And I
           would say that in the meetings with the subcommittee,
           obviously the questions that have been asked have been
           good and helped us focus also on some areas, some I
           think that we were also aware of even at the time you
           were asking some of the questions as well.
                       So we're trying to move on with this thing
           at this point, but there are about 24 plants involved
           with this initiative, and these are for the most part
           the plants that have not really addressed the
           waterhammer issue.
                       The other plants for the most part are
           those that do not credit the fan coolers, and they're
           able to take alternative measures.  For example, they
           can put in the procedures, restrictions on using the
           fan coolers so that they don't have to worry about the
           waterhammer event, and they've been able to address it
           that way.
                       There are a few, handful of plants that
           aren't involved with this initiative, a couple that
           have tried to apply RELAP.  We're still reviewing
           those.  We have not come to a conclusion on those
           other plants yet.
                       MR. SIEBER:  Just a question, I guess.  A
           lot of plants can't use the fan coolers after a LOCA
           because the containment atmosphere density is too high
           and it's too big a load on the fans.  So when you get
           a containment isolation, the fans usually trip and,
           except for a smaller number of PWRs, they don't
                       So the real issue is if you have the
           waterhammer and you rupture part of the piping, do you
           bypass containment? 
                       I think to answer that you have to know
           what kind of a rupture you have.  For example, if you
           just split a seam someplace, service water pressure is
           higher than containment pressure.  So leakage is in
           rather than out.
                       Has that been taken into account, any of
           these factors?
                       MR. TATUM:  Well, we have considered that. 
           There are many different kinds of scenarios. The
           containment bypass is one, and that can be very 
           complicated because depending on the plant design, you
           may have to have more than one rupture in the system
           to get a containment bypass.
                       Typically service water systems are easily
           isolated from outside the containment.  So there are
           different mitigating factors to consider here.
                       Also, the service water system, what you
           mentioned with the load on the fan coolers and
           whatnot, that's true.  It's kind of plant specific
           that way, but in fact, what many of the plants do is
           they will operate the fan coolers in the plants
           involved with this particular initiative, typically
           will shift to a low speed on the fans in order to be
           able to handle the load.
                       And so they credit those fan coolers in
           some fashion.  It may be just for long-term cooling of
           containment.  If it's a small containment, maybe it's
           in clipping the peak pressure a little bit.  It varies
           from plant to plant, and you have to get into the
           details of each specific plant in order to see to what
           extent they're crediting the fan cooler.
                       MR. SIEBER:  Well, the containment
           atmospheric pressure can triple during a large LOCA,
           and that really changes the load on the fans, and so
           typically you don't put fan coolers on at all until
           after the first hour to get the spray down and deep
           pressurization.  I think that makes a difference.
                       MR. TATUM:  Well, it does, and for some
           plants that the case, and for those plants, in
           particular, it wouldn't be an issue, and those would
           be among the group that we've already closed.
                       MR. SIEBER:  And I guess another comment
           is that a lot of things happen during the first minute
           or so of a large LOCA, and even though you probably
           have a radiation detector on the outlet of the service
           water, I think that's pretty far down on the list of
           things to look at, and so isolation is, you know,
           maybe it happens; maybe it doesn't.
                       MR. TATUM:  Well, it would be late on. 
           The question is, you know, if you're looking at the
           severity of the event, how long do you have?  And if
           you're talking about a split in the seam somewhere
           where it's not a major thing, you've got a lot of
           time, whereas if you're talking about a major rupture
           of the piping system and a direct path, maybe it's
           more significant.
                       So there are a lot of variables that go
           into this, and I think that's one of the points I
           think that needs to be appreciated here, is just the
           complexity and the number of variables we're talking
           about, but that's pretty much all I have in the way of
                       I'd like to turn it over to Vaughn
                       DR. WALLIS:  Does the staff have a
           position on this work?  Are you accepting it?
                       MR. TATUM:  Yes, we do have a position,
           and I'd like to defer discussion of that until we hear
           from EPRI because they're going to attempt to provide
           additional information, and I think for continuity of
           the discussions here it would be good to have what
           they intend to say here available to the other
           members, and then we can go on to the staff
           perspective on this.
                       MR. WAGONER:  I guess I get the honors
           now.  Is there a microphone?  Am I hot?
                       Okay.  Good morning.  I'm Vaughn Wagoner
           with Carolina Power & Light Company, and I chair the
           Utility Advisory Committee that is composed of the
           members of the utilities that have been supporting
           this project with EPRI, and let's see.  Well, I'm here
           this morning and joining with me are Tom Esselman and
           Greg Zisk from Altran Corporation and Tim Brown from
           Duke Energy, and Peter Griffith was going to be here
           with us this morning, but unfortunately could not make
           it at the 11th hour.  So we'll have to try our best to
           fill in if questions get to that level.
                       So I just want to give a brief
           introduction here.  Let's see, Tom.  What do I do?
                       MR. ESSELMAN:  Page down.
                       MR. WAGONER:  Page down.  Oh, that's why. 
           I paged up, and it wouldn't work.  Okay.
                       Okay.  Very briefly this morning, what we
           want to do with you is go through an overall
           description of what we've done in this thing just to
           be sure everybody is on the same page, and then get
           into some specifics that we've been talking with with
           the Thermal Hydraulic Subcommittee, particularly in
           the areas of air release and heat transfer and the
           scaling issues.  These seem to be continuing
           questions, and we want to try to get at those and
           address them for you this morning.
                       First, I just want to give you a little
           bit of background.  When we started out in this thing,
           as you've heard, there were utilities or plants
           generally fell into two or three groups:  those that
           just flat didn't have the problem because of whatever,
           over pressure in their systems or whatever.  They
           didn't have a problem and didn't have to address it.
                       Others that had some facet of the program,
           but could address it in terms of either operational
           changes or other changes to the plant.
                       And then a third grouping of plants that
           had -- that appear to have the issue, create the steam
           voids, et cetera, but whose piping systems were very
           close to being qualified in using classic systems with
           the theoretical loads that you could calculate.
                       So then the question became is there some
           mechanism or is there some activity because these are
           aerated systems for the most part and there's boiling
           going on; is there something going on there that we
           could take advantage of?
                       DR. WALLIS:  Well, let's ask you.  You're
           assuming these are aerated systems.  Do you monitor
           how much air is in the water in these plants or do you
           just assume it's there?
                       MR. WAGONER:  Well, there's fish that live
           in the pond and they don't die.  So there's got to be
           some oxygen in there.
                       DR. WALLIS:  But they aren't all like
           that.  Don't some of them have a storage tank and they
           recirculate and so on?
                       Do they all bring in water from the
                       MR. WAGONER:  The open systems that I'm
           familiar with --
                       DR. WALLIS:  Are all open?
                       MR. WAGONER:  -- as far as I know, all
           participating in this study are all --
                       DR. WALLIS:  Are all open systems?
                       MR. WAGONER:  They're either open or they
           are closed systems, but we treat a closed system
           differently with respect to the potential for gaseous
                       DR. WALLIS:  So are we talking only about
           open systems here or are we talking also about --
                       MR. WAGONER:  Yes, sir.  We're talking
           about both open systems and closed systems, but in the
           technical basis report and the user's manual, there
           are differences.
                       DR. WALLIS:  So in the closed system we
           don't have an idea of how much air is in there?
                       MR. WAGONER:  Well, we do have an idea.
                       DR. WALLIS:  But we don't have a
           measurement or something?
                       MR. WAGONER:  Well, you've got -- you know
           there's air in the water that's put in.  Then
           typically there's some kind of oxygen scavaging added
           to the -- because it's a closed loop to prevent rust
           and stuff like that.  So what you're left with then is
           the other.
                       DR. WALLIS:  So you're taking oxygen out.
                       MR. WAGONER:  Right.  So what you're left
           with are things like nitrogen and what other small
           constituents of things that aren't removed by oxygen
           scavaging chemicals.
                       DR. POWERS:  So when you say, "Okay.  I've
           got this water" -- do you say you have some idea how
           much dissolved gas there is?  How do you come up with
           that idea?
                       MR. WAGONER:  Typically you would -- we
           don't typically take measurements of it on a routine
           basis, but then again, it's large bodies of water,
           surface area exposed to air.  So you --
                       DR. POWERS:  Yeah, I know, but now I still
           need a number.
                       MR. WAGONER:  Okay.
                       DR. POWERS:  How do I get that number?
                       MR. WAGONER:  And that number is that we
           would look in a textbooks and see what the typical
           dissolved gas would be.
                       DR. POWERS:  Okay, and I look in those
           textbooks and they give me the number for pure
           distilled, 23 meg water.  Okay?  And that's a number.
                       Now, if I looked farther in the textbooks,
           they would tell me there are section now coefficients
           that will tell me how dissolved salts will reduce that
           number.  Do you take that into account?
                       MR. WAGONER:  Dissolved salts?
                       DR. POWERS:  Un-huh.
                       MR. WAGONER:  Do you mean things that
           might be dissolved in the water?
                       DR. POWERS:  Right.
                       MR. WAGONER:  Not necessarily.  I guess
           the question would be, you know, how much effect is
           it.  Does it take it all out or a little bit?
                       DR. POWERS:  Well, I guess I'm asking you
           what the effect is.
                       MR. WAGONER:  And I guess I can't answer
                       DR. POWERS:  Oh,
                       DR. WALLIS:  When these pumps pump the
           stuff around, there are regions of low pressure where
           maybe you get air bubbles coming out and so on.  So
           there are mechanisms that influence the air content of
           the water.  It's not as if you just take the figure
           6.7, solubility of air and oxygen at one atmosphere in
           distilled water and use that.  I mean, there are other
           things going on.
                       MR. WAGONER:  I'll acknowledge that.  I
           guess I would disagree that there are pockets of low
           pressure between the pump and discharge.
                       DR. WALLIS:  Well, it's just the thing
           that so surprises me is that you just sort of take
           this curve and it's assumed it applies without further
                       MR. WAGONER:  Let me ask.   Have there
           been any measurements that you guys are aware of that
           have actually been made in water or any other thing?
                       MR. ESSELMAN:  Vaughn, this is Tom
                       The specific amount of gas, whether it be
           nitrogen or air, that's in a plant dependent situation
           depends on the plant, depends on whether you have a
           bond or a cooling tower or a closed loop system with
           a tank, whether it's a nitrogen blanketed tank or not,
           and all of those things will enter into -- and what
           the temperature is of the lake.  That's clearly
           different in Minnesota than Texas; what the pressure
           is, whether you're taking it from the bottom of the
           lake or the top of the lake.
                       All of those details are not dealt with by
           us.  What we're providing is a general recommendation
           that says you need to determine how much dissolved
           gas, whether it be air or nitrogen or whatever, is in
           your plant at the beginning of the event.
                       And the kind of factors that we're talking
           about are plant specific, and many of the things that
           we're talking about are going to depend on the details
           of the tower or the pond, and that has to be
           determined, and it's clearly identified as needing to
           be determined by the utility that's using this
                       DR. KRESS:  Your experiments determine the
           fraction of the air that's in the water that gets
           released, but they started out using clean, saturated
                       MR. ESSELMAN:  We use --
                       DR. KRESS:  Water saturated with air.  Do
           you think that fraction that you determined
           experimentally might have some dependence on the
           initial concentration of air in the water or --
                       MR. ESSELMAN:  We looked at the way that
           air and nitrogen would come out of solution with an
           increase in temperature.  We saw that the behavior of
           the different gases that could be in there is similar,
           and that the representation or the using oxygen,
           because we had a normally aerated water system; we
           used tap water.  We measured the oxygen and used
           oxygen as an indicator of what was being released as
           a percentage.
                       I think given the -- we will discuss this
           in more detail, but given the way that we did the test
           and the range of data, we believe that it applies to
           a highly aerated or a moderately aerated or a highly
           nitrogenated or a moderately nitrogenated system.
                       So the steps is, number one, the plant
           needs to determine what they start with, and then they
           need to determine how much water is affected, and then
           they can calculate how much air would be released from
           that, how much gas, noncondensable gas would be
                       DR. WALLIS:  You use oxygen as the
           indicator.  I'm not clear that you ever measured air. 
           You used oxygen.
                       MR. ESSELMAN:  We didn't.  We used oxygen
           as an indicator.  That's correct.
                       DR. WALLIS:  And the assumption is that
           nitrogen behaves exactly the same way.
                       MR. ESSELMAN:  We don't presume that it
           behaves exactly the same way.  We know that it behaves
           differently.  We looked at how nitrogen and air and
           oxygen behave, and their behavior is similar enough
           that we were confident that using oxygen as an
           indicator was representative.
                       But we jump ahead.
                       MR. WAGONER:  So I guess the correct
           answer to your question was that it is a plant
           specific determination.
                       Thank you, Tom.
                       And that is in the user's manual.
                       DR. POWERS:  But, I mean, I guess what's
           distressing is you don't tell the user that he needs
           to worry a little bit about things other than handbook
           values.  Pure water solubility just isn't going to cut
           it for most of these.  Most of these external water
           sources are going to have a certain amount of
           dissolved material in them.  It's going to affect the
           activity of oxygen strongly and nitrogen more
                       MR. WAGONER:  But is it not true that
           within the tech. manual or within the user's manual it
           does say that on a plant specific basis you need to
           look at the --
                       DR. KRESS:  If we assume the extraction of
           the air during the process of the event, the boiling
           event and so forth, was a stripping mechanism, which
           is generally described in mass transfer texts as a
           product of some sort of mass transfer coefficient and
           a surface area and a driving force, the driving force
           being the concentration in the difference between the
           liquid and what's in the --
                       DR. POWERS:  Activity.
                       DR. KRESS:  -- activity.  Okay.  But --
                       DR. POWERS:  Activities count in this.
                       DR. KRESS:  Yeah, okay.  But my point is
           it seems to me like that activity is concentration
           dependent.  It depends on the concentration in there,
           and you're saying --
                       DR. POWERS:  But, I mean, the subtlety of
           water is it's not dependent on the concentration of
           oxygen.  It's dependent on the concentration of
           everything else.
                       DR. KRESS:  Yeah, yeah.
                       DR. POWERS:  I mean that's why water is
           different than usual solutions.
                       MR. WAGONER:  So I guess the question then
           would be whether or not in your minds or our minds
           that if, given the conditions that exist within the
           fan coolers during this transient event, is there,
           other than the total amount, is there anything that's
           going to preferentially act on or not act on the
           ability of oxygen, nitrogen, and whatever else is in
           there to get out of the water?
                       And when you're taking it down to darn
           near zero pounds absolute and then boiling the heck
           out of it, I'm not sure that was -- I guess the
           question is:  is there any significant differences in
           what's going to happen with the ability to --
                       DR. WALLIS:  Well, it's not zero pound --
           it's about half an atmosphere, isn't it?
                       MR. WAGONER:  Well, it eventually gets up
           to half an atmosphere, but it --
                       DR. WALLIS:  Well, it goes through
           something lower before that?
                       MR. WAGONER:  Well, as the pumps fall away
           and as the steaming starts, you have a pressure
           decrease as nature is taking the water column down to
           its normal 32 or what --
                       DR. WALLIS:  So it goes down to about
                       MR. WAGONER:  So it's headed down, and
           then the steaming process starts, and then the
           pressurization starts chasing the depressurization.
                       DR. WALLIS:  And so all of your
           experiments are done at half an atmosphere.  Isn't
           that the case?
                       MR. WAGONER:  I believe that's correct.
                       DR. WALLIS:  Which was chosen for some
                       MR. WAGONER:  Somewhere between the
           starting point of zero and roughly atmospheric that
           some of these systems go to.  So we tried to pick a
           point that didn't give too much credit to just
                       DR. WALLIS:  But this is plant specific,
           isn't it?  I mean, this pressure history is plant
                       MR. WAGONER:  Generally, yes.
                       DR. WALLIS:  And so you're claiming that
           your experiments all are operating at one half an
           atmosphere are somewhat typical of all plants no
           matter what the history of the pressure in that plant?
                       MR. WAGONER:  Because of the fact that the
           pressures are not -- we're not talking about hundreds
           of pounds of difference.  We're talking about, you
           know, three to five pounds difference absolute, across
           the range of plants.  Because generally there's
           various elevation differences, and you only go to zero
           on the depressurization side, and then the
           repressurization side is generally around an
           atmosphere or less.
                       DR. WALLIS:  Well, you're saying this, and
           I'm not sure this is in the report.  I mean, you read
           the report.  Someone did experiments at half an
           atmosphere, and it's never really -- maybe it is.  I
           didn't find it -- sort of explained why this is
           representative of what you're talking about here,
           which is a history of pressure which can be quite
           variable from plant to plant.
                       MR. WAGONER:  I thought that we had
           discussed that in the original reports.  Perhaps
           I'm --
                       MR. ESSELMAN:  I would comment briefly
           that we have looked at both the effect of
           depressurizing a system and the effect of boiling a
           system, and there are papers and references that deal
           with how water behaves when it's depressurized and
           agitated.  The amount of gas that's given off within
           this time period, which is about 30 seconds, is very
           small in comparison to what we measured from the
           results of boiling.
                       This material, including that pressure, we
           will go through when we deal with the boiling test,
           which is on the agenda.  I guess we might defer the
           details until we get --
                       DR. WALLIS:  You're saying something which
           sounds credible.  If you had done the experiment at,
           say, one atmosphere and a half an atmosphere and got
           the same amount of air because the boiling process
           dominates, that would be convincing.  It would be nice
           to see it.  I mean, you're sort of assuming there.
                       MR. ESSELMAN:  We ran at a half an
           atmosphere because we wanted to remove the air in the
           system prior to the start of the test, and we did that
           by running steam through it and then closing and
           allowing that to condense.  So we started with an air
           free system that was at a half an atmosphere.
                       We also researched the release that we
           would have expected by pressure beforehand and
           concluded that whether we ran it half an atmosphere or
           one atmosphere would be immaterial, and we ran the
           test on that basis and --
                       DR. WALLIS:  This is on a theoretical
                       MR. ESSELMAN:  Well, based upon testing
           that had been performed by others, yes, not by the
           testing that we had performed.  But yet we looked at
           that; we referenced that work in the technical basis
                       MR. WAGONER:  Okay.  Let me move on
           through what we're trying to accomplish in the
           program, and four things that we were trying to do.
                       One was understand the behavior of the
           system, and you heard the overviews of what went on. 
           And we wanted to understand in general how that
           worked, what happens in terms of coast-down.  Did flow
           ever really quit?  What happens in terms of fan coast-
           down?  Did fans die rapidly or did they die away
           slowly such that it really was an issue?
                       And then where did water go?  Is steam
           created?  Where does it go?  How far does the bubble
           go, and those kinds of things, and how we go about
           tracking those?
                       We wanted to determine the safety
           significance of the issue.  Frankly, as you heard,
           there was a lot of data around on high pressure
           waterhammers.  There wasn't much around on low
           pressure waterhammers and what happens here.
                       And so we wanted to try to understand
           that, and basically there's three things we had to
           deal with.  One is retaining cooling capability of the
           fan coolers at whatever post accident requirements
           that are there; maintaining containment integrity,
           such that it didn't set up a bypass for containment;
           and then maintaining or not flooding the containment,
           not creating a flooding path for containment.
                       So that was the three things that we try
           to deal with, and then we wanted to provide a
           methodology to assure that we do maintain these
           pressure boundaries and also, again, as you heard
           mentioned, we want to minimize modifications that we
           didn't have to make.  We were willing to do anything
           that we needed to do, but if we didn't have to, then
           we wanted to try to pursue that.
                       And frankly, as we worked through that,
           and that was the reason that a bunch of us utilities
           got together, even though that we determined -- had
           the potential for the problem; when we looked at it,
           even using some Joukowski type loading, we were close. 
           It got down to trying to qualify the steel in the pipe
           supports, and we were darn close.  So we were just
           looking for a little bit.
                       And you've heard the numbers, 20, 30
           percent in load interaction with the piping support
           system, and if that was possible, then we wouldn't
           need to make modifications to the plant, and frankly,
           the intuitive feeling is, and my experience with
           waterhammers up to about 300 pounds or so, the stiffer
           you make the system, the more trouble you get into.
                       I spent two years chasing one in the wrong
           direction, and we went back and chased it in the other
           direction and put rod hangers on the pipe, and it's
           been banging for 15 years, and we don't have a
           problem.  The more steel I put in it, the more
           concrete we tore out of the wall.
                       Okay.  But moving along -- I'm sorry?  Oh,
           I'm sorry.  I thought I heard someone.
                       Anyway, we put -- in order from an
           industry perspective, we got Altran Corporation
           together and assembled an expert panel to provide us
           an independent perspective of what it was we're doing. 
           We wanted to get the very best in the industry that we
           could, but unfortunately you're all on the ACRS.  So
           we had to go with --
                       DR. POWERS:  Flattery, sir, will get you
           anywhere you want to go.
                       MR. WAGONER:  So we did assemble these
           folks with a lot of experience, and I can tell you,
           and I think most of you have had interaction with
           them, they are independent.  It didn't matter who was
           paying the bill.  We had some quite informative and
           lively discussions on what it was we were trying to do
           and acknowledged right off that we don't know
           everything about the science and the details of the
           interaction, but what we think we have done is provide
           a reasonable approach that helps us to adjudicate the
           loading, and that's what we're really working at.
                       And we had this utilities steering
           committee.  I chaired it, and we were active in it,
           and our focus was to be sure that we were looking at
           that stuff that would help us where the rubber meets
           the road, if you will, and look at safety significance
           and then look at applicability of the results to the
           power plant.
                       Let me drop down two slides in your
           handout, and I'll come back.
                       DR. WALLIS:  Well, the one that you didn't
           show us.
                       MR. WAGONER:  Well, I was going to come
           back to that one, if you'll -
                       DR. WALLIS:  You're going to come back to
                       MR. WAGONER:  Yes, sir, I will.  Okay? 
           Only because it's -- well, I'll get to it here.
                       I want to wrap up my part with just a
           perspective on where I think we are in this situation. 
           First off, we're dealing with a very low probability
           event, and the combination of LOOP-LOCA or LOOP-main
           steam line break, when you sum them all up, for all
           the plants that are participating, it's less than ten
           to the minus six.  Actually it's much less than ten to
           the minus six because this ten to the minus six on
           frequency is over a 24 hour period.
                       This thing is over in 60 seconds, and when
           you do that, you take it down another couple order of
           magnitude.  So we're dealing with something at ten to
           the minus eight, ten to the minus nine probability of
           even happening, and in fact, as you know, there are
           efforts underway to eliminate simultaneous LOOP-LOCA
           as a design basis event.  So --
                       DR. POWERS:  I mean, I think what you're
           saying is that the mean value of the probability is
           very low, but if I asked my blacksmith friends if they
           are very certain about that number, they say, "Well,
           no."  And so when I ask them about 95 percentiles,
           those probabilities come up fairly dramatically, don't
                       MR. WAGONER:  Come up to -- bring them up
           to -- bring them up two orders of magnitude, but then
           take it down to the real time of the event, which is
           60 seconds, and you add back three orders of
           magnitude.  So I think realistically any way you cut
           it, the initiating event is pretty low probability.
                       DR. WALLIS:  But you're not asking us to
           evaluate the risk.  You're asking us to evaluate a
           technical report on waterhammer.
                       MR. WAGONER:  Yes, sir, I am, but what I'm
           asking you to do is look at a perspective that is at
           a reasonable judgment to use to mitigate the
           theoretical loading versus understanding everything
           that's happening right at the interface.  That's where
           I'm coming from from a risk perspective.
                       DR. ROSEN:  What you're saying is that if
           you don't have a loss of off-site power, you have a
           LOCA, but you don't have a loss of off-site power; you
           don't have this event.
                       MR. WAGONER:  The event never happens. 
           That's right.
                       DR. ROSEN:  And I think it's generally
           understood and believed that loss of coolant accidents
           don't cause losses of off-site power.  Generally
           plants, even when they trip, as they would in a loss
           of coolant accident, the grid is typically unaffected
           by that.  The plants continue to receive off-site
           power, and in that case, this event wouldn't happen
           because the fans would never coast down.  They would
           be starting if they weren't running, and the component
           cooling water or whatever service water would never
                       DR. POWERS:  Isn't there a lower bound on
           this just given by the seismic hazard?  You can never
           go lower than the seismic hazard on this one?
                       DR. ROSEN:  I think that's fair because
           losses of off-site power would occur during a major
           seismic event that was strong enough to cause a LOCA.
                       MR. WAGONER:  So anyway, I think we're
           starting with a low probability event.  We looked at
           the risk of pipe failure, again, looking at our three
           safety functions, maintaining coolant capability,
           bypassing containment or flooding containment.  Those
           last two require you to do something to the integrity
           of the system.
                       And we think there are significant margin,
           and that's why I go back to the slide that you thought
           I was going to skip over, relative to the structural
           integrity.  If we looked at a typical tubing or
           typical typing material, steel --
                       DR. POWERS:  People never do that though,
           do they?
                       MR. WAGONER:  Huh?
                       DR. POWERS:  I mean when we go through
           ASME codes and things like that, we never look at
           typical.  We look at lower bound numbers, don't we?
                       MR. WAGONER:  I've lost you.  What's --
           this is typical piping that's used, is carbon steel,
           standard wall, .375 thickness.  It might be eight,
           ten, 12, 14 inch.  So that's why I say this is
                       DR. POWERS:  Well, you're going to go
           through these various stresses numbers here.  Are
           those typical values or are they lower bound values?
                       MR. WAGONER:  Well, these numbers are
           right out of the code.
                       DR. POWERS:  Okay.
                       DR. WALLIS:  Well, it doesn't say use Sult. 
           It says use S allow, isn't it, which their number
           doesn't become 3,000?  It becomes less than 1,000.
                       MR. WAGONER:  Okay, and that's true, but
           you can use ultimate if you're looking at an
           operability issue or looking at a real world behavior
           of the pipe.
                       MR. BROWN:  Vaughn, this is Tim Brown,
           Duke Energy.
                       That's a faulted event.  So ASME lets you
           use 2.4 SH, which is very close to S-ultimate.
                       DR. WALLIS:  It lets you use Sult?
                       MR. BROWN:  It's very close to S-ultimate.
                       MR. WAGONER:  Thank you, Tim.
                       But anyway, there's some margin.  These
           numbers you'd have a factor of about six.  Take it
           down a little bit and you've got a factor of two,
           three, four, five.
                       DR. WALLIS:  Now, this 600 -- sorry.
                       DR. FORD:  I was about to say is B-280 as
           a copper?
                       MR. WAGONER:  That's right.
                       DR. FORD:  Copper, copper-nickel?
                       MR. WAGONER:  Yeah, that's typical copper-
           nickel tubing, which in fact is typically what's in
           the heat exchanger.  Some of them have been changed to
           a stainless steel.
                       DR. FORD:  Have any of these analyses been
           done on degraded piping?
                       MR. WAGONER:  These are always -- these
           are done -- well, this is a typical wall thickness. 
           All of these systems are monitored for degradation,
           but through Section 11 of ASME code.  So heat
           exchangers, the tubes are monitored for degradation. 
           The piping systems are monitored for degradation.
                       DR. FORD:  Is there not concern though,
           Vaughn, that, for instance, B-280 -- when it goes
           through that U bend, there will be erosion presumably
           at that U bend.  So at that point that's the thing
           that's going to be hit by the waterhammer.
                       MR. WAGONER:  Un-huh.
                       DR. FORD:  So at that degraded U bend,
           which is presumably eroded, after 20 years or
           thereabouts in 8 ppm oxygenated water, what is the
           safety issue then?  Did not that degraded U bend be
           now exposed to that waterhammer pressure?  Would it
           stand it?
                       MR. WAGONER:  It could be, but again,
           we're monitoring these systems.  We run eddy current
           (phonetic) probes through those heat exchangers to see
           what the tubes look like.
                       DR. FORD:  And that has been done?
                       MR. WAGONER:  Yes.
                       DR. FORD:  And there is no degradation at
           that U bend?
                       MR. WAGONER:  If there is, you have to --
           you have to address it.
                       DR. FORD:  How often is it inspected?
                       MR. WAGONER:  Well, that depends on what
           you find.  If you've gone ten years and haven't seen
           anything, then you -- through ASME, you're allowed to
           -- through the code you're allowed certain inspection
           intervals, you know, based on your findings.
                       DR. FORD:  Presumably the -- okay, and the
           same applies to the carbon steel header which is
           essentially a closed tube?
                       MR. WAGONER:  Closed with respect to the
           loop that it's in, yes.
                       DR. FORD:  And it would be a welded closed
                       MR. WAGONER:  Right, typically, yes.
                       DR. FORD:  Okay.  And that is inspected
                       MR. WAGONER:  Yes.
                       DR. FORD:  Because that will degrade.
                       MR. WAGONER:  Yep.  And there have been
           replacement programs that you heard last time.  Some
           folks have had to replace sections of piping due to
           monitoring and indications of degradation, and that's
           typical of the whole steam system.
                       DR. FORD:  Just assume that what with the
           ISI inspection periodicity you had a waterhammer
           effect and it hadn't been inspected and it hadn't been
           replaced.  How would that affect the whole safety
                       MR. WAGONER:  Well, actually --
                       DR. FORD:  Could a degraded pipe, whether
           it be the piping, the A-106 header, or the copper-
           nickel tubing -- it was degraded, hadn't been replaced
           -- could that withstand that water pressure?
                       MR. WAGONER:  And, yes, it would be a
           multi-degradation scenario, but in fact, from a
           personal perspective, I talked with some of our
           operations folks at one of the plants and said, "Okay. 
           What if?"
                       And there's a couple of things that
           happen.  One is our emergency operating procedures are
           all symptom based.  So a couple of things could
           happen.  You could have a containment bypass that
           would be harder to detect, but it would be indirectly
           indicated because you'd have to also have a loss of a
           service water flow in order to get a containment
                       Then the other possibility would be
           containment flooding, and that's right in the EOPs
           because those are all symptom based, and you would be
           looking at, you know, your levels and things that are
           already going on.
                       So the symptom based EOPs don't care where
           the water is coming from.  They just address it from
           a flooding issue if need be.
                       MR. SIEBER:  It seems to me that
           degradation in those systems was mostly through mic.
           attack, microbiologic --
                       MR. WAGONER:  Yeah, there has been.  I
           think mic. has shown up in stainless steel systems on
                       MR. SIEBER:  It really shows up in carbon
           steel piping.
                       MR. WAGONER:  Oh, okay.
                       MR. SIEBER:  And the ISI program uses an
           ultrasonic thickness gauge, which is a spot
                       MR. WAGONER:  Yes.
                       MR. SIEBER:  Those numbers there are min.
           wall numbers, okay, for typically that's Schedule 80
           piping, and so when you measure the thickness in the
           manufacture, there's a corrosion allowance built into
                       MR. WAGONER:  Okay.
                       MR. SIEBER:  And all of the stress
           allowances are based on min. wall.  Okay?  So that's
           how you get a service life out of it.  You could
           actually calculate the degradation and the bursting
           pressure if you're below min. wall, but the code says
           you've got to replace it when you hit min. wall or
           below it.
                       MR. WAGONER:  Okay.
                       MR. SIEBER:  And you have to measure at
           more places if you find one place that's below min.
                       MR. ESSELMAN:  The 600, is this with air
           in the lines or is that without air in the lines?
                       MR. WAGONER:  No, that's just an
           assumption at 20 feet per --
                       DR. WALLIS:  That's just an assumption?
                       MR. WAGONER:  Well, it's at a 20 foot per
           second --
                       DR. WALLIS:  Is this the Joukowski
           pressure or is this with air?
                       MR. ESSELMAN:  This is Tom Esselman again.
                       That is uncushioned.  It's without air. 
           That's just the straight Joukowski --
                       DR. WALLIS:  Then why do we worry?
                       MR. ESSELMAN:  The purpose of this is to
           say that a failure mechanism that we need to address
           is not one that is frequent in waterhammers of much
           larger pressure which causes the tube or a pipe to
           burst.  And in these systems, 600 psi waterhammer is
           greater than any of the waterhammers we expect to see
           because we have a controlled velocity of closure.
                       The closure velocity is determined by the
           pumping characteristics.  So that this is the largest
           pressure that we can see from this event that we're
           talking about here, again.  The burst pressure which
           does have to -- which has to be augmented clearly by
           satisfying all of the ASME code requirements not only
           for burst, but for bending, but that burst pressure
           just is shown to indicate the margin that we have been
           the pressure that we will see in this event and what
           it takes to burst the pipe.
                       Now, bursting the pipe is one of the
           mechanisms that have to be considered.  The other is
           a traveling wave that has pulled supports out of the
           wall for other kinds of waterhammer, and even for this
           waterhammer at those magnitudes, it has the potential
           to do that.
                       But yet from an integrity point of view,
           a piping integrity point of view, what we would like
           to -- what we're trying to point out here is that
           we're not concerned -- obviously we have to be
           concerned, but yet this waterhammer cannot challenge
           the burst pressure of the typical components.  What we
           are focusing on is the traveling wave, the conversion
           of those waves into support forces, which is Vaughn's
           second bullet, if I may, that says that we are
           focusing on support failure and subsequent deformation
           of the piping system that would be required to
           challenge the pressure boundary integrity.
                       We have to evaluate for burst pressure,
           but we're so far away in this case that we are
           focusing much more on how to track this pressure wave
           through the system and get to the point where we can
           calculate support forces because that's the line of
                       Before pressure boundary integrity can be
           challenged, you have to cause the support to fail, and
           then you can subsequently challenge the pressure
           boundary integrity.  That's a much more difficult
           failure mechanism to occur.
                       DR. WALLIS:  This is very interesting to
           me.  We spent about two thirds of our time, and we
           have yet to get to the EPRI report, which is the whole
           focus of our meeting, isn't it?
                       Are you up here to take all of the shots
           before we get to EPRI?
                       MR. WAGONER:  I was going to give a brief
           introduction.  Let me just make one more point and
           I'll quit, and that is I think to why are we worried. 
           Dr. Wallis, frankly, I have the same question.  Why
           are we worried?
                       Because we're really down to dealing with
           a compliance issue.  We're trying to make the
           mathematics work in our piping analysis system. 
           That's where we are.
                       I don't believe -- we've got a low
           probability event.  I don't think we have a safety
           significant issue, and we're down to trying to make
           the mathematics work so that we can say that we have
           a system that is our piping support system meets
           design basis so that we're in compliance with our
           design basis.  I think that's all we're dealing with,
           frankly, and we need a little bit to do that, 20, 30
           percent, and that's what we're trying to get out of
           this cushioning thing.
                       And with that I'll move on.  Thank you.
                       Tom, you're up.
                       MR. BOEHNERT:  Now, I understand we have
           to go into closed session; is that correct?
                       MR. WAGONER:  Yes, the next slides do
           contain proprietary information.
                       (Whereupon, at 11:25 a.m., the meeting was
           adjourned into closed session, to reconvene at 12:32
           p.m. in open session.)
                       MR. TATUM:  Okay.  Jim Tatum again from
           Plant Systems Branch.
                       Staff perspective on this, first of all,
           we would agree with the points that were raised by the
           subcommittee.  Obviously when you take a look at it,
           there are shortcomings in the testing apparatus.  The
           hA is a very difficult value to come up with.  Even if
           full scale testing were done, the correct analytical
           approach for calculating and coming up with a value
           that would be applicable to other pipe sizes would be
           questionable no matter what.
                       So there's uncertainty, and there's going
           to continue to be uncertainty from that perspective. 
           But I do want to acknowledge that points raised by the
           subcommittee are valid.  We agree, and where do we go
           from there?
                       And basically in looking at generic letter
           9606 and resolution and whatnot, there are other
           factors that we need to consider, I think, from a
           perspective of regulation, public health and safety
           and whatnot.  We really need to try to put this in
           perspective in trying to determine where do you want
           to go from here.
                       Now, in looking at the other factors, the
           other factors that come to bear here, first of all, we
           do recognize and appreciate that this is a complex
           phenomenon.  It's very difficult to model.  There's
           going to be uncertainty, and we need to be able to
           deal with that somehow.
                       We believe it's important to appreciate,
           I guess, the work that EPRI has done, the involvement
           of the expert panel and that's gone into it.  I think
           by and large they've done a pretty good job with the
           resources that have been available, and the effort
           that they've put into it.
                       They're kind of at the end of the rope --
           end of the road on this.  We understand their --
                       DR. POWERS:  Or the end of the rope,
           either one.
                       MR. TATUM:  Yeah.
                       MR. TATUM:  They're as limited in
           resources was we are.
                       DR. WALLIS:  Which end of the rope are
           they on?
                       MR. TATUM:  Yeah.  Maybe that was a
           Freudian slip.  I don't know.
                       MR. TATUM:  Anyway, they're limited on
           resources.  They're having difficulty getting
           additional funds from participating utilities.  We can
           appreciate that.  We hear that on our end as well.
                       The NUREG CR-5220 waterhammer loads, if
           you'll look at what's calculated in that approach,
           which is a bounding approach, the Joukowski approach,
           what EPRI is proposing in their methodology gives you
           a reduction by a factor of 1.2 to possibly 1.6.  If
           you look at the NUREG, it talks about the fact that
           the evaluation by NUREG CR-5220 could be a factor of
           two to ten conservatively, depending on what's going
           on, air cushioning, steam condensation, that sort of
                       Unfortunately it doesn't qualify how much
           reduction to expect for different facets of the
           waterhammer event.  However, I think what EPRI is
           proposing is certainly reasonable, and it's within the
           expectations at least that I would have in looking at
           what is said in NUREG CR-5220 and what they're
           proposing.  I don't think it's out of line.
                       LOOP events, I think in the testing and
           analyses that have been done, the waterhammer group
           here has shown rather convincingly that the LOOP
           event, LOOP only without steam, would be bounding.
                       Okay.  If we take a look at just the LOOP
           event, that takes us back to USI A-1 basically.  That
           was reviewed previously, and we considered that part
           of the resolution.  I think it was 927, Rev. 1, talks
           about resolution in there, and we acknowledge that
           plants have during start-up phases experienced those
           waterhammers due to LOOP, due to LOOP testing.
                       Any plant design weaknesses or
           vulnerabilities due to LOOP have been identified
           during early start-up days and whatnot, and those
           problems have been corrected.  So at least in my mind
           the situation with steam in the piping is a step
           removed really in significance from just the loop
                       And if we were going back to resolution of
           USI A-1, I'd just remind you we really didn't go out
           to the plants and have them do anything to address
           this issue, and I don't think it is our purpose, nor
           was it our purpose, in issuing Generic Letter 96-06 to
           have plants go and address this issue.  It was really 
           the concern relative condensate induced waterhammer
           that drove the waterhammer issue in Generic Letter 96-
                       So we have sort of transitioned here in
           the work that's been going on from what our concern
           was to a different aspect of the concern, something I
           think that is a little removed from what our real
           concern was to begin with.  We were thinking that
           condensate induced waterhammer would be the real
           severe issue that needed to be addressed, and I think
           what we've learned based on the work that EPRI has
           done is that, no, for low pressure systems we really
           don't have to be so concerned about that.  It's really
           the loop event, and that brings us back to USI A-1,
           and I don't think we want to try to force the industry
           into doing something that we didn't ask them to do
           originally and really wasn't part of the generic
           letter consideration.  So we do have to be a little
           bit sensitive to that.
                       Again, I'd emphasize cooling water systems
           are maintained not only for in-service testing and
           ASME code or other standard requirements, but also
           Generic Letter 89-13 was issued in recognition of the
           problems that we were seeing, reports that were made,
           LERs and whatnot with degradation and vulnerabilities
           that were being identified by utilities over the years
           with service water systems and cooling water systems.
                       So we have asked utilities, and we have
           done inspections to confirm that they are implementing
           programs to satisfy those concerns to make sure they
           know what the vulnerabilities are, what the
           degradation mechanisms are.  
                       If it's mic, they're identifying that, and
           they have established programs to address that. 
           Obviously those degradation mechanisms are very plant
           specific.  It depends on the water quality, et cetera,
           but the plants are responsible to know what's going on
           in their system and to implement programs to maintain
           the quality of the system and the integrity of the
                       And we're confident that they are at a
           point where they're doing that.  We've performed
           inspections to satisfy ourselves of that.
                       Also, we would agree with what Vaughn
           Wagoner and EPRI have said.  We believe that this is
           of low safety significance, primarily just looking at
           the numbers for LOOP plus LOCA.
                       But if you go beyond that, if you had a
           problem with service water in containment, we've had
           other evaluations, other initiatives where you look
           at, well, what is the robustness of containment, how
           much can it take during, for example, maybe a hydrogen
           explosion, and the containments can take more
           typically than what we give them credit for, which
           tells us that, well, okay; you do have some margin
           there to heat up containment.  If you did have a break
           in the service water system, in the cooling water
           system, typically those are isolatable from outside
           containment.  I wouldn't expect that to be a problem.
                       So there are actions that can be taken
           should the event occur, which also helps to put this
           in a different kind of a risk perspective, and early
           on we were hoping to be able to address it from that
                       Unfortunately, it becomes such a plant
           specific evaluation that it's not something that our
           staff, that the Risk Assessment staff could handle on
           a generic level, and so we deferred to industry and
           asked that they consider risk, and that's why, partly
           why, I think, Vaughn mentioned that, was because it
           was requested by the staff to see if they could handle
           that or deal with that more handily than we could. 
           That was the reason for that.
                       MR. SIEBER:  Let me ask a simple question. 
           If condensation induced waterhammer is just a small
           fraction of the forces that pump driven waterhammer
           has, and since start-up testing for every plant that
           I know, which isn't all of them, for sure, has already
           tested pump driven waterhammer and all of the
           deficiencies corrected, why can't the issue be
           resolved just on the basis of that logic?
                       MR. TATUM:  Well, that's certainly a
           possibility and something that could be considered. 
           It's not something the industry has proposed, but it
           is something that I think is within the realm of
                       We're still reviewing the issue and trying
           to see how it fits together, but it's our expectation
           that for LOOP, the plants, in fact, are able to handle
           those events.
                       MR. SIEBER:  That's right.
                       MR. TATUM:  They have shown that during
           the start-up testing and whatnot.  
                       The complication maybe that you get into
           there is the combined loads and what's required by the
           FSAR design basis.  Would you require plants to
           combine those loads somehow?
                       So you get into the design basis base and
           FSAR requirements and being able to address that.  And
           it's a possibility it's something that certainly the
           industry can suggest.  We have discussed it, but not
           really gone into detail on that.
                       MR. SIEBER:  Thank you.
                       MR. TATUM:  So having considered these
           other factors, I'll just put up my last slide here,
           which would give you our preliminary conclusions.  As
           I've said, we haven't completed our review.  We do
           have a number of open items.  One has to do with air
                       We believe that for the work that has been
           done, that the proposed amount of air is conservative. 
           However, we're looking at differences in plant
           arrangement, for example, that maybe would explain or
           argue that, well, maybe the amount of air for one
           arrangement versus another may not -- maybe you
           wouldn't credit that much, and we just need to think
           through in our evaluation the different plant
           arrangements that we would expect to see and whether
           or not the proposed amount of air release would be
                       At least we believe it would be
           conservative for the different plant arrangements.  So
           we're looking really at that kind of a level or that
           type of a review for air.
                       However, for the testing that was done and
           for the limited scope testing, you know, representing
           basically a stagnant tube, but without the continued
           flow and whatnot, we do believe rather convincingly
           that it is conservative, and it may not be the right
           number, but part of what we're considering is, well,
           is it a conservative approach and do we believe that
           it would give us confidence that if the utility used
           this approach, that they would give us an answer or
           come up with a load that is conservative with respect
           to the waterhammer condition.
                       It's not just is it the right number, but
           is it a conservative number, and I think the
           subcommittee has pointed out very well that it may not
           be the right number, probably is not the right number,
           certainly not exact,b ut we're tending to look more on
           whether or not it's conservative and whether or not we
           can base our evaluation on the work that was done and
           use that in resolving or closing out this issue for
           these plants.
                       DR. ROSEN:  Jim, I only have one remaining
           residual, remaining concern, and that is that post
           LOCA-LOOP emergency operating procedures are specific
           enough to assure that plant staffs will isolate
           faulted fan coolers if that should happen, even though
           these analyses say it probably won't.
                       Is that something you're thinking about?
                       MR. TATUM:  Well, it's not something --
           you know, the emergency response was touched on a
           little bit by EPRI, and you do get into the symptoms
           based or symptoms driven response, and to the extent
           the operators are able to identify the reason for the
           symptom, they can address it.
                       But you get into real complications with
           operator response and human error and human factors
           and whatnot, and we really haven't gone into that
           level of detail.  We have not involved emergency
           response people.
                       I don't know.  Our feeling is that it's
           relatively low safety significance.  We don't know
           that it really warrants that level of review at this
           point.  That's kind of where we are on that.
                       CHAIRMAN BONACA:  I had a question.  Do
           you expect us to write a report on this issue?  I
           mean, at the end you're telling us these are
           preliminary conclusions.  You told us that there are
           a number of open issues, and I think you have some
           judgment you're making regarding conclusions, and I am
           left, you know, with a question in my mind.  Are we
           ready to write a report of this or should we?
                       MR. TATUM:  Well, obviously the
           conclusions I'm giving you here are the staff's views
           on what we've seen, our understanding of the work
           that's been done and the report as it has been
           presented in our review to date.
                       We do have, as I say, some open issues,
           but we do not think that the shortcomings of the
           analytical derivations or the experimentation and the
           issues that have been raised by the subcommittee, we
           do not believe that those shortcoming really are show
           stoppers with respect to being able to use that report
           and credit it for analyzing waterhammer events at
           these plants.
                       We think that to the extent we do identify
           significant issues during our evaluation, and like I
           say, the air is one.  We have pulse rise time, I
           think.  We're considering single pulse, multiple
           pulse.  You know, getting back to our review of the
           document itself, we may find the need to impose
           certain restrictions on how the report is used.
                       One restriction that we know we would
           impose is that the report would only be used -- we
           would only accept it for resolution of 96-06
           waterhammer.  It would be allowed for any other
           application because the testing is pretty specific to
           96-06 for fan cooler systems.  It would not be
           applicable to RHR or other systems that typically
           experience waterhammer.
                       So we're going to be very specific on
           where we allow it.  It's only this limited use
           application, but we think that industry has provided
           sufficient argument.  It's convincing, I believe, to
           provide reasonable assurance to us that if the
           utilities use that methodology, they can at least come
           up with a value for support loads and whatnot that's
           realistic, credible, and something that we can use to
           resolve the issue.
                       CHAIRMAN BONACA:  Okay.
                       MR. HUBBARD:  This is George Hubbard.
                       I'd just like to reemphasize that; that I
           think really the question is:  is the user manual that
           they will be providing to industry -- does it provide
           a reasonable method for a plant to take, do plant
           specific analysis, and use this methodology to
           determine their waterhammer loads?  Does that provide
           a reasonable method for them to use and considering,
           in particular, the low safety significance of this
                       And I think, you know, if you were to
           write a letter, we would be looking for the ACRS to
           tell us yes or no, that the use of this user manual is
                       DR. WALLIS:  Usually what happens is the
           staff takes a position and we see something written
           from the staff, and then we write a letter saying we
           agree with the staff or whatever.
                       In the absence of this final statement
           from the staff, you're sort of asking us to be the
           staff and to write a review of the document.  It's not
           really our job.
                       MR. HUBBARD:  Okay.  I guess the point is,
           I think, from the management perspective we're seeing
           that this with maybe some limited -- being limited to
           the containment fan coolers from a management
           standpoint; we're seeing that this does provide a
           reasonable approach, and that any restrictions we
           would be putting in our safety evaluation on how they
           apply it.
                       But basically, considering the safety
           significance of this issue, I think they've got a
           reasonable approach for dealing with this.
                       DR. ROSEN:  In fact, we do have your final
           conclusions on this.
                       DR. WALLIS:  I have another question. 
           This document, this EPRI report, is this going to
           eventually be a public document?
                       MR. TATUM:  Yes, it is.
                       DR. WALLIS:  So that means that in the
           presentation we kept being promised improvements to
           the report, and I think that the real driving force
           for that is that eventually it's going to be out there
           in the public.  So it's got to be a convincing
                       MR. TATUM:  Well, it will be proprietary,
           and there will be a non-proprietary version.  We also
           have editorial comments that we've found and we will
           be sharing with EPRI, corrections that need to be
           made.  They will prepare a final version, and also, I
           think, put their own corrections and also add the
           additional detail that they've promised the
                       But once they've put that final version
           together, then they will also prepare the
           nonproprietary version and made that submittal.
                       DR. WALLIS:  So I think there are sort of
           two issues here.  One is is this a safety issue and is
           this good enough to resolve the safety issue.  The
           other one is is this the sort of report you want to
           see out in public as typical of what the NRC accepts.
                       They're sort of different questions.
                       MR. TATUM:  Yeah, and as I say, I mean,
           the staff really doesn't have a problem accepting the
           report for the specific limited application.  We would
           have a problem obviously accepting it as a way to
           evaluate waterhammer in general
                       MR. SIEBER:  Maybe I can ask one more
           question.  Is there a list of plants that have
           resolved this issue outside of the methodology of the
           EPRI process?
                       MR. TATUM:  I do have a listing of plants. 
           I can't tell you off the top of my head what they are,
           but there have been quite a number of more plants that
           have resolved it outside this process.
                       MR. SIEBER:  Okay, and of course, there's
           a list of the members of the group who would intend to
           resolve it this way.  If I take those two lists, does
           that include all of the plants subject to the generic
                       MR. TATUM:  All except I'd say maybe about
           half a dozen.
                       MR. SIEBER:  What happens to them?  You
           know, what are they doing?
                       MR. TATUM:  Now, the half a dozen that are
           left, a couple of them have submittals in house that
           we're reviewing.  They have used RELAP and were not
           comfortable with their use of RELAP, and so we need to
           take a close look at it.  So those are in process.
                       Others that we're looking at, I think your
           concern is, well, what if they wanted to use this EPRI
                       MR. SIEBER:  Well, that would be one
           concern, or what happens after this group has spent
           maybe a million bucks or whatever to do this, and then
           somebody else devises some, you know, very simplistic
           approach.  What is the criteria by which you would
           accept all of these various methods?
                       MR. TATUM:  Well, a particular utility is
           always free to propose an approach, and we obviously
           are obligated to review that.  And, in fact, that's
           what brought us here to begin with.  Utilities were
           trying to make submittals on their evaluations that we
           felt were just not adequate, and we asked the
           questions.  We would ask the same questions that we
           asked in the beginning about the evaluation.  What
           were the assumptions and considerations that went into
           it, whether or not they followed Joukowski, if they
           were proposing some other approach and what was the
           justification; that's what drove this group of
           utilities together to form the working group and to
           develop this methodology.
                       It wouldn't be a trivial matter for a
           single utility to come in on their own and say, "Well,
           we'd like to use this other approach."  We'd expect
           the same kind of effort and expense, I would expect,
           to justify that approach.
                       MR. SIEBER:  Okay.  Thank you.
                       MR. TATUM:  Any other questions?
                       (No response.)
                       MR. TATUM:  Okay.  Well, thank you very
                       DR. KRESS:  Thank you.
                       And I turn the floor back to you, Mr.
                       CHAIRMAN BONACA:  Yeah, I think we should
           postpone any further discussion to the afternoon.
                       DR. KRESS:  Yeah, I think that's correct.
                       CHAIRMAN BONACA:  And with that I think
           we'll recess for lunch now.  Well, we do have some
           discretion because the two meetings we have in the
           afternoon, the first two are just internal matters. 
           One is reconciliation of ACRS comments.
                       I would propose that we do that when we
           reconvene, say, at 1:45, and then after that -- and we
           will do the subcommittee report at 4:00 p.m., at the
           conclusion of the reactor oversight process.
                       Okay.  With that, then the meeting is
           recessed until 1:45.
                       (Whereupon, at 12:55 p.m., the meeting was
           recessed for lunch, to reconvene at 1:45 p.m., the
           same day.)
           .                     A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (2:30 p.m.)
                       CHAIRMAN BONACA:  Let's resume the meeting
           now.  The meeting will come to order again.
                       And we're going to review the reactor
           oversight process.  We have presentations by the NRC
           staff, and I'll turn the meeting to the Chairman of
           the subcommittee, Jack Sieber.
                       MR. SIEBER:  Okay.  I'll be very brief. 
           Actually we have had four previous meetings on this
           subject where we have looked at various components of
           03-05 and how it fits together, and today is a review,
           which is necessary for us because we have an SRN that
           we need to answer, dated April 5th, 2000.
                       And you'll notice on the board that it's
           rated A plus, which means get it done or stay here
           forever, and so what I'd like to do is we will discuss
           performance indicators, initial implementation,
           significance determination process, and the technical
           adequacy of the significance determination process to
           contribute to the reactor oversight process.
                       And since we are going to put out a report
           at this meeting some time, I would encourage members
           to ask the pertinent questions that they feel are
           matters of concern to them so that we can have the
           advantage of the staff's response.
                       And with that, Mike.
                       MR. JOHNSON:  Thank you.
                       My name is Michael Johnson from the
           Inspection Program Branch, and I'm joined at the table
           by Mark Satorius, who is the Chief of the Performance
           Assessment Section, and Doug Coe, who is the Chief of
           the Inspection Program Section.
                       And as was indicated, we are here to talk
           about the reactor oversight process.  I ought to
           mention that also at the side table we have Don
           Hickman, who is, as you are aware, our performance
           indicator lead.  Chris Nolan is here representing the
           Office of Enforcement, and in fact, throughout the
           room are a number of folks from my branch and who
           serve in various capacities, and also Steve Mays from
           the Office of Research.
                       So we've got a pretty good spectrum of
           folks in the room to listen in on and possibly
           contribute on the discussion of reactor oversight
                       As was mentioned, we have had several
           briefings throughout the first year of initial
           implementation for the ACRS, and those briefings have
           focused on areas, I think of key importance to the
           ACRS in preparing for this letter writing opportunity
           that you have for the Commission.
                       And we focused in on the important areas,
           I think, that are of interest to you.  We focused in
           on performance indicators, significance determination
           process.  We went through a fairly exhaustive
           presentation, I think, and tried to demonstrate for
           you the use of the SDP.
                       We talked about in a session, I think, in
           July the action matrix and tried to respond to your
           questions and provide you a good overview of what we
           intended to do with respect to the action matrix and
           the reactor oversight process.
                       At our last meeting in July, we also took
           the opportunity to try to forecast for you what we
           were going to -- then, at that time, we were
           previewing what we were going to tell the Commission,
           that we ended up telling the Commission in fact on the
           20th of July about the reactor oversight process.
                       At that time we really used some of the
           high level slides that captured the results that we
           documented in the Commission paper and the fact that
           we, again, did, in fact, discuss with the Commission.
                       Those overall results, and I'll just
           repeat them briefly, right now is that based on the
           input that we got from internal stakeholders and
           external stakeholders, based on a very, very thorough,
           I think, use of self-assessment metrics and internal
           feedback through a Federal Register notice and an
           internal survey, reached the conclusion that the
           reactor oversight process, while not perfect, does do
           what we intended it to do, in that it makes steps in
           the direction of improving its ability to be more risk
           informed, understandable, predictable and objective,
           and in fact, goes towards meeting the agency's NRC
           performance goals, maintaining safety, efficiency, and
           effectiveness, those goals that you're well aware of.
                       Having said that, we did learn lessons
           throughout the first year.  We tried to characterize
           those lessons for you, and in fat, we had planned
           actions that we described in the Commission paper, and
           we talked about those planned actions in July.
                       And so the point that we tried to leave
           with in July, and I want to start off with perhaps
           today, is, again, while we know the process isn't
           perfect, we believe and have told the Commission and
           I think the Commission recognizes that the ROP is a
           step in the right direction.  It does represent an
           improvement over the previous process, and we ought to
           go forward and make improvements, and that's our
           mantra, the mantra that we carry for the staff, with
           the staff, is that we are going to continue to improve
           the ROP in this next year, in fact, the year that
           we're already in, the second year of implementation of
           the ROP.
                       I ought to also mention by way of
           background that in addition to, you know, talking
           about the status in that last briefing, we did
           something that I thought was very useful, that is, the
           ACRS subcommittee did something that was very useful
           for us, and that was that we went around the table,
           and each of you told us, each of the subcommittee
           members told us what their primary concerns were with
           respect to the ROP, and we wrote those down, and we
           listened to those concerns.
                       And they dealt with things like confusion. 
           There's confusion with respect to, for example, what
           is meant by a green PI and how that differs from a
           green inspection finding and how we treat those
           consistently through use of the action matrix.
                       We talked about, the ACRS subcommittee
           talked about the consistency of the treatment of
           issues in various cornerstones, if you will.  In fact,
           we talked about the ALARA cornerstone, the
           occupational safety cornerstone, and the ALARA SDP and
           where that gets you with respect to the significance
           of issues and whether or not that's equivalent when
           you look at the reactor safety SDP and where you come
           out with respect to that.  That was an issue.
                       We talked about the treatment of safety
           conscious work environment and all of the cross-
           cutting issues and the concern on the part of the
           subcommittee members at that time with respect to
           those issues in the ROP.
                       We talked about the plant specific
           thresholds for performance indicators or the fact that
           we ought to be moving in the direction of plant
           specific PIs or plant specific thresholds, I should
           say, associated with performance indicators.
                       There was a concern about rewarding the
           good performance in this process, and really a
           concept, I think, on at least some participants' minds
           that the old process, the SALP process used to provide
           something in terms of incentive for licensees to
           improve their performance, and in fact, the ROP, the
           existing ROP that we've gone to, does not.
                       There was a concern late in the meeting
           about the consistency of ROP implementation, the issue
           being that are we, in fact, at the threshold for
           documentation level at the identification of green
           issues and white issues.  Are we consistent among the
           very regions in terms of how we implement the ROP?
                       So we talked about those issues.  Those
           were among the issues that we raised, and, in fact,
           there are other issues that we're aware that the ACRS
           has continued to raise and that we've continued to
           take action on.
                       In fact, one of the things I wanted to
           tell you is that as you'll hear in a few minutes we
           have taken or are taking action and moving in the
           direction to address many of the concerns that you've
           raised in the past, and in fact, I feel very positive
           with respect to the role of the ACRS in terms of
           shaping the direction of the staff with respect to
           improving the implementation of the --
                       Has the word gotten out that we're easily
           swayed by flattery?
                       MR. JOHNSON:  The flattery is almost over. 
           So let me --
                       MR. JOHNSON:  The last point I would make,
           and then I'll shut up and let Mark talk, is that I do
           want to tell you that we are prepared today to talk at
           a very high level with respect to the ROP, and we'll
           touch on all of the areas that are of interest to you,
           and we'll do our best to answer your questions.
                       I do want to tell you though that we did
           not bring the cast that I would have brought if we had
           the time to do the very detailed reenactment of some
           of the earlier presentations that we had for the ACRS,
           for example, the SDP discussions and those kinds of
                       So I simply tell you that to say that
           welcome your questions.  We'll do our best to address
           your questions, although I don't think the time is
           going to allow us to delve into a lot of detail on any
           of the issues that we've talked about in the past.
                       Having said that, let me turn it over to
           Mark, and Mark will start off the discussion, a very
           brief presentation, I might add, on lessons learned
           and actions that we're going to take on the major
           areas of the ROP, and then we'll be quiet and
           entertain your questions.
                       MR. SATORIUS:  Thanks, Mike.
                       I'm going to talk about both performance
           indicators and also assessment.  But like Mike
           indicated, we're here to do our very best to answer
           your questions as they develop and to give you a good
           briefing on where we've come thus far.
                       I would like to point out that unlike Mike
           and Doug and the majority of the folks in the
           Inspection Program Branch, I'm a relatively newcomer
           and been in the branch for three months.  So I don't
           have, I guess, the bench strength in my memory that
           some of my colleagues do.  So like I said --
                       MR. SIEBER:  Which probably won't help you
                       MR. SATORIUS:  I suspected as much.
                       I thought I'd start on performance
           indicators with just a very brief background just to
           kind of frame the performance indicator issues, and
           that is we put together some guidance with NEI in a
           working group that we had empaneled to develop some
           reporting guidance, and that was NEI 99-02, and that
           first revision was then revised again based on input
           from the working group, and also our stakeholders in
           the spring of 2001 after the first year of initial
                       The working group primarily was put
           together to provide resolution on PI issues as they
           developed, insights as to where problems existed with
           the PIs, and also as an avenue to develop any needed
           replacement PIs should it become evident that they
           were necessary.
                       With respect to the first bullet, that was
           a replacement scram PI indicator that at the onset of
           the ROP and initial implementation there was an issue
           involving whether we had identified the appropriate
           scram performance indicator, and that was the first
           performance indicator that we took on to conduct a six
           month pilot.
                       We performed that six month pilot in the
           spring of this year, came to a conclusion that the
           proposed pilot PI did not contain any advantages to
           the original PI, and it was the staff's view that we
           would retain the original PI for use.
                       Due primarily to some industry senior
           executives' interest in this matter, we have drafted
           a letter that would address our position on how this
           PI should be retained, and that letter is at the
           Commission right now for their review and consultation
           prior to issuance.
                       Once that's issued, it would be our intent
           to go ahead and inform the industry via a regulatory
           information summary that would indicate that we will
           retain the PI that was originally put into place.
                       MR. SIEBER:  And I guess the difference
           between the original industry position and your
           current position relates to whether manual scrams are
           included or not.
                       MR. SATORIUS:  That's exactly right, and
           the replacement PI proposed to do away with what's
           termed unintended consequences that develop as a
           result of manual scrams counting.  There were some
           positions that there would be unintended consequences
           as a result of potentially an operator hesitating or
           possibly not inserting the manual scram, and the
           replacement scram we concluded to a large extent did
           not remove the potential for unintended consequences. 
           There were unintended consequences that were developed
           as a result of that new replacement PI, and that was
           the conclusion.
                       MR. SIEBER:  Well, as a former operator,
           I think that when you count automatics and manual
           scrams just as a scram, the operator doesn't care one
           way or another.
                       MR. SATORIUS:  We got that.
                       MR. SIEBER:  The difference is if you
           don't count manual scrams and the operator is more
           likely to manually scram the plant where the automatic
           set both takes it off.
                       So I don't know whether that's good or
           bad, but that's what the original argument was.
                       MR. SATORIUS:  Some of the feedback we got
           from pros was that the operators would do the right
           thing irrespective of whether they were counted or
                       MR. SIEBER:  I think that's true.
                       MR. SATORIUS:  And we got that indication
           from a lot of operations managers in direct contact
           with various licensee staffs during the first year of
           initial implementation.
                       MR. SIEBER:  With regard to that indicator
           though I think that one thing that I note is that the
           threshold between green and white is such that it's
           not particular risk significant.  Okay?  You know, a
           plant is designed to deal with an automatic or a
           manual scram so that you actually have -- before it
           becomes risk significant to any appreciable extent,
           you have to get into the more serious thresholds.
                       Another indicator that's like that is the
           loss of heat sink.  For example, you have to lose heat
           sink to get to a red indicator three times a day every
           day for three years, and boy, if your plant is in that
           bad a shape, you know, I would say that indicator
           doesn't tell me much
                       MR. JOHNSON:  Yeah, and, Don, you're
           welcome to jump in at this point or you can wait if
           you want to a more opportune moment.
                       MR. HICKMAN:  Okay.
                       MR. JOHNSON:  But let me just say a couple
           of words before you do, Don.
                       One clarification is that we're going to
           count -- both indicators count manual scrams.  If you
           look at the primary change in the replacement PI, you
           won't find the word "scram" at all.  You'll find a
           shutdown, and then we've gone though the effort to try
           to define a shutdown that is a rapid shutdown like a
           scram without saying the word "scram."
                       And if you look at --
                       MR. SATORIUS:  And it introduces a 15
           minute period in there, in other words, a rapid
           shutdown within 15 minutes, and I think our view was
           when all is said and done, the potential for
           unintended consequences associated with that 15
           minutes is probably more than the operator -- and like
           you say, you haven't been an operator.  In the heat of
           battle in the control room, he's going to reach up and
           do the right thing.
                       MR. JOHNSON:  So I guess the point I was
           making was that we're going to count manual scrams. 
           We think it's important to count manual scrams.
                       Now, your point is well taken with respect
           to the thresholds.  Typically what we find is if a
           plant is going to begin to have problems with scrams,
           we'll see performance problems showing up that are
           reflected in other indicators, and in fact, for
           example, there's a special inspection going on right
           now where the plant had a scram and then had some
           other complications.
                       And so we'll do an event follow-up type
           inspection to look into that issue.  So we're not --
           that takes me into a good point, and that is to say
           that the performance indicators are a part of the
           indication that we have about the overall performance
           of the plan, but it's not the sole indication.
                       MR. SATORIUS:  I'll go now to just the
           unplanned power change PI.  The original PI read the
           number of unplanned power changes in reactor power
           greater than 20 percent within 7,000 critical hours,
           and there were a number of questions within our
           working group on that.
                       The industry and NEI had proposed a
           different unplanned power change PI that they intended
           to bring to the table to be piloted at some time this
           summer or fall.
                       We had also developed one ourselves and
           had entertained whether it might be useful to pilot
           both of them at the same time.  Through our working
           group NEI has taken those, our proposed, their
           proposed and, I guess, they're framing them or they're
           collecting data and seeing as to where those would all
           fall out, and they haven't gotten back to us with
           their proposed unplanned power change PI.
                       We've gone ahead and developed ours and
           would propose that at the next meeting that we have
           with them, to go ahead and pilot that at some point in
           the fall and early winter.
                       The last issue involves improving the
           safety system unavailability PI.  We've established a
           separate working group to work on that specifically. 
           Part of the problem that we have with this one is the
           fault exposure hours associated with an unknown as to
           when the initiating event was.
                       In other words, for example, you  may have
           an 18 month surveillance where the previous time you
           might have had an opportunity to identify that you had
           a problem would have been 18 months ago, and it's --
           using the standard T over two gives you nine months of
           fault exposure time, and on any diesel that's going to
           put you into rad.
                       And the consistency issue that we have
           here, and we discussed this with the subcommittee
           before, was a lot of times if you look at this demand
           failure, in other words, during the surveillance and
           you plug that into an SDP because of the chance for
           operator successes, because of the chance or
           opportunities for off-site power to be restored,
           you'll oftentimes get a green SDP finding on a red PI
           finding, and we recognize that as a consistency
                       Industry also has identified that, and
           this safety system unavailability group is working to
           develop a pilot PI that we would intend to begin
           piloting.  I believe it's in January, isn't it, Don? 
           Yes, January.
                       In the interim though, recognizing that
           there are some challenges, especially from a
           consistency standpoint, we're going to take interim
           steps where for any demand failure, such as the
           example I just gave, the diesel, that we would, in
           fact, use the SDP to determine the actual significance
           because it more closely ties it to risk significance
           as opposed to the counting of hours and the use of T
           over two, although T over 2 is pretty consistent from
           PRA and also in the ASP analysis.
                       But that is an interim step that we plan
           on taking until we can get -- and that interim step
           would continue throughout the piloting of the PI and
           until we would be able to develop a PI that would more
           accurately measure this unavailability issue.
                       MR. SIEBER:  If you continue to use T over
           two in the SDP process, would you --
                       MR. SATORIUS:  Yes.
                       MR. SIEBER:  -- not come up with the same
           result that you come up with out of the PI?
                       MR. SATORIUS:  No, you don't, and the
           reason is that the SDP takes a look at, and then Doug
           probably can talk to this better than I, but the SDP
           takes a look at other matters outside the simple
           counting of hours.  It looks at the ease or the
           ability of an operator to take compensatory action and
           how likely that is to be successful.  It takes a look
           at, for example, if you were to have a diesel that
           would fail 12 hours into its full power run.  If you
           were to have an actual scenario with a loss of off-
           site power, the chances for the recovery of off-site
           power within 12 hours are relatively high.
                       So you take that, coupled with the
           potential for operators to take  -- it gives you a
           better scenario and the SDP more accurately
           categorizes it or addresses it from a risk
                       MR. JOHNSON:  This is just another one of
           those advertisements that I'll try to throw in.  This,
           I think is one of the most substantial improvements to
           the ROP in the area of performance indicators that
           goes a long ways towards addressing a number of the
           concerns and the recommendations of the ACRS in the
           past in that I think at the end of the day what we
           will have in this revised SSU is something that is
           clearer, that does provide consistency in the use of
           the definition of unavailability.
                       We've got all of the right folks in this
           working group.  We're talking to the PRA folks.  We've
           got Research participating.  We've got the maintenance
           rule folks participating.  We've got a representative
           from INPO/WANO.
                       And so we'll have a standard definition of
           unavailability that will be used for this performance
           indicator.  And so when you apply this performance
           indicator, again, you'll have consistency.  It'll be
           easier for the operators, and it will get us to the
           right result.
                       And when you go to run through an SDP, a
           finding that would reflect an unavailability  for the
           PI, you'll end up at the same spot.  So that scratches
           a lot of itches, and so we think that's a very good
                       CHAIRMAN BONACA:  Yeah, sine you have
           performance indicators and you're moving to other
           issues, I would like to just ask a question regarding,
           again, one issue that has been brought up by this
           committee many times and our Chairman who is not here
           has raised this issue and I somewhat am representing
           his thoughts, too.
                       The fact that this PI is a known plant
           specific; they are generic.  Okay?  And you know, we
           went through an exercise yesterday, just some chatting
           about it, and for example, take the high pressure
           injection system, which is a significant system in all
           power plants because it's an element of LOCA
                       And you know, I can think of specifically
           a group of early C plants out there, like St. Lucie
           and Calvert Cliffs, known things, that have two high
           head pumps in that system, 50 gpm each, that provide
           very little floor, high head.  Therefore, those plants
           are vulnerable more than others to small break LOCAs
           because the pressure may hang up there, and you may
           not be able to add water in it.
                       I mean, that's a known thing technically,
           and in fact, the PRAs reflect the importance of that
           scenario in the risk, as well as the importance of
           that system for the plant.  Okay?
                       They also happen to be pretty limited in
           auxiliary feedwater.  So, therefore, you know, if you
           look at the PRA, it shows a very significant
           contribution, and you know, so here I have some very
           specific insight on the safety aspects of that plant
           tied to that system.
                       I also have the latest generation of
           Westinghouse plants like CBER.  With five I had
           injection pumps that provide, I believe, 375 gpm each,
           at the 2,300 psi.  Two of them are charging pumps. 
           Two of them are self-injection pumps.  One of them is
           a back-up.  They're interchangeable.
                       Tremendous capability up there, and
           clearly that shows in that the fact that small break
           LOCA is not a dominant sequence in those plants.  You
           know, these are the specifics.
                       Now, so if I really looked at getting
           insights from PRAs and from risk regarding these two
           things, I would treat the self-injection very
           differently for the St. Lucie type plant than I would
           call for this Westinghouse type plant.  They're
           telling me very different things.
                       I would set probably the thresholds in
           different locations.
                       I would also even put a multiplier maybe
           on the C type plant, given that the system is so
           fundamental, important for the plant, and yet if I
           look at the PIs, the way they are defined right now,
           they don't discriminate at all in that sense.
                       I mean we discussed this issue to death
           already, and they're not plant specific, and by the
           way, when I look at the question, number one, from the
           Commission that says if the PIs provide meaningful
           insight into aspects of plant operation that are
           important to safety, they don't provide insight at
                       And yet the PRAs are providing that
           insight right now that there is this strength for the
           Westinghouse type plants, and there is this weakness. 
           Let me call it that way.
                       And I wanted to provide this example
           simply because I think it's poignant in indicating how
           much more one could get from existing risk information
           from these plants that is not present in the current
                       DR. ROSEN:  let me before you answer that,
           Mark, take the same point from a slightly different
           angle.  What we really want to measure in these
           indicators is the overall risk of plant operation.
                       MR. SATORIUS:  Yes, I would agree.
                       DR. ROSEN:  And that's a hard job, but to
           pick out a few safety systems, high pressure
           injection, aux. feedwater, on-site power, et cetera,
           and say those are what we're going to measure makes
           them surrogates for this much more robust measure,
           which is a measure of the overall risk of plant
           operation.  They're a stand-in for something we really
           want to measure, which is the overall risk.
                       So Mario correctly points out that the
           real thing to base this on is the PRAs because it
           would get at the plant specific issues directly, and
           I say to follow that on that some plants are, in fact,
           doing that internally.  They have to participate in
           this process obviously, but some plants have risk
           monitors or risk indices that are based on their
           configuration risk management programs, which take in
           all of that stuff.  
                       More and more plants -- the plant I came
           from had one, but more and more plants now have them
           and are using them to good benefit, controlling their
           configuration risk.
                       I suggest that long term now and in your
           thinking moving towards replacing individual system
           unavailability measures with a more integrated measure
           based on the PRA gets to the thing we all want to
           measure, which is the overall risk of plant operation.
                       MR. JOHNSON:  Yeah, let me try to talk to
           that if I can.  I think what I hear and the direction
           that we're headed in is synced up.  I stopped short in
           my discussion of what we're doing with respect to the
           safety system unavailability PI to talk about the
           strongest piece of that enhancement that we are
           considering with the unavailability PIs, and that is
           the addition of reliability indicators that are a
           fallout of the risk based performance indicator
           program that Research worked on.
                       And when you have those performance
           indicators, well, what we'll do is we'll set plant
           specific thresholds, plant specific thresholds, and so
           what we'll look at is not a standard unavailability
           percentage or a standard liability percentage, but
           we'll look at a percentage that is based on a standard
           delta CDF, based on the change in reliability or
           change in unavailability.
                       And we're talking about doing that in the
           near term.  We're already working on the user -- we've
           had a number of conversations with Research.  They're
           tapped into this focus group that is working on
           unavailability improvement.  So we're headed in that
           direction in the near term, and that, I think,
           scratches that itch.
                       With respect to this longer term use of
           integrated indicator, I'll tell you right now the PIs
           that we have are surrogates.  They are indicative. 
           We've always said they would be indicative, and that's
           where we were when we started this program, and that's
           as far as we've been able to come.
                       Although if you look down the list of the
           things that we're asking for and the things that are
           on that risk based performance indicator task,
           development task that Research has briefed you on in
           the past, I know one of those things is an integrated
                       And so in the longer term, I think in the
           longer term there is some direction towards seeing if,
           in fact, there is a capability to add something like
                       Now, I think there's some philosophical
           things that we need to get beyond before we adopt
           something like that.  I think right now we're more
           comfortable given the limitations, given where we are
           in the development.  There is more comfort with this
           indicative approach, this selection of a few systems
           that are surrogates for the overall state of the
           performance of the plan, but that's certainly on our
           developmental longer range, the use of what it is
           you're suggesting.
                       So, I mean, I think this is a good area
           where we're actually moving in the direction that ACRS
           would indicate is a good direction for us with respect
           to the performance indicators.
                       DR. SHACK:  Let me take a slightly
           different approach that's different than my
           colleagues.  I mean, most of my colleagues look at
           this as sort of a gigantic risk meter, that you know,
           we clock in every once in a while, and I like that
           approach because it sort of gives you kind of a
           unifying thing.
                       Whereas I look at some of these
           performance indicators as surrogates for ways to
           measure things like safety, culture, and that, you
           know, even though my Westinghouse four loop plant
           could take lots of unavailability in the high pressure
           injection system, it's not a good sign that you don't
           keep the system up and operating.
                       And to my mind many of these indicators,
           you know, if I base them on risk, nothing will turn
           out to be safety significant.  You know, everything is
           unimportant until the accident happens, and there's
           some measure of attitude here that is kept in by
           looking at something that measures performance rather
           than risk.
                       But that leads to sort of fundamental
           problems and inconsistency because the significance
           determination process is risk informed, and yet some
           of the other PIs I can look at as measuring some other
           kind of parameter, and that leads me to logical
           inconsistencies, although I'm almost happier logically
           inconsistent than I am purely risk informed  at the
                       DR. POWERS:  I don't understand that. 
           What's the conceptual difference between the two?
                       CHAIRMAN BONACA:  Yeah, I really think
           that, no, the fact is that could be something that you
           could construe that if, in fact, you put the threshold
           so close to an expected performance, that you step
           over the bound because you're sloppy about it, right? 
           So you're measuring culture.
                       But you're not because you're putting the
           threshold far enough that you capture only certain
           cases where, you know, just you capture maybe one or
           two out of 100.  So the measure is --
                       DR. SHACK:  Well, some of these plants,
           and I set them on a consistent delta CDF for all
           plants, some plants would have enormous tolerance, and
           some plants would have much narrower ones.
                       CHAIRMAN BONACA:  The fact you have a
           question that says do they provide meaningful insights
           into aspects of plant operations that are important to
           safety, and you know, again, I don't think that you
           get insights on the culture from the PI because, I
           mean, you will see variations of that.  I mean,
           otherwise you would see some kind of grading
                       But certainly you do not get insights that
           you have from existing risk assessment tools regarding
           through the PIs.  I mean, you don't get those because
           they don't differentiate on what is important for the
           plant and set certain criteria on what is important
           for the plant.
                       In fact, I dare say that if you had a full
           understanding of that through PRAs, you may have
           different sets of PIs for different plants.  I mean,
           you could have that.
                       DR. ROSEN:  This is the old structuralist
           versus rationalist approach, and I'll come down in
           between, and I'll be a rationalist with structural
                       Really having a fully integrated risk
           unavailability or integrated risk monitor would be a
           very good thing, and I think you should work to it,
           but that's not throwing out the structural aspects,
           the points that Bill was making, that Shack was
                       CHAIRMAN BONACA:  No, I'm not throwing
           them out either.
                       DR. ROSEN:  Because we have a risk
           informed program here where we use risk to the extent
           we can, but we have to be thinking about the fact that
           the safety culture at the plant is a leading indicator
           of what these things are.
                       I mean the safety culture goes downhill
           before you ever see these numbers start to change.
                       CHAIRMAN BONACA:  Yeah, and in fact, you
           know, the inspectors have pointed out that if the
           thresholds are too far, they don't count enough to, in
           fact, identify trends like they should.  So they
           stated that actually the thresholds are allowed.
                       DR. SHACK:  But I think risk information,
           I think, will move you even further away from or at
           least that's my concern.  I don't know the --
                       DR. ROSEN:  I don't think so.  I think
           risk basically would move you further over, but risk
           informing swings you back.  It brings you back to the
           middle where it says we have to take into account the
           safety culture.
                       And I suggest that it's a timing
           difference, that the perfect plant has a great safety
           culture and very low numbers on its indicators, but
           when it begins to degrade, it degrades first in its
           culture and then the indicators begin to follow it,
           will begin to follow it because, in fact, the plant's
           hardware starts to reflect the degraded maintenance of
           whatever else.
                       MR. SIEBER:  But the emergence of a
           declining safety culture, which is a cross-cutting
           issue even though it shows up as indicators, the
           indicators respond, demonstrate perhaps a cross-
           cutting issue is involved because you've already built
           in a lot of latent defects.
                       And I think that that is part of Bill's
           concern.  You know, if you had ten -- if I had safety
           injection pumps and five diesel generators for a
           single unit, you would say that's pretty safe.
                       If you have a really lousy safety culture,
           probably half of the stuff doesn't work.  So I would
           just assume you look at individual competent declines.
                       DR. POWERS:  I wonder if you could speak
           to those performance indicators that usually aren't
           associated with any risk metrics, thinking of things
           like the safeguard performance indicators and whatnot,
           and in particular, I would appreciate it if you would
           speak to it in the context of providing -- whether
           those performance indicators provide meaningful
           insight and aspects of plant operation that are
           important to safety.
                       MR. JOHNSON:  Tom, why don't I let you
           start and then I'll add?
                       MR. HICKMAN:  Did you want me to start or
           you said you were going to start?
                       Okay.  The --
                       DR. POWERS:  This question was so easy he
           asked his chauffeur to answer it.
                       MR. HICKMAN:  Right.  The indicators in
           the other strategic performance areas are difficult to
           associate directly with risk, as you know, and so
           what --
                       DR. POWERS:  But I'm not asking you to
           associate them with risk.  I'm asking you to associate
           them with safety.
                       MR. HICKMAN:  Okay.  Well, I guess you
           could say the same thing interchangeably there.
                       They're associated with performance in
           those areas which have some sort of impact upon the
           safety at the plant, but it's hard to tie any kind of
           number with that, and that's the reason that those
           indicators don't have red response -- red bands.
                       What we've done in those areas is to use
           basically expert opinion to determine expert panel
           type of approach to determine when indicator values
           are to have reached a level where the NRC ought to
           step in and take action.
                       In establishing those thresholds, as I
           said, we did that with an expert panel, we confirmed
           those based upon the results of the pilot program, the
           six month pilot program and also the results of the
           initial historical data that was provided by all
           licensees prior to initial implementation.
                       And what we discovered was that the expert
           panel process worked very well, that, in fact, we had
           established levels that seemed to be very appropriate,
           first of all, at the green and white level for
           identifying outliers.  That seemed to work very well.
                       As far as the higher color categories,
           colored bands, as I say, we just have the yellow. 
           There's nor ed for those.  Again, that's based upon
           the expert panel opinion that those are the levels
           where we need to take increased action to prevent any
           further decline.
                       In some of those areas, of course,
           licensees have to maintain those programs, and so it's
           not acceptable to say, you know, the program is broken
           in that regard.  What we have to do is make the
           program work.
                       So at the yellow band level, the NRC will
           step in and take whatever action is necessary, whether
           it requires orders or anything, whatever it takes to
           make sure that the program works.  
                       That's the process behind the development
           of those thresholds.
                       DR. POWERS:  I think what I'm really
           asking you, if you could give me a thumbnail sketch of
           the rationale the experts use to arrive at the
           conclusion that there was some level where the NRC had
           to take increased action to make the program work.
                       MR. HICKMAN:  I'm not the expert in those
           areas, but I can tell you briefly what I know about
           what they did.  It was based primarily on their
           experience in the emergency preparedness area, for
                       They had a lot of experience with the
           number of drills that were being performed by
           licensees and the amount of participation that was
           involved in those.
                       Actually in that cornerstone or that --
           yeah, that cornerstone, we achieved, we think, quite
           a success because it caused licensees to do exactly
           what we wanted them to do, to run more drills and put
           more people in it.
                       And the thresholds were established based
           upon their experience, and they turned out to be very
           good, very close.
                       With regard to the other cornerstones, the
           performance indicators in the public radiation safety,
           for example, are not likely to be exceeded.  The
           industry has performed pretty well in those areas, and
           it would have to be a series of serious breakdowns at
           the plant for them to be exceeded, and those are what
           are used in the public radiation safety area.
                       The safeguards area, we still have some
           concerns about that, and we're still working on that,
           but the security performance index has worked well and
           has had some success in causing licensees to fix
           system that they had not paid much attention to in the
           past, although we're still working on that.  There's
           still a lot of concerns about the security equipment
           performance index.
                       And there's likewise concern about the
           other two indicators in that cornerstone.
                       DR. POWERS:  Can you give us a thumbnail
           sketch of what your concerns are?
                       MR. HICKMAN:  In the safeguards?
                       DR. POWERS:  Right.
                       MR. HICKMAN:  One concern, I think, was
           that the security equipment performance index was
           probably not worded quite right.  It claims to monitor
           the unavailability of the security equipment, and in
           fact, we don't really do that.  We look at the
           compensatory hours, guard postings in compensation for
           degraded equipment.
                       And so it doesn't really do what the words
           seem to imply that it does because we use a surrogate. 
           We posted guard hours as opposed to actual unavailable
           hours for the equipment.
                       That was done because it's easy for
           licensees to collect that data.  It's more difficult
           to keep track of the actual unavailable hours.
                       DR. POWERS:  I guess one of the questions
           that the licensee can legitimately ask is, "Gee, I've
           discovered I've got a piece of equipment," right? 
           Pieces of equipment break.  He discovers it Friday
           afternoon.  He does not have a replacement part.
                       He takes compensatory action for it. 
           Everybody agrees that it's compensatory action, and
           yet he has -- he gets a degradation of this while he's
           waiting for a weekend to get over, and then on Monday
           he can call and get the replacement part that he
                       Why should that be a degraded action?  It
           seems to me that's a victory for him.  I mean, he
           should get a gold star put next to his name on that
                       MR. HICKMAN:  We've heard that type of
           comment, actually maybe even a little more intrusive
           into licensee performance, the case where that happens
           and they have the part, but they don't want to have to
           call the tech. in on the weekend and pay them extra
           money to fix it when they can fix it on Monday, and
           that issue has been raised by licensees a number of
                       I guess the answer to that is that the
           threshold is set high enough to accommodate some of
           that type of activity.  Plus, there are exemptions in
           the indicator.  There is a blanket exemption  for
           preventive maintenance.
                       So we're encouraging them to fix the
           problems before they break and you won't count those
           at all. But there is allowance.  The threshold is at
           eight percent.  So there's a certain amount of that
           kind of problem that can occur, and it still won't
           cross the threshold.
                       MR. JOHNSON:  Yeah.  I mean, I think John
           has given the answer that I wish I would have been
           able to give right off the cuff, but that's why I rely
           on Don.
                       Two points that Don made that are really
           key.  One is if you talk to NEI and ask them about
           performance indicators that are working well, they'll
           point to the EP performance indicators and they'll
           talk in some cases about this security equipment
           performance index, and it's because of what Don said,
           and it is causing licensees to take actions in areas
           to address performance problems that really ought to
           be addressed.
                       With respect to EP, in fact, if you have
           problems, adverse trends in your performance, if
           you're not, in fact -- and you want to improve that
           performance, if you want to improve your participation
           and improve your drill performance, what do you do? 
           You run more drill sand you perform better at those
                       And that's what we want with respect to
           performance indicators, and in fact, we've found
           instances where plants were not performing as they
           should have been performing with respect to EP.
                       Just to take you back on it, the second
           point I'll make is remember the development.  The
           development was we said what are the cornerstones;
           what's the important information that we need about
           those cornerstones; and so what can we get from
           performance indicators; what can we not get from
           performance indicators?  So we need to do baseline
           inspection, and so remember performance indicators are
           only a piece.
                       But there is a nexus.  In fact, the
           performance indicators, we believe, do have face
           validity in that they do tie back to giving us
           insights on those key attributes that we need to
           measure in each of the cornerstone areas.
                       And so as Don points out, we need to do
           more with both, with the security equipment
           performance index.  With 7355 rulemaking, we know
           we're going to need to go back and look at those
           safeguards performance indicators, to improve them, to
           make them more consistent conceivably with how that
           rulemaking comes out.  So we know we've got some work
           to do.
                       But those performance indicators also give
           us good insights in an indicative kind of way with
           respect to performance of the plant in those
                       MR. SIEBER:  Every indicator refers to one
           of the seven cornerstones in the framework.  I presume
           unplanned power change is initiating event
                       MR. SATORIUS:  Yes, it is.
                       MR. SIEBER:  Is an unplanned power change
           risk significant at all?
                       We used to change power to reduce
           radiation dose so we could have containment entry.  Is
           that a risk?
                       MR. HICKMAN:  Do you want me to answer
                       MR. SATORIUS:  Yeah, go ahead.
                       MR. JOHNSON:  Why don't you take that?
                       MR. HICKMAN:  No.  In fact, we say in the
           guidance document, in 99-02 that unplanned power
           changes in themselves are not risk significant, but
           under other circumstances, they could lead to risk
           significant events.
                       The reason that the staff is interested in
           unplanned power changes is because historically we
           have noted a relationship between plants that are
           constantly going up and down in power and the plants
           that in previous assessment process we identified as
           poor performers or watch list plants or declining
           trend plants.
                       And we've seen the plants that tend to run
           steady state are also safer plants.
                       What we're counting, that indicators, not
           just any power change, but it has to exceed 20
           percent.  So for smaller power changes, we don't pay
           attention to those, but we're counting those that
           exceed 20 percent of full power.
                       MR. SATORIUS:  I might add to that the
           scram PI falls into that same category, that it's
           traditionally a PI that under previous assessment --
                       MR. SIEBER:  It's not risk significant.
                       MR. SATORIUS:  Right, but it matches up in
           the past that plants that are scramming at lot, the
           same as plants that are up and down a lot in the past
           assessment process had tended to be poor performers.
                       MR. HICKMAN:  And one other important
           thing there is.  The threshold is high on that
           indicator.  We understand that there's going to be
           some of that, and we allow for that.
                       MR. SIEBER:  Well, I worked at a plant
           once that did load following, believe it or not.  Are
           they exempt from this PI?
                       MR. HICKMAN:  Yes.  There are a number of
           exemptions, and that's one.
                       MR. SIEBER:  Okay.
                       MR. JOHNSON:  You'll find that discussion
           in 007.  We do a pretty good job of laying out why we
           chose, for example, the unplanned power changes, and
           it goes to what Don said.
                       MR. SATORIUS:  I'm going to go ahead and
           go to the next slide, and didn't have a lot that we
           had intended to discuss at least in this presentation
           on assessment.  The first bullet, I think, ties into
           the discussion we had just had under PIs, and that has
           to do with, you know, consistent responses to PIs and
           inspection issues and our endeavors to assure that the
           information we're gathering through the PI process is
           consistent with the system that we're using to
           evaluate safety and risk significance with inspection
           findings., especially the disconnect or the potential
           for the disconnect where you may have, because of
           fault exposure hours, had a PI that goes red and at
           the same time if it had been an inspection finding and
           there was an SDP associated with it, it would more
           than likely be green.
                       So we've identified that.  We're working
           towards that through the safety system unavailability
           working group, and as I had mentioned, in the interim
           we intend on for demand failures within the PI arena
           to use an SDP to analyze that risk significance and
           apply a color.
                       The second thing we wanted to discuss real
           quickly was an issue involving no color findings.. 
           When we briefed the subcommittee, I believe it might
           have been in May.  We went through our rationale for
           no color findings, and my recollection, there was
           quite a bit of dialogue because for us to explain to
           the subcommittee our bases for no color findings and
           where did they fall, are they in between green and
           white, are they less than green, and we've kind of
           concluded based somewhat on our interaction with the
           subcommittee at that time and also with some
           interaction that we've had, I guess, primarily with
           some other offices within the headquarters and also
           with the regions that it just confuses matters.
                       MR. SIEBER:  It certainly does.
                       MR. SATORIUS:  You know, I've heard
           anecdotally that no color to some folks made no sense,
           and for the guy walking down the street, you ask him
           and if I tell you I have four color and something
           called no color, where would you plug that in?
                       So we concluded that the best approach
           here would be to just call these matters green and go
           on, and so that's the direction we're headed on that.
                       MR. SIEBER:  Well, that's one element of
           at least the public confusion that the color system
           has, you know.  You have green, white, yellow, red,
           and then you have a different color, which I think is
                       MR. SATORIUS:  It is gray.  It is gray if
           you go to the Web site.
                       MR. SIEBER:  If you didn't inspect them at
           all, and there's a pink or magenta color that says I
           inspected it, but didn't have any findings.
                       And so when you look at this you need to,
           as my computer has it, 256 colors to be able to figure
           out what's going on.
                       MR. SATORIUS:  And we recognize that, and
           it's going to require some procedural changes because
           in the past by colorizing an inspection finding, that
           suggested it passed through an ADP, and these no color
           findings are traditionally issues that may fall within
           traditional enforcement or do not fit within an SDP,
           and we need to change our guidance to reflect that.
                       But we think that the better view here is
           just to call them green.
                       MR. SIEBER:  Good.
                       MR. SATORIUS:  It makes sense.
                       MR. SIEBER:  I think another element of
           potential public confusion is that people generally
           associate green with good, whereas green is not good. 
           It's bad because now you've actually found something
           that has to go into the corrective action system.
                       DR. WALLIS:  Green one is good.
                       MR. SIEBER:  I think that the purple,
           magenta, pink is the best.
                       DR. POWERS:  I think there's some
           advantages to being color blind because the more
           appropriate thing is that these no color findings are
           within the licensee response band, and I mean, that's
           the definition, and that's what you intend, and
           everything else seems to make sense to me.
                       MR. JOHNSON:  That's exactly right. 
           That's what we're doing, is we're saying those are
           licensee response band findings.
                       I can't not react to your green is good or
           whatever.  You know, with respect to a performance
           indicator, as Graham is pointing out --
                       MR. SIEBER:  Green is good.
                       MR. JOHNSON:  -- green is okay.  If you
           have green, if you're in the green band with respect
           to scrams --
                       MR. SIEBER:  But we're talking about
           findings here.
                       MR. JOHNSON:  -- that's a -- but if we're
           talking about findings and we're talking about
           everything that we find that is a green needs to go
           into licensee's corrective action program, and so
           there is that sort of difference in the explanation
           that we've tried to be careful to make, and we
           continue to have to live with based on the scheme that
           we've set up.
                       MR. SATORIUS:  Okay.  Doug, you're up
                       MR. COE:  SDP is a first up.  The SDP has,
           I think, been acknowledged by man as one of the more
           significant differences in the new program versus the
           old program, and it was born of a need to address the
           concerns of our stakeholders that we be more
           consistent and more objective across the nation,
           across the different regions and across time with our
           assessments of performance.
                       And so given that we have seven
           cornerstones, some of which are amenable to a risk
           kind of evaluation and some are not, the overriding
           objective for the SDP is one of objectivity and
                       In the implementation in the first year of
           the SDP processes, we have had some issues come up
           that we know that we need to deal with, and we are
           dealing with them.  The first here, as indicated, is
           that we need to do a better job of being more clear
           about the assumptions that we are using to exercise
           the SDP logic, be that in the risk informed SDPs or in
           the others.
                       In any case, it was always our intent that
           our basis for our decisions be clear, more clear than
           they had been in the past, and so we do need to do a
           better job of in some cases documenting the
           assumptions that we use.
                       The other thing that has become a
           significant issue for us is timeliness.  A recent
           audit that was performed based on the 20 issues that
           have been brought to our headquarters panel between
           April of 2000 and February of this year indicated that
           the average time from the exit meeting to the final
           panel results was about 98 days, and as you're aware,
           I'm sure, the Commission has pretty much mandated that
           we set a goal for ourselves of 90 days absolute. 
           That's not on the average.  That's not a median. 
           That's absolute.
                       So we have a good deal of work to do to
           improve the timeliness aspect, which certainly is our
           intent because it needs to support the assessment
           process, which is conducted on essentially a quarterly
           basis, if not a continuous basis in some respects.
                       DR. POWERS:  So then your objectivity
           criterion for this, you've done an internal assessment
           and an external assessment.  You're getting yourselves
           real high scores on that objectivity?
                       MR. COE:  Well, I would say that relative
           to the previous program, yes.
                       DR. POWERS:  Yeah, relative to the
           previous program, right.
                       MR. COE:  Relative to the previous
           program, I think, clearly the use of risk metrics, for
           one, sa a means of achieving greater consistency from
           plant to plant, from region to region, and from time
           period to time period is certainly giving us a better
           and more visible yardstick of measurement than when we
           had in the past, which was essentially a more
           subjective SALP criteria process.
                       And the point that was made earlier is a
           valid one, that the non-risk informed cornerstones,
           the ones that are not amenable to the use of risk
           analysis directly, we have to make judgments regarding
           the responsiveness or the level of engagement that we
           would expect to have and seek to measure that or to
           grade that in a way that remains consistent with the
           other cornerstones, the risk informed cornerstones.
                       So from the standpoint of objectivity, I
           think being clear about our decision logic and
           employing the same decision logic from issue to issue
           as we encounter across the regions and across time, I
           would have to say -- and I think we said this in SECY
           01-114 -- that we have achieved a greater objectivity.
                       We also have continuing challenges in the
           risk informed arena to continue to improve the Phase
           2 notebooks which are the primary implementing tool
           that is in the hands of the inspectors and is intended
           to provide them with the ability to improve their
           understanding of the risk drivers at their plants on
           a plant specific basis and to make an initial
           screening kind of assessment of the potential risk
           significance of the findings that they may come up
                       We are continuing to --
                       DR. POWERS:  Do all plants have Phase 2
                       MR. COE:  We have -- all plants will have
           Phase 2 notebooks issued in Rev. 0 form, we think, by
           the end of September.  We have the last three that
           Brookhaven completed for us.  We've reviewed, and it
           remains for them to complete revising them in
           accordance with our comments, delivering them to us so
           that we can put them out via letter and then to the
           Web page.
                       DR. POWERS:  I'm not sure what phase zero
           or whatever it is you called the format means.
                       MR. JOHNSON:  You referred to a Rev. 0.
                       MR. COE:  Revision 0 is the first official
           issuance of the Phase 2 notebooks for each plant or
           each plant type, and you know, we expect that there
           will be further revisions.  We know that there will be
           because as we have issued Rev. 0 and have gone out to
           do benchmarking against the plant's own internal PRA
           analysis, we are finding that we need to have some
           changes made in order for the notebook to better
           represent that plant's design and operation.
                       DR. POWERS:  At what point will you be
           able to say all plants have these sheets that have
           been benchmarked?
                       MR. COE:  Well, we've only been able to
           complete about eight benchmarking trips, I believe,
           this year, fiscal year, but we are budgeted to
           continue that process next year.
                       The short answer to your question is I
           think it will take us into probably fiscal '03 to
           present all plants at the current rate.
                       DR. POWERS:  Is it a case of if you had
           twice the budget you could do it twice as fast, or is
           this nine women can't make a child in one month sort
           of situation?
                       MR. COE:  Certainly I've been told that
           having a greater amount of money would improve -- we
           could accelerate the rate at which we do these
           benchmarking trips.  However, you would eventually be
           limited by the staffing.  Okay?  We have to have the
           right people out there.
                       Typically we invite and get the senior
           reactor analyst in each region to participate in
           these.  We think that's valuable for them as well, and
           I think that's pretty much been the case for the ones
           that we've done so far.
                       So, yes, we could accelerate it with
           greater funding, but there would be a natural limit. 
           I'm not sure exactly what that limit would be.
                       MR. SIEBER:  It's my understanding that
           you don't have an operable SPAR model for every unit. 
           Is that true?
                       MR. COE:  SPAR models are also under
           development, and I don't know exactly where we stand,
           but the recent, most recent development program
           estimates given the budget and the funding that have
           been asked for, but maybe not entirely approved yet,
           would have us completing all of the SPAR models out
           some time in fiscal '04, I believe.
                       MR. JOHNSON:  And that's SPAR-3, I think.
                       I was actually looking for Steve Mays and
           he's not around.  Tom, do you have?
                       MR. BOYCE:  Forty-three SPAR models have
           been developed so far.  Seventy are supposed to be
           completed by the end of FY '02.
                       MR. JOHNSON:  You've got to go to the mic. 
           And give you name and then --
                       MR. BOYCE:  Tom Boyce in the Inspection
           Program Branch.
                       I'm going to try and relate the status
           that Research really should be telling you, but Steve
           Mays did just depart, and the most recent data that
           I've heard is that 43 SPAR models have been completed
           out or 70 total.  The remaining will be completed in
           FY '02.  They also have to go through a benchmarking
           process, and only on the order of five have been
           benchmarked up to this point.
                       They're doing them in conjunction with the
           SDP Phase 2 notebooks where possible using the SRAs in
           the regions.
                       DR. POWERS:  No one has ever --
                       MR. BOYCE:  That process takes time.
                       MR. SIEBER:  Well, let me follow up my
           thought.  The last number I heard was 37, but that was
           a couple of months ago.  So you've made progress, but
           if you lack a functional SPAR model and you don't have
           a Phase 2 notebook, how do you do significance
           determination?  Are you relying on the licensee?
                       MR. COE:  In many cases we will ask the
           licensee for an analysis and we will review that
           analysis, but I would hasten to add that, you know,
           the Phase 2 notebooks are out there as high level
           representations.  They lack the details of the SPAR
                       MR. SIEBER:  Well, it's screening, right? 
           The purpose is screening and to knock out the
           nonsignificant stuff at the local level.
                       MR. COE:  It's screening, but even in the
           final revision, even after we've done the
           benchmarking, you know, the intent is that the
           notebooks provide essentially an opening assessment,
           an initial opening assessment of what we believe the
           risk significance might be for a finding.
                       That can certainly be modified as better
           information is made available to us, but in many cases
           we're finding that the inputs that we make to the
           licensee's models are being reflected properly in the
           notebooks, in the use of the SDP Phase 2 level
                       MR. JOHNSON:  I guess I get a little
           nervous about our answers that we're giving that
           research ought to be more appropriately given.  Keep
           in mind that research does ASP analyses on any plant,
           every plant based on the SPAR-2 model, and we're
           talking about the SPAR-3 model, and --
                       MR. SIEBER:  Well, that goes back to the
           senior reactor analyst, the SPAR-3, right?
                       MR. JOHNSON:  So I guess the point I want
           to make is don't -- if you have continuing questions
           on where we are with respect to SPAR models, and some
           of the agencies' priorities are changing based on
           direction from the Commission, as you're probably well
           aware, with respect to that, I'd ask that you hear
           from research and not my group on the final answer.
                       MR. SIEBER:  I guess the bottom line of my
           last two questions is if you don't have a Phase 2
           notebook, you don't have a Phase 3 SPAR model, then
           you may be in a weak position with regard to dealing
           with the licensee because you're relying on the
           licensee's information
                       MR. COE:  I think one of the advantages of
           what we're doing with the use of risk analysis in the
           SDP though is to avoid this issue of my model is
           better than your model.
                       MR. SIEBER:  Right.
                       MR. COE:  What we're trying to do, and
           it's been my observation over the past six or seven
           years that I've been engaged in the risk analysis
           business that the primary impediment to furthering the
           use of risk analysis in this agency, and many others
           perhaps, is one of communication, and if nothing else,
           the SDP process should be helping us open up the
           methodologies, the analytics, the assumptions of a
           risk analysis and make them more apparent and more
           visible to a wider number of stakeholders, principally
           those who are closer to the plant, to the physical
           realities, to the physical design, to the physical
           operation of a plant who can either, therefore, accept
           or challenge those assumptions, that logic that goes
           into this analysis, which produces a result that we
           act upon.
                       And so I think that although we're in our
           initial stages of improving our ability to communicate
           with each other and with our licensees and with our
           public, we are progressing in that direction.  At
           least at the moment, I think we are, and I do hope to
           avoid the situation that you've just articulated.
                       MR. SIEBER:  Well, one of the interesting
           things is to my knowledge, there's no regulation that
           requires a licensee to have a current PRA.
                       MR. COE:  That's true.
                       MR. SIEBER:  And so it's possible you
           could run into a situation where you don't have the
           information and the licensee doesn't have the
           information, and the process to me becomes pretty
                       And while you're in the process of coming
           up with a decision as to what color a particular
           finding is through SDP, it becomes invisible to the
           public as to how you got there.
                       DR. ROSEN:  You see, Jack, that's the
           point of having a good SPAR model or good Phase 2
           notebooks.  For the case where the licensee is very
           weak in his own PRA development, I think that's a very
           useful and necessary thing for the staff to have.
                       On the other end of the spectrum though,
           with a licensee with a very robust PRA that's highly
           documented and very open, why does the staff even need
           these Phase 2 notebooks and SDPs?
                       The right answer, it seems to me is when
           a plant like that has an incident or a finding, you go
           to their PRA staff, sit down, and at a clean table
           discuss how the risk analysis would evaluate the
           circumstances and come to some kind of joint
           conclusion that both sides can support.
                       I've seen that process work at the place
           I used to work at, and I think that's superior to your
           model versus my model.  There's only one model.  It's
           either right or wrong, and both people have access to
                       MR. SIEBER:  I think for public
           confidence --
                       DR. POWERS:  PRA is just not at that stage
           yet, and there can be two, three, four dozens of
           models of a plant which are equally right.  PRA is
           just not an exact science yet.
                       DR. ROSEN:  I didn't say it was an exact
           science.  I just said that having one model that both
           sides, the regulator and the licensee, can agree is
           the best shot at what's right and evaluating a given
           set of circumstances using that model is, it seems to
           me, the way to go rather than one side having some
           kind of little simplified model and the other side an
           advanced model.
                       DR. KRESS:  I think that there are
           regulatory uses for these things that you wouldn't
           want the staff to have to run to the licensee every
           time they wanted to do some sort of risk
           determination.  So I think there's good reasons for
           the staff to have their own models.
                       MR. SIEBER:  I think so, too, public
                       DR. POWERS:  Just the capability that the
           staff has when they have their own model is what's
           worth the investment.
                       MR. JOHNSON:  Yeah, we're fully supportive
           of the agency's continued SPAR-3 development, and in
           fact, even though I don't speak for our office with
           respect to the priority and certainly not the research
           in terms of the agency's priority on SPAR, we
           recognize that it's the way we want to go because we
           don't want to be overly reliant on licensees.
                       As Doug indicated, and in fact, I missed
           some of the conversation, but I wanted to make one
           last point, and that is, you know, there are two
           opportunities for us to reconcile the significance of
           findings for the SDP.  One is through the SDP process
           itself in our Phase 2 and Phase 3 analysis, and then
           we provide that information in terms of preliminary
           analysis to the licensee, and the licensee runs their
           model, and we reconcile where we ought to be based on
           the input that we get from the licensee.
                       But we have a second opportunity, and that
           is through the use of the ASP program, and in fact,
           research checks each of the analyses that we do where
           we have a greater than -- in fact, a greater than
           green finding.  They'll compare what they come out
           with respect to the ASP, as part of the ASP program,
           of course, they do the analysis using our models, and
           then they share with the licensee and they get
           licensee input.
                       And so we reconcile those differences and
           look for holes or areas with respect to the Phase 2
           work sheets or the process that we have that may be
           causing those holes.
                       So there are a couple of opportunities and
           a number of exchanges with us and licensees, but I do
           not want you to leave here with the perspective that
           we feel like we're overly reliant on licensee models
           because that's just not the case.
                       Having said that though, we do think that
           SPAR-3 development ought t continue.
                       DR. WALLIS:  Could you explain to me what
           a Phase 2 notebook is?  Is this Phase 2 notebook the
           paper document with all kinds of check marks, or is it
           a computer into which you can put various information
           and reach conclusions based on some software?
                       MR. COE:  No, it's the former.
                       DR. WALLIS:  And eventually it should
           hopefully be something like the latter.
                       MR. COE:  There's thought being given to
           creating a user interface to the SPAR models that look
           very similar to, you know, the way that the analysis
           was represented in the Phase 2 notebooks.
                       One of my principal concerns from the very
           start has been that it's often too easy for inspectors
           in the field to pass their findings off to
           specialists, risk analysts, and if they don't engage
           themselves in the process in some form of risk
           analysis, they tend not to understand the results of
           the specialists.
                       And so one of the distinct advantages of
           a Level 2-like approach for risk analysis is that it
           helps the inspectors understand both the benefits and
           the limitations of a risk analysis, and it gives them
           the opportunity to explore sensitivities of various
           assumptions that they are in control of, and rather
           than let an analyst be in control of the assumptions
           and the logic that tend to drive the results, this
           puts this information and the ability to manipulate
           those assumptions and that logic in the hands of the
           people who will then, you know, presumably have an
           opportunity to accept greater ownership of the end
                       So, I mean, in fact, one of the questions
           that the committee might wish to consider in terms of
           your letter would be whether or not a three phase kind
           of approach for the risk informed SDP is worth our
           continuing development.  In other words, you know, one
           of the options we had was to simply have all of our
           inspection findings sent off to an army of risk
                       That didn't necessarily help the inspector
           better understand or guide their future inspection
           activities, nor did it allow for a greater population
           of individuals who were closest to the plant to
           participate in achieving either acceptance or being
           able to challenge the various assumptions that were
           being used.
                       DR. POWERS:  It seems to me that one of
           your biggest headaches that I would worry about in the
           future -- I don't know that you have it -- I would
           worry about in the future is the frustration of the
           inspector seeing things and not seeing anything come
           about it.
                       I mean, right now already he's in the
           position of finding things that don't even go into --
           well, I guess they allow him to write on a report now,
           but they don't seem to go anywhere, and you get this
           problem of what good am I doing here, the thing I have
           to do.
                       And similarly, sending things off to an
           army of analysts only makes that problem worse, it
           seems to me.  I mean I think you've got a real morale
           problem brewing among your inspectors if they continue
           to get isolated as a cog in this system that you've
           set up.
                       MR. COE:  Exactly, and I feel the same
           way.  My emphasis has been from the start, has been to
           give the inspector the tools that they could use to
           find the most significant issues that might exist at
           any given site.  
                       Now, admittedly, using the risk method
           that we're using for reactor safety issues, you could
           arguably say that we've set the bar higher because
           there is a definite objective bar that has to be met,
           and the attendant basis that we have to provide to our
           stakeholders to say that we've met that limit or that
           threshold to carry an issue forward into a greater
           than very low significance manner, apply it in that
                       But in addition to setting that bar
           higher, we've given the inspectors the tools to help
           them see how issues might get to that point, and in
           the ultimate analysis, I believe that that's risk
           informing  our inspectors.
                       So, again, I think if you have thoughts on
           that, you know, because there are multiple ways of
           pursuing a risk based estimate.
                       DR. POWERS:  Well, I mean, anything that
           leads to the inspectors understanding that they are
           essential and that, in fact, their role has been
           upgraded, not downgraded, is to my mind the way to go.
                       MR. COE:  Precisely, and I would agree.
                       Next I would just offer that we are
           continuing development work in the areas of shutdown
           SDP, which is kind of at a Phase 1 screening checklist
           level at the moment, trying to develop some Phase 2
           kind of sequence based tools.
                       Containment which has always been kind of
           a place holder in our current program based on some
           work that research has done for us, and we need to
           carry that work forward and produce a more usable
           tool, and in the fire area, of course, which we've
           talked about at some length before, and we all
           recognize the nature of fire analysis, risk analysis,
           is probably one of the more difficult for us to
                       DR. POWERS:  I would like to pursue fire
           just a little bit.
                       Go ahead, Jack.
                       MR. SIEBER:  Well, I was just going to
           comment on that.  When I look at the SDP process for
           fire, it is so simplified that it appears to me to be
           pretty subjective, to say the least.  I mean, you've
           got a choice of three.  It's really bad; it's not too
           bad; or it pretty good.
                       DR. POWERS:  That's the part of the SDP
           that I just do not understand at all, is that we have
           this rather mysterious set of numbers that I actually
           think I know where they came from.  I'd love to hear
           somebody defend them, but be that as it may, how I
           select which number to use seems to be totally up to
           whether I'm a buddy with a guy that I'm inspecting or
                       MR. COE:  Well, I would certainly say that
           we have acknowledged the need to be more specific
           about how to characterize the various classes of the
           parameters that we use as inputs to that fire
           analysis.  One very important one that tends to
           influence it a lot, influence the outcome a lot is the
           performance of the fire brigade, and we've
           acknowledged that there's a need to clarify that
           guidance so that it's more consistent.
                       And I can't explain exactly where each of
           the numbers came from, but what I can tell you is at
           a high level, the fire protection SDP as reflected in
           Appendix F of our guidance document 06-09 is
           essentially attempting to have about the same level of
           detail that the reactor safety Phase 2 SDP has tried
           to hit, and in fact, it's linked to the reactor safety
           Phase 2 SDP.
                       But what we're really trying to do across
           the board, across all of these risk informed SDPs is
           to de-emphasize the numerics and emphasize further the
           choices that historically and traditionally have been
           made by risk analysts and to put the thinking, the
           judgment of choosing those various assumptions more
           directly into the hands of the inspector.
                       DR. POWERS:  How do I decide that
           something is low, middle degradation or high
           degradation?  I mean, explain to me how I pick that
           number other than the fact that this guy's a good
           buddy of mine.  I know he's doing the right thing
           versus this guy is a penny-pinching, cost cutting
           dude.  I'm sure that he will not do the right thing.
                       MR. COE:  Well, first of all, I do have a
           greater confidence in our inspection staff that they
           wouldn't lose their objectivity in that manner, but
           that doesn't mean that we can't improve that 
                       You're absolutely right.  I mean, there is
           a need to be better and more consistent, I should say,
           in terms of making sure that one inspector will judge
           a particular condition that they see in the same
           fashion as any other inspector in another region or
           across time.
                       DR. POWERS:  If that's your objective,
           that's a good one.
                       MR. COE:  It is.
                       MR. SIEBER:  I think there ought to be
           another one, too, that whatever the outcome is,
           whatever the color of the finding is ought to reflect
           true risk significance potential for fire because that
           is a prominent actor in reactor safety.
                       DR. POWERS:  I mean, your priority on
           fires has gone way up based on the IPEEE insights to
           my mind.
                       Now, let's go to the numbers in the SDP. 
           I assume they come out of five.  That's my guess.
                       MR. COE:  And now you've just gone beyond
           my level of expertise.
                       MR. JOHNSON:  We, in fact -- Matt, I can't
           remember what briefing it was, which of the briefings
           it was where we talked specifically about --
                       DR. POWERS:  The one I was not at.
                       MR. JOHNSON:  Yeah, it was the one you
           weren't at, but I guess what I would offer is if you
           do have some detailed questions, Dana, that we don't
           have the right folks where to deal with that.  At that
           earlier briefing we had the branch chief and the
           section chief and we had the guy who implements the
           SDP for us now, and in fact, we had the guy who
           developed the fire protection SDP, and those are
           really the guys who ought to be answering your
           detailed questions, I think.
                       CHAIRMAN BONACA:  I had a question.
                       DR. POWERS:  The question is very simple,
           and it explicitly addresses what the Commission has
           asked.  It's asked do these have any relationship to
           safety, and so the question is very simple.  What do
           the numbers coming out of five have to do with fire
           risk.  Why those numbers and not some other numbers?
                       MR. COE:  Well, I can tell you that one of
           the significant issues that's being dealt with right
           now is the issue of fire initiation frequency because
           that does vary, and that does tend to be a significant
                       And from the standpoint, you  know, of
           what does this mean and how does it relate to safety,
           you know, again, we're still using the same risk
           metric, and it all boils down to whether or not the
           assumptions and the logic that you're using to arrive
           at your metric -- how well that comports to the actual
           plant design, the deficiencies that you found, and the
           way that that plant is operated.
                       So, again, doing a better job of defining
           how to use the fire initiation frequencies and what
           values are most appropriate for various situations,
           how we define the levels of degradation  for fire
           barriers, for the fire brigade performance, and making
           that more consistent from inspector to inspector is
           really our intent.
                       And what we believe is that the closer we
           get to establishing that those inputs most accurately
           reflect the plant's condition gives us greater and
           greater confidence over time that that risk output,
           that metric is reflective on a comparative basis from
           issue to issue across different plants so that we can
           grade our inspection responses accordingly.
                       DR. POWERS:  Are you thinking not
           necessarily in the next three years or four years, but
           maybe longer term, and I'm not going to define what
           longer term is, but it's beyond 2003.  I'll tell you
           that -- to have the equivalent of a SPAR for fire or
           other external events?
                       MR. COE:  The current SPAR development
           plan speaks of external initiating event models, but
           doesn't, under the current budget forecasts, doesn't
           really begin to really get started with that until I
           believe it's fiscal '03 or '04.
                       DR. POWERS:  Well, I mean, that's pretty
           soon.  I mean, that's more encouraging than I would
           have thought.
                       MR. JOHNSON:  Again, you're asking a
           question that really is better answered by Research,
           I think.
                       DR. POWERS:  You guys are on the hook. 
           You can't get out of it that easy.
                       CHAIRMAN BONACA:  I have a question on a
           separate issue.  It's more for information.  I can't
                       If you have risk informed PI, say,
           something that we discussed before safety injection,
           and it goes from your green to, say, white or yellow,
           do you perform a significance determination evaluation
           of that?
                       MR. JOHNSON:  No, we don't.
                       CHAIRMAN BONACA:  But if you did, that
           would blend the criticism we are making of not being
           plant specific because what you would do, you would
           then use PRA to evaluate the significance of that, and
           therefore you'd absorb the blend of criticism that we
           are leveling on the process.
                       MR. JOHNSON:  I actually answered too
           quickly.  What I should have said was -- I think we're
           rushing to correct my answer -- what I really should
           have said was that in general the PI program is set
           with thresholds, and crossing those thresholds alone
           is enough to enter the action matrix.  So if you have
           a white, then you do what the action matrix would
                       But there are a number of cases where
           nothing would prohibit, for example, an inspector from
           running a performance issue that happens to be also
           reflected in the PI through the SDP to determine the
           significance, and we've had a number of instances like
           that where we have -- in fact, we're working on one
           right now that is a PI reporting issue that would have
           if the licensee reported it in a certain way that PI
           would be red, but we know that when we run that issue
           through the SDP, it's actually a white issue,
           potentially a green issue, and it deals with this
           issue of false exposure for demand failure that Mark
           talked about.
                       So in fact, probably the more accurate
           answer to your question is that, yes, inspectors can
           run a performance issue, any performance issue,
           through the SDP to determine its significance.
                       MR. SIEBER:  Well, if you get into a
           degraded performance indicator, that calls for
           additional inspection.  The additional inspection can
           or may not result in findings.  Findings are run
           through SDP.  So you end up having a risk input to
           everything that start out as a performance issue.
                       CHAIRMAN BONACA:  No, I'm focusing only on
           the PI.  What it means is that if you said, okay, I
           have a PI and now it's gone from green to yellow, say,
           and I'm going to run it through the significance
           determination process, which essentially relies on a
           plant specific PRA.  Then all of the criticism we have
           been leveling on the process will be eliminated
           because you will have an opportunity to evaluate after
           the fact, okay, whether or not it's significant, and
           you would treat it like anything else that you treat
           by significance.
                       MR. JOHNSON:  I would say that the safety
           system unavailability working group that we've
           empaneled acknowledges that and recognizes the
           problems that we have with fault exposure hours not
           being plant specific, being more generic in nature,
           the PI itself being generic in nature.
                       And we are working towards developing an
           unavailability PI that I think I indicated earlier we
           would want to pilot starting in January.
                       But in the interim, we've done, I think
           exactly what you've just described, and that is for
           those PIs, safety system unavailability PIs where
           there's a demand failure, we would run it through the
           SDP, and we would tie it more closely to actual risk,
           rather than just using a generic counting of the
           hours, so to speak.
                       CHAIRMAN BONACA:  Absolutely.  I mean, at
           the beginning you use the reference system as you have
           right now, and then you filter it through a process
           where a plant specific PRA is being used to make a
           judgment on the significance of that.
                       That would, in my judgment, you know,
           address all the concerns we have raised.
                       MR. JOHNSON:  And that's a short-term fix,
           right.  That's a short-term fix that we're going to
           implement on -- we're hoping to implement by the first
           of January.  So we're pleased to hear that ACRS is
           pleased with the approach we're talking.
                       MR. SIEBER:  Well, okay.  I guess that --
                       DR. POWERS:  He's really gotten smooth
           over the years.
                       MR. SIEBER:  I guess that the ultimate
           action that the staff can take is through enforcement,
           and to get to the enforcement process, you have to
           have inspections and findings.  And it's the PIs that
           generate potentially the inspection process.
                       So to me, you know, at least in that sense
           it's tied together on more or less of a risk basis.
                       CHAIRMAN BONACA:  It's indirectly.  I
           think what they're proposing here to do would make it
           very direct in that, you know, from the beginning you
           don't have a true risk based determination in the
           calling (phonetic) of a PI, but you have a
           significance determination process allows you to get
           there, and so that would -- and that would not really
           complicate the system.
                       MR. COE:  No, that's right, and I'm not
           sure we would want to have a system where the changing
           of the color of a PI would then generate --
                       CHAIRMAN BONACA:  I understand.
                       MR. COE:  -- further regulatory
           aggravation by having an inspection.  We would want
           the PI ultimately to do it all for us.  That would be
           plant specific enough that it would do it all for us. 
           It wouldn't  require additional inspection because
           that would be more resource on us, as well as
                       CHAIRMAN BONACA:  In that case then you
           would consider, for example, saying, okay, it looks as
           if this licensee is going from green to white.  Let's
           evaluate through the SDP if it is true, and then you
           would have this assessment that would allow you to
           keep a green, for example, if, in fact, the
           significance of it was very low.
                       MR. COE:  That's correct.
                       CHAIRMAN BONACA:  Okay.  So you were not
           stepping in, and you would have the basis for keeping
           it in the green, which would be based on plant
                       MR. COE:  That's correct.
                       MR. SIEBER:  I would be nervous if you
           attempted to, even if they were plant specific, set PI
           thresholds that would skip over inspection process to
           arrive at some kind of enforcement action.  That's
           different than what your chart that you gave us.
                       MR. JOHNSON:  But let me -- well, I was
           almost going to try to see if I could say what it was
           you would be saying in terms of describing the
           enforcement program and see if maybe I can clarify it
           a little bit.
                       When we set it up, we have PIs and
           inspections that are independent inputs, and each of
           those are enough to get you across threshold into --
                       MR. SIEBER:  SDP.
                       MR. JOHNSON:  -- some assessment act --
           beyond SDP, into some assessment action.
                       MR. SIEBER:  Okay.
                       MR. JOHNSON:  Including enforcement if
           there's a violation associated with a finding, but
           depending really on the action you make, you could get
           an order or, you know, some other enforcement, things
           that are typically considered enforcement actions.
                       And so as I think Mark was trying to
           describe, we don't have the situation or we don't want
           to set up the situation where you have a PI and then
           you've got to go out and do some inspection and then
           run that through the SDP and now you have what you
           need to enter the action matrix.
                       The PIs and the inspections, each are
           independent input and sufficient inputs into the
           action matrix.  What we're trying to deal with is this
           problem that we have with unavailability PIs and the
           fact that they're not, as we set them up now, risk
                       So in those specific cases where we have
           these large blocks of exposure, that it would be
           better to run those through the SDP because that risk
           informs those.  That takes the leap in the short term
           to get us where we're trying to go.
                       CHAIRMAN BONACA:  So rather than having
           the pain of adjusting them all up front, which would
           be a very big challenge, you really have a process by
           which in the few cases where you have a step-down
           performance potentially, you do evaluate through this
           significance determination process --
                       MR. COE:  That's true.
                       CHAIRMAN BONACA:  -- and make the call.
                       MR. COE:  Yes.
                       DR. ROSEN:  In your earlier spirited
           defense of the adequacy of the safeguards and
           emergency preparedness indicators, you said something
           like we're pleased that we've seen licensees take
           actions based on these indicators to improve
           performance in those areas, in a sense basically
           rating the indicator by whether there was a response
           by the licensee to it.
                       MR. COE:  Backing into the answer, so to
                       DR. ROSEN:  Yeah, backing into the answer,
           and that's sort of been troubling me and gnawing at
           me.  I'm not quite sure what the issue is, what's
           bothering me, but I think it goes back to the question
           the Commission asked us, which is are these indicators
           providing meaningful insights into aspects of plant
           operation that are important to safety.
                       And we have to write to the Commission
           something about that, and your answer is, well, we
           don't know about that.  The licensees sure are doing
                       I can't quite connect those things.
                       MR. JOHNSON:  Can I try to -- I think that
           was my statement actually.
                       MR. COE:  No, I think it was Don's, but go
           ahead.  You can defend it.
                       MR. JOHNSON:  Don is the person who
           amplified it.  I probably said it in the wrong way.
                       What I meant to say was that with respect
           to, for example, the emergency preparedness
           performance indicators, we have found instances since
           the ROP based on these performance indicators where,
           for example licensees were, perhaps performing well
           with respect to drills, but only a small percentage of
           the responders were participating in the drills.
                       And based on these performance indicators,
           they provided broader training to all of the likely
           responders, and in addition, measured the performance
           of those responders through this drill participation,
           this drill performance indicator and the combination
           of those two have resulted in improved performance in
           areas that we think are important with respect to the
           emergency preparedness area.
                       So what I said, I think, was maybe that
           the licensees are improved -- if they want to improve
           their performance, they run more drills, and so, in
           fact, they've done that, but the point I was trying to
           make was in areas where we think performance needed to
           be improved based on what we believe is important with
           respect to the cornerstone, we've seen licensee
           performance.  We've seen these performance indicators
           indicate performance problems, and we've seen
           licensees take action to address those performance
           problems in areas that are important.
                       Hopefully that better clarifies what I
           meant to say.
                       DR. ROSEN:  It does, and I think what I
           have to do is make the hard link between if the
           licensee performs better in the safeguards area, then
           that is an aspect of plant operation that's important
           to safety, ergo, we are safer.
                       I mean, that's not something this program
           can do for me.  I have to have that external from your
           finding.  You tell me the licensee is performing
           better in the safeguards area or in the emergency
           preparedness area, and therefore, the plant is safer.
                       It's not as direct a measure as in the
           mitigating systems area.  It takes another piece of
           information outside of the finding that comes out of
           this program, if I'm expressing myself correctly.
                       MR. JOHNSON:  I understand.
                       DR. ROSEN:  You have to have this article
           of faith first, and then you can draw that conclusion.
                       MR. JOHNSON:  It's certainly not as easy
           in the non-reactor safety cornerstones, particularly
           the EP -- no, particularly the physical protection
           cornerstone.  It's not as easy to make that tie, if
           you will.
                       MR. COE:  But the common framework has
           been that each cornerstone has been described as
           having several key attributes, and the words "key
           attributes" are not -- there's a definite set of
           attributes as we've spelled out in SECY 007, and each
           of the cornerstones has those attributes spelled out,
           and each of those attributes is assessed in some
           fashion, either through the performance indicator
           program or through inspection findings or maintenance
           rule inspections, PI&R inspections, et cetera.
                       And so across all cornerstones, there's
           that same common basis.  So your hard link is really
           the adequacy with which you feel the staff has
           identified the key attributes of each cornerstone and
           has appropriately linked those key attributes to some
           method of measurement, either PIs or inspection.
                       DR. KRESS:  I think his problem is how to
           quantify those key attributes in terms of their impact
           on actual risk for safety.
                       MR. COE:  I understand that's the problem.
                       DR. KRESS:  Ones in one cornerstone may
           have much smaller impact than ones in an attribute in
           another cornerstone.
                       DR. ROSEN:  How do you weight the
                       DR. KRESS:  And how do you weight the two,
           I think, is his issue, his problem.
                       MR. COE:  Okay.  If we're ready to move
           beyond SDP at this point we can go to inspections and
           the challenges that we faced in the inspection.  The
           conduct and documentation of inspections has been one
           of defining in a consistent manner what our threshold
           is for documentation.  
                       The standards are articulated in our
           guidance document 0610, and we're continuing to work
           on improving that in terms of how we document them and
           at what threshold we document inspection findings.
                       We have the maintenance rule inspection
           procedure, which during the first year of
           implementation was felt to be -- we felt we could
           improve its risk and performance focus, and so we've
           engaged in pilot inspections, and we are rewriting the
           inspection procedure and engaging in the pilot
           inspections to test it out.
                       We expect that those will be ready for --
           the new inspection procedure will be ready for
           issuance in the next inspection cycle starting on
                       DR. WALLIS:  I'm sorry.  I didn't
           understand the first bullet at all.  You don't mean
           thresholds in the documentation.  You mean
           documentation of thresholds or documentation of
           determinations of something?
                       I don't understand what you mean by
                       MR. COE:  The issue here is at what
           threshold does the inspector document a finding.  In
           some part this is based on whether the finding is
           deemed to be minor, in which case if it's deemed to be
           minor against a set of criteria that we've tried to
           provide, then the inspector does not document it at
                       DR. WALLIS:  So this word "threshold" here
           has nothing to do with all the other thresholds we've
           been talking about.
                       MR. COE:  That's correct.  It's a
           documentation threshold.  That is, at what threshold
           does the inspector actually document their findings
           and observations?
                       And because the definition of minor isn't
           as precise as some of our other definitions, there's
           been some variability there.  We're trying to improve
                       DR. WALLIS:  So these thresholds, I mean,
           you could say they're consistent.  If it's white, you
           have to document it, and you could relate it to the
           other thresholds.
                       MR. COE:  Yes.  Well, there's no question
           about findings that are green or white or yellow or
           red.  We document those.  Okay?
                       The question comes in many cases as to,
           you know, whether your finding -- if your finding is
           minor, then you don't document it at all.
                       DR. WALLIS:  This is sort of the no color
                       MR. COE:  Well, and then there's the
           question of no color findings, which we've addressed
           as we've indicated earlier.  That was originally an
           issue as well.
                       The no color findings were documented. 
           There wasn't any question about that, but how they
           were documented, to what extent they were documented. 
           In other words, one of our objectives is to try to
           reduce the bulk of the inspection report and to more
           properly focus it on issues of greater significance.
                       So you'll see our inspection reports are
           smaller in volume, and we try to be more focused and
           we try to cut out a lot of the filler or not filler
           necessarily, but the information that might have
           historically been included in order to get to the more
           significant issues.
                       The next point is licensee self-
           assessments.  We're considering that.  We're starting
           to think about that.  I think we have to really think
           carefully.  We've only had a year's worth of
           experience, but we certainly are beginning to think
           about how to apply licensee self-assessment programs
           within the ROP framework.
                       And finally PI&R inspection frequency went
           to biennial from an annual.  However, the number of
           inspection hours annualized only dropped by about 25
           percent because we added a few more hours in between
           the biennial team inspections, which were about 250
           hours now.  We've allowed for about 60 hours of
           inspection on specific issues.
                       And this was to try to reduce somewhat the
           burden on the licensee by giving them a team
           inspection once every two years rather than once every
           year and also to allow the staff to probe, the
           inspection staff to probe into areas that were
           specific to PI&R concerns in between the two -- in
           between the team inspections.
                       So that's a summary of some of the major
           insights that we've gained in our first year, and at
           this point I guess we'll be happy to answer any
           follow-up questions.
                       DR. POWERS:  I have a question.  I'm
           intrigued to know what your response is to those
           plants that were, I think, SALP-1 plants in the past,
           got relatively little inspection, and suddenly find
           themselves being inspected quite a little bit more
           under this new system and yelp about that.
                       What is the stock response to them?
                       MR. JOHNSON:  I'll start, I guess.  I
           don't know that we have sort of a response that we've
           had a lot of success with, to be honest.  I mean --
                       DR. POWERS:  I didn't say it was
                       MR. JOHNSON:  And to be honest, there
           haven't been a lot of licensees who have raised that
           particular concern, although the industry in general
           would say -- has, in fact, looked at where we came out
           with respect to resources in general and does expect
           that we continue to look for efficiencies when we go
                       And there are, it's true, there are plants
           that were SALP-1 and, in fact, so they are getting
           more inspection under the baseline.
                       One of the things that was interesting
           with respect to the response to the Federal Register
           notice from licensees, and we had generally NEI
           writing in, but we had some individual licensees
           writing in, and it dealt with -- it deals with the
           perception of burden.
                       And while there are licensees who, I
           think, in fact, get more inspections, there are a
           whole bunch more licensees who think that the burden
           is more appropriate in that they're not having to
           react to the impact of inspections, that is, findings,
           a lot of findings at a very low level that tend to
           distract and cause licensees to expend their effort.
                       So I think when I talk about it, I talk
           about not inspection knowledge, but I talk about the
           burden of the program, and I think there's a wide
           acceptance to this fact that the burden with respect
           to the ROP is more right size given the significance
           of the issues and what we've been able to do through
           the SDP and other things.
                       That's sort of what I try to do to answer
           that question
                       MR. COE:  And I would only add that the
           good performers get good outcomes in terms of our
           assessment process still.  Okay?  And the extent of
           inspection that they get, although it's more
           normalized across all of the plants is one of the
           burdens that we all share in achieving this public
           confidence, one of our strategic goals.
                       DR. POWERS:  Well, it seems to me that one
           of the challenges that you face in getting public
           confidence in the system is that when they look at
           this system versus the old system with respect to just
           inspection -- and I really liked your answer, by the
           way, on look at the total thing and the burden -- but
           when they look at just inspection, they say, "Yes, the
           NRC has created a system.  They inspect the good
           performers more.  That means they're inspecting the
           bad performers less."
                       MR. SIEBER:  That's right.
                       DR. POWERS:  And I think that's a
           challenge, and I really liked your answer from the
           total burden is that you're putting the weight really
           where it does the most good as opposed to just being
           out there inspecting.  I like that answer.
                       MR. SIEBER:  Well, I'm not exactly sure
           that I agree with that whole statement because no
           matter whether you get a violation under the old
           system where you had to write an answer back, it still
           ended up in your corrective action program, and even
           non-sited violations end up in the same place and
           green findings end up in the same place.  Everything
           ends up in your corrective action system
                       And so the burden that the licensee has
           regarding how he has to deal with all of these issues
           is totally dependent on the deficiencies that are in
           the plant, whether you find them or the licensee finds
                       What does change is the licensee's
           inspection fee, as a good licensee's hours went up, so
           he pays more money, and a lesser performing licensee
           ends up getting a fee reduction, which to me is
           something the chief financial officer sees.
                       DR. POWERS:  It would be interesting to
           see the stats on that.  I agree with you that the good
           performers get a fee up.
                       MR. SIEBER:  Right, and more inspection
                       DR. POWERS:  But I'm willing to bet if
           this system is working right that the bad performers
           didn't see any reduction in fee.
                       MR. SIEBER:  Well, inspections.
                       DR. POWERS:  And fees for inspections.
                       MR. SIEBER:  Inspection hours.
                       DR. POWERS:  But in total, what they're
           saying is it's not fair to look just at inspection
                       MR. SIEBER:  But that's what you get
           billed on, and as long as you aren't getting civil
           penalties, that's the monetary --
                       MR. SATORIUS:  But if I could add, I think
           one of Mike's points also was the fact that to go
           beyond just fee billing because arguably the old SALP-
           1, the current program is a good performer, and the
           SALP-3, the current, isn't an acceptable performer. 
           They're going to have more expenses with entering
           things into their corrective action.  They're going to
           have more issues.
                       MR. SIEBER:  That's right.
                       MR. SATORIUS:  They're going to have more
           staff hours that they're going to spend to resolve
           these issues arguably than the good performer who has
           a more robust corrective action system and has better
           maintenance, has less issues to resolve.
                       MR. SIEBER:  And that was my first
           statement, is you're going to pay for those whether
           you find them or the licensee finds them.
                       MR. JOHNSON:  Yeah.  I guess the other
           point I would make is don't forget that the reason
           sort of the outcry a couple of years ago, two and a
           half years ago, whenever it was, that got us on this
           path revising the oversight process was -- and it
           didn't relate to inspection hours or fees.  It related
           to predictability.  It related to burden.  It related
           to objectivity or really subjectivity being central to
           the process.
                       And those are the things where I think
           this current process offers relief that licensees --
           that make them think that this is a better process.
                       Now, we've got challenges.  The point
           about -- you know, David Lochbaum still says that we
           don't spend enough  attention on plants with
           significant performance problems.  That's his
           criticism of the ROP.
                       You know, he's looking at it from the
           other perspective.  When you get an IP-2 or you get a
           plant that's having -- that ends up in the degraded
           cornerstone column of the action matrix, he wants us
           to do more than we're doing today.
                       So the people who fall on the other side
           of the spectrum, that's the other piece of the story,
           I guess.
                       MR. SIEBER:  Well, the objectives that
           were laid out by the commission, which appears in the
           first couple of pages of your assessment document
           which just came out, I'm pretty well convinced that
           you are on the way to hitting all of them.  But I
           picture this process as going on for another five
           years at a minimum where you can say, "Yeah, I have
           all of these bases covered," and so you're just on the
           doorstep of the edit (phonetic), in my view.
                       Would you disagree with that?
                       MR. JOHNSON:  Not at all, not at all.
                       CHAIRMAN BONACA:  Actually, I mean, I
           think there's more even distribution of resources is
           a better approach.  I mean, there used to be before
           the fact that they were presumed good performers that
           continue to be presumed good performers because they
           didn't look enough.  When they looked hard, they find
           they were not anymore.
                       So you know, that is a problem, and I
           think today with a more even distribution of
           resources, that's not going to happen as easily.
                       MR. SIEBER:  Any other questions or
                       MR. JOHNSON:  Just one last comment, if I
           can.  I really was serious when I suggested that we
           benefit from these exchanges, and we do need the help
           of the ACRS to the extent the ACRS is willing to weigh
           in with respect to the SSU development work that we're
           going to do, to look at the piloting in January and
           going forward.
                       So if there is an opportunity and if the
           ACRS is willing, we'd look forward to opportunities to
           continue to interface and get your input.
                       MR. SIEBER:  I think that's appropriate.
                       If there are no other questions, Mr.
           Chairman, I'll turn the meeting to you.
                       CHAIRMAN BONACA:  Thank you.  Thank you
           very much.
                       At this point I think we will, first of
           all, go off the record.  We don't need a transcriber
                       (Whereupon, at 4:22 p.m., the meeting was

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