485th Meeting - September 6, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Thursday, September 6, 2001

Work Order No.: NRC-004                             Pages 304-491

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433.                         UNITED STATES OF AMERICA
                                 + + + + +
                            485TH ACRS MEETING
                                 + + + + +
                             SEPTEMBER 6, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
                                 + + + + + 
                       The Advisory Committee met at the Nuclear 
           Regulatory Commission, Two White Flint North, Room 
           T2B3, 11545 Rockville Pike, at 8:30 a.m., 
           Dr. George E. Apostolakis, Chairman, presiding. 
                 DR. GEORGE E. APOSTOLAKIS, Chairman
                 DR. MARIO V. BONACA, Vice Chairman
                 DR. F. PETER FORD, Member
                 DR. DANA A. POWERS, Member
                 DR. STEPHEN L. ROSEN, Member
                 DR. WILLIAM J. SHACK, Member
                 DR. THOMAS S. KRESS, Member at Large
                 DR. JOHN D. SIEBER, Member
                 DR. GRAHAM  B. WALLIS, Member.           ACRS STAFF:
                 DR. JOHN T. LARKINS, Executive Director
                 CAROL A. HARRIS, ACRS/ACNW
                 HOWARD J. LARSON, ACRS/ACNW
                 SAM DURAISWAMY, ACRS
                 DR. SHER BAHADUR, ACRS
                 PAUL A. BOEHNERT, ACRS
                 MICHAEL T. MARKLEY, ACRS
           NRC STAFF:  
                 RALPH LANDRY
                 TONY ULSES
                 RALPH CARUSO
                 SUDHAMAY BASU
                 JENS ANDERSEN, General Electric
                 FRAN BOLGER, General Electric
           .                                 I-N-D-E-X
                    AGENDA ITEM                            PAGE
           Opening Remarks by ACRS Chairman . . . . . . . . 306
           Peer Review of PRA Certification Process . . . . 309
           Presentation by Mr. Markley
           Meeting with NRC Commissioner Merrifield . . . . 330
           TRACG Best-Estimate Thermal-Hydraulic Code . . . 381
           Presentation by Dr. Wallis and Mr. Landry
           Proposed Final Revision to Regulatory. . . . . . 427
           Guide 1.78 Presentation by Jens Andersen 
           and Fran Bolger
           Proposed Final Revision to Regulatory. . . . . . 456
           Guide 1.78, Main Control Room Habitability 
           During a Postulated Hazardous Chemical 
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:31 a.m.)
                       CHAIRMAN APOSTOLAKIS:  The meeting will
           now come to order.  This is the second day of the 
           485th meeting of the Advisory Committee on Reactor
                       During today's meeting the committee will
           consider the following; a report by ACRS Senior Staff
           Engineer regarding peer review of the PRA
           certification process; the TRACG best-estimate
           thermal-hydraulic code, and proposed final revision to
           Regulatory Guide 1.78, Main Control Room Habitability
           During a Postulated Hazardous Chemical Release; and
           proposed ACRS reports.
                       In addition, the committee will meet with
           NRC Commissioner Merrifield to discuss items of mutual
           interest.  A portion of this meeting may be closed to
           discuss General Electric proprietary information
           applicable to the TRACG thermal hydraulic code.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Mr. Sam Duraiswamy 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 session.  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.
                       One item of interest is that this is the
           300th ACRS meeting for our own Paul Boehnert.  He
           started working here -- I mean, the first ACRS meeting
           he attended was on September 11th, 1975.  That was the
           185th meeting.
                       And we have a little treasure here.  We
           have a picture of the staff engineers and the ACRS
           members from October 7th, 1977, and there is a young
           man here dressed very '70s, with a big tie and
           mustache.  So I think the members will enjoy having a
           look at it, and I will pass it around.  So we
           congratulate Paul and his dedication. 
                       DR. APOSTOLAKIS:  And for the way your
           taste in clothes has evolved.
                       DR. APOSTOLAKIS:  Okay.  So we are passing
           around that picture.  Our first session today deals
           with a peer review of the certification process for
                       Mr. Michael Markley, our senior staff
           engineer, attended the North Anna Power Station peer
           review that was conducted by the Westinghouse Owners
           Group, last July and he will report on that today. 
                       MR. MARKLEY:  Good morning.  Thank you for
           the opportunity to present my observations here.  I do
           want to qualify that these are my observations, and
           they don't represent the views of the ACRS or the NRC,
           and the first few slides are really mostly just
           reviewing what the process grading and significance
           determination will cover.
                       The latter ones are really the majority of
           my observations.  So if you would prefer I breeze
           through these early ones, I can.  The ACRS last
           reviewed the NEI 00-02 in October 2000.  
                       It was an information briefing, and they
           pretty much laid out what they were planning to do. 
           This evolved out of the Boiling Water Reactor Owners
           Group certification process.
                       All licensees are performing it, and most
           of these are being conducted by the owners groups, and
           in this particular case, the Westinghouse Owner Group
           did the Dominion one.
                       As you may recall, during that briefing,
           talked about where they would like to see the PRA
           certified, and that was to a Grade 3 level. The Grade
           1 is really essentially pretty much a point of
           departure with the IPEs, and so that really is -- they
           would expect most all of these to meet that level.
                       The Grade 2 would be risk ranking of the
           capability of doing SSCs, and so forth, and that they
           would be a combination of probablistic and
           deterministic insights.
                       Grade 3, which is where I think the
           majority of the Dominion observations were, and I
           think you will also note that if you read in the
           materials that there were a number of contingency
           findings there, and for the license to meet that Grade
           3 certification, they would have to satisfy those
           contingencies to do so.
                       And Grade 4 is a little bit further than
           where they are today for most licensees, and that
           would be that the PRA itself would be useable, and not
           necessarily with the compliment of deterministic as we
           normally see them.  
                       DR. APOSTOLAKIS:  So Grade 3 then would
           seem to be a good goal?
                       MR. MARKLEY:  That is the target mark
           today.  And for the levels of significance for the
           facts and observations, as they had findings, they
           would document them on a fact and observation sheet,
           and provide them to the licensee, with level of
                       And, for example, if it was extremely
           important and they had to satisfy it to meet the grade
           today, then it would be given an "A" then.  Most
           findings typically would fall in the Category B of
           significance, where it could be accommodated during
           the next updated PRA.
                       MR. ROSEN:  Mike, on that slide, why do
           you have a contingent item for grade assignment on
           both A and B?  I thought that was just B?
                       MR. MARKLEY:  Well, A would be contingent
           also.  They are both contingent.
                       MR. ROSEN:  Okay.
                       MR. MARKLEY:  According to a NEI 00-02
           process.  I mean, it is just the way it is.  For them
           to receive a grade, if they were given -- they can be
           given a Grade 3 with no contingencies, or a Grade 3
           with an A or a B.  That is kind of the way it fell
                       DR. KRESS:  How many members of this peer
           review are there?
                       MR. MARKLEY:  There were -- on this
           particular one, there were -- let's see -- seven.  I
           will get into that a little bit as we go.  The level
           of significance -- and these really -- there were very
           few observations that fell into these categories, with
           C, B, and desirable to maintain flexibility, but not
           likely to affect the results or conclusions.
                       And D, B, and editorial, are minor
           changes.  And the S, B, and superior treatment, there
           were a fair number of items that were observed and
           brought to the attention of the licensee as being
           exceptional, or very well done.
                       The one thing that I would point to is
           that the information that I had when I departed were
           the licensee's exit -- you know, turnover -- from the
           Westinghouse Owners Group.  
                       So they have gone back and forth since
           that time, and some of these contingencies have gone
           away, I'm sure, but they are still offering more
           information, and doing follow-up actions between then
           and the time that the report came out.
                       DR. KRESS:  That S is an interesting
           level.  Why did they feel it necessary to do that?
                       MR. MARKLEY:  Well, this is part of the
           NEI 00-02 process, but I think if this is a model for
           other licensees --
                       DR. KRESS:  So it is a model for other
           licensees to look at and say, hey, maybe we ought to
           use that treatment?
                       MR. MARKLEY:  Well, one of the things that
           I think is interesting here is that each owners group
           is going through and doing these.  About half of the
           Westinghouse Owners Group had done them, and they
           still had the other half yet to do.
                       And there is a fair amount of
           organizational learning that is going on through that. 
           They have identified things that were good practices,
           or even parts of the procedure that were useful and
           that they may want to consider in a possible revision
           to 00-02, and that's not really on the table just yet.
                       But each owners group will have its own
           little population of notes and lessons learned, I
           think, at the end of this in going through the PRAs
           with their licensees.  So I think the S is useful in
           that respect.
                       MR. ROSEN:  And it is an analog to what
           info does with good practices.
                       MR. MARKLEY: Right.
                       MR. ROSEN:  And finding things that are
                       MR. MARKLEY:  And one of the benefits, I
           think, of North Anna that they have certainly derived
           is that Surry is very similar to North Anna.  There
           are clearly site specific differences, but for the
           most part the core of the PRA is very similar to
                       And Surry has been probably one of the
           most examined PRAs in the country.  It has been
           through a 1150, a 1400, a 6144 for low power shutdown,
           and they serve -- 
                       DR. POWERS:  And every time they do it,
           they find something new about the plant.
                       MR. MARKLEY:  Right.  So in that respect,
           I think the peer review team had a little bit more
           difficult challenge in finding opportunities for
           improvement.  This was a fairly mature PRA as compared
           to many of the others that would be out there.
                       Surry is also going to be a pilot for the
           Option 2 Part 50 stuff.  So, I mean, their
           participation in pilots I think has clearly benefited
           their PRAs in many ways.  
                       I think that in looking at the peer review
           team itself, clearly because the PRA was more mature,
           the findings were more sparse, as compared to a plant
           that may not have had as long a history in developing
           their PRA and the talent.  
                       They just added another person during that
           time period who used to be the head of the PRA group
           from San Onofre.  So it is continuing to evolve there. 
           This particular team was really fairly talent laden.
                       Some of the people that you have had
           presenting before the ACRS half a dozen times or
           better, they had 25 years of nuclear experience on
           average, and 17 years of PRA experience on average,
           which is really quite substantial compared to the
           industry on average.
                       The team members demonstrated a healthy
           team interest, and this was one of the more important
           things to me, is that they were really demonstrating
           a questioning attitude, and looking hard through the
           PRA, and trying to find vulnerabilities, observations,
           insights, opportunities for improvement.  
                       There was really no apparent rush to
           certify the PRA.  They did have a very challenging
           time schedule to do it within a week, and when you
           recognize that there are presentations for the
           licensee to bring the peer review team up to speed
           with where they are, and what they have done.
                       They had to do a self-assessment before
           the team was scheduled to come there, and so some of
           those items, they had to tell them what we have done
           in response to the self-assessment, and what have we
           done in response to what was done at Surry, because
           Surry was one of the earliest NEI 00-02 evaluations.
                       And so looking at that, you know, there
           were a fair amount of methodical things they had to
           get through.  And then three days to really dig into
           the PRA, and then you have the exit on Friday.
                       So a week is really a fairly challenging
           period of time to dig through the multiple volumes of
           a PRA.  
                       MR. ROSEN:  But, Mike, isn't there some
           prior work for the team?
                       MR. MARKLEY:  Sure. 
                       MR. ROSEN:  The team does some homework
           before it ever gets there?
                       MR. MARKLEY:  That's true.  Yes, they do
           have the benefit of a lot of prior information.  It is
           an extensive structure sampling, but it is a sample. 
                       DR. APOSTOLAKIS:  But very few PRAs though
           have been reviewed line by line.  
                       MR. MARKLEY:  No, I don't think --
                       DR. APOSTOLAKIS:  It is very difficult. 
           I mean, you are expending a lot of resources trying to
           do that.
                       MR. MARKLEY:  Right.
                       DR. APOSTOLAKIS:  The one that comes to
           mind is the review that Sandia did Zion and Indian
           Point, where they really went over it with
           excruciating detail.  But it is very difficult to do
                       I think experienced reviewers can look at
           things on a sampling basis and say something.
                       DR. POWERS:  I guess the question is how
           do we know that the sampling is adequate?
                       DR. APOSTOLAKIS:  Well, again, it depends
           a lot on the reviewers.
                       MR. MARKLEY:  I think that is what you are
           going to have though, is that there is going to be
           some variability in the population and the experience
           of the teams they will be sampling.
                       But I think the strength of this
           particular one was the talent of the team, and they
           brought a lot of experience to the table.  
                       DR. APOSTOLAKIS:  In my experience, if you
           take an accident sequence, and you really try to
           understand it, and you go all the way down to the data
           that they used, you get a very good idea as to whether
           the PRA is a good one or not.
                       DR. POWERS:  How many fields do we have
           that say, oh, we are going to sample.  I guess that is
           good enough.  I mean, every place I can think of where
           you sample, they go to elaborate efforts to say how do
           we know that the sampling is going to be indicative of
           what the whole looks like.
                       DR. APOSTOLAKIS:  I don't think this is
           sampling in the sense of asking people what they
           think.  It doesn't have to be a random sample.  I
           think it is up to the reviewers to -- well, what it
           says is that they did not review the whole thing from
           cover to cover.
                       But I don't think it was a random sample,
           where somebody says --
                       DR. POWERS:  Well, how do you go about
           picking a sequence to look at?  You say, gee, I will
           look at the risk dominance sequence.  Well, that is
           the one that the PRA producer has probably spent the
           most time on.  
                       And so it is most likely to be done well,
           and so maybe you don't want to pick that one.  You
           want to pick one of the less dominant ones.  
                       DR. APOSTOLAKIS:  Well, that was just
           missed.  Some of these guys might do that.  I don't
           know what they did.  
                       MR. ROSEN:  Well, I think there is more to
           it than that.  I think these people talk to each
           other.  There are a fairly small number of PRA
           professionals in the industry, and there is a lot of
           communication between them.  
                       So they know what the issues are, and the
           modeling issues, and the development issues within
           each other's PRAs.  And a team like this, whose names
           I looked at, which was really a very superior team,
           probably comes with a pretty good idea of where to
           drill down, and to look for problems.
                       MR. MARKLEY:  They did, and they found
           problems in some of the top level events that had
           common themes and trickle down effects.  So if you
           were looking at each one of these areas, there were
           things that if they found a weakness in one area, it
           affected other areas, too, and that is not surprising.
                       But the NRC has the same dilemma, I think,
           if you are talking about what is an adequate sample. 
           I mean, our inspections are a sample, and that's the
           nature of it.  You are trying to find something, and
           to see whether that is representative of another
           problem, or to look deeper in a particular area.
                       During the consensus session, I think
           there was a healthy debate, and in looking at each one
           of the sub-elements within the particular categories
           and elements to evaluate each one, and then to have it
           rolled up into an overall rating.
                       And which items would be level of
           significance A, or B, and in most cases the licensee
           was not present.  They did not have an opportunity to
           offer counter-arguments for that debate.
                       They would present them at the end of the
           day or meet with them early in the morning to discuss
           what the preliminary conclusions were.  And at that
           point in time, in addition to the fact and observation
           sheets, new information would have come to light.
                       And then they would adjust things a little
           bit, but for the most part the consensus determined
           their own independent conclusions, and then shared
           with the licensee.  
                       And as I said, even after the exit, I am
           sure that things are still being discussed back and
           forth as more information is shared.
                       DR. APOSTOLAKIS:  What do you mean by
           there is no follow-up procedure?
                       MR. MARKLEY:  There is no recertification. 
           For example, if someone wanted to take their PRA from
           an overall Grade 3 to an overall Grade 4, there is
           really no follow-up procedure.  
                       Or if they wanted to take something from
           an individual element from a Grade 2 to a Grade 3,
           there is really no planned NEI procedure to go back
           out and recertify these, and to give them a higher
                       DR. APOSTOLAKIS:  How about making sure
           that they actually did what they were asked to do?  I
           mean, there were some comments, and is there a
           feedback mechanism there?
                       MR. MARKLEY:  As far as follow-up, I mean,
           it is really part of the closeout of the report.  I am
           not aware of any follow-up evaluations to verify that
           what was agreed to be done is actually done.  
                       DR. APOSTOLAKIS:  And that is related to
           what you said down here.
                       MR. MARKLEY:  Right.
                       DR. APOSTOLAKIS:  Because if they do it,
           then presumably they get the higher grade.
                       MR. MARKLEY:  Right.
                       MR. ROSEN:  You mean, Mike, there is not
           even a letter from the licensee to the NEI staff that
           says here are the things that the PRA peer review
           found, and here is what we did about them, and thank
           you very much?
                       MR. MARKLEY:  It would seem to me --
                       MR. ROSEN:  That is not a recertification. 
           It is just a statement by the licensee that they did
           what was expected.  I mean, that is sort of halfway
           between sending another team out to check like INPO
                       INPO, when they make comments and
           recommendations, they come out and take a look the
           next time.  Well, maybe even before the next
                       MR. MARKLEY:  Well, I would not suggest
           that they don't maybe reconsider the information.  If
           the licensee offers new information, it seems to me
           that that would be reasonable, and I cannot tell you
           what will happen following the actual on-site visit.
                       I know that they plan to issue the report
           within a few weeks, and clearly the licensee offers
           additional information, which may affect contingent or
           overall grades.
                       But as far as where it ends up after they
           issue the report, and where the licensee responds
           back, I can't explain how that is translated into an
                       And I think grading is really part of the
           process, but in most respects I think the licensee
           would agree, and the owners group would also, that the
           real value is in the suggestions for improvement to
           the PRA.
                       And what the licensee actually does with
           to make enhancements subject to that, and grading is
           part of it, but the benefit is really in the insights
           and the information, and how they can use that to
           improve things and to make changes.
                       And they clearly identified a number of
           useful recommendations, and how those get translated
           into actions.  And incompleteness will still exist,
           and there is variability in the use of plant specific
           data from licensee to licensee, and how it is
           considered here. 
                       There is variability in how uncertainly
           and other things are considered.  But it does
           represent progress, and that's why I think it would be
           very advantageous if there was a follow-up type
           procedure for them to go back, and that once a
           licensee feels like they have made sufficient progress
           in an area, it would be useful I think for them to
           request another visit of that type.
                       I don't see any reason why that couldn't
           occur independently of an individually planned or a
           broad industry wide initiative to do a baseline peer
           review of all the PRAs.
                       I think it would be worthwhile for ACRS
           members to attend.  I can't say in particular what --
           if you weren't going to go for the whole week, what
           days might be the best days to go, because clearly
           there are going to be peaks and valleys in the
           findings and the conclusions, and how that all gets
           wrapped up.
                       And it would always be worthwhile to go to
           an exit meeting, but that process of when the major
           findings are derived, and how they get resolved,
           that's hard to tell, and that would vary from
           certification to certification, and how complete they
           had done their self-assessment, and what had been done
           out of that.
                       DR. KRESS:  Is the one week a fixed amount
           of time, or --
                       MR. MARKLEY:  That is the way it is now,
           or at least that is the way the Westinghouse Owners
           Group is doing it.  I can't tell you what the others
           are doing.
                       DR. KRESS:  It doesn't depend on how many
           findings they are coming up with?
                       DR. APOSTOLAKIS:  No, because they don't
           resolve them on site.
                       MR. MARKLEY:  Right.
                       DR. KRESS:  But I was thinking along
           Dana's lines; how do you know when you go to get
           another sample, and it is like inspection.  If I found
           some things, I would want to look further.
                       MR. MARKLEY:  Right.
                       DR. KRESS:  And that is the way that I
           would decide whether my sample was good or not.
                       DR. APOSTOLAKIS:  My understanding is that
           they don't find those things when they are there.  
                       DR. KRESS:  Oh.
                       DR. APOSTOLAKIS:  They read stuff before
           they go, right? 
                       DR. KRESS:  They just come in with their
                       DR. APOSTOLAKIS:  Well, as you discuss
           things, you may find out things, but it's not as if
           you go in cold and you start looking and you say, oh,
           I found this.
                       MR. MARKLEY:  It is very much like an ACRS
           meeting.  They have the information before the 
           meeting, and they have the meeting itself, and the
           same with inspection.  
                       DR. APOSTOLAKIS:  So they read everything,
           all the documents, very well?
                       MR. MARKLEY:  Well, we can't assure that
           all the members did, George, but we presume that they
           have done some.  
                       MR. ROSEN:  Well, I have watched members
           of these teams prepare to go off to another site, and
           there is a lot of dialogue in addition to the stacks
           of material.  
                       A guy calls up and asks questions about
           material that he has received,and has a dialogue with
           the PRA people at the site that is going to be
                       DR. APOSTOLAKIS:  And what is -- I mean,
           let's not forget what is the value of this?  I mean,
           they are not asking us to bless anything, right?
                       MR. MARKLEY:  No.
                       DR. APOSTOLAKIS:  It is just something
           that industry does to make sure that they good PRAs. 
           But if a licensee comes before the NRC requesting
           something, using this PRA then, the staff will have to
           be reviewed.  
                       And if the PRA has gone through this, then
           presumably that review will be facilitated.
                       MR. MARKLEY:  I think it is very
           worthwhile.  To me, there are very few downsizes in
           going through and evaluating opportunities to improve
           the PRA.
                       DR. APOSTOLAKIS:  Yes.
                       MR. MARKLEY:  It is voluntary, but I do
           think it could do a lot to help the NRC in achieving
           its strategic goals of maintaining safety and
           enhancing public confidence, and reducing unnecessary
           regulatory burden, and increasing effectiveness and
                       It certainly will help the decision making
           process if they offer this kind of information in
           their submittals.
                       MR. ROSEN:  Well, the staff can always ask
           have you gone through peer certification, and if the
           answer is yes, then what did they find.
                       MR. MARKLEY:  Right.
                       MR. ROSEN:  And then you can get a good
           handle on it, and then the staff can even ask what did
           you do with those findings.
                       DR. APOSTOLAKIS:  Only if they are
           relevant to the particular issue at hand.
                       MR. ROSEN:  Sure.
                       DR. APOSTOLAKIS:  And we are not looking
           at the big picture here.
                       MR. MARKLEY:  Well, I think it should help
           the NRC processes in a number of ways; and in
           licensing, clearly as the precedents are made, in
           terms of regulatory initiatives, once something has
           been approved, then there should be an easier track
           for other similar requests to be approved in a more
           timely manner, with less review.  
                       And in terms of inspection, I think it
           could help the ROP implementation in a number of ways. 
           I think it would be very worthwhile for the NRC staff,
           whether they are the project managers, or the senior
           reactor analysts, or the resident inspectors, to
           attend these.
                       I think there is a huge benefit in
           understanding more about the PRA, and I think they
           would learn a lot by attending the certification
                       As far as future ACRS review, we did have
           David Lochbaum attend this, and certainly the NRC
           staff has attended some other PRC certifications.  I
           am not aware of which ones in particular.  I did
           become aware of one this morning.
                       But I think the appropriate time for the
           ACRS to look at it again would really be after the
           owners groups had completed their initial reviews, and
           when you can kind of sit back and say what did we
                       You know, what -- well, the Westinghouse
           Owners Group, for example, was using the sub-tier
           criteria, which is not part of NEI 00-02.  It was
           subject criteria that had been developed by the BWR
           owners group.  
                       But they found it very useful in
           evaluating the sub-elements within each of the PRA
           overall elements.  So how those things fit into
           lessons learned, and whether those things could be
           combined into a improved NEI 00-02, I think would be
           very useful at that point in time.
                       And that would also be a good time to hear
           from people like David Lochbaum, and other concerned
           citizen groups who have attended these and have
           observations as well.
                       I think in the lessons learned, you know,
           what kind of follow-up actions.  You have asked
           questions on what are the licensees doing, or how does
           the Commission verify what has been done.  I think
           that is a very important issue.
                       And then how have these things been
           translated into regulatory initiatives, and been
           useful, and made the NRC more effective, efficient,
           and how it provides more confidence, the pillars of
           the NRC strategic plan.
                       It also provides some additional
           perspective as we look at more issues related to PRA
           quality.  The revisions, 1.174, and the ANS and the
           AMSE standards, and things like that.  
                       DR. APOSTOLAKIS:  Good.  That's it?
                       MR. MARKLEY:  Yes.
                       DR. APOSTOLAKIS:  Any questions for Mike? 
           If not, thank you very much, Mike.  Commissioner
           Merrifield is here.
                       COMMISSIONER MERRIFIELD:  Good morning.  
                       DR. APOSTOLAKIS:  Do we need the
                       COMMISSIONER MERRIFIELD:  No, I don't have
                       DR. APOSTOLAKIS:  Well, welcome,
           Commissioner.  We are very pleased that you are here,
           and so we can talk really about items of mutual
           interest, and without further ado, the floor is yours.
                       COMMISSIONER MERRIFIELD:  Well, thank you
           very much, Mr. Chairman.  I appreciate the kind
           invitation that the ACRS has extended to me to come
           and share with you some of my own views about what is
           going on here at the Agency, within the industry, and
           at many of the plants and facilities that I have had
           the opportunity to visit during the almost 3 years now
           that I have been on the Commission.
                       Up front, I would want to say and issue my
           appreciation for the strong level of cooperation that
           we have had between the Commission and the ACRS.  I
           think it has been a good dialogue during the time that
           I have been here.
                       Obviously, we have had a series of a very
           well qualified and helpful Chairman, and I know that
           you will continue what is a proud tradition in that
                       I am, for example, very pleased with the
           work done by Dana Powers on the research report, and
           I will be going into that in greater detail a little
           later on in my presentation.
                       And it has also been a pleasure to get to
           know and work with a number of the members at ACRS. 
           For example, I had a very positive visit to Argonne
           National Labs, hosted by Dr. Shack, and saw a lot of
           the very important research work that was being
           conducted by Argonne in the research area, on issues
           such as steam generators and otherwise.
                       So I look forward to a continued dialogue
           in that respect.  Today, I am going to try to give my
           presentation in a fairly high level -- and not get
           into the technical details of a lot of it.
                       That is after all an appropriate role
           being a Commissioner, and certainly that is the level
           that I want to present today.  To underscore what is
           the obvious, what I am going to talk about today
           represents my own opinions, and not those of the
           Commission, although I would hope that in many
           respects the Commission would concur with those, but
           they are in fact my own views.
                       The first thing that I want to talk about
           a little bit is my insights from some of the
           activities that I have had over the last 3 years.  I
           have had the pleasure and the opportunity at this
           point to visit 83 of the 103 operating nuclear power
           plants in the United States.
                       I also in the visits that I have had to
           over a dozen foreign countries have seen in excess of
           two dozen reactors outside the United States, and I am
           also taking the time to visit a variety of other
           facilities for which our agency regulates.
                       I have been to, for example, 7 of the 9
           fuel facilities that we regulate, and a number of
           research reactors, and research facilities -- Argonne
           National Labs, and otherwise -- to get a better
           understanding and appreciation for the myriad of
           issues that our agency has grappled with.
                       In terms of the plants themselves, and the
           state of the industry, I have said in many public fora
           that I believe that the state of the industry right
           now is the strongest that it has been in the last 20
                       The material condition and operating
           performance of the plants that I have been to I think
           is reflective of that increased performance and
           operating experience of the industry.  And that
           involves a variety of different factors.
                       Work planning, for example.  When you look
           at the outage time, the on-line time of the reactors,
           and you look at the amount of maintenance that is
           going on on-line, obviously there is a great deal of
           care being undertaken by the owners and operators of
           the units to make sure that they are operating at the
           highest levels of safety and performance.
                       And that is indeed I think an improvement
           over where the reactors were 20 years ago and 10 years
           ago, or 5 years ago.  Increasingly, there is a greater
           reliance in corrective action programs to make sure
           that items that are identified by the staff, and
           hopefully by their staff and not by our staff, get
           into that corrective action program in a timely way so
           that it can be addressed, and keep that plant at the
           highest operating and safety performance.
                       Frequently, I think licensees have a
           better recognition and understanding of the need for
           appropriate asset management.  As there are a greater
           number of licensees that are making the choice to
           increase the term of their license from 40 to 60
           years, a recognition that the portions of the plant --
           the material condition of the plant, the steam
           generators, the secondary side -- have to be
           maintained in an appropriate program to keep that
           resource operating at the highest operational and
           safety levels.
                       As you go around the reactors, you see
           that there are shorter refueling outages.  Now,
           obviously some have always questioned this as to
           whether is that the right place for safety.  
                       I think what you see associated with those
           shorter refueling outages is a lot better planning, a
           lot better understanding by the licensees of the work
           that needs to be accomplished, and how that is to be
           timed in such a manner as to take the most effective
           utilization of manpower resources.
                       For me, I think the key indicator of how
           those outages are progressing is the extent to which
           there are operational difficulties coming out of the
           outage.  Do you have downpowers soon after those
           outages have occurred.  
                       In years past, I think you saw a lot more
           of that, and certainly in today's operations, I see
           that that is decreasing significantly, and I think
           that is the right way to go.  
                       It means that they are planning better,
           and it means that they are doing what is necessary to
           maintain the safety of that plant.  
                       License renewal.  I want to go into a
           little greater detail about license renewal, but I
           think the top level item that I would want to mention
           in my visits and in the discussions that I have had
           with the utility executives over the last 3 years, I
           think there is an expectation among the utilities, and
           I think it should be an expectation among this
           Commission, that virtually all of the units that we
           are currently regulating, all 103 operating units,
           will most likely seek a 20 year life extension.
                       And so I think we need to plan for that
           eventuality.  We have had an increasing amount of
           attention -- and I will go into this in a little
           greater detail later, but we have had an increasing
           amount of attention regarding risk-informed
                       We have put a lot of effort into the risk-
           informed maintenance rule, and we are currently
           grappling with 50.44 and 50.46.  I think there is a
           mixed bag out there.  
                       There are some licensees -- South Texas,
           San Onofre, Fort Calhoun, there are a group of
           licensees who I think have a high degree of commitment
           to utilizing a risk-informed regulatory framework, and
           are very encouraging of the efforts of the agency to
           go down that road.
                       In reality, I think that there are a
           larger number of licensees, and I think an uncertain
           number to that extent, who have a lot of doubts about
           that, about whether they want to put in the time and
           expenses necessary to go with a risk informed Part 50.
                       There are many who are comfortable with
           the current form of Part 50, and have no real stake in
           seeing an option.  Given that, I think we need to
           appropriately judge and continue to interact with NEI
           from a budgetary and management standpoint to make
           sure that the resources that we are dedicating toward
           risk-informed and Part 50 are appropriately balanced
           given the amount of interaction and interest on the
           part of industry.
                       We have a lot of challenges as an agency
           before us.  I am going to go into some of the further
           ones that we have coming ahead.  But the commitment
           toward a risk-informed Part 50 is going to mean a lot
           of money.  
                       It is going to mean a lot of resources
           from both an FTE and a dollar standpoint, and we have
           to have some understanding down the road that there is
           a value that is going to be derived from that, because
           after all we do impose our fees on licensees.
                       And if we are spending a lot of money on
           areas at the end of the day that may not be fully
           realized and fully utilized by those licensees, you
           certainly have to make sure that we question
           appropriately the dollars that we spend.
                       Human capital.  I am going to go into a
           little greater detail in that later on, but we have
           talked -- those of us in the Commission and outside of
           the Commission -- about the challenges that we face as
           an agency in an aging work force.  
                       Those very same challenges are evident at
           the plants.  They are evident in perhaps some
           different ways, and manifest themselves in a different
           group of individuals, but they are challenges shared
           throughout the industry, and one that I think we
           should need to maintain vigilance and a look at.
                       When I visit the plants, one of the first
           things that I -- and in fact the first thing that I
           do, is to meet with our resident inspectors, and I
           have had the pleasure of meeting probably in excess of
           a hundred of our residents over the course of the last
           few years.
                       I frequently -- and some people smirk at
           this, but I consider or refer to them as our sentinels
           of safety.  They are our front line individuals out
           there identifying potential problems at the plant, or
           verifying that in fact things are working
                       I believe that the group as a whole, the
           resident inspectors that we have, are very well
           trained, and very capable, and very outstanding good
           people.  They are people who I believe the Commission,
           and that we all, can be proud of.
                       We have asked a lot of our resident
           inspectors over the last few years in moving towards
           the new reactor oversight program.  Early on -- you
           know, 2-1/2 years or so -- when I was meeting with the
           resident inspectors at that point, there were a lot of
                       They had a lot of questions about the
           direction that we were moving with the new reactor
           oversight process.  What I have found more recent is
           a group of inspectors who have embraced that program,
           and believe that it does in fact improve our ability
           to identify and address safety issues at the plant,
           and judge whether there is declining performance in
           individual facilities.
                       And I think that there is a greater level
           of confidence in those inspectors that we are doing
           the right thing, and I think that is positive.  I
           think there is a much higher degree of uniformity,
           from top to bottom, within the Commission, and support
           for the new reactor oversight program.
                       One of the things that I think has been a
           concern, but I think that I have been hearing from
           both the inspectors and the licensees, are issues that
           sometimes fall out of our inspection program, and we
           have a very disciplined manner in which we go about
           inspecting the plants.
                       And we have asked our inspectors to be
           more disciplined in the way that they do it. 
           Obviously, any individual walking through the plant,
           be it a Commissioner, a member of the street, or one
           of our inspectors, might see some things that may
           trouble them, or may raise an issue or a question.
                       It is clear to me that the licensees, and
           it is clear to me that our inspectors, are comfortable
           in engaging those issues, even when they are not
           within the parameters of our inspection program.
                       The positive thing that I think has
           changed from where we were before is the recognition
           that we need to allow in our inspectors, and that the
           Commission needs to allow the licensee to
           appropriately put that in the framework of the
           corrective action program.
                       For too long in the past, we would have
           inspectors who would identify a problem at the plant,
           and they would drive the licensee towards resolving
           that issue, irrespective from a risk standpoint where
           it fell on the corrective action program.
                       And I think that we have a much more
           sensitive notion now that we can bring these issues to
           the licensee, and leave the licensee with a challenge
           and the opportunity to place that in the appropriate
           area under the corrective action program, and deal
           with that in a timely and appropriate fashion.
                       Feedback from licensees.  At the end of
           the day, I always meet with the top level management
           of the licensee.  The reason I do that is that I want
           to get some feedback from them on how we are doing,
           and I want to give them some candid feedback in terms
           of how I think they are doing.
                       Some things that have come out of those
           meetings I think is a uniform recognition that the new
           reactor oversight process is working.  There are some
           concerns that I have heard in a variety of plants.  
                       Security, and the OSRE program, and that
           has something which has a lot of notoriety, and
           certainly has the attention of me and I think the
           other members of the Commission, and it is something
           that we are looking at.
                       We have the SPAR program that we are
           rolling out, and there are a lot of questions that go
           along with that, but one that we will continue to
           vigorously pursue over the next few years.  
                       Fire protection.  In our new oversight
           framework, do we have a program that appropriately
           judges fire protection, and that is a question, and I
           will discuss that a little bit further later on.  
                       Finally, the conduct of investigations. 
           We have a discrimination task force right now looking
           at harassment and intimidation issues.  This is an
           issue which clearly raises the concern of plant
                       I have talked to line staff, and folks who
           are the welders and the pipe fitters, and the
           electricians, who raise concerns to me.  I have talked
           to the plant management who has concerns.  
                       There is a litany of folks who believe
           that we may have a better way of doing it, and that is
           clearly one, again, that I think the Commission is
           going to continue to take a look at.
                       During the last two years one of the
           things that I have tried to do in my plant visits is
           have an all hands meeting, and try to meet with a
           group of personnel at the plant to give them some idea
           of what the Commission is all about, and what we do in
           my own personal interactions.
                       Those meetings have ranged from 100 to 150
           people, and up to about a thousand people that I met
           with at the Beaver Valley site.  The reason that I do
           that is simple.  For many of the individuals at the
           plant, the only people that they have an interaction
           with at the plant are our resident inspectors.
                       And those are very positive from our
           perspective, and so I think it is useful for those
           licensees, and the individual members of those
           utilities, to have a greater understanding of the
           context for which the NRC has, and the role that we
           have and that Congress has given us in the cradle-to-
           grave regulation of nuclear materials and nuclear
                       I leave them with a message.  It is
           typical at many of the plants that I challenge them to
           make sure that they are not complacent.  One of the
           biggest fears that I -- well, not fears, but concerns
           that I have -- is that although we have I think a very
           high level of performance right now, we need to make
           sure that we and our licensees do not fall into the
           trap of thinking that we can't continue to move
                       I think we need to and we need to keep our
           focus on that.  Another issue that I frequently
           discuss is the issue of insularity.  As we have more
           and more plants coming under the umbrella of
           licensees, there is the ongoing concern that a utility
           with many, many sites, may consider that all of the
           best practices, all of the best knowledge, fall within
           that group of units, and that is clearly not the case.
                       Each licensee I think brings something to
           the table, and I encourage all of our licensees to
           peer review, and to go out to other plants, and to go
           internationally to see how other people do their work
           to make sure that they continue to be top performers.
                       Latent problems.  Clearly, we all need to
           be vigilant that while we are -- that we can say that
           we are doing a good job right now, but there may be
           issues that we failed to identify 20 years ago that
           may still be there.
                       And so it is those latent issues that may
           come back to bite us, and so again I challenge the
           individuals at those plants to be vigilant to those
           issues, and not merely to look at the report and say,
           yes, five years ago we checked that out and it was
           fine. It may be that that check may not have uncovered
           what is really a safety significant issue.  
                       License renewal.  I think a lot of credit
           should be given to our staff about the thorough
           disciplined and timely manner in which we have gone
           about pursuing the license renewal program.  Clearly,
           this is an effort which has some of the highest
           scrutiny among Members of Congress.
                       Overall, obviously we have worked our way
           through six units so far.  Currently, we have
           applications affecting a total of 14 units.  And as I
           have mentioned, I believe virtually all plants will
           seek license renewal down the road.
                       We have made a lot of progress in the
           timeliness of the way in which we have been conducting
           those reviews, going from what we thought was going to
           be 36 months, and to actually coming in at around 25
           months with Calvert and Oconee, and with ANO, we were
           able to bring that mark down to 17 months.
                       Well, why has that happened?  I think
           there is a myriad of reasons for that.  Part of the
           credit goes to ACRS.  I think there is a comfort level
           within the Commission that this group is taking the
           time and vigilance to make sure that those license
           renewals are thoroughly vetted so we can have the
           comfort that when we issue that, that we have the
           technical basis and foundation upon which to make our
           claims that that will be safe for an additional 20
                       I think some credit goes to the fact that
           the quality of license applications has improved.  To
           their credit, I think the members of NEI recognize
           that we need not keep repeating the same issues, and
           that the NRC has a series of questions that are asked
           relative to the initial units that there ought to be
           a clear identification in the follow-on applications
           addressing those issues as well.
                       At the end of the day, presumably the
           number of questions that we need to ask on any license
           application may be reduced because the licensees have
           taken the time to make sure that many of the questions
           are answered up front.  
                       Now, obviously there will be a continuing
           need for vigilance, and there will be issues that will
           emerge.  But I think we do have a greater discipline
           on the part of our licensees in that respect.  
                       On the part of our staff,I think the
           Generic Aging Lessons learned, and the Standard Review
           Plan, will also go a long way to having a program
           which is more regularized, and more disciplined, and
           will bring with it process efficiencies that will
           presumably allow us to review these renewal
           applications in the kind of timely manner that we have
           adjudged for ourself.
                       Now, will we ever be able to meet a six
           month deadline for license renewals?  I for one am not
           putting that litmus test on our staff.  At the end of
           the day, the important thing is that we conduct the
           reviews in a thorough manner, in a disciplined manner,
           so that we can make the assertion that we believe the
           extension of a license for 20 years will be safe.
                       What that is going to mean I think for
           this group is that the license renewal process should
           not become routine.  I don't think there is an
           expectation on my part -- and I have never heard of
           anyone who would say otherwise -- that the ACRS should
           merely be rubber-stamping what is going on with the
                       I think there is an expectation that you
           will do a thorough review, and you can and should, if
           appropriate, identify issues which the staff has
           failed to resolve.
                       For this agency to maintain the level of
           public confidence that we want, we need to have that
           important element of the ACRS review.  So, I would
           commit to you my own belief that it is important for
           you to continue the level of review that you have.  
                       The next topic that I want to address is
           the issue of power uprates.  Currently, we have 12
           power uprates under review, and within July alone we
           have approved five power uprates on the nature of
           around 1.4 percent.
                       The staff estimates are that we may have
           44 power uprate applications within the next five
           years, several of which obviously would be GE boiling
           water reactors seeking extended uprates in the nature
           of 15 to 20 percent.
                       And we also have information that
           Westinghouse may be considering uprates in that range,
           10 to 20 percent, for the Westinghouse and CE plants. 
           That is a lot of work for the agency, and there is a
           lot of expectation on the part of all of our
           stakeholders, and the public, that we review those in
           a thorough manner, again to make sure that we feel
           confident in the work that we are doing.  
                       Now, as it relates to small power uprates,
           the 1.4 percent range, I have discussed with a number
           of people -- and I think I may have mentioned to one
           or two members of this group -- that my concern that
           we were spending as much time on 1.4 percent uprates
           as we were on 5 to 7 percent uprates.
                       From a risk-informed standpoint, it is
           hard to understand or justify an equal amount of time. 
           So I think that in that particular area that there are
           indeed process improvements that can be made.
                       On the other end of the spectrum are the
           obviously extended power uprates.  When we have
           licensees coming in seeking uprates in that range, 15
           to 20 percent, I think there is a strong expectation
           on my part that the work of the ACRS in reviewing what
           the staff is doing has got to be very thorough and
           technically sound.  
                       Our staff has to have a solid basis for
           making an approval, or recommending an approval, of
           uprates of that magnitude.  I think the Commission has
           that expectation, and I have that expectation, and I
           would expect other members of the Commission would as
           well, and certainly I think the public does.
                       Those are -- well, obviously those have a
           significant level of concern.  I think that I have
           identified some of the numbers that we have right now. 
           What is that reflective of?  Well, when you go out and
           you visit the plants and you meet with the licensees,
           is clearly reflective of the nature of the power
           market right now.
                       What licensees will say is that one of the
           most efficient methods from a cost benefit standpoint
           of generating new power is to provide power uprates at
           the existing fleet of plants.  Dollar for dollar on a
           kilowatt basis, that is some of the most cost
           effective ways of doing it.
                       And that is all well and good, but to the
           extent that we can feel comfortable about doing that
           that it is safe, that's fine.  But as we go down this
           road, I think we do need to be vigilant in terms of
           making sure that we are having a sound, technically
           appropriate evaluation of that.
                       And ACRS obviously is a key component. 
           And the final mention I would say on this topic is
           that it is going to take a lot of effort.  And in
           terms of all the other demands that we have coming
           towards the Commission, we, the Commission, are going
           to have to evaluate the resources that we put into it.
                       With all of the topical reviews coming in,
           GE is the one that we are pursuing right now, and
           Westinghouse, if it indeed pursues the programs for
           the Westinghouse, the CE plants, that is a lot of work
           to be done, and a lot of challenges for all of us, and
           those will have to keep on top of.
                       The new reactor oversight process -- and
           I have talked a little bit about this already, but I
           do think that this is an area in which the Commission
           as a whole, the staff, can take a lot of pride in a
           lot of very positive work.
                       Now, what we felt very confident for a
           long time in the process that we used to inspect and
           determine the level of safety at these plants,
           obviously there were a lot of questions about that.
                       And ultimately that led us towards a more
           risk-informed reactor oversight process.  One of the
           things that I have noted to many people is that I
           think that this new process, with the performance
           indicators in the more risk-informed inspection
           program, is more readily accessible to members of the
           public, because it allows more timely access to the
           performance indicators through our website.  
                       And I think the average members of the
           public who live around the plants, and work around the
           plants, are interested in plant performance, have a
           tool available to them now where they can make
           comparisons of how one reactor is operating relative
           to another.
                       And I think it gives more information
           available to our stakeholders to allow them to make
           their own choices, and to make their own reviews.  And
           one of the things that you see is a lot of the members
           of the press picking up on this.
                       When I and the Commissioners get a stack
           of clips every week of the newspapers around the
           country who are reporting on us, and frequently now
           you see reports tracking the NRC website that include
           that reference to it, and I think that is a good
                       One of the sidelights, and certainly going
           into the process wasn't something that we necessarily
           expected, but I think one of the side benefits of our
           new inspection program and the performance indicators
           is that we have had increased public confidence that
           we were in fact keeping on top of these plants.
                       Now, some of that may be that the public
           is just more informed about what we were doing as a
           regulator, but I think that it is a more objective,
           predictable, consistent, and transparent methodology
           that the public can use to assess that information.
                       The other part of the new inspection
           oversight program that I think is important is the
           emphasis on the licensee corrective action program. 
           As I mentioned before, the fact is that we had at some
           points in the past inspectors who were driving the
           licensee towards giving end points, which were not
           necessarily from the standpoint of the risks
           associated with the plant, weren't necessarily the
           right place to be.
                       It may have been a personal interest of an
           individual inspector.  With the framework and
           discipline that we have in the new inspection program,
           I think it allows us the ability to say to our
           stakeholders, be it Congress, or be it members of the
           public, to State Legislators, or to others, that we
           have a disciplined framework that we can apply to all
           of the plants.
                       And that we can give a greater level of
           assurance that the same level of safety oversight is
           being given, and that when we put our imprint that we
           believe that the plant is operating safely, that we
           have a greater basis upon which we can make that
                       By allowing items to be identified, and
           allowing those to go into a licensee's corrective
           action program, I think that again allows the licensee
           go manage the plant in the most appropriate fashion.
                       We are identifying areas where there are
           concerns, and they are putting those from a risk
           perspective in the right portion of their action plan,
           and making those things happen.  I think that is good
           for the licensee, and I think that is good for us, and
           I think that is good for the public as a whole.
                       Are we in the perfect place yet, and I
           think the answer to that question is no.  I think that
           the new reactor inspection oversight program is a work
           in progress.  I think it is going to continue to
                       Clearly, there are areas that we are
           focusing on for continued improvement.  Safety system
           unavailability.  There are some disconnects between
           the way in which we evaluate that, and the way that
           WANO evaluates that, for example, and that has been a
           concern amongst some licensees.
                       I know that the staff is engaging with the
           utilities to see if we can resolve some of those
           issues, and I look forward to reviewing where the
           staff is going on that matter.
                       Unplanned power changes.  There are many
           licensees who have come to me and who have said that
           we are concerned about that particular indicator
           because in the current marketplace there may be an
           economic reason for on a weekend taking a piece of
           equipment down for a time to work on it, which from a
           risk standpoint makes a lot of sense.
                       But the way in which our performance
           indicators are picking that up might not necessarily
           be in concert with that, and I think that continued
           dialogue on that issue on the staff's part is a good
                       The significance determination process has
           been one that I think has challenged a lot of people. 
           It has been more timely and time consuming than in
           fact we had thought.  It has been rather cumbersome,
           and it has been something that there has been some
           growing pains on.
                       One thing that I think is positive is the
           fact that we will be completing I think later this
           month the SDP notebooks that will be available on a
           plant-specific basis.
                       I think that is going to make it easier
           for our resident inspectors to deal with these things
           in a timely manner, and obviously for the other
           inspectors, be they in regions or at headquarters,
           that will do it as well.
                       But again continued focus on that I think
           is going to be something that the staff is going to
           have to work on.  There are specific SDP concerns that
           have been raised relative to security, fire safety,
           ALARA, and these are areas in which arguably we didn't
           have the degree of scrutiny in our old inspection
           program that had been brought out.
                       And so I think that is a positive thing if
           we are looking, for example, a lot more at fire
           protection and ALARA than we used to.  How we deal
           with those -- and they are a little trickier to deal
           with than the SDP program -- the staff is going to
           continue to have to work on that.
                       And again as I say, it is something that
           I am looking forward to getting what the staff's
           suggestions are.  One of the issues that has been
           raised about the new program is the issue of no-color
                       We go in and we find a no-color finding,
           and that is not necessarily transparent to the public
           what we mean by that, and I think we need to have a
           continuing dialogue both within and outside of the
           agency about how we can better define and justify no
           color findings.
                       I mentioned how our resident inspectors
           are sharing their insights with licensing management. 
           I think that is a positive thing.  I think that both
           the licensees think that is good, and I think our
           inspectors feel comfortable that they can do that.
                       We need to make sure that we are doing
           that in a balanced manner, and not going too far out. 
           But I think right now we are about where we ought to
                       There is some issues coming down the line,
           and I don't have any answers to necessarily define an
           opinion on them, but research, for example, is looking
           on the issue of risk-based performance indicators.  I
           look forward to those recommendations.
                       I don't have a specific opinion one way or
           the other, but obviously there are concerns about
           going down a risk-based road, and we need to deal with
           that carefully and appropriately.
                       New plants.  This is an obviously -- well,
           there is a possibility for a staggering amount of work
           before the Commission and before the ACRS.  I think
           that the earliest thing that we will obviously see is
           the issue of early site permits, and something that we
           may see in this fiscal year and the next fiscal year,
           and testing out that portion of Part 52.
                       Pebble-bed modular reactor.  There is a
           lot of discussion about that.  Everyone has a lot of
           interest in that, and certainly Exelon has been
           spending a lot of time on it.  There are a significant
           amount of challenges.  They are a non-water reactor.
                       There are obviously the technology which
           is out there, and that the Germans have done a lot of
           work on, and the Chinese have an operating pebble-bed
           reactor, which I did have the opportunity to visit.
                       But there are things associated with that
           reactor that we don't have necessarily the right level
           of comfort with right now.  There are different types
           of fuels, and significant use of graphite are in the
           reactor itself.  
                       Braydon cycle turbines and the effects
           that that may have on operations of the unit, and what
           type of confinement/containment structure that may
           have, and a lot of policy issues go along with that
           particular design which may be a challenge.
                       The AP1000, obviously there is a lot of
           work that Westinghouse may bring before us in that
           regard, and in their efforts, and in one which I
           believe we will have to deal with in a timely manner.
                       Some which are out there, but certainly
           knocking on the door, is the General Atomics reactor,
           and Westinghouse's IRIS reactor, International
           Reactor, Isolated and Secure, Innovative and Secure,
           and regulatory infrastructure programs associated with
           these types of new reactors.
                       There is a lot of work out there, and are
           we where we need to be?  No, I don't think so, and the
           reason for my feeling on that is a little work that I
           had done.  
                       Last December, I put out a COMM which was
           adopted by the Commission, asking for the EDO and the
           staff to assess where are we relative to our resource
           capabilities on reviewing new reactors.  Do we have
           the right people and do we have the right dollars, and
           do we know what we need to do from a research and a
           regulatory standpoint in regards to those.
                       Our response from the staff is due on that
           in September.  I would expect that we will have a much
           more detailed understanding of the level of the staff
           expertise that we have out there, and what our
           existing regulatory infrastructure is, and how it
           relates to those innovative reactor designs, and where
           we need to go.
                       My hope is that that staff paper will give
           the Commission a better understanding of the
           challenges before us, and additional resources that we
           may need.  
                       Now, how does this relate to the budget? 
           This is something that the Commission has had to spend
           a lot of time worrying about.  Congress for its part
           in this fiscal year decided that in the fiscal year
           that we are in, decided to give us some additional
           money, $10 million.
                       There are questions obviously on how we
           are going to spend that.  Is that the right amount of
           money, or is that not the right amount of money.  I
           think the Commission has had a difficult balancing
                       Part of it is dealing with very high
           expectations.  There are a lot of possibles out there,
           and things that we may see.  That is balanced against
           making sure that we have a staff that is capable, but
           not a staff that overspends itself, either in terms of
           not having sufficient resources, or getting out too
           far ahead of where our licensees are going.
                       And so I think the Commission in its
           effort has tried to make sure that we are the right
           size.  I am very concerned about an over expectation
           of our getting too many things.  That we may plan for
           far more orders, and far more designs, and that far
           more or many more licensing actions than may
                       And so I think we need to deal with this
           carefully.  I think that we need to have an ongoing
           dialogue with our licensees, and with NEI to make sure
           that -- and with Congress, to make sure that we are
           asking for the resources that we need to do the work
           that we have and no more.
                       There are some issues out there that
           remain as challenges.  Programmatic ITAAC.  This is
           something that I think that we are going to have to
           grapple with, and before we see reactor orders, I
           think we are going to have to resolve that.
                       I think the staff now is working with NEI
           to try to bridge some differences that we have and see
           where we go.  
                       Early site permits.  Clearly, we need to
           understand if we are in the right place relative to
           Part 52, and our staff readiness to deal with those
           early site permits, and those questions need to be
           asked, and certainly will.
                       How will we deal with the regulatory
           infrastructure for non-light water reactors.  We
           clearly are not there yet, and if we had an
           application for a pebble-bed reactor, along with some
           of the time lines that have been thrown out there, we
           would have to detail an exemption space in certain
           issues, and fill in as we go, in terms of a regulatory
           infrastructure, utilizing what we have available to us
           right now.
                       Finally, construction inspection.  Now,
           that may come sooner rather than later.  I had a
           chance to go out and visit WMP1 out at Hanford, and
           although that facility has not been in an active
           construction status since 1983 or so.  
                       When you walk through it, because of the
           nature of the high desert atmosphere out there, and it
           almost looks as if construction stopped two months
           ago.  In some of the welds and large-bore piping, they
           are very, very clean.
                       The work put together by that licensee to
           make sure that they understood and they had the
           quality assurance documentation in place, such that it
           could be picked up by another contractor down the
           line, was readily apparent.
                       We may see that come forward.  I don't
           know.  That is a licensing choice, and that is
           something that they are currently evaluating.  There
           is a lot of news right now about what TVA may do
           relative to Browns Ferry One or other sites.  
                       Who knows.  Who knows.  But it may involve
           us having to sooner rather than later think about how
           we go about construction inspection.  There are a lot
           of issues that ACRS is clearly going to have to
           grapple with.  
                       And having a role in licensing and design
           certification is clear.  That is clearly a foremost
           role of this group.  Review of new plant designs. 
           ACRS has had a long and starred position in that
           respect, and will continue to as we have if we do in
           fact have reactor designs.
                       Fuel issues dealing with the pebble-bed,
           and the differences in that fuel is something that we
           are going to have to take a look at, and certainly we
           will depend on your analysis to provide us the
           technical basis there as well.
                       The development of regulatory
           infrastructure in non-light water reactors.  We need
           to make sure that we have the appropriate licensing
           basis to make sure that we have the confidence so that
           we can tell the public that we are doing it right, and
           we need your help in making sure that we get there.
                       Continued review of the NRC's research
           program.  I am going to go into a little bit more
           detail there, but clearly that is an ongoing role, not
           only in terms of the statute, but in terms of the
           expectation on my part of this group.  
                       Finally, risk-informed, performance based
           regulations, an ongoing issue, and one which will
           clearly play into the area of new plant orders and new
           plant designs if they materialize.
                       Risk-informed regulation.  I think all of
           us, and I know I certainly say, that this is a double-
           edged sword, and I think everyone has to realize that. 
           I think licensees have to recognize that as we pursue
           a risk-informed path that may mean that there may be
           increased regulation to reactors.  
                       On the part of our staff, it may mean that
           as we go through this that there may be areas that we
           have to reduce unnecessary burden.  It goes both ways. 
           I think that the staff did a positive job, in terms of
           working through the South Texas exemptions relative to
           special treatment requirements.
                       We have obviously work in front of us
           relative to Option 2, this proposed rule for April of
           2002; and currently the Commission has before it
           papers relative to 50.44, combustible gas
           requirements, and 50.46, risk-informing ECCS.
                       Now, on the last two, these are I think
           very sensitive issues, combustible gas requirements
           having come out of TMI, and obviously a significant
           amount of concern on a variety of important
           stakeholders about how we go about emergency core
           cooling systems.
                       Now, these are high priorities for the
           industry, and yet for our part, we need to have a
           strong technical understanding of what these mean. 
           And before I take a vote on those issues, I want to
           make sure that we are going in the right direction,
           and we have that basis, that safety basis, for moving 
           forward in a confident manner.
                       An issue which has been of significant
           interest I know to the Chairman is the issue of PRAs. 
           It is clear that there is not a uniformity within our
           licensees in terms of quality of PRAs.  I think it is
           positive that licensees have been putting in an
           increased amount of effort in terms of peer reviews on
                       I think it is positive, for example, that
           Dominion has invited David Lochbaum in to be part of
           their peer review effort.  I think Dominion should be
           congratulated for that.  I think hopefully that will
           be a positive experience for them.
                       Certainly Mr. Lochbaum is going o be
           vigilant in his comments, but I think -- and as they
           have been in many cases -- they will be thorough and
           well considered.
                       On the part of ASME and ANS, obviously
           there is work there as well.  Having greater
           uniformity within the ASME process I think is a very
           positive one.  
                       On the issue of ANS and the lower power
           and shutdown conditions, and the PRAs for those, I
           think that effort is a positive one as well.  As it
           relates to the ASME, our TAs, the Commission's Tas,
           were briefed yesterday.
                       I believe that they are now on Revision
           14A of that particular effort.  There have been, I
           think, in the past significant differences between our
           staff and some of the other participants, upon where
           that effort is heading.  
                       What we were led to believe, or what the
           Tas were led to believe today, is that in fact there
           is convergence in that area, and that we are coming
           together.  And not to say that there aren't still
           issues out there, but I think convergence is underway.
                       In the case of ACRS, I think oversight of
           what we are doing as an agency on PRA, and having an
           understanding of what the licensees are doing in the
           utilization of PRAs, is quite critical.  
                       Overviewing the research program and how
           folks in research are using risk I think is obviously
           of foremost concern.  It is important, and I think a
           role that ACRS has, and will continue to provide great
           utilization for the Commission, at least for me, of
           the understanding of the scope in depth of the
           knowledge of the Commission staff on PRA.
                       And then again this is in an area where
           there is not uniformity, and I think the Commission
           has got to do as a whole a better job of making sure
           that we provide the training necessary so that our
           line inspectors, so that folks in the field, so that
           folks in headquarters, have the right grasp of PRAs as
           a tool, and we have it appropriately framed within our
           regulatory framework.
                       As part of that, I think it is important
           for the ACRS, when it perceives that the Commission
           does not have an understanding of risk, or where our
           understanding of risk is not commensurate with the
           regulatory decisions being proposed, that they notify
                       Now, obviously that is something that the
           ACRS has always done, but something that I think
           obviously will need to continue.  We need to have that
           signal from you when our staff may not be where they
           need to be relative to our framework.
                       For my part, in looking at Option 2 and
           Option 3, I am very much eager to find out where ACRS
           is on various of the elements there, and I hope that
           you continue as you do to keep I and other members of
           the Commission informed.
                       I don't think there are any particularly
           noteworthy issues that I would want to say in this
           regard that there is one that I would mention.  I know
           that I have discussed this with the Chairman, and that
           is related to NFPA 805, in risk informing our fire
           protection requirements.
                       I had a briefing initially on that some
           months ago, and I had some doubts as to whether after
           having gone through that effort to have a risk-
           informed option for fire protection, whether anyone
           would take advantage of it.
                       Now, if you spend a lot of resources to
           have a risk-informed option, and at the end of the day
           no one wants to take advantage of it, it is hard to
           justify the fact that you spent all that money.  
                       In the meantime, and I think since we have
           had our discussion, I think there has been some
           conversation between our staff, and between industry,
           and other parties about where we need to go on that,
           and I look forward to a further briefing from our
           staff in terms of where we are going, and how that may
           resolve itself.
                       The role of research.  I want to come back
           and credit Dana Powers again.  This is an area which
           I have spent a lot of time thinking about over the
           last few years, particularly as it relates to our
           budgetary process.  
                       Clearly, we do not have the resources
           available to us that this agency once had on research. 
           Dollar for dollar, you can make all kinds of
           comparisons, but we don't have what we once had. 
                       What that means is that we have to treat
           each dollar that we have ever more seriously, and make
           sure that we are getting the highest benefit from each
           one of those dollars.  
                       It also means that increasingly that we
           are going to have to -- that as an agency, we have to
           recognize that we, like utilities, aren't the sole
           source of knowledge on one given area.  
                       We can't be insular about our beliefs and
           our knowledge on the fuel for which we regulate. 
           Thirty years ago, clearly that wasn't the case, and we
           had a whole host of people that were looking to in
           this agency.
                       But today there are examples, I think,
           where we can look to our counterparts, whether it is
           in Switzerland, Japan, France, England, Germany, or
           elsewhere, who have capabilities that exceed ours that
           we should tap into and not necessarily attempt to
                       We should make sure that we can identify
           the areas which are most important for research that
           we do need to have capabilities to address to meet our
           regulatory framework.
                       And so the work that was done in that
           effort, I realize that is not something or a product
           of the ACRS that can or want to do every year to that
                       But it provided a very important tool for
           me, in terms of reviewing what are the dollars that we
           should be spending on research up and down, up and
                       I think it made for a more informed
           budgetary process for me, and certainly I would expect
           that it made it more informed for the other members of
           the Commission.
                       It provided insights on what research is
           doing well, and insights on things that research is
           not doing so well.  Now, I went back this morning, and
           I remembered the slides that had been provided to us. 
           I think it was in a meeting when we had a review of
           the research efforts.
                       And I think the framework -- and this is
           on page 5 of your slides -- is the work needed for
           NRC's independent examination of regulatory issues. 
           Has the work progressed sufficiently to make
           regulatory decisions, and should the program be
           modified to better meet agency needs.
                       And that is the real heart of the question
           that the Commission has gotten, and that the
           Commissioners have to ask in our process.  We need the
           information to make regulatory decisions.  
                       If we have the information, maybe
           sometimes we need to think about moving on and
           identifying those areas where we need to move the
           resource issues.
                       Now, going forward, there are obviously
           some daunting challenges for research; new reactor
           designs, extended power uprates, risk-informed
           regulation, extended fuel burn-up, MOX, fire
           protection; and a more emerging issue of control rod
           drive mechanism cracking; and steam generators, which
           has always been an issue.
                       There are a myriad of things that we are
           going to have to take a look at.  As we go along, it
           is important for I think the ACRS to look at do we
           have the right coordination between research and NRR
           to make sure that we are identified, and that is the
           heart of much of this, although NMSS is clearly
           important as well.
                       But do we have the right communication and
           coordination, and to identify areas, be they current
           needs or anticipated means.  Are we enhancing our
           technical capabilities to meet emerging challenges. 
           Are we linking our research programs to our
           performance goals, or our strategic performance goals.
                       That is one of the things that Congress
           obviously looks very closely at.  Are we communicating
           value.  Are we breaking down organizational barriers
           that are isolating people within our organization and
                       And are we appropriately leveraging our
           international resource initiatives, or are we dollar-
           for-dollar getting the best value out of our research,
           and I think that is an important criteria that we need
           to hear or I need to hear from ACRS, and it is helpful
           for me in the policy decisions that I have to make as
           a Commissioner.
                       Part of that is obviously assessing high
           priorities and identifying areas where the Commission
           and the staff needs to put more resources.  As a
           sidelight to that, I think the ACRS needs to be ever
           mindful during your reviews during the course of the
           year to identifying the areas where maybe enough is
           enough, or maybe we don't need to put as many
           resources, and I think we need to be mindful of that
           as well.
                       We do not have -- and I don't think there
           is an expectation among any of the Commissioners, nor
           in Congress, that there is an open path in terms of
           what we are going to be able to get for money.  
                       So we need to make sure that we are
           identifying not only the add-on's, but perhaps we also
           don't need to put as many resources, and I urge your
           continued thought on that matter as well.
                       I want to mention -- and this is the last
           part of what I want to say today, but we have had a
           lot of concerns about human capital, and it has been
           expressed by each and every member of this Commission.
                       So of what I am going to say is obvious,
           and many of you are within university communities, and
           so I am telling you things that you well know.  We
           have a level number of engineers coming out, but a
           dramatic drop in the number of nuclear engineers.
                       We have had a significant drop, and half
           of our research reactors have been shut down, and many
           very vital research reactors are under consideration
           to be closed.
                       Now there is a variety of dynamics for
           which that provides a challenge to the agency.  The
           first one from a human capital standpoint -- and I
           have been able to go out and visit some universities,
           and I have more planned to do so this year.
                       But when you go out to those universities,
           not only are there fewer people there in those
           university programs, but increasingly the percentage
           of those individuals who are foreign nationals is
                       So the yield that we can take advantage of
           for staffing our ongoing research needs becomes more
           complicated.  We can't always hire all of those
           people, and obviously for national security reasons.
                       And in some positions, we have got to have
           people who are American citizens, and so that is a
           challenge to us.  At the same time that we have a
           demand for that, those very same demands are within
           the industry itself.
                       They have many of the same demographics
           that we do.  Now, obviously the number of nuclear
           engineers in the industry is much lower.  They have a
           need for a much wider variation of engineers, of
           chemical, of electrical, of mechanical, of civil
           engineers, than we do.
                       But that level of expertise and having the
           ability to tap into that is very, very important.  At
           the same time, we also utilize those research reactors
           and the staffs for basic research, the research that
           we are doing.
                       The University of Michigan is one that has
           a lot of questions, and are they going to continue to
           be there for us, and we spend -- I don't know what the
           dollar level is, but it is no small amount of money
           that the University of Michigan gets each year.
                       We spent some dollars there putting in
           special equipment so we could take advantage of that
           reactor, and that has been a very, very positive
           program at the University of Michigan.  
                       If they shut that down, that is a
           capability that we lose in our Office of Research, and
           where we are going to put that is an open question. 
           And so those reactors are very, very important to us
           for that reason as well, and as we talk about human
           capital, I think we also need to talk about research
           capital and the importance of those facilities.
                       I am pleased that the Commission has
           supported legislation on Capital Hill and introduced
           on both sides, which would provide additional dollars
           to university research programs.  
                       We have tried to encourage Congress not
           only to focus that on some of the DOE programs, but
           also on the need to be mindful of the NRC as well, and
           hopefully they will do that if that indeed moves
           forward down the line.
                       But we have got to maintain that focus in
           that area.  Now, in the discussions that I have had
           with industry, one other thing which I think is a
           little different, and I think we need to be mindful of
           -- and it is a little bit more difficult given the
           current nature of the economy, but for a long time the
           demographics within the industry have been the same.
                       We have a lot of folks there, and the
           average age in the plants is in the 40s, in the mid-
           to-high 40s.  For them there losing some of their
           profession, some of their engineers, but the loss of
           craft work is also very important there as well.
                       In the economy that we have had over the
           last 10 years, there is a lot of opportunities for
           welders, electricians, pipe fitters, and others in the
           crafts to go elsewhere at higher or equal or higher
                       And that is going to be a continuing issue
           for our utilities.  Can they attract and maintain the
           line staff to operate these facilities at the levels
           that we have become accustomed to, and that is
           something that I think we are going to have to --
           well, that is an issue that is appropriate for
           licensees to manage, but one that I think we certainly
           need to be mindful of.
                       There are a lot of issues there.  For all
           of us -- and the last point -- I would make -- I think
           Congress has been paying a lot of attention to us
           recently.  I think that attention has been somewhat
           more positive than it has been in the past.
                       When I came on board three years ago, I
           think there was a lot of criticism about the way this
           agency was run, and in the more recent discussions
           that I have had with Members of Congress, and in the
           more recent hearings that I have participated in, I
           think there is a greater belief that the Commission is
           on the right track.
                       We are more risk-informed, and we are more
           disciplined, and we are not as bureaucratic and red-
           taped oriented as we used to be, and we are providing
           a level of safety that the public expects, and at the
           end of the day that is the most important matter of
           them all.
                       So, with that, that is my presentation. 
           Unfortunately, I don't have a whole lot of time left
           because I have got a meeting coming up, but in the few
           minutes left, I can certainly take one or two
                       DR. APOSTOLAKIS:  Any members that would
           like to ask any questions?
                       DR. POWERS:  Let me first interject and
           thank you for the kind comments about the research
           before, but let me make it clear that that was very
           much of a committee product, and to the extent that
           maybe I orchestrated it, my name might be attached to
           it, but in fact all of the members contributed
           substantially to that.
                       COMMISSIONER MERRIFIELD:  I knew that and
           I apologize for not --
                       DR. APOSTOLAKIS:  For praising Dana.
                       COMMISSIONER MERRIFIELD:  No, I don't
           apologize for praising Dana.  I apologize for not
           fully appraising the entire committee.
                       DR. POWERS:  And I would want to say that,
           I, too, have worried a little bit about the
           ancillarity of the nuclear industry as we move to some
           consolidation in the ownership.
                       But fortunately I have had the opportunity
           attend some of the industry's fire protection forums,
           and where you get to see the continuation of a history
           of the exchanging of information within the industry
           of safety information.
                       And as we grow an interest in fire, I
           might invite you to attend one of those fire
           protection forums.  I think that you will see that it
           is an industry that is very healthy still in its
           ability to transfer within itself good practice, good
           safety practices in at least the fire protection area.
           And that has been gratifying to me.
                       COMMISSIONER MERRIFIELD:  And I would
           agree with that, although I would say that I think
           that has been an issue of no small debate.  I had a
           chance last year to go down to the INPO CEO forum, and
           there was a lively debate that occurred there amongst
           some of the CEOs about the level of sharing within the
                       And I think there are individuals of
           different minds on that matter.  For my part, I think
           that sharing is a good thing, whether you are a
           utility, whether you are a Commission.  You know, we
           share with our international counterparts and seek
           information from the as well.
                       And in nuclear safety, withholding of
           information is not the right thing to do.  Sharing is
           the right thing to do, and I hope the utilities
           continue to follow that premise.
                       DR. APOSTOLAKIS:  And maybe one last
                       COMMISSIONER MERRIFIELD:  Yes.
                       DR. KRESS:  Well, recently the new reactor
           oversight process has been much on our minds and
           agendas.  And we wonder -- well, there seems to be a
           lot of enthusiasm for it out there among almost
                       We wonder if that enthusiasm is brought
           about because it is mainly more transparent and more
           acceptable, and an easier thing for everybody to do,
           as contrasted to perhaps its real technical
                       And is it doing what it is intended to do,
           in terms of assuring that there is no undue risk from
           the specific plants.  I wondered if you might want to
           comment further on that.
                       COMMISSIONER MERRIFIELD:  Well, I mean,
           obviously that is an area where we want to have ACRS
           continue to keep an eye to it.  I use fire protection
           as an example, and I think in the old process that we
           did not take a look at fire protection to the extent
           that we needed to.
                       And I think the new system does.  I think
           we are conducting inspections on fire protection on a
           much more disciplined and vigilant manner than we
           were.  If we were pursuing this program, and weren't
           finding problems, then I would have more questions
           about it.
                       The fact is that the new program is in
           fact identifying areas that we had missed before, and
           picking out areas where we needed to do a better
                       So is it perfect?  No, I don't think it is
           perfect.  Will it continue to evolve?  Yes, it will
           continue to evolve.  Is it better than what we had
           before?  I think so, and I think there is uniformity
           in that respect.
                       Is it technically better?  Yes.  I am
           hearing that it is, and I think there is some
           indicators that are out there that would lead one to
           that conclusion, but obviously if there are some
           concerns, we can continue to probe.
                       We should not be satisfied with the
           product.  We should continue to improve it, and to the
           extent that we can identify the urge to improve, we
           should certainly move forward.  
                       DR. APOSTOLAKIS:  Well, thank you very
           much, Commissioner Merrifield.
                       COMMISSIONER MERRIFIELD:  Well, thank you
           for allowing me to come in and share some of my
                       DR. APOSTOLAKIS:  That's great.
                       COMMISSIONER MERRIFIELD:  I know that this
           isn't always something that you have had an
           opportunity to do, and it is very helpful for me.
                       DR. APOSTOLAKIS:  Thank you. 
                       COMMISSIONER MERRIFIELD:  And any
           reactions that you have, I look forward to a
           continuing positive dialogue.
                       DR. APOSTOLAKIS:  Good.  Thank you.  Okay. 
           We will recess until 10:20.
                       (Whereupon, the meeting was recessed at
           10:03 a.m. and resumed ats 10:29 a.m.)
                       DR. BONACA:  The meeting is called to
           order.  We are now going to review TRACG, best-
           estimate of hydraulic code, to head this session.
                       DR. WALLIS:  Thank you.  I was not at the
           subcommittee meeting on August 22nd, and Paul Boehnert
           has just come around and said that I should never be
           allowed not to be at a committee meeting because of
           issues that I may raise later on. 
                       I was the November 13th one, however, and
           let me give you an overview.  This is a code which has
           been around for a long time.  It has various features
           in some hydraulics which one can question, but that is
           true of all codes.
                       And what GE has done is they have applied
           it to these anticipated operation occurrences using
           the CSAU methodology.  And whatever the defects may be
           in the code, if you do a proper assessment of
           uncertainty, then that takes care of them.
                       If it is a bad code and has big
           uncertainties, and it has a better code, it has lower
           uncertainties.  but the whole issue of best estimate
           code is that it is an estimate code, and you estimate
           the uncertainties quantitatively.  
                       And best is really not the right
           adjective.  As you get a better code, you get smaller
           uncertainties, but the real issue here is that you
           must quantitatively assess the uncertainties.
                       And I think what is impressive about what
           GE has done is that they have done that.  They went
           through the CSAU methodology, and whatever may be the
           faults in the modeling in the code, this comes out in
           the assessment of these uncertainties, using CSAU, and
           in comparisons with data.
                       And the comparisons with data for these
           plant occurrences I think we will see, and what we saw
           in November are really pretty darn good.  So the
           conversions are good, and they have gone through an
           exemplary exercise, or it appears to be an exemplary
           exercise, in using this methodology.
                       And the staff, and another thing which is
           very important in this, is that the staff has had the
           opportunity to exercise the code.  So if there are
           strange things about the code, the staff has had a
           great opportunity to run the code and try to find
                       And I think that is a very important
           reason why the staff, and we, and why we would have
           confidence that the staff has done these things and
           that the code is robust, and indeed stands up to the
           tests that they have put it through, as well as GE has
           put it through.
                       So personally, unless there are some
           surprises coming up, I don't think that it matters too
           much that I wasn't at the subcommittee meeting.  But
           now maybe Tom Kress would like to add something to
           what I have said.
                       DR. KRESS:  I think you have covered it
           pretty well.  I think we had a number of questions
           that we had and that were raised at the previous
           subcommittee, and I think that the presenters at the
           next subcommittee did a very laudable job in
           addressing those particular questions.
                       DR. WALLIS:  So, I think that we really --
           who is first, is it the staff,or --
                       MR. BOEHNERT:  Yes.
                       DR. WALLIS:  The staff is first.  Ralph. 
           It is a great pleasure to welcome Ralph Landry back to
           make a presentation to this committee. 
                       MR. LANDRY:  Thank you, Dr. Wallis.  My
           name is Ralph Landry, NRR, the staff lead on the
           review of the TRACG code.  I would like to give just
           a brief overview of some of the topics that I want to
           hit on rather lightly this morning with the time
                       We can't go into a great deal of detail,
           but I would like to give you an overview of what we
           did in this review, and what some of our findings were
           in the review.  So I would like to very briefly talk
           about the time line, and when we received the code,
           and what has led up to this draft SER.  
                       And how we approached the review to the
           code, and the applicability of the code, and some of
           the assessment, and our evaluation, our traditions and
           limitations which we have stated in the draft SAWYER
           on the use of the code.
                       And we would like to point out that when
           we get to that point that these conditions and
           limitations really are an extension of the code beyond
           its requested review.  That the conditions and
           limitations which we have stated are those which would
           be imposed should the code be taken beyond its stated
                       Some of our conclusions, and then I would
           like to touch on the lessons learned.  Dr. Wallis
           talked about the review of the code and what we have
           done in this review, but this is the third code that
           we have reviewed in the past 2-1/2 years, the third
           thermal-hydraulics code that we have reviewed.  
                       And in each of those reviews, we have seen
           a different presentation of the code, and different
           support of the code, and the application of the code
           has been different.
                       But we have learned something and I would
           like to touch on some of those lessons that we have
           learned in this process.  
                       MR. BOEHNERT:  Ralph, let me interrupt a
           second.  I should have said this before you came up,
           but I need to make a statement that both Dr. Ford and
           Dr. Bonaca are in a conflict of interest for this
           session because of owning GE stock.  But that needs to
           be on the record.  Thank you. 
                       DR. POWERS:  Do we maintain a quorum?
                       MR. BOEHNERT:  That's a good question. 
           Well, they can be present here in the room.  So that
           should not be a problem regarding the quorum.
                       MR. LANDRY:  Okay.  A quick overview of
           the time line.  We received preliminary information on
           the code in the spring and summer of 1999.  These were
           times when the applicant, General Electric, came in
           and then presented to us what they wanted to do with
           the code, TRACG, and how they wanted to approach the
           approval process, and gave us an overview of the code
                       We started receiving the actual submittal
           in January of 2000, and that submittal was completed
           in February of 2000.  This was submitted in sections,m
           the documentation, and finally the last piece we
           received was the code itself.
                       We received the code in both source form
           and in executable.  So that we were able to install
           the code on a computer.  We were able to install its
           executable, and we were able to build an executable
           version of the code.
                       DR. WALLIS:  And you were executes for the
           plants, too.
                       MR. LANDRY:  Plus, we have received some
           input from the applicant.  In November 2000, as Dr.
           Wallis pointed out, we met with the ACRS thermal-
           hydraulic subcommittee, and presented a number of the
           results of our review of the code, and the applicant
           presented an in-depth detailed overview and discussion
           of the code and its capabilities.
                       In July of this summer, we formally issued
           our REIs, and in August, we formally received the
           response to those REIs.  What we have done is follow
           the course that we have with the other code reviews,
           and we feel like this has been very successful.
                       Where we have come up with questions and
           concerns, and have shared those with the applicant
           during the course of the review, those are informal,
           and we have sent E-mails to the applicant, and told
           them what our concerns were.
                       They would respond informally with E-
           mails.  Some of those requests resulted in further
           requests, further requests for clarification, and
           meetings, and phone conversations, and until we
           finally arrived at a point this summer where we said,
           okay, we have all of our questions listed for the
           application in this code.
                       We went through the formal process of
           management approval, and issued the formal request for
           information to the applicant.  Of course, they had
           been interacting with us for the past year-and-a-half,
           and knew what the questions were, and knew what the
           answers were, and were able to respond immediately
           with a formal set of responses.
                       We prepared our draft safety evaluation
           report in July, and we shared that with the
           subcommittee, and met with the thermal hydraulic
           subcommittee two weeks ago, at which point we
           discussed the findings of our draft SAWYER.  
                       Now, how did we approach this review. 
           TRACG, as Dr. Wallis pointed out, has been around for
           quite a while.  It is a decedent of the TRAC-B code
           developed INEL, or now INEEL.  
                       The code was submitted several years ago
           during the SBWR review, which was subsequently
           withdrawn.  The code was submitted at that point for
           a LOCA application to SBWR and received a very
           extensive review, both by the staff and by the
           contractor, BNL, located at the National Laboratory.
                       DR. SHACK:  Is that a best estimate LOCA
                       MR. LANDRY:  No, that was for an Appendix
           K application at that point, and that will come up
           again.  During that review the code received an
           extensive thermal hydraulic review, thermal hydraulics
           capability, and --
                       DR. WALLIS:  Excuse me, but did the ACRS
           get involved with that?
                       MR. LANDRY:  Yes, the ACRS was involved in
           a good part of that review also.
                       MR. BOEHNERT:  We had some subcommittee
           meetings on it, but I don't believe we had a formal
           review with the full committee, because the review was
           terminated because the project was terminated.  
                       MR. LANDRY:  The decision of the staff was
           because of the nature of the application of the code
           at this point for anticipated operational occurrences
           that what we would try to do would be to look at the
           review that was done for SBWR and build on that
           review, rather than go back and do an in-depth thermal
           hydraulic review of the code.
                       We tried to build on what was done, and we
           only asked a few REIs on the thermal hydraulic aspects
           of the code which were pertinent to the application to
           the AOO transients which were pertinent to the
           application to the AOO transients.
                       Instead, we felt that it would be more
           productive if we would apply our resources to a more
           in-depth review of the neutronics of the code, because
           there was a 3-D kinetics package in the code.  
                       If you will remember when we reviewed the
           RETRAN 3-D code, the 3-D for RETRAN was referenced to
           the neutronics package, and not to thermal hydraulics. 
           We did such an extensive review of the neutronics of
           that code, and because this code also had a 3-D
           neutronics capability, we wanted to focus heavily on
           the neutronics capability because we knew that the
           package was different than that which we saw in the
           RETRAN 3-D code.
                       And we knew that it was going to be
           different than that which we have in our own TRAC-B
           Nestle combination.
                       DR. WALLIS:  Can I ask you something here? 
           When you ran the code, you also ran the thermal-
           hydraulics part of the code?
                       MR. LANDRY:  That's right.
                       DR. WALLIS:  And you actually tried
           various things with that to see if it was giving the
           right response?
                       MR. LANDRY:  Yes, we ran some full-plant
           calculations also.
                       DR. WALLIS:  And you didn't just do
           neutron kinetic  --
                       MR. LANDRY:  Right.  We have run the code
           in other areas.  But we wanted to focus our review on
           a couple of areas that we felt would be very important
           for AOO transients.
                       One thing that -- and getting to Dr.
           Shack's question, when the code was submitted prior to
           this, it was not as a statistical or realistic LOCA,
           but now it is being submitted as a statistical or
           realistic AOO code.
                       It is being submitted to take advantage or
           utilize the CSAU methodology to support and defend the
           code's capabilities.
                       DR. WALLIS:  And by statistical
           methodology, you mean CSAU?
                       MR. LANDRY:  Yes.  We were focusing on the
           uncertainty analysis which was provided in support of
           the code.  Questions came up about, well, shouldn't a
           code be reviewed in depth on every single thing it can
                       Well, we really can't have that leeway
           with a code.  When it is submitted for AOO transients,
           we can't go back and support a complete review of
           every single aspect of the code, and every potential
           application of the code, because the code is not being
           applied for that.
                       It would not have been fair to the
           applicant to review the capabilities of this code for
           a LOCA application, because it was not submitted for
           a LOCA application.  
                       It is going to be submitted for a LOCA
           application though, and so we are going to get a shot
           at that.  General Electric has informed us that they
           are coming in in the first quarter of 2002 with a
           realistic CSAU LOCA application for the code.
                       And we will get a chance at that point to
           do another look at the thermal hydraulic capabilities.
                       DR. WALLIS:  Well, the statistical
           methodology is tied to the application.
                       MR. LANDRY:  Correct.
                       DR. WALLIS:  And you go through the
           application and look at the uncertainties for the
           predictions for that particular application.  And if
           some professor at some university shows that the code
           does a poor job of protecting her experiments, let's
           say, in a lab which has nothing to do with a reactor,
           that is irrelevant isn't it?
                       MR. LANDRY:  It can be.  It can be
           relevant if you can show the uncertainty in the
           important parameters.
                       DR. WALLIS:  As it applies to --
                       MR. LANDRY:  And are the parameters for
           the application represented properly in that
           experiment, and are the parameters important, and how
           do you represent those parameters, and what is the
           uncertainty in the way you represent those parameters.
                       DR. WALLIS:  I think that this is
           something that we need to perhaps say clearly though,
           is that there are models in the code which will not
           represent full separate effects tests done everywhere
           by everybody.
                       MR. LANDRY:  Correct.
                       DR. WALLIS:  And you can always find tests
           on which the code does a lousy job.  If there are too
           many of those, I guess you worry, and I guess you have
           to say are the same lousy jobs present in this
           application, and you have to do the investigation.
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  And if they are not present
           in this application, they don't matter; is that a true
                       MR. LANDRY:  Maybe they are less
           important.  I would not want to be so harsh as to say
           that they don't matter.  I would rather say that they
           are less important, or we have to understand the
                       DR. WALLIS:  Yes, they do understand the
           importance, and they turn out to be small, and that
           you don't worry so much about it.
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  And if it is small enough in
           terms of some evaluation criteria, it does not affect
           your approval of the code?
                       MR. LANDRY:  That's correct.  I would also
           like to point out at this time that all of the codes
           which were received thus far for review have been
           submitted prior to the staff's issuance for comment of
           draft reg guide 1096 and the draft SRP.  
                       This was the first time that we have seen
           a submittal of a transient analysis tool under the
           evaluation of CSAU methodology.  This was using the
           full CSAU methodology, and this is the first time that
           we have seen such an animal coming out.
                       The applicability of the code.  I don't
           want to go through all of the transients within these
           categories.  These are just the major categories that
           the code was going to be applied to.  
                       And increase and decrease in heat removal
           by the second system.  Decrease in reactor coolant
           flow rate, and reactivity and power, distribution
           anomalies.  These do not go into the area of
           reactivity insertion accidents, such as rod ejection,
           or stability analysis, and I will get into those in
           comments later.
                       DR. WALLIS:  But some of these are
           actually supported by plant data and real transients?
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  Do you recall which ones of
           these there is real plant data on?  Maybe we will get
           into that later.
                       MR. LANDRY:  I think GE may have some
           comments on that later, and I would rather defer to
           them and have them -- because not all the plant data
           were used for the full assessment.  Plant data were
           used in assessments specifically --
                       DR. WALLIS:  This is something where
           unlike large break LOCA, you don't have plant data?
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  But we do have plant data,
           and that gives us much more assurance that the code is
           being realistic if it can predict that data?
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  I think that is one of the
           things that helps us to agree with you if we are going
           to do so.  It helps us to agree with your conclusions.
                       MR. LANDRY:  Well, that will lead that
           into the next slide.  The assessment code that was
           performed included the phenomeological tests that Dr.
           Wallis was referring to a few minutes ago, separate
           effects and integral tests, but also plant operational
                       BWR-based in the country has a large
           database of operational data.  Start-up test data, and
           specific tests that have been performed, plus
           operational occurrences.
                       And the data that are available from those
           occurrences -- the main stream line isolation valve
           closures, the turbine trip tests that are performed --
           provide us with a database wherein we can take scaling
           effects out of the assessment process.  
                       You don't need to do a scaling report, a
           scaling assessment report, when you have full-sized
           plant data.  So, scaling is one; whereas, if you do
           phenomenological testing, now you worry about are you
           scaling the phenomena properly.  
                       DR. WALLIS:  Can I ask you another
           question now then?  GE did some evaluation of their
           code against plant data.  Did you run the code and
           assess it against plant data?
                       MR. LANDRY:  No.
                       DR. WALLIS:  So we have to go on GE's
           assessment there?  What did you assess it against?
                       MR. LANDRY:  We ran cases, some sample
           cases, to determine how the code performs, and to see
           if it was performing full plant cases --
                       DR. WALLIS:  Excuse me, but the one thing
           you could have done was to say, okay, let's take this
           plant data that they fit so nicely with the code, and
           see what happens if we try and do it, and maybe tweak
           things in the code.
                       MR. LANDRY:  Well, for the big plant data,
           one specific area where we did run was a narrow focus
           on the neutronic capability.  We ran some of the
           neutronic cases which we had from the full-sized
           plants in looking at the neutronics packages.
                       DR. WALLIS:  But then that still is not
           independent of the thermal hydraulics are they?  You
           have to know the reactivity, and the effective voids
           and things.
                       MR. LANDRY:  Yes.  Those were run by Tony
           also.  So, let me ask Tony to respond to that.
                       MR. ULSES:  Let me jump in here.  I am
           Tony Ulses, now of the Office of Research.  I need to
           catch my tongue here.  What we did was that we set up
           a sample problem, which was basically similar to what
           we did in the RETRAN work, where we were looking at a
           reactor that was initially specified by me to be a
           very easy problem to set up.
                       It is not a real reactor, and it will
           never run, but we also did run the test cases that
           were given to us by GE, basically, and we did run the
           Peach Bottom deck.  
                       But beyond looking at the output to make
           sure that it was the same output that was in the
           licensee document, we did not go in and run any safe
           assessment for the sensitivity test.
                       DR. WALLIS:  So you did get the same
           output for --
                       MR. ULSES:  Oh, sure, yes.  But that was
           run to confirm that the deck was actually giving us
           the same answer that was in the actual licensing
           documents.  But going in and actually varying
           parameters, no, that was not done in this case.
                       DR. WALLIS:  And it might have given you
           some more assurance that it was a robust code, and if
           you varied some assumption or whatever, you might be
           a bit suspicious about whether it was within the
           uncertainty estimates of GE or something then?
                       And it would be useful to do that, rather
           than just checking that you get the same run that they
                       MR. LANDRY:  Right.  As I said earlier,
           part of this review process has been a learning curve. 
           We have learned a lot of lessons, but we have tried to
           focus each review on what we thought was the most
           important area for each code.
                       Continuing with the code assessment, one
           of the things that we did point out, and that GE has
           taken care in, in their assessment reports, is to make
           sure that the nodalization for the plants is
           consistent with the nodalization that was assumed and
           used for all the assessment and uncertainty analysis
                       Now, this of course comes right out of the
           CSAU recommendations.  Part of phenomena
           identification, a ranking table was prepared, as
           required for CSAU analysis, and if we are going to
           correlate the phenomena with the test, and with
           quantitative assessments that were performed in
           support of the code.
                       All of the medium and high-ranked
           phenomena listed in the PIRT were assessed in the
           uncertainty analysis.
                       DR. WALLIS:  By GE.
                       MR. LANDRY:  By GE.  And the assessment
           shows the capability in the code to represent the
           experimental and operating data.  Some brief remarks
           on the thermal hydraulics, and some observations.  As
           we have pointed out in the past, it is a two-fluid
                       It has six conservation equations; boron
           transport equation, and non-condensible gas mass, and
           it uses a two-regime unified flow map.  And while this
           can be criticized --
                       DR. WALLIS:  Excuse me, but is this a one-
           dimensional model?
                       MR. LANDRY:  Yes.  Now, this can be
           criticized as being rather restrictive.  The two-
           regime map is acceptable and does cover all the
           normal, and operating, and anticipated transient
           regimes that would occur in a BWR.  
                       Questions have been raised about the
           applicability of the map for a LOCA.  Those questions
           were raised during the SPWR review, and questions were
           raised on the mixture level TRACing model for a LOCA.
                       Those are items which General Electric is
           aware of which we discussed with them, and which we
           will be reviewing when they submit the code for the
           realistic LOCA next year.
                       The old TRACG code, TRAC-B code, took the
           kinetic energy term out of the energy equations to
           make the solution easier.  However, that creates
           problems in that you end up with non-conservation of
           energy, and energy unbalanced.  
                       The kinetic energy terms have been put
           back in and retained in the energy equations for
           TRACG, and this helps to avoid energy balance errors. 
           We do point out in the draft SAWYER that there was a
           question raised on the GEXL correlation, the critical
           boiling length correlation.  
                       This question came up not with GEXL in
           general, but with the specific application of GEXL14. 
           Those questions came up during the power uprate review
           that was being performed by the staff, independent of
           the --
                       DR. WALLIS:  Was this the one that our
           computer was used to generate data?
                       MR. LANDRY:  Well, General Electric does
           have other data that they can use in support of
                       DR. WALLIS:  But this is the one isn't it? 
           This is the case where --
                       MR. LANDRY:  Yes.
                       DR. WALLIS:  -- they used the computers to
           generate data, which were then regarded as being data?
                       MR. LANDRY:  Yes.  That was one of the
           things.  That review is ongoing and is coming to a
           closure, and because GEXL is used within TRACG, we
           wanted to make sure that we had not left any doors
                       And we wanted to be sure that because we
           knew this other review was going on, and questions
           were raised, we wanted to have closure of that same
           issue with TRACG.  This is not a unique TRACG
                       But when the GEXL14 question is resolved
           by the staff, that resolution will be applied to TRACG
           also.  The inclusion of the comment was intended to
           bring closure and to alert future reviewers of
           applications of the code, that this question had come
           up, and to make sure that the closure has been taken
           should they be looking at an application of the code
           relying on GEXL14.
                       The basic component models are used as
           building blocks, as with TRAC-B.  We also noted in and
           wanted to point out, that there is a full-sized steam
           separator validation in the code.  
                       Full-sized steam separator data are
           available, and very good data, and are used to
           validate the steam separator model in the TRACG code.
                       DR. WALLIS:  Now, the NRC has its own TRAC
           code, which is no longer worked on.
                       MR. LANDRY:  We have TRAC-B, and --
                       DR. WALLIS:  But research has its own TRAC
                       MR. LANDRY:  Yes.  
                       DR. WALLIS:  So you have an opportunity,
           or they must have run it on something.  They just
           didn't develop it.  Have they run it on these kinds of
                       MR. LANDRY:  I am not sure what research
           is going with the TRAC-M code.  
                       DR. WALLIS:  Well, presumably they use it
           for something.  Didn't they try to evacuate some
           transients with it?  It is not just --
                       MR. ULSES:  Actually, Dr. Wallis, by --
                       MR. LANDRY:  Well, in his new job in
           research, Tony is involved in --
                       DR. WALLIS:  I think it would be very
           useful if -- and I think we have said this in our
           letters, that besides this running the user code, NRC
           runs its own code on the same problem.  This engine
           has a TRAC, and it would be interesting to see if the
           two TRACs give the same answer on the same TRAC.
                       MR. ULSES:  By no small coincidence, Dr.
           Wallis, I happen to be working as we speak on the
           TRAC-M assessment and we are actually participating in
           the international standard problem, looking at the
           Peach Bottom assessment, and we are actually going to
           be comparing the codes to the plant data.
                       DR. WALLIS:  So we have some of the same
           problems with the NRC code.
                       MR. ULSES:  Yes, sir.  
                       DR. WALLIS:  But you have not gotten any
           results yet; is that correct?
                       MR. ULSES:  We are in the process of doing
           that, right.
                       DR. WALLIS:  So we don't want any
           surprises do we, or it would be interesting if there
           were surprises.
                       MR. ULSES:  Well, we hope not.  Actually,
           I wanted to make another comment on the question of
           assessment that you asked, Dr. Wallis.  I think maybe
           you were kind of driving at the question of the user
           effect on the code, and that might be based a little
           bit on our experience with our previous reviews, where
           the user had the ability to really go in and make a
           lot of changes to the internal mechanisms of the code.
                       I think what you are going to find is that
           with the TRAC series of code is that the user does not
           have nearly as much flexibility.  In other words, you
           can't go in and specify a Weber number, for example,
           in the TRAC input deck.  
                       I mean, that is in the code, and it is
           there, and the user can't go in and change that.  So
           the user effect is obviously there, but it is not
           nearly as large as we have seen in the past.  
                       DR. WALLIS:  But in the NRC code, you can
           do these things.
                       MR. ULSES:  Well, I can go into the source
           code, and change it, and recompile it certainly.  But
           the input itself, you can't go in and say -- well,
           make it change as I was talking about before, and like
           in the previous codes that we have reviewed without
           naming names.
                       MR. LANDRY:  Names are being withheld to
           protect the innocent.
                       DR. SHACK:  Or the guilty.
                       MR. LANDRY:  Or the not-so-innocent.  I
           would like to address very briefly now the neutron
           kinetics, since we did spend a great deal of time
           looking at the 3-D kinetics in the code.
                       The focus as we discussed already was on
           the code, and does the code work, and why does it
           work, rather than on how.  The emphasis was on
           execution of the code, and in particular execution of
           the kinetics package.
                       Comparisons to benchmark data and
           comparisons to our own TRAC-B Nestle combination.
                       DR. POWERS:  When you say focused on, does
           it include work, and why does it work?  Could you tell
           me a little more about what you mean by that, or are
           you speaking in a numerical method? 
                       MR. LANDRY:  We did not go in depth
           looking at the numerical methodology, and looking at
           the derivation of the equations, but rather what was
           looked at is whether the code predicting data from
           such items such as the Peach Bottom test, and does the
           code predict the SPERT test, the SPERT-3 test, well.
                       Does the code compare with our code in
           predicting the same test.  When we did a prior review
           of the 3-D capability, we were showed how or found how
           our code and the other codes, the 3-D kinetics
           capabilities compared, and compared extremely well.
                       We wanted to see how this code's 3-D
           kinetics capability, which was a little bit different
           approach, compared with our code, because we already
           had two codes that looked almost the same, and now how
           is this one going to look compared to what we have.
                       DR. POWERS:  So it was more of the black
           box approach?
                       MR. LANDRY:  Yes.  Until we ran into a
           problem.  In this process, we ran into a problem and
           found that we did not understand why the two codes
           were predicting very dramatically different results,
           and started looking at the input data, the structure
           that generated the input for the two codes.
                       And we found that -- and I will get into
           that later, but that one of the lessons that we
           learned was we had to be very, very precise in
           specifying the problem, especially thought problems,
           and we also had to look at the upstream codes and
                       When you have upstream methodologies that
           are very old, or that rely on a very limited number of
           groups, you get results that are very hard to compare
           with methodologies that are much newer, and are using
           multi-group techniques.
                       So when I say we were trying to look at
           how our -- well, not look at how, but look at why
           there are differences and do they work, this is where
           the focus was.  
                       What is the difference between these two
           methodologies and why is there a difference, rather
           than how does this code work.
                       DR. WALLIS:  So you did this for
           neutronics -- I mean, you compared TRACG with TRAC-B?
                       MR. LANDRY:  Right.
                       DR. WALLIS:  But you did not send the
           thermal hydraulics to do something similar. It was
           like comparing TRACG with TRAC-M, which would be the
           complimentary thing to do with the thermal hydraulics. 
           So you have just done it with the neutronics?
                       MR. LANDRY:  Right.
                       DR. WALLIS:  Now, we wrote a letter to the
           agency suggesting that work be done on Y codes work,
           despite the differences in assumptions, and despite
           some of the assumptions being unusual.  
                       And we have gotten a reply that it was
           difficult to do this, and it was going to be very
           expensive, and so on, and you seem to be doing it
           anyway to some extent through these neutronics.
                       MR. LANDRY:  But if you remember, Dr.
           Wallis, at the beginning, I said that we were focusing
           our review in specific areas.
                       DR. WALLIS:  But I think we ought to take
           some lessons from this; that you found it useful to
           run the NRC code and the GE code as far as neutronics
           goes, and make comparisons, and look at the reasons
           for differences, and ask why, and to figure it out,
           and to resolve those differences?
                       MR. LANDRY:  That's correct.
                       DR. WALLIS:  And this may be a good
           example of how things should be done with the thermal
           hydraulics end of things in the future.
                       MR. LANDRY:  You are getting into my
           lessons learned; and, yes --
                       DR. WALLIS:  And maybe we are on the same
                       MR. LANDRY:  No, we are on the same
           course.  This is TRAC, but we are on a different
           course.  We are in full agreement.  In other reviews,
           and our stepping back and saying how should we
           approach other reviews, with each review what should
           be the focus of the review.
                       And we learned so much in this review, or
           we learned so much on every review, and on this
           particular review, a value in doing just what you are
           talking about, a detailed comparison.
                       And that that same philosophy can be
           applied, and probably will be applied in future
           reviews in other areas as the need arises.  And
           continuing with the kinetics examination --
                       DR. WALLIS:  Well, let me say that this
           gives a lot of public confidence if you can do that. 
           If you can say that we have done independent runs with
           some NRC code which we understand, and this has given
           us a basis for evaluating the other code.
                       And we have learned as we have gone along
           about perhaps faults of both codes, but the result is
           a better understanding and a better judgment about
           what is acceptable.
                       MR. LANDRY:  Yes.  We agree with you, and
           we are making strides in those directions.  
                       DR. WALLIS:  I hope that you will have the
           staff to be able to continue doing it.
                       MR. LANDRY:  That is out of my control. 
           Some of the conclusions on the kinetics review, we
           felt that the code does capture the relevant physics. 
           We felt that the documentation was adequate for
           internal General Electric use.  
                       We did have some criticisms of the
           documentation, especially in the kinetics area. 
           However, we felt that because the code is used
           internally, and it is not put out in the public
           sector,the applicant controls the education and
           training of the users, and has the capability to fill
           in where there are gaps.
                       So it is adequate for internal use, even
           though we felt that it could have been better.  We
           felt that the test problem definitions that we based
           on ABWR code design was good, but we did learn that we
           had to be very specific and very careful in defining
           test problems.
                       We felt that there was reasonable
           assurance that TRACG can model the AOO transients.  
                       DR. POWERS:  Well, you have to be very
           careful in defining problems.  Presumably that is a
           lesson that we learn about everything.  Can you tell
           me more here?  Are you telling me that it is
           impossible to define a problem well?
                       MR. LANDRY:  No, but it just means that we
           have to do more homework in defining the problem to be
           sure that when we define it that it is going to test
           what we want to see tested, and it is not going to
           mislead us into an examination of something that is
           occurring that isn't relevant.
                       DR. POWERS:  Okay.  So it is not a case of
           reaction to the statement.  Okay.  I find it very
           difficult to -- in challenging to define a test
           problem, and test some -- to compare against some
                       And I am going to use this calculation to
           calculate something that I have not been on, and I can
           never be sure that I am actually getting what I think
           I am getting out of it.  That's not what you are
                       MR. LANDRY:  No.  That means that you have
           to be very cautious when you set up that problem to be
           sure that what you get out is what you want to get
           out.  It doesn't mean that you can't get it, but it
           means that you have to be very careful to make sure
           that you are focusing in on the problem that is real,
           rather than a problem that is not.
                       DR. WALLIS:  What does it mean by -- what
           do you mean by this "reasonable assurance TRACG can
           model" statement?  TRACG can model anything presumably
           and get some answer.  What is your criterion for
                       If they run the code, what is your
           criterion?  Is it because it is close enough to the
           data or isn't the assurance that the uncertainty
           evaluation is sound.  Therefore, when you do your
           figure, you have got a good assessment of how close
           you are to some boundary, and what is the chance of
           stepping over it and all that sort of stuff?
                       MR. LANDRY:  It is looking at the
           uncertainty evaluation that was performed and saying
           the uncertainty evaluation is well done.
                       DR. WALLIS:  Is it good enough for
           regulatory use?
                       MR. LANDRY:  But in this case, or in one
           of the cases that we are looking at, is a thought
           problem, a made up problem, and we look at the problem
           and say, okay, it is a reactivity transient.
                       The peak powers are different, but it is
           over an extremely short period of time, and when we
           look at the longer period of time for that transient,
           we see that even though the peak powers are different,
           the energy deposited over the entire transient is the
                       And if the right phenomena are occurring
           and are in the right spots, and --
                       DR. WALLIS:  So the uncertainty and the
           overall power is small?
                       MR. LANDRY:  Right.
                       DR. WALLIS:  So you have some sort of
           acceptance criterion which says that the uncertainty
           has to be within some limits or something, or you just
                       MR. ULSES:  Well, actually, let me jump in
           here.  Basically, what that statement is intended to
           mean is that if you look at the review of the kinetics
           package in its entirety, including both the test
           problem that -- called the GE validation against
           experimental data on all of the other work that we
           did, basically the bottom line conclusion was that the
           effect of any of the -- well, I am just thinking how
           best to put this.
                       That was really intended to discuss the
           fact that as Ralph said, we did have some -- well,
           some malingering differences in the prediction of
           power for the sample problem.
                       However, the effect of those differences
           on the bottom line answer for AO transients, which is
           the effect on changes in the minimum critical power
           ratio, was effectively nil, and actual what I mean by
           nil, was that it was basically almost impossible to
           see the effect.
                       But that's the relevant output of all of
           these transients.  We do all this stuff with all these
           big codes, and we get one number out of it.  
                       DR. WALLIS:  What number did you get for
                       MR. LANDRY:  Well, this is just looking at
           this transient.
                       MR. ULSES:  Right.  This is how it is
           applied in actual licensing of the plants.  I mean,
           that's what they use to set the operating limits of
           the plant.
                       DR. WALLIS:  I see.  Well, the criteria
           for accepting this code are that there is reasonable
           models over physics, and that is part of it.  But the
           other part of it is that when you make a prediction,
           you can also predict the uncertainty.  
                       Now, that is the requirement for the best
           estimate code isn't it?  Now, what the staff does with
           that I think is still up in the air.  The use of the
           code may be able to do all the things with CSAI and
           predict all these uncertainties.
                       But I don't think the staff has really
           thought through what it is going to do with these
           uncertainties when it gets them, and that's where I
           think we have also mentioned in our letters that, yes,
           our codes are doing all these things that we have
           asked them to do, and you need a measure of the
           predictions, and the answer, and the causes of all the
           answers and all of that.
                       But what are you going to do when you have
           got that?  I mean, there has still got to be some
           relationship with these uncertainties to margins and
           acceptance criteria, and so on.  
                       I am not sure that the staff really has
           thought that through.  Do you have any comments on
                       MR. LANDRY:  At this point, we would just
           have to say we are continuing to study that, and we
           are trying to define.
                       DR. WALLIS:  Well, that's typical.  I
           mean, you see, there must be a criterion, some
           acceptance criterion, when they want to uprate the
           power to some point where it is meeting some boundary.
                       Then how big the uncertainties are in the
           code are very important to know, and whether you may
           step over that boundary or not.  So it seems to me
           that maybe the acceptabilities then are going to
           depend upon the use.
                       Yes, they have got a good code, and they
           have an assessment of uncertainty, and then look at
           something like power uprate, and start using this
           code, and then you can figure out perhaps how big the
           uncertainty or what is the effect of the uncertainty
           on your decision about whether or not they should be
           allowed to uprate power.
                       MR. CARUSO:  Dr. Wallis, this is Ralph
           Caruso from the staff.  We do actually have some
           criterion in this area for AOOs.  For example, we set
           a safety limit minimum critical power ratios to ensure
           that 99.9 percent of the rods don't undergo boiling
                       I think that your question is what does
           reasonable assurance mean, and I think that the ACRS
           has had this discussion with the Commission in the
           past about what reasonable assurance means, and I
           don't think there has ever been any definition that
           everyone has agreed to.
                       This is an eternal question that we try to
           deal with, and it comes out of judgment to a large
           extent at this point.  When we can quantify it, for
           example, and say setting safety limit MICPRs, we try
           to do that.
                       We are trying to do our regulation in a
           more risk-informed manner, and that is another attempt
           to do it in a more quantifiable way.  But right now
           these are the words that the law requires us to use to
           make a finding.  
                       So those are, unfortunately, the words
           that we use and they are not well defined.
                       DR. WALLIS:  But the law requires you to
           make a finding with 95 percent confidence.
                       MR. CARUSO:  No, the law requires us to
           make a reasonable assurance finding.
                       DR. WALLIS:  If your criterion is 95
           percent confidence, then the fact that they have
           evaluated these uncertainties enables you to make that
                       MR. CARUSO:  We could say that a 95
           percent confidence does define reasonable assurance,
           but --
                       DR. WALLIS:  That is the thing that I
           think is not being worked out yet.  I mean, you have
           got the tools to do it, but if someone comes around
           like tomorrow and says reasonable assurance is 99
           percent, then you have still got the tools to do it,
           but where you come out on allowing some change in the
           plant may be different.
                       MR. CARUSO:  I really hate to pass the
           buck on this, but I do believe that this has been the
           subject of some extensive discussions with the
           Commission about the definition of reasonable
           assurance, and I don't believe that anyone has come up
           with an acceptable definition for all the parties
                       DR. WALLIS:  So maybe my --
                       MR. CARUSO:  This is a little bit beyond
           my pay grade as they say.
                       DR. WALLIS:  -- saying that you have got
           a good tool is, but the staff isn't quite sure how to
           use it, is a true statement.
                       MR. CARUSO:  I can't explain why.  I don't
           want to get into philosophy on this particular issue.
                       DR. WALLIS:  It is not philosophy.  It is
           really very real.
                       DR. KRESS:  Yes, and in a number of our
           letters, we have commented that the staff needs to get
           more into formal decision criteria, and this is
           exactly what we mean by formal decision criteria.  How
           do you use these uncertainties to make our decision.
                       And you would come up with some sort of a
           technical definition of reasonable assurance that way,
           and we said that in a number of letters.  And I think
           it could be repeated over and over.  I think it is
                       DR. WALLIS:  And the reasonable assurance
           probably should be risk-informed.  If it is not
           important to risk, then you can do it with less
           assurance perhaps.
                       MR. CARUSO:  And there is a lot of effort
           going on in that area for a formal decision.  
                       DR. KRESS:  And that would be part of the
           formal decision process.
                       DR. WALLIS:  That is part of a broader
           picture.  So, maybe we should move on. 
                       DR. KRESS:  But I don't think that is
           these guys' job.  They just have to be sure that the
           code can -- well, I agree with you that if there is
           reasonable assurance that it does the uncertainty
           correct, then they have got a basis for saying its
           okay for this.
                       MR. CARUSO:  As a lower level engineer, I
           would be thrilled if someone could define the term for
           me, but I have not seen it defined yet.
                       MR. LANDRY:  Okay.  Moving on to
           experience, user experience with the code, some of the
           things that we wanted to point out from our use other
           code was that TRACG uses input decks that are very
           closely related to the TRAC-B specification, which
           means that a person who is knowledgeable in any of the
           TRAC codes can come in and with a very minimal level
           of training become proficient in the use of TRACG.
                       So it opens up a pool of people who have
           the capability of using the code proficiently.  That
           major changes between TRAC-B and TRACG are well
           described in the report.  
                       We do feel that and we have said to
           General Electric that additional guidance to the user
           would be useful on time step size selection.  We also
           point out that the General Electric Company has
           developed a set of standard input decks, and standard
           input specifications, for the code.  
                       This, we feel, is a big step forward in
           reducing the user effect, and as we have seen in other
           code reviews, users can have a great effect on results
           by how they specify the input deck.
                       A lot of that has been taken out with the
           code and with its internal use with the company.  So
           that the user effect is reduced significantly.  
                       Some of the conditions and limitations
           which we specified in the SAWYER.  As I said earlier,
           these really are conditions and limitations which
           would apply to the extension of the code beyond the
           specified use of the code at this point.
                       And dealing with GEXL14, we have already
           discussed.  Our application to stability and ATWS
           analysis.  In the past, there were two reviews of the
           code, TRACG Code 4 stability analysis, and for ATWS.
                       Those reviews were done in an extremely
           focused and an extremely narrow way.  The application
           for stability was for setting set points, and what we
           wanted to do was to acknowledge that, yes, those
           reviews had been done for that specific purpose.
                       And that use of that code in general to
           stability and ATWS would be far beyond the conduct of
           those reviews, and far beyond what we have done in
           this review.
                       So that if the code is to be applied for
           stability analysis or for ATWS, that it should be
           reviewed further for those specific applications. 
           That this is not approval for those applications.
                       DR. WALLIS:  Doesn't this also apply to
                       MR. LANDRY:  Yes.
                       DR. WALLIS:  Why didn't you say that?
                       MR. LANDRY:  Because this is transients.
                       DR. WALLIS:  So by implication, LOCAs
           would not be included?
                       MR. LANDRY:  By implication, LOCAs are
                       DR. WALLIS:  So that is well understood by
           the language then?
                       MR. LANDRY:  This is anticipated
           operational occurrences.
                       DR. WALLIS:  And that is well understood
           by GE, too.
                       MR. LANDRY:  LOCA is not an AOO.
                       DR. WALLIS:  Because I think there was a
           concern that this was a sort of back door approval. 
           That you approved the code for one thing, and then GE
           says, oh, you approved it for this, and therefore it
           is good for everything.
                       MR. LANDRY:  This is not an approval for
                       DR. WALLIS:  Okay.  Thank you.  Can we
           move to your conclusions?
                       MR. LANDRY:  Conclusions.  As we have
           talked about GEXL14 in the past, and we said that he
           kinetic solver is adequate to support the conclusion
           that the models are correctly derived in a competent
           phenomena, and involved in AOO transients.
                       We feel that the analysis that we have
           performed give confidence that TRACG can be acceptable
           for AOO transients.  We believe that the uncertainty
           analysis follows accepted CSAU analysis methodology.
                       We were very pleased to see a transient
           code come in applying the CSAU methodology. 
           Uncertainties and biases have been identified in all
           of the highly ranked phenomena based on experimental
           data, and have been validated.
                       The bottom line is that the staff finds
           the TRACG-02A code acceptable for application to the
           AOO transients presented in the submittal.  So the
           lessons learned, we touched on all of this already.  
                       We have reviewed three codes, and each
           code has been unique in its application, and in its
           submittal, and in its support.  Each of the codes were
           submitted prior to the draft REG guide and draft SRP
           section being released to the public.
                       The review that we have seen so far is
           that CSAU can be used successfully to support a
           transient methodology.  That it is not limited to LOCA
                       As we have talked about already, when you
           generate a thought problem, you have to use a great
           deal of care in generating that problem to be sure
           that the problem is going to focus in and test what
           you want tested, rather than mislead you, and lead you
           down the wrong path.
                       But we also have learned from the
           discussion from this review that the upstream codes
           that are used should also be reviewed.  We should have
           access to upstream codes.  
                       If a code is used to set lattice physics
           parameters, we should look at that methodology if
           those parameters become important to the kinetics
           package and for the application of the code, for
                       The experience from these reviews has
           taught us a great deal about the usefulness of having
           a code and being able to exercise a code, and even if
           we exercise specific parts of the code, we have
           learned a great deal from that process.
                       And a great deal that we would not have
           learned had we not had the code in-house, and had we
           not had the code, we would not have gone down the
           wrong path on the kinetics examination.
                       But we would not have learned things about
           the background for the kinetics input that we did
           learn in this process because we had the code.  Having
           the code in-house has been an extremely useful tool to
           us, and has helped us a great deal in the reviews.
                       And as Dr. Wallis has pointed out, there
           are areas in which we can improve in the code and
           having to put in-house, and other areas that we can
           examine further for official reviews.
                       This has been a building process for us,
           and from each of these codes we have learned something
           in the review process, and we have been able to build
           in the way that we conduct each of these reviews.
                       DR. SHACK:  What is a best estimate AOO
           code buy for it?  
                       MR. LANDRY:  Well, in this case it can
           change the operating limit, the minimum critical power
           ratio.  You can use it to set your set points, and
           your power ratios, more accurately, more
                       DR. WALLIS:  Do these set limits on
           something like power uprates?  
                       MR. LANDRY:  I'm sorry?
                       DR. WALLIS:  Do these transients limit
           power uprates in any way?
                       MR. LANDRY:  Yes.  This can buy you in the
           power uprate arena.  When the code comes in for review
           for LOCA, that can buy in in the larger power uprate
           arena also.
                       There are a lot of applications for which
           understanding margin -- and maybe we should say
           understanding margin rather than reducing margin.  But
           understanding the margin available can help you if you
           want to increase power, or if you want to change
           operating limits.
                       MR. CARUSO:  In discussions with the
           vendors, we have learned that a lot of them use these
           margins not just necessarily to raise power, but for
           example, to reduce -- for example, to reduce diesel
           generators start time requirements, or to reduce valve
           stroking time requirements.
                       And they give the plants more breathing
           room and a better idea of where the cliffs are, and a
           better idea of how they can operate their plans.  So
           it is not just that they can raise power and make more
                       It is that they can operate more safely
           because they understand where the limits are.  
                       MR. LANDRY:  This concludes the staff's
                       DR. WALLIS:  Thank you very much.
                       MR. LANDRY:  And I believe that General
           Electric is next on the agenda.
                       DR. WALLIS:  Are we going to close this
                       MR. BOEHNERT:  No, they intend to have an
           open session.
                       DR. WALLIS:  To have it completely open?
                       MR. BOEHNERT:  And then close, if
           necessary, in final discussions.  
                       MR. ANDERSEN:  Okay.  I'm Jens Andersen,
           and this is my colleague, Fran Bolger, and we are here
           representing GE, and I am pleased to make this
           presentation to the ACRS.
                       It deals with the application for
           Anticipated Operational Occurrences, which can be
           abbreviated to AOO,or also called transient analyses.
           What I would like to do is, and primarily for the
           benefit of the ACRS members that have not participated
           in the previous thermal-hydraulics subcommittee
           meetings, is to just give a brief overview of the
           scope of the TRAC application, and the application
                       And then I would like to discuss some of
           the issues associated with the review, the NRC review,
           and the reviews with the ACRS thermal-hydraulics
                       As Paul Boehnert said, the presentation
           that I have here I tried to keep it non-proprietary
           and it is completely open, and there are some slides
           that I may want to use, and which may contain
           proprietary material.
                       TRAC is a realistic goal for BWR
           transients analysis.  TRACG is the GE version.  I
           don't know if you know, but back in 1979, a project
           was initiated to generate a BWR version of TRAC.
                       It clearly started from the PWR version,
           and that was at that time, it was rejoined an NRC-EPRI
           and GE project.  And that project lasted through a
           couple of phases, and finished in 1985, and that was
           clearly what we saw in the first TRAC-B version.
                       What we have done in GE is that we have
           continued the development of the code.  We have
           incorporated some of our GE proprietary models, and
           probably most significantly we have incorporated the
           same nuclear message that we use in our current design
           and licensing evaluation into the code.
                       And that is probably the major additions
           in TRACG.  The code has the capability to do a lot of
           different type of analysis, including LOCA, ATWS, and
                       However, in this submittal, we have
           focused on the application to AOO transient and that
           is all that we have asked for the NRC to approve.  It
           does have some capability to do multi-dimensional flow
           int he vessel part, the model size, and essentially
           one-dimensional in the code.
                       It has a flexible modular structure that
           do allow the user to simulate virtually any problem
           that you want to simulate.  However, we have done
           extensive nodalization sensitivity studies as part of
           our assessment, and that is documented in the
           qualification licensing topical report.
                       And basically what we have done is that we
           have come up with a standard nodalization to use for
           BWR, and that is the one that we recommend for use for
           these types of calculations.  This is a nodalization
           that we will fix in our internal procedures for how to
           do these calculations.
                       The nuclear kinetics model is a 3-D
           nuclear kinetics model, and is essentially the PANACEA
           nuclear 3-D nuclear simulator model.  This is the one
           that we use in all of our current licensing analysis,
           and what is unique in this application is that we have
           implemented it, together with TRAC, and we are
           applying it for reactor transients.
                       Conservation equations.  The two fluid
           model simulating steam liquid also has the capability
           for boron and non-condensible gases.  However, these
           models do not come into play for AOO transients.
                       Boron would only come in for ATWS
           analysis, for example.  We have a relatively simply
           flow regime map, and it is used consistently by all
           components in the TRAC.  
                       For example, a jet pump component, or the
           components that we use to simulate the regions in the
           vessel, or the components that we use to simulate the
           steam line, all use the same flow regime map --
                       DR. WALLIS:  That's the same for the
           horizonal and vertical flow, and bends, and
           everything, is it?
                       MR. ANDERSEN:  The recognition was started
           by flow for a horizontal flow in the flow regime map,
           based on the critical part number.  However, most of
           the components, or virtually all components in the BWR
           where you have two-phased flow are vertical
                       And so the focus has been on the vertical
           flow machines.  Based on the determination of the flow
           machine, we then come up with a consistent set of
           correlations for heat transfer for that particular
           flow regime, and again that is used by all components.
                       And the users do not really have any
           options to change these models in the code.  We have
           models for all of the major components in the BWR. 
           The recirculation pumps, the jet pumps, the fuel
           channels, the steam separators.  
                       We have performed an extensive
           qualification based on separate effects, which are
           simple tests where you can isolate individual
           phenomena.  We have done component testing where we
           have looked at full-scale component data -- and let's
           say jet pump data, steam separator data.
                       We have done integral system effects test,
           and these are basically scale simulation of the BWR.
           These were primarily tests that were done for LOCA
           applications, but they do have relevance in showing
           the interactions between the various components in the
           BWR system.
                       And most importantly though we have full-
           scale plant data that we have used in the
           qualification, and that is important in dealing with
           the scaling issue, and essentially having the full-
           scale data means we don't have to address the scaling
                       DR. WALLIS:  When you do a CSAU, you have
           to make comparisons with data?
                       MR. ANDERSEN:  Yes.
                       DR. WALLIS:  And presumably all of these
           data, from separate effects test through full-plant
           data, play some role in the CSAU comparisons?
                       MR. ANDERSEN:  Yes, they do.
                       DR. WALLIS:  But you would expect that
           perhaps some of them should have more weight than
                       MR. ANDERSEN:  Well, what we have done is
           that we have used primarily the separate effects test
           and the component test to quantify the model
                       For example, we have full-scale wide-
           fraction data for a full-scale BWR bundle.  We have
           full-scale data for jet pump performance; and full-
           scale data for a full-scale separator.  
                       Those are the models that we have used to
           quantify the model uncertainty.  Now, we then went
           ahead -- and you are kind of getting ahead of my
           presentation, but I will answer the question now.
                       But we have then gone ahead and quantified
           all these model uncertainties, and the way that we
           used the data is that we applied our proposed
           application methodology to the plant data.
                       In the plant set, what we are doing is
           that one of our critical safety parameters as
           mentioned by Ralph Landry is the minimum critical
           power ratio.
                       And what we do is that we determine that
           at a 95 finding value, a 95 percent probability, a 95
           percent confidence, which is roughly a two-sigma
                       What we did was that we went in and we
           took plant data like the Peach Bottom turbine trip,
           and we applied our application methodology, and said,
           well, if we account for the uncertainty in predicting
           the wide fraction or the wide coefficient in the core,
           and the uncertainty in predicting the carry-on from
           the separator and so on, we took all these
           uncertainties and said what is the impact on our
           prediction, say, of the power response, which was
           mentioned at the Peach Bottom test, and we do that at
           the two-sigma level, then we show that we bound the
                       So we have used the plant data primarily
           as a confirmation of our application methodology.
                       DR. WALLIS:  This is a tremendous step
           forward from the days when people simply took some
           line through another point and looked at it, and said,
           oh, this looks excellent, or good, or maybe, or
           whatever, and made some qualitative judgment.
                       Now, there is a quantitative, logical
           basis for using data to assess the code.  I think that
           is what you are giving us an example of.
                       MR. ANDERSEN:  Yes.
                       DR. WALLIS:  And I think that is a
           tremendous step forward from the days of guess work
           and judgment, and just looking at some things and
           saying, oh, it looks good enough.
                       MR. ANDERSEN:  Well, that was clearly one
           of our lessons learned from the previous review under
           the SBWR program, and instead of saying this agreement
           is good, or this agreement is excellent, we tried
           everywhere in our assessment to put numbers, and to
           say, well, we predict these data within, for example,
           of 5 percent, or whatever the number is.
                       The scope is to apply to plants operating
           in the United States which are BWR-2 through BWR-6,
           and the events are the anticipated operational
           occurrences, and these are the events that increase
           and decrease, and react to pressure increase or
           decrease in core flow, and increase or decrease in
           reactor coolant and ventry, or decrease in core
           coolant and temperature.
                       And these are the primary classes for the
           operational occurrences.  
                       DR. WALLIS:  That is what you are trying
           to predict?
                       MR. ANDERSEN:  Those are the ones that we
           normally analyze to set the operating limits.
                       DR. WALLIS:  And which of your plant data
           covered which of these --
                       MR. ANDERSEN:  We have pressurization
           events, and we have a flow chain event, and we have
           one of the stability cases, and, for example, the
           LaSalle case that we analyzed that involved a decrease
           in the reactor coolant temperature.
                       We had a loss of feed water transients,
           and so we have had plant data in each of the event
                       DR. WALLIS:  This is another reason, I
           think, that the subcommittee felt some confidence, is
           that you had full-scale plant data for all of these
           transients that you were intending to analyze, unlike
           the LOCA situation, where you don't have that data.
                       MR. ANDERSEN:  Yes.  The documentation
           that we submitted to the NRC, this was the first
           document, and was really a document that laid out our
           plans.  We had early discussions with the NRC back in
           the spring of 1999.
                       Most of the licensing topical reports were
           submitted, and I think the first were submitted in
           December of '99, and the last in January and February
           of 2000.  The model description qualification report,
           a report outlining the application methodology.  We
           also submitted the users manual.
                       We submitted the TRAC source code, and a
           number of sample problems for the NRC to use in their
           evaluation, which included most of these plant cases
           that I described up here that we used in our
                       And what we were asking for was a safety
           evaluation for the applications AOO transient.  This
           is really a brief overview of the process, and what we
           decided to do was to adapt the CSAI methodology to
           transient, and basically follow the guidelines as they
           are described in the report that the NRC put out in
           the CSAU methodology.
                       And also in the guidelines in Regulatory
           Guide 1.157, which was really the application of the
           best estimate methodology to LOCA analysis, but that
           really laid out the CSAU process.
                       And we tried to follow that.  So it
           started with the first step, the identification of the
           plant and the events, which are the BWR226 and the AOO
                       And then we went through the phenomena
           identification and ranking process, where we looked at
           all of these event categories, and we looked at the
           importance of the phenomena by judging the impact on
           the critical safety parameters, and that is critical
           power ratios, the peak vessel pressure, the minimum
           water level, and the fuel thermal-mechanical
           parameters, such as maximum cladding strain, or market
           to assembly line melting in the fuel.
                       And what we did was that we addressed in
           our quantification of the uncertainty all high and
           medium ranked parameters.  I think the CSAU, the
           original CSAU methodology, only calls for the highly
           ranked parameters.
                       However, there has been a lot of
           discussion on whether medium will make high, and it is
           not really such a big deal to include the medium. 
           What you can do is that you can in many cases get away
           with just picking bonding numbers for the
                       And where you really want to sharpen your
           pencils are on the highly ranked, which are the really
           important parameters.
                       DR. WALLIS:  But you might find out when
           you do your qualifications and determinations that
           some of your mediums were really low, and perhaps some
           of them were high, and you learn as you complete the
                       MR. ANDERSEN:  And we learned something
           like that, and what we learned is that if you get
           enough experts together in the PIRT process, then
           everything becomes important.  
                       When we actually did the sensitivity
           studies, and we looked at the top 20 of what was
           important, there was only one of the medium that made
           it in there, and its impact was really insignificant.
                       The CSAU calls for starting with this
           process, and this is really how you evaluate the co-
           applicability and how you do the quantification, and
           the accuracy, and the uncertainty, because you look at
           the PIRT parameters, and you say, well, when you
           evaluate the code, you do it relative to what is
                       And we looked at the structure of the
           basic equations models and correlations, and in the
           merits, and basically what we did was that we cross-
           referenced that against the PIRT table, and for
           example, in the application methodology, there is a
           cross-reference that tells you that for each of the
           parameters, where do you have to go in the model
           description to find the documentation on that model.
                       Similarly, there is a cross-reference that
           says that for a given parameter that was judged to be
           important, where do you find test data that can be
           used to evaluate the accuracy of that model, and that
           can be used to quantify the uncertainty of that model.
                       The other thing that the CSAU called for
           is that you have to account for the effective reactor
           input parameters in operating States, and are you
           beginning a cycle or ending a cycle.
                       Uncertainty in plant parameters, and we
           have accounted for all of these, and then essentially
           at the end, you go ahead and you do your statistical
                       And what we do is that we calculate the
           statistical limit for the critical safety parameters. 
           For example, the minimum critical power ratio is
           evaluated as a tolerance limit at the 95 percent
           probability, and 95 percent confidence.
                       And there we really followed the
           guidelines that were in Reg Guide 1.157 for a LOCA. 
           That Reg Guide says that you have to use 95 percent
           probability, and it also says that two-sigma is good
                       And it turns out that when you do 95 and
           95, you are really close to two-sigma.  
                       DR. WALLIS:  Now, you referenced DG-1096
           in your slide.  Did that make any difference?
                       MR. ANDERSEN:  Well, DG-1096, as Ralph
           Landry pointed out, came out after we had submitted
           these reports, and I have looked at DG-1096, and I
           believe that we covered all the major elements in both
           DG-1096 and also in the requirements of the 
           Standard Review Plan 15.0.2.
                       DR. WALLIS:  And you don't have any
           disagreement with the methodology described in DG-1096
                       MR. ANDERSEN:  I don't think I have. 
           There can be discussions on the degree of detail.  I
           think the major elements are covered.  The only
           disagreement I had with DG-1096 is that DG-1096 has a
           significant emphasis on scaling, and I don't think
           that scaling is required in a case like this, where we
           have full-scale plant data.
                       DR. POWERS:  Okay.  I think maybe you have
           to change your thinking a little bit about scaling,
           instead of just being sized.  The full-scale plant
           that you have is not identical to the plant that you
           are calculating, right?
                       MR. ANDERSEN:  Well, the --
                       DR. POWERS:  The data that you have is not
           precisely for the plant that you are going to
                       MR. ANDERSEN:  Well, the data that we
           have, the plant data, are for different plant types. 
           For example, the Peach Bottom turbine trip is for a
           large BWR04.  We have data for Nine Mile Point Two. 
           That is a BWR05.  
                       We have data from LaSalle that is BWR05,
           and we have data from the Leibstadt plant, which is a
           BWR06.  We have data from most of the plants that are
           operating out there.
                       DR. POWERS:  But not the same dataset --
           well, is there a dataset for the same transient at 4,
           5, and 6?
                       MR. ANDERSEN:  We have -- well, for the
           pressurization event, we had that from the Peach
           Bottom, which is a BWR04.
                       DR. POWERS:  Now, what happens at a
           pressurization event at a BWR06?
                       MR. ANDERSEN:  We know, because they
           usually test that at the plant start-up testing, that
           it is milder at a BWR06 because of the much faster
           SCRAM speed.  
                       The other thing that was done in the Peach
           Bottom test was that normally there is a SCRAM on the
           position of the turbine control valve.
                       In the Peach Bottom test, that was
           disabled, and so you only had SCRAM and the flux,
           which made it a more severe transient.  So the Peach
           Bottom test really is more severe than what you would
           expect to occur in a real plant.  
                       DR. POWERS:  All I am suggesting is that
           maybe you need to look at the words in the CSAU
           methodology and translate them in comparison to what
           you have, and what you are going to calculate for the
           biases and things like that.
                       I mean, it is not -- you didn't use the
           word geometric scaling because by and for in most
           situations they are talking about is where someone has
           done some small test, and now they are trying to
           predict a plant.  
                       But you have a different situation, and
           you just have to interpret the words.
                       MR. ANDERSEN:  Yes.
                       DR. WALLIS:  It could be that some
           transients that you have observed took you into a
           region where certain things happen, and in some other
           transient, you might get into a region where something
           physically was different, and that would be a scaling
                       MR. ANDERSEN:  Yes.
                       DR. WALLIS:  And though it is at full-
           scale, you are into some region or diminimous group
           which we have not explored yet.
                       MR. ANDERSEN:  That's a good comment.  We
           have tried to address that in the model description,
           where we talked about the model.  In the sections that
           talk about, for example, friction, we have tables and
           paragraphs that discuss what is the range that you are
           expecting in the BWR plant, versus what is the range
           of the applicability of the models that we use.
                       So we have made an attempt to determine
           that these models are valid over the ranges that you
           would expect in a BWR, but you have a good point.
                       But the one important point that I wanted
           to make is that we have submitted basically three LTR
           model description and qualification reports in an
           application methodology report, and a match all
           tendency -- and I would probably do it myself, is that
           you start by reading the model description.
                       And that is probably not the best thing to
           do.  The best thing is to start with the application
           methodology, because that really describes what is it
           that we want to use it for, and what are the
           requirements that we are trying to satisfy.
                       And then it goes through the PIRT tables
           and says that these are the things that are important
           for this application, and then it has the tables that
           says, well, this is where the important phenomena are
           described in the model description, and this is where
           they are assessed in the qualification report.
                       And you really need to know that when you
           make a judgment and whether the model is good enough. 
           You need to know what it is going to be used for, and
           what are the requirements.  What is good enough, and
           you need some criteria to make that judgment.  
                       So you really have to start with the
           application methodology, and that is what we have
           tried to provide in that report.  And basically the
           goal of the application methodology was to demonstrate
           that we meet the requirements as specified in 10 CFR
           50, Appendix A, and those are basically the one, the
           two, the standard review plan.
                       And it boils down to the General Design
           Criteria, 10, 15, 17, and 26, and probably 10 and 15
           here are the ones that deal with the calculated
           response, which deals with the specified acceptable
           fuel design limits, and the peak vessel pressure.  
                       What we have tried to do is to demonstrate
           the criteria and its applicable for licensing
           calculations.  And that when we use that tied to the
           proposed application methodology, and account for the
           uncertainties and biases, then we can assess the
           overall conservatisms in the methodology relative to
           the regulatory requirement for the AOO events.
                       DR. WALLIS:  Now, I want to ask the NRC. 
           You said that you set out to demonstrate these four
           things here.  
                       MR. ANDERSEN:  These are the regulatory
           requirements and these are the ones that basically
           were addressed when we did our PIRT table.  We said,
           well, what are the critical safety parameters.  It is
           a minimum CPR.
                       And the way that we satisfy General Design
           Criteria 10 in the specified acceptable fuel design
           limits is that we say, well, we shall have no boiling
                       DR. WALLIS:  So you are saying that these
           are the things that we have to be able to show that
           TRACG can do?
                       MR. ANDERSEN:  Yes.
                       DR. WALLIS:  All right.  And this is more
           specific than actually what the staff presented, and
           does the staff accept that these have been
                       MR. LANDRY:  Yes.
                       DR. WALLIS:  Thank you.
                       MR. ANDERSEN:  The methodology, the
           statistical methodology is outlined in the CSAU
           process.  We have quantified the uncertainties in the
           model, and in the plant parameters, and in the initial
           conditions that could be like uncertainty in the void
           quotient, and uncertainty in SCRAM speed at the plant,
           or uncertainty in the operating conditions, like the
           power flow combination at the plant.
                       For each of these models, we have tried --
           or for each of these phenomena, we have identified
           what is the uncertainty, and the uncertainty
           distribution.  You can then combine them through your
           statistical methodology.
                       DR. POWERS:  Are they all independent?
                       MR. ANDERSEN:  We have treated them as
                       DR. POWERS:  Are they really?
                       MR. ANDERSEN:  And some of them are not
           and we have shown that in the application methodology.
                       DR. WALLIS:  So your methodology can
           handle situations where they are not independent?
                       MR. ANDERSEN:  Yes.  What we have done
           then is we have performed sensitivity studies as I
           mentioned earlier, and basically once you have
           quantified these uncertainties, you can vary the
           parameters over their uncertainty range, and you can
           determine what are their impact on critical safety
           parameters like minimum CPR.
                       And we have done these studies to evaluate
           the ranking that we did on the PIRT table, and that is
           where we concluded that it tended to be very
                       And when it comes down to what is really
           important, there are surprisingly few parameters that
           are really important.  It is primarily the parameters
           that deals with the responses of the reactor core.
                       DR. WALLIS:  Now, in this you have just
           picked., for example, void fraction in initial
           conditions.  Those aren't some hydraulic parameters,
           such as phase slip models?
                       MR. ANDERSEN:  No, these are just
           examples.  I mean, everything that is in our PIRT
           tables would be here.
                       DR. WALLIS:  Such as some of the thermal
           hydraulic models?
                       MR. ANDERSEN:  Yes.  They are all in here,
           like the void fraction, which is this here, and the
           uncertainty in the carryover for the separator.  They
           are all in here.  
                       MR. BOLGER:  This is Fran Bolger with GE. 
           When we do our statistical analysis, we vary all our
           high media ranked parameters together and randomly to
           determine the combined uncertainty.
                       MR. ANDERSEN:  And that's essentially what
           Paul Boehnert described.  That is what we do in our
                       DR. WALLIS:  And how many runs do you need
           to do?
                       MR. BOLGER:  We can do a minimum of 59
           trials if we decide to use an order statistic method,
           and we will do at least that many trials, and then we
           will determine whether we can -- whether the
           distribution is normal.  
                       If we can't demonstrate as normal, then we
           will normal distribution statistics.  If not, we will
           use order statistics.
                       DR. POWERS:  What kind of confidence
                       MR. BOLGER:  Depending upon the type of
           parameter that we are looking at, some of the safety
           parameters, such as the clad strain, center line meld,
           peak pressure, reactor water level, we do that on a 95
           percent confidence level.
                       And in the operating limit methodology, we
           have a method by which we combine the uncertainly in
           critical power with the uncertainly in the individual
           critical powers preceding the event to determine or to
           calculate the number of rods susceptible to the
                       DR. POWERS:  If you wanted a 95 percent
           confidence level on the 95 percentile values, wouldn't
           you have to use more than 59 rods?
                       MR. BOLGER:  Well, based on the number of
           trials we use, we apply a corrective factor so that
           our tolerance limit is representative of 95 percent.
                       DR. POWERS:  So you fudge a little bit in
           other words?
                       MR. BOLGER:  That's correct.
                       MR. ANDERSEN:  Well, 59, if you apply all
           the statistics, 59 is the minimum number of tiles for
           a 95-95.  In reality, we have run closer to a hundred
           tiles, which allow you to pick the second highest of
           the set, and get the 95-95.
                       DR. POWERS:  Yes.  My experience with the
           order of statistics is that you run around with 150 or
           200 it takes to kind of get some feel for the 95-95
                       DR. WALLIS:  And this is made possible by
           the fact that you can run your program now more
           rapidly on computers that exist today.  You couldn't
           perhaps do this 10 years ago.
                       MR. ANDERSEN:  Oh, yes.  Computers today
           enable us to do this.
                       DR. WALLIS:  So in a way, CSAU may have
           been a bit ahead of its time, and it should be done,
           but the ability to do it was limited because of
           computer capability.  And now that there is no
           limitations, there is no reason why people should not
           use CSAU.
                       MR. ANDERSEN:  We find that it works very
           well for these events.  I would like to talk a little
           about the fact that this is about the same time line
           that Ralph Landry showed.  We had our first meeting
           with the NRC in May of '99, where we laid out the
                       All the documents were submitted by
           February of 2000, and we had a kick-off meeting both
           with the NRC and with the ACRS thermal-hydraulics
           subcommittee meeting in the middle of March.
                       DR. WALLIS:  You can move on.  I think we
           have seen this before.
                       MR. ANDERSEN:  Okay.  I will do that.
                       DR. WALLIS:  We are very close to the
           conclusion.  We are getting very close to finishing on
                       MR. ANDERSEN:  Okay.  We received a total
           number of 21 formal RAI from the NRC, and some of
           these questions had multiple parts.  And some of the
           comments that we had received from the ACRS were
           addressed as part of these RAI, and particularly RAI
           Number 19.
                       Other comments that we received, we
           addressed at the meeting that we held two weeks ago. 
           It had to do with the guidance that are specified in
           Draft Regulatory Guide 1096.  I believe we covered all
           the elements in 1096.
                       And justification and assumptions for the
           basic equations, and that's why I really showed this
           slide before that showed that you start with the
           application methodology, and you look at what is
                       And then you quantify what are your
           uncertainties, and what are your assumptions, and you
           say, well, is that relevant for the intended
                       And, yes, there are simplifications in our
           basic equation, but we believe that we have shown that
           they are -- that the equations are adequate for the
           intended applications for BWR AO transients.
                       There were a number of issues on
           clarification of the models.  How is the wall shear
           treated, and clarification ont he flow regime map,a nd
           clearing on some of the interfacial terms for the
           interfacial shears, as well as the interfacial area,
           and heat transfer.
                       And we provided that information in the
           August 22nd meeting.  There were some issues that were
           addressed or raised on the TEE-based component, and
           what we have in TRAC is that we have a number of
           special components that are based on a generic TEE-
                       For example, the jet pump is a TEE-based
           component.  You have the suction and dry flow mixing. 
           The steam separators are a TEE-based component.  And
           in these components, we have specific models that we
           have incorporated into the code to address the unique
                       And we have quantified that on using full-
           scale data, and so we believe that the areas in the
           BWR were TEE-based phenomena are really important.  We
           have incorporated adequate models, and we have
           demonstrated the adequacy to comparisons, the full
           scale data.
                       And then coming back to Dr. Wallis'
           opening comment, is that depending on how good or bad
           it is, we have quantified the accuracy, and we are
           using that in the CSAU methodology.
                       There were some questions on the nuclear
           modeling, and how we deal with the decay heat groups,
           and the delayed neutron precursory groups, and we have
           addressed those comments also.
                       DR. WALLIS:  We need to just get the idea
           that you addressed all the questions that we have, and
           then we can perhaps ask the subcommittee who were
           there whether this was a satisfactory addressing on
           your part.  You will tell us, Dr. Kress, whether these
           were addressed.
                       DR. KRESS:  I felt that the responses and
           the way they addressed our particular questions were
           very responsive, and were satisfactory answers.  Now,
           there was another set of issues raised by our
           consultants, and it was unfortunate, but I don't think
           the GE people had these ahead of time.
                       And we touched on most of them, but I am
           not sure how --
                       DR. WALLIS:  Well, I don't think we need
           to go into the details unless any other committee
           member has a question.
                       DR. KRESS:  Well, unless another committee
           member has a different opinion, I thought that they
           did a very good job of clarifying and addressing these
           particular issues.
                       DR. WALLIS:  So we could perhaps move to
           the last slide.
                       MR. ANDERSEN:  Okay.  And that is
           basically concluding remarks, and summarizing what I
           said in my introduction, and applied it for BWR2 to 6
           transients.  We meet the regulatory requirements, and
           we have demonstrated the capability of the model.
                       And there has been an extensive review,
           including the NRC and the ACRS, and we have attempted
           to use the full-blown CSAU methodology, and I believe
           that we have followed the requirements of draft
           Regulatory Guide 10-96 very closely.
                       And we have demonstrated the methodology
           for all event type, and in our conclusion that is what
           we are asking the NRC to approve in the SAWYER, is
           that TRACG are applicable for AOO transients for
           licensing analysis.  Thank you.
                       DR. WALLIS:  Any other questions?  If not,
           I would like to thank you for a professional
           presentation, and I will hand the meeting back to the
                       DR. APOSTOLAKIS:  Thank you, Dr. Wallis. 
           We will recess until five minutes past 1:00.
                       (Whereupon, at 12:07 p.m., a luncheon
           recess was taken.)
           .                     A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (1:05 p.m.)
                       DR. APOSTOLAKIS:  The next item on the
           agenda is the proposed final revision to Regulatory
           Guide 1.78, Main Control Room Habitability During a
           Postulated Hazardous Chemical Release.  Dr. Powers,
           it's yours.
                       DR. POWERS:  It is?
                       DR. APOSTOLAKIS:  Yes.
                       DR. POWERS:  Gosh, what a present.  
                       DR. APOSTOLAKIS:  You see how generous we
                       DR. POWERS:  Since we are doing historical
           things, let me comment that the second time that I
           worked for the ACRS on this side of the table, as
           opposed to that side of the table, I was asked by Dave
           Moeller to come in and consult on control room
                       And not only that, but I saved all the
           documents that I got from that particular exercise,
           and have them to this day, and can use them to check
           the current speaker.
                       We are going to delve into this issue, and
           one aspect of the many issues of control room
           habitability that have arisen lately is that this one
           is an interesting issue.
                       We have spent quite a little time on it in
           the past, and it has to do with assuring that the
           control room remains habitable in the event of an
           accidental release of toxic chemicals either as a
           result of an event on the site, or something off-site.
                       We got a detailed presentation on this in
           the recent past.  I see all the members who are
           sitting around the table now actually got to
           experience that.  So, they should be familiar with it.
                       And in the course of that presentation,
           what was explained was that they were trying to update
           and combine a couple of regulatory guides, and help
           make the licensees' challenge in dealing with chemical
           hazards less burdensome.  
                       As the presentation went on, we
           recommended that they think about producing a
           regulatory guide that was more performance oriented
           than it was prescriptive, and the staff has done that
           and are ready to go final on this regulatory guide.
                       And to give us a few moments of
           discussion, because as the speaker will explain, when
           he went off to find a template for what a performance
           based regulatory guide would like, he was told that
           when he produced it, he would have it. 
                       So, with that introduction, I would ask
           Sud to come up and give us a brief discussion.  We are
           not planning to go into every chapter and verse on the
           regulatory side, and more to concentrate on the issues
           of how you make a regulatory guide performance
           oriented.  Sud.
                       MR. BASU:  Thank you.  Let's see.  So,
           with that introduction, I thought, well, maybe I don't
           need to say anything and I can go home.  On the other
           hand, I remember that it is two years this month that
           I gave a briefing on the subject to the full
                       And since then, there has been one or two
           new members in the committee.  So I thought for the
           benefit of the new members that I will go through the
           background a little bit, and then just focus on the
                       DR. POWERS:  Just test George, and see how
           much he actually remembers.  Ask him what IDLH stands
                       DR. APOSTOLAKIS:  No questions.
                       MR. BASU:  Okay.  So, I will go through
           very quickly the Reg Guide 1.78, which addresses the
           control room habitability issue, and in fact just one
           aspect of the control room habitability issue, and
           that is the habitability during a postulated or
           accidental release of a hazardous chemical.
                       That was published in 1974, and a couple
           of years later, there was another Reg Guide published
           on specifically the chlorine issue in 1977, and that
           addressed the protection and control of operators
           against accidental release of chlorine.
                       Since then, somewhere in the 1983-1984
           time frame, a Generic Safety Issue 83, GSI-83, was
           formulated to address the control and habitability
           issue, which led to further studies of control room
           habitability, and again not just the habitability
           during a chemical release, but other aspects of
                       There were a couple of reports that came
           out in the 1985 to 1987 time frame on various aspects
           of control room habitability, and then in the mid-
           1990s, the '95 time frame, NRR identified a need to
           revise the Reg Guide 1.78, given that by then we had
           more information available on toxic chemicals, the
           toxicity limits, and also on dispersion modeling, et
                       Also, there was an incentive to combine at
           that point Reg Guide 1.78 with 1.95, and simply
           because a lot of things that are common within the two
           guides, and as we are moving to NRC performance based
           regulations, towards risk-informed regulation, it was
           the most appropriate thing to do to combine the two to
           reduce the unnecessary regulation burden.
                       So with that, and giving as short an
           introduction as I could provide, let me tell you about
           what the proposed final revision to Regulatory Guide
           1.78 is.  
                       Revision 1 provides the screening measures
           for determining toxic releases that should be
           considered for control room habitability evaluation. 
           It is nothing different from Regulatory Guide 1.78,
           and that guide also provided screening measures.  
                       But of course now these screening measures
           will be based on updated toxicity limits that we have. 
           For releases that require consideration in the control
           room habitability evaluation, the revision provides
           guidance to determine concentration in the control
                       And again 1.78 did also determine
           concentration in the control room based on outdated or
           old, or dispersion modeling, and so what this does is
           that this takes advantage of the new and improved
           discussion modeling to provide or to determine the
           concentration in the control room.
                       And the Revision 1 provides guidance for
           protection of control room operators against
           accidental toxical limits, and 1.78 did, and so did
           1.95.  Again, the difference here is that now this
           guidance is now more performance based than
           prescriptive, and I will elaborate on this shortly.
                       So, let's see where we are.  So to give
           you a highlight of the revision, the focus is on
           developing a Reg Guide that kind of strikes a balance
           between the prescriptive approach that we had, and the
           original Guide 1.78, and more of a performance-based
                       And if we go back to the September '99
           time frame, when we get the presentation on the then-
           draft revision to Reg Guide 1.78, this is before
           coming up with the draft for public comments, and to
           the period when the subcommittee chair of the ACRS
           recommended that we move into the performance based
           approach, and that we take advantage of the risk
           insights to come up with a guide that will then
           provide burden reduction.
                       So our focus in the revised regulation or
           in Revision 1 to Regulatory Guide 1.78 is to strike
           that balance, and to come away from the prescriptive
           approach and go into the performance based approach,
           but in some areas where we have retained the
           prescriptive approach, and I will address that
                       This is of course motivated by the fact
           that there are fewer LERs in recent years, and there
           is no TS requirements for toxic gas monitoring
           systems, and naturally the burden associated with the
           prescriptive guide could be somewhat relaxed, and that
           is the motivation.
                       Now, we have retained in Revision 1 the
           latitude for the licensees to continue using the
           traditional engineering approach to submit
           applications or calculations in favor of the license
           amendment, but we are also encouraging licensees to
           make better use of the risk insights in assessing the
           control room habitability.
                       When we published that guide for public
           comments, there was a general comment of regulatory
           significance, and a fairly significant one, that
           addressed the somewhat implied backfitting
                       And this is sort of the implementation
           language in the Reg Guide.  It was not intended, and
           the implementation language was not properly put
           together at that point.  We have since taken care of
           that and coming away from a draft guide to the
           revision one.
                       And I think that you all have copies of
           that, and so that's what I mean by Revision 1 not
           imposing the backfitting requirements.  Licensees have
           the flexibility to continue using current licensing
           bases in addressing the control room habitability
                       Once again, licensees are encouraged to
           make better use of these insights to reduce the
           burden.  And so that would be the highlights, and so
           let me go through the summary of changes between the
           Regulatory Guide 1.78 and the Revision 1 to the
                       We have revised the toxicity screening
           measures based on the toxicity information.  This is
           the time to give the quiz on IDLH.
                       DR. POWERS:  George will explain the
           acronym on that.  
                       DR. APOSTOLAKIS:  It was only two years.
                       MR. BASU:  It was only two years, that's
           right.  The original guide was based on a reference
           that is back in 1968 on toxicity limits and dangerous
           properties and chemicals by sex.  
                       It not only contained much fewer toxic
           chemicals, but it also had toxicity limits based on
           the then available data.  Since then, and that is 30
           years plus, we have updated the data available on
           toxicity limits of many more chemicals, and these data
           are based on research findings, and technical work,
           and so what we are proposing is the so-called IDLH,
           the Immediately Dangerous to Life and Health limit.
                       And that is the limit that is endorsed by
           NIOSH, the National Institute of Occupational Safety
           and Health, and other safety organizations, like OSHA,
           the American Institute of Hygienists, and so on and so
           forth, and the IDLH limit, which is defined as the
           level that would cause injury or fatality if you will
           if no protection is afforded within 30 minutes of
           exposure to that level.  
                       And that is considered more appropriate
           because there is the provision and there is the
           guidance for the control room operators to don
           protective gear within 2 minutes of the detection of
           a toxic chemical.
                       So the operators are not expected to be
           subjected to these levels for an extended period
           beyond 2 minutes.  And this provides relaxation and
           burden reduction.  
                       It is still prescriptive in the sense that
           we are providing a very prescriptive limit, an IDLH
           limit, but it is more appropriate.
                       DR. KRESS:  What triggers the response of
           the operator to go put on the mask?  Is it an odor, or
           are there alarms?  
                       MR. BASU:  Detection devices.
                       DR. KRESS:  A detection device?
                       MR. BASU:  Yes.  There is a protector that
           sets off an alarm.
                       DR. KRESS:  What is it detecting?
                       MR. BASU:  What is it detecting?  The
           concentration of a chemical in the control room.
                       DR. KRESS:  So it is sensitive to a whole
           range of toxic chemicals?
                       MR. BASU:  There are detectors for
           individual chemicals.  
                       DR. KRESS:  Now, there are different
           toxicity limits for those.
                       MR. BASU:  That's correct.
                       DR. KRESS:  And different detectable
           limits.  What I am trying to get at is will these
           detection devices detect these things long before they
           get up --
                       MR. BASU:  You mean before a toxicity
           limit is reached?
                       DR. KRESS:  Yes.
                       MR. BASU:  Yes. 
                       DR. POWERS:  Well, I think in fairness, in
           some cases IDLH and the detection limit are pretty
                       DR. KRESS:  Well, is there some
           distribution around this two minutes that the
           operators can don these masks?  For example, are some
           of them going to take 4 minutes, or is there some
           probability that it will take 4 minutes?
                       And the other question that I had with
           this was that given that probability, is 4 minutes
           enough time to damage them?  It won't kill them, but
           it may impair their ability to function or something?
                       DR. POWERS:  Well, IDLH was set up so that
           -- well, I think it is about 90 percent of the
           population suffers no damage within 30 minutes.
                       DR. KRESS:  I see.
                       DR. POWERS:  Now, I am not sure of that,
           whether it is 90 percent or 50 percent.  Well, it must
           be 90 percent. 
                       MR. BASU:  It is actually 95.
                       DR. POWERS:  So, 95 percent.
                       DR. KRESS:  Okay.  Then that gives me some
           comfort.  I mean, that is why I am looking for --
                       DR. POWERS:  It is a horribly misnamed
           level, because it says immediately dangerous to life
           and health.
                       DR. KRESS:  Well, that is what really
           threw me.  
                       DR. POWERS:  Well, it is not immediate,
           but pretty soon.
                       DR. BONACA:  Actually, the report is
           pretty vague about what --
                       DR. POWERS:  Everybody has a different --
           you know -- there is a distribution within any
           population in your sensitivity to any given chemical,
           and in fact some people are extraordinarily sensitive
           to formaldehyde in some means, to the point that you
           can't use Scotch tape and things like that.
                       And they are on the tails of the
           distribution, and you really don't take care of that,
           but it takes care of most people.
                       DR. KRESS:  My concern is can you detect
           these things before you get to a problem, and if you
           detect them, is there assurance that the operators
           will don their masks, and that is just one number, or
           is it a distribution --
                       MR. BASU:  Well, that two minutes is also
           that 95 percent.
                       DR. BONACA:  I have the same kind of
           question also, because it gives the option of human
           detection this says.  For example, smell.  So I was
           thinking how do you calibrate that, and how do you
           know that you are donning quickly within 2 minutes.  
                       Is two minutes totally realistic for human
           detection, and yesterday we discussed that, and then
           it was pointed out that in some cases that it is
           actually the finest --
                       MR. BASU:  You mean the toxic chemical
           manufacturer resident, and if you are a resident for
           more than 2 minutes, you will not be able to detect by
           odor threshold.
                       DR. BONACA:  How do you correlate the
           smell to the two minutes?
                       MR. BASU:  The odor thresholds -- I think
           all the cases that I am aware of are much lower than
           the IDLH standards, and also lower than the detection
           limits of the detection instruments.  
                       So you will know, and if you are detecting
           by the odor threshold, you will know it is there.  And
           the question is whether or not in two minutes that it
           builds up to the level that then exceeds the toxicity
                       DR. BONACA:  Are operators being trained?
                       MR. BASU:  Yes.
                       DR. BONACA:  Because I know that there is
           general training for wintergreen smell, or --
                       MR. BASU:  Well, if you look at the
           emergency procedures and planning, there is a planning
           guidance for the operators to be familiar with various
           chemicals and their toxicity limits.
                       MR. SIEBER:  Actually, the complexity of
           the detector is relatively small, because you run a
           stringing process to determine either on-site or off-
           site the presence of whatever toxic chemicals there
                       The water power plants, especially the
           ones out in the country, the only thing that is there
           is that they use gaseous chlorine as part of their
           chlorination process.  So that would be the only
           detector that you would have.
                       If you lived in an industrial complex
           where you would have potential for other businesses to
           leak toxic gases, and you would be required to be able
           to detect this.
                       DR. POWERS:  If you want my opinion on the
           detectors, with the exception of a few, I think the
           ammonia detectors have gotten pretty good.  The rest
           of them, I am going to trust my nose.
                       MR. BASU:  For chlorine, it is the
           detection limit and IDLH.
                       DR. POWERS:  Yes, very close.
                       MR. BASU:  And we are talking about the
           dispersion model, and that is different from the Reg
           Guide 1.78, and Revision 1, and I touched on that
                       The Reg Guide or the original Guide 1.78
           has a very simple model, with the diffusion not having
           any temporal dependence, and it has a very special
           spatial dependence. 
                       And since 1974 onward, there has been a
           lot of work done on it, and mostly dispersal modeling. 
           So we took advantage of that, and at the NRC, we have
           been using the HABIT code, which has a couple of
           models that are relevant to the toxic chemicals, the
           EXTRAN and the CHEM model that are used to determine
           the dispersal and the concentration in the control
                       There are other models available, and we
           are not necessarily endorsing one and only one model. 
           Licenses are certainly encouraged and come up and can
           use other models that have similar capabilities to do
           the calculations, and submit the calculations.  And if
           these calculations bear out, then they will be given
           the appropriate credit for them.  
                       DR. KRESS:  Does the Reg Guide specify
           anything about the meteorological conditions?  For
           example, that they should use the most conservative
           dispersion co-efficients?
                       MR. BASU:  No, no, we are not saying --
           and this is the chemical part of it.  Did you say
                       DR. KRESS:  No, I am talking about
                       MR. BASU:  No, we are not actually saying
           that, that they need to use the most conservative
           ones.  We are saying to use the most appropriate one
           which has certain features, like it can --
                       DR. KRESS:  No, no, what I am talking
           about is in these, you have to put in usually the
           atmospheric stability.
                       MR. BASU:  Well, the atmospheric stability
           for most plants, the stability category in the 95
           percent level is Category F, and I will be coming to
           that shortly.
                       DR. KRESS:  Okay.
                       MR. BASU:  And which is what is used, and
           I will show you a simple algorithm.  
                       DR. KRESS:  Which is conservative?
                       MR. BASU:  Yes.
                       DR. KRESS:  That is what I was after.  Do
           you specify that in the reg?
                       MR. BASU:  Yes.  I will come to that
           algorithm, but there is a plan that does not fit that
           category, and we also have adjustment factors
           specified that you can use to take care of that plant
                       Risk evaluation or risk insight, there was
           none in Reg Guide 1.78 back in '74, and understandably
           so.  We were not thinking in a risk-informed space in
           those days.  We do now have a consideration of risk in
           this revision, and risk insight for Reg Guide 1.174 in
           a broad best sense.
                       And again that is not regulated by the
           fact that there are fewer LERs in recent years, and no
           tech spec requirements for TGMS.  So this is a way to
           reduce unnecessarily burden by taking advantage of the
           risk insight.  Where we have --
                       DR. APOSTOLAKIS:  Isn't one answer for
           dealing with changes, permanent changes, to the
           licensing basis?
                       MR. BASU:  Changes in licensing basis? 
                       DR. APOSTOLAKIS:  And it is not supplied
                       MR. BASU:  Well, if the licensees propose
           voluntarily there will be changes, then they can --
                       DR. APOSTOLAKIS:  Changes in what?  In
                       MR. BASU:  Changes in TGMS requirements.
                       DR. APOSTOLAKIS:  So they can use this?
                       MR. BASU:  They can use this if they wish.
                       DR. APOSTOLAKIS:  Well, how would they do
           that?  They can't really quantify the PRA, although --
                       MR. BASU:  That's right, and that is what
           the challenge is.
                       DR. APOSTOLAKIS:  So they have to be
                       MR. BASU:  That's right, they have to be
                       DR. KRESS:  Very creative.
                       DR. APOSTOLAKIS:  Very creative.
                       DR. POWERS:  Just claim all your operators
           god, and say, gee, the plant -- 
                       MR. BASU:  I have seen a couple of
           examples of license amendment applications in the past
           -- and this is before even 1.174 was published --
           where the licensees did make use of the probability
           argument, and so I think they can be creative enough
           to do this.
                       DR. APOSTOLAKIS:  I would like to see
           that.  Have you ever seen any analysis along these
                       MR. BASU:  Not making reference to 1.174,
           but I have seen analysis to the probability arguments
           in a couple of applications, yes.  Maybe I can dig
           those up.
                       DR. BONACA:  I had a question with regard
           to the evaluation and main control room habitability. 
           In the text, it specifies in cases where you have
           chemical containers that are not designed to withstand
           earthquake or flood, you should consider these
           releases in conjunction with the event.
                       MR. BASU:  Coincidence.
                       DR. BONACA:  Coincidence.  And then it
           says in evaluation that it may also be proper to
           consider releases coincident with, for example, design
           basis, and loss of coolant accidents.  Isn't it -- why
           would that be?  I mean, even if there is no
           mechanistic link between the LOCA and the release?
                       MR. BASU:  Well, if these are two events,
           there is always a probability, however small it might
           be, for the two events to occur coincidental with each
           other is it not?
                       DR. BONACA:  Well, I thought we were going
           to what is in the licensing basis.
                       MR. BASU:  Well, it is not in the
           licensing basis, and I understand that, but it can
           occur.  Now, I think -- and I am not sure, but are you
           reading from the draft Guide 1.78?
                       DR. BONACA:  I am reading from 1.78.
                       MR. BASU:  I think we made some
           modification on page 9 of 1.78, and we said that in
           the evaluation of the control room habitability, it
           may also be appropriate to consider releases
           coincident with the radiological consequences, as for
           example, et cetera, and demonstrate that such
           coincidental events do not produce an unacceptable
           level of risk.
                       And we have defined the unacceptable level
           of risk like that.
                       DR. BONACA:  It seems to me quite
           prescriptive.  I thought that you were going more in
           a risk-informed direction, and in a case you may find
           that the coincidence of a release and the LOCA are
           such low probability that you shouldn't --
                       MR. BASU:  That is exactly what we are
           saying, that if it is such a low probability, then you
           don't have to worry about it.
                       DR. BONACA:  But you said that with such
           coincident events not producing an unacceptable level
           of risk.
                       MR. BASU:  Yes, and that unacceptable
           level of risk was previously defined as the one that
           has a very low probability.
                       DR. BONACA:  Oh, I see, very low
                       DR. KRESS:  Can't you make a judgment
           ahead of time in this case?
                       MR. BASU:  Did we make a judgment?
                       DR. KRESS:  It seems to me like you could
           already say that that is such a low probability that
           it should not even be a consideration without actually
           calculating it.
                       DR. APOSTOLAKIS:  Unless you have a
           mechanical -- 
                       DR. KRESS:  Unless it is on the site
           itself, inside the plant.  That may be it.
                       MR. BASU:  Yes.
                       DR. KRESS:  I was thinking off-site.
                       MR. BASU:  Oh, no.  We have moved into the
           performance based approach, and providing guidance for
           protection measures.  We prescribed the toxicity
           limit, and we said that if you exceed this toxicity
           limit, then what are the measures that you will be
           checking, and that's where the performance-based
           measures come in.
                       Of course, the objective is adequate
           protection, and at the same time unnecessary burden
           reduction.  The last one is --
                       DR. APOSTOLAKIS:  Could hou give an
           example of an actual performance-based --
                       MR. BASU:  Let me go into the -- well, it
           is probably a couple of slides back, and let me see if
           I can do that.  This is the prescriptive part of it
           that I am talking about, where we did the hazard scan,
           the toxical chemical hazard screening.
                       And where we said that chemicals stored
           within 5 miles of the plant or in transit within 5
           miles of the plant, or 5 miles away or more away from
           the plant are exempt from any further consideration,
           and that is in the original guide.
                       And in-transit within 5 miles, but
           infrequent shipments also are exempt.  Chemical stored
           within 5 miles or in-transit frequently, and there is
           a definition in the guide of what that frequency is
           for various modes of shipments, and I am not going to
           go into detail on this unless anyone has a question
           about it.
                       But in terms of in-transmit frequently
           within 5 miles require consideration as follows, and
           we are providing a simple algorithm of calculating
           weights of chemicals that you need to consider for the
           distance and for various air exchange rates.
                       And that is the table that you see in
           front of you, and then of course these weights are
           also proportional to toxicity limits.  These weights
           are based on a toxicity limit of 15 milligrams per
           meter cubed, toxicity limits.
                       So if you had a hundred milligrams per
           meter cubed, then the weights are then directly
           proportional to that.  And the weights are inversely
           proportional to the air exchange rates as you can see
           from the table itself.
                       And then the weights are also adjusted for
           meteorological conditions, and I think that Tom had a
           question previously with regards to that, and if you
           have stable conditions, the multiplier is one.  If you
           have Stability Category E, which is a better
           condition, then your multiplier is 2.5., and that
           means that you can allow more weight.
                       If your condition is worse than F
           category, the multiplier is 1.4 and you allow less
           weight.  So these are the prescriptive parts.  And
           then for chemicals not meeting the screening criteria
           -- in other words, you have more weights of a
           particular chemical within a given distance, and for
           a given air exchange rate, et cetera, then the
           guidance is to perform detailed control room
           habitability evaluation, and here is the traditional
           approach that is in 1.78, except that in Revision 1
           that it is updated and improved.
                       And that is the latitude of providing for
           the licensee to continue using that approach, and we
           are encouraging once again the risk evaluation,
           because if your risk is very low and insignificant,
           and acceptable, and then you don't have to do for the
                       Performance-based guidance, an example,
           and someone asked me -- the Chairman asked me for an
           example.  I think the objective is to provide adequate
           protection for control operators and an assurance that
           the control room is habitable.  
                       So that is the overall objective of the
           performance-based, and how we go about doing it is we
           recommend periodic survey of stationary and mobile
           sources of toxic chemicals to see what kind of sources
           are there, and what kind of release events have
           occurred in the past, and the statistics, and the
           concentration, et cetera.
                       And also testing of control room envelope
           leakage.  Once you have done this, then -- and you
           satisfy yourself that the highest concentration that
           you can achieve for a given chemical in the control
           room is still below the toxicity limit, we are saying
           that implementation of a protection measure is not
                       I mean, you don't have to do it, and if
           you have it, so be it, but it is not a requirement. 
           When the concentration does exceed the toxicity limit,
           you, of course, require some protection, and the
           protection has various elements.
                       First of all, you need to be able to
           detect the concentration level, and then you need to
           be able to isolate the control room, and finally of
           course you need the protection of control room
                       If you recall in the original 1.78, all
           these attributes were very, very prescriptive
           detections, detection in terms of detection measures,
           and we prescribe what kind of detection instruments,
           and how many, and where they should be located, and
           what should be their protection.
                       DR. APOSTOLAKIS:  I don't think that a
           performance-based.  I think that is prescriptive.
                       DR. POWERS:  He sets a standard of safety,
           and he doesn't need it.
                       DR. APOSTOLAKIS:  Well, where is the
                       MR. BASU:  What I was saying was the
           original, and in the original 1.78 we said how many
           detectors you need, and where you need to locate them,
           and install them, and all other features.
                       Here we are saying that if -- in the
           revised guide, we are saying that if the
           concentration, and you do not know whether your
           concentration is exceeding the toxicity limit or not,
           you need some detection.
                       And you need to be able to detect a
           particular or a given chemical species at a level
           which is below the IDLH.  We are not going anything
           beyond that.  
                       So it is really up to the licensees to
           determine what should be the detection limit and based
           on what that detection limit be, that there are
           certain instruments that they need to install, and
           whether they need to look at these instruments as long
           as you can detect the concentration which is below the
           IDLH.  So that is performance-based.
                       DR. APOSTOLAKIS:  Is that the second
           bullet or the third bullet?  You don't mean to imply
           that all of these are supposed to be performance-
                       MR. BASU:  Which one?
                       DR. APOSTOLAKIS:  All these bullets.
                       MR. BASU:  No, no, I am just giving you --
           you asked for an example, and this is an example where
           the performance-based --
                       DR. APOSTOLAKIS:  I'm sorry.  Does this
           comply with the four characteristics of a performance-
           based rule that the staff has promulgated?  That you
           have a measurable quantity.
                       MR. BASU:  A measurable quantity.
                       DR. APOSTOLAKIS:  And specifically
                       MR. BASU:  Yes.
                       DR. APOSTOLAKIS:  And then you have a
           measure, and then the licensee will be free to
           demonstrate -- to use methods to demonstrate
           compliance.  What was the fourth one?
                       MR. BASU:  And a measure of performance.
                       DR. POWERS:  And exceeding the --
                       MR. BASU:  And a measurable performance,
           and I think that is what is captured here in this, and
           the same thing with the control room isolation. 
           Again, if you go back to 1.78, it is very
           prescriptive, in terms of how you isolate, and what is
           the air exchange rate, and how you calculate these air
           exchange rates, et cetera.
                       And we are not -- we came away from that,
           and we said that you need assurance that the control
           room is isolated, and there is no inadvertent air
           leakage beyond a certain amount.
                       And, of course, the protection of the
           operators, in terms of providing the protection gear. 
           Again, the 1.78 was far more prescriptive in that
           regard.  We are saying that the protection gear should
           be provided.
                       Not how many, and not when and where kind
           of thing.  And I think about the only thing that is
           prescriptive here within that 95 percent confidence,
           Tom, or 95 percent level, is donning the protective
           gear within 2 minutes, and that is kind of based on
           the actual time it takes in the 95 percent population.
           There is always that 5 percent population that it
           takes a longer time.  
                       So that's it in a nutshell of the changes
           to the revision, and I should mention that since the
           publication of the draft guide in February of this
           year, that we have received public comments on the
           guide, and in what I would consider broadly in 3 or 4
                       General comments of regulatory
           significance and I have given an example already where
           the implementation language was such that one could
           conceivably interpret that language as an implied
           backfitting requirements.  
                       That it is not intended, that that was not
           intended.  We have revised that language, and this is
           the tendered language put in there that sort of
           reflects the voluntary initiative on the part of the
                       Otherwise, they can continue to use the
           licensing basis approach.  So that is what I mean by
           the general comment of regulatory significance.  There
           was a category of technical comments of regulatory
           significance, and I also gave an example of that.  
                       There was a comment that -- and that Dr.
           Bonaca asked about coincident release of chemicals
           with a LOCA type event, and I think that I answered
           that in the risk-based.  
                       So those are the types of comments.  There
           were technical comments on the adequacy of either a
           number, or a statement, and those have all been
           addressed in the revision.
                       And the final category was purely
           editorial comments, like a comma was missing
           somewhere, and the numbers were not properly aligned
           in the table, and that kind of thing.  Hopefully we
           addressed those as well.  So I think we are in a
           position that this can go final for publication.
                       DR. POWERS:  What I found attractive about
           the way the thing had been put together is they have
           a very prescriptive screening criterion that can be
           done with a minimal amount of investment. 
                       I mean, you find out how much weight you
           have, and where, and you compare it against the table
           suggested by location, and atmosphere, and the nature
           of your control room.
                       And that gets most people out of the woods
           very quickly.  And then the staff comes in and they
           say, okay, here is the standard for safety.  And there
           are actually two of them in there.  
                       One is that they adopted the IDLH as the
           limiting concentrations, and those are pretty good. 
           They are endorsed by huge numbers of people, and at
           least there is some consistency there nationwide.
                       And the other one is this 2 minute donning
           thing.  And they said, okay, licensees, go ahead and
           meet it.  On the other hand, they also say that if you
           don't want to mess with this stuff, and you want to do
           what you have done in the past, that's okay, too,
           because that is highly prescriptive.
                       My thinking was, especially as we wrestle
           with material licensees, many of whom are not in the
           financial position to go a risk-type of approach, but
           still would like to have some flexibility in the way
           they engineer systems, this is a pretty good pattern
           for setting things down.  
                       The licensees that are small operations
           have a prescriptive path and they just follow the
           prescription, and the thinking has been basically done
           by the staff.  
                       And licensees with a little more
           capability can use creative engineering to meet the
           safety standard that the staff has set.  The licensees
           with a lot of capability can come in and argue over
           the safety standard by doing risk analyses.
                       And I thought that was a nice combination
           of things that could serve as a pattern for doing
           these kinds of things where they don't affect an
           enormous number of plants. 
                       I mean, there is only a handful that
           really get into this, and similarly with the materials
           licensees, you have a similar kind of situation, and
           I thought it was a good pattern and worth looking at
           in that regard.  
                       DR. APOSTOLAKIS:  Okay.  Thank you.
                       MR. BASU:  Okay.  Thank you.  Actually, I
           need to thank the ACRS for providing comments back in
           September of '99, and that is what prompted us to take
           another look at and make this more performance-based.
                       DR. POWERS:  I think it makes it a cleaner
           regulatory standard, because now your focus is just on
           what is the safety limit, rather than how you organize
           the chlorine detectors on-site.  
                       And that gets you out of the position of
           having technical innovation outdate your regulatory
           guide.  Are there any other questions that people
           would like to ask?
                       Again, I think with the specific issue,
           this is a pretty arcane issue.  As a pattern for how
           we can think about doing performance based regulatory
           guides, especially in the nuclear materials area, I
           think it is worth reading in that regard.
                       And incidentally, those of you who went to
           Waterford, it very much affects them.  They are very
           affected by this particular reg guide, but most plants
           aren't.  Browns Ferry doesn't have to worry.  Well,
           they may have to worry about ammonia actually, because
           there is enough agricultural work around there that
           they might have ammonia.  Okay, Mr. Chair.
                       DR. APOSTOLAKIS:  Okay.  Thank you very
           much for your presentation.
                       MR. BASU:  Thank you.  
                       DR. APOSTOLAKIS:  Now, we are scheduled to
           take a break, but we have first drafts of two letters
           that I know of, Waterhammer and the control room
           habitability, and we have also Larkinsgram that I
           understand has been drafted.  And then we have to
           debate the oversight process.
                       Now, we can proceed and perhaps dispose of
           one of those.  
                       DR. WALLIS:  My preference is that I think
           I would like to do that now.
                       DR. APOSTOLAKIS:  Well, after the break. 
           I was coming to that.  We have a couple of competing
           priorities here.  One is that it would be nice to
           approve of something so we have a sense of
                       And I think that Dana's letter is probably
           a prime candidate for that.  I get a sense that the
           Committee doesn't have any problems with what was just
           presented, and the letter is written in the --  
                       DR. KRESS:  And we have the Larkinsgram.
                       DR. APOSTOLAKIS:  And we have the
           Larkinsgram.  Maybe we can do those first and get rid
           of them in 15 minutes.
                       DR. POWERS:  The Larkinsgram is undergoing
           a final tweak.
                       DR. APOSTOLAKIS:  Okay.  If it is not
           ready, then --
                       DR. POWERS:  Sherry says it is finished.
                       DR. APOSTOLAKIS:  Then we can perhaps pick
           up your subject, Graham, and how much time do you
           think we should spend on that?
                       DR. WALLIS:  Well, I think you will agree
           with me.
                       DR. APOSTOLAKIS:  Yes, but how much time
           do you think it will take to agree with you, 45
           minutes or a half-an-hour?
                       DR. WALLIS:  I would like to have just 5
           minutes for you to agree with the conclusion and the
           scope of what I want to say, and then I will flush it
                       DR. APOSTOLAKIS:  Okay.
                       DR. WALLIS:  But I don't want to go and
           write a letter which is diametrically opposed to the
           view of the committee.
                       DR. APOSTOLAKIS:  That is perfectly all
           right.  Then we will pick up, I think, the oversight
           process, because even though we have lots of time
           tomorrow, if we are still debating it tomorrow, we
           will never write a letter.  So I think Jack needs the
           night tonight to do whatever the committee decides and
           what advice they give you.
                       DR. WALLIS:  Poor fellow.
                       DR. SHACK:  You are wildly optimistic,
           George, but that's okay.
                       MR. SIEBER:  I may have difficulty writing
           something I don't believe in. 
                       DR. APOSTOLAKIS:  Well, if you don't
           believe in it, you will participate in the debate, and
           you can express your views. 
                       MR. SIEBER:  Right.
                       DR. APOSTOLAKIS:  But the alternative is
           to do it tomorrow, which is impossible, where nobody
           can write anything.  So I really want to go into the
           oversight process as soon as we can, and after we get
           the warm feeling that, yes, the outline of the letter
           is in sight, then we can look at other things, okay?
                       So the first thing we will do then is
           Dana's letter, and then we will look at the
           Larkinsgram if it is already, and then we will go to
           Graham.  Yes, Sherry?
                       MS. MEADOR:  Would you like Dana's letter
           upon the screen?
                       DR. APOSTOLAKIS:  Yes, but in 20 minutes.
                       DR. POWERS:  Mr. Chairman, we have quite
           a few mark-ups on that letter already.
                       DR. APOSTOLAKIS:  Mark-ups?
                       DR. POWERS:  Yes.  Do you want me to read
           it to you as it is marked up?  I can do that.
                       DR. APOSTOLAKIS:  You mean she doesn't
           have that? 
                       DR. POWERS:  No, she doesn't have that
                       MR. ROSEN:  The Larkinsgram is ready.  
                       DR. KRESS:  I also have a second draft of
           the Waterhammer.
                       DR. APOSTOLAKIS:  Okay.  We will be back
           in 20 minutes and see what is ready, and whatever is
           ready, we will do that then.
                       (Whereupon, the meeting was recessed at
           2:00 p.m.)

Page Last Reviewed/Updated Monday, August 15, 2016