487th Meeting - November 8, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Reactor Safeguards
487th Meeting
Docket Number: (not applicable)
Location: Rockville, Maryland
Date: Thursday, November 8, 2001
Work Order No.: NRC-102 Pages 1-356
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
NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
487th MEETING
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THURSDAY,
NOVEMBER 8, 2001
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ROCKVILLE, MARYLAND
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The committee met at the Nuclear
Regulatory Commission, Two White Flint North,
Room T2B3, 11545 Rockville Pike, at 8:30 a.m.,
George E. Apostolakis, Chairman, presiding.
COMMITTEE MEMBERS PRESENT:
GEORGE E. APOSTOLAKIS Chairman
MARIO V. BONACA Vice Chairman
NOEL F. DUDLEY Member
F. PETER FORD Member
THOMAS S. KRESS Member
GRAHAM M. LEITCH Member
DANA A. POWERS Member
COMMITTEE MEMBERS PRESENT: (cont'd)
STEPHEN L. ROSEN Member
WILLIAM J. SHACK Member
JOHN D. SIEBER Member
GRAHAM B. WALLIS Member
ACRS STAFF PRESENT:
SHER BAHADUR
SAM DURAISWAMY
CAROL A. HARRIS
JOHN T. LARKINS
HOWARD J. LARSON
MICHAEL T. MARKLEY
ALSO PRESENT:
RALPH ARCHITZEL
STEWART BAILEY
RAY BAKER
RUSSELL BELL
JEFF BENJAMIN
BILL BURCHILL
WILLIAM BURTON
GENE CARPENTER
ED CONNELL
JIM DAVIS
ALSO PRESENT: (cont'd)
JOHN FLACK
CHRISTOPHER GRIMES
ALLAN HAEGER
TIM HANLEY
DONNY HARRISON
JAMES W. JOHNSON
ED KENDRICK
TOM KING
MARK KLUGE
TAD MARSH
MIKE MAYFIELD
SCOTT NEWBERRY
JOHN NOSKO
CHUCK PIERCE
JASON POST
LARRY ROSSBACH
MARK RUBIN
JERRY N. WILSON
RAY P. ZIMMERMAN
JOHN ZWOLINSKI
I N D E X
AGENDA ITEM PAGE
Introduction and Opening Remarks . . . . . . . . . 5
Final Review of the Hatch License Renewal . . . . 7
Application
Dresden and Quad Cities Core Power Uprate. . . . .80
Staff Presentation . . . . . . . . . . . . . . . 163
NRC Safety Research Program. . . . . . . . . . . 213
Overview of Research and Advanced Reactors . . . 279
Proposed Update to 10CFR, Part 52. . . . . . . . 310
P-R-O-C-E-E-D-I-N-G-S
(8:30 a.m.)
CHAIRMAN APOSTOLAKIS: The meeting will
now come to order. This is the first day of the 487th
meeting of the Advisory Committee on Reactor
Safeguards.
During today's meeting the Committee will
consider the following: final review of the Hatch
license renewal application, Dresden and Quad Cities
core power uprate, NRC Safety Research Program
proposed update to 10 CFR Part 52, and proposed ACRS
reports.
A portion of this meeting may be closed to
discuss General Electric nuclear energy proprietary
information applicable to Dresden and Quad Cities core
power uprate.
This meeting is being conducted in
accordance with the provisions of the Federal Advisory
Committee Act. Dr. John T. Larkins is the designated
federal official for the initial portion of the
meeting.
We have received a request from Mr.
Russell Bell of the Nuclear Energy Institute for time
to make oral statements regarding the proposed update
to 10 CFR Part 52.
A transcript of portions of the meeting is
being kept, and it is requested that the speakers use
one of the microphones, identify themselves, and speak
with sufficient clarity and volume so that they can be
readily heard.
I'd like to bring to your attention three
speeches that Chairman Meserve and Commissioner Dicus
gave recently. They are in this handout, "Items of
Interest." In particular, the speech by Commissioner
Dicus on new directions in research should be of
interest to the members, since we are working on our
report on research being carried out by the Office of
Research.
These speeches were given at the Water
Reactor Safety -- no, it's not Water Reactor anymore
-- at the Nuclear Safety Research Conference, which
used to be Water Reactor Safety Information Meeting --
a very significant change in name.
I would like to remind the members that
during lunchtime today they will -- they are scheduled
to interview three candidates for potential membership
of the ACRS. Dr. Larkins has a comment to make.
DR. LARKINS: Yes. Please note the
members in Group 2, Bonaca, Powers, Rosen, Leitch, and
Wallis, you are now going to have your interviews in
the Subcommittee Room rather than the Caucus Room. So
please make note.
CHAIRMAN APOSTOLAKIS: Thank you.
DR. LARKINS: That's both today and
tomorrow.
CHAIRMAN APOSTOLAKIS: Any comments or
statements any of the members wish to make before we
start?
Okay. The first item on the agenda is the
final review of the Hatch license renewal application.
Dr. Mario Bonaca is the cognizant member. Dr. Bonaca?
VICE CHAIRMAN BONACA: Yes, Mr. Chairman.
We met on October 25th with the applicant and with the
staff to review how open items on the Hatch
application are being resolved. We note that several
of the open items on these applications were also open
items on previous applications as well as on some
applications under review right now.
So we were interested in this resolution,
and we were interested in how the clarification will
be brought to other licensees for future applications,
so that there will not be open items in the future.
We felt that the SER contains significant
clarification of staff position of these issues, and
we were interested also in reviewing the appeal
process that had been used at least partially by this
applicant with the staff. This is the first time we
have seen -- at least from license renewal -- the
appeal process underway.
We have requested the staff to come and
give us some highlights of that meeting. And with
that, I will invite Mr. Grimes of License Renewal to
open the presentation.
MR. GRIMES: Thank you, Dr. Bonaca, and
good morning, Chairman Apostolakis and other members
of the Committee.
The staff is pleased to have this
opportunity to present the results of the staff
evaluation of the Hatch license renewal application.
As Dr. Bonaca pointed out, we continue to learn some
lessons in ways to clarify and improve the license
renewal process, and we're going to continue to pursue
those and keep the Committee informed as we make
improvements to the guidance and to the process.
But our focus today is to present the
results of our review of this specific application for
renewal of the Hatch operating licenses and to
describe the resolution of the open items and the
basis upon which we will move forward to make a
recommendation to the Commission.
And so we hope that today we can describe
that to you and find out what the Committee views are
on whether or not there's any matter that we need to
clarify. We're still considering whether or not we
want to revise the safety evaluation to make further
improvements before its final publication and
presentation to the Commission.
And so at the conclusion of this meeting
I will want to make certain that we clearly understand
what the Committee's views are on whether or not
there's anything additional that we need to do before
preparing a recommendation for the Commission.
With that introduction, I would like to
turn the presentation over to Butch Burton, who is the
Senior Project Manager responsible for the Hatch
license renewal review, unless there are any
particular overview questions that you have of me.
MR. BURTON: Okay. Thank you, Chris.
As Chris mentioned, my name is Butch
Burton. I'm the Lead Project Manager for the staff
review of the Hatch license renewal application.
What I'm going to try to do today is
rather than getting into a whole lot of detail related
to the review, I'm going to try and paint an overall
picture of the application, some of the challenges
that the staff encountered during its review, how we
dealt with some of those challenges, and, then, of
course, if there are specific questions, detailed
questions that any of you have, hopefully either I or
some of the staff who are here today can answer those.
Let's start with basic plant overview.
Can everybody hear me? Because I'm using the remote
mike.
And this is similar to the slide that I
showed, what, about six months ago when I was before
you before. A little bit of background about Plant
Hatch. The application was submitted in late February
of last year. As you all know, it's a two-unit BWR
located in Appling County, Georgia. I believe the
largest metropolitan area is Savannah, about 90 miles
northeast of the plant.
Unit 1, its current license expires in
2014. They're asking for a 20-year extension to 2034.
Similarly, Unit 2, current license expires in 2018,
and they're requesting an extension to 2038. Our
initial SER was published in February of this year,
and we issued the final SER in early October.
I'm actually going to begin at the end.
Let me talk a little bit about the staff's conclusion,
and then I'll talk about how we reached that
conclusion.
10 CFR 50.29 discusses the three criteria
that are necessary in order to approve the license.
The first, which is really the essence of our staff
safety review, is that actions have been identified
and have been or will be taken such that there is
reasonable assurance that the activities will continue
to be conducted in the renewal term in accordance with
the current licensing basis. That's what we're -- the
bottom line of what we're trying to get at.
In addition, this second bullet has to do
with the environmental portion of the review, and the
final bullet here has to do with basically if there
were any requests for hearings, any issues raised
there. And for Hatch there were none.
So, basically, the three main criteria to
issue the renewed license, we believe that the
applicant has met that, and I'll go through in the
presentation to show you why we believe that.
Okay. The Plant Hatch application, as you
know, is the first BWR, and it had a very unique
approach. And some of the things were: it was the
first to use the topical reports, the boiling water
reactor vessel and internals project reports. It was
the first to use that, so that was the first time that
we were able to apply those to a plant.
Southern Nuclear, who submitted the
application, it actually used a different approach
than some of the previous applications. They used a
functional approach as opposed to a system approach,
and that was a challenge to the staff. And I'll talk
about that a little bit more when I talk about
scoping.
It was also the first to apply the Aging
Management Program attributes, the 10 attributes.
They applied them not only to the Aging Management
Programs, as we are used to seeing, but they also
applied them to demonstrating the adequacy of the
aging management. And I'll talk about that a little
bit later, but that also posed initially a challenge
to the staff.
All right. The first thing that we look
at that the staff does in its review is it looks at
the scoping and screening, and there are actually two
parts to this. The first part is we look at the
actual methodology that's used for scoping and
screening. That's real critical, because if we can't
have confidence in the process that they use to get
their results, then everything else is questionable.
So we do spend a fair amount of time in
the beginning of the review to make sure that we
understand the methodology and that the methodology is
in accordance with the rule.
As I mentioned before, they were unique in
that they used a functional approach versus a system
approach to their scoping. So the functional
boundaries were very important, because the functional
boundaries were not necessarily the same as the system
boundaries.
And the staff -- we did our review by
system, so what happened was an individual reviewer
would look at his or her particular system, look at
the functions that that system performed, and then had
to follow that and trace that through.
The end of the system wasn't necessarily
the end of the function. So what we found was that
system reviewers who were doing the scoping, there was
a lot of crosstalk. As they followed the function and
they reached the end of their system, they had to talk
to the next person who was handling where that
function picked up.
So there was a lot of crosstalk that was
done in making sure that we could follow the functions
through. And as I mentioned before, the scoping and
screening requirements for the methodology should meet
the Part 54 requirements.
A little bit later on, I'm going to be
talking about some of the various inspections that we
did. And there was -- one of the things that we did
to support the methodology findings was we actually
went down to the applicant's headquarters and actually
conducted a methodology audit. And I'm going to talk
about that a little bit later.
As I mentioned, the scoping and screening
review consisted of two parts. The first was looking
at the methodology. The second part was actually
looking at the results of the methodology. And this
is just sort of a summary of what we found there.
As a result of our review, we found -- we
developed 119 scoping and screening questions -- RAIs
-- and also we had four scoping and screening open
items. Again, this portion of the review was also
supplemented with a scoping inspection, different than
the audit that focused on the methodology. The
scoping inspection actually focused on some of the
results of the scoping evaluation. And, again, I have
a separate slide that talks a little bit about the
detail of that.
After the scoping and screening, the next
was aging management -- aging management and time-
limited aging analyses. This is where we get into
some of the Aging Management Programs. Once they
identify which structures and components should be in
scope and subject to an AMR, now we look at, what are
the aging effects, and what programs are in place to
manage those aging effects? That's what this portion
of the review did.
It turned out, when all was said and done,
there are 31 Aging Management Programs that are
credited for license renewal. Eighteen of them were
already existing programs, five were existing but
needed some enhancement of some type, and then eight
of them were new. And, in fact, in the original
application there were 29 Aging Management Programs.
As a result of the staff's review, there
were two additional ones that were developed. One was
the diesel generator maintenance activities, which
really dealt with the management of some of the skid-
mounted components with the diesel, and the other was
aging management of cables. So there were actually
two additional programs that came out as a result of
the result.
VICE CHAIRMAN BONACA: I thought that
small bore piping inspection was a new one-time
inspection.
MR. BURTON: No. Actually, the small bore
piping inspection that came out as a result of the
open item, that was actually covered in the scope of
the treated water systems piping inspection, one of
the -- I believe that inspection was a new program,
and that is a one-time program.
And so the small bore piping, once we
decided what it was going to be, we found that the
TWPSI, as they called it, could actually be covered
in --
VICE CHAIRMAN BONACA: Yes. So --
MR. BURTON: -- in the unit.
VICE CHAIRMAN BONACA: So, I mean, you
resolved it by including it in the existing -- so you
modified an existing program to accommodate that.
MR. BURTON: Correct. Correct.
VICE CHAIRMAN BONACA: Okay.
MR. BURTON: There are a couple of
specific Aging Management Programs that I think
probably require a little bit of discussion. One is
the Corrective Action Program. That is a separate
Aging Management Program, but it applies across many
different systems.
And what it is is that any time you find
evidence of age-related degradation, how do you
disposition that? And the Corrective Action Program
provides the guidance and the requirements and
acceptance criteria to do that.
In terms of the 10 aging management
program attributes that I mentioned before, this
single Aging Management Program covers four of those
attributes -- the corrective actions, the confirmation
process, administrative controls, and operating
experience. When you go to that Corrective Action
Program, it discusses how to address those four
attributes.
VICE CHAIRMAN BONACA: Is this a program
separate from the plant Corrective Action Program?
MR. BURTON: No. No. It is the same one.
VICE CHAIRMAN BONACA: Okay.
MR. BURTON: And, in fact, and what I was
going to get to before, is that is -- that has an
Appendix B pedigree, but what Southern Nuclear has
done, even those portions that are in license review
that normally do not have an Appendix B pedigree,
those have all been upgraded to that level of
oversight.
Again, some of the statistics. As a
result of this portion of the review, there were 308
RAIs; 170 were related to the Aging Management
Program, and I want to explain that. And as a result,
we had 14 open items.
If you look at --
MEMBER LEITCH: Butch, can we just go back
to that Corrective Action --
MR. BURTON: Sure.
MEMBER LEITCH: -- Program again for a
minute? So let me understand, that when there's an
unexpected aging degradation, and the commitment is
that they would put that into their Corrective Action
Program.
MR. BURTON: Yes.
MEMBER LEITCH: Right? Now, that has all
the attributes of a Corrective Action Program,
including trending?
MR. BURTON: Yes.
MEMBER LEITCH: So that --
MR. BURTON: Root cause analysis, extent
of condition, all those. All those.
MEMBER LEITCH: Now, what is the
licensee's commitment to that Corrective Action
Program? In other words, that's just a program that's
in their administrative procedures, is that right? In
other words, what flexibility would they have over
these additional 20 years to change that program?
MR. BURTON: Ah.
MEMBER LEITCH: Say, for example, they
decide, well, we're not going to have trending as a
part of that program anymore.
MR. BURTON: Okay. Good question.
MEMBER LEITCH: Do they have that
flexibility? How would that be controlled?
MR. BURTON: What happens is that all of
the Aging Management Programs are ultimately
incorporated into the FSAR. And being part of the
FSAR, it is subject to -- to all of the requirements
in terms of changing the FSAR, 50.59, all that stuff.
So, and we also have a provision in the
license renewal rule that until those things are
incorporated into the FSAR during the review process
that there is a separate but similar kind of thing
that they have to go through whenever they change
this. There is an annual update that Part 52 takes
credit for.
MEMBER LEITCH: An update of the FSAR.
MR. BURTON: Of the application.
MEMBER LEITCH: Of the application.
MR. BURTON: Of the license renewal
application. There is a yearly update of that during
the renewal phase. Once the -- I mean, the review
phase. I'm sorry. Once the review is over and all of
this is incorporated into the FSAR, then 50.71E takes
over, which is the annual update for the FSAR.
So we try to cover it -- what happens --
the changes during the review phase, and then once
it's put into the FSAR the normal Part 50 update
requirements take over.
MEMBER LEITCH: So that Corrective Action
Program is not described in the FSAR; the AMP Program
is?
MR. BURTON: Yes. The Corrective Action
Program ultimately -- that we're talking about now for
license renewal will be put into what's called an FSAR
Supplement. And there's actually a license condition
to make sure that that happens, which I'll also talk
about.
MEMBER LEITCH: Okay.
MR. BURTON: So we do try to have that --
MR. GRIMES: I would like to add that for
the Corrective Action Program specifically Part 50,
Appendix B, provides the attributes of a Corrective
Action Program, and 50 -- I believe it's 50.54A
describes the process by which approved QA plans can
be revised and updated.
So if there was going to be a change in
trending or the root cause evaluation or any of the
procedural details that an applicant uses in current
operating licenses, as well as renewed operating
licenses, there are regulatory requirements that
monitor the effectiveness of Corrective Action
Programs and provide enforcement vehicles to control
those.
That's one of the reasons why we feel we
can rely on one-time testing to identify conditions
for which an effective Corrective Action Program can
make a determination about whether future inspections
or changes in procedures might be warranted.
VICE CHAIRMAN BONACA: One point, though,
is of interest. You know, the Committee has often
debated one-time inspection versus a periodic
inspection. And this is really the key point, where
the commitment to one-time inspection can be
overturned in case the one-time inspection identifies,
in fact, issues or problems or aging mechanisms that
were not inspected.
And this Corrective Action Program, all of
the elements, I mean, for Appendix B would result,
then, in the -- in a change to that. It would become
a periodic inspection probably with some kind of
periodicity because you identify an aging mechanism
that you did not expect.
So this is an important element, a key
element actually, of license renewal.
MR. BURTON: Yes, very true.
I did want to talk a little bit about the
170 RAIs that related to the Aging Management
Programs. When the original application was
submitted, the Aging Management Program descriptions
were in Appendix A. The staff is used to seeing how
each of the 10 attributes are covered in each of those
Aging Management Programs.
When we looked at Appendix A, it didn't
have that, or at least it didn't have it clearly
broken out. And as a result, there were a lot of RAIs
generated, and it actually turned out that they were
very repetitive, because we had review -- specific
reviewers for each Aging Management Program, and
they're all beginning to ask the same question.
So that's why you have a large number of
questions related to the Aging Management Programs.
They were very repetitive. You didn't address the
scope of the Aging Management Program. Where is that?
And you had that possibly 29 times, depending on what
the specific situation was.
But when we talked to them about it, they
said, "Oh, no. We actually do have it in the form
that you're looking for in Appendix B," and they sent
that to us, and it took care of probably 99 percent of
the questions.
But one of the lessons learned that we had
-- one of the lessons we learned from that was that if
we can start discussions with the applicant fairly
early on to get some of those kinds of questions out,
all of these probably could have gone away.
And what you'll see in some of the
applications that are being reviewed now, after Hatch,
you'll find that now there is a very early engagement
with the applicant to start to ask some of these
fundamental questions in terms of, where is this, am
I not -- I'm not seeing it where it's supposed to be,
is it somewhere else, dealing with some of these
navigational issues. So that was one of the lessons
we learned from that.
MEMBER LEITCH: Butch, I think that the
ACRS members, at least certainly me, found that our
review of Hatch was somewhat complicated by the
functional approach rather than the system approach.
I'm wondering, after all was said and
done, what you felt about that. Should we be trying
to discourage the functional approach, although it --
you know, it finally worked out okay. But are there
others in the pipeline that are using the functional
approach? Could you give us some perspective on those
types of things?
MR. BURTON: Sure. I guess, first, let me
say that the second BWR to come through is Peach
Bottom, and it's in-house now and being reviewed.
They did not take that approach. I think initially
they were going to, but when they saw some of the
challenges that the staff was encountering with it I
think they went back and rethought that.
I will say this. Obviously, I don't know,
it's certainly possible that another applicant may
choose to do that. It was a challenge for the staff,
because it was the first time that we encountered
that. But I think when all was said and done we
learned a lot from going through it.
So if we do get another application that
uses a functional approach, I think the staff is much
better prepared to deal with that. Obviously, we
can't tell them how to package their application
necessarily, but I think that the industry who tends
to watch -- those in the pipeline watch what's going
on now, and I get the sense that the general consensus
is that they will probably stick with a system
approach as opposed to a functional approach.
But if a functional approach comes in, the
staff will deal with it, and I think we probably are
better able to do it now than we were in the
beginning.
MR. GRIMES: Yes, I will -- I'd like to
point out that the vehicle that we've used to try and
discourage excessive use of the functional approach is
the standard form and content for a license renewal
application that is reflected in NEI 9510, Revision 3.
And we also explored this during the
demonstration project on how to improve the efficiency
and effectiveness of the review process. And I think
simply a reflection on the excessive level of effort
required to work our way -- work our way through this
review is a sufficient motivation for future
applicants to pursue a more efficient packaging.
I will say that we are encountering some
difficulty with the Peach Bottom review by virtue of
boiling water reactors have overlapping system
capabilities that tend to make it difficult to
identify -- distinguish between system-intended
functions and component-intended functions.
And so there's still more to be learned in
terms of packaging commodities and being able to
clearly identify the relationship between intended
functions, the components that are relied on, or the
systems, and then the associated aging effects and
Aging Management Programs.
But I do think that the industry and the
staff both have learned a lesson from this experience,
and we'll continue to work towards identifying ways to
make the review process more transparent.
VICE CHAIRMAN BONACA: Yes. I think, you
know, it goes beyond -- the review process goes -- as
we said, an interested member of the public would be
-- I think it's an important issue because, just to
illustrate that, I mean, you may have a CCS system,
and you're looking for what components in the CCS
system are in scope.
And you find that maybe high pressure
injection pumps are not there on the PWR, and the
reason is that they also maybe perform a containment
spray function. So, therefore, they've put under
containment. So you are looking for CCS systems and
you don't find them, and the first assessment is that
a licensee has not included those components in the
scope.
And then, if you search enough, then -- or
you get a response, you know, you get information. So
I think that's an issue that needs continued
attention, because it makes it hard for anyone who
looks at the application to understand what is in
scope and what is not. And it leaves a reviewer with
the question mark of, what is there that I cannot
possibly trace that is not in scope and should be in
scope. So it's an important issue.
MR. BURTON: I do want to say one thing
about Southern's application, because I know that they
have -- people have had very strong comments about the
format and things like that. But I think it's
important to understand at the time they were putting
their application together, a lot of the license
renewal infrastructure had not been fully developed
the way it is now.
And, in fact, you know, they had been
encouraged to try and think sort of out of the box in
terms of unique ways to package and bring it in. And
I don't think anybody anticipated that we would
converge so quickly with GALL and the standard format
for the application in the SER. And so to some
extent, Southern kind of got caught in the wake of all
of that.
But it really was very unique. It showed
some out of the box thinking. I think in that
respect, it was actually very good. I know for the
staff, in terms of some of the navigational issues
that came up, it really challenged us a lot, and I
think we learned a lot from it.
VICE CHAIRMAN BONACA: Yes. I didn't
intend my comments as a criticism of Hatch at all.
They were caught in the -- I just mentioned it as a
criticism of the type of project.
MR. BURTON: Oh, sure. Sure.
Okay. The next few slides I'm going to
talk about some of the inspections that we had. The
first one, not really an inspection, it's the scoping
and screening audit that I talked about before. We
went down to the applicant's offices in Birmingham for
a week to go through their methodology.
Some of the things that we looked at, we
looked at the exemptions of which there were 32, we
looked at the design basis events, and for the design
basis events they had just recently put in an update
to the FSAR, something called a nuclear safety
operational analysis, which really just discussed
primarily their design basis event. So we had a nice,
clean document to look at.
We looked at Commission orders, of which
there were 28 from 1974 through '98. And we also
looked at some of the implementing procedures, and I
want to talk about that a little bit.
But what we were trying to do there in
looking at some of these things was we wanted to look
at some of the source documentation and see what kind
of commitments have they made over the years, and what
structure, systems, and components are they going to
have to have to ensure that they meet those
commitments, and were they, in fact, identified. And
we found that, going through that, that they did, in
fact, identify all of the necessary SSCs.
One of the things that we looked at were
-- and I think this gets to one of your questions
earlier -- was when you look at this, how is that
actually being implemented? We know what -- the
description of the methodology that's in the
application, and we know what's required in the rule.
But how do you actually implement it on the ground for
the reviewers?
And when we looked at the implementing
procedures versus our understanding of how they
institute the methodology, we found some
discrepancies. And what we found was that the
implementing procedures were more goal-oriented, this
is what you should wind up with, as opposed to saying
-- telling a reviewer, "You need to do this, then
this, look at that," you know, those kinds of things.
We were looking for something a little more
prescriptive.
So we were faced with a situation where
the methodology, as it's described in the application,
says one thing, and it looks good. But now when we
look at the implementing procedures we're seeing
something a little bit different. How do we resolve
that?
So, in fact, what we did was we actually
took three systems and actually sat down with the
engineers and said, "Okay. Start us from the source
documents and walk us all the way through and explain
to us exactly what you did." And we went through
those -- I think it was standby liquid control, HPSI,
service water. I think those were the three.
So we actually sat down with them from the
source documents all the way to the results, and what
we found is that what they actually did was as
described in the application and met the requirements
of the rule.
But out of that, because we found a
problem with the implementing procedures, we developed
an RAI requesting them to revise the procedures so
that it reflects what's actually done. And in
response to that RAI, they said that they would update
the procedures. They even gave us a date certain --
September 11th of 2000 -- that they would have that
done.
And it turned out that September 11th just
happened to be the first day of the scoping
inspection. So one of the things that we did as part
of the scoping inspection was to go back and look at
the implementing procedures to make sure that they
were, in fact, updated. And they were. So that was
just an example of some of the things that we found
during the audit.
Okay. I just mentioned the scoping
inspection. That was a week-long inspection at the
plant site. During that inspection, we wanted to see
how the commitments that they make are actually
implemented on site. And that was our first
introduction to their -- what they call -- I think
they call a commitment tracking system, their
commitment tracking system.
And what they do is all the commitments
that are identified in the application and identified
in the -- in our safety evaluation they put into a
matrix, and you can follow that matrix from the
commitment down to the actual implementing procedures
on site.
And we actually followed that through, and
when we looked at the implementing procedures they
actually had redline strikeout versions that had not
been implemented yet, because you have to -- you know,
we have to -- they have to wait until all of this is
approved. But they had redline strikeout versions
basically ready to go.
So, obviously, at this point, when we were
doing the scoping inspection, our goal was not to make
sure that everything was -- everything that ultimately
should be in there was in there, but we wanted to make
sure that they had the process right.
And, in fact, they did. And, actually,
when you look at it, they were actually much further
ahead than some of the previous applications with
regard to the actual implementation of their
commitments. So we were -- we are pretty pleased with
that.
MEMBER LEITCH: At the procedure level, do
you happen to know if they have a system that prevents
those commitments from being inadvertently written out
of the procedures in the future? I know that some
plants have like a margin note or something, so that
it indicates that this particular part of the
procedure is a regulatory commitment and cannot be
just --
MR. BURTON: Right, yes.
MEMBER LEITCH: -- in advertently written
out of the procedure by a future revision to the
procedure.
MR. BURTON: Yes, I understand your
question. And we have Ray Baker from Southern Nuclear
I think can probably answer that succinctly.
MR. BAKER: My name is Ray Baker. I'm the
Project Manager for the Hatch application. And, yes,
you're right. There are some plants that actually do
a marginal notation in the procedures themselves.
That's actually a good way of doing it, I think.
Hatch is currently looking at doing that,
but our process today is to maintain a commitments
database or a commitments matrix, and the
administrative control procedures require a person who
is reviewing a procedure for change to access the
database and make sure that any changes that he makes
to the procedure will not invalidate any commitment,
whether it's a license renewal commitment or other
Part 50 commitments that have been made. And so
that's the current process.
MEMBER LEITCH: Okay. It does the same
thing, just a different way.
MR. BAKER: Yes, sir, that's right.
MR. BURTON: Okay. Our third trip to
Southern Nuclear was for our aging management review
inspection. When we go down for the aging management
review inspection, now we're focusing on the Aging
Management Programs and whether they are, in fact,
written, and some of the supporting documentation on
site actually gets to the applicable aging effects
that it claims to manage.
We did another -- took another look at the
commitment tracking system, this time focusing on the
Aging Management Programs and how the commitments were
tracked. And, again, we concluded that they were
being tracked appropriately, that they had actually
captured everything that they needed to capture.
We had a final inspection, just a couple
of days. This final inspection is optional. It's
really sort of a cleanup if there are any outstanding
issues that we may need to check in -- that we
identified previously that maybe need to make sure
that are properly followed up on. We take a couple of
days and go down and do that. Again, we found that
everything -- any final questions that we had they had
taken care of.
Okay. Next thing, wanted to talk a little
bit about some open items. First of all, in terms of
summary, in our SER we had 18 open items that were
identified. Twelve of them were resolved without
appeal. Six of them went through the appeal process.
And, you know -- and I can -- I'll be talking about at
least a couple of those later on.
One of the issues -- and I brought this up
primarily because this was brought up a couple of
weeks ago with the subcommittee -- had to do with
buried components. What we have is a one-time
inspection of the buried fuel oil storage tanks, and
that was one of the open items.
And what Southern Nuclear had done was
they were -- had actually looked at one of the four
buried tanks. These are huge 40,000-gallon tanks.
They had actually done -- gone in and looked -- done
some ultrasonics and stuff like that on one of the
tanks, to look at the tank bottoms to see if there was
any age-related degradation.
They took advantage of the opportunity of
being in the tank to do that and found none. They
took that experience and said, "Okay. Well, the other
three tanks, same material, same environment, they've
been buried for the same period of time. We think
that the results that we saw in the one are applicable
to the other."
The other thing was that there was --
there are also fuel oil tanks for the diesel-driven
fire pumps. These are much smaller. They're above
ground. You can just go and look at them any time.
And so because they are the same material in -- the
environment was even more benign than the environment
of the buried tanks, we felt like the condition of the
buried tanks bounded those for the fire pumps. So
that was how we had resolved that one.
A couple of weeks ago we got into a
discussion of, what exactly do you do in terms of
managing the tanks? What do you do if there, in fact,
is some leakage of those big tanks? It's underground.
You can't see it. What's the safety consequence of
that?
First of all, the interior of the tanks
are inspected via tech specs. What they have in their
implementing procedures, one of the things that we
looked at when we went down there was as part of their
-- the implementation of their Structural Monitoring
Program they have excavation procedures that direct
them to -- if you're digging up and around that tank,
go and take a look at the coatings, because the tanks
are coated.
And there's a protective coatings Aging
Management Program that gives them all of the details
of how to do that. So that was how that was taken
care of.
MEMBER FORD: Could I just ask a question
on the --
MR. BURTON: Sure.
MEMBER FORD: When you said that there's
an Aging Management Program for the protective
coatings, for instance, to what depth does your staff
go to examine whether those programs are adequate
technically?
MR. BURTON: Okay. And I don't know all
of the technical details, but I think I've got my guy
here, Jim Davis, who can --
(Laughter.)
-- speak to that.
MR. DAVIS: I was actually on the NISC
Committee that wrote the underground coatings
specification for the Department of Transportation,
and I reviewed this. There's quite a bit of
difference in what they do and with what you'd have to
do with an oil or gas pipeline or a tank on ground.
But we looked at the program, and we've
negotiated with NEI and the industry, and we have an
alternative program that we find is acceptable. And
that is the UT measurements on the bottom of the tank
to make sure that there's no corrosion due to the soil
and no corrosion due to water being on the bottom of
the tank.
For buried pipe, we had a lot of
discussion on all of the applications. And,
basically, any time they dig the pipe up they're going
to examine the pipe.
In addition to that, they're not taking
credit for what they're doing. In a lot of cases they
have some -- some of the utilities have Cathodic
Protection Programs and they do the pipe-to-soil
potential surveys, which is what the standards tell
them to do. But they're not taking credit for that
because the equipment was not purchased safety-
related.
So they have a program that they're not
taking credit for, and they have a program whenever
they dig up the pipe they look at it, and they're
taking credit for that for aging management.
MR. GRIMES: And, Dr. Ford, I'd like to
add to that that in general all of the technical staff
used the 10 attributes of an effective Aging
Management Program in order to decide, as Dr. Davis
pointed out to -- these negotiations that he referred
to are basically identifying what is necessary and
sufficient for any one of the attributes, the 10
attributes. And that is what we referred to as our
basis for concluding that the program is technically
effective.
MEMBER FORD: The reason why I'm picking
it up is, as I mentioned at the last meeting, I don't
doubt that what you've said is correct. It is in the
public forum that we made it clear that that has been
done.
MR. GRIMES: And to the extent that we
continue to look for ways to enhance the Generic Aging
Lessons Learned that constitutes the compendium of
what attributes we feel are necessary and sufficient
for any one of the programs, and those areas where the
staff feels that the 10 attributes might not be clear,
or might have some plant-specific variability and want
further staff attention.
CHAIRMAN APOSTOLAKIS: Chris, you really
mean only sufficient, not necessary and sufficient,
right?
MR. GRIMES: I mean necessary and
sufficient.
CHAIRMAN APOSTOLAKIS: Really?
MR. GRIMES: To the extent that -- yes,
the -- there are -- those things that we feel are
really needed in order to be able to defend the
effectiveness of a particular program and manage the
applicable aging effects.
And in some cases we, in the industry, got
into long and heated debates about whether or not
particular attributes like trending -- you know, when
is trending needed for things that don't occur on a
frequent enough basis to establish a good trend. So
we did want to really come out and say, "What are
those things that are really necessary for an
effective Aging Management Program, as well as what is
sufficient for the purpose?"
That's the standard that we use in order
to ensure that we're achieving our -- the agency goal
of not -- of avoiding unnecessary burden.
VICE CHAIRMAN BONACA: Could you put back
the previous slide? The last bullet you say that
continually inspected the -- via tech specs. What
does the inspection consist of that's not -- I mean,
we are talking about here a one-time inspection of
buried fuel oil storage tanks --
MR. BURTON: Right.
VICE CHAIRMAN BONACA: -- from inside.
MR. BURTON: Right. What --
VICE CHAIRMAN BONACA: That is not
repeated.
MR. BURTON: Yes. One of the things that
we talked about last week, one of the questions that
you had was, what's normally done with these tanks in
terms of, you know, going in and taking a look and
stuff? And what normally is done is they go in and
they clean the tanks periodically, and stuff like
that.
Normally, what they do is they take
advantage of that time to go in and look around, see
what evidence there is of age-related degradation,
things like that. I don't know if you guys wanted to
add anything.
VICE CHAIRMAN BONACA: That's a visual.
I mean, that's just a visual inspection.
MR. BURTON: Right.
MR. PIERCE: Yes. My name is Chuck Pierce
of Southern Nuclear. I think what Butch is referring
to up there when you say interior inspected via tech
specs, just to add a little bit to that, is we have
provisions in the tech specs to check the tanks
monthly to make sure that they -- for level, and there
are ways that -- we have both Control Room indication
and we can go out and take a dipstick and check the
tank monthly for level and see if there's any change
in level and deal with any leaks from that
perspective.
VICE CHAIRMAN BONACA: Yes. This is
important because, I mean, during the subcommittee
meeting we had the discussion regarding the
acceptability, and the concern was possible external
damage that may result in doing installation that may
have caused the coating to be fractured or broken,
and, therefore, corrosion to come in from the outside.
And two points were made. One is that
that would be a concern also with the current license
term and not necessarily just specific to the license
renewal.
And, second, we looked at the -- these are
not the day tanks. We asked specifically that
question. These are the backup tanks, and that if, in
fact, a leak developed, there will not be a
significant safety concern because it would not lead
to significant depletion of inventory of fuel before
-- to prevent any safety function, you know.
So that was one consideration that the
subcommittee discussed, and I believe we had some kind
of concurrence on that perspective.
MR. BURTON: Yes. We --
VICE CHAIRMAN BONACA: So we are going
back to the meaning of the rule when it talks about 70
systems, support systems that support the safety
function, and so on.
MR. BURTON: Right. Okay. Next thing I
was going to talk about was fire protection a little
bit. And, actually, for fire protection let me go
back to scoping for just a second. As I'm sure you
all are well aware, fire -- the licensing basis for
fire protection systems, they vary widely across the
industry. There have been so many exemptions that
people have taken.
And so the cumulative benefit of doing
reviews that we normally get for most systems we don't
get as much for fire protection because they are so --
they are so unique so many times. So what we've found
is that when we're doing the scoping we find that
we've got to get our fire protection engineers
involved and digging down into the licensing basis
pretty early, looking at the fire hazards analyses
and, you know, some of the commitments there, to see
what exactly is necessary to meet 50.48.
So we -- that is one of the lessons
learned is that to get our fire protections -- fire
protection engineers in there early to start looking
through these. And, in fact, for Hatch we had -- we
had folks down there looking at fire protection both
at the audit stage and at the scoping inspection
stage, doing some walkdowns and things like that.
So from a scoping perspective, fire
protection is somewhat unique in that we really have
to hit it early.
In terms of aging management fire
protection components, there is a separate Aging
Management Program for that -- fire protection
activities. One of the things that came up a couple
of weeks ago had to do with aging management. There
wasn't an issue with some of the other components in
the system, but there was an issue with what -- how
they managed the sprinkler heads.
And what that issue was is that we asked
them to follow the guidelines of NFPA-25. NFPA-25
says that sprinkler heads need to be looked at after
50 years, and then again at 10-year intervals. And
given the fact that we're now looking at plants that
are going to be operating for 60 years, how does all
that play out?
And that actually came up as an issue for
the staff, and then it -- we also discussed it a
little bit at --
CHAIRMAN APOSTOLAKIS: What's the basis
for the 50 years?
MR. BURTON: Okay. And that was one of
the questions. One of the things -- and we have since
gone back and actually tried to take a look at that.
The basis for the 50 years came from a statistical
study. I have the information right here. What they
did was they looked at 3,000 sprinkler heads, and
they've traced these over rolling 10-year intervals to
look at the degree of age-related degradation.
And what they found statistically is that
heads that were in use for 55 to 60 years had only a
two percent failure rate. And those who -- those that
were in service for 40 years had a 1.8 percent failure
rate. So given those numbers, I guess it was
engineering judgment that said, "Look, I think we can
be pretty confident that these things will operate for
about 50 years without suffering an extensive amount
of age-related degradation based on these numbers."
So it was really based on a statistical study.
CHAIRMAN APOSTOLAKIS: So they have a
failure rate of 1.8.
MR. BURTON: For 40 -- over 40 years.
CHAIRMAN APOSTOLAKIS: 1.8 what, percent?
MR. BURTON: 1.8 percent of the sprinkler
heads.
CHAIRMAN APOSTOLAKIS: So two percent.
MR. BURTON: Roughly two percent.
CHAIRMAN APOSTOLAKIS: Times 40. That's
80, right, .8 probability of failure in 40 years? Is
that what it is?
MR. BURTON: I don't think it was roughly
two percent per year. I think it was roughly two
percent cumulative over the entire time. You're going
to ask me a lot of details about the study I don't
really know, but --
CHAIRMAN APOSTOLAKIS: I'm just curious
how these --
VICE CHAIRMAN BONACA: It makes a big
difference.
MR. BURTON: Yes, that's a big difference.
I would think if it was the kind of numbers that you
said, they probably wouldn't go with 50 years. But
that's --
VICE CHAIRMAN BONACA: Well, you go with
the explanation of distribution, multiplying straight,
you know --
CHAIRMAN APOSTOLAKIS: Well, I think it's
1.8 and --
MEMBER FORD: When this question came up
at the last meeting, essentially we made the
observation that 50 years is unbelievable, from a
knowledgeable public's viewpoint, with their cars,
etcetera, etcetera, etcetera.
Dr. Davis gave a very good corrosion
engineering explanation as to why it's not
unreasonable, and your statistics can bear that out.
However, the arguments that are made are dependent
very much on maintaining a specific environmental
material, environmental system.
MR. BURTON: Absolutely.
MEMBER FORD: How sure are we that that
has been maintained at Hatch?
MR. BURTON: Okay. Good question. And,
in fact, what Dr. Ford is saying is true. The study
that I refer to does say that these numbers are good
assuming that you have good maintenance, good
inspections, all those good practices.
MEMBER FORD: Adherence to certain
corrosion criteria.
MR. BURTON: Right. And what you will
find is that some of those conditions that back up
these kind of numbers are what you find in some of the
actions that are called for in the protective action
activities AMP.
MEMBER FORD: And in terms of monitoring
and control at Hatch.
MR. BURTON: Yes.
MEMBER FORD: Okay.
MR. BURTON: What you're speaking to now
are those 10 attributes, the detection methods, the
frequency of inspection, those kinds of things. Those
are the 10 attributes that we look for for all of the
Aging Management Programs.
MEMBER FORD: Maybe I'm misreading that
second sentence that you have there. It's saying
essentially that it hasn't been looked at, and it
won't be looked at until 50 years.
MR. BURTON: Oh, okay. Well, yes, maybe
I --
VICE CHAIRMAN BONACA: But the system is
tested.
MR. BURTON: Oh, yes. Yes. In addition
to the normal system testing, right.
VICE CHAIRMAN BONACA: What is the
frequency of testing?
MR. BURTON: Again, I don't know the
details of that. I don't know if --
VICE CHAIRMAN BONACA: Over here, is that
the frequency?
MEMBER POWERS: I mean, the fire
protection systems each year get 35 hours worth of
inspection in the normal program. And what they're
specifically looking for is degradation in both the
automatic and the manual fire-fighting capabilities.
There is, in addition, a triennial
inspection that's looking more at the safe shutdown
capabilities, but included in that is the ability to
keep one train of shutdown capabilities free of fire
damage. Where the licensee has relied upon automatic
suppression, as part of a campaign to keep one train
free of fire damage, they would look at that
suppression capability every three years.
MEMBER FORD: Okay. So the communication
that's given by that second sentence is misleading.
VICE CHAIRMAN BONACA: If it implies that
it is a first inspection, absolutely, yes.
MEMBER POWERS: Typically, on the -- the
challenges that you have with sprinkler heads is the
activation mechanism of them, because they can't be
located close enough to a ceiling, just by where they
are. And various mechanisms are done to make them
effective, and that includes things called heat
collectors and things like that, which nobody knows if
they really work. In fact, they may work the wrong
way.
But, I mean, it -- I mean, these things
are looked at. I mean, and people agonize over them
at some -- to some great extent, because they are part
of a major feature of the plant safety.
VICE CHAIRMAN BONACA: Actually, though,
it is important to note that this inspection here, the
first one, is intended to be actually either a
replacement of the head, straight number -- 50 years
you replace the head, or you inspect it closely enough
to determine that it is still performing as good as it
should.
CHAIRMAN APOSTOLAKIS: How is it different
from a test? Maybe this is --
MR. BAKER: Dr. Apostolakis, the NFPA-25
test that -- inspection that's referred to here is a
destructive examination of a sample of sprinkler heads
that's in addition to the normal fire protection aging
management activities.
So this is -- this is an ultimate
verification, if you will, after 50 years that you
still have sprinklers. You have confidence that the
remaining sprinkler heads of that type will, in fact,
perform as intended.
MR. GRIMES: I'd also like to add -- I was
wounded slightly by Dr. Ford's statement that the
second bullet was misleading. It's a factual
statement. NFPA-25 recommends sprinkler head
inspections after 50 years. We frequently refer to
industry standards as having particular provisions.
But embodied in that particular factual statement is
a reliance on a whole host of plant preventive
maintenance and inspection activities, housekeeping
methods.
There's a panoply of stuff that underpins
our particular reliance on a standard. If we say we
rely on the ASME Code, you know, we trust that you'll
understand there's a whole lot more to the in-service
inspection program with respect to maintenance of the
environments or, you know, preventive maintenance of
the plant condition.
So we didn't intend to be misleading. We
just intended to refer to -- that was the underpinning
of the resolution of this particular issue.
MEMBER FORD: I guess I'm showing the lack
of my knowledge. But as an informed member of the
public, if that's the only information I had, I'd be
worried.
CHAIRMAN APOSTOLAKIS: I wonder whether
you are hurt, too.
(Laughter.)
VICE CHAIRMAN BONACA: Just one piece of
information we received in the subcommittee meeting
was that the 50 years, it's -- does not refer to --
from the day of start of operation, but it refers to
the day of installation I guess. And for this plant,
I believe that the 50 years will come three years into
the license renewal term.
And, you know, that gave us some comfort,
that at least at the beginning of the license renewal
term, or close enough to that, we are going to have a
distraction --
CHAIRMAN APOSTOLAKIS: The point is that
these inspections give you a lot of information. You
are collecting information through the tests.
VICE CHAIRMAN BONACA: Yes.
CHAIRMAN APOSTOLAKIS: So that's really an
important point. I mean, it's not that they're
looking at them for the first time in 50 years.
MR. BURTON: And thank you for the
clarification, Dr. Bonaca, because I was going to make
a point that that 50 years is not 50 years of plant
operation, but 50 years from the time the system is
declared operable.
VICE CHAIRMAN BONACA: So, evidently, that
has been installed for seven years before the plant
went to power.
MR. BURTON: Right. Exactly. Okay. I
guess I'll have to rethink this slide. Okay.
CHAIRMAN APOSTOLAKIS: So since NFPA-25
says it, it must be right, right? It's in NFPA --
MR. BURTON: Well, I --
CHAIRMAN APOSTOLAKIS: Or you don't know
about the NFPA-25 -- that's okay.
(Laughter.)
MR. BURTON: You caught me on that one.
I don't know what to say. Yes.
A couple of the other open items that we
have talked about were -- had to do with postulated
pipe breaks and cast austenitic stainless steel
components; specifically, the jet pump assemblies and
fuel supports. One of the open items that we had
developed and that did go through the appeals process
had to do with whether or not postulated pipe breaks
should be considered a time-limited aging analysis.
And the way that works is that the
cumulative usage factor for fatigue is part of what's
considered in identifying locations for pipe breaks,
and it itself is a TLAA. And so the question was,
well, if that is, shouldn't this be also? That was
point one.
The other point was that in our statements
of consideration it called out postulated pipe breaks
as being one of the things that should be considered
a TLAA. Southern Nuclear felt that that was something
that didn't necessarily need to be considered as a
TLAA, and that was taken through the appeal process,
which I'm going to talk about in a few more slides.
And in the end, we decided that, yes, it
probably should be considered a TLAA, and that
resolved the issue and they gave us all the supporting
material that we needed for that.
Another one had to do with cast austenitic
stainless steel components. The question was whether
there needed to be a one-time inspection of these
components. The staff's initial position was that
there probably should be. We went -- again, this was
also taken through appeal, I believe. I believe this
was one of the appeal items.
And it was decided that rather than
looking at the components themselves, which industry
wide have actually shown no evidence of cracking, for
those inspections that have been done, that, rather,
we should probably look at focusing on the welds. And
one of the BWR VIP reports, VIP-41, actually gives
guidance for the inspection of some of the welds.
And so the idea was that the welds would
probably be a precursor to cracking in the components.
So as part of the resolution, we said, "Okay. We're
not going to ask for a one-time inspection there.
We'll let the inspections of VIP-41 of the associated
welds be the precursor for that."
MEMBER FORD: Butch, again, at the meeting
we had a while ago, this also came up with quite some
discussion. The question being as to whether the
inspection of another component is necessarily a
precursor to failure of these components.
MR. BURTON: Right.
MEMBER FORD: Given that you've got a
different material, maybe a different degradation
mechanism. And we were rather put at ease by the
statement that there was going to be a research
program on this topic.
Could you just give very, very quickly
some idea of the timeliness of this research program?
When will it be completed, to support this conclusion?
MR. BURTON: Okay. Sure. And let me just
say very quickly is that, yes, one of the things that
we talked about was having some joint research done
between the BWR VIP and our Office of Research to just
-- just to confirm that -- whether or not doing
inspections of these components really is warranted.
And, actually, I have my BWR VIP guy here,
Gene Carpenter, who can speak to that. So --
MR. CARPENTER: Good morning. This is
Gene Carpenter from Materials Chemical Engineering
Branch. Yes, we are looking into the possibility of
doing some joint research, as Butch was saying. At
this time, we have not gotten that onto the schedule
for research to be conducted in fiscal year 2002 or
2003.
We are planning to have it at some time in
the very near future, hopefully to run for a period of
no more than three years, at which time we should have
some additional information to make determinations as
to whether or not any inspections will be necessary in
the license renewal term.
MEMBER FORD: So it could be six years
before you have any data at all to confirm this
assumption.
MR. CARPENTER: But that is still before
Hatch will go into a license renewal term.
MEMBER FORD: That is true. I've got one
other question. I think this is your last slide on
AMPs, is it not?
MR. BURTON: Yes.
MEMBER FORD: There was another question
brought up about stress corrosion cracking of high-
strength bolting.
MR. BURTON: Yes.
MEMBER FORD: Which is one of the open
items. And it was put to rest as far as Hatch was
concerned in that inspection of the bolting indicated
no problems, and that they were all below the 150 KSI
yield point, which is generally attributed to cracking
of the high-strength components. It's pure luck,
however, that it was below 150, because there's no
upper specification limit.
This question has nothing at all to do
with Hatch. It's more of a generic question. Since
there is not an upper specification limit, how are we
sure that this is not going to be a problem in the
future? And how are you going to address that?
You're really -- you're looking at it in a reactive
mode.
MR. BURTON: Yes.
MEMBER FORD: Rather than a proactive
mode.
MR. BURTON: Yes. I understand what --
MEMBER FORD: For replacement bolts, for
instance, or whatever you might do.
MR. BURTON: Okay.
MEMBER FORD: Are you going to ask that
there be an upper strength specification on such
bolts?
VICE CHAIRMAN BONACA: This is important
also because, if you remember, we discussed this in
the previous application, and we -- I was confused.
I thought they were the same bolts. The licensee told
us that they had limits, torquing limits, on those
bolts, below 150 KSI.
And we were told by the staff that they
were a different type of bolts, so that would be good
for us to have an understanding of what bolts we're
talking about and why in some cases you impose a
150 KSI limit on torquing activities, and in other
cases you don't.
MR. BURTON: Okay. Yes. And I'll ask Jim
Davis --
MR. DAVIS: Jim Davis from the staff.
It's pretty well known throughout the industry about
the 150 KSI limit. It's been discussed at a lot of
technical meetings, and a lot of people have those --
that limit in their specs now.
The problem is there's in the neighborhood
of 40,000 studs, bolts, fasteners, in a plant, and
it's pretty difficult to backfit all of those.
Certain ones they know there's troubles with. These
are the assay 193 B7 volts, and have a 105 minimum
yield. And they've come in as high as 150-, 175,000
KSI yield, looking back at the material test reports.
What we've done is I've raised this
question with every single application so far, and
they'll all cited the industry experience. There's
been one case of cracking, and that was at Dresden on
their reactor closure studs. And those are the four-
inch diameter closure studs, and they actually cracked
in a very short time. They had a crack 180 degrees
around, about two inches deep.
They don't crack when a reactor is in
operation because it's too warm and the moisture
doesn't get there and cause the corrosion, cause the
damage. So there's only two cases that we've ever
seen of cracking other than 410 bolts that cracked in
Anchor Darling check valves.
So we've let them rely on operating
experience to say that they haven't seen the problem,
and Hatch actually looked through their certified
material test reports and showed that they were --
they were all under 150 KSI yield. So that's the way
the industry has approached it. It's just too
expensive to go back and replace all those fasteners,
because there are just so many of them.
MR. BURTON: Okay. Now I'm going to go
and move on to one-time inspections. At the
subcommittee, we had --
MEMBER LEITCH: Just before that, if you
were going to leave open items, there was one that I
was assigned lead responsibility to follow up on. And
I was not at the subcommittee meeting, so I -- and it
had to do with housings for various fans in the HVAC
system.
And I guess the question was whether they
were -- I guess the licensee considered them active --
the fans were active, certainly, but whether the
housing were a part of that or not, and I think
staff's position was that they were really passive,
long-lived components, and, therefore, should be part
of a program.
I guess from reading it looked like that
issue was satisfactorily resolved, and they are,
indeed, going to be part of the program.
MR. BURTON: Right. Yes. I'm glad you
brought that up. We had an open item having to do
with housings for certain active components -- fans,
dampers, things like that. They were in scope, but it
turned out that Southern Nuclear decided that they
didn't need to be subject to an AMR because they they
were part of the active -- the associated active
component. And, as you know, active components are
not subject to AMR under license renewal.
The staff's position, though, was that the
housings for these active components we should be
treating them similar to how we treat valve bodies and
pump casings, which are specifically called out in the
rule and the associated statements of consideration.
The idea is that the component may be
active, but the housing for that component may have a
pressure boundary function, structural integrity
function, something that is necessary in order for
that active component to work. And as such, if that
housing is long-lived and passive, and it has
applicable plausible aging effects, then we need to
look at that. We need to capture that in license
renewal as part of an Aging Management Program. That
was the staff's position.
When we looked at it, Southern Nuclear
said, "Well, no, the valve housings and the pump
casings are specifically called out in the rule and
the statements of consideration, and that -- and also
in the guidance document NEI-9510." And that because
they are specifically called out, that's all we need
to deal with.
The staff's position was, no, those are
given in those documents merely as examples. And when
you go back and you actually read the wording, every
time valve housings and pump casings are brought up in
those documents, it says "for example." So the idea
is that those are examples of how to treat housings.
And so our staff in doing the scoping and
screening evaluation, we recognize that no, the
housings for fans and dampers are also critical to
making sure that that associated active component can
perform its function. And that went through one level
of appeal, and we -- and in the end it was decided
that, yes, those housings would be subject to an aging
management review and were brought in.
MEMBER LEITCH: Okay. Does that rationale
apply to standby gas treatment, reactor building
ventilation, control room ventilation?
MR. BURTON: Yes.
MEMBER LEITCH: All those important --
MR. BURTON: Yes. In fact, when it was
brought up as an open item, standby gas treatment
system, control building HVAC, outside structures
HVAC, and reactor building HVAC were all captured in
that open item. So, yes, it does apply.
MR. GRIMES: Dr. Leitch, I'd also like to
add we learned a valuable language lesson in the
resolution and clarification of the guidance. There
are some plants that when they talk about the housing
of a fan, they're referring to the frame, and they
consider the shell to be part of the ductwork, in
which case we -- the staff position would -- we would
agree.
We're not looking for the frame that's
holding the motor. We're looking at -- we -- our
interest is the shell, as Butch pointed out. We're
looking at the pressure boundary function. And so
this is -- we've clarified our guidance, so that those
plants that refer to the shell when they talk about
the housing understand our interest is in aging
effects associated with the shell, not necessarily the
frame. The frame we do consider to be part of the
active component.
MEMBER ROSEN: I'm left a little troubled
by the discussion we had earlier about the research
program, which I take to be a research program on cast
austenitic stainless steel.
MR. BURTON: Okay.
MEMBER ROSEN: In that I don't understand
how the process works. If that research should show
some additional aging mechanisms, how that process
works to -- that would lead to the licensee being
committed to doing whatever the research required.
MR. BURTON: Okay. And that's a good
question. I have a slide a little bit later that
discusses how we deal with new and emerging issues.
And, actually, the housings issue was an example of
that, and what you're saying is also. How do we get
that -- the results of that into the whole process?
If you can hang on just a couple more
slides, I think I can speak to that.
MR. CARPENTER: Butch, if I might,
specifically for the BWR VIP program, which this is
part of, that research is part of, what the BWR VIP
program has in place is a commitment to the staff from
all BWR owners in this country, that any activities
that they have committed to -- and this would be part
of a joint research with the BWR VIP, so they would
make appropriate modifications to the BWR VIP-41
report, Inspection and Final Evaluation Guidelines.
They would come back at that point and
revise the inspection criterion for all BWRs. So if
they -- if we find in the future that we need to do
additional inspections for these internal components,
part of this VIP program, then it's already taken care
of by previous commitments to the staff.
MR. BURTON: Okay. So --
MR. CARPENTER: But Butch will also
discuss further --
MR. BURTON: Yes, I guess I don't have to
talk about that part of it. And then the other part
of that also is part of the BWR VIP program. It's my
understanding -- and correct me if I'm wrong, Gene --
but part of the program is that the inspection results
of the VIPs, as the VIPs have been instituted, that
the inspection results are actually published
semiannually. So that everybody who is subject to
those VIPs gets an overall idea of what is going on in
the industry and can deal with it appropriately.
So one of the things that we talked about
at the subcommittee was one-time inspections. This
idea has been talked about a lot for some of the
previous applicants, but it's probably good to go
through it again.
The statements of consideration for the
rule discuss when it's appropriate to do one-time
inspections. And one of the concerns from some of the
subcommittee members is, how can you justify a one-
time inspection if it turns out that there are aging
effects that reveal themselves later on?
So what we do -- first of all, one-time
inspections are intended to be confirmatory only. And
the idea is that when you have a commodity group, a
material-environment combination, which is what we
call a commodity group, if there are normally aging
effects associated with that commodity, but actions
have been taken such as water chemistry, to preclude
that aging effect, the idea is that we're handling it,
we don't expect to see anything, but what we'll do is
we'll do a confirmatory inspection one time to make
sure.
And as Dr. Bonaca said before, if we do
that one-time inspection and, in fact, we do find
evidence of age-related degradation, then through our
Corrective Actions Program -- not ours -- their
Corrective Actions Program, they will take that
operating experience, funnel it through, make whatever
appropriate changes there are to the appropriate Aging
Management Programs, and it may not be a one-time
inspection anymore. It may be an ongoing kind of
thing.
So that's the idea behind one-time
inspections. Make sense? Okay.
MR. GRIMES: Also, and I would like to add
to that, I want to remind the Committee that a
fundamental principle of license renewal that the
Commission noted in the statements of consideration
when the rule was published, that we anticipate that
operational experience in the future may reveal new
aging effects that we just don't know about at this
point in time. We expect to continue to conduct
anticipatory research and learn more things about
aging effects.
The regulatory process provides a means
for us to reflect on that and to identify what
corrective actions we feel should be taken across the
whole of the industry. And it is founded on that
principle that the Commission continues to have that
process, so that we can rely both on the licensee's
Corrective Action Program to identify plant-specific
experience that warrants a change in Aging Management
Programs, or the Commission's generic communication
process can identify actions to be taken on a generic
basis.
And for that reason, we don't need any
special commitments to go look for aging effects that
we do not yet know about. And so it is important that
we be -- that we be able to rely on the regulatory
process to continue to learn and evolve and react, and
that is what -- why we are comfortable with the
concept of one-time inspections and the capabilities
of the corrective action processes to appropriately
maintain the licensing basis starting 10 years hence,
way off in the future.
MR. BURTON: Okay. Next thing I wanted to
talk about was the appeal process. We have technical
differences of opinion with applicants. It happens.
And it's important that we have a reliable,
transparent, predictable way of resolving those.
Another aspect is from a public visibility point of
view it's important for public confidence that people
understand what we do and how we do it. So we've
developed this appeal process.
But I think one thing that's important to
understand is that what we do -- Hatch is not the
first one to have to deal with resolving these kinds
of technical issues. We've been doing this right from
the beginning. The difference is that we've tried to
formalize the process, again, for visibility,
transparency, public confidence.
Let me -- I'm going to jump back and forth
a little bit here. Let me show you the flowchart for
how we do this. I know that's hard to read. But,
basically, if we get a difference of opinion on an
issue, we start it through and what we do is we
escalate it -- hopefully, we resolve it at the first
appeal.
If we don't, it starts to get escalated up
through higher and higher levels of management, both
management -- staff management and applicant
management. So both sides get to see what's --
exactly what's going on.
In the case of Hatch, we had issues that
were appealed first level, at the branch chief level,
and a few that went to the division director level,
but at that point we got everything resolved. So I
think -- which is -- we kind of went down through I
think right around in here. I think that's as far as
we got in the process.
And, of course, as we go through we
document everyone's position. We document the
resolution and the basis for the resolution. And we
incorporate all of that into our safety evaluation.
So we had -- as I had mentioned before, we
had six items that went through appeal. I can't
remember how many were resolved after the first level
and how many went to the second. But we did have six
items that went through appeal.
Let me go back to this now. Actually,
this just says what I already said. If we can't
resolve it at the working level, it's escalated up
through management, and management does hear the
technical arguments on both sides. Because this was
the first time that we went through it in such a
structured way, as with anything else, we found ways
that we could improve the process.
Southern Nuclear had provided some
comments and suggestions on how to improve the
process. And one of the things about the license
renewal infrastructure is we do have processes in
place to capture those lessons learned and ultimately
incorporate them either into the review guidance or
the specific staff guidance for how we do what we do.
But our infrastructure allows us to capture those
lessons learned. So -- and the appeals process is no
different.
Okay. Next thing, treatment of emerging
issues. And Gene already spoke specifically about how
things that are discovered, as far as BWR VIP, gets
factored in. But it's more than that.
The first thing is issues are always being
identified. I don't think there has been an
application yet where we have not had something, okay,
and so obviously we realized later on very quickly we
need to disposition those in a very predictable, very
transparent way.
When we do that, as we resolve an issue,
there are several things that have to be taken into
account. Not only how it's resolved for that
particular applicant, we've got to understand how it's
going to be addressed for those who come after, and
how -- does it need to be addressed for those who
perhaps already have their license.
Okay? So we've got to look at all of
those. And for those who come after, the -- you can
actually break them into two groups. Those who come
immediately after haven't had an opportunity to
incorporate the resolution into their application. So
we've got to disposition that through RAIs and perhaps
open items and things like that.
For those who are a little bit further
out, who still perhaps haven't put their applications
together, they have an opportunity to incorporate
those. And, actually, that's exactly what you've seen
with much of the work with GALL. The plants coming in
in 2002 are the GALL plants. They were far enough out
that they can incorporate all of the resolutions for
GALL.
Those who came in before that at -- such
as Hatch, Hatch did not have the opportunity and the
benefit for all of that. So some of those things have
to be dispositioned in a separate way. But part of
our treatment of emerging issues is to take all those
into consideration.
Another example is seismic two over one,
which I'm sure you all are familiar with. You've seen
that in the SER.
We resolved that. Right now, we developed
a set of RAIs for those immediately after to start
getting their arms around it. For those further out,
we expect that to be dealt with in their application.
Go ahead. I'm sorry.
VICE CHAIRMAN BONACA: Realize, however,
the comment we made regarding -- we raised some issues
regarding how do you provide this guidance to future
applicants, was more pointed to the fact that this
SER, more than previous ones, had significant
clarifications inside them.
For example, seismic two over one, there
is a discussion on a couple of pages in which the
discussion of preventative versus mid-event, again, it
is clearly laid out. And now there is a logic there
that makes sense on why certain components should be
in scope.
And that's very important discussion that
I think, you know, we don't want to have it just lost
into page X of one specific SER. I think that if it
is provided in some guidance format, it will prevent
future open items.
MR. GRIMES: That's correct, Dr. Bonaca,
and I would like -- I'd like to address that. By
making a distinction between emerging issues and
process improvements, which has described the way that
-- as issues come up, we established staff positions.
We've determined solutions. And for issues like the
treatment of non-EQ cables, which emerged in the
middle of the Calvert Cliffs review, we identified an
aging management solution for that that ultimately was
captured in an explanation that was incorporated into
the Generic Aging Lessons Learned Report.
Taking a slightly different tact in terms
of seismic two over one, or an issue that we're about
to bring to the forefront on scope of station blackout
equipment, where there was -- where we discovered that
there was a miscommunication or a misunderstanding
about the true nature and extent of a particular
commitment related to resolution of either scope or an
Aging Management Program.
The process that we followed before the
institution of the improved renewal guidance is the
same process that I would expect to follow after, and
that is we'll send a formal letter to the industry and
to the interested public advocate. In this case, I'd
use Mr. Lochbaum to represent the public interest.
We send a position to them and say that
we've clarified a staff position. We open a dialogue
with our stakeholders in terms of making sure that
we've actually achieved the desired shared
understanding.
And then we'll pull that back into a
decision on where that should be appropriately
reflected, whether it's in NEI 9510, whether it's in
the standard review plan, whether it goes in Generic
Aging Lessons Learned, or there is even a fourth
category and that is that both the industry and the
NRC staff maintain what we refer to as style guides,
and that is common language use that doesn't really
rise to the level that dictates the need for any kind
of formal procedure. It's just a collection of good
practices.
And so we would expect to continue to do
that, and, in fact, we intend on submitting the more
detailed explanation of seismic two over one to the
industry to pursue a generic dialogue with them to
settle any more misunderstandings that we might have.
And then to -- and that then will become
part of the collection of things to do to further
improve the guidance. And I know that you want me to
commit to a date certain for the next revision of that
guidance. But, quite frankly, I've only got two
examples, so far, and I don't think two changes
warrants a reissuance.
But it could be that by the time that we
get the 2002 applicants that we'll have a dozen or so
further lessons from the class of 2001. And at some
point we'll reach a collection that's large enough to
warrant formal revision. But in the meantime, I have
committed the industry that we're going to find a
place to exhibit these clarifications, so that future
applicants and the ACRS and the public will see the
additions to the guidance as they're unfolding.
VICE CHAIRMAN BONACA: Thank you.
MR. BURTON: And I did want to add that as
part of the -- when we inform the industry of the
staff position and we start that dialogue, that that
process does include the appeal process if there are
significant differences to resolve them through the
appeal process.
Okay. Coming down towards the end. As a
result of the staff's review, we identified three
license conditions. The first two are standard. The
first one -- I mentioned before that there is an FSAR
Supplement. It's a summary description of all of the
activities and programs that they are crediting for
license renewal. That supplement has to be
incorporated into the FSAR at the next update
following issuance of the license. We capture that as
a license condition, and that's standard.
The other thing is that in those Aging
Management Programs there are a number of things that
the applicant says that they're going to do before
entering the extended term. We capture those
commitments as a license condition -- again, pretty
standard.
There is a third license condition that we
have for Hatch that has to do with the reactor vessel
Integrated Surveillance Program. This is one aspect
of an Aging Management Program called reactor vessel
monitoring. One of the aspects of that is that you're
going to have a Surveillance Materials Testing
Program.
At the time that the application was
submitted, we had in-house BWR VIP-78 that -- they
were saying that the actions in that BWR VIP, those
are the actions that we're committed to taking for the
capsules.
We had not finished our review of that.
Okay? So we couldn't just bless it. So what they
committed to was they said, "We'll do VIP-78, or, if
for some reason that's not acceptable, we'll institute
our own plant-specific program, because they have
their own capsules."
And so -- and they detailed exactly what
actions they would take, so we have a license
condition that says you need to inform us which of
those two you're going to take. So we have that third
license condition.
MR. GRIMES: Butch, if I may, before you
leave the license conditions, I want to respond
directly to the concern that Dr. Rosen raised before
in terms of in the case of the BWR VIP, there's a
range of commitments that go along with that.
And the staff didn't specifically point to
the associated research activities that Dr. Ford drew
comfort from for CAS. We identified an aging
management practice that we concluded was acceptable
with surrogate inspections.
The research program provides added
comfort. And it does get captured as a commitment,
along with all of the other commitments, for program
descriptions that will be included in the FSAR that
can be managed pursuant to 50.59.
The Integrated Surveillance Program,
however, didn't have the benefit of the commitments.
It, in fact, was a promise to develop a program in the
future for which we needed to call it out separately
as a license condition in order to ensure that that
program would achieve all of the necessary program
attributes.
So it gets treated different from all of
the other commitments that are simply referred to or
articulated in the FSAR.
MR. BURTON: Last slide. And I'm ending
where I started. 10 CFR 54.29 outlines the criteria
to determine whether or not it's okay to grant a
renewed license, the three bullets that you saw at the
beginning of my presentation. Hopefully, after the
presentation you have a little bit better
understanding of the basis for us feeling that they
have actually met this criteria.
That's all I have.
VICE CHAIRMAN BONACA: Thank you very
much.
Now I would like to just mention that I
thought it was a very good presentation on your part.
I think it was one of the better presentations we had
insofar as being informative. And I'm saying this
just because, first of all, to recognize you but also
to say that this kind of format for the final
presentation to the ACRS I think is valuable. It, you
know, comes down to issues that we have expressed
concern on rather than just simply statements of
closure of open items.
So with that, I thank you. And I would
like to know if there are any comments from members of
the public, or questions. There are none. Therefore,
I'll give it back to you, Mr. Chairman.
CHAIRMAN APOSTOLAKIS: Thank you, Dr.
Bonaca. We'll recess until 10:25.
(Whereupon, the proceedings in the
foregoing matter went off the record at
10:04 a.m. and went back on the record at
10:23 a.m.)
CHAIRMAN APOSTOLAKIS: Okay. We're back
in session.
The next item is the Dresden and Quad
Cities core power uprate. Dr. Ford has an
announcement to make.
MEMBER FORD: Being a GE retiree, I have
a conflict of interest.
CHAIRMAN APOSTOLAKIS: Okay. And the
Chairman of the cognizant subcommittee is Professor
Wallis, who will lead us through this discussion.
Graham?
MEMBER WALLIS: Thank you, Mr. Chairman.
I'd like to point out to the Committee
that these applications for a power uprate from Quad
Cities and Dresden resemble the application from Duane
Arnold that we reviewed last month. The major
technical issues are much the same as in their
previous application.
The Thermal Hydraulics Subcommittee met
with Exelon and the staff on October 25th, 26th, for
a total of one whole day. And Exelon and the staff
now have to compress those earlier presentations by a
factor of four, so I propose to dispense with any
further introduction and invite John Nosko to begin
his presentation on behalf of Exelon.
MR. NOSKO: Thank you, Dr. Wallis, and Mr.
Chairman.
On behalf of Exelon Nuclear, we would like
to thank you, thank the Committee, for reviewing our
application and our submittal, and for giving us the
opportunity this morning to make this presentation.
Our presentation does follow the published
agenda. It incorporates materials to address the
questions received from the ACRS before the meeting.
There is one question that did come to us late
yesterday on core parameters. It is not part of our
main presentation, but we will be prepared to discuss
it during our section on response to subcommittee
questions.
Our submittal is requesting a 17 percent
increase in license power level for the Dresden
station and a 17.8 percent increase for Quad Cities
station. The goals of our project are to safely use
the excess capacity currently available at the
stations to increase power production levels to
leverage industry experience by using a proven and
accepted methodology to minimize the impact of the
uprate on the stations by maintaining a constant
reactor dome pressure, and to make our analyses and
designs for both stations as similar as possible, to
simply reviews and configuration management.
We'll be taking advantage of installed
spare capacity at the stations. The clearest example
is that we'll be operating all four of our condensate
and condensate booster pumps, and all three of our
motor-driven reactor feed pumps. I should note that
using all installed feed and condensate pumps is not
uncommon in the industry.
This uprate will be accomplished in one
phase. The plant modifications will be installed
during the next refueling outage for each unit and in
the online period immediately preceding that refueling
outage. And following the uprates, our units will be
generator limited, which means we'll be varying
reactor power seasonally to maintain maximum output
from the generators.
This next slide summarizes the differences
in key operating conditions between the plants today
and what we expect after the uprate. At Dresden,
thermal power is increasing from 2527 megawatts
thermal to 2957 megawatts thermal. Quad Cities is
currently rated at 2511 megawatts thermal, but is
increasing to the same uprated power level.
Steam flow is increasing from 9.8 million
pounds per hour to just over 11.7 million pounds per
hour. You can see maximum flow through the core does
not change, and neither does reactor dome pressure and
temperature.
Looking at some significant plant
differences, the Dresden and Quad Cities are BWR-3
sister units, but there are differences between the
plants. There's a slight difference in license
thermal power levels, as I just mentioned. Quad
Cities has a mix of Siemens and GE fuel in the core,
but Dresden-3 no longer has any GE fuel in it.
Dresden-2 recently reloaded new GE 14 fuel during this
past refueling outage that just completed.
At our meeting with the subcommittee a
couple of weeks ago some differences in the power-to-
flow maps for the two stations were noted. Although
the MELLLA line for both maps is the same, there are
differences in the natural circulation lines and the
recirc pump minimum speed lines.
Stations originally had the same natural
circulation line, but some years ago Quad Cities
station was able to collect plant data that revised
their PIRT. And, in addition, Quad Cities has a limit
of 32 percent for their recirc pump minimum speed to
avoid system vibrations, but Dresden is able to
operate satisfactorily down to 28 percent speed.
Dresden and Quad Cities have different
systems to provide key functions at the plants. For
core isolation cooling, Dresden uses a nearly passive
isolation condenser system. Quad Cities has a single
multi-function RHR system, but Dresden has separate
systems for shutdown cooling and for low pressure
coolant injection. And a physical construction
difference at Quad Cities allows cross-tying of their
spent fuel pools.
Looking at some of the plant modifications
now, new GE 14 fuel assemblies will replace the
existing GE and Siemens fuel. This will be done
gradually over three or four operating cycles, and
this new fuel will allow us to reach the higher EPU
power levels while maintaining a 24-month operating
cycle.
I mentioned Dresden and Quad Cities are
BWR-3 units. As such, their steam dryers are smaller
than the later designed BWR-4s, 5s, and 6s, and are
not able to handle the increased steam flow and
extended uprate as well. So to prevent the higher
moisture carryover levels that would have otherwise
been predicted, we decided to modify the steam dryers
to keep those levels to no greater than they are
today.
We're adding clamps to eight of the 20 jet
pump sensing lines to eliminate a concern for
potential vibration-induced failure of those lines
caused by the passing frequency of the reactor recirc
pumps.
A research system runback and a low water
level SCRAM setpoint change are being added to improve
station availability. Today only two of the three
reactor feed pumps and three of the four condensate
pumps need to operate at rated power, and if a pump
trips, the standby pump automatically starts.
After the uprate, we will no longer have
a standby pump, so we're adding this runback feature,
the SCRAM setpoint change, to prevent a low water
level SCRAM on loss of either a single feed pump or a
condensate pump.
Changes to the isolation condenser time
delay relay and to the low pressure coolant injection
swing bus timer are being made to reflect accident
analyses for the extended uprate, and we're also
making setpoint changes to nuclear instrumentation.
MEMBER WALLIS: In your presentation, will
you go back into the -- go back over some of the new
accident scenarios that are envisaged with the
runback?
MR. NOSKO: We will be able to discuss
that at that point in time, sure.
MEMBER ROSEN: Will you also be able to
discuss the testing that you envisaged for the runback
system?
MR. NOSKO: Yes, sir. Yes, sir, we can
discuss that. We do have a separate section on
testing and implementation later on, and we'll be glad
to incorporate that.
For our balance of plant -- I'm sorry,
sir.
MEMBER LEITCH: Excuse me, John. Will the
plant be able to reach the full extended license
capability after the first cycle of -- after the
modification is done in the first refueling outage?
Or will that require three refueling outages until you
get all of the new GE fuel and --
MR. NOSKO: No, sir. We will be able to
reach full power. I did mention that we will be
generator limited, so for that reason we might be a
couple of percent megawatts thermal shy of what the
license request is.
MEMBER LEITCH: So it could be that -- I
think at Byron and Bradewood that that is the
situation, isn't it? In other words, you're running
at like only 99 percent power because of -- in other
words, you're not able to achieve the license --
MR. NOSKO: Byron and Bradewood, there is
a -- it's Byron station and -- one of the units at
Byron station, and that's not to do with the fuel. It
has to do with the way they're measuring feed flow.
MEMBER LEITCH: I see.
MR. NOSKO: So, for us, we will be able to
achieve -- with the first refueling, we will be able
to achieve the higher power levels.
MEMBER LEITCH: Okay. Thank you.
MR. NOSKO: Yes, sir.
Continuing, then, with the balance of
plant modifications. We're making changes to the high
pressure steam path. We're installing a new high
pressure turbine, and we're changing the setpoints of
the cross-round relief valves.
The piping analyses that were conducted
show that we needed to make changes to our main steam
and TORUS attached piping supports as well as to some
dry well support steel. We're upgrading the
interrupting capability of the non-safety-related 4KV
switch gear to handle the additional running loads.
A feature to trip the delta condensate
pump on -- if -- in the event of a loss of coolant
accident is being added, so we can retain the ability
to shut down with feedwater. And there are more
changes, but time doesn't permit me reviewing all of
the balance of plant changes to other systems.
We performed all of the evaluations
required by the licensing topical reports for extended
power uprates. Those analyses used NRC approved
methods within previously accepted ranges. And in all
cases the results were within the acceptance criteria
for the ultimate EPU configuration of the stations.
And with that, I would like to introduce
Tim Hanley of the Quad Cities station, and Jason Post
of General Electric Company, who will begin the
discussion of analyses and evaluations with the
thermal hydraulic analyses conducted for the uprates.
MR. HANLEY: Hi. My name is Tim Hanley.
I'm the Senior Reactor Operator at Quad Cities station
and the senior license holder at Quad Cities station.
I'm going to cover stability, and then Jason will take
over and cover the ATWS analysis.
Why don't you go ahead and go to the next
slide, and I'll talk through that.
Both Dresden and Quad Cities currently are
operating under the interim corrective actions for
stability, which basically has two facets. One is we
avoid intentionally entering the regions of
instability, which are shown in the upper left-hand
corner of the graph up there.
The key operational aspect of that is
there has to be adequate room between the cavitation
pump line and the instability region to allow the
operators to maneuver the plant to get through there
to get up to full power. On the graph you'll see the
line on there. That is the last Quad Cities unit to
start up. And as you can see, there is adequate
margin in between the minimum pump speed cavitation
line and the instability region. And that doesn't
change for EPU.
MEMBER WALLIS: Which of the 10,000 lines
on this is --
MR. HANLEY: Okay. These are the regions
of instability. These two regions here are regions
where if you enter them, you monitor for instabilities
and take immediate actions to exit those regions.
This up here is the immediate SCRAM region. If the --
you get into this region, the operators immediately
SCRAM the reactor.
The line I was talking about, the redline
here, that is the last Quad Cities unit to start up.
The region that for -- operationally, you have to have
adequate room in here for the operators to maneuver
the plant, so you can get through this region without
getting into the instability region. You have to be
able to increase recirc pump speed to increase power
without going into the instability region.
The margin between the pump cavitation
interlock line, which is what says you can raise
recirc pump speed, and the bottom of the instability
region doesn't change for EPU. In fact, it stays
exactly the same. We have maintained the absolute
power levels and flow levels that you'd find in the
bottom of the potential instability region when we go
to EPU.
The only real changes here is because we
are implementing MELLLA as part of EPU to allow us to
get up to our new rate of thermal power, we've
extended both the immediate SCRAM region and the
region here where we can monitor for instabilities and
take action to exit the region to account for that
area where we will not be able to operate by going to
MELLLA.
The other aspect which we've covered of
stabilities a little bit already is that what the
operators do if they get into the instability region.
In these two regions, they would monitor for
instabilities by watching their nuclear
instrumentation, look for increased amplitude in the
oscillations. If they see that, they'll SCRAM the
reactor.
Otherwise, we insert rods to reduce the
flow control line down to a point where we're outside
the instability region. It's all covered in operator
training. It's aided by computer alarms that warn the
operators of they're in the regions. So, really, for
EPU, the only changes for both stations is that we'll
be extending these lines or these regions to account
for the MELLLA regions.
MEMBER ROSEN: What do you do in simulator
training to address those kinds of -- getting into
those regions?
MR. HANLEY: Yes. The most likely cause
of getting into these regions is a loss of a recirc
pump. You know, if you're operating it along this
high flow control line, and you lose a recirc pump,
you're going to run back along that constant flow line
-- or constant power line.
The operators have to know which is part
of their turnover and what flow control line they're
operating at. If they get a trip of a recirc pump,
the computer will alarm, say you're in the instability
region. If you're above what was our current 100
percent flow control line and flow gets below this
level, they'll immediately SCRAM the reactor.
Otherwise, they insert control rods to get out.
We do have certain scenarios that they
have to detect the instabilities. We actually give
the nuclear instrumentations giving the oscillations,
so they have to detect that and SCRAM the reactor
instead of just inserting rods to get out of there.
That's considered a critical step in those test
scenarios that they actually can -- do see that and
take the appropriate action.
MEMBER WALLIS: Is this picture for
Dresden or Quad Cities?
MR. HANLEY: Well, that's what's a little
bit confusing. The power flow map is Dresden's, the
startup is Quad's, which is why that line is not right
on top of this minimum pump speed line.
MEMBER WALLIS: So how about natural
circulation, which one is that?
MR. HANLEY: It's also the Dresden line.
MEMBER WALLIS: And could you sketch where
the Quad's natural circulation line is?
MR. HANLEY: The Quad natural circulation
line is a little bit different shape.
MEMBER WALLIS: It's quite a lot
different, isn't it?
MR. HANLEY: But I believe it starts
slightly higher.
MEMBER WALLIS: And it bows out --
MR. HANLEY: And bows out further. That's
correct. That --
MEMBER WALLIS: This is just because it's
based on plant data instead of theory, is that --
MR. HANLEY: Yes. At Quad Cities in I
believe either the mid-to-late '70s they had a trip of
both recirc pumps. At that time, we weren't required
to SCRAM the reactor on a loss of forced recirc flow.
We were allowed to shut down. What they did is they
plotted the points for the natural circ line as they
shut down.
Dresden is still using the generic GE
natural circ lines for their plants, because they've
never had an opportunity --
MEMBER WALLIS: Which appears to be not
that accurate a prediction, right?
MR. HANLEY: Well, I think it's fairly
generic, and it wasn't aimed at predicting the exact
plant. The important point is neither plant is
allowed to operate with natural circulation any more,
so the exact shape of that line doesn't mean a lot to
the operation of the line. They're not allowed to
operate in that region anyway.
MEMBER WALLIS: It is a kind of cutoff,
though, so it -- it's useful for the operators to know
where it is.
MR. HANLEY: For the natural circ, like I
said, we don't even go below the minimum pump speed
line. That's what's really important for the
operators to know. The recirc pump is operating along
the minimum pump speed line, and that's really more
useful for the operators than what the natural
circulation line is.
So, really, for overall stability for
neither -- the plants don't change, the way we're
addressing them. Both plants have installed OPRMs for
the long-term solution for this. However, there is a
Part 21 notification out on that, and we are not going
to have that put into the RPS trip system until that
Part 21 notification is resolved. That was true EPU
or non-EPU. So until that Part 21 notification on the
OPRM gets resolved, we will be operating both units
under the ICAs.
With that, I'd like to turn it over to
Jason Post of General Electric to discuss the ATWS
analysis.
MR. POST: Yes. I'm Jason Post. I'm the
Manager of Safety Evaluations and Engineering Quality
at GE Nuclear Energy. On the ATWS analysis for the
EPU we do a full scope ATWS analysis to ensure that
the ATWS mitigation systems are acceptable, meet the
requirements, and also to show that the change from an
EPU is not that large. The change is acceptable.
We maintain integrity in three areas. One
is the reactor, second is the primary containment, and
third is the fuel. Reactor integrity is demonstrated
by the peak vessel pressure. We use the ASME service
level C limit of 1500 psig. The pre-EPU result there
is shown as 1402 psig. The EPU result did increase
the pressure. The peak result for GE 14 was 1492, and
with the transition core it was 1499.
So it is -- there are conservative factors
in the analysis, and we do meet the peak vessel
service level C.
MEMBER WALLIS: This is right up to the
limit, though. 1499 is essentially at the limit of
1500.
MR. POST: It is right at the limit.
That's correct.
MEMBER WALLIS: And earlier Mr. Nosko said
that you were -- said there's balance of plant limit,
there's some turbine limit in power I think. It looks
as if this is also a limiting condition, since you are
coming up to the limit of peak vessel pressure.
MR. POST: That's correct.
MEMBER WALLIS: So you are limited by
safety considerations.
MR. POST: That's true.
MR. HAEGER: Well, I should add -- this is
Al Haeger. I should add we chose the -- initially
chose the license power level based on the generator
limit, and then this is a result of --
MEMBER WALLIS: This also turned out to be
a limit, and it might have -- might have turned out to
be a little closer, and then you'd have to go back and
say it's not the generator that limits, but it's ATWS
that limits.
MR. POST: There are things that can be
done I think to mitigate this response if it was
necessary -- instrumentation setpoints, recirculation
pump trip setpoints. Those sorts of things could be
done to improve this response if it was necessary.
For the primary containment, there is two
factors we look at -- the peak suppression pool
temperature and the peak containment pressure. Peak
suppression pool temperature -- we use 202 degrees,
which happens to be the peak result from the loss of
coolant accident calculation on the containment
response.
We could probably justify a higher
temperature as a limit, but it simplifies it just to
say what they justify for LOCA is the same temperature
we're going to use here. The pre-EPU result was 190
degrees Fahrenheit, so it did increase by 11 degrees
for the EPU up to 201.
Peak containment pressure, 62, we're
nowhere near that limit. This is not a LOCA event, so
there's no blowdown to the dry well. It's just
steaming to the suppression pool. It's a thermal
hydraulic calculation, a thermodynamic calculation to
calculate the pressure. It's well below the limit.
Peak fuel temperature -- we use the
10 CFR 50.46 limits, 2200 degrees, and 17 percent
local oxidation limit. The result -- this is a case
where the peak temperature result is due to boiling
transition, so there's no uncovering of the core. The
core is never really threatened.
But we do a very conservative calculation
of the boiling transition, and that results in a
temperature here of a little bit less than 1500
degrees. With that, there is -- the metal/water
reaction is negligible.
MEMBER LEITCH: Do these plants have two
manually operated slick pumps? Is that the --
MR. HAEGER: That's correct.
MEMBER LEITCH: And there is no provision
here for automatic slick injection on a --
MR. HAEGER: That's correct.
MEMBER LEITCH: There is none.
MR. HAEGER: There is no automatic slick
injection.
VICE CHAIRMAN BONACA: So could you
comment on -- I mean, there are embedded operator
actions and time for interaction in these
calculations, right, these results?
MR. POST: That's correct.
VICE CHAIRMAN BONACA: Could you comment
on those? I mean, I would like to know --
MR. POST: Yes. We use a two-minute
operator action time for the SLCS injection after the
ATWS signal has occurred or the suppression pool
temperature has reached the peak -- the Boron initiate
-- Boron injection initiation temperature, whichever
is later.
So it's some time, two and a half minutes,
something like that, into the event that we're
assuming the operator has initiated Boron. Then there
is some time delay before it actually reaches the
core.
VICE CHAIRMAN BONACA: And what's the
difference between the previous power level and now,
insofar as the time?
MR. POST: It's almost insignificant. The
initial peak pressure transient is really governed by
the MSIV closure, and there's really very little
difference in the time. We use exactly the same time
for both analyses. So we've not shortened the
operator action time to mitigate the higher power
level. We use the same operator action time.
MR. HAEGER: Now, you're going to see
later that for the probabilistic risk assessment one
of the success -- you know, success criteria are also
based on operator action time, and that didn't change
also for the short -- for what we call the early
standby liquid control initiation success criteria for
power uprate. It didn't change there either.
It did change for the other -- what we
call the late success criteria. It changed slightly
in the PRA space. But for the deterministic analysis,
the time didn't change at all.
VICE CHAIRMAN BONACA: So you had the same
assumption of the timing for operator action.
MR. HAEGER: That's right.
MEMBER LEITCH: So some plants have a
system that if power is still up six seconds after
SCRAM they automatically inject slick. And what
you're saying is had you such a system, it wouldn't
appreciably reduce that peak vessel pressure?
MR. POST: No, that's correct. It would
not. The Boron system has very little impact on the
peak suppression pool -- peak reactor pressure because
that occurs before the Boron has any impact on the
event.
MEMBER LEITCH: The main issue is the
speed with which the MSIVs close. Is that --
MR. POST: It's the recirculation pump
runback and how fast that pump runback gets the power
down is the main driver to reduce that peak pressure,
and the SRB capacity. A lot of -- some plants have
more SRB capacity than the Dresden and Quad Cities
units, and they're going to have a better response, a
lower pressure in the response.
MEMBER LEITCH: Okay.
MR. POST: So moving to ATWS instability,
this is something that's generically dispositioned.
There was not a specific analysis for Dresden and Quad
Cities. The event is of -- like a two recirculation
pump trip from a limiting EPU condition on a MELLLA
boundary. You run back to natural circulation, manual
SCRAM fails, and an instability develops and grows,
and the operator is completely unable to insert any
control rods.
There were two reports that were written
several years ago that have been accepted by the NRC.
The first one is NEDO 32047, and that one shows the
response to this event with no mitigation at all. And
it shows that the highest power bundles do go in and
out of boiling transition due to the reactor
oscillations, and eventually they -- a few of the
highest power rods experience an extended dryout, and
with that they heat up enough to cause core damage.
And as reported in that report, they are
-- about half a percent of the core by volume will
experience this extended dryout and boiling and some
fuel damage.
The companion report was 32614, and that
shows the ATWS response with mitigation, and it
determined two key factors to prevent fuel damage.
One was to lower reactor water level. When you lower
water level you are now putting your feedwater into
the airspace in the downcomer, which raises the
feedwater temperature dramatically and you get a big
increase in the temperature as it -- at the bottom of
the core, which mitigates the instability.
It doesn't make it go away, but these very
high power oscillations that can cause the extended
dryout no longer occur.
The second is the Boron injection. Again,
that does not prevent the instability either, but it
does -- it does, over a matter of 10 or 15 minutes or
so, make the instability go away completely.
We get -- when we presented this to the
Duane Arnold subcommittee review, there was a concern
that we hadn't done limiting EPU conditions. And
since that time we've gone back and have done a
sensitivity study for more limiting EPU conditions,
even more limiting than either -- any of the EPU
plants that have been presented to this Committee --
and found that the results are essentially unchanged.
We did it for a GE 14, and it has the same
or longer time before it experiences the extended
dryout, and the mitigation actions are still just as
effective.
MEMBER POWERS: When you did the power
oscillations, what kinds of energy deposition do you
have in the fuel?
MR. POST: There are around 70 to 80
calories per gram is the energy deposition rate.
MEMBER POWERS: And how do you know the
fuel survives that?
MR. POST: Well, it's well within the
limits of what the design -- what the fuel is designed
for. I think it's -- the licensing limit is like 170
calories per gram, and we think it will take well more
than that.
MEMBER POWERS: I wonder why. I mean, we
have a history of experiments now showing that as we
burn fuel up it takes less and less, and the original
idea that this fuel would stand up to 180 calories per
gram has pretty much evaporated as you go to burnups
about 20 gigawatt days per ton.
Now you're telling me we're putting in 70
or 80, and I seem to be -- to recall experiments where
those kinds of powers caused fuel damage in
experiments, admittedly not this fuel but other types
of fuel.
MR. POST: Yes. I'm going to have to say
I'm really not the expert in that area. Dr. Yans
Anderson was here previously and answered a very
similar question, and, unfortunately, he couldn't be
here today. But I would want to get back to you with
an answer from someone like Dr. Anderson from Global
Nuclear Fuel.
MEMBER POWERS: Okay.
MEMBER LEITCH: My question -- I'm sorry.
Were you finished? Okay. My question related to the
likelihood of an ATWS. Do these plants all have an
alternate injection?
MR. POST: Yes, they do. Yes, we don't
take credit for that in any of our analysis, but they
have it.
MEMBER LEITCH: Thank you.
MEMBER ROSEN: Do you actually simulate
ATWS and simulate operator responses to these
instabilities during ATWS?
MR. POST: In the analysis or --
MEMBER ROSEN: No, in the simulator.
MR. POST: -- in the simulator?
MEMBER ROSEN: And in the training.
MR. HAEGER: I'd like to get Tim Hanley to
answer that question.
MR. HANLEY: This is Tim Hanley again. We
do actually do training on this. The generic EPGs,
which our site EOPs are based on, does have them
looking for instabilities, injecting standby liquid if
they hit the Boron injection temperature, or actually
before they hit the Boron injection temperature on the
TORUS, or if they see instabilities when they're in an
ATWS.
MEMBER ROSEN: Well, I was more interested
in the water level reduction.
MR. HANLEY: And, actually, that's the
first step. When you go down the level leg in the
EOPs, if you're not below the feedwater spargers,
it'll tell you to immediately terminate and prevent
injection, except for Boron, CRD, and RCIC, to lower
level less than the feedwater spargers to prevent its
instability.
MEMBER ROSEN: It seems a little
counterintuitive for operators to --
MR. POST: Well --
MEMBER ROSEN: -- injection to the core
into a unit --
MR. POST: -- when it was first
introduced, it was certainly counterintuitive. But
it's been the procedure in place for well over 10
years now, since it was first introduced by the
Emergency Procedure Committee. And I think the
industry well understands the need for it and how
effective it is.
MR. HANLEY: This is Tim Hanley again. If
the -- you know, if the rods don't go in, all the
operators -- you know, the only way to effectively
lower power is, in fact, to lower the moderation by
lowering the water level. So although it's
counterintuitive to our normal response to most other
accidents, this is a particular one that we do do
extensive training on.
MR. POST: Next we're going to move into
the containment analysis with Mark Kluge.
MR. KLUGE: I'm Mark Kluge. I'm with the
Project Engineering Team for the Dresden and Quad
uprates, and I'm going to discuss the containment
analysis.
First, we'll look at the results for the
design basis loss of coolant accident. The peak
drywell pressure we reached for EPU conditions is
43.9 psi, which is well within the acceptance limit of
62. And when we performed the analysis with the same
assumptions for the pre-EPU case, we found that we
changed the peak pressure by only about a pound.
Peak drywell air temperature, as you can
see, goes up for EPU only approximately two degrees,
and, again, is well within the acceptance limit of
340.
MEMBER WALLIS: This is for design basis
LOCA. Which is the worst LOCA? This is the worst you
are looking at here or the --
MR. KLUGE: Loss of coolant accident is
the worst case for peak drywell pressure. A small --
a steamline break actually gives you higher airspace
temperatures. But, again, the results are well within
the limit.
MEMBER ROSEN: How high?
MR. KLUGE: I believe it's 337.9 degrees
for that case. That's the bottom case for that
particular parameter.
MEMBER WALLIS: So that gets us much
closer to the limit, then.
MR. KLUGE: Yes.
MEMBER ROSEN: Now, did you also mean to
imply that for that case, for the high temperature
case, the small break, that the pre-EPU and post-EPU
and EPU numbers are very close?
MR. KLUGE: They are, again, very close.
The matter is just a few degrees.
MEMBER WALLIS: But you are also just a
few degrees from the limit, so --
MR. KLUGE: Correct. But that's a typical
result for these types of plants.
On the next slide we have the results for
the suppression pool. Again, doing the analysis with
the same methodology for the pre-EPU and post-EPU
case, when we use bounding assumptions that envelope
both plants, the post-EPU result for a suppression
pool temperature is 202 degrees with a nine-degree
rise. And this is the number we used in our piping
and structural analysis.
For NPSH, which I'll discuss in a moment,
we did plant-specific peak temperatures. And as you
can see, there are some minor differences there. The
peak wetwell pressure goes up only nominally for the
EPU case, and, again, is well within the limit.
MEMBER POWERS: When you do the blowdown
into the suppression pool, do you look at chugging?
MR. KLUGE: Yes.
MEMBER POWERS: And what did you find?
MR. KLUGE: Yes, we looked at all of the
MARK-1 hydrodynamic loads, and we reran all of the
limiting cases and found that the existing load
definitions are still bounding for EPU.
We'll move on to NPSH. Both Dresden and
Quad Cities require credit and containment
overpressure for limiting case NPSH. That is a short-
term case where all the pumps are running, and a long-
term case where fewer pumps are running, but they are
sufficient to maintain both core and containment
cooling.
These next two drafts show that in all
cases the available overpressure for an analysis that
uses conservative assumptions to limit the pressure
exceeds the required credit to maintain adequate NPSH.
And, again, there are minor differences due to plant
differences.
And if there are no questions in that
area, I'll turn it back to Jason to discuss the LOCA
analysis.
MR. POST: A full scope LOCA analysis was
performed using the standard approved methodology.
That analysis starts off with a nominal PCT
calculation. It's a nominal assumption to -- it does
the full break spectrum and all of the various
failures, determines the worst event, worst break.
And then, with that, the first thing you do is you
include uncertainties and you calculate the -- what's
called the upper bound PCT, and that is the one that's
shown there just right at the upper bound
1600 degree F limit.
That limit is based upon the limits of the
data when that methodology was qualified. There is
actually a submittal before the NRC now to raise that
limit to 1800 degrees or possibly remove that limit
completely.
Then, in addition, you also take the
nominal PCT and you change assumptions for the
Appendix K methodology -- these are things like the
break flow, the metal/water reaction coefficient, the
K-heat conservative adder of 20 percent.
And you redo the calculation for the
limiting break and that comes up with the Appendix K
result, and then you finally add some additional
uncertainties and you come up with the licensing basis
PCT, and you must show that the licensing basis PCT is
below the 10 CFR 50.46 limit of 2200 degrees
Fahrenheit.
MEMBER WALLIS: What was the 1600 degree
value before the extended power uprate? What did it
come to?
MR. POST: I cover that on the next slide.
MEMBER WALLIS: Oh, you do.
MR. POST: The pre-EPU upper bound PCT was
estimated to be 1500 degrees, but that was not for a
GE 14 core. And GE 14 is worse than the existing
legacy fuel. The legacy fuel -- I'm sorry, for GE 14,
the difference of the EPU is only about 10 degrees, so
there's a very small difference for -- for EPU. So
that the primary difference is due to the different
fuel type.
And analysis results for the licensing
basis PCT, it was 2110, which is less than the
acceptance criteria. The upper bound PCT was 1599.6,
which rounds up to 1600 degrees, so it does meet --
MEMBER WALLIS: Pretty good --
MR. POST: Yes. And the maximum local
oxidation was six percent, and the core-wide was
.1 percent, so those are well less than the limits.
Next slide.
There was a question from the subcommittee
regarding the impact of steam updraft and the fact
that you have a flatter radial power distribution and
how that impacts this.
A couple of points here. The DBA LOCA
analysis for the current power and for EPU results
have a high steam updraft in the central core region
which prevents the core spray flow from reaching the
hot channels. That's part of the analysis. That's
the way it's done.
So we do take credit for cooling from the
steam updraft, but we do not take credit for any
direct spray cooling to the hot channels in the
calculation of the LOCA PCT.
Now, the flatter core power profile may
result in a higher power in the peripheral bundles,
and so you're going to have more steaming, more steam
updraft in those bundles, which can hold up more water
in the upper plenum. So you're going to reduce the
cooling flow to those, although the increased updraft
does help the cooling of those bundles as well.
But it's self-limiting because you're
going to reach the volume of -- or the mass of water
that's being held up sooner, which will cause
breakdown and cause the water to get back down into
the core. So it's a self-limiting effect. It really
has essentially no impact on the calculation.
MEMBER KRESS: Does this increase the
carryover of liquid out the break?
MR. POST: I don't believe so. I'm quite
sure it doesn't.
MEMBER WALLIS: Well, if there's a higher
steam velocity, you probably will.
MEMBER KRESS: You'll have more steam
flowing in a different location and at higher
velocity.
MR. POST: Of course, the pressure
response is driven by the fact that you have a higher
power in the -- you know, in the reactor. It takes a
little bit -- the blowdown is a little bit longer.
I'm really not certain that the steam updraft has a
significant impact on that blowdown phenomena. I
don't think it does.
MEMBER WALLIS: When you get this kind of
flow, do you actually make a pool instead of a spray
impacting directly on the -- whatever it is, the --
MR. POST: That's correct. There's a pool
of water that's held up in the upper plenum.
MEMBER WALLIS: Once you've made a pool,
it doesn't really matter --
MR. POST: Right.
MEMBER WALLIS: -- what the distribution
of the spray is.
MR. POST: That's right.
MEMBER WALLIS: As long as it's not being
blow out the break.
MR. POST: Right.
MEMBER KRESS: Does your computer count --
account for the water that gets blown out the break?
MR. POST: Certainly. It accounts for the
water that goes out the stand pipes and spills over
into the downcomer. Once it gets into the downcomer,
it would flow out the break and would not -- it would
be below the jet pumps and would -- it would go out of
the break. Certainly, it accounts for that. So if
that effect is there, it would certainly model it.
MEMBER KRESS: And how do you -- what do
you input for that in the code? Does it actually
calculate it mechanistically, or does it input a
fraction of the core spray that goes out?
MR. POST: Frankly, I'm not quite certain
of exactly how the model works in that regard, what
the coefficients are and how it's calculated. I can't
answer that.
There was also, then, the long-term spray
cooling. Of course, in the long term you're going to
get the void collapse in the core. Water level is
going to steady out at the two-thirds core height at
the top of the jet pumps. And with the flatter power
distribution, that does not impact the spray
distribution. It's within the range of the 30-degree
sector tests that were performed previously on core
spray distribution, so it does not impact that long-
term core cooling.
So, next, Ed Connell is going to cover the
materials issues.
MR. CONNELL: Good morning. I'm Ed
Connell. I'm the Project Engineer for the EPU project
at Dresden and Quad Cities.
The first topic I'm going to talk about is
flow accelerated corrosion. For the EPU conditions,
we looked at the susceptible piping systems,
determined those where the flow or the temperature had
increased, and for those we went through and
calculated a -- the wear rate, an increased wear rate.
The wear rate increases were modest. The
largest was 33 percent, went from 1 mil to 1.3 mil.
More typical of a large increase was in the feedwater
lines where we went from 19 mils per year to 21 mils
per year.
Since the existing wear rates are modest,
these increases are routinely accommodated. And the
way we accommodate them is we adjusted, as
appropriate, the inspection intervals for the program,
so the program has been modified to account for these.
MEMBER ROSEN: Could you hold on for a
minute? On that slide, you talked about this 33
percent increase, where was that?
MR. CONNELL: That's on the reactor water
cleanup line.
MEMBER ROSEN: At what point?
MR. CONNELL: I'm not sure I remember the
exact point.
MEMBER WALLIS: This wear rate increase,
1 mil per year to 1.3 mil per year, that's based on
some mechanistic analysis. It's a Reynolds number to
the .8 or something like that? What is it based on?
MR. HAEGER: That's really right out of
the checkworks program that we discussed last time.
MEMBER WALLIS: Which is too complicated
to describe here.
MR. HAEGER: Well, at least none of us
sitting at the table can describe it very completely.
What we showed last time, though, was that the
parameters we're using are within the bounds of
checkworks that other plants have typically used.
MEMBER LEITCH: Did I understand you to
say that the critical point here was reactor water
cleanup?
MR. CONNELL: It's not a critical point.
It's a point that exhibited the largest percentage
increase.
MEMBER LEITCH: My question really was:
why does the reactor water cleanup flow change?
MR. CONNELL: It's -- you get slightly
more subcooling. You get a little more flow down that
as you come off the vessel. So you've got a slight
temperature increase.
MEMBER FORD: I think your point is that
this is Schedule 80 pipe, about .3 wall thickness, .3
of an inch, about .375 wall thickness, and your
inspection period is -- hat you'll take that increment
well into account, is that correct?
MR. CONNELL: That's correct.
MR. HAEGER: Yes. Just to clarify why we
showed that number, we wanted to show you the largest
percentage increase and then the largest absolute
increase, just so you get some feel of where these
increases were.
MEMBER WALLIS: It would be good to put it
in perspective of how much you need to wear away the
-- to have a problem.
MEMBER ROSEN: This is gun barrel piping,
Schedule 80.
MR. HAEGER: Is that right?
MR. CONNELL: I believe that's correct.
We can look.
MEMBER WALLIS: 375 wall.
MEMBER POWERS: How often do you have to
change your feedwater line?
MR. CONNELL: How often do we have to
change it because of this? It won't change it at all.
MEMBER POWERS: A hundred years maybe?
MR. CONNELL: Perhaps that. But we won't
change it within the licensing on it.
MEMBER POWERS: Nothing for the wall?
MR. CONNELL: Yes. I'm trying to
remember. There's something -- they're over an inch,
but I -- I don't remember.
MEMBER FORD: The feedwater lines are
pretty big things, so Schedule 80 is -- it's a vague
statement. It's a thick pipe.
MEMBER WALLIS: It would be nice just to
have some numbers that make it clear.
MEMBER SHACK: This is, what, a 24-inch
pipe, Schedule 80? About an inch and a quarter, inch
and a half, yes.
MR. CONNELL: Yes, that's approximately
correct.
MEMBER SHACK: It's at least an inch.
MR. CONNELL: Yes, it's over an inch.
MEMBER SHACK: It's over an inch.
MEMBER POWERS: Well, it's a good thing,
because in four years you're going to remove a lot of
it.
The next slide is on the reactor vessel
fluence. As part of EPU, the fluence to the end of
life has been recalculated. It's been recalculated
using the revised General Electric methodology. At
the time we did that work, the methodology had not
been approved by the NRC staff.
It's now been provisionally approved.
What we looked at in the interim was the PT curves for
the -- the existing PT curves, and they are
sufficiently conservative. There's enough life left
that we will have time until past the end of the next
cycle to go back and incorporate the methodology in
the General Electric new topical report that's just
been approved.
MEMBER POWERS: So you don't discuss
fatigue?
MR. CONNELL: No, we -- we hadn't planned
on it. The existing curves will go right over it.
It'll carry us --
MEMBER POWERS: There's no --
MR. CONNELL: -- through that.
MEMBER POWERS: -- on your vibrations
and --
MR. HAEGER: Oh. We discussed that in
some depth at the subcommittee. We were not asked to
specifically present it here. There is one open
question that we're going to be responding to, but
other than that we didn't plan to address it
specifically here.
MEMBER POWERS: I'll chat with my brethren
on the subcommittee.
MR. HAEGER: Okay.
MEMBER POWERS: They can answer my
question.
MR. CONNELL: Next, Jason and I are going
to address four open questions from the subcommittee.
The first two have to do with the electrical
distribution system, and they are for postulated off-
normal conditions.
The first concerns the -- what we call the
bus 21/22, which are off the Y windings, off the unit
auxiliary transformer, and the reserve auxiliary
transformer. And they feed the recirc pumps and the
feedwater pumps.
The postulation is that there is a bolted
fault at the same time that you transfer all the loads
from one of the transformers to the other. This is
different after EPU basically because you're running
the additional feed pump. So the contribution to the
fault current will be increased momentarily because of
the additional running feed pump.
So when you look at that, the fault
current is higher after EPU. So what we have done to
mitigate that is that we have reinforced the bus to
take that higher momentary current, and we've done
that through the aid of testing to prove out that the
modifications will, indeed, take that higher fault
current.
We have also adjusted the relay that
initiates the breaker trip, has two settings on them.
One we call instantaneous, which picks up in about a
hundredth of a second. We've eliminated that, and now
we pick up on the setting that's set at six cycles.
It'll pick up at six cycles or a tenth of a second.
And during that time period, the fault
current will decay from the extra pump, and you'll be
back within the rating of the breaker. We've also
looked at all of the other components, I think in
response to a question. That question was: in the
transformer, is that designed to take this? And it
is. And we've also looked at the connecting buses,
and that's within their rating also.
The second question related to electrical
had to do with the -- on this postulation, the plants
are running, you've got the low split between the UAT
and the RAT, and you have a fast bus transfer from one
to the other. The question was related to the higher
current. The current will exceed the continuous duty
rating of the transformer. However, the current is
within the short -- the short overload period of
design of the transformer.
And, of course, we've also looked at the
other components in the system, such as the bushing
and the cabling and the bus, and that's all within its
short duty rating.
During that time, the operators are
trained and they have a procedure where they'll cut
back the load to be within the continuous duty rating.
And we've allowed them an hour to do that, because the
transformer short duty rating for the overcurrent is
in excess of two hours.
The last question that I'm going to
address had to do with the steam dryer. At the
subcommittee, there were extensive discussions about
the dryer, and there was one question that was asked
that hadn't been answered, which had to do with the
lugs on the dryer.
And the question was: are these
inspected? And the answer is: they're inspected at
10-year intervals. They were inspected during the EPU
outages. We just did that last week at Dresden, and
there were no indications in any of the lugs.
MEMBER FORD: I guess the question -- you
enunciated a question correctly, but the deeper issue
was that in the earlier Duane Arnold application, the
statement was made that because of the increase of
vibration stresses on the steam dryer, there would be
a transference of stress to the lugs.
My question was: well, how will that
impact on the cracking of that welded component, the
lug? And you've correctly said that there would be --
they are normally inspected every 10 years. Would the
increase of stress on that lug indicate that that is
-- 10 years is an insufficient inspection periodicity?
MR. CONNELL: I guess I wasn't prepared to
-- I didn't understand that question in that way.
MEMBER FORD: Well, I didn't give,
admittedly, it in that detail. It was really to
relate to the integrity of that lug, which has cracked
in the past. How is that impacted by the increase --
supposed increase in stress?
MEMBER SHACK: Do you mean, how close do
you come to a fatigue limit?
MEMBER FORD: Fatigue or a cracking limit,
a stress corrosion limit, or whatever.
MR. CONNELL: I understand your question
now, but I didn't understand that was the question.
Sorry.
MEMBER FORD: I apologize. I apologize.
MR. HAEGER: We can get some information
back to you on that.
MEMBER FORD: Yes. And if you remember,
the impact of this was really more of a loose parts
analysis. You're going to have the whole steam dryer
drop down onto the top guide. And I think it -- what
would happen? Or can't anyway.
MR. CONNELL: Jason?
MR. POST: Yes. There was a question on
the ORIGEN Code from the subcommittee, and if that's
used to do a space-time demand calculation. And
ORIGEN is used to calculate the core inventory for the
radiological release calculations, the dose
calculations. It's a prescripted methodology. It's
performed at end of cycle with a maximum discharge
exposure to maximize the inventories.
It is not used to do a space-time
variation calculation. We have compared ORIGEN to the
CINDER Code, which is a model that can do a space-time
variation calculation, and have shown that ORIGEN
results are either the same or higher for the
individual isotopes, and so it gives a conservative
radiological release calculation.
Now, there was also a question about the
radial power distribution.
MEMBER POWERS: I guess that raises the
question --
MR. POST: Sure.
MEMBER POWERS: -- I am hardly expert in
this, but I seem to have seen people compare ORIGEN
predictions to what they actually find in the fuel,
and my impression is they're pretty good. That would
suggest that maybe the CINDER Code is not so good.
MR. POST: Well, the results between
CINDER and ORIGEN were really quite close.
There was another question on the radial
power distribution. This is Dresden-2, cycle 17,
which is the current operating condition. This is a
core -- say a core to core. The numbers there are the
-- let me use this and stand up.
These are the radial peaking factors of
the individual fuel rods. Here are -- these little
cruciforms are where the control rods are inserted.
This -- again, it's a core to core. It's a core-to-
core symmetric design.
There are four bundles on here that have
the highest radial peaking factors of 1.4 or so. I
think there is -- where did they go here? There was
a couple of them --
MEMBER ROSEN: Is this the pre-EPU or
post-EPU case?
MR. POST: This is the pre-EPU. This is
cycle 17. This is the current operating condition.
MEMBER WALLIS: Can we win a prize for
finding them?
MR. POST: Yes. The first one to find
them gets a free donut.
(Laughter.)
I know there were four -- there were four
of them on here. They were about 1.4, I thought.
MEMBER WALLIS: They all seem to be 1.2
something.
MR. POST: Yes.
MEMBER WALLIS: So what's the question?
MR. POST: Then it -- I'll have to confirm
that. Then this is cycle -- Dresden-2, cycle 18.
MEMBER WALLIS: There are some 1.4s on
this one.
MR. POST: Yes. This one -- I counted.
There's -- here's a whole bunch of 1.4s. This is the
EPU condition, and there are approximately 23 -- I
think I counted -- fuel rods that have a radial
peaking factor of 1.4 or higher. So the peak is --
MEMBER WALLIS: So it has increased.
MR. POST: Yes. So the peak is still the
same. There's nothing above a 1.44 or 1.45 or so.
That's the highest. But there -- it went from four in
a core to core to 23 in a core to core.
MEMBER WALLIS: So except we couldn't see
the 1.45 and --
MR. POST: Yes. I'm not sure that that
was the correct transparency. I'll have to confirm.
Because I counted them off the hard copy, and I
counted four, so --
MEMBER WALLIS: So the message is that the
maximum radial peaking factor has not changed.
MR. POST: Correct.
MEMBER ROSEN: But that pre-EPU you had
some small number of bundles at 1.4, or nearly, and
post-EPU or EPU you end up with something like 24
bundles.
MR. POST: In a core to core, correct.
MEMBER ROSEN: In a core to core. But
overall the power is generated for the EPU from a
general flattening of the power shift.
MR. POST: Right. And the radial peaking
factor of more rods at 1.4 is evidence of that, that
it's a flatter power distribution. Exactly.
MEMBER ROSEN: But it isn't very core
wide. It doesn't take -- doesn't seem to take -- that
was the reason for my question. It doesn't seem to
take much of the core to get there.
MR. POST: It's a matter of perception.
Certainly, that -- yes. It's -- there is still a low
of low power bundles in here. I mean, out in the
periphery we've got 1.3s, 1.2s, that's correct. There
are a lot of low power bundles still in the core.
MEMBER WALLIS: Well, for the benefit of
the public, could you explain the significance of this
term "radial peaking factor"?
MR. POST: The radial peaking factor for
the whole core average should be 1.0. So it's a
measure of the individual bundle power ratio to the
core average bundle power.
MEMBER WALLIS: Core. It's not bundle
average.
MR. POST: Core average.
MEMBER WALLIS: So you can have numbers
that are less than one.
MR. POST: That's correct.
MEMBER WALLIS: But it doesn't say how
high it is, then. It's a ratio to the core average.
MR. POST: That's correct. And --
MEMBER WALLIS: Would it be a correct
statement that the power per bundle has not changed in
the maximum bundle by -- as a result of the EPU?
MR. POST: That's exactly correct. We --
MEMBER WALLIS: It's not just the ratio to
the average, but the absolute power per bundle.
MR. POST: Right. The highest --
MEMBER WALLIS: The highest amount of
power per bundle is still the same.
MR. POST: The highest power bundles were
on limits, and we were not able to raise the power.
MEMBER WALLIS: That's the whole principle
of achieving EPU this way, by spreading --
MR. POST: That's correct.
MEMBER ROSEN: Maybe a comment for the
process is that we're talking -- on the assumption
that we're going to see additional requests for other
BWRs on this for EPU, it would be helpful if this
presentation was made with some sort of help for the
reader, maybe some kind of color coding. It's very
hard to compare.
MR. POST: Yes. We just got this
question --
MEMBER ROSEN: Yes, I know.
MR. POST: -- last night. And so this is
the best we could come up with in the moment. We'll
certainly take that into consideration for future
presentations.
MEMBER WALLIS: Are we moving on to PRA?
Is that the next -- oh, no, the large transient tests
you're going to talk about.
MR. HAEGER: Two open items, actually.
MR. KLUGE: This is Mark Kluge from Exelon
again. I'm going to discuss the first of the two open
items in the safety evaluation report.
Al, can you put our slide back up, please?
This open item involves the ultimate heat
sink at Dresden station. Dresden's ultimate heat sink
consists of the intake and discharge canals, which
trap water in the event of a failure of a downstream
dam on the river. And I'll ask Al to put up a
photograph here.
The Unit 2 and 3 intake canal runs from
the river to the plant, and the discharge canal runs
back out to the river here. The intake is
approximately 2,000 feet long. So we're talking about
a substantial amount of water.
Al, if you could switch back.
This inventory is used for safe shutdown
in two ways. It supplies makeup to the isolation
condenser for decay heat removal, and it also supplies
cooling water for the diesel generators. The ultimate
heat sink is replenished by means of portable pumps to
support safe shutdown in the long term, and all of the
required actions for operating in this matter are in
the current plant procedures. The PU --
MEMBER WALLIS: Where do you pump from?
MR. KLUGE: I'm sorry?
MEMBER WALLIS: Where do you pump from
with the --
MR. KLUGE: We pump from the intake, as we
do during normal plant operation. The difference, of
course, is that we're now separated from the river as
an unlimited supply.
MEMBER WALLIS: The canal is replenished
by pumps pumping from the river?
MR. KLUGE: Pumping from the lowered river
bed.
MEMBER WALLIS: After the dam has failed?
MR. KLUGE: After the dam has failed, the
river bed lowers below the canal intake level, but, of
course, doesn't go completely away because the river
has a series of dams.
MEMBER WALLIS: So the aftermath of the
dam failure has all gone away and the river is now in
a suitable state for pumping from?
MR. KLUGE: The river is presumed to still
have inventory, yes. And we're only pumping the water
over the rise at the intake.
MEMBER WALLIS: And not to be full of all
kinds of junk and stuff, is that -- pumpable from?
MR. KLUGE: Pumpable from.
MEMBER WALLIS: Okay.
MR. KLUGE: Yes.
MEMBER WALLIS: That doesn't always
happen, right?
MR. KLUGE: That doesn't always happen,
but that is the current licensing basis.
MEMBER WALLIS: So this is approved by the
NRC?
MR. KLUGE: The EPU impact on the ultimate
heat sink we evaluated by doing a very bounding
analysis of the water that would be available in the
intake canal and found that EPU changes the time
available to make up from the lowered river bed from
about five and a half days to four days.
As a result of our IPEEE and seismic
margins analysis, we committed to certain
modifications which are related to a seismic event.
Specifically, we do not currently have a seismically
qualified makeup path to the isolation condenser.
And because those modifications are not
intended to be installed until one cycle after EPU
operation, the staff requested that we do some focused
risk evaluations of such a scenario in which the
seismic event would fail the dam, and the makeup paths
to the isolation condenser have limited seismic
capability.
The results of those evaluations showed
that the risk of core damage in that scenario was
acceptably low, and that the EPU impact on that risk
was negligible.
Now I'll turn it over to Tim Hanley to
discuss transient testing.
MEMBER ROSEN: Before you get away from
that, acceptably low, what kind of numbers were you
talking about?
MR. KLUGE: The risk of a seismic event
failing the dam, failing all of the isolation
condenser makeup, and thereby leading to core damage,
is on the order of 1E-5.
MEMBER KRESS: And where is it that says
that that's an acceptably low value?
MR. KLUGE: That falls within an
acceptable region in Reg. Guide 1.174.
MEMBER KRESS: I don't recall 1.174 giving
acceptance criteria for individual sequences.
MR. KLUGE: Well, as I said, this was a
special case where the staff asked us to analyze one
specific sequence. We do not have a seismic PRA for
Dresden station.
MEMBER KRESS: Yes, but I don't think
1.174 gives any guidance on what to do about
individual sequences. So, you know, did the staff say
that it was an acceptably low value?
MR. HAEGER: Well, as we are discussing,
this is still an open item with the staff.
MEMBER KRESS: I see.
MR. HAEGER: But we felt that, given this
scenario, that that was an acceptable level, and
that's what we -- we submitted.
MEMBER KRESS: Okay.
MR. HANLEY: This is Tim Hanley again from
Exelon Nuclear.
The other open item with the staff is the
large transient tests. Our submittal was based on
ELTR-1 and ELTR-2. ELTR-1 calls for two large plant
transient tests. One is an MSIV closure, if you're
uprating greater than 10 percent from your current
license power, and the other one is the generator load
reject for uprates of greater than 15 percent above
your current license thermal power.
I want to say ELTR-1 is a generic uprate
guideline or topical report that covers power uprates
that include a steam dome pressure increase and those
that don't. It doesn't differentiate the testing
requirements between those two types of uprates, and
a big part of our basis for not doing those tests is
the fact that we are not increasing reactor steam dome
pressure.
In fact, GE has since submitted another
submittal to do constant power uprate EPUs that do not
require those tests. Overall, our basis for not
wanting to do these tests is they are, in fact,
initiating large transients on the plant from the full
power conditions. It's not warranted based on the way
we're doing our uprate.
Essentially, all we'll be changing is the
thermal power and the reactor and the steam line flow.
All of the other main parameters of interest, which
would be the SCRAM time, bypass valve response, relief
valve response, are all unchanged.
With the limited changes to the inputs,
the Oden Code that we've used to analyze the plant's
response has indicated that the response would be
within an acceptable level for the individual
components that would be challenged during these
tests.
So with -- having very little to gain out
of performing these tests, and, in fact, running tests
on operating reactors, we believe that it's better
from a safety perspective not to run these tests.
MEMBER POWERS: I can't understand the
plausibility of your argument for the MSIV closure.
Can you explain a little bit on this load -- generator
load rejection?
MR. HANLEY: Yes. In the generator load
reject from full power, as the stop valves get 10
percent closed from their full open position, you get
an anticipatory SCRAM. So the rods go in then. None
of that has changed. So it's actually -- although the
pressure transient has started to increase, the rods
are already going in at that point.
The other thing important about the
generator load reject, you still maintain bypass valve
capability. We haven't changed the bypass valve
response time, the bypass valve capacity, and once the
rods go in you're well within your bypass valve
capacity.
You do see -- we do see some increase in
the peak pressure that you see in the vessel, because
you do have a greater amount of steam flow that's
being interrupted and a greater amount of power to
begin with. But the transient actually terminates
very quickly.
And because we haven't changed those other
inputs, the stop valve closure point at which you get
the SCRAM, the SCRAM response time, bypass valve
response time, it doesn't seem prudent to go ahead and
run this test when there's very little to be gained
from it.
Again, this isn't --
MEMBER LEITCH: In some of the reading
here, it seemed to suggest that some of the
justification for not doing the test was based on some
testing done at KKL.
MR. HANLEY: KKL actually did an extended
power uprate, did testing. The real justification was
to show that the Oden Code that we're using adequately
predicts the plant's response at uprated conditions.
They compared the Oden results. They ran a KKL to the
actual plant response, and it was -- conservatively
predicted the response and did follow the trend of the
plant's response for all of the parameters of
interest. So --
MEMBER LEITCH: But KKL has a 100 percent
bypass system. The four plants we're discussing are
like 25 percent bypass?
MR. HANLEY: We're actually about 40 for
-- 40 percent of our current, so it goes down to
approximately 37 percent, something in that range.
However, in the MSIV closure, your bypass valve
capacity is irrelevant because you don't have bypass
valves anyway.
MEMBER LEITCH: Yes, you're talking about
the generator load reject system.
MR. HANLEY: For the generator load
reject, the real issue is you get -- you get quickly
below the bypass valve capacity, even at Dresden/Quad
Cities. It reduces the pressure, because the bypass
valve response time -- as the stop valves are going
closed, the bypass valves don't open quickly enough to
compensate for that.
So even at KKL they did see a pressure
spike with the generator load reject. And the actual
capacity of the bypass valve system doesn't -- is only
in play for a very, very short period of time, because
then you're down to decay heat that you're worried
about.
And, really, the basis for that was to
show Oden can predict both plant responses before and
after EPU, and that was part of our basis for not
doing it. Oden says that we'll stay within the
parameters that the components can operate under.
MEMBER POWERS: Professor Wallis has
trained me to understand that when somebody says that
a code conservatively predicts something that it
predicts it rather badly, but that it's high. Is that
the case here?
MR. HANLEY: Actually, I believe we have
some backup slides on this. It does predict a higher
value in most of these -- in all of these cases, but
it is --
MEMBER POWERS: These are proprietary
slides, so we're going to have to discuss these at --
some of the members have -- it looks like some of the
members have some materials, but at this point --
MR. HANLEY: We can get that afterwards.
And, again, this is an open issue with the staff.
If there is no more questions, I'll turn
it over to Bill Burchill.
MEMBER ROSEN: Well, I expected at this
point you would address the testing that you are
planning to do for what -- based on your modifications
of the reactor recirc runback.
MR. HANLEY: There is another section in
the back that covers startup testing in general.
MEMBER ROSEN: Oh, okay.
MR. HANLEY: This was an open issue, so
I'll address it when I come back to do that.
So I'm going to turn it over to Bill
Burchill.
MEMBER WALLIS: Can you do this in about
five minutes, Bill?
MR. BURCHILL: I will do that, sir.
MEMBER WALLIS: But I can't promise you
there will be no questions.
MR. BURCHILL: My name is Bill Burchill.
I'm the Director of Risk Management for Exelon.
There were no open questions from the
subcommittee meeting, but we were asked to provide a
summary of our risk impact study. What I'm going to
do -- if you could go back a slide. I don't want to
get onto this one yet.
I want to report the principal results of
the -- both qualitative and quantitative evaluations.
For the quantitative evaluations, we used CDF and LERF
as our figures of merit, and we did principally use
the full power internal events PRA, which had been
upgraded in 1999 and has been reviewed by the BWR
owners group.
The other evaluations did use some
quantitative tools but did not do a full plant risk
evaluation.
We evaluated the impact of all of the
changes that have been previously described in
hardware, procedures, operating conditions, and
setpoints. And, in general, we found no new accident
types. We found no significant changes to accident
scenarios. We found no changes to system dependencies
and no vulnerabilities that were introduced by the
EPU.
There were very limited impacts that
could, in fact, be quantified primarily in the
initiating event area and also in the operator
response times.
The examples of effects that would, of
course, come into play is the higher stored energy and
decay heat load, operating the increased number of
feedwater and condensate pumps, and more valves being
needed for both overpressure protection and
depressurization.
Now go to the next slide.
MEMBER POWERS: You said you found no new
accidents introduced by this uprated --
MR. BURCHILL: That's correct.
MEMBER POWERS: It seems to me I received
some material which I -- naturally I can't put my
hands on immediately that says that the turbine
runback does introduce some -- a new accident.
MR. BURCHILL: It's not a new accident
class, however. I mean, because we look at the
impacts of what the turbine runback would produce, and
we also look at the impacts of the failure of the
turbine runback when called upon. And they are
equivalent to scenarios that are already in the PRA.
Now, this slide is more detailed than will
fit in five minutes, but I want to point out that we
did look at all of the technical elements of the PRA,
particularly, as I said, the initiating event
frequency, success criteria, system changes, and
operator response times.
We used sensitivity studies to evaluate
these, and it also provided a guide for updating the
PRA for our next cycle of update. This slide
summarizes the key quantitative results from the full
power internal events PRA.
And you can see that there are three basic
areas. One is the area of the initiating event
frequency. There is an impact based on the fact that
we're running one more condensate pump and one more
feedwater pump, and the very first line shows that
there is a contribution there.
This contribution is actually
conservatively stated here, because we didn't take
credit in this case for the recirc pump runback
feature. That was not designed at the time that we
had this evaluation completed. So that evaluation, if
we were to take that into account, would essentially
be a zero impact.
The next five are in the operator action
category, and in each case the impact is a slightly
decreased time for the operator action. The actions
we're talking about here are generally in the 20- to
30-minute timeframe, and the decrease is on the order
of four to five minutes in those cases. So we
evaluated those analytically. We took those impacts
and determined what the new human error probabilities
would be.
MEMBER WALLIS: But all of these numbers
are 20 percent. Presumably there's some calculation?
It's strange they all come out to be the same.
MR. BURCHILL: Most of them are times that
are either 20 minutes down to 16 or 25 down to 20.
MEMBER WALLIS: So they're all the same 20
percent.
MR. BURCHILL: Yes.
MEMBER WALLIS: So this is also -- this
must be proportional to the power uprate or --
MR. BURCHILL: Well, we assumed
conservatively, and I'll use that word with care, that
we -- that there was a linear relationship between the
power increase and the time reduction. Beyond that,
we cranked it through the normal evaluation techniques
for ATPs.
The last one is the change in the
depressurization success criteria. This was probably
the largest individual change in success criteria
area. Where previously one valve would be sufficient
for depressurization, in the case of the uprated power
two valves were required. And this obviously
introduces a change to both the success criteria. It
also introduces some new failure probabilities, and,
in particular, changes our evaluation of the common
cause failure effect.
The next slide summarizes overall the
quantitative results. Again, I point out, as was
pointed out earlier, the plants are similar, but they
do have differences in equipment and that's the
principal reason for the differences in base values.
The first group of numbers is the base,
CDF, and LERF. The second group of numbers that are
expressed in percent are the impact of the EPU. The
absolute value impact, while it's the combination of
a number of individual contributions, is essentially
the same for both plants. It's about 2.4 times 10-7
per year differential on CDF.
MEMBER ROSEN: This is just with --
looking at internal events.
MR. BURCHILL: That is correct, sir.
MEMBER ROSEN: Not fire or anything else.
MR. BURCHILL: That's correct.
So the difference in the five to 10
percent that you see here is entirely due to the
difference in base value. The LERF numbers may look
to some of you who are familiar with this to be fairly
high in comparison to the CDF numbers. Generally, for
a MARK-1 containment, one would expect a LERF on the
order of 10 to 20 percent of CDF.
These numbers are considerably higher
simply because of the conservative methodology that we
used to calculate LERF. It's a methodology endorsed
by the NRC staff in Reg. Guide 1.174, and it has
served our needs for our applications to date.
Now, this is not a risk-informed
application, but -- so, as such, there are no specific
regulatory acceptance criteria. We did benchmark the
results against what are published in Reg.
Guide 1.174. What we found was that the delta CDF is
in the very small risk change region, and the delta
LERF is in the small risk change region.
The delta CDF is deep within the small
risk change region, the very small risk change region,
by about a factor of four. The delta LERF is just
barely into the small risk change region. And if one
takes into account what we believe is the degree of
conservatism in that calculation, it, too, would be in
the very small risk change region.
VICE CHAIRMAN BONACA: Just a question I
have. What is the ATWS contribution to the -- to your
CDF, 2.6 and 10-6. What's the --
MR. BURCHILL: If you add up all of the
scenarios that go to ATWS, it's about in 10 percent of
the scenarios.
VICE CHAIRMAN BONACA: Ten percent of 2.6
and 10-6.
MR. BURCHILL: Right. Okay. If I go to
the last slide, these are the qualitative risk
evaluations that were performed, and I want to quickly
point out that we did use some quantification in
these. We do have a fire PRA model for both plants.
That was developed in support of the revised IPEEE
submittal a couple of years ago.
We did examine the top 10 scenarios in
both PRAs, and those represent about 90 percent of the
CDF. We found only minimal impact, primarily on
operator action times that were long term. So,
effectively, there was a negligible impact.
For seismic, as has been mentioned, we
only have a seismic margin analysis on both plants.
We did a qualitative evaluation of the results that
were previously reported in that analysis, principally
with respect to whether any of the fragilities would
be changed or impacted by the increased power. We
found no significant impact.
We did, in response to the staff's
question, as has been mentioned, do one event-specific
event tree to quantify the impact of this dam failure
scenario that we talked about. And you're absolutely
correct, there is no specific acceptance criteria.
However, if we do map that scenario onto the Reg.
Guide 1.174, while the base value calculated was 10-5
per year, the delta was 10-8 per year. So that
actually falls well below -- you know, well into the
very small impact range, even though the base is
higher.
On the shutdown, that's all qualitative.
And, again, we evaluated our defense-in-depth actions
that we take during shutdown. We found that the only
thing that was impacted was long-term operator
actions, and also a success criteria for alternative
decay heat removal. But this is out in the 30-day
ballpark, so some of the fallback positions on
alternative decay heat removal would not be available
until after about 35 days compared to about 38 days
pre-EPU.
And, of course, we do have a configuration
risk management program during shutdown to assure that
any impacts are managed.
With respect to flooding, we do not have
flooding in our current internal events PRA. We are
installing it at this time. But the IPEEE studies
show -- I'm sorry, the IPE studies show that flooding
contributed only about one percent. So we looked at
that and did not see any impact with respect to either
new initiating events or increased initiating event
frequencies.
So our conclusion from each of these other
risk sources and operating modes is that the impact is
acceptable. I'd be happy to answer questions.
Otherwise, I will turn it over to Tim Hanley again.
MEMBER ROSEN: In all of the plant
modifications, you're not stringing into a cable?
MR. HAEGER: There is one DC cable that we
are stringing to improve the voltage at one of the
reactor panels. As far as other cable for some of the
mods, I think there has got to be some cable for that,
I assume.
Ed, I'm looking to you for confirmation.
MR. BURCHILL: And I presume the question
is based on impact on fire risk.
MEMBER ROSEN: That's right. That's where
I'm going.
MR. BURCHILL: I understand. Right. I
think in our examination of the top 10 scenarios I do
not know if we looked explicitly at this new cable,
but I would assume that the impact would be fairly
small.
MEMBER POWERS: I would assume that if you
strung new cable you'd have to go through and do
another screening on your fire areas.
MR. BURCHILL: That would be true. But I
would be surprised if this were being strung in an
entirely different location than is currently being
used.
MEMBER POWERS: Yes, I was --
MR. BURCHILL: For a similar function.
MEMBER POWERS: Well, I was thinking of
you --
MR. HAEGER: Actually, the cable I was
referring to is just a redundant, parallel cable to
reduce the voltage drop.
MEMBER POWERS: It changes the combustible
loadings in the room at the very minimum, and it also
then increases the cable tray loading. I mean, there
has to be some reanalysis that has to be done.
MR. BURCHILL: If we were to go in to
fully quantify that, that would be true. Any other
questions?
MEMBER WALLIS: There is a -- is your
friend here going to speak or --
MR. CONNELL: I can't tell if you have
heard enough or not, but what I was going to say was
on the cable -- and all of the modifications we always
look at that, that's one of the checked off features.
The major cable pulls for these modifications were the
ones that -- 125 volt DC that Al had mentioned, and
also for the pre-filters that we've added in the
condensate demin area, and that is examined.
Of course, in that area it's -- that's all
non-BOP equipment down in that area. But it does
impact the fire loading in the area, and it is
considered.
MR. BURCHILL: Yes. The fire loading
impact on the risk would be extremely minimal. If
they were really routed in different locations, that
would be where you would --
MEMBER POWERS: Might have to do another
associated circuits analysis.
MR. BURCHILL: I'm sorry?
MEMBER POWERS: Have to do another
associated circuits analysis.
MR. BURCHILL: That would be done under
the appendix. Well, it's -- this isn't an Appendix R
plant, but it --
MEMBER ROSEN: There's a discussion in the
staff's SER -- draft SER about the need to update the
PRAs sooner than the normal cycle because of the
extensive amount of modifications, both operational
and hardware. Is that something you're going to do?
MR. BURCHILL: The plan at this moment is
not to make an explicit update because of the results
of these sensitivity studies. If we need to make an
update, we have the basis to do that. What we would
do is only update about six critical parameters in the
PRA and then roll that into our online risk monitor.
The current plan is to actually
incorporate those at our next update cycle, which
would put them into place in May of next year.
MEMBER ROSEN: May of next year.
MR. BURCHILL: Yes.
MEMBER ROSEN: Rather than two years as
stated in the draft SER.
MR. BURCHILL: I don't know what the draft
SER says about our update cycle, but it would be May.
That's our next deadline for periodic update.
MEMBER ROSEN: May of 2002.
MR. BURCHILL: Correct.
MEMBER WALLIS: Are we ready to move on
or --
MR. BURCHILL: I'll turn it over to Tim
Hanley, then, who will talk about the training and
testing.
MR. HANLEY: This is Tim Hanley again.
I'm going to cover the training and testing that we're
-- we have done and are going to do during our power
uprate.
We did extensive classroom training for
the operators covering all of the aspects of EPUs,
modifications, procedure changes, uprate operating
experience. We did a lot of simulator training,
started with a walkthrough of the simulator coming in
at full EPU conditions, what the plant will look like
for the operators the first time they come to take the
shift under EPU conditions, did some normal operation
scenarios, swamping pumps, reducing recirc flow,
moving control rods, and then did dynamic scenarios
that were selected to highlight the differences and
also the similarities between the operator actions for
these transients and accidents.
They included recirc flow controller
failure, loss of feedwater heating. We did do a
turbine trip/no bypass ATWS and did an MSIV closure
with a loop LOCA. And, really, the operator's
response to that was that the -- it really doesn't
change a whole lot working through the symptom-based
EOPs that -- you know, they're monitoring parameters
and taking actions based on what those parameters are,
and their actions really haven't changed
significantly.
For the testing, we're going to --
MEMBER LEITCH: Tim, did I understand you
to say that the simulator has already been modified?
MR. HANLEY: All of this training has been
completed at Dresden. At Quad Cities, our uprate
outage is not until February. We're in the process
during this week and next week of updating the
simulator at Quad. We'll be doing our simulator
training, the final training cycle of this year, and
the one before our February EPU outage. But we are
following the same model as Dresden.
MEMBER LEITCH: So the down time on the
simulator is not appreciable. It's only a matter of
a couple of weeks?
MR. HANLEY: That's correct.
MEMBER LEITCH: Yes, okay.
MR. HANLEY: That's correct. And that was
planned into our training cycle before we began the
year.
For our testing, we'll be following the
ELTR-1 testing for the incremental testing. We'll
actually be starting at 90 percent of our current rate
of power, getting a set of data there, going up to a
constant flow control line at 100 percent power,
increasing power once a day in a three percent
interval, gathering the data, comparing it to the
acceptance criteria, before we move on the next day.
We do have a dedicated test team led by an
SRO at each site, and we are sharing resources between
the two sites, so we capture any lessons learned from
Dresden as we go to Quad Cities.
We are a two-system control system where
particularly testing is the pressure control system
and the feedwater level control system. We're
changing where the pressure control system will
control pressure, so -- because we'll have a lower
turbine throttle pressure than we currently do. So it
will be controlling at a different band.
And then three-element control will
obviously have different inputs for feed flow and
steam flow, if we want to do explicit testing on the
stability of those systems and their response to
changes in those parameters.
We do have -- since we're increasing the
flow significantly through the feedwater and steam
piping, we'll be installing vibration monitoring, both
inside and outside of the drywell, and monitoring
vibration data on both of those systems.
The acceptance criteria was established
from the ASME stress analysis limits, and that's the
basis of determining acceptability of the vibrations
we see on those lines.
Specifically asked about earlier was
modification testing, particularly on the recirc
runback. We are doing -- we'll do unique modification
tests for each of the mods that we're doing for EPU.
For the recirc runback, there's really a series of
modifications that were put in as a reliability --
plant reliability because we're using the extra
condensate feed pump.
One of those is the recirc runback. We'll
be testing the recirc runback, verifying the speed is
the speed that the runback is what we expect. We'll
be testing the entire logic train by a series of
overlapping tests. We have some pressure instruments
that -- for the feed pump low suction pressure that
will be verified in the setpoints. And we'll verify
the setpoints of the SCRAM once we reduce the SCRAM
setpoint from eight inches to zero inches.
We do not plan on doing a feed pump trip
at full power and watch the recirc pumps run back.
The basis for that was we -- it's not a safety issue.
We are not installing this mod. We don't take credit
for it in any safety analysis. It's strictly to
maintain the plant online in case you lose a feed pump
or a recirc pump.
And in an effort to not cycle these large
motors and pumps unnecessarily, we don't intend to do
a dynamic test of that entire system at full power.
MEMBER LEITCH: Can we talk just a second
about the SCRAM setpoint, level setpoint? You're
reducing that by --
MR. HANLEY: Eight inches.
MEMBER LEITCH: -- from eight inches to
zero?
MR. HANLEY: To zero, that's correct.
MEMBER LEITCH: And that only -- that
reduction only occurs when there's a trip signal into
one of the condensate pumps. Is that correct?
MR. HANLEY: No, no. That's a -- strictly
an RPS setpoint change. Yes, the RPS setpoint is at
plus eight inches right now. We've got, as part of
our EPU submittal, to reduce that down to zero.
MEMBER LEITCH: And that will be in all of
the time. That is --
MR. HANLEY: That's correct. It doesn't
set down -- it'll always be zero.
MEMBER LEITCH: Okay. I misunderstood.
Thank you.
MEMBER ROSEN: Well, there is the law of
perverse consequences, which says that if you don't
test something that then surely something will be a
problem. You're balancing off two -- two competing
issues -- one, the need to -- the desire to not cycle
these large motors and pumps versus the desire to
fully test the system which may have some unknown
failure mode. And it's always a judgment call, isn't
it, at the end of the day.
MR. HANLEY: And that's right. That --
you've got to balance, you know, the long-term
reliability of the equipment, not only just the motors
but also the seals on the pumps get rattled when you
trip them. The recirc pumps will be running back,
which can have negative effects on the seals on the
long term.
But, really, test -- tripping a feed pump
from full power really does only test one facet of it.
That just verifies that it worked under those
conditions. The overlapping testing that we'll do of
the complete logic train is what we're relying on to
shake out any unexpected consequences. Does this
runback come in when it's not supposed to?
So it's those facets, and that's why we
have a unique mod test for the modification, to ensure
that there aren't any unexpected consequences out of
it.
Currently, right now our procedures will
tell the operators, if you lose a feed pump and a
standby is not available, what they do is reduce
recirc pump speed to --
MEMBER ROSEN: But they do that manually.
MR. HANLEY: They do it manually. So the
action really isn't changing. We're just having an
automatic system that'll do it.
MEMBER ROSEN: And it's the automatic
system that won't be tested.
MR. HANLEY: Well, we will be testing the
automatic, but we won't be doing it at full power.
We'll test the recirc pumps' scoop to speed runback is
what we have designed it to be, and that it comes in
when you get a feed pump trip and the other inputs,
which is 20 inches reactor water level. We will be
testing all of those things.
Really, the only thing we're not going to
be testing is, does that keep you from hitting zero
inches and getting a SCRAM in? Because we won't be
doing it from full power. We'll be doing it in, like
I said, incremental steps as part of the outage or
part of the startup testing.
MEMBER WALLIS: Can we move on, Steve?
Can we move on? Are you satisfied?
MEMBER ROSEN: Yes.
MEMBER WALLIS: Do you have a bottom line
to show us?
MR. HANLEY: Yes. I'm going to turn it
over to John Nosko for our conclusion.
MR. NOSKO: Thank you, Tim, and our thanks
again to the Committee for listening to the
presentation.
Just to quickly summarize, our application
for the extended power uprate has followed the
standard approach for extended uprates using a
constant reactor pressure. We've conducted extensive
analyses using accepted methodology, conservative
inputs. We have found no significant impacts on the
plant response or system integrity. The changes in
plant risk we characterize as minimal.
And our conclusion, as you can see, is
that plant operation is acceptable at EPU conditions.
And with that, we thank you for your time.
MEMBER WALLIS: Thank you.
MEMBER LEITCH: I had just a couple of
questions. One relates to the basis of the tech spec
changes. And in the Dresden tech specs, there is a
sentence that presently exists where it says, "No
credit is taken in the safety analysis for the
isolation condenser system operation."
The proposed change is that sentence is
stricken, which implies that now credit is taken for
the isolation condenser operation, is that correct?
Which is -- it says the isolation condenser system is
not a safety-engineered feature system, not an
engineered safety feature system, and no credit is
taken for the safety analysis, or IC system operation.
And it proposes striking that sentence.
MR. POST: This is Jason Post. We do not
take credit for the isolation condenser. As we did
the common plan and looked at the common features of
the plants as we did the analysis, the isolation
condenser was not used in the safety analysis for LOCA
and ATWS and those types of analysis.
MR. HAEGER: Yes, I think the sentence is
struck because in the loss of feedwater we did use the
isolation condenser as modeled in there to -- to
respond to that event.
And, Mark, maybe you can amplify it
further. But I think we were just uncomfortable with
that statement in there in regards to the transient
analysis.
MR. KLUGE: This is Mark Kluge from
Exelon. Al is correct. The use of the isolation
condenser and the loss of feed transient is discussed
in the current FSAR. What Jason is referring to is
that the safety analysis for that event runs out only
until the parameters of interest have turned around.
And in that timeframe, the isolation
condenser is not credited to mitigate that transient.
It's only used as a -- in terms of long-term decay
heat removal once the transient itself has recovered
to the point it will.
MEMBER LEITCH: So to paraphrase that, am
I hearing that this is mainly to -- in cleaning up the
tech spec basis rather than a --
MR. KLUGE: It would make the tech spec
basis consistent with the FSAR.
MEMBER LEITCH: Okay. And I guess a
similar question related to a statement here that
talks about relief valves. It says these valves are
sized assuming a turbine trip, a coincident SCRAM, and
a failure of the turbine bypass system. And the
proposed changes would strike that sentence. Wouldn't
that still be the case?
MR. KLUGE: No. Again, this was the
original sizing criteria for the relief valves as
discussed in the FSAR. For the EPU condition, that
sizing was meant to prevent lifting any of the safety
valves. For the EPU condition, although all the
transient and accident analysis results are acceptable
and meet their acceptance criteria, there is a
potential that under absolutely limiting conditions we
could lift a safety valve.
So, again, we're changing the bases to be
consistent with how the FSAR will read in this case
after EPU.
MEMBER LEITCH: Okay. I understand.
Thank you.
MEMBER WALLIS: Are there any more
questions? Can we move on to the staff's
presentation? We thank you again.
We have run a little late. I'm sorry, Mr.
Chairman. Doing the best we can.
CHAIRMAN APOSTOLAKIS: I'm sure this is
not your best.
MEMBER WALLIS: It's not the first time.
I just assume that we can make adjustments to the
people we're going to see over lunch break.
CHAIRMAN APOSTOLAKIS: Perhaps the staff
can --
MEMBER WALLIS: John, are you ready to go?
MR. ZWOLINSKI: A few logistics.
MEMBER WALLIS: Are you ready now? John,
are you ready?
MR. ZWOLINSKI: Yes, sir.
MEMBER WALLIS: Please begin.
MR. ZWOLINSKI: Thank you, sir, very much.
Good morning or good afternoon. I'm John Zwolinski.
I'm the Director of the Division of Licensing Project
Management, NRR. We're here to present our review of
the extended power uprate on Dresden and Quad Cities.
I wanted to take just a couple of minutes
and beg your indulgence. I note the time is running
on. Before we start our presentation on Dresden and
Quad Cities, I'd like to reflect for just a couple of
minutes on Duane Arnold. Your letters obviously
caught the attention of not just myself, the staff,
but my senior management.
We've issued the Duane Arnold amendment,
and this is the safety evaluation for that amendment.
I'm going to send this over in the near term. I
recognize people's schedules and it may be difficult
for you to take the time to actually take a look at
this. But this is a foundation for us as we go
forward, that indeed we took your comments, concerns
in your letter, and in so many words I think we've
incorporated those in this product.
I would even go so far as to be happy to
line in and line out if that would help the Committee
to see the significant changes the staff made.
I'd like to emphasize that the staff has
performed a comprehensive review for Dresden and Quad
Cities, much along the lines of what we did with Duane
Arnold. We've been very sensitive to -- to assure
that we understand what the staff really did and
characterize that accurately, whether we performed
independent analysis, the rigor of that analysis, what
exactly did we do to confirm that the licensee's
application warrants acceptance.
I'd like to emphasize that in the approval
of the Duane Arnold power -- extended power uprate not
only did I personally spend a lot of time ensuring
this product met management expectations, I had Tad
Marsh, my Acting Deputy, independently go through this
product in great detail to meet not just the
expectations of our management team but those that we
were challenged by the Committee.
We made a detailed presentation to the
Subcommittee on Thermal Hydraulic Phenomena a couple
of weeks ago. I believe it was October 26th. A
review of the application was performed, as I said, in
a manner similar to Duane Arnold. However, our review
also covered unique features associated with Quad
Cities and Dresden.
I'd like to remind the Committee that our
review methodology that we used on Duane Arnold and
continues to evolve is predicated on the lessons
learned from Maine Yankee. All areas affected by the
power uprate have been reviewed and evaluated by our
staff. The staff has critically examined the
methodologies and their application for this power
uprate.
We have concluded that all analytical
codes and methodologies used for licensing analysis
are acceptable for this application. Although we
reviewed information in many areas, we intend to focus
our presentation today on areas we believe to be the
most important to the power uprate.
In that regard, unless there is anything
on the Duane Arnold issue, I'd like to move forward
with the presentation on Quad Cities and Dresden.
Specifically, with me, Larry Rossbach, the Lead
Project Manager for Dresden and Quad Cities power
uprate reviews. Larry is our NRR Project Manager for
Dresden plant.
Also at the table is Stu Bailey, Project
Manager for Quad Cities. Larry will give an overview
of the review process used for the application and the
order of presentations. He will also introduce the
other presenters at the table.
Noting the time, we'll move as quickly as
we can. I am sensitive to be responsive to any
questions or concerns that the Committee may have.
Larry?
MR. ROSSBACH: Thanks, John. Larry
Rossbach, NRR Project Manager for Dresden.
I just want to briefly summarize our
review approach. The staff used as guidelines in our
review the General Electric topical reports covering
generic guidelines and generic evaluations for BWR
extended power uprates referred to as ELTR-1 and
ELTR-2. These licensing topical reports have
previously been accepted by NRC as acceptable
guidelines for power uprate applications.
Staff also relied on the standard review
plan and the safety evaluation for Monticello Nuclear
Generating Plant power uprate as a guide for the scope
and the depth of our review. The staff's --
MEMBER WALLIS: The standard review plan
is not a standard review plan for uprates. It's some
other kind of standard review plan.
MR. ROSSBACH: It is. It's a general
standard review plan --
MEMBER WALLIS: Right.
MR. ROSSBACH: -- that we would use,
right, for any of our reviews.
The Dresden and Quad Cities power uprate
reviews were done in parallel with the Duane Arnold
review, which this Committee reviewed about a month
ago. In many cases, we used the same reviewers.
Where needed, the staff requested
additional information to complete our review. Staff
also completed three audits associated with our
review. One of these was done by the Reactor
Assistance Branch. They audited the global nuclear
fuels analyses. This was done at the Wilmington,
North Carolina facility.
Our Probabilistic Assessment Branch staff
audited the licensee's risk assessment review at
Exelon's Midwest offices. And the plant systems
reviewer audited the analysis done in his area at the
Dresden site. We prepared short summaries of review
in several areas -- the reactor systems area, plant
systems review, material degradation issues, and risk
assessment review.
So with that, I'll turn it over to the
first presenter, Ed Kendrick, who will discuss the
reactor systems review.
MR. KENDRICK: I'm Ed Kendrick of the
Reactor Systems Branch of NRR. During the previous
subcommittee, Ralph Caruso, our Section Chief,
presented details of our analysis of the reactor and
fuel systems performance. I want to cover a few
things.
The first -- a review scope -- we want to
point out the review scope, what I would call generic
reviews, that since 1991 all of the new fuel designs
from GE have been audited for compliance with the
approved fuel design criteria, each -- from the
initial nine by nine to the current GE 14.
And the maximum extended load line limit
analysis has been reviewed and approved for a number
of BWR plants, so these -- these areas are essentially
covered generically. And although it's the first
application of these for Dresden and Quad, there has
been extensive review before this application came in.
The specific review scope for Dresden and
Quad Cities covered the review and evaluation of the
record of performance sections of the EPU safety
analysis reports submitted by the licensee to GE,
licensing topical reports.
We also had an onsite review at GE
Wilmington. The purpose of this one was to ensure
continued compliance with the approved analytical
methods and codes, the procedures, and we also
evaluated the specific Dresden and Quad Cities reload
core safety analyses.
I'd point out that changes to the tech
spec safety limit minimum of critical power ratio were
submitted separately and were reviewed separately.
And that's why you don't see it in the EPU SER.
MEMBER POWERS: Explain to me under fuel
evaluations how it is that you know that the fuel --
these new GE fuels will tolerate the power inputs
associated with ATWS oscillations.
MR. KENDRICK: Okay. The fuel design is
audited. We actually have done some calculations of
the GE 14 fuel. The capabilities of the bundle to
generate the power and stay within all required
thermal limits has been confirmed. The ATWS scenario,
the bundle, has actually been optimized for stability.
It is more stable than the previous nine
by nine and ten by tens. And this satisfies the
criteria for the ATWS rule.
If there's no more detailed questions on
that, I think we'll answer any specifics --
MEMBER POWERS: Well, specifically, what
we asked the applicant earlier today was how much
power was it going to be putting in in the form of
these oscillations as he tried to recover. He
indicated something on the order of 70 to 80 calories
per gram. We asked him, why does he think that the
fuel will stand up to that.
He indicated that that was within the
criteria that you sat. That is an accurate statement,
I believe. The criteria is 180, but the experimental
data have come to question the adequacy of that.
MR. KENDRICK: Right. The -- in fact,
that's being addressed under the extended burnup
program. The --
MEMBER POWERS: Does the extended burnup
program have GE 14 fuel?
MR. KENDRICK: Not GE 14, but the -- the
question is primarily that of cladding performance,
not fuel performance. We look at the fuel design, the
fuel that is capable. The cladding that's used for
this bundle design is less sensitive to corrosion and
spallation, which have been the key initiators for the
RIA with the low enthalpies that have been observed.
MEMBER POWERS: So they are testing this
particular cladding?
MR. KENDRICK: I don't know if this
cladding will be tested. But for the GE 14, the
cladding material of that type will be tested. So
this is an ongoing program, and, you know, coolant
chemistry, cladding treatments, all of these are --
you know, are being used to address this.
An overview of the -- review of emphasis
considered that there was no increase in the reactor
dome pressure or in the core flow, but that the EPU is
achieved with a flatter radial power distribution and
higher average bundle powers.
Again, it has come into question, what
does the flatter power distribution do? It's a matter
of concern. We look at this when we do the onsite
reviews. We look at the actual calculations for the
-- the initial calculations for the core performance.
To do that, we examine their equilibrium bounding core
analyses. And then the question was, okay, how do you
get there?
Normally, the first transition cycle may
be the most challenging, so we were able to review the
initial -- the transition cycle calculations. Indeed,
in some areas, you were closer to the limits. We're
still within all of the thermal limits.
MEMBER WALLIS: I asked Exelon earlier
about this business of the radial peaking factor,
which they said was the ratio of bundle power of a
bundle to the average power.
MR. KENDRICK: Right.
MEMBER WALLIS: And they said this hadn't
gone up. We talked about 1.4, and so on. And then I
asked him if this -- it was also true that the maximum
bundle power itself would not be changed, and they
said yes. But it seems to me that the -- if the
higher average goes up and the ratio of maximum
average is the same, then the maximum must also go up.
MR. KENDRICK: The peak bundle power
essentially does not change. You have more bundles
that are operating closer to that peak.
MEMBER WALLIS: So the peak doesn't change
but the average changes. In that case, the average
goes up. Then, in that case the radial peaking factor
must go down if it's the ratio.
MR. KENDRICK: Right.
MEMBER WALLIS: When they were talking
about it going up. I don't quite understand the --
MR. KENDRICK: Well, they were showing the
bundles above the core average. There are more of
them that are operating --
MEMBER WALLIS: And they couldn't find the
1.4.
MR. KENDRICK: Well, but it has been 1.5
or something to have been -- to be consistent with the
logic that I'm trying to pursue here. Well, the --
there are more bundles that would be -- could operate,
as they indicated, at 40 percent above the core
average.
MEMBER WALLIS: I know. I understand
that. But the question is: how can you have --
increase the higher average bundle power and have the
same average to maximum ratio and not increase the
maximum?
MR. KENDRICK: A lot of the analyses are
done where the maximum bundle is forced to be on the
limits, somewhat artificial but -- but you come up
with a control rod pattern and an operating strategy
so that you put as many bundles as you can on limits.
MEMBER WALLIS: So if we did all of the
right arithmetic, all of these statements would turn
out to be consistent eventually?
MR. KENDRICK: Yes. The core average --
relative power distribution and -- the average core
power is going up by 17 percent in absolute terms.
MEMBER WALLIS: All right. So in that
case there, the ratio of maximum to average will
presumably have to come down in order to stay at the
same maximum by quite a bit.
MR. KENDRICK: Right.
MEMBER WALLIS: And that was not evident
from the Exelon presentation.
MR. KENDRICK: Okay.
MEMBER WALLIS: But you are assured -- you
can assure me that the maximum bundle power is still
the same as it was before in --
MR. KENDRICK: We're still within the
kilowatt per foot limits that we were before.
MEMBER WALLIS: You're within the limits.
Has it increased?
MR. KENDRICK: It has increased slightly.
MEMBER WALLIS: Slightly.
MR. KENDRICK: But, again, there is still
-- they're within the fleet. There are other reactors
that are operating at higher powers, absolute powers.
MEMBER WALLIS: Well, that's another
question, though. Okay. So, anyway, it's within the
limits.
MR. KENDRICK: Yes. Within all of the
thermal limits.
MEMBER WALLIS: Okay. Thank you.
MEMBER KRESS: I was concerned that the
flatter profile would increase the carryover for ECCS
injection. Did you guys look at that?
MR. KENDRICK: We looked at that. We
heard the -- essentially the same presentation that
you heard, and it seems reasonable. We haven't -- the
latest thing that is also new to us, too, and we
haven't evaluated that, that will be in the SER --
MEMBER KRESS: Okay.
MR. KENDRICK: -- the final SER. So we
did look at the -- all of the safety performance for
both this equilibrium core and for the initial core.
As discussed during the subcommittee, we checked that
the capability of the slick system, Boron injection
system, to perform the design function at the maximum
system pressure was very -- we determined that for
Dresden-2 everything was okay. For other units, some
modifications may have to be made to the relief valve.
Our basic conclusion was that after our
review of the report and our own site reviews, the
licensee's submittal with the GE power uprate SER and
with their response to our RAIs and with their onsite
review, they demonstrated that Dresden and Quad can
operate safely at the EPU conditions during steady
state, AOO, and accident conditions.
The design basis analyses were done with
approved methodologies, and we've verified that none
of the assumptions in those approved methodologies
have been challenged.
Cycle-specific analysis performed for
Dresden demonstrates that you can achieve a core and
approach the equilibrium core, for which much of the
analysis was done. And the EPU meets all applicable
NRC regulations.
MEMBER WALLIS: But not only can be
operated but will be operated.
MR. KENDRICK: It will be operated because
if -- in the, say, unlikely event that they couldn't
achieve the power due to something down the line, the
core will still be protected. And we convinced
ourselves that all of the safety flections and that
the thermal limits would be met.
Any questions on how we conducted our
reviews?
MEMBER WALLIS: Are you concerned about
the 1600 degrees limit being met exactly?
MR. KENDRICK: Yes. As Ralph Caruso
indicated during the subcommittee meeting, we
challenged this and effectively asked if they had to
go through a number of iterations, and were told that
they didn't, but if they did it's the acceptance
criteria. And as I indicated, the acceptance criteria
was established with a number of conservatisms
which --
MEMBER WALLIS: I guess they gave what I'm
not sure is the right answer. I mean, they said that
they didn't want to go through another calculation
because they've already -- I think they implied that
it might show a different answer which would not be so
favorable.
I would have thought that if you are
pretty close to a limit that's probably the reason why
you should go and redo the calculation.
MR. KENDRICK: I think we reviewed their
inputs to their -- the calculation, and they were all
-- all of the input values had been verified for the
licensee, the QA is verified, and we couldn't see a
reason that they would have to repeat the calculation.
MEMBER WALLIS: But the fact that you
considered whether or not -- you asked them whether or
not they had iterated several times indicates that it
is possible to tweak the number by iterating.
MR. KENDRICK: As with almost all
calculations where you have acceptance criteria, and
you do have some latitude in using tech spec values
versus measured values, there are ways that they could
have come under the criteria. And we did check a
number of inputs to make sure that they hadn't made
too many assumptions that we didn't agree with.
MEMBER WALLIS: But you didn't ask them to
make another input and see what happened?
MR. KENDRICK: No, we didn't ask them to
make another run in this case.
I might mention that when we do these
onsite reviews, we have full access to all of the
calculation files, all of the input files, to the
design people, the independent verifiers, the
management -- technical managers, and to the QA and
licensing people.
MEMBER ROSEN: Can we go on to the plant
systems review, then? Okay? Ralph Architzel.
MR. KENDRICK: Thank you.
MR. ARCHITZEL: Good morning. I'm Ralph
Architzel with the Plant Systems Branch. I was the
lead reviewer in this case. We did have other
reviewers in the Plant Systems Branch, including Steve
Jones for the spent fuel pool, Rob Elliot looked at
some of the strainer delta P calculations, and Ron
Young in the petroleum and HVAC areas.
We do have a -- as Larry mentioned, we did
the telephone conferences and RAIs and additional --
we did perform -- I did perform one audit at the site
during the performance of this review. The audit was
focused on the ultimate heat sink and also reviewing
some of the NPSH calculations.
Plant Systems Branch does have a wide area
of responsibility, as you see on these next charts.
I'm not going to go over these. I'll try and save
some time.
But I do want to let you know there was a
large -- large number of areas that the Plant Systems
Branch does review, and we've been asked to talk about
three of those areas during this meeting, if there's
no questions.
Those areas were the containment response,
the net positive suction head, and the ultimate heat
sink for Dresden only. Two of these items, in
addition to looking at the EPU effects, we also
examined -- there was existing licensing basis issues
that in addition to just concentrating on the
EPU effect we had to consider existing licensing basis
considerations during the course of our review.
Going up to the containment response --
Mark Kluge from Exelon has already gone over this also
-- but basically the analysis methods used conformed
with the ELTR-1, Appendix G, topical guidelines. The
licensee used M3CPT for short-term response. They
used LAM, which was noted in the ELTR, which is a
change, for mass and energy releases. And they used
superhex for the long-term containment response.
And some of these are code changes from
what was their previous licensing case. They're using
different codes at this time.
The containment pressure demonstrated a
small pressure increase due to the EPU, but you should
note that the analysis did result in reduced pressures
from the licensing basis. So this actually results in
a reduced containment pressure from a licensing basis
standpoint, this EPU.
The wetwell pressure peaks higher than
previous. Regarding the suppression pool temperature
response, there was, as noted before, approximately an
eight- or nine-degree increase in the suppression pool
temperature. Additionally, the analysis methods were
another 10-degree increases, about a 20-degree
increase in the suppression pool temperature as a
result of these EPU and associated code changes.
This did impact the NPSH, but the
temperatures remained below the structural limits.
Regarding local temperatures in the suppression pool,
they demonstrated there was no stream entrainment in
the ECCS suctions, and that addresses one of the GE
requirements for local temperature requirements for
the suppression pool.
Containment airspace temperature response
-- the peak temperatures do remain below design, as
noted earlier. The steam line break is the limiting
case and it -- before, and now it comes fairly close
to the limit, and it's terminated when the sprays are
turned on at 10 minutes. The EPU, in effect, was very
small, and the containment dynamic loads remain
bounded.
That's all I had for containment system
response.
MEMBER POWERS: When you say the
containment dynamic loads remain bounded, explain to
me a little more what you mean by that.
MR. ARCHITZEL: What I mean is the
licensee went in and looked at the -- the analysis
that's done for the MARK-1 long-term program, and all
of the different condensation, oscillation, etcetera,
and the pool swell, and looked at the load definitions
there and made statements to us, they did those
analyses.
Those will be calculations at the site
that I did not look at that GE would have done. And
they made sure that those MARK-1 containment program
results were still within the analysis of the test
results and the bounding load definitions for
structures inside like the TORUS and the --
MEMBER POWERS: And so you just took --
you just took on faith that they had done those
correctly.
MR. ARCHITZEL: As far as the long-term
program bounding, yes. I did not look at the GE
analysis for the -- for the dynamic loads.
MEMBER LEITCH: Concerning the containment
airspace temperature response, all four of these units
have deactivated the head spray line, have they? I
guess -- I don't -- there used to be head spray.
MR. ARCHITZEL: Do you mean inside the
reactor?
MEMBER LEITCH: Yes, that wouldn't --
MR. ARCHITZEL: I was talking about the
containment.
MEMBER LEITCH: I was thinking back to an
earlier issue.
MR. ARCHITZEL: That would be a reactor
system. I think the --
MEMBER POWERS: Are you speaking of the
drywell spray?
MEMBER LEITCH: No, head spray I was
talking about.
MR. ARCHITZEL: I'm not familiar with
that. I'd have to get back to you.
MEMBER LEITCH: Okay. It's --
MEMBER POWERS: Well, are the drywell
sprays intact?
MR. ARCHITZEL: I did not -- I assume the
drywell spray is still there and that's why the
pressure turned at the 10-minute points. There were
no changes noted on the drywell sprays.
Going on to the net positive suction
issue, as noted earlier, the EPU does result in a
higher suppression pool temperature sooner in the
transient. ELTR-1 noted that this would be a
requirement for some GE BWRs, and both Dresden and
Quad Cities do need more credit for NPSH than they had
previously requested. Dresden had previously been
approved and Quad Cities had an application in.
The licensee used conservative assumptions
to -- different than the LOCA peak pressure
temperature assumptions to determine what the
temperatures and pressures would be for NPSH. A big
factor in this EPU, the existing licensing basis, was
the strainer differential pressure calculations and
accommodating the new strainers. And the differential
pressures they had result in a significant pressure
drop increase that they had to accommodate with this
EPU.
And that was incorporated. The procedures
and training had been given to the operators to
recognize cavitation and when to throttle back flow
and take credit for that at the 10-minute point and
other points during a transient in their emergency
procedures.
And, therefore, they've requested -- and
the staff plans to approve -- overpressure credit in
a step-wise fashion to the accident end. And there's
a -- we could go and look at a curve, and I've got
that if anybody is interested on how that's approved
through the --
MEMBER WALLIS: You agreed with their
presentation, that they showed this bar graph where
what they need is so much and what's available is so
much, and it's always enough.
MR. ARCHITZEL: That's not -- I would not
agree precisely with those margins. I mean, they go
right to the limit in a step-wise fashion. There's
times when there's no margin. There's times when they
cavitate.
But can I show the backup here for a
second on this -- on the Dresden backup? I'm not
totally -- I mean, do you have the backup?
MEMBER WALLIS: It sounds as if your
evaluation was a bit more thorough than their
presentation. You looked at all of the conditions.
They looked at some of them.
MR. ARCHITZEL: Just give me one second,
because it's easy to show.
MEMBER WALLIS: I'm not sure if I need to
see all of the details, but you looked at the whole
site while they just looked at a few points.
MR. ARCHITZEL: It's in the application.
Basically, if you look at -- this point here was --
the point I'm trying to make is just that this is in
their application, and you could present it
differently, but this point was one of the margins
presented. You do step down, so it is an average
margin as you go through with time. But you do hit
the actual available pressure curve with their
application and with what we're granting.
So I didn't want to totally agree with it,
but you can present data different ways, and --
MEMBER WALLIS: So, essentially, your
review was more thorough than their presentation as --
MR. ARCHITZEL: More thorough than their
presentation, but --
MEMBER WALLIS: I understand what you're
saying here, but that doesn't matter. I think we have
to move on.
MR. ARCHITZEL: The last item I have to
talk about is the Dresden ultimate heat sink, and the
EPU does affect the quantity and makeup required due
to the increased decay heat for the ultimate heat
sink.
The isolation condenser is used for hot
shutdown for the 30-day duration in the event of a dam
failure. The isolation -- in several steps. The
initial shell inventory is credited for a 20-minute
duration. EPU only affects related to the shell
inventory, affects the minimum cooldown rate which
will be reduced. But, still, the 20-minute duration
is not challenged. It's that you may have less of a
cooldown during that initial 20 minutes.
In the short term, the isolation condenser
from makeup -- it's relied on from diverse onsite and
non-safety-related sources. This is before and after
EPU. There are a variety of onsite sources available
-- tanks, cleaned storage tank, and Unit 1 intake
canal. Again, these individually still can make the
20-minute -- the two-hour criteria that's available.
In the long term, after two hours, it
requires them two hours to establish makeup from the
ultimate heat sink, this is -- again, there's no time
impact associated with this, getting the two hours
established from the ultimate heat sink. And they
have procedures in place and tested to get that
online.
The available inventory -- and there are
some diverse non-safety-related paths they're relying
on. Part of the reason for the ultimate heat sink
still taking some time to resolve is that there was
existing licensing issues associated with what they
credited at what time.
The available ultimate heat sink inventory
in the intake canal only has been now credited, and
that will be lasting four days under current
conditions. We're at 5.5 under the previous power
condition, so there is that -- that aspect of the
change.
The licensee is crediting portable low
head/high volume pumps to replenish the ultimate heat
sink from the river or they could also replenish it
from the discharge canal, but -- if there was water in
the discharge canal. And this is a previous credit
that had been addressed in the SEP program to obtain
these portable low head pumps, and the staff is
finalizing its review there and anticipates approval
of this methodology.
MEMBER WALLIS: You're not worried about
the state of the river after the dam has failed? I
mean, there may be no river, it may be another place.
It may be --
MR. ARCHITZEL: Well, that's a limiting
case. And there is some concern there; however, they
still -- once they get it into the intake canal, you
still have some settling available. You still have
the intake rates.
In addition, there is a lot of inventory
in the other canals. You'd have to take a lot of non-
safety failures. If you're -- do not have the water,
like, in the intake canal or the hot or cold canal,
there's a lot of -- in the lake that's available. So
in a real sense, there are a lot of other sources
available, but with a seismic event they'd be gone.
So --
MEMBER ROSEN: But all of that was in the
current licensing basis, right?
MEMBER WALLIS: Apparently it was, yes.
MEMBER ROSEN: We're not talking about a
change to the EPU.
MR. ARCHITZEL: They have something that
would transition in the licensing basis that basically
we recognize an informed license at this time. There
has been changes in the ultimate heat sink through
time.
MEMBER WALLIS: Are there any other
questions at this point? I was wondering about the
materials degradation.
MR. ARCHITZEL: The EPU impact is a timing
impact, but there are -- there is a need to define,
clearly, the licensing basis.
MEMBER WALLIS: Materials degradation
issues -- could we just maybe read these and ask if
Dr. Shack has any questions. Are you satisfied, Bill,
with what --
MEMBER SHACK: The only thing that
surprises me is just how high the wear rates are in
the feedwater line. I mean, at 20 mils a year --
MEMBER POWERS: And we're never changing
the line.
MEMBER SHACK: -- that's a healthy wear
rate.
MEMBER WALLIS: Unhealthy wear rate.
MEMBER SHACK: The increase is fairly
modest.
(Laughter.)
But the baseline is surprisingly high for
a line that you really didn't want to change.
MEMBER POWERS: The license renewal folks
will need to look at that one, I suppose.
MEMBER SHACK: Yes. I would think the
license renewal people would --
MEMBER WALLIS: Do you have any questions
on the presentation that --
MEMBER POWERS: The applicant indicated
that he had no fatigue issues arising despite the
higher flows. His staff also find that to be the
case.
MEMBER WALLIS: I think the staff is
essentially agreeing with the applicant on these
issues, isn't it?
MEMBER POWERS: You found no instances of
-- where fatigue was a concern?
MR. NOLEY: This is Gonoma Noley from
Clinical Branch. We agree with the conclusion the
applicant had regarding the fatigue usage factor for
the safety and non-safety systems for the steam dryers
that were stresses -- maximum stresses from normal and
upset for bending a membrane, still below the
endurance limit for the standard seal.
MEMBER POWERS: Did we have any instances
where the CUF became close to one?
MR. NOLEY: I can't hear you.
MEMBER POWERS: Did we have any instances
where the CUF became close to one?
MR. NOLEY: No. You don't need to compute
the CUF if you are below the endurance limits.
MEMBER POWERS: This time I didn't hear
you.
(Laughter.)
MR. NOLEY: You don't need to compute the
cumulative uses factor if you are below the endurance
limits for the material.
MEMBER WALLIS: So maybe we could accept
that you accept the applicant's view of materials
degradation issues, and the Committee has no further
questions on that matter? Is that a fair statement?
I'm trying to move us along. I don't think this is a
matter that we are worried too much about. I thought
we might move along.
I'm sorry not to give you a chance to give
your presentation.
MR. ROSSBACH: Donny Harrison will present
the PRA review.
MEMBER WALLIS: Maybe we can move along
faster this one, too?
CHAIRMAN APOSTOLAKIS: Let me ask a
question. You don't need to -- the numbers for core
damage frequency in LERF that the licensee presented
are fairly low, a few 10-6 a year. And the licensee
told us that their PRA had been reviewed by the BWR
owners group. Did you review it?
MR. HARRISON: No, I did not.
CHAIRMAN APOSTOLAKIS: Not you personally.
I mean --
MR. HARRISON: No. I conducted the review
for the PRA Branch, and we did not look at -- we did
not perform a detailed review of the PRA model or the
system models. What we did do is look at the results,
look at the impacts that they provided as part of the
EPU, and looked at it for reasonableness.
CHAIRMAN APOSTOLAKIS: So you don't really
know whether the numbers they gave us are valid or
reasonable, and the delta CDF and delta LERF are
reasonable? And the reason why you don't really care
is because it's not part of the petition, is it? This
is not a risk-informed --
MR. HARRISON: This is not risk-informed.
They provide risk information -- I'm sorry. I didn't
introduce myself. I'm Donny Harrison. I'm in the PRA
Branch.
They provide it because the topical report
requests that they provide it. We look at it strictly
to gain insights into the plant as far as what the
impacts of the EPU are. We don't, for this type of
application, go and look at the actual PRA and
determine if it's acceptable.
CHAIRMAN APOSTOLAKIS: Okay. So there was
a series of operator actions in one of the viewgraphs
of the licensee --
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: -- where basically
what was happening was the available time was reduced
by about 20 percent.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: And then, what we
saw was that the impact on CDF was one percent or so.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: Now, did you review
that part? What model did they use to make the
connection between the probability of human error and
the available time? Is that --
MR. HARRISON: No. We didn't look at --
CHAIRMAN APOSTOLAKIS: What model did they
use? Do you remember?
MR. HARRISON: We didn't go in and look at
the actual reliability analysis method. I do remember
from some slides that I saw probably back in July that
there's a variety of different methods they used. But
one of them was their -- it's an old method. I don't
recall off the top of my head what else, but there are
performance shaping factors they use to determine that
some things are cause-based and some things are time
limited, and that's --
CHAIRMAN APOSTOLAKIS: Now, you said that
you -- basically, that although the PRA here is to
give you insights --
MR. HARRISON: As far as --
CHAIRMAN APOSTOLAKIS: -- I am perplexed
by that word -- "insights." What does that mean? I
mean, if we don't really get into the models and try
to understand what they're doing --
MR. HARRISON: What we're trying to gain
a perspective on is the impact from the power uprate
itself. And so what we're looking for is to basically
ask questions using the information that comes from
the various pieces of the submittal, and pursue those
to see if there's anything that would be a surprise.
For example, on the ultimate heat sink, we
went and asked a number of questions about their
seismic modeling, because that was identified as a
vulnerability. Well, it was a hole, if you will, in
the seismic margin analysis out of the IPEEE. And so
we pursued that.
And to answer Dr. Kress' earlier question,
even though there's not a specific criteria or a
guideline in Reg. Guide 1.174, what we were looking
for was this in an unacceptable condition. And so we
were looking at this particular scenario because it
wasn't anywhere where we could actually tell what the
risk was associated with it.
So we look for things that stand out, and
then we pursue those to see what the impact was.
CHAIRMAN APOSTOLAKIS: Yes. But you say
in your viewgraph that the staff, in its review, used,
what, the safety evaluation of the IPEs and their
IPEEEs.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: And as I recall,
one of the findings there was that the human error
probability for the initiation of standby liquid
control was particularly abused in the IPEEEs. Now,
does that insight from there give you an insight here?
MR. HARRISON: I don't recall that
particular piece but -- on Dresden. What I do recall
is that there were documentation questions on their
reliability analysis that came out of --
CHAIRMAN APOSTOLAKIS: The Dresden
reliability analysis or the IPEEE?
MR. HARRISON: Out of the IPEEE --
CHAIRMAN APOSTOLAKIS: IPE.
MR. HARRISON: -- IPE, yes.
CHAIRMAN APOSTOLAKIS: IPE.
MR. HARRISON: We're both confused. Out
of the IPE, I think there were some -- there was --
the level of documentation -- that was back in the
early to mid '90s. Dr. Burchill has come on board in
the mid '90s, late '90s. And partly why we did a site
visit was to look at how do they maintain --
CHAIRMAN APOSTOLAKIS: I didn't mean that
Dresden abused it. It was a generic --
MR. HARRISON: It was a generic --
CHAIRMAN APOSTOLAKIS: Yes.
MR. HARRISON: Okay.
CHAIRMAN APOSTOLAKIS: Yes.
MR. HARRISON: I'm sorry. I thought you
were --
CHAIRMAN APOSTOLAKIS: No, no, no.
VICE CHAIRMAN BONACA: But the fact is if
you look at the CDF for this plant, it's one-tenth of
similar BWR-3, MARK-1 containment plan or less. And
so if you take CDF increase to be 10 percent, 10
percent of a very small number --
MEMBER ROSEN: Is very small.
VICE CHAIRMAN BONACA: -- is very small.
MR. HARRISON: This is the internal event
CDF you're referring to.
VICE CHAIRMAN BONACA: I understand that.
MR. HARRISON: Right.
VICE CHAIRMAN BONACA: I'm comparing to
similar plans of similar designs that typically I've
seen with -- for the same CDF to be a factor of 10 or
more.
So, you know, we had a claim that there
was, I believe, a minor --
CHAIRMAN APOSTOLAKIS: Very small.
VICE CHAIRMAN BONACA: -- increase -- yes,
minimal changes in plant risk. Well, that's based
very much on what's in it, and --
CHAIRMAN APOSTOLAKIS: So they could do it
using 50.59, right?
VICE CHAIRMAN BONACA: And if this small
number is driven, for example, by optimistic operator
actions, then one is concerned because the ATWS event
is dominated by operator action, so far as -- do you
see where I'm going?
And so it would be nice to have insights
in this line of thinking, but --
MR. HARRISON: And this was a question
that partially came up as part of Duane Arnold as
well. Especially for the early initiation of slick,
which is typically four to six minutes into the
accident, that's the time that it's usually
calculated.
For Dresden, they changed their -- the
model that they were using to determine that time, so
it -- I think it -- it was at six minutes. Let's stay
at six minutes with the methodology change. So for
them, they didn't change their human error
probabilities.
But that doesn't answer your question,
which is, is the base model acceptable? What we rely
on for that -- again, this is not risk-informed, so we
looked at the results of the BWR owners group review.
We asked some questions of the licensee. They provide
either simple calculations back to us or they provide
some additional results. And we make a judgment call
on the acceptability of that for this application --
again, with the application of --
CHAIRMAN APOSTOLAKIS: Yes. I have a
couple of questions here. One is, is the BWR owners
review the same as NEI's certification process?
MR. HARRISON: I think the BWR owners
group was the base upon which the NEI process --
MEMBER ROSEN: George, the BWR owners
group pioneered the certification process which is now
embedded in the standard, the ASME standard and the
NEI.
CHAIRMAN APOSTOLAKIS: But it's primarily
NEI, though. Now, the way I understand that process,
how it works, is that they don't really declare this
is good or bad. They tell you, you know, for this
kind of application, this is what you should do.
MR. HARRISON: Right. They give you a
ranking.
CHAIRMAN APOSTOLAKIS: So it would be of
interest to see here whether that review said that --
or concluded that what they did was appropriate for
estimating human error probabilities when you change
the time available by 20 percent.
You know, the overall PRA may be very
good, but that particular point, you know, might be a
weakness, for example. And it's a weakness of the
state of the art, actually. I don't think it's
something that we do very well.
But the other thing that I'm just curious
-- maybe I don't understand the regulation -- this is
not a risk-informed application.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: Yet we are looking
at 1.174. So what would you have done if the delta
CDF were above the 1.174 acceptable limits? It would
say, you know --
MR. HARRISON: It would put us into --
and, again, I'll come back to the example on the
seismic failure of the dam. If there's an area where
we're not sure where we are, or if we think that the
number is, say, somewhere in the 10-3 range, 10-4
range, we would pursue that under the -- we have a
risk regulatory information summary process that would
say, is this something that would rebut the
presumption of adequate protection?
And if it was something like that, then we
would pursue even further with the licensee to either
refine their analysis, provide additional detail to
show that they weren't an outlier. They may come back
-- I mean, if they just barely got into, say, the
higher region in Reg. Guide 1.174, they may be able to
argue that it's a conservative analysis, it's a
screening approach, and try to argue back.
But if they are clearly in that area, we
would pursue through the -- through that process. We
would notify the --
CHAIRMAN APOSTOLAKIS: But what happens I
think in this case is that the limit of 1.174 is not
really adequate protection limit.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: So --
MR. HARRISON: I'm just using it as a
guideline.
CHAIRMAN APOSTOLAKIS: -- you are
concerned about adequate protection, so what may
happen is that you approve the petition with a delta
CDF or delta LERF above the 1.174 limit, but still we
provide the adequate protection to the public health
and safety. I mean, that could happen.
MR. HARRISON: Right.
CHAIRMAN APOSTOLAKIS: Could it not?
MR. RUBIN: If I could add, Dr.
Apostolakis -- Mark Rubin from PRA staff -- yes,
you're absolutely correct, of course. The staff --
CHAIRMAN APOSTOLAKIS: Of course. I like
that.
(Laughter.)
Whatever you say now is okay.
(Laughter.)
MR. RUBIN: Maybe I've said enough.
(Laughter.)
The issue of pursuing risk information
where it's not a risk-informed approach was discussed
with the Committee previously when the Commission
letter was sent up.
And the intent was a slightly different
twist from what we're seeing here -- was to deal with
situations where no risk insights or information were
provided at all, yet the staff thought that there
might be a potential, even though the regulations were
met, for some undue risk to creep in.
Here we have situations where licensees
are providing some or quite a bit of risk information,
yet they're not risk-informed. Some of those mean the
predominant or a major element of the justification is
not focused on the risk.
Even though they did provide information
and it's not risk-informed, we're still looking at the
1.174 guidelines as a good benchmark to give a feeling
of where they are. Clearly, if they were above 1.174,
there's a considerable margin between that and
adequate protection.
But as we discussed when we came before
the Committee on the non-risk-informed risk issues,
tripping the 1.174 guidelines would be the point where
we might start questioning adequate protection, and
then we'd be looking into it with a great more effort.
Here, we do not, you know, come close to that point.
MEMBER POWERS: It seems to me that one of
the issues that arises in connection with this looking
at the risk information is the staff had a concern
that they may be introducing a new accident with their
runback. And, I mean, the licensee contends that,
well, that's a class of accidents that he already
recognized in his PRA, and I assume you looked at that
and agreed with that conclusion.
MR. HARRISON: On the particulars, what
often happens is we take the licensee submittal, and
I tend to look at responses to other questions that
other staff members ask in other branches. And often
times that raises a question in my mind as to how it's
being dealt with.
That's how we came across the question on
the main -- on the auxiliary transformer and the
reserve auxiliary transformer and pursued those with
the licensee. On the recirc runback, the licensee is
putting that in to offset the potential for increasing
turbine trips, because now they're running all of
their pumps.
We then asked if you're going to put in a
circuit that runs back to the pumps, what's the
potential for a spurious runback that now trips you?
And we were provided calculations and assured that
that was a small number.
We don't necessarily -- I don't look at it
to say, is this a new accident or is it not a new
accident? I look at it more as, is there a scenario
that wasn't -- that could occur that hasn't been
analyzed? And, if so, what is the magnitude of that?
MEMBER POWERS: See, this is your
opportunity to get in good graces with the Chairman to
say, "This is what I mean by insights."
(Laughter.)
MEMBER WALLIS: So, George, are we ready
to move on?
CHAIRMAN APOSTOLAKIS: I am -- I have no
more questions. I almost said I'm happy, but I --
(Laughter.)
-- have no more questions. I like your
last bullet, though. I really do. I think it was
carefully drafted.
MR. HARRISON: Thank you. I wrote it.
(Laughter.)
CHAIRMAN APOSTOLAKIS: Very carefully
drafted.
MEMBER WALLIS: Do you have a bottom line,
John, that -- I don't see a bottom line here. Are you
recommending, or are you proposing to approve this
application?
MR. ZWOLINSKI: Yes, sir. I had some
closing remarks.
MEMBER WALLIS: Right. Please.
MR. ZWOLINSKI: Well, one, I'd like to,
obviously, thank the Committee for the opportunity to
present our review of the Dresden and Quad Cities
extended power uprate. We consider our completion of
the Duane Arnold extended power uprate, as well as the
Quad Cities and Dresden, to be a major accomplishment
for the staff.
I'd like to again emphasize that the NRR
staff has undertaken an extensive review of these
applications. All areas affected by the power uprate
have been reviewed and evaluated by the staff. Staff
has critically examined the methodologies and their
application to this power uprate request.
We have concluded that all analytical
codes and methodology used in the licensing analysis
are acceptable for this application. The results of
the deterministic analyses have demonstrated that the
proposed increases in power level for the Dresden and
Quad Cities units are acceptable and meet regulatory
requirements.
Thus, the bottom line to the staff's
efforts in its review of this application is that we
would propose to approve the licensee's request in
going forward.
I'd like to also mention that we feel that
extended power uprates will be submitted to staff for
quite some time, and, as such, we are proposing to
undertake a lessons learned of our activities, conduct
a workshop with the industry. We're going to take
data and input such as that received from this
Committee and others, and attempt to improve our
overall review process and streamline the process to
the extent practical.
You may recall that we are spending a lot
of effort in doing these reviews, on the order of 2500
to 3000 hours. Are we reviewing the right issues, the
right areas, to the right scope and depth? And we're
challenging ourselves in this lessons learned activity
as we go forward.
Other plants have docketed, and those
reviews are underway. Can we be more focused in our
review effort? And we're challenging ourselves to
work more effectively and efficiently, while we
maintain safety.
So with this, this concludes our
presentation, and I'd like to -- like to say that I
remain very sensitive to assure that high quality
products are issued by the agency. I believe we've
met that threshold on Duane Arnold. We'll meet that
threshold with Quad Cities and Dresden.
MEMBER POWERS: You did not, in your
closing remarks, speak to the issue of the large
transient test.
MR. ZWOLINSKI: I'd be happy to provide
the Committee with the status of where that's at, or
ask Tad Marsh, my Deputy --
MR. MARSH: We have formulated an opinion
regarding the large transient tests, and we are
undergoing a senior management review of that opinion.
We recognize there are pluses and minuses associated
with this test, as you were pointing out. One has to
make a decision regarding all of the benefits and all
of the detriments that may be involved. So we
anticipate that decision either at the end of this
week or early next week.
MEMBER POWERS: Do you have any
reservations about the ability of this Oden Code to
adequately predict the plant response?
MR. MARSH: No, we do not.
MEMBER WALLIS: So what about the open
items? They will be resolved before you will issue
the amendment or --
MR. ZWOLINSKI: Yes, sir. Yes, all open
items will be resolved prior to issuance of this
amendment.
MEMBER WALLIS: Are there any other --
MEMBER POWERS: Well, I'm -- I guess, Tad,
you gave me the wonderfully political answer that --
MR. MARSH: Yes.
MEMBER POWERS: -- senior management is
looking at this. You are not willing to share with us
the bottom line? Are we going to test or not?
MR. MARSH: Not at this point, because
it's -- it's still before our senior management. And
we -- just to be perfectly honest with you, there are
good technical arguments both ways with respect to
this issue. The staff has given its best argument,
and we're trying to weigh all of those various
arguments. And we recognize --
MEMBER POWERS: And there's a physical --
there's a philosophical -- we're going to accept the
ELTR-1 and 2. When it says don't do things, we ought
to say -- accept it when it's going to do -- when it
says do do things. That's the other --
MR. MARSH: That's certainly true.
MEMBER POWERS: But on the other hand,
ELTR-1 I guess is being modified by changes in
opinion.
MR. MARSH: The latest proposal in from GE
is that they do not do these large transient tests,
and that is under staff review as well.
MEMBER POWERS: Does that open up all the
rest of the methodology for reexamination?
MR. MARSH: I don't believe so. No, I
believe that this is a narrow issue with respect to --
to the testing, these large transient tests and
whether these particular tests are needed to assure
construction, completion, adequacy, testing of an
operator action times. I don't believe it opens up
any broader issues than that.
MR. ZWOLINSKI: Dr. Powers, we've gotten
into the pros and cons, challenged our staff,
challenged the management team, and we are on a
balance scale. And we're in constant dialogue with
our senior management to resolve this particular
issue.
We're somewhat embarrassed that it has not
been brought to closure at this time, but it would
certainly be brought to closure before this amendment
is issued. So I feel we have the next week or two to
bring --
MR. MARSH: If the Committee would prefer,
we'd be glad to come with -- to you with our decision
in whatever way you'd like. There can be -- in the
safety evaluation or a presentation, whatever you'd
prefer.
MEMBER WALLIS: I think that's something
for the Committee to discuss.
MEMBER POWERS: I guess I agree with
Professor Wallis that we need to look at the totality
of this and how crucial this transient test is --
MEMBER WALLIS: Right.
MEMBER POWERS: -- in our thinking.
MEMBER WALLIS: Right.
MR. MARSH: As we are as well with respect
to --
MEMBER ROSEN: I, for one, would like to
discuss it with the other members.
MEMBER WALLIS: Are we ready to move on?
Unfortunately, these uprates lead to lower operator
reaction times. We always seem to get longer reaction
times when we --
(Laughter.)
-- as a Committee.
CHAIRMAN APOSTOLAKIS: So your error
probability goes down.
MEMBER WALLIS: Our error probability
hopefully goes down, yes.
MEMBER POWERS: Professor Wallis, you beat
yourself up too much. You should blame the staff for
inadequately arranging the agenda.
MEMBER WALLIS: No, the buck stops here.
I'm sorry.
(Laughter.)
Thank you very much, John, and the staff,
for your presentations.
MR. ZWOLINSKI: Thank you.
MEMBER WALLIS: I will return this meeting
to the Chairman.
CHAIRMAN APOSTOLAKIS: Thank you,
Professor Wallis.
We will recess until 2:15. Remember that
we have to interview some prospective candidates.
(Whereupon, at 1:05 p.m., the proceedings
in the foregoing matter went off the
record.)
A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
(2:17 p.m.)
CHAIRMAN APOSTOLAKIS: We are back in
session. The next item is the NRC Safety Research
Program. Dr. Bonaca is the member responsible this
time.
VICE CHAIRMAN BONACA: Well, we had a
discussion yesterday afternoon and we defined an
agenda, so I'll just leave it now to Mr. King, I
guess, to lead. Oh, no, okay.
MR. ZIMMERMAN: Well, good afternoon. I'm
going to introduce the team. We appreciate the
opportunity to be meeting with you today to describe
some of the accomplishment that we've had that we view
as very important accomplishments. The initiatives
that we have under way and some of the challenges that
we have underway, and as always we look forward to
your feedback and questions as we, as we discuss the
topics.
Let me introduce first those individuals
that will be making presentations. Following
discussions by myself, Jim Johnson, who is a Special
Assistant to the Office Director, Ashok Thadani, who
would like to be here and passes on his regrets. He's
on foreign travel. Jim will follow my discussion.
That will be followed by Tom King, who is the Director
of the Division of System Analysis and Regulatory
Effectiveness.
Mike Mayfield, who is the Director of the
Division of Engineering Technology, will follow, and
I'm sure that there will be, during the interaction
and discussion, Scott Newberry, new to Research. He
joined Research -
MEMBER POWERS: But new to the Committee.
MR. ZIMMERMAN: About four months? About
four months ago, is the Director of the Division of
Risk Analysis and Applications. I've been with the
Office of Research since the latter part of March of
this year. And with that, we'll go ahead and begin.
On the first slide titled outline, and I'm going to
move through these slides at a pretty good pace. Make
sure you won't hesitate to slow me down when you want
to and speed me up similarly.
MEMBER POWERS: Well, maybe, maybe you
should go through this and you can give us an idea how
and if, and if concerns over, should we say, security
issues and liquid plants might impact the ability to
carry out other research programs.
MR. ZIMMERMAN: That's a good question and
it's very, it's very timely because that's basically
the discussion that's been going on a lot just today.
There's a lot of information being passed back and
forth this afternoon. So I'll definitely touch upon
that. This slide really addresses what we're going to
be discussing over the next couple of hours. I want
to spend a little bit of time on our recent
accomplishments. Talk, obviously, about the good
report that you provide to us, advance reactors
discussion.
What we're looking at doing is swapping
the order and doing the refocusing and reinvigorating
item after the discussion on the ACRS Report. I'm
only, I've got a hard commitment at 3:30, and I wanted
to make sure, as much as I'd like to be here for
everything, I wanted to be here for the reinvigorating
if I had to make that decision along those lines.
CHAIRMAN APOSTOLAKIS: So you just
prioritized?
MR. ZIMMERMAN: Yes. I have nothing
against Tom's presentation. I have no doubt that it
will be, it will be very good.
MEMBER POWERS: So confident in fact you
don't need to be here, right?
(Laughter.)
MR. ZIMMERMAN: And then we wanted to wrap
up on new challenges, some of the areas that Mike will
talk about in the materials area. And we're
interested in getting your thoughts as well,
obviously, as we look at anticipatory research, some
items that you feel that are appropriate for
considerations as we look into the preparation for the
outgoing fiscal years.
Okay, on Slide 2, recent accomplishments.
Jim is going to get into this, but I wanted to spend
a few moments on this particular slide at a high
level. And one of the things that we're trying to do
and it's not really, it's not a new initiative. It
may have been talked about before this committee in
the past, but it's very important for our office to be
able to clearly articulate what it's accomplished in
layman's terms so that we can explain to internal and
external stakeholders the work that we do and what
we've accomplished with the resources that we have,
both our staff and our dollars.
We have significant initiative underway in
our various documents, in our briefings, to make sure
that we are working hard in making those
accomplishments known. And it's not the issuance of
a new reg document by itself, it's how that new reg is
going to be used and then finding out is it really
being used the way it was intended. It's, that's a
very important initiative.
And again, Jim will talk about it and I'm
sure we'll have some dialogue on it.
MEMBER POWERS: I guess I'm a little bit
surprised you didn't, maybe you thought it was
premature to highlight the, well I guess, you have a
spent fuel storage up there, but the risk analysis of
the spent fuel pool at decommissioning plants I
thought was a substantial research contribution in
there.
MR. ZIMMERMAN: And I would agree. And
there's others, the IP, IPEEE, we're completing the
IPEEE review and we feel that that's been a very
significant endeavor. It's not meant to be an
exhaustive list, there are others. And I agree, Dana,
with the one that you've mentioned. I'm not looking
at getting into each of these. If there's any here
that peak you interest, that you want to discuss, we
went through these in some detail during our recent,
recent NSRC Annual Conference that we had. Again,
with a, with the concept of wanting to be able to make
sure that our stakeholders understand the work that
we've done.
And I realize that there are, these are
not new issues to you, you've been heavily involved in
them. And as Dana, the Designer, said, you can see
they may not be up here as well.
MEMBER POWERS: And I think it's important
to get a, I mean I agree with Roy that communicating
what's been accomplished is very important. And to
the extent that we can contribute to that in the
research report, we really ought to do that. And so
it will probably be useful to have a list that at
least approach comprehensiveness.
MR. ZIMMERMAN: In some common threads
that you had in your report, the expert panel from
former Commissioner Rogers had in his report, it
addressed this issue of communication. The purpose of
theirs was a little different, so they spent a little
bit more time on it. But that thread was in your
report, as you know, to us as well. And it is one
that is a significant one, as I mentioned before. So
unless there's anything particular on this slide, I
won't go into any of the individual --
MEMBER FORD: I've got a question,
however.
MR. ZIMMERMAN: Okay.
MEMBER FORD: You've listed two things,
PRA and aging research. As two separate items, and at
the, I haven't seen any efforts to combine them, to
put a time component into PRA. There was a talk given
at the research conference two weeks ago, was it? Or
whenever it was. It was almost like a no giveaway.
It was a, well, it may, it may be funded, it may not
be funded. And yet I would have thought that this was
a fairly high-level leap. Is it going to be funded?
And is it a high-priority item?
MR. NEWBERRY: Yes. Scott Newberry. Yes,
there is a good amount of funding in the next fiscal
year's efforts to build upon work that was done in
this past fiscal year. Working, marrying the activity
in my division with Mike's. So there was a, I think
I'd call it a feasibility study looking at aging in
the feed water system. To really get into the physics
of aging, aging and incorporating it into a risk
model.
And the hope now is to move into items
that are a little bit more complicated. I think we're
thinking about looking at aging. Well, if the
materials are cable, I think this fiscal year is what
I think you're considering, yeah.
MEMBER POWERS: It's cable, I think.
MR. NEWBERRY: Yes, it will be funded, is
the answer.
MEMBER FORD: You've listed down 5046 as
an accomplishment. Is that really an accomplishment
or is that work that's still underway?
MR. NEWBERRY: Yes/no. Accomplishment in
terms of the feasibility study building upon the
framework to indicate, yes we thing that 5046 can be
risk informed. Certainly work underway to do the
technical work, and we're in the middle of that.
MEMBER POWERS: Yes, so I think we have to
treat that one a little more carefully.
MR. ZIMMERMAN: Okay, moving on. These
are just some additional areas that, we already spoke
about the risk in form, the consolidation of thermal
hydraulic codes, the work that's being done is steam
generation plan. Again, it's, as you put together a
list, it's where you want to stop and these are some
other ones that obviously are very --
MEMBER WALLIS: Well, these thermal
hydraulic codes were being consolidated when I came on
this committee, and that's about four years ago. And
I think it was probably the five year plan, maybe.
So, there must be about this, this babe must be about
to be born.
MR. KING: We're hopeful with this next
fiscal year that the baby will be born. And we'll
have a working version.
MEMBER POWERS: I have to say that one of
the things that I was, have been very impressed by is
the use that you're being able, your making of
computational fluid dynamics and attacking some
particularly tough issues in mixing flows and
countercurrent flows. So impressed that I, I told
Commissioner Diaz he ought to get a briefing on it.
That, not that you had the answer yet, but that the
tool is being integrated into your capabilities to
respond to the Licensing Branch when they have these
tough thermal hydraulic questions.
I don't think you should be reluctant to
highlight. I think that's, that's a testimony to what
you've been able to do.
MEMBER WALLIS: It's an accomplishment,
it's been done.
MR. ZIMMERMAN: It's another example of
getting the message out. And I'm not sure if we've
briefed Commissioner Diaz yet. I know we have briefed
Carl Pepperella(phonetic). We are looking at, again,
explaining more of what we're doing so people have a
good --
MEMBER POWERS: I think you, I think
Commissioner Diaz would just be very interested in
what you're doing and, not that you have final answers
yet, but that you're attacking them with that tool.
Because, you know what I mean, he has a thermal
hydraulics bent himself and he's interested in these
front-line --
MEMBER KRESS: For example, I think this
jet cutting of steam generator tubes, I think you used
that --
MEMBER POWERS: Yeah, but you know we
didn't believe those results, Tom.
MEMBER KRESS: I know, I know, but that
was a place where you can highlight the use of that
CFD. Plus on this steam generator mixing issue.
MR. ROSEN: Roy, you know I've been, well
I'm like the new guy on the block here. And for all
those years I looked at what the NRC was doing with
research and wondered about it. And I would like you
to comment on, overall, do you take a prospective
strategic point of view, looking at all the pieces,
and say where is the risk to the public's health and
safety?
And make sure that you're putting the
puzzle together in a resource constrained environment
in a way that does, in fact, put the money, the
public's money on the things that, where there maybe
aspects of unknown risk. Do you have some sort of top
down process that does that?
MR. ZIMMERMAN: We do that a
prioritization process. It's an algorithm that does
have weighting factors into it. It focuses on all of
our four performance goals, but it's weighted toward
maintaining safety. So we do have that. The key is
that through the course of the year we know that
reactive work is going to come, it's the nature of the
job. That will occur.
And we have to have the process for how we
add on new work that needs to be done and shed other
work or postpone other work. And bringing that into
play, from the, along with the original planning that
was done, and integrating it is really the key that
you can do that in real time. We have to have a
ranking so that when the new work comes, you have a
way of doing it. And the other piece you have to
bring into play is the fungibility.
That the individuals that may have to do
this new work, may not be the same people that, you
know, that you were originally planning on shedding
this other work to do it. We've got to bring in the
reality of the fungibility of the individuals, whether
they be our staff or a Contractor's.
But I guess the more directing us there
is, yes we do have a process for ranking our work.
MEMBER FORD: On that issue, do you have
a metric for your success? I remember at your, at the
presentation to the Commissioners, following Dana's
report, there was some of the beating of the chests
about your decreasing funds over the last however many
years. One way around it is to show by metric what
you're contributing to improving the safety. Do you
have such a metric? And do you use it to get more
money?
MR. ZIMMERMAN: We have, well there are,
in terms of getting more money, I mean set aside
September 11th --
MEMBER FORD: Yeah.
MR. ZIMMERMAN: -- we compete with other
offices on, you know, on basically a level playing
field to be able to explain how we have, have
prioritized our work. And again, we need to get
better and I think we are getting better. I'm
relatively new on the block in research, obviously.
But I think that, it's an area that we still need to
get at. We have such expertise in our office, that it
is obvious to the person who's doing the work the
benefit of what they're doing.
I mean it's a little bit of the forest and
trees, and they understand it and may not immediately
understand why it's being challenged or questioned.
In fact, human nature kicks in and you get one or, you
know you're --
MEMBER FORD: You just get defensive.
MR. ZIMMERMAN: -- you just don't want to
be challenged because you have a defensive reaction to
it. It's just human nature. But we need to do that
to ourselves to be able to break down what is the
deliverable? What is ultimately going to come out
that an objective audience is going to look at? And
is it going to agree with us on it's own merits if
this is work that's worth doing. Whether it is for
maintaining safety or reducing the necessary burden or
any of the four performance goals. And we're not
quite where we need to be on that, but we're getting
better at it.
MEMBER WALLIS: I think your answer is you
don't have a metric. You have a sort of qualitative
argument that we have these objectives and we met
them, but that's not the same thing as having a
measure.
MR. ZIMMERMAN: Our metric at the highest
level for your performance plan is that we're going to
complete 40 tasks.
MEMBER WALLIS: Umm hmm.
MR. ZIMMERMAN: That doesn't communicate
very well. Right? That's not the metric that we
want. So we're working to say that's not good
communication. What is a better communication
vehicle? And what we're doing is we're identifying
the top priority items that we can define. We're
putting timeliness goals on those, and we're saying
that we're going to meet the timeliness of these top
ten things that we're working on in our office.
That's the change that we've made from saying we're
going to do 40, 40 things.
MEMBER WALLIS: Well, if you had something
like there's a risk uncertainty reduction worth or
something, I mean that's some kind of a thing which
you can measure. You could say, yes, when we do this
research, this --
MEMBER POWERS: I just have to interject
and say I have watched, over the last 20 years, at
least three organizations, one national laboratory and
two private organizations, go through various attempts
to find a metric. And you cannot. And it never
works. And there's no point in doing it. What Roy is
talking about where you say, look, here's how we fit
into the overall scheme of things and here's what
we're doing in accomplishing -- it's what you need to
do here.
There's not a number you can attach to
these things and come back and say, uh uh, my number
is up two tenths or down three tenths and what not.
No single member is going to communicate all that they
do.
MEMBER KRESS: I'd like to, I'd like to
second that comment --
MEMBER FORD: I'd like to argue that one.
If you look around this country and the world in fact,
unless you haven't that trick you will have.
MEMBER POWERS: Now I have watched Dupont
Central Research go through this, I've watched Eastman
Kodak go through this, and it never works.
MEMBER FORD: Eastman Kodak is about to go
down the drain.
(Laughter.)
MEMBER POWERS: Not probably because of
the research program.
(Laughter.)
MR. ROSEN: Well, maybe because they put
their money on the wrong thing.
VICE CHAIRMAN BONACA: Let me just say one
thing, I would like to interject. Maybe I was remiss
at the beginning of the meeting not to define further
what the purpose of the presentation was.
(Laughter.)
VICE CHAIRMAN BONACA: And I apologize
for, I just jumped out from introducing to this and
then I just, okay, so I assumed, and I was wrong, that
everybody understood. What happened is that we every
year write research report. And we had a plan to
write a very focused report this year. Focused
probably on new reactors and providing some feedback
to research regarding their closure or recommendation
from the 1990, from the 2001 report. And we met with
Research yesterday. They told us that they were
talking about many more things than just simply the
reactors.
And so the purpose of this meeting,
really, is to hear the message they have to give us on
all these different areas, and then at the end of this
meeting to regroup as a committee and decide whether
or not our focus is going to be different the report.
We still intend to write a more concise
report than last year, because last year was a
comprehensive one. It addresses many areas of
research and I believe that there isn't something we
can decided about that.
MEMBER POWERS: I think we can just focus
on cutting out the heavy section of steel research and
that would be fine.
(Laughter.)
VICE CHAIRMAN BONACA: So, no, but I just
wanted to, I wanted to just, just make sure that we as
a committee, you know, follow this path. I mean we
are all trying to get to the end of this meeting and
understand how, you know, how come this report finally
decision on what this research report should contain
for this year. The intent being, again, that it
should be focused on some lesser items than last year.
Touch some new issues, and certainly new reactors is
a new issue that we spent quite a bit of time already
this year looking at it.
MR. ZIMMERMAN: Okay, I'll move on. And
I think some of the discussion that we had will come
up during the reinvigorating discussion again. In
moving to the background slide, we had the benefit,
this past spring, to have your report, which was very
broad and thorough in scope. We had the expert panel
report which was very good. We also have the National
Lab Report coming together. So we had great, great
input coming in to assist us.
And there was common threads that existed
between those, between your report and the others.
And I just wanted to spend a moment on those as we
start to gravitate into your report. One of them,
that we already talked about, was the communication
and the need for that. Another one was the need to
maintain core competencies. And we fully agree with
that.
You had indicated in the report the
importance of identifying those areas that we felt
were very important that we maintain those core
competencies. Areas that either contract expertise
didn't exist, or if it did exist, we really, the
feeling was it needed to be in-house as well. And we
fully agree with that and we have done that and
identified where those areas are.
You also talked about preparing for future
challenges. Advance reactors, risk control framework
and the like. And we are fully on board and
supportive and agree with those. And again, it was
consistent with what we saw in other reports. The
issue on PRA about improving the standard on PRA and
the robustness and vastness of the use of the PRA, we
agreed with as well.
So there was a lot of commonality and
common threads. The ACRS report, as you know, was
briefed in May. The SRM quickly followed and then in
July we provided our response to the SRM, which is
really aimed at looking at what areas, research fill,
we should continue with work activities where ACRS had
recommended sunsetting was a specific area of the SRM.
We provided our response back on July
20th. We neglected to send a copy of that response to
the ACRS, and I wanted to formally apologize for not
having done that. We should have done that at that
time. And we're going to talk about some of those
individual items as we go forward.
We were able to take your input and use it
to inform our budget process to some degree for fiscal
year '03. Some of the work was already in our '02
budget, so there was already alignment. Some of the
areas were, again, we were in agreement. We were able
to get them into our '03 budget, but the timing was
such that we didn't have a whole lot of time to do it.
We did what we were able to and we will
continue to do that as we start to work on the, on the
'04 budget process as well. The question came up
before about what is the impact of September 11th, on
this? We're going to need to wait and see, but I
don't think we're going to have to wait too much
longer. One of the things that's going on right now
is that we are very actively working with OMB about
what our needs are and they're reviewing our other
work and it goes back again to setting our priorities.
And if we have to, if we don't get all the
funding that we're looking for or making our best
case, if it turns out that we need to do what we call
an add shed process as a result of that, not just
within this office but how it affects other offices,
we'll be prepared to do that. Okay, again we really
appreciated the time and effort that went into the
report that John gave. It was very broad and
encompassing and it was a great assist to us.
There were a number of areas. Obviously
you had recommended additional research. Examples
like high burn up fuel are examples where we have got
those areas into the '02 budget. Recommendations for
closure, we're going to talk about those in a couple
of minutes. Let's keep going. I think I've already
talked about those items. Move on to Slide 7. Again,
we've expanded the testing program on high burn up and
various types of planting material.
We're looking at what can be done with
PHEBUS for severe accident conditions. Those are
areas that now are funded for '02. On the last bullet
we are doing the pebblebed preapplication review and
supporting NRR on the AP-1000 preapplication review.
So there's a number of areas where the issues you've
raised we're fully engaged in.
On Slide 8, we get into the four areas
where it was recommended that we bring work activities
to closure. On the Control Room Design Review and the
vessel lower head failure research we're in agreement.
Those items are being brought to, brought to closure.
We are sunsetting those activities. On Slide 9, I
think it's a little bit more of a mixed bag, and I
think on these two I'd be looking to see if Tom can
talk a little bit about the common cause failure
aspects and then Scott on the ATHEANA Program.
MR. NEWBERRY: I'll take them both, okay.
Now without going into too much detail, these were two
areas that the committee recommended sunsetting and
we're proceeding to that in what I guess I'd call an
orderly way. I just signed paperwork this morning on
the common cause, where we were, we have wrapped up
the methodology work and would only complete this
fiscal year remaining inside reports from data that is
being put together. And so the program will
essentially be sunset this fiscal year, consistent
with your recommendation, I think.
Of course we would continue to gather
operating experience data from plants. And should
there be common cause information there, we would
continue to gather that at some level. And Pat
Baranowsky(phonetic) and Steve Mays have initiated a
program to be much more efficient there in terms of
creating a web-based program. I think eventually
we'll get over there and talk to you about. That's,
I think, very exciting, moving away from hard copied
paper reports, new regs, something that would be
available on-line should we be able to make it
publicly available, which is another issue.
CHAIRMAN APOSTOLAKIS: What's ICDE?
MR. NEWBERRY: It stands for, that's an
NEA, you know, an international common cause data
exchange activity, where we meet periodically with
international counterparts to exchange data, and
discuss use and insights from the data.
CHAIRMAN APOSTOLAKIS: Are you getting any
useful information from our international partners?
I mean are the open enough to tell you what's going on
in their plans?
MR. NEWBERRY: I can give you a general
answer without specifics, and Steve Mays is sitting
back there shaking his head yes, absolutely. I
haven't been briefed on the very recent meeting up in
Ottawa where we, Pat was up there. But I think the
answer is yes, George, but I can't go into detail.
CHAIRMAN APOSTOLAKIS: That's worth
spending whatever it's --
MR. KING: It's very inexpensive. It's
like 15, 13k a year is our membership fee and a couple
of meetings, but we get the data from all the
participants.
CHAIRMAN APOSTOLAKIS: Right. So even
though your budgets are going down, 13k -- all right
fine.
MR. NEWBERRY: Okay. I think we're
scheduled to eventually get over here and talk to you
not only about, you know, about our human reliability
plan. I believe the committee has it. We're working
to get a meeting up. I think we were planning sooner,
but I think we're going to have to, that's one of the
impact items from 9/11. The staff that I have working
in that area --
MEMBER POWERS: Yeah, let me emphasize to
you that that meeting should be held when you're
ready.
MR. NEWBERRY: Okay.
MEMBER POWERS: And not on some schedule.
Because it's more important that you be ready for the
meeting, than it is to have it in some particular date
or something like that.
MR. NEWBERRY: Okay, thank you. But just
commenting on that particular item, we plan to proceed
with sunsetting the developmental activities
associated with ATHEANA moving more into its
application and quantification.
CHAIRMAN APOSTOLAKIS: Let me understand
that though, I don't understand it. You will proceed
with the application of something that has not been
developed? But you will stop its development?
MR. NEWBERRY: It's my understanding that
we will use what has been developed to date.
CHAIRMAN APOSTOLAKIS: To do what?
MR. NEWBERRY: To assist us in --
CHAIRMAN APOSTOLAKIS: In more
development?
MR. NEWBERRY: No, to assist us in the
pressurized thermal shock, steam generator tube
rupture, and other risk studies or assessments we're
doing to support, you know, regulatory applications.
CHAIRMAN APOSTOLAKIS: But you don't plan
to stop the development of human reliability methods?
MR. NEWBERRY: No, no, no. Well --
CHAIRMAN APOSTOLAKIS: I mean that would
be something that would be a separate effort, after
ATHEANA?
MR. NEWBERRY: I'm really not prepared,
George, to go into the details on that. But I do know
right now that the basic thrust of our efforts is to
move away from investing much more in the
methodological development of ATHEANA itself.
CHAIRMAN APOSTOLAKIS: So when we say
that, I'm wondering what we mean. I mean ATHEANA as
it stands today in terms of its objectives and the
people who are doing it and so on, you plan to sunset
that and then do something about human reliability
again, right? Maybe with a new project or a new
people, new ideas, or using a number of ideas from
ATHEANA? Because our report never said that, you
know, that the whole thing is useless. I mean we just
said, look, you were supposed to develop a
quantification method. It's been a while now and you
haven't.
MR. NEWBERRY: Right, we're going to move
ahead with the quantification and its support in these
other applications. I think that's all I'm prepared
to get into. I haven't got into it myself in the time
I've been on the job, frankly.
MEMBER POWERS: We have a plan that
they've sent us.
CHAIRMAN APOSTOLAKIS: Yeah, I've seen
that.
MEMBER POWERS: I mean ordinarily we would
have, be following this meeting up with a subcommittee
meeting and they've got the major players playing too
many roles right now.
CHAIRMAN APOSTOLAKIS: So is the
quantification, let's say we follow the plan that Dana
mentioned and all of a sudden we have a flash of
brilliance and in six months we have a great
quantification method. Would that be part of ATHEANA
or you will call it something else?
MR. NEWBERRY: I don't know. You'll have
to come talk about that.
CHAIRMAN APOSTOLAKIS: Okay, the memo that
was not sent to us says that the staff believes that
the ATHEANA distinction between the likelihood of the
aeroforce in context and the condition or probability
of the unsafe act, given the aeroforce in context, is
appropriate for any human reliability analysis method.
The six were developed and proved estimates of the
likelihood of safe acts.
And then it goes on to defend that
concept. We never said anything about that.
MR. NEWBERRY: And my understanding from
what you're reading, there are reasons why it wasn't
sent to you.
CHAIRMAN APOSTOLAKIS: Because of that.
MR. NEWBERRY: I can't answer all those
questions.
CHAIRMAN APOSTOLAKIS: Anyway, it's a
little more defensive.
MR. ZIMMERMAN: Well, it looks like this
is a topic that needs additional dialogue.
CHAIRMAN APOSTOLAKIS: I guess when we
review the human reliability plan, this then will come
up.
MEMBER POWERS: Yeah, I think we've, we
let them get their plan together and come talk to us.
CHAIRMAN APOSTOLAKIS: The thing is that
we also have to tell something about the plan, what to
put in the research report.
MEMBER POWERS: Well, I think, I think we
just have to reserve comment until we've had a chance
to let them explain this plan to us thoroughly.
CHAIRMAN APOSTOLAKIS: Well, we may even
have the subcommittee meeting before there is a
research report.
MEMBER POWERS: Well, I think it's
important that we not try to jam that, that
subcommittee meeting in on top of everything else that
the principles are playing. I mean I think that's
just --
MR. NEWBERRY: I think it's fair to tell
you right now that the people doing this work have
stopped working on it. They are being deferred
virtually 100 percent to other activities.
MEMBER POWERS: I think we've got a little
ways, I mean I think we've got a while. And my
feeling about it is that they formulate plan, I may
not understand everything that's in that plan, but I
think I can. It's just a matter of getting together
with them. There's no point in getting together with
them until they've had a chance to prepare a good
discussion on it. Because it will be a good
discussion. I mean good in the sense that it will be
interesting to everybody.
And I think if that runs afoul of our
schedule that we just say, well, we're not going to
talk about that right now. You've just got to be
fair, because you can't ask these guys, they're
already working 14 hours days.
CHAIRMAN APOSTOLAKIS: I think we're
understanding of that. It's just that I thought we
were going to, I mean these are the only two topics in
fact where you disagree with us. So, these two,
right?
MR. NEWBERRY: Well, my reading on it --
CHAIRMAN APOSTOLAKIS: Well, you disagreed
by your mission with another one. Because if I go to
your last slide, Roy, Number 10. And then I go to the
Research Report, Volume 4, we had about a page on
decision making methods, and you are completely
silent, so far at least. Is it something that you
don't plan to pursue and you disagreed with us?
MR. JOHNSON: There is a small scale in-
house effort underway right now. But it's all done
in-house and I would presume that when we've
established the elements of a, of a program, then it
will go much broader. Right now we're just looking at
how one would take uncertain information and use it in
the decision making as opposed to looking at any
formal decision methods now in terms of laying out --
CHAIRMAN APOSTOLAKIS: So you are
disagreeing with us?
MR. ZIMMERMAN: I don't think it's a
matter -- you'll see it Jim, it says it differently
than this. To me it's not so much that we disagree,
it's that in the, in the hierarchy of what we
prioritized this item came in in a place that we have
a modest effort underway now. It's not, it's not
tabled, it's not that nothing is going to be. We are
going to invest time and effort into it, it just may
not be on a robust a scale or time period that maybe
desired.
MEMBER POWERS: I think, if I recall the
wording, it was not drop everything and look into
decision methods. Think about, is there something to
be done here? I mean it sounds like you're responding
at the same level of urgency as the wording in the
report.
CHAIRMAN APOSTOLAKIS: Have you read the
letter of the committee on the revised oversight
process?
MR. JOHNSON: Say again?
CHAIRMAN APOSTOLAKIS: Did you read the
letter of the committee on the revised oversight
process?
MR. JOHNSON: No, I did not.
CHAIRMAN APOSTOLAKIS: Maybe you should.
Because this is not just bringing in methods, because
real computations, the oversight process is a major
activity of the Commission and the committee makes a
few comments there that certain things would have been
done better if these methods were already in place.
MR. JOHNSON: Okay.
CHAIRMAN APOSTOLAKIS: We're not talking
about bringing an academic approach here to things.
When you say green, white, yellow and red, some guys
for a few decades have been worried about these
things. And they have come up with some ways of
handling them. And that's part of this
recommendation. That position that you leave last
month, the revised oversight process.
MEMBER KRESS: I see, a couple of weeks
ago.
MR. ZIMMERMAN: Okay, I think we're ready
to move on. It sounds like the last slide, Slide 10,
are again things that we've really already touched on
so I would suggest that we start the discussion on the
reinvigorating initiative that we have in place, if
that's okay with the committee.
MR. JOHNSON: Okay, again my name is Jim
Johnson. And NRC had its first agency action review
meeting this past June on the 26th through the 28th of
June this year. Chairman Meserve made some remarks at
that meeting, and as a part of his remarks he
identified ten, the ten most significant challenges
facing the agency.
And among those challenges that he
identified, one of them was refocusing and
reinvigorating the role of research to the agency
demands. Advance reactives was a second one, as well
as risk-informed regulations. These were three of the
ten challenges that the Chairman identified. Shortly
after that, the Office of Research had an off-site
retreat and this reinvigorating challenge was further
discussed.
And it was the consensus of the senior
managers of the Office of Research that we would
develop a paper that would describe a plan of action
to deal with the challenge, this particular challenge
that the Chairman identified. And what you see on
this very first viewgraph is just three of the topics
that would be included in that report.
CHAIRMAN APOSTOLAKIS: Did the Chairman
tell you why he feels that the Office of Research
needs to be refocused and reinvigorated? These re
prefixes, did he explain them? Are you unfocused now?
MR. JOHNSON: I don't think he provided a
great deal of explanation. This is, plus I wasn't at
the meeting. This is what I gleaned from
conversations and what I've seen written. And the
only recorded message we had was in the minutes of the
EDO to the Commission where these challenges were
stated.
We have inquired about additional meaning
to them, but we are just operating now with our
understanding of what the Chairman had intended by
these challenges.
MEMBER WALLIS: You need to have a measure
of, a metric for vigor to be invigorated.
CHAIRMAN APOSTOLAKIS: And a metric of
focus. So you don't have an SRM, right?
MEMBER POWERS: It's not a mystery what
the concern over the focus is. I mean I think if we,
we look at other of Commissioner Meserve's speeches
that he has been concerned about the lack of
anticipatory research.
MR. ZIMMERMAN: I think there's a few
things that drive it from the Commission level.
There's the issue of the percentage of anticipatory
research. There's the alignment issues that we've
been working with NRR on in terms of the user need
process. I think both offices are working
constructively on that, but it's a challenging area to
work on the balance between user need and anticipatory
research and some of the, some of the intricacies of
that process are being re-evaluated in a significant
way right now.
And they really revamped the way that
process and that interface works. But that issue is
one that the Commission became aware of. That the two
offices were trying to work through that. That the
two offices were trying to work through issues of
independence, and what does independence mean as it
applies to research. And there's continuing dialogues
to try to deal with specific cases so that we can
achieve a more harmonious working relationship when
some of these issues manifest themselves.
Some of these issues, again, came to the
Commissions attention because they were prolonged
dialogues on these topics. You sprinkle in the fact
that the research budget has been going down, so their
budgets have as well. So it's not to say that
research is alone, but the fact that the budget was
going down, there's some demoralization that occurs
for individuals that have seen that change and an
inability to get work done on things that they feel
need to get done.
So there was a lot of this all coming
together in my mind that this mosaic led to this issue
that we need to add clarity to some of these areas
that are confusion about these points of intersection
and the interface between how offices will work
together. The role of research, whether it's
independent, whether it's supportive of NMSS and NRR.
The percentage on anticipatory work. And that's my
thoughts on where, what's behind this.
MR. JOHNSON: And this should definitely
be described as a work in progress and it will
probably evolve over time. Although we've identified
these three topics for the report, they too may change
as we get more in to it.
MEMBER FORD: What is the time they're
needed? When do you have to complete this vision
process?
CHAIRMAN APOSTOLAKIS: Didn't we have that
last year? Didn't we have a vision?
MR. JOHNSON: There is a vision statement?
CHAIRMAN APOSTOLAKIS: Why are we
revisiting it? We didn't like that vision?
MR. JOHNSON: Oh, no, no, no. We are not
saying we are going to write another vision. We are
talking about a report that --
CHAIRMAN APOSTOLAKIS: Oh, put everything
together.
MR. JOHNSON: -- this is a topic of the
report.
CHAIRMAN APOSTOLAKIS: Okay, okay.
MR. ZIMMERMAN: It ties together. It goes
back to the earlier discussion about are we working on
the right things. But one of the things that we need
to do is just re-baseline ourselves, make sure that
we're where we ought to be. If we look at our, at our
vision and our mission, does that align with the work
that we're doing? Are we working on the right thing
so we get back to basics and reground ourselves.
So we wanted to, as a group, make sure
that we were aligned, that the mission, the vision,
the foundation building blocks were all in alignment,
that they are right, we don't have any issues, and
then we can go from there. That's what we were trying
to do at this retreat, is put them in front of us,
stare at them, talk about them.
If we're not in alignment, which would
have surprised us at that level. But if we weren't,
sit and talk it out. That's what the retreat was for,
is start there and then go from that point.
MEMBER FORD: When is this white paper to
be finished?
MR. JOHNSON: We are aiming to have a
draft of it ready by the end of the year, end of the
calendar year. Then we'll iterate on it, you know,
for a period of time.
MR. ZIMMERMAN: As you'll see, as Jim goes
through you will see the different pieces of what
makes this up. There's a whole smattering of pieces
that we're working on to accomplish this.
MR. JOHNSON: Okay. And although we do
have this vision and mission statement, in fact this
is SECY 99281. But we have received some, some
comments on this document suggesting that it ought to
be revisited and some corrections made. The other
topic would be to provide some historical perspective.
Again, this is just a document that would talk about
the strengths and the accomplishments of the Office of
Research.
And then the final point would be the
reinvigoration process. And the remaining viewgraphs
that we have here are to address this reinvigoration
process. And we would start with the communication.
We believe that communication is an important part of
any reinvigoration process. And it's clear to know,
when we talk about communication it's such a broad and
general area, and so we have to be fairly specific and
know what problems we are trying to address.
We have to know who our stakeholders are.
And we generally characterize them as both internal
and external.
CHAIRMAN APOSTOLAKIS: This is a subject
that keeps coming up, as you know. What came to mind
now is that, you know, for years people out there know
that if they pick up a National Laboratory Report, all
the references are NUREG. You pick up an industry
study, you don't see any NUREGs. Well, maybe now
things are a little different. Maybe you can ask
these people why that is so? But you will get very
useful -- is it because they are not aware of the work
that is being done?
Is it because they don't like it or they
disapprove? I don't know. But several of us have
complained in different forums in the last, whatever,
20 years. You know, the National Lab guys always cite
NUREG reports, the industry always cites its own
reports. And there doesn't seem to be --
MR. JOHNSON: We are aware of that and at
the NSRC Conference this year we had a special session
on communications, where we invited external
stakeholders in and to speak to those subjects. And
basically the bottom line is, is that we ought to, you
know, involve our external stakeholders early on in
the process. That was the general consensus of those
on the panel, be involved in the actual planning.
CHAIRMAN APOSTOLAKIS: Do you still have
restrictions sending people to national conferences,
for example? And presenting papers?
MR. JOHNSON: There's no restriction that
I'm aware of.
MR. MAYFIELD: There's the obvious, you
can only send so many people so many times.
CHAIRMAN APOSTOLAKIS: Oh, I understand
that.
MR. MAYFIELD: Yeah, but beyond that, and
in fact in the statements of work that we send to the
laboratories there is a piece that goes in there that
says we encourage publication and peer review
journals. So there is encouragement to both the DOE
Laboratories as well as our other commercial companies
to publish. Publish in peer review journals, to
attend conferences. We do hold the, sort of reserve
the right to say which ones they're going to go to and
how much we spend on it, but we do encourage it very
actively. And encourage our staff to participate
also.
MR. ZIMMERMAN: This initiative is a real
back to basics, Management 101. It's the things we
were talking about before, about being able to explain
in plain English the things that we do internally and
externally. But it's also how do we communicate
within our own organization? How do we do our own
staff meetings?
Do we get the word out and give time for
people to digest it and ask questions if they don't
understand it? Or is it a one-way dialogue rather
than a two-way dialogue. The whole art of
communication and asking for feedback and wanting
feedback so it's viewed that you want the feedback,
not that you're asking but you don't want it.
You know, it's building that trust through
the organization. Reinvigoration is going to take all
of this stuff. It's having meetings with set agendas
that are understood what is success for the meeting.
Where the meetings start on time and end on time. And
it's a whole, again it's a mosaic of a lot of
different things because when we don't do those things
and it become habitual, you start to lose the staff.
And we're trying to move in the opposite
direction. So it's more attention to some of these
areas is what we're --
MEMBER POWERS: I think it always bears
repeating. We have a superb staff in Research. I
mean relative to most government agencies, you've got
the cream of the crop here.
CHAIRMAN APOSTOLAKIS: I suspect a part of
the reason communication is not very good at its
various guises, is the lack of time on the part of
people. People just don't have time to read, to go,
to listen to other people. I mean if you're under
tremendous pressure to do something by next Tuesday,
the last thing you're going to think about is, you
know, going to a conference or talking to somebody or
listening to somebody else.
And I think that's something that you
can't do much about.
MR. ZIMMERMAN: You've got to find that
happy medium. The staff, when surveyed, there was a
survey done by an SCS candidate, the last SCS
candidate development group. You might have seen that
report. It was a very good report about
communications. And they surveyed from different
offices. And one of the things that they said about,
about our office, is they're not getting enough
information from the management team.
They can get it from reading inside NRC,
but they are not getting enough through our own staff
meetings. Obviously that's clearly not what we want
to have. So, again, you line all these things up
under reinvigorating, they all have a little piece.
They're all little stressors in there. And we need to
work on them collectively. You've got to get your
arms around them and then you've got to wrestle them
to the ground.
MR. JOHNSON: And I think the bottom line
is you need strategies to deal both with the internal
and the external stakeholders. And that was part of
the exercise with the Rogers Committee. We had a lot
of external stakeholders there, communication was a
big issue and at the NSRC we invited external
stakeholders there to try and get suggestions and to
develop strategies to deal with them as well.
MR. ROSEN: That's part of the answer to
George's question. You know, George, you asked why
does the industry never reference NRC work and --
CHAIRMAN APOSTOLAKIS: And vice versa.
MR. ROSEN: -- yeah, vice versa. Well, I
think it all goes back to this question of getting
external stakeholder comment and integration into your
planning process. Clearly there are going to be
things that the industry wants to do that the NRC is
not going to have an interest in, and that's fine.
And clearly there are going to be things
the NRC wants to do, in the nature of confirmatory
work, that the industry would rather you didn't do
probably. And that's fine too. But there's going to
be a big middle ground, a vast area of congruence
which, if identified, will lead to the kind of
referencing that you want.
Because the work was planned jointly and
administered and maybe even funded jointly under the
guidelines that I've seen that I think make sense.
And in that sense, going back and reinvigorating and
refocusing that process to make it more of a joint
effort with industry. Nobody is as smart as all of
us, and to have that really work would make a lot more
sense.
MR. JOHNSON: Well, we are participating
in a CSNI working group, which has been set up to try
and identify the impediments of regulators working
with the industry. And both the NRC and EPRI will
have representatives on there. So that's another
attempt to try and, you know, bring them to bare on
this.
MR. ROSEN: And maybe another comment on,
as long as I've interrupted the flow here.
Internally, Roy, when you're talking about this need
to listen and talk to your own staff and management,
will lead to a very positive result. One, that is
that when we do, when you do decide, using your
priority scheme, to have certain things not be funded
anymore, this add shed process. When you get to shed,
the people who's work is being shed will be able to
trace the decision back to the original vision and
priority structure, rather than just some ad hominem
attack on them.
MR. ZIMMERMAN: Right, it's not arbitrary
in the way the decisions are made.
MR. ROSEN: It's not arbitrary, it's not
about you, it's not about your skill level. It's all
about the mission of the organization and the agency.
MR. ZIMMERMAN: Right.
MEMBER POWERS: You have your work shed,
you blame it on somebody.
MR. ROSEN: I don't think so. I think if
you, if you understand the reasons for it and are
integrated and have a common, the kind of trust that
I think Roy is trying to build, and, between the
management and the staff, that you'll find something
else to do that's more valuable and you'll come back
the next day invigorated, to work on something that's
more mainstream.
MR. NEWBERRY: Just to chime in there.
One of the activities that came out of our retreat
relating to this is to relook at our prioritization
process. Because there is some lessons learned that
we have coming out of last year's budget cycle, and
we're going to --
CHAIRMAN APOSTOLAKIS: What process is
that?
MR. NEWBERRY: The prioritization process
that we use to rank our work. It is --
MR. ZIMMERMAN: It's against the four
performance goals.
MR. NEWBERRY: It's against the four
performance goals. Very much so, very much so. And
there, there a number of views on how to improve it.
And we're going to try to take those views and --
CHAIRMAN APOSTOLAKIS: -- what you're
ignoring.
MR. NEWBERRY: Formal decision making.
MR. ZIMMERMAN: That's right.
MEMBER FORD: Just for my information,
what are these four performance goals? What are they?
MR. JOHNSON: Maintain safety, public
confidence, effectiveness and efficiency --
MEMBER FORD: Oh, this is the NRC
performance goals? It's not the research performance
goals?
MR. ZIMMERMAN: Agency performance goals.
That applies to all 12 offices. Depending on what
office, you may find most of your work in one area
like another area. For program offices it tends to be
split pretty well across the four performance goals.
MEMBER FORD: But there's not a separate
subset of goals which are quite specific to research?
MR. ZIMMERMAN: No. There's vision that
talks about the independence and maintaining core
competencies and --
MEMBER FORD: Yeah, but those aren't,
that's not a specific goal, is it? It's a broad goal,
but if you asked an individual researcher to measure
his performance against that, could he do it?
MR. ZIMMERMAN: Well, what we're trying to
do is get our staff to be able to explain their work
with regard to the four performance goals.
MEMBER FORD: Okay.
MR. ZIMMERMAN: And it would, and we're
all learning, all the offices are learning. It's not
like one office has found the answer, we're all
getting a little better at it. But the answer isn't
just say that, well, the work I did helped maintained
safety or it improved public confidence. You take it,
it's harder to do that. What was it that maintained
safety? What was it that improved public confidence?
And to the extent that you can do it in a
numerical way that is irrefutable, that's what you're
trying to do.
MEMBER FORD: You're going back to metrics
again, aren't you?
MEMBER WALLIS: You are.
MEMBER FORD: It seems to me though that
the decisions are different. I mean as an agency,
when we make decisions that affect the licensees, then
these four goals are of course very important. You
want to maintain safety, you want the public to
understand your decisions, the licensees to understand
your decisions and so on.
CHAIRMAN APOSTOLAKIS: When you make
decisions regarding, you know, research projects, then
that's a different decision now.
I don't see how maintaining safety is
important to this. So you probably need another set
of goals that will of course be consistent with the
agency-wide goals, but for example you might want to
say provide better information for, or not better,
vital information for better decision making.
Then the question comes up, what's better
decision making? Well, maybe reducing the
uncertainties or building a model where none exists.
Then you become a little more specific regarding what
the office is doing.
MEMBER FORD: One of the things that
puzzles me --
CHAIRMAN APOSTOLAKIS: Maintaining safety
is irrelevant.
MEMBER FORD: On this very issue, one of
the things that puzzled me, looking at this team
generated action plan, for instance. To me, I could
see some very clear technical objectives. Though, at
the end of the day it wasn't at all clear to me how
those results were going to be transitioned to the
staff. And when you talk to the staff, what are you
expecting from research, there is a kind of pained
silence. So there's a --
MR. ZIMMERMAN: I think that's the process
that we need to get to so you see --
MEMBER FORD: But that's the one vital
link that you're missing.
MR. ZIMMERMAN: Right.
MEMBER FORD: Because then your value is
clearly seen by the staff.
MR. ZIMMERMAN: Right. I got a little
lost when you were talking about how it doesn't apply
to maintain safety. What I think I got from what you
said, because this is a challenging topic.
CHAIRMAN APOSTOLAKIS: It certainly is.
MR. ZIMMERMAN: This is not easy. Under
the, under the different four goals there are
strategies of how you get to there. What do you do?
And risk informing is an example of how you, a
strategy to work to maintain safety.
CHAIRMAN APOSTOLAKIS: Right.
MR. ZIMMERMAN: Also it helps with
decision making. What you're describing in terms of
formal decision making fits in under effectiveness and
efficiency to be able to feed out to help make those
decisions. If you make inefficient decisions --
CHAIRMAN APOSTOLAKIS: You are absolutely
right. But I mean one of the first things you learn
there, if you follow that route, is that different
decision problems require different methods, different
objective have different objectives and so on. So
when we talk about the top goals of the agency, of
course you want to maintain safety. I'm not saying
you don't.
But I don't see how a goal like that would
affect your decision on funding a particular research
activity. I mean, you know, everything we do is
relevant to safety.
MEMBER WALLIS: It's very important that
everybody else is pursuing these goals, you've got to
fit in with it. You've got to --
CHAIRMAN APOSTOLAKIS: You're fitting into
it, but it's not, it's so high level as to be useless.
That's what I'm saying.
MR. ZIMMERMAN: I'm not sure if this is
helping or hurting. I'll give you sort of audience
example. The vessel-head cracking was not something
that was in the budget, it wasn't planned for that.
It came up, it's reactive work, something had to give.
If we're going to pick up the work that this office
did, something had to be shed.
It didn't take very much, going through an
add-shed, to say that that activity directly relates
to safety. That was one of the higher priority work
items that we did in support of NRR to take a look at
the work that was being done to support the issue
that's in the bulletin. So, if we communicate amongst
ourselves we clearly brought out the maintain safety
aspect of the work that Mike and others did in that
area.
And that was a basis for people getting
pulled off of other things to go to work on that.
MEMBER FORD: That's a beautiful example.
That's a beautiful example, and it's a pleasure to see
that interaction between Jack Strosswriter(phonetic)
and you guys. And it's very positive. Now why aren't
there ten or 20, I mean you're giving one, but can you
cite ten, 20 such examples this year? I mean that's
the sort of volume for that budget you've got.
And that's the sort of volume that you're
really looking for.
MR. ZIMMERMAN: We're going, we're going
around to that, I think, to that first chart of recent
accomplishments. You know, the recent
accomplishments, another one that is significant had
to do with the high burn up with regard to cask
loadings. And moving away from the overly
conservative assumptions associated with clean fuel
and spent fuel. And when that work was done, that
provided the basis to take casks off the streets, off
the highways that have the potential for providing
exposure to individual that are in proximity to
highway accidents, there are fewer casks.
There's fewer chances of a problem. And
there's quantifiable savings for the industry, for the
taxpayer, as a result of that activity. That work came
out of this office. And it's probably over a billion
dollars of savings as a result of that work. So when
you reinvigorate, when, when, if what I say is true
and the facts support it to an objective audience,
then that should put spring in the step or invigorate
if our own staff should feel proud that they did that.
And we ought to be proud in sharing it
internally and externally.
CHAIRMAN APOSTOLAKIS: In this case, Roy,
wouldn't you say that you met a goal of reducing the
risk for the health and safety of the public? That's
what you just said.
MR. ZIMMERMAN: On that particular area?
CHAIRMAN APOSTOLAKIS: Yeah, on that
particular area.
MR. ZIMMERMAN: We reduced exposure to
workers, individuals by that.
CHAIRMAN APOSTOLAKIS: Okay.
MR. ZIMMERMAN: Did it maintain safety?
The work that we did that did the review verified that
there was still sufficient margin. We maintained
safety by ensuring that. It had a bigger vector on
reducing the necessary regulatory burden. Now am I
going to hire enrichments to be loaded, it allotted
more fuel per cask, it allotted variations and
flexibility and cask design. And again, and it got
casks off the road.
So when you look at how it feeds the four
performance goals, the vector on maintaining safety in
my mind is smaller than the vector on reducing
unnecessary regulatory burden. I improved realism.
I'm not sure if this is helping or hurting.
CHAIRMAN APOSTOLAKIS: No, I think it's
helping. It is very helpful, yeah.
VICE CHAIRMAN BONACA: I would like to
just, again, sorry about that if I'm focused on the
research report. But I took the task of putting it
together.
(Laughter.)
VICE CHAIRMAN BONACA: You know we
received here a recommendation counter to what we
discussed with Mr. Vidani(phonetic) a couple of months
ago, that the report would be focused on advanced
reactor reviews or new challenges and materials and
anticipatory research. And we haven't, we need to
touch on any one of these subjects.
CHAIRMAN APOSTOLAKIS: Where is this from?
VICE CHAIRMAN BONACA: It is the last page
of the presentation. So I would like to just make
sure that before the next 50 minutes are over that we
--
MR. JOHNSON: Okay, we'll take just a few
minutes to get through the remaining charts here.
Let's flip to the next one. It just says that we want
to enhance our environment for innovation. And I
think in order to do that we've got to be concerned
about the scope of our work. And we ought to, we want
to emphasize anticipatory work and we want
intellectual and technical leaders.
We need strategies for, to make sure that
those kind of things are in place. The
infrastructure, you've heard a great deal about that
in the past. Chairman Meserve, at his keynote address
at the NSRC, spent a great deal talking about the
infrastructure and its importance. The next viewgraph
--
MR. ROSEN: You skipped over innovation
very carefully, very quickly, and that's a whole
week's worth of discussion, of course.
MR. JOHNSON: Right.
MR. ROSEN: And clearly some of the things
you talked about earlier, Roy, which is the building
of trust allows people to fail. It gives them a
chance to innovate, but not all innovations are
successful. If you require 100 percent success, then
you're not going to get much innovation.
CHAIRMAN APOSTOLAKIS: Can you really do
that when your budget keeps going down?
MR. ROSEN: Well, I think you can but I --
CHAIRMAN APOSTOLAKIS: Can you afford to
have people try crazy ideas and fail?
MR. ROSEN: Well, crazy --
CHAIRMAN APOSTOLAKIS: You can't.
MR. ROSEN: -- crazy are not so good, but
I think reasoned risk in an environment where the
management is will to accept the outcome along with
the proponent, you know, this is a good, an idea that
may or may not work. But if it doesn't we haven't
lost a whole lot, and if it does there's a tremendous
upside. And management buys in on the front end in a
trusting environment with that, you may get some
innovation.
But if you're requiring, you know, if this
doesn't work we know who to hang kind of approach,
well then for sure everybody pulls back into their
shell and you won't get any innovation.
MEMBER FORD: Could I ask a question?
This is so fascinating, I'm sorry to be interrupting.
I'm sorry. Have you thought about talking to people
who's business it is to maintain and create an
innovative R and D environment? Dana pointed out
that, you know, he knows that some have failed.
Others have won.
MR. JOHNSON: Right.
MEMBER FORD: And why not go to them? I
can think of one organization you go to, hence my old
one, but they know how to do it. So why don't we go
and ask them how to do it?
MR. JOHNSON: Well, we --
CHAIRMAN APOSTOLAKIS: See, that's related
to a comment that I wanted to make. I think this
discussion is taking off on a scungent that is
unrealistic. We're going to start again talking about
very high level desiderata or we need intellectual
leaders. The question is if you put intellectual
leaders up there, immediately you should ask, can that
be accomplished within the environment this agency is
working? And I think not. I really think you can't
have innovation and you can't have -- well, no.
Intellectual technical, you have your technical
leaders here, but you can't grow them.
MR. ROSEN: Why is that not a problem,
George? Why are you willing to accept that?
CHAIRMAN APOSTOLAKIS: They have so much
work to do that is, needs to be done. They don't have
all the resources. They keep telling us they
prioritize, and at the same time we talk about
innovation and the right to fail? How do we do that?
MEMBER FORD: Do you think that is
unusual? You think that this situation is unusual?
MEMBER WALLIS: George, you have so much
that you have to do and you can still be an
intellectual leader, I hope.
(Laughter.)
MEMBER POWERS: No, he believes in
decision theory. There is no hope for him.
(Laughter.)
CHAIRMAN APOSTOLAKIS: They asked Dr.
Watson, Nobel Prize winner in DNA, how does one do
good work? And he said one does good work when one is
underemployed and has time to try crazy ideas and fail
and start again. Then the Reporter came back and
said, but now you are directing this laboratory in New
Jersey, I think. He said, yeah. I'm not doing any
good work anymore.
(Laughter.)
CHAIRMAN APOSTOLAKIS: And I think there
is a hell of a lot of truth in that. I, what I'm
saying is we've been doing this now for four years.
The research report and in other forums and so on.
We're talking about innovation. It's like this fun
thing that major corporations advertise that they want
people with initiative and then they kill them away if
they have any.
Can we really achieve these things within
the realities of the agency. I mean we can all talk
about intellectual leadership and innovation, and I
really don't think we can have much innovation now.
You guys don't give any plans anymore, do you? You
guys are not all, what was the mechanism, what is the
mechanism for getting a good idea that is innovative
with a high probability of failure? What is the
mechanism that will come to Scott and Scott will
evaluate it and say, let's fund it. Right now, what
is that mechanism?
MR. JOHNSON: Well, we've asked all of our
National Labs. We'll ask this committee.
CHAIRMAN APOSTOLAKIS: To do what?
MR. JOHNSON: We'll ask our staff for
ideas for --
CHAIRMAN APOSTOLAKIS: For innovative
ideas?
MEMBER POWERS: I think this is an easy
answer to him.
MR. JOHNSON: Yes.
MEMBER POWERS: There is innovation in
this agency and the research program and I can think
of three areas that come immediately to mind. I think
of, to work Joey Muscara proposed as part of the steam
generator program to look at stress corrosion cracking
mechanisms. I can think of the stuff that they're
doing in developing fire risk assessment, where
they're literally developing the technologies for
doing fire risk assessments.
CHAIRMAN APOSTOLAKIS: I don't think
that's innovative.
MEMBER POWERS: I think the stuff that
they're doing on, with CFD that we just mentioned
before is an innovation. Perhaps not an innovation in
Graham's world, but in the regulatory world that's a
big innovation.
CHAIRMAN APOSTOLAKIS: Why is it
innovative, Nathan? I mean Dana. We know we need a
methodology to assess risk and they're doing it. Why
is that innovative.
MEMBER POWERS: Mr. Apostolakis, I assert
my right to have the floor here.
CHAIRMAN APOSTOLAKIS: You do have the
floor.
MEMBER POWERS: The, we know that
innovation is a local phenomena, it's not a global
phenomena. And just because they don't win Nobel
Prizes here, in fact I think if somebody won the Nobel
Prize they would probably congratulate him and then
fire him. Because he was obviously not working on the
main mission.
(Laughter.)
CHAIRMAN APOSTOLAKIS: I hope --
MEMBER POWERS: But they are doing
innovation and I think there's no question about it.
MEMBER WALLIS: I think you have
innovation on all kinds of levels.
MEMBER POWERS: Sure.
MEMBER WALLIS: When reviewing, say, a
thermal hydraulic code, it's being done a certain way
by a licensee or a vendor and they've put together
this thing. And you look at it and say, gee whiz, I'm
not sure I believe that. I can think of a different
way to balance momentum and I can compare my result
with theirs. That is innovative. They are doing
something which is new and you're bringing this
insight to bear on something, rather than just
accepting somebody else's deal.
CHAIRMAN APOSTOLAKIS: I think you should
put in your previous slide under external
communication, ACRS. We have a big problem with
communication.
(Laughter.)
MR. ROSEN: I think the problem seems
rather limited to you, George.
(Laughter.)
CHAIRMAN APOSTOLAKIS: No, when somebody
tells me I need to do this, and then I'm thinking
about it how to do it in a good way, for me that's not
innovation. I'm just doing a good job and what I was
asked to do. That's not innovation.
MR. ROSEN: Well, a lot of it --
CHAIRMAN APOSTOLAKIS: Well, but anyway I
don't know, That doesn't help Dr. Bonaca, so let's not
spend that much time on this.
VICE CHAIRMAN BONACA: Also, you members
who will contribute in a prolific way to this --
MR. JOHNSON: Let's move to the --
CHAIRMAN APOSTOLAKIS: I'm criticizing the
system, by the way, not the people. I said, what are
the conditions?
MR. JOHNSON: Okay, if we move to the next
slide, where again we're still on refocus and re-
evaluation process. We believe that it is important
to emphasize in-house work and we've put on the table
the possibility of re-baselining NUREG-1150 that does
not necessarily mean that we would do five plants.
But it would be a mechanism to involve a
lot of our staff as opposed to contracting the bulk of
the work out. We also need to increase cooperative
work, as we've mentioned, mentioned that earlier.
MEMBER POWERS: When you speak of
cooperative work, I see the words and what immediately
springs to mind is what I thought was an outstanding
job that you've done in organizing this PTS activity
where you brought three of the branches together with
as diverse a technical focus of any three that I think
you could have brought together.
Thermal hydraulics, the blacksmiths, and
the risk guessers, and brought them together to work
on a focus task. And that is one of the areas that I
would call creative management in, and I think that's
one that you ought to be really proud of.
MR. ZIMMERMAN: We appreciated the write
up and the report about that too.
MEMBER POWERS: Yeah, it's, I mean that
really was, I think that's the wave of the future in
research. Is getting these multiple disciplinary
activities to work on a focused attack on a problem
that you can resolve when you bring those three
disciplines, well, two disciplines and the blacksmiths
together.
(Laughter.)
CHAIRMAN APOSTOLAKIS: What do you mean by
re-baseline NUREG-1150, Jim?
MR. JOHNSON: Updating it with the most
recent information. We've spent millions of dollars
on severe accident research and it's not reflected in
NUREG-1150.
CHAIRMAN APOSTOLAKIS: And how would that
help the agency in its mission?
MR. JOHNSON: Well, it would update the
base of information that is currently being used.
NUREG-1150 is referenced in so many different places
in various regulatory applications. So it would
provide more up-to-date data. And in addition to
that, it would involve a large number of our research
staff who may not have had hands-on experience in
doing PRA-type analysis.
MR. ZIMMERMAN: No decision has been made
on this. It's, again, from a creativity standpoint,
it's an item that was brought up that looks like it
has merit for consideration. And that's why it's on
the slide.
CHAIRMAN APOSTOLAKIS: I'm just wondering,
I mean we have now the IPs and the IPEEEs. Is stream
relying on NUREG-1150 as much as in the old days? Or
is there something innovative that we can do with the
IPs and the IPEEEs. And maybe with NUREG-1150 and come
up with something else. I don't know.
MEMBER KRESS: My view that George is, in
NUREG-1150 is the one place where they did a
comprehensive uncertainty analysis. It includes both
epistemic and, you know, aleatoric. When you go now
and do a PRA and factor uncertainty into that, you
don't get the full thing that you got out of NUREG-
1150.
And it gives you a meter from which to
gauge the uncertainty that you calculate from the PRA
and I think it will be valuable in your risk informed
thinking when you incorporate uncertainties into that.
Because you need this to, as a meter to gauge what the
full uncertainty might be, given what you calculated
by the PRA. Because they're not the same thing.
And I think that's the place where it
might be very easy.
MEMBER POWERS: I think they have just
about mined the IPEs for what they're worth. Because
remember the IPEs have a specific, very specific sort
of objectives that really are quite different than the
role that risk is being played in now. And you can't
interrogate that the way you can 1150. I mean I think
the insides document, which is one, by the way, one of
my favorite documents. The IP insides document I
think is, was a real tour de force there, but it's
utility relies in believing in the ensemble
approximation for reactor uncertainties.
That is I can look at a whole collection
of plants and from that understanding something about
the uncertainties. And that's just never been
demonstrated.
MR. JOHNSON: Now see these last three
slides is just a continuation of this same theme.
We've already talking about the mission and vision
statement. There are two things that concern us with,
with the current statement. That
s the use of the word independence, and the vision
statement is rather long. The next viewgraph talks
about staff morale and identifies some potential
things that can be done to improve staff morale.
The last slide addresses RES performance,
and talks about things like accountability and
timeliness and making sure that you have quality
products. And this is not intended to be a
comprehensive list of all the things that we need to
do to reinvigorate, but this is just a starting point
for us to consider and to kick around a little bit.
Thank you, that's all I have.
CHAIRMAN APOSTOLAKIS: I think this white
paper will be very useful, especially you're doing
every little thing you mentioned, or big thing, you do
what you have on Page 7. You give a specific way or
example of how to achieve that. So you enhance Branch
Chiefs involvement in management issues. For example,
the budget. Now that tells me about your way of doing
it. The regional wire was a little cold earlier about
other stuff like enhanceability for information. I
don't know what that means.
If you give me examples of how to do it,
then more power to you.
MR. JOHNSON: Yeah, we wouldn't put
examples in the paper unless there is a mechanism or
a strategy for doing it.
CHAIRMAN APOSTOLAKIS: Okay, that would be
great.
MR. JOHNSON: We can't ultimately do that
if it's actually, it's going to succeed. You've got
to bring it to light, and the only way you're going to
do that was to put examples.
MR. ZIMMERMAN: Okay, I think we're set to
move on to the advanced reactor part of the
discussion. I apologize that I need to leave. I very
much enjoyed the discussion, thank you very much.
CHAIRMAN APOSTOLAKIS: Is Mike going to
speak after you?
MR. MAYFIELD: I think what I've got to
say can be done in about 30 seconds, so maybe as we
come back I can go through this.
CHAIRMAN APOSTOLAKIS: Okay.
MR. KING: How much time did you want to
take?
CHAIRMAN APOSTOLAKIS: Well, we have
another meeting, right? We have other, do you want to
take a few hours, around 4:15?
MR. KING: Yeah, where are we on this
agenda?
CHAIRMAN APOSTOLAKIS: 4:15. We have to be
done by 4:15.
MR. KING: Okay, what I'm going to do is
provide an overview of everything that's going on in
research and advance reactors. And I've got to point
out at the beginning that this is work in progress.
Some of it is yet to be determined because some of it
hasn't really shown up at our doorstep yet. We're
projecting it will. A lot of it is still subject to
budget discussions that are underway right now, both
priorities and the funding levels.
And we can talk a little bit about that.
We really expected, expect the details, I think, of
the kinds of things you wanted to deal with in your
report. Technical issues on the pebble bed, new
licensing frame work, you know, in concept what could
that look like and so forth.
Research plan for HTGR research. All of
that stuff, in terms of having detailed discussions
with you, is we won't be ready probably until early
next year. And we'll talk about the schedules. So if
you're looking today for some meat to dig into and
some positions to wrestle with, they're not ready yet.
VICE CHAIRMAN BONACA: As I mentioned
yesterday, it's difficult for us to write a report on
your research program when the program still is not
defined. I mean when we discussed this with Schrock
at the time he envisioned that we would have that
progress made now. That you would have already some
definition for example of surrogate, safety goals that
can be used for plants other than, you know, water
reactors. And evidently we have no data, so anyway
let's see what you have and then we'll make a
decision.
See, that's why you have to make a
decision on what is important enough to contain they
year, given the constraints and the fact that we have
a deadline of March 29th, I believe, for the report.
MR. KING: Okay, I'm not sure what Schrock
had in mind when he talked to you earlier, but all our
schedules have always been to really start detailed
technical discussions with you probably in January.
Both on pebblebed, on research plan for HTGRs and
other things that might follow that. So let me just
quickly, you know, the RES role and responsibility in
the advance reactor I think is pretty simple.
I think research really is charged with
preparing the agencies and the technical
infrastructure to deal with these future activities
coming down the road in the case of advanced reactors
to facilitate licensing reviews of future plants. How
we do that is one, we've got the lead for
preapplication reviews of non-LWRs and innovative LWR
designs, like the IRIS design that's coming down the
road.
We've got the lead to develop or adapt
analytical tools that we think we might need if we
want to do some independent safety assessment on these
future designs. And to develop the technical basis
for whatever guidance or confirmatory data we think we
might want to have available just to either check what
applicants are telling us or to bring ourselves up to
speed so the staff can do a better review and deal
with some of these issues ourselves. We can ask
better questions, we can be more knowledgeable.
What are we involved in? Today we're
involved in two things that are ongoing. The
pebblebed preapplication review, which started back at
the end of April. We've been having monthly meetings
with Exelon. And we're in support of NRR on the AP-
1000 preapplication review.
We're looking at the scaling issues
associated with scaling up from 600 to 1,000 megawatts
electric. What we expect shortly is another request
for preapplication review on another HTGR, the general
atomic design called the gas turbine modular helium
reactor.
We have a kick off meeting scheduled for
December 3rd, where they're going to come in and tell
us what it is they want and when they want it. We
have, expect a similar request to get started on the
IRIS preapplication review, that's an innovative LWR.
Our understanding is the initial focus of that will be
with what thermal hydraulic testing program is needed
to actually confirm the design.
We expect to begin shortly, as soon as the
budget stuff is settled, initiate development of some
thermal hydraulic and severe accident code
capabilities to deal with HTGRs, to deal with AP-1000
and IRIS. And we'll talk a little bit more about that
later.
We're looking at what confirmatory or
exploratory research, experimental-type programs we
want to, we want to conduct. Whether it's on high-
temperature materials, graphite or some, you know, AP-
1000 thermal hydraulic confirmatory tests. A full
range of things that we think would be useful to do,
the problem is do we have the resources to do it?
And we're also thinking about the
technical basis for future plant licensing framework.
And we'll talk about that some more. Those are what
I call near future, and a lot of that would get
underway this fiscal year. Maybe some of it would be
next fiscal year, but a lot of it this fiscal year.
Longer term, maybe several years down the road,
there's DOE's Generation IV program. Going on right
now we're pretty much just observers in that, but
there are, at some point down the road, they would
start some interactions with us on licensing issues.
DOE had a program on, it used to be called
accelerated transmutation of waste. I think the
accelerator part has sort of gone down the drain, but
they still have a transmutational waste program. And
it's my understanding they're thinking now of liquid
metal reactors. They're program planning calls for
coming into NRC on licensing issues with those in the
next few years.
And there may be other things. Who knows
what else will come down the road. So there's a whole
laundry list of stuff that --
VICE CHAIRMAN BONACA: I have a question
on that. And the question is you said essentially
they are waiting until these concepts may be more
advanced and there is some kind of licensing
interaction taking place for you to start involvement.
MR. KING: You're talking about Generation
IV now?
VICE CHAIRMAN BONACA: Yeah.
MR. KING: Yeah.
VICE CHAIRMAN BONACA: And you know one of
the, I think one of the main impediments to your
ability to develop a new, let me call it a new
regulatory framework for, say the pebblebed reactor,
is that the pebblebed is referred to us, there's no
time to develop a new frame work.
MR. KING: Right.
VICE CHAIRMAN BONACA: Okay, if you wait
for Generation IV reactors until they have a concept
on the table, you are never going to be able to have
a new regulatory framework from scratch. So wouldn't
it be important, if you really wanted to develop that,
to start now?
MR. KING: Yes, I agree with you. And
don't misread my comments. I wasn't suggesting we wait
for Generation IV. I'm just suggesting --
VICE CHAIRMAN BONACA: No, but you mention
that, you know, this is, they'll come maybe in three
or four years and then we'll be talking about a new
licensing environment, but that will be too late.
MR. KING: I agree. The ideal thing is to
get started now so that when these designs are ready
to come in, the new framework is in place. I agree
with you.
VICE CHAIRMAN BONACA: Otherwise they'll
go to propose it to you, what they want to do, and it
maybe acceptable, like you know in case of the
pebblebed they may have a viable approach. There are
some good ideas there, but still there is nothing new
about the process.
MR. KING: Yeah. I mean pebblebed doesn't
want to wait for a new framework, so they developed a
process that shoehorns their design into the current
set of regulations. You're going to hear about that
tomorrow.
MR. ROSEN: I'm chairing a Generation IV
subcommittee on liquid metal reactors and John Flack
is here, he's your liaison with the Generation IV
effort. And I think what the staff will have in front
of themselves, in front of yourselves very soon, like
in the first quarter of next year, a pretty good look
at where Generation IV is likely to go.
And the issue is the one Mario talks
about. And it's really there. It's a kind of a
chicken and the egg situation, where you don't, you
need to kick off with some work with the Generation IV
people. And the right, the question is the timing.
When are you really going to do it? When are you
really going to bring them in?
And then ask them for their views and
bring some focus to this in terms of what NRC does.
MR. KING: We have some work underway
through a NERI, well DOE NERI program that involves
MIT and Sandy and some others looking at a, you know,
a risk based, a risk informed approach. And the staff
has interest in that. And what we've committed to do
right now is provide a paper to the Commission in June
of '02, with our recommendation on whether or not to
proceed and develop such a frame work.
Our view is in that paper we would have
done enough thinking to sort of layout the concept so
the Commission has an idea of what they are being
asked to approve. So that's our, that's our schedule
for this year. Now we expect the NEI is preparing a
white paper on their views on this whole thing. They
now say it's February before we're going to get that.
The NERI program, I'm not sure exactly
what the schedule is for that or the end product. And
the staff, again there is a budget issue. How much
resources are we going to get to work on that this
year, which hasn't been settled.
MR. ROSEN: I've been very concerned in
that role, in my role in Gen IV, that the DOE would
not coordinate well enough with the staff and there
would come a time when it was too late to move and
the, and NRR would say before we move an inch on this,
we need x, y and z, and there wouldn't be any time
anymore. That's the problem that Mario has pointed
out. And I think we need to head that off, and the
people to head it off are you by saying, by taking a
proactive stance with DOE on Gen IV.
MR. KING: I agree with you. I think --
MR. ROSEN: So you need, if you want to
talk about graphite, for example graphite moderated
reactors, there's some materials research you need,
you need to be funding on graphite right now, for
example.
MR. KING: Well, I think just to be able
to review an HTGR, there's probably a number of things
we ought to be thinking about doing right now. And on
top of that, to have a new licensing framework which
in our view ought to technology neutral. You ought to
start with some high level criteria and work down into
some principles and some guidelines or what, you know,
goals, whatever we want to call it.
To some degree, when you get down to some
level it's all technology neutral. And then clearly
when a design comes in, say, that's an HTGR, you have
to look at specific HTGR issues. But there ought to
be a way to set that up so that you don't have to go
through everything in the regulations today and say
does it apply, not apply, and explain why. Yeah,
John?
MR. FLACK: Yeah, John Flack with
Research. In fact, I was just off the phone with Rob
Faslouce(phonetic) about an hour and a half ago
talking about the working groups and the possibility
of us getting engaged at the working group level to
already to start to understand what the regulatory
issues might be. So I think this is going to start to
happen, it's just, we're just at the very beginning
stages of it.
But I agree. I think there's more that we
can do with the ongoing effort of Gen IV. In fact,
this is what the GOE, the Gen IV work, right.
VICE CHAIRMAN BONACA: But it seems to me
that, I mean if you at some point, there is a pressing
need to integrate the deterministic process and the
risk informed process. You know, right now we're
still struggling and even option three will never take
us there. I mean there is some initiative to, but you
would want to have a new licensing process that
incorporates risk information as an integral part of
the approach.
And right now, I mean we're still
struggling and the Exelon approach really is not doing
that yet.
MR. NEWBERRY: I think, just let me
underline our emphatic agreement with this point. And
also noting that we are already experiencing
significant budget pressures here between, and this
was a discussion an hour ago, between supporting --
VICE CHAIRMAN BONACA: Yeah.
MR. NEWBERRY: -- decision making and
actual views versus trying to get out ahead on the
framework issue.
CHAIRMAN APOSTOLAKIS: That would qualify
as an innovative case work.
MR. ROSEN: So now the budget issue is
right there with the DOE program, it's a wonderful
situation because there you can say to DOE, now it's
time for some DOE money to come in flowing. It
shouldn't be just agency money. It's a DOE program
which intends to support a new generation of reactors
for deployment by 2030, okay. It's 2002, it's time to
start spending a little money.
VICE CHAIRMAN BONACA: And I don't think,
you're absolutely right. And I don't think that the
development of the concept is going to be resource
intensive for prospective of a lot of money for labs
and so on. There's going to be more trying to tap the
industry and tap everybody else and come up with a
concept that the industry can be committed to that
integrates in fact this perspective that I know we
just can't put together.
I mean the deterministic approach and the
risk informed one. So, but until you have some
progress made there, we'll be always prevented by
some, somebody putting a new proposal in for to do it.
But you know what, I mean let's be realistic.
Intellectually, yes, this is a very
challenging and interesting thing to do. But from a
practical point of view, I think it scares people. I
mean especially potential licensees, you know. But to
go with a new regulatory system now, what are we
doing? I mean we're going to have all sorts of issues
come up. At least the one we have now has been tried.
And if we can change it a little bit, so I am very
sympathetic with their, with their views.
So I have a question about doing, I mean
beginning a discussion on how to do it, how much we
should, that's exactly what should be done, I think,
in the development of framework. They might be
radically different if --
CHAIRMAN APOSTOLAKIS: Look, am I going to
disagree with you? No. I'm just telling you that I
feel that, you know, when these people come and they
want to use as much of the existing system as
possible, even though I get upset perhaps that I don't
see much innovation, well, I understand though that
their problem is really to get a license.
MR. KING: Well, if we go forward with
this new framework, I think you're right. That's
clearly an innovative approach. That's a clean sheet
of paper approach. What?
CHAIRMAN APOSTOLAKIS: Therefore, it will
not be funded. Remember my words.
(Laughter.)
CHAIRMAN APOSTOLAKIS: The system will not
be funded. Go ahead. Have you heard of Cassandra?
VICE CHAIRMAN BONACA: Good, that's
exactly what I was thinking about, Cassandra. Who is
she?
CHAIRMAN APOSTOLAKIS: The mother of
Hector.
MR. KING: In a broad sense, the types of
issues --
CHAIRMAN APOSTOLAKIS: Yes, she was a
broad.
MR. KING: -- to deal with in our work and
research are the things that come out of
preapplication reviews, which are technical issues on
designs, as well as some policy issues. And as I
said, I think the bulk of the effort is going to be
developed, or work put toward infrastructure
development. It includes the framework.
Part of that is also looking at what
skills and capabilities do we need? And along with
that comes the resource issue, and that's what's still
being worked on right now. Okay, technical issues.
As I said, we started with PBMR back in late April.
We have gotten to the point where they
have a number of technical issues. This is not a
complete list, I just tried to list some of the bigger
ones here. The review is still in progress, in fact
I got a conference call with Exelon this afternoon to
talk about when they're going to give us some
information that we need to do our job.
But I think clearly the big issues that we
see are fuel performance and qualification. That
involves a whole host of things. You know, what needs
to be done in terms to demonstrate the fuel, how much
do you want to test, under what conditions, is
accelerated testing okay or not okay. There's a whole
host of questions.
CHAIRMAN APOSTOLAKIS: So, let's come back
again to Dr. Bonaca's program. In terms of the
research plan, you at some point plan to prioritize
these or do work on all of these or what? I mean this
is not a meeting on the --
MR. KING: This is, we're talking about
the PBMR preapplication review. We --
CHAIRMAN APOSTOLAKIS: These have to,
okay.
MR. KING: -- we intend in the
preapplication review to try and provide some feedback
to Exelon on these issues in terms of, let's just take
fuel for example. They are going to come in and
propose a fuel test program to demonstrate their fuel
performs as advertised. We would like to give them
some feedback and say, yes, that's okay, no it's not
okay, you don't include this or that.
Right now we're wrestling with are you
going to give us enough information so we can even
make a call like that or give some preliminary
feedback. And as you march through these issues, on
the pebblebed we intend to try and give as much
feedback as we can at the preapplication stage, so
when they prepare an application it's something, you
know they know what to put in it and we know what to
expect. Now, the flip side of this is it, what do we
need to develop so when an application does come in,
we can actually review it and have some confidence in
the decisions we make.
And that's where it gets to, do we want to
develop a helium version of TRAC, a helium version of
Melcor? Do we want to do some independent testing of
graphite, high temperature materials, fuels? Same
thing on AP-1000. Do we want to do some independent
thermal hydraulic testing with this scaled up design.
So those are the questions we're wrestling
with right now. The details, trying to give Exelon
feedback on some of these issues and the things
they're telling us, that part is funded, that part is
underway. We intended to start meeting with the
committee probably around February, on the pebblebed
issues, and go through them in detail in terms of
here's the issue as we see it.
Here's our position. Here's the feedback
we think you ought to give Exelon and get the
committee to weigh in on that, so when we prepare a
paper, which right now is scheduled for June, to go to
the Commission to identify what our positions are,
that we've got the committee's feedback on that.
So that's our plan on the pebblebed. AP-
1000, NRR has the lead on that. I don't know exactly
what their scheduled is for interacting with the
committee, but our piece is to look at the passive
ECCS performance on this scaled up design.
MEMBER POWERS: It's interesting when the
subject of AP-1000 comes up, nearly everyone comments
on the heightened containment.
MR. ROSEN: Could you talk a little
louder, Dana.
MEMBER POWERS: The heightened
containment, otherwise known as level arm with a tank
of water on the top. Is no containment part of this
for research here?
MR. KING: The whole issue of containment
and severe accident behavior in the scaled up design
right now is part of what's called the Phase 3 review.
We're in Phase 2, which is looking at the thermal
hydraulic testing needs. Exactly what role research
is going to play in that is, again, it needs to be
worked out.
It's not that it's not going to be looked
at, it just hasn't been looked at yet. Okay,
potential policy issues. Just quickly on the
pebblebed. Again, this is not an exhaustive list, but
some of the bigger ones, you know, certainly
containment versus confinement, their desire to have
a much reduced emergency planning zone. The issue
you're going to hear about tomorrow on the licensing
approach using frequency criteria and sort of a, their
version of a farmer curve to define safety
classification of equipment and the acceptance
criteria for the various design basis accidents,
leading ultimately, the Commission probably needs to
weigh in on that.
You'll hear our preliminary views on that
tomorrow. The whole role of the regulator in fuel
fabrication now on an HTGR, where some people say,
well, the guy at the controls of the fuel fabrication
plan has more to do with safety than the guy at the
controls of the reactor itself. How do we, I mean how
do we regulate that?
Are we going to regulate the process now?
Are we going to sample the product? Overseas
fabrication, there's a whole bunch of things that are
wrapped up in that. Again, these are things --
CHAIRMAN APOSTOLAKIS: Much like the
software liability issue, huh?
MEMBER KRESS: It's a lot like that.
CHAIRMAN APOSTOLAKIS: It's the same
thing, process versus product. That's a problem we
had four years ago here.
MR. KING: And then the bottom issue is
the general one, the frame work issue, which we tend
now to go to the Commission in June and get a policy
reading on do we proceed with that or not. Wrapped up
in the infrastructure question is, and we're looking
at the resources that are available and where do we
put them, is sort of the broader issues of how much
independent capability should we have?
I mean you look at Lightwater reactors and
where we stand today. And millions of dollars on
fuels research, severe accident research, thermal
hydraulic research. All of that is PRAs information.
All of that provides a foundation on which we make
decisions today. We don't have much of that for gas
reactors or liquid metal reactors.
How much do we want to develop? How much
do we need? And that sort of is going to feed into
then how much money and what activities should
research be doing to develop infrastructure. The
issue of cooperative research. We had our workshop on
HTGR safety and research issues. We're trying to
follow up on that and see where it might make sense to
plug into some of these international HTGR research
programs.
Does it make sense to plug into with
licensees maybe and share costs of doing some of this.
If we can agree on the information that's needed, why
not share costs to get it. There's issues like that.
MR. ROSEN: Tom, one of the things that
Generation IV long ago concluded is that the U.S.
government can't afford to do this alone.
MR. KING: Yeah.
MR. ROSEN: So Generation IV is an
international effort. So I mean I think it would be
surprising for me to hear ultimately that this country
decided to make four Generation IV reactors. The
regulation of them is a domestic issue. I'm not sure
that would be a viable result. What I'm saying is I
think if you're going to design and fund and test and
build these things internationally, you also have to
regulate them in some sort, with some sort of heavy
international involvement.
MR. KING: That's clearly another policy
issue.
MR. ROSEN: It's a difficult question
because in the way regulation is done in different
countries.
MR. KING: Yes, yes.
MR. ROSEN: But you can't even define a
research program unless you, unless you think about
the regulators around the world's attitudes towards
given designs.
MR. KING: I'm not sure, you can't design
a research program, I think clearly an international
research program is better than just a going it alone
program. But right, each country may have different
views on what's important and what the needs are and
how do you work that out so you can agree on
something?
MR. ROSEN: Well, you have to make sure
you don't, you put it together in a sense, in a way
that's, that doesn't leave a lot of big holes and
doesn't do to much duplication.
MR. KING: Right, right. Okay. I think
Slide 8, we talked about, the future plant licensing
framework. There is interest out there, and there's
also interest on the research staff to work on that.
Key considerations that we would want to do some
thinking on before we ever went to the Commission and
made a recommendation would be, and what's the scope
of what's going to be covered by this new framework.
Is it public protection, worker
protection, environment protection, property
protection? How would you structure this thing?
Starting with some top level goals on risk, on
safeguards, on maybe some other things. Maybe put
some principles in that apply to every, every future
design, defense and depth, ALARA, cost benefit,
performance monitoring, good engineering practices.
I don't know, you can come up with a list
of things that you might think would qualify as a
principle. And then to implement those principles,
what kind of criteria and requirements would you come
up with. You would certainly need some risks metrics
and criteria. Clearly the CDF and LERF maybe okay for
today's LWRs, but that's, LERF particularly was based
upon NUREG-1150, which is today's LWRs and I'm not
even sure apply to something like IRIS.
Do we want to develop some technology
neutral general design criteria? Do we want to
reference various, either international or national
codes and standards, I think apply to everybody. Are
there processes --
MEMBER WALLIS: I'm sitting here listening
and it seems to me that what you're laying out here is
almost as much work as designing the reactor itself.
Why is it such a huge task?
MR. KING: Why is this such a huge task?
MEMBER WALLIS: Yes, it seems to be a huge
task.
MR. KING: Because there's a lot of things
to think about. When you're going back and starting
with a clean sheet of paper --
MEMBER WALLIS: Well, suppose I just said
forget it, take the, get the regulations and --
MR. KING: Just take today's and --
MEMBER WALLIS: -- and see how far you can
go with that.
MR. KING: That's what's being done today.
CHAIRMAN APOSTOLAKIS: And when they say
that, we should be very understanding.
MR. KING: I personally, it can be done.
I think the amount of discussion and opinions that
we're going to have to deal with are going to be quite
large. But I think it's a certainly doable project.
VICE CHAIRMAN BONACA: I don't think it
would be, it would utilize a lot of elements of what
has been done before.
MR. KING: Yeah, I think there are more
general design criteria. A lot of them are technology
neutral and written pretty well. You pull them out
and you use them.
VICE CHAIRMAN BONACA: The ingredients are
the same pretty much. The question is how do you put
them together.
MR. KING: And I think if you can agree
upon the basic attributes that ought to be in here,
then you can frame, you know, what's the best way to
describe those to put some criteria or guidance in
dealing with those. There's another part that goes
with this, if you can lay all that out, you then have
to figure out what are the acceptable methods and data
that can be used to demonstrate compliance with these
things. So there's the flip side to that.
MR. ROSEN: There is one still in place in
the universe where things will still be the same. And
that's the Commission Safety Goal Policy Statement,
right?
VICE CHAIRMAN BONACA: No.
MR. ROSEN: A tenth of one percent.
VICE CHAIRMAN BONACA: That's LWL.
MR. ROSEN: Why wouldn't you say that no,
that the new technology we put in place should not be
any, should not harm, should not contribute risk
greater than a tenth of one percent.
MEMBER KRESS: One reason is your comment
that they are going to be, for a while they're not
asking just for this country, they're asking for
various places. There's no reason other countries
ought to have the same safety codes.
MR. ROSEN: You think that other countries
could have tighter goals or looser goals?
MEMBER KRESS: Yeah, it's a matter of risk
management.
CHAIRMAN APOSTOLAKIS: Or different
methods.
MR. ROSEN: Well, yeah, now I understand
your point and I think it's a good one. And I think
the question though is then can we all have the same
reactors. We went, in the Generation IV program, the
idea was to share the costs and build reactors that
are safe, proliferation resistant, etcetera, etcetera,
but they would be designed and it would be not just
one reactor. There would be several different kinds.
But the idea that they would have
different ultimate safety goals is one that hasn't
been raised before, I don't think. At least in polite
discussion.
CHAIRMAN APOSTOLAKIS: Well, we have come
up with a number of high level goals. But the other
thing is that we had a workshop at MIT about a year
ago. Not on that particular Generation IV design, but
somebody said, boy, we're going to have a thousand of
those.
MR. ROSEN: Right.
CHAIRMAN APOSTOLAKIS: A thousand? And
goals would be the same? How can that be? I think
when the Commission developed the goals they had in
mind, you know, more or less of what the situation was
at the time, with 105, 109 units. Here is a guru on
goals behind you, Steve, so if I build 1,000 reactors
tomorrow, Joe, should I keep the goals the same? I
must, at 4:15 we recess. There is other people coming
--
MR. ROSEN: -- which is a key issue is a
level of safety, which is exactly what you're talking
about?
CHAIRMAN APOSTOLAKIS: Yeah, yeah.
MR. KING: And that can be, you know,
different QHOs or it can be, are we now going to talk
about environmental protection or property protection.
CHAIRMAN APOSTOLAKIS: That's right. DID
is what?
MR. KING: Defensive data. See, now they
have a code for it so you --
(All talking at once.)
MR. KING: Okay, the last two slides, well
the last, next to the last slide is schedule. I won't
go through it in detail, but you can see that's our
schedule for both the PBMR and the research plan. And
we tried to put in the rough time frame of when we'd
like to come back and start talking the details with
the committee. And the last slide is just, we've been
thinking about what research we need with AP-1000,
IRIS and HTGRs in mind.
There are a number of candidate ideas we
have. Again, the resource issue has to be settled and
the priority issue has to be settled before we can
settle this. That's it.
CHAIRMAN APOSTOLAKIS: Thank you. You
have 30 seconds.
VICE CHAIRMAN BONACA: So this is the
first installment and then we're going to have an
extra two hours? I was hoping, no. Okay, we have now
a brief presentation from you?
MR. MAYFIELD: I'll keep this very brief,
and the point of the new challenges is we are working
and have been for some time, but we're redoubling some
efforts to try and get ahead of some of the
degradation issues. Over the last year we've seen
that more than a year, cracks in piping that we never
anticipated seeing. We're seeing cracks in CRDM
housings that we never anticipated seeing.
We're seeing some degradation in steam
generator tubes that goes a bit beyond what we've
seen. So we're looking in the materials research
program to try and get on the leading edge for a
change. Not that I really think we'll get there in
the next year or so, but looking out in the longer
term, how, what kind of work can we, can and should we
start in the next year or to two years that hopefully
would get us in a position to be able to deal with
emerging issues, new challenges.
Not that we would guess precisely what
they are, but that we'd have enough information to try
and deal with them. That sort of takes us to the last
bullet that was on Roy's Slide 10, in terms of the
anticipatory research. We've been challenging
ourselves to look ahead and try and identify areas
where new degradation, new damage mechanisms for the
materials issue and same kinds of things in the other
areas.
We are reaching out to the staff in a
fairly formal way this year asking for their ideas
well in advance of the budget formulation to try and
give people enough time to think about this and to put
forward their best ideas in a way that gives them a
fair chance when we sat down to put together the
budget and decide what issues we're going to put
forward.
We are also interested in input from this
committee, as well as, I think next year we're looking
to reach out, again formally, to a much broader
audience or the external stakeholders. So that's sort
of where we were going with the idea of the new
challenges.
And we know they are out there. Materials
just is a good example of it, but we're interested in
gaining some insights and suggestions for areas that
don't necessarily have an immediate application, but
where they have, there's some reason to believe that
it's an area that we need to explore.
MEMBER POWERS: You're focused on the
existing fleet of reactors in this call for --
MR. MAYFIELD: Right now it's on the
existing fleet of reactors, but it's, as we go along,
as that --
MEMBER POWERS: As Tom's work expands, you
expand it. Right now you're looking at that.
MR. MAYFIELD: Yes, so that was all we
really wanted to say.
MEMBER POWERS: I think, by the way, this
reaching out to your staff early in this process is
just a heck of a good idea.
MR. MAYFIELD: We'll see how it works.
MEMBER POWERS: Yeah, well, it's one of
those things that --
MR. MAYFIELD: We've got a lot of smart
people.
MEMBER POWERS: Yeah, it may not work too
well now until you persuade them that you're actually
going to listen to them. I mean sometimes you guys
put them through contingency exercises that may change
their view just a tad.
(Laughter.)
MR. KING: Okay, that's it, Mario.
VICE CHAIRMAN BONACA: Okay, well I thank
you very much for your patience. Clearly we were
discussing right now that at some point this committee
needs to reflect on what we've heard today, and then
make a decision, you know, what we should have as a
content for the report. I mean these are not likely
subjects. In fact, that's possibly the scope.
And so hopefully we can get half an hour
of time before --
CHAIRMAN APOSTOLAKIS: We will find more
than a half an hour. Remember that we, we're going
through Saturday noon or something, so we'll find the
time, don't worry.
VICE CHAIRMAN BONACA: And what I would
like to do is clearly we leave this meeting with some
commitment from some members to contribute some talk--
CHAIRMAN APOSTOLAKIS: Sure.
VICE CHAIRMAN BONACA: -- on these areas,
so that I can begin to put them together. So with
that, I'll give you back the --
CHAIRMAN APOSTOLAKIS: Thank you,
Chairman. We'll recess until 4:33.
(Whereupon, the foregoing matter
went off the record at 4:14 p.m.
and went back on the record at
4:35 p.m.)
CHAIRMAN APOSTOLAKIS: The meeting is back
in session. Next item proposed update to 10CFR, Part
52. Cognizant member is Dr. Shack. Bill.
MEMBER SHACK: This is just a briefing on
a proposed update to 10CFR, Part 52, which is a
licensing alternative for advance reactors. The staff
is proposing some changes in the rule and we're just
going to get an update on those proposed changes.
MEMBER POWERS: Do we have a petition?
MEMBER SHACK: There are two petitions, in
fact, I think. Yup, speaking of petition.
MR. WILSON: Thank you, Mr. Chairman, I'm
Jerry Wilson and I'm with the new reactor --
CHAIRMAN APOSTOLAKIS: Can you raise the
screen a little bit. Raise up?
MR. WILSON: Yes, let's see if I can move
this up.
CHAIRMAN APOSTOLAKIS: I think that's the
one, isn't it? Don't worry about it, don't worry
about it.
MR. WILSON: He knows what to do.
CHAIRMAN APOSTOLAKIS: Very good.
MEMBER KRESS: And would you get that spot
off there?
(Laughter.)
CHAIRMAN APOSTOLAKIS: Okay, Mr. Wilson.
MR. WILSON: By way of background, I've
been working on the development and implementation of
Part 52 since 1987. Now when the Commission issued
Part 52, in 1989, they stated that this was the most
important change in the NRC's licensing process in
over 30 years. At that time we created three new
licensing processes, but we had no experience in using
them, so right from the beginning we planned to come
back at a future date, after we had some experience,
and do this update rule making.
Now what has happened since then? Well,
let's do background here. Shortly after Part 52 was
issued, the Department of Energy sponsored a 30 site
permit demonstration program that was participated in
by NRC and industry representatives. And the
conclusion of that effort was that there are no
regulatory impediments to achieving an early site
permit.
Also we received five applications for
design certification and granted three of them. And
the committee was involved in the review of those
applications. The, I believe the NRC demonstrated
flexibility in the implementation of those
requirements and showed that that process can work.
And finally for approximately ten years
the staff interacted with stakeholders on certain
implementation issues associated with the combined
license review process. We issued a SECY paper in
April of last year on that, and the Commission
approved those issues in its SRM on September of 2000.
So with that we believe that Part 52 is
ready to be used, but as we said, intended to do a
rule making. So we prepared a rule making plan that
the Commission approved in January of '99.
And with that approval, the Commission
encouraged us to have early interaction with
stakeholders. So I posted on our rule making website
and noticed this rule making in June of 1999, and then
sent letters to stakeholders that identified a number
of issues that we were considering for this rule
making and invited comments.
In response to that we only received one
comment that was from the Nuclear Energy Institute and
they submitted that in April of this year. Now in
August the Commission issued an SRM and it suggested
the staff share draft rule language before issuance of
proposed rules for certain rule makings. One of which
was Part 52.
And so in September of this year, we
posted draft rule language on Part 52, on our rule
making website. We also issued a Federal Register
Notice notifying the public that this language is
available. And finally issued a letter to the
advisory committee providing the draft language for
their consideration.
Now with regard to the rule, as I said
earlier, the NRC believes that the rule is ready to be
used, and has stated that in a recently issued SECY
paper on our readiness assessment. Because of that
and because of the experience in using the rule, we
believe there's no need for any significant changes to
the rule to be used in future applications.
The other point I want to make on that is
at the time we were developing Part 52, the staff was
also involved in some advance reactor reviews. And we
had those designs in mind at the same time, and so we
believe that these licensing processes in Part 52 can
be used as they are today.
But having said that, I also believe that
there are some changes that can be made. Things of
clarifications and corrections. I thought I'd walk
through a few examples here. So if you'll see in the
draft rule language that I provided the committee, we
have made some minor changes in Parts 21, 72 and 140,
to make it clear that those regulations apply to
applicants under Part 52.
And the provision in Section 52.17, which
deals with the content of your application for an
early site permit, we want to make it clear that when
you submit an early site permit you are not describing
just one particular design that you may want to build
on that plant, maybe a range of designs.
And so we've envisioned that an applicant
would submit enveloping or bounding characteristics
that would deal with the types of releases and other
factors for different types of designs.
And another item we made in the combined
license process is clarifying findings relative to
ITAAC. There's two sections in the regulations where
it talks about findings and we're trying to clarify it
that in 52.99, that's where we discuss inspections and
notifications at ITAAC are complete, but that in
53.103, where the Commission is making its decision on
authorization to operate, that's where the
Commission's finding on whether or not ITAAC or the
net is made.
So these are some examples of the types of
clarifications that you'll see in the draft rule
language. Now also we have what I would consider
corrections to the rule. One is dealing with
Appendices M, N, O and Q. When the Commission created
Part 52, they directed the staff to move those other
licensing processes to Part 52, and we did that. But
through some administrative problems that wasn't
deleted from Part 50, so we're correcting that in this
rule making.
Also we want to make it clear that an
applicant for a combined license that's using a custom
design, is not referencing a certified design, would
provide a plant-specific PRA. And along those lines
also an applicant for a combined license, if you're
familiar with the design certification requirements,
there's a requirement on testing for new design
features. And we want to make it clear that that
would apply to someone coming in for a custom design
that it's not referencing a certified design.
CHAIRMAN APOSTOLAKIS: I have a question
on that.
MR. WILSON: Certainly.
CHAIRMAN APOSTOLAKIS: The language that
is being proposed says, and for the members it's one
hundred and page 12, if you want to follow that, over
Tab 5. It says --
MR. MARKLEY: That would be Page 7 of
yours, Jerry.
MR. WILSON: Thank you.
CHAIRMAN APOSTOLAKIS: Oh, I'm sorry,
yeah, yours is seven. We always inflate the number of
pages.
MR. ROSEN: You said 112, George?
CHAIRMAN APOSTOLAKIS: Twelve, 112, Tab 5.
You're looking at the wrong tab.
MR. ROSEN: I'm looking at Tab 5.
CHAIRMAN APOSTOLAKIS: It doesn't work.
MEMBER KRESS: I don't know where the
hundred comes from.
MR. ROSEN: Tab 5, no, 112?
MEMBER KRESS: There's no 112, just 12.
CHAIRMAN APOSTOLAKIS: It's getting late.
Okay, the language is the following. Item 4, the
second area from the top. An application referencing
a certified design must include the plan-specific PRA
that uses a design-specific PRA and is updated to
account for site-specific design information and any
design changes.
So I'm trying to understand what this
means now. It means that the Reviewer of the plant-
specific PRA cannot question the design-specific PRA
that was used in the certification? Because that was
part of the certified design? Is that how this would
work? Did you find it on Page 7? Item 4, second
paragraph.
MR. WILSON: Okay, I'm with you now, all
right. The idea in general, and then I'm going to
give you a clarification. In general, is that
information reviewed and resolved or to use the word
certified in the design certification process, if you
reference that design that information comes forward.
And since it's resolved, yes you wouldn't
re-review that information. However, in the case of
PRA it's a special circumstance. And during the time
that we were working on the actual language that is in
what we call the design control document, the industry
requested that a lot of the details in the PRA not
come forward into the certified design information.
And so in this particular case there
actually is rather limited information that would come
forward and fit into that category that you're
describing of not re-reviewed. Now what we are
talking about here though is that we would expect that
you would take what is in the certified design
information for the PRA.
You would add in the site-specific design
features, such as the ultimate heat sink, and you
would also modify it to reflect any design changes
that the combined license applicant may have requested
to that certified design. And so that was the idea of
this rule language.
CHAIRMAN APOSTOLAKIS: All right. I
understand that, but I guess I'm a little
uncomfortable with this. For example, let's take, I
mean I was on the committee when we approved,
certified the 8600 PR design, plus you know, the PRA
package.
And they did, you know, certain things
that were probably state-of-the-art at the time. It's
been now a number of years. One that comes to mind is
this software liability issue, they did a few things.
Let's say somebody now comes with an 8600 application
in the year 2006, and it comes to you for a review in
the year 2010.
That would be a full 12 years or so, 14
years after the original design was certified, and we
know, I mean the state-of-the-art advances, of course.
Now perhaps at that time we are doing things better in
certain areas. Software liability and other areas.
Is your reviewer bound to accept what Westinghouse did
in 1995? Even though the state-of-the-art has
advanced?
MR. WILSON: In general, yes. And as I
said in the case of the PRA there was very little of
the PRA other than the basic assumptions that came
forward into this certified design information. So
certainly we would expect that we are not requiring
that they redo the PRA and redo it up to the latest
standards.
CHAIRMAN APOSTOLAKIS: But is it, is there
anyway you can find the language for this paragraph
that allows for some updating of the design-specific
PRA without really penalizing the applicant. I mean
I appreciate that the whole point of certification was
to, for the applicant to know what they're going to
find when they come to us. But to freeze something,
like a PRA, I think is unhealthy.
MR. WILSON: Well, it doesn't preclude
them updating it.
CHAIRMAN APOSTOLAKIS: I know it doesn't.
MR. WILSON: It's just that we're not
requiring that update at this point in time.
MR. ROSEN: That's what George's problem
is.
CHAIRMAN APOSTOLAKIS: Yeah, that's my
problem.
MR. ROSEN: He wants you to require it.
CHAIRMAN APOSTOLAKIS: If you put the
language there that will give the reviewer flexibility
to, you know, to work with the latest technology. I
mean we do that in everything else.
MEMBER SHACK: Well, you tell them to use
the addition of the code that they built the plant to.
CHAIRMAN APOSTOLAKIS: They what?
MEMBER KRESS: He's just agreeing with
you.
MEMBER POWERS: Yeah, if somebody builds
to a particular addition to the code, the government
would be against that addition to the code.
CHAIRMAN APOSTOLAKIS: Well, I appreciate
that but I mean --
MR. MARKLEY: PRA is different.
CHAIRMAN APOSTOLAKIS: It's evolving all
the time. I mean we know that, that's why it's risk
conformed and not risk based. Let me use that
argument now --
MEMBER POWERS: George, let's consider
people in both worlds. I mean they can approve the
data, they understand new things, you don't make them
go back.
CHAIRMAN APOSTOLAKIS: We don't.
MEMBER POWERS: Well, sometimes we do,
sometimes.
CHAIRMAN APOSTOLAKIS: Yeah.
MEMBER KRESS: I think George is right.
If we've got new ways to do things with a PRA, new
information and we should allow new information to be
used.
MEMBER POWERS: Allow is different than
require.
MEMBER KRESS: I really would not like to
require, because NRC needs to have the best
information it can.
CHAIRMAN APOSTOLAKIS: This is a
regulatory decision here. I mean you can't say I will
close my eyes to new information because the law says
I have to go with what was valid 15 years ago.
MR. ROSEN: But it's not like it's an
undue burden on the licensee. He can make his mind up
not to build a plant if the rule requires an updated
PRA based with new human error models. He might say
that's too hard, I won't build the plant.
MEMBER POWERS: That's a non, a non-
starter. I make this thing incredibly onerous and if
you get it and want to build a plant, that's okay.
CHAIRMAN APOSTOLAKIS: No, that's your
decision. Well, how about if you say --
MR. ROSEN: That's extreme interpretation
of what I'm saying.
CHAIRMAN APOSTOLAKIS: -- that uses an
updated design-specific PRA. I mean, but of course
that's open-ended too. I understand you have to --
MR. WILSON: Let me add a little more to
this.
MR. ROSEN: I think here's the answer. It
should be tied to the ASME and ANS standards. Because
it's a consensus process.
MEMBER KRESS: Put the word state-of-the-
art PRA.
CHAIRMAN APOSTOLAKIS: Oh, my God, no.
MR. ROSEN: State-of-the-art is beyond the
standard.
CHAIRMAN APOSTOLAKIS: Yeah, sure.
MR. ROSEN: But there is a standard.
(A lot of people talking at once.)
MR. WILSON: I want to add a little more
to the discussion.
CHAIRMAN APOSTOLAKIS: Of course.
MR. WILSON: Internally in the staff we
have been discussing this and I have been working with
our folks in the responsible branch on this very issue
of updating and you probably heard the staff talk
about things like living PRA. And in my discussions
with them, the staff is considering these issues of
updating, but they decided that if they require that
or if they propose to have such a requirement, they
wanted to do it separate from the particular rule
making.
So what I'm trying to do now is just be
sure we have a PRA that covers the design and defer
for now that issue of having someone update what was
done during the design certification stage.
CHAIRMAN APOSTOLAKIS: Where else would it
go?
MR. WILSON: Well, it would be a
requirement that would be directed at PRAs in general.
CHAIRMAN APOSTOLAKIS: No, because,
separate rule? No. The think is, you know, with the
license renewal thing, because the rule says do it
this way, people are doing it this way. And every
time we raise a question about risk, they say, ah, but
5054 doesn't say anything about that.
And it was done, you know, sometime ago.
So I suspect if you put it somewhere else, the same
thing is going to happen. The rule itself doesn't say
that, so I'm not going to do it. And you end up
making regulatory decisions using very old
information, possibly.
It could valid, I mean I'm not saying that
this will happen, but in some areas it might.
MR. ROSEN: Well, we've argued, George,
about voluntary versus discretionary in the case of
the current licensees, and I think it's time for
future reactor licensees to not to make is so
voluntary. And so I support the idea that we make it
required.
And the, you know, then the staff can
figure out what they mean by a valid, up-to-date,
state-of-the-art, plant-specific PRA.
MEMBER KRESS: Well, those are words I
want in there.
MR. ROSEN: Valid, up-to-date, state-of-
the-art, plant-specific.
CHAIRMAN APOSTOLAKIS: No, I'm willing to
let the stuff come up with the appropriate language so
that we don't appear like we want to start everything
again from scratch. But I think the idea is that.
That we want to be up-to-date.
MR. WILSON: I'll go back and talk to our
PRA folks.
MEMBER POWERS: And find a good reason not
to do that, right?
(Laughter.)
CHAIRMAN APOSTOLAKIS: You see then the
rule, one last point. The rule is a bit inconsistent
and maybe that's a good argument for doing it. On the
previous page, you say if the application does not
reference a certified design, the application must
contain a plant-specific PRA. And of course it is
understood that it will be, you know, according to the
state-of-the-art. So if you are not referencing a
certified design, you do it one way. If you are, you
do it in a slightly different way. Which may not be
slightly different, it may be significantly different.
MR. WILSON: But you can make those kinds
of discussions about design approvals and design
certifications in general. I mean once the agency
certifies a design, approves a design and said we're
going to hold with that approval, we're not going to
revisit it and we don't expect the applicant to come
in with changes, then we're always in that situation
of down the road when they reference back to that
design, it's, that was state-of-the-art at that point
in time.
MR. ROSEN: Look, a license is a contract
between the staff and the licensee. You specify the
guy who is about to give something up, which is a
license, which is the Commission who is about to give
up a license, specifies its requirements for the
person who wants it. And the requirements should be
just what I said. A valid, plant-specific, up-to-
date, state-of-the-art PRA.
MR. WILSON: But as part of that we also
do regulatory analysis and we have to show house
benefit for new requirements.
MR. ROSEN: It would be, it would be out
of touch for the Commission not to require that they
have a policy statement.
CHAIRMAN APOSTOLAKIS: New requirements I
think regarding the facilities themselves.
MR. ROSEN: For new plant? For new
designs? Just remember when you talk about old
plants, then you are in back fit space. Everybody is
thinking back fit space. But if this is a new plant,
where a new contract is being cut with the proposed
Contractor, the licensee, and so the Commission could
set its requirements.
And I recommend that's what its
requirements ought to be.
CHAIRMAN APOSTOLAKIS: How about if you
put, for example, an application referencing a
certified design must include a plant-specific PRA
that uses the design specific PRA, as a appropriate,
and is updated to account for the site-specific design
information.
VICE CHAIRMAN BONACA: As appropriate?
CHAIRMAN APOSTOLAKIS: Is appropriate.
MEMBER SIEBER: That doesn't require it.
CHAIRMAN APOSTOLAKIS: No, but it gives
some freedom to the reviewer to say this particular
part is not appropriate anymore. No matter how you
put it, it's going to be abused.
MR. ROSEN: Actually, George, the law of
inverse codification takes over here. The less
codified it is, and less specific it is, the more
flexibility the staff has to ratchet, to different
things and to get inconsistent. The better thing to do
is to make it specific in the rule that the licensee
needs to come up with a valid, up-to-date, state-of-
the-art, plant-specific PRA, period, if they want a
license.
CHAIRMAN APOSTOLAKIS: Well, I would, if
you want to go that way, I would take Number 2 and
Number 4. One is referring to the existence of a
certified design, the other to a case where you don't
have a certified design. Drop them and replace them
by one that says an obligation must include the plant-
specific PRA, period.
MEMBER SHACK: Rule Number 1 is no
regulation can ever require a state-of-the-art.
CHAIRMAN APOSTOLAKIS: I didn't say state-
of-the-art, I said plant-specific.
MR. ROSEN: No, Rule Number 1 is that
anybody, state-of-the-art is whatever it is today.
And then since it's up-to-date, you have to improve it
as the years go on.
CHAIRMAN APOSTOLAKIS: No, but what's
wrong with just --
MR. ROSEN: There's nothing wrong with
improving it, that's what we've been doing for years.
CHAIRMAN APOSTOLAKIS: What's wrong with
requesting a plant-specific PRA, and then leave it for
other lesser documents to elaborate on the guidance,
the regulatory guidance which are easier to change.
If you put it here it's cast in stone.
MR. ROSEN: That's good.
MEMBER SIEBER: If you buy a certified
design, if you buy a certified design and make no
design changes to it, why wouldn't the PRA for that
certified design be adequate?
MR. ROSEN: Well, because --
CHAIRMAN APOSTOLAKIS: A lot of it will
be. But a lot of the stuff that is done, you know, by
our waiting because we didn't know what to do at the
time.
MEMBER KRESS: Somebody comes up with a
new sequence in shut down mode and fire --
MR. ROSEN: And the nature of PRA is that
it evolves with the data, with the data from the plant
that it's based on. The data for unreliability and
unavailability at first is nothing but an estimate.
But the second, the first time you update it, it is
based on the data from that plant, and so on.
CHAIRMAN APOSTOLAKIS: I still remember
the discussion with --
MR. ROSEN: PRA involves the more closely
modeled the performance of the plant.
CHAIRMAN APOSTOLAKIS: I still remember
the discussion we had in this committee when we were
debating the approval of AP-600, the AP-600 design
when it came to the software reliability issue. I
mean everybody agreed that nobody knows what to do
with it. Westinghouse said we use some failure rates
from this source, then we multiply them by ten and we
looked at the result. And then we did something else.
We did it, and then we said, well, all
right, what else can you do? Now in the year 2015,
maybe that would not be good enough. That's what I'm
saying. Because at that time at least people were
pleased at least to see some effort to see what's the
impact on the result because they knew that there is
nothing out there to help you do it.
So would then the applicant be able to
say, well, I'm sorry but that's part of the certified
design so it's still good enough.
MR. ROSEN: And I'm going to update it
with current data from reliability --
CHAIRMAN APOSTOLAKIS: Yeah.
MR. ROSEN: -- reliability from my plant.
And we'll do it.
CHAIRMAN APOSTOLAKIS: I would just ask
for a plant-specific PRA, in the new rule and let the
regulatory guides elaborate on the details. Because
they are easy to change, right? You can use language
and also, as we all know, a regulatory guidance
unacceptable approach. So no one is coming up with
another one. But the rule is a rule. I've learned my
lesson from license renewal, I'll tell you that.
Every time we raise an issue, oh, no, no,
no, the rule doesn't say that. Well, that's the way it
works and that's the way we're going to do it.
Anyway, that's a comment. I mean that's why you're
here, right, to get some comments.
MR. WILSON: Right, thank you. And moving
along --
MR. ROSEN: You understand, I'm slightly
to the right of the Chairman.
(Laughter.)
MR. WILSON: You're on my left.
CHAIRMAN APOSTOLAKIS: Both literally and
figuratively.
MR. WILSON: I think in terms of
rottenness, I think we're --
MEMBER KRESS: That's right, this is
Attila the Hun.
(Laughter.)
MEMBER POWERS: Recognize that the left
wing over here may have something to say.
MEMBER SHACK: Time to move on, George?
CHAIRMAN APOSTOLAKIS: Fine with me. I'm
surprised you haven't said anything.
(Laughter.)
MEMBER SHACK: I wanted to see how long
the rope would string. There's no limit, obviously.
(Laughter.)
CHAIRMAN APOSTOLAKIS: I'm done, I'm done.
MEMBER SHACK: This is a bungee cord.
(Laughter.)
MR. WILSON: All right, so I gave some
examples of clarifications and corrections and their
role and there's also some burden reductions. We have
a provision now that in the event that you apply for
a design certification we also require you to apply
for a design approval.
That had to do with the fact we had no
experience in doing design certification reviews. Now
that we have that experience, we don't believe that
requirement is needed and we're proposing to delete
them.
CHAIRMAN APOSTOLAKIS: I'd also like to
bring the attention of the committee to hundred and
page six where they use, in the second paragraph, a
need for power in connection with inter ilia issuance
of early site approvals. The use of latin is very
welcome by the Chair. I think especially Dr. Powers
should pay attention to that.
MEMBER POWERS: If this was the only
mistake the Chair had made, then Dr. Powers would be
shocked. Since it's not --
CHAIRMAN APOSTOLAKIS: I like it. When I
saw it I said this is a good rule. Is this a Part 52,
okay.
MR. WILSON: Now I was also asked to
discuss how Part 52 might be used in a future
application for the pebblebed design, which the
committee has heard about. Now by way of background,
Office of Research is doing a preapplication review
for the pebblebed design. There's been a SECY paper
describing that that was issued in April of this year.
And subsequent to that, in May Exelon
submitted a letter with a number of regulatory issues
that they would like to see some changes on that would
facilitate their future application. These are things
like anti-trust, annual fees, decommissioning,
financial requirements.
Also in May 25th, Exelon submitted a
licensing plan for the pebblebed where the proposed a
sequence of first, requesting an early site permit,
then a combined license to build the plant, and then
finally a design certification. And in that letter
they also proposed seeking a single license for
multiple reactors.
Staff issued preliminary reviews on that
licensing plan in August of this year, and we stated
that their proposed sequence is acceptable but raised
some concerns about the issuance of a single license
and timing of testing.
Now the staff is preparing a SECY paper on
these issues and also these other aspects of the
single license and testing issues. And I'm
anticipating that paper is going to be issued shortly.
Now in looking at these various licensing options
relative to the pebblebed, with regard to early site
permit, Exelon stated they anticipate submitting an
application in mid-2002.
I see the staff using the early site
permit process as it's written with no major
obstacles. Now when the combined license comes in,
and at the moment we're expecting that in late 2003,
although that date, I understand, may slip. But once
again, we would use the process as it is written, but
we envision, that because it's a gas-cooled reactor
there 's going to be a need for some exemptions and
licensing conditions in areas that the current
regulations don't cover.
But I would say though that most of our
regulations will apply to the gas-cooled reactors.
Now if they follow up after issuance of the COL with
the design certification application, one of the
things the staff may do is codify any design specific
requirements that come from that combined license
review in the design certification rule making.
So we'll have some design specific
requirements in that situation. Now the staff has
prepared a SECY paper that's discussing this process
and determining what the appropriate license
conditions will be. That preparation, that paper, the
staff is going to come and discuss with the committee
tomorrow, so I won't get into any discussion on that.
So in conclusion, staff believes that the
licensing processes in Part 52 are ready to be used in
any new applications. We'll have this update rule
making underway. We don't think any significant
changes are needed to process new applications, and
these processes are also applicable to an application
for the pebblebed design or, for that matter, any
other gas-cooled reactor design. So with that, I'm
available for questions.
CHAIRMAN APOSTOLAKIS: So what are these
other viewgraphs in your handout?
MR. WILSON: Just some back ups.
CHAIRMAN APOSTOLAKIS: Oh, okay. I really
like that.
MEMBER SHACK: On Page 10, the changes in
the Tier 2 document --
CHAIRMAN APOSTOLAKIS: Which Page 10?
MEMBER SHACK: The real Page 10.
CHAIRMAN APOSTOLAKIS: The real Page 10.
MEMBER SHACK: For the various certified
designs now essentially allows them to make changes in
the Tier 2 documents with a kind of 5059 kind of
freedom. What was the previous one? It doesn't, you
know I don't see a line out.
MR. WILSON: Oh, I'm sorry. When we did
design certification, one of the things about design
certification is the backfit. The idea that once we
have a resolution on the design we want to lock that
in and so that neither the staff nor the applicant
would make changes unless it was really significant.
And so we created a special change
process. So design certification doesn't come under
50109 or 5059. And also because the applicants asked
for a two tiered documentation, we had change
processes for Tier I and Tier 2, and just kind of a
lead in saying there's a rather complicated specific
change process.
Now we had a 5059-like change process that
used terminology very similar to the terminology in
the old 5059, unreviewed safety questions and things
like that. And so after that was done, the Commission
suggested to staff that, hey, we ought to revise this
change language to be comparable to that. Plus that
also, not only does it give new terminology and new
definitions, that's all been worked out with the
industry and we have regulatory guidance on how to
implement that.
And so I wanted to use as much of that as
possible, but still keep the basic idea of the higher
standards there. And so we went back and we proposed
changes to adopt as much of that language as possible
so we could also use that underlying guidance.
And so basically, I mean the short answer
to your question is we took out phrases like
unreviewed safety question, and put in phrases like
minimal increase.
CHAIRMAN APOSTOLAKIS: What is DCD?
MR. WILSON: Design control document.
When you apply for design certification, you have the
standard safety analysis and design descriptions. But
when it came to certifying the design, there was some
changes in that documentation. So for example the
rule that certifies the design references this
documentation and that's all publicly available
documentation.
So it doesn't have proprietary information
in it, and also as I said earlier, the industry asked
that a lot of the details on the PRA not be in the
certified design information. So that was taken out.
So we wanted to create --
CHAIRMAN APOSTOLAKIS: Oh, so the PRA is
not?
MR. WILSON: Most of the PRA is not in the
certified design information.
CHAIRMAN APOSTOLAKIS: That's good.
MR. WILSON: Just the basis assumptions
that were used that are associated with those design
features that are involved.
CHAIRMAN APOSTOLAKIS: There is a
statement here on Page 12, that would, in fact, not
allow what I asked earlier. So if the PRA is out,
that's good. Changing any method, it says, is not
allowed.
MR. WILSON: So when we took that
information out, we needed a new name for that
document and we called it the design control document.
But it's --
CHAIRMAN APOSTOLAKIS: So updating the PRA
in the sense I mentioned earlier, would be allowed?
MR. WILSON: There's not much to update.
All we retained was basic assumptions that --
CHAIRMAN APOSTOLAKIS: All you have to do
--
MR. WILSON: -- I don't think would change
unless the design changed.
CHAIRMAN APOSTOLAKIS: Yeah, okay, okay,
that's good, that's good. Now there is another
question I have on Page 2, your Page 2. The very top.
How modular designs are defined?
MR. WILSON: Yes.
CHAIRMAN APOSTOLAKIS: I understand the
first one. It's a nuclear power station designed that
consists of two or more nuclear reactor modules. The
second one is not clear to me. A nuclear power
reactor design composed of subassemblies which, when
assembled without a module center structure assistance
and components on site, constitutes a complete nuclear
power reactor. What is that?
MR. WILSON: Let me first start out by why
did I do this? If you look at Section 52.103.G,
you'll see there that the Commission may approve
authorization to operate on a module-by-module basis.
Now where did that come from? Well, that came from,
at the time we were writing the rule we were dealing
with designs like MSTGR and Prism, where there were
two or three reactors that were together in an overall
power station.
But you can envision a situation where
they would be building it and you wouldn't be bringing
all three on-line at once. You'd bring them on
reactor-by-reactor. And so we wanted to be sure the
process would handle that. And we used the term
modular at the time, but didn't define it.
Well, now the difficulty with modulars,
the industry uses that term in a number of different
ways. And we need to get this clarified and make sure
it fits in with the rule. And so if you look at
AP600, Westinghouse says that's a modular design.
Well, what that means though is that they
envision portions of the plant being assembled off-
site and those modules brought together and put
together on the site forming one complete nuclear
reactor plant. Now comes pebblebed. They also refer
to that design as modular, but what they mean when
they say that is that the overall plant is going to
consist of upwards of ten small nuclear reactors. And
they refer to those small reactors as modules.
CHAIRMAN APOSTOLAKIS: Yeah.
MR. WILSON: Well, those are much
different definitions. We need to do something to
clarify what the Commission is talking about in terms
of its authorization to operate. And so this is the
first shot at this, we're not done with this. But the
goal here is to clarify how the Commission is going to
treat modular reactors, given that the industry is
using this term in a number of different ways.
CHAIRMAN APOSTOLAKIS: But again, maybe
I'm missing something, but I don't know why you need
the second definition. I mean Westinghouse may be
using it, but how does it affect the regulations?
MR. WILSON: As I said, we're not done
yet. I tend to agree with you, we probably don't. But
I'm getting this out here so we can facilitate future
discussions and in the proposed rule hopefully get
this straightened out.
CHAIRMAN APOSTOLAKIS: I mean the first
one clearly is meaningful because, you know, they may
start with three modules and then add further modules
years later. And that makes much more sense.
MR. WILSON: And that allows me to make a
point I forgot to make, is this draft ruling, which is
a work in progress, this isn't the finished thing.
There may be changes in it before we actually come up
with the final proposal.
CHAIRMAN APOSTOLAKIS: All right.
MEMBER SHACK: Anymore comments or
questions? I believe we have, NEI would like to say
some things about their petitions.
CHAIRMAN APOSTOLAKIS: Thank you very
much, Mr. Wilson. You handled us well.
MR. WILSON: Many years of experience.
(Laughter.)
MEMBER SHACK: Dealing with grumpy old
men, right.
(Laughter.)
MR. WILSON: The secret is get them
fighting among themselves.
CHAIRMAN APOSTOLAKIS: That's right.
MEMBER KRESS: I am not old.
MR. ROSEN: Or grumpy.
MEMBER KRESS: Well, grumpy I admit to.
(Laughter.)
MR. BELL: Thank you. My name is Russell
Bell and I am from NEI. Thanks for inviting me to
just say a few brief words, especially in the lateness
of the hour and the interest of the committee. Let me
just follow up by, we're making a few key points as we
provide, continue to provide input to the NRC on the
Part 52 rule making.
And I'll start by agreeing with Jerry that
Part 52, probably is, could be used as is. Yet the
plan has been all along to reflect some lessons
learned, make some clarifications and some adjustments
and corrections characterized.
And that's happening. The fact that it
can be used as is doesn't mean though that it can't be
improved in a more substantive way, or that as long as
we're opening the book again and revising it, we
shouldn't take advantage of the opportunity to look
for ways to enhance the rule.
So we've identified a number of changes
along the lines that Jerry talked about.
Clarifications, corrections. In fact many of the same
ones. However, we've identified or we're advocating
two additional
CHAIRMAN APOSTOLAKIS: -- the front.
MR. BELL: The one that says on/off?
(Laughter.)
MR. ROSEN: When all else fails, try
following the procedure.
MR. BELL: This is my only visual aid.
Hopefully you got a copy. And there are two main
things I want to talk about that are inextricably
linked. In addition to the kinds of things, the
clarifications, the corrections, we are advocating two
proposals that are more substantive. And July 18th it
was of this year we submitted two rule making
petitions to the NRC.
I think that you have those in your
packages. And they're aimed at improving the focus
and efficiency of the Part 52 process. This is for
the early site permit and combined licenses. So now
is the time to look for these kinds of things and in
fact the Commission admonished in their February 13th,
requirements memorandum to look for process
efficiencies and we think we've found some.
The first would avoid so-called
duplicative reviews of valid, existing site or
facility information that was previously reviewed and
approved by the NRC and subject to a hearing. So here
we're thinking about, you've heard that new plants
would most likely first be sited at existing
facilities. Either existing plants where, well where
plants are operating or where plants were perhaps
approved to be built, but were never built.
And that makes perfect sense. And
intuitively there should be some efficiencies
available to do that. This might be taking credit for
some of the ology type information that doesn't, that
doesn't change very much over, you know, a couple of
decades or several years.
It might be the fact that if you put a
plant at an existing, if you put a new plant at an
existing site where plants are running, there are
operational programs in place related to emergency
planning and radiation protection and all those kinds
of things that are up and running. They are
established effective programs that would, and then
the proposal would be that those would be expanded to
encompass the additional units.
To accomplish this we've proposed two new
sections to the rule numbered 52.16 and 52.8. The
other petition seeks to eliminate outdated, frankly,
NRC reviews of alternate sites, alternative sources of
generation and need for power.
These emanate from the National Environmental --
CHAIRMAN APOSTOLAKIS: Policy Act.
MR. BELL: -- Policy Act, NEPA. Thank
you. And, which is carried out for NRC via Part 51
regulations. The, this petition that looks to be in
line with the views that the Chairman expressed in a
letter to Senator Domenici, also in February, I
believe, where he said these matters are more the
business of the state and local officials and the
marketplace to determine, again, what type of
generation to build, where it is needed and whether it
is needed.
And the NRC really is, these matters are
distant from the NRC's mission. So these two are
obviously more than a correction, it's more than a
clarification. These are substantive enhancements
that we'd like to see. In commenting on the Part 52
rule making, we're advocating that these, action on
these petition, which by the way, the comments were
due to today on the petitions.
I forwarded them to the NRC earlier today
and maybe you already have a copy of our November 8th
letter which summarizes the basis and the intent of
the, both proposals. We're advocating that the NRC
expedite consideration and action on these proposals
so that they can get on board with the ongoing Part 52
rule making which is now scheduled to, I think the
staff schedule is to complete work on that in April,
send the paper, the proposed rule to the Commission.
We're down to the -- I'll pause for
questions in a moment. Why don't I just finish. On
the Part 52 rule making again, I mentioned the
schedule is now April. There was a time when the
schedule was this past April, for the notice of
proposed rule making. And for good reasons we and the
NRC agreed that we should take the time now, take more
time to consider the range of changes that might be
necessary.
You don't go and revise a major piece of
work like Part 52 very often, so we ought to get it
right. But now the rule making has slipped again to
April of next year and frankly the cushion we had or
the surplus schedule we had is gone.
This is the center piece of the regulatory
frame work for new plants, so our message is that
center piece, that regulatory infrastructure for new
plants needs to be in place and we're hoping that
there will be no further delay.
So the need to expedite the action on the
rule making, on the, excuse me, the petitions. We have
had a number of interactions on all these matters.
The petition issues as well as the lesser
clarifications, corrections, these types of things
we've had a number of conversations and public
meetings with the staff. And I believe the comments
are due on Tuesday, that the staff, as Jerry pointed
out, issue draft, publish draft ruling for stakeholder
comment. Those comments are due Tuesday and we'll be
providing input to the staff next week.
At the bottom there it just highlights a
couple of things. In terms of the 50.59-like process,
I think it's important to preserve the distinction
between so-called design basis information versus
severe accident-related information which is required
by Part 52.
Okay, the original certifications include
a higher threshold for determining when prior NRC
approval is required for severe accident information
versus design basis. And that higher threshold is
known as a substantial increase threshold. And we'd
like to --
CHAIRMAN APOSTOLAKIS: Let me understand
this, Russ. Are you saying that if, that I can change
for severe accidents the way of calculating something?
MR. BELL: Yeah.
CHAIRMAN APOSTOLAKIS: If I can show first
that these would result in a substantial increase in
the frequency of occurrence of an accident or all
these rules of 50.59, rather than a minimal increase?
You are replacing minimal by substantial?
MR. BELL: That's right.
CHAIRMAN APOSTOLAKIS: And you're doing
that for the accidents, severe accident issues?
MR. BELL: Right.
CHAIRMAN APOSTOLAKIS: Only?
MR. BELL: That's right. And I'll just,
just to reiterate --
CHAIRMAN APOSTOLAKIS: Okay, just to
understand it.
MR. BELL: The existing rule has the work
substantial increase in there. And while we think
it's appropriate to substitute minimal elsewhere in
the 50.59-like process, as it applies to professional
design basis information, we wouldn't touch this part
of it.
CHAIRMAN APOSTOLAKIS: So the rule now is
being changed when they insert this language, minimal?
MR. BELL: Yes.
CHAIRMAN APOSTOLAKIS: The existing rule
already says substantial. Well, you can't say these
things because this is 50.59 thinking that is very
recent.
MEMBER SHACK: Right, I mean you know in
the old one, the Tier 2 change, the design basis was,
you know, unresolved safety issue, I guess.
CHAIRMAN APOSTOLAKIS: Unreviewed safety
issues.
MEMBER SHACK: Unreviewed.
CHAIRMAN APOSTOLAKIS: so now you would
have two different sets of conditions for a departure
from Tier 2?
MR. BELL: And there always have been,
just again, to reiterate. One of the corrections
Jerry highlighted was that to require COL applicants
who do not reference a certified design to be subject
to the same requirements as design certification
applicants for testing and demonstrating performance
of innovative safety features.
And we're, our strong view is that that's,
that should not be, that new requirement should not be
included in the notice of proposed rule making that
comes out. In fact, the record on Part 52 seems
pretty clear to us that the Commission considered
whether that type of requirement was appropriate at
licensing. They spoke to it in the statements of
consideration of the Part 52 rule and said that it, in
fact, it should not. So again, we'd like to, like to
see no change there.
MR. ROSEN: I really don't understand
that. Can you help me through that? We set up a
certified design and anybody who says they'll build in
accordance with that gets all sorts of relief. But
the next guy comes in and says I don't like that
certified design, I want to build something else that
I kind of worked out in my garage. And it's got
highly enriched uranium in it.
And that guy wouldn't be subject to the
same testing and performance demonstration
requirements as design certification applicants
because he's not referencing the design, certified
design. He can do anything he wants. So I don't
understand that.
MR. BELL: He would, in terms of
requirements for obtaining the license he would have
to go through this. He would not be required to
demonstrate prior to obtaining the licensing through
testing and prototype testing, separate affects
testing.
The kinds of things that he's, that his
innovative design is proposing to do. In the license,
presumably, there would be conditions on demonstrating
those features through, you know, start up testing.
And I think these kinds of things have been done
before. In fact, there's existing NRC guidance that
says this is the best and appropriate.
MR. ROSEN: And presumably the purpose of
this is to encourage innovation? Or what are, it
seems --
MR. BELL: Yes, in fact the Commission
statements, which I don't have in front of me, spoke
in terms of the burden that required for instance that
prototype testing be complete prior to COL issuance,
that would impose a significant burden. But they went
on to say, but that's, there are ways around that,
including licensing the prototype.
And again, demonstrating through start up
testing that the innovative safety features are --
MR. ROSEN: I'm getting the picture now.
This is to permit something like a PBMR, effectively.
Because a PBMR is not a certified design.
MR. BELL: It's in space.
MR. ROSEN: And so it would not be subject
to the same testing and performance demonstration
requirements.
MR. BELL: As a condition of getting,
prior to granting the license.
MR. ROSEN: This is the door through which
the PBMR goes, is what I see. Is that right?
MEMBER POWERS: Why are we doing this?
MEMBER SIEBER: So you don't have to build
prototypes, the operating plant prototype.
MR. ROSEN: Oh, so you don't have to get
the designed certified if you're a PBMR. You can just
get some other, you know, Part 52 will apply to you,
you go through this window if it's put in. Clearly,
you get some other arrangement with the Commission to
do a prototype of something else, whatever license --
MEMBER POWERS: Why would I want to do
this?
MR. ROSEN: I'm not sure you would.
MEMBER POWERS: No, I don't think I want
to do this. I mean if the guy can't come in and show
me --
MR. ROSEN: This is NEI's proposal.
MEMBER POWERS: Yeah, I mean, what are we
arguing here, that somebody can come in here with some
cockamamie scheme for passive heat removal or
something like that, and because it's sufficiently
cockamamie that nobody can figure out whether it works
or not without even building it and try it?
MR. BELL: I think the staff would perform
its historical function in terms of the design review,
and in fact, 50.34 the date of the existing
requirements on providing technical information in
support of a design that demonstrates adequate ECCS
performance and all these kinds of things.
All those requirements would apply and a
licensee, like Exelon, an applicant like Exelon or
anyone else, would have to provide that type of
information. There would still be, of course, the
give and take that occurs between the staff and the
licensee.
MEMBER POWERS: I can see this as a staff
stress test on a guy who spent a billion dollars
building a reactor and the staff comes along and says,
no, you don't get a license. It sounds like a staff
stress test to me.
MR. BELL: I would just, just to clarify
I would say that's not an NEI proposal. I think the
Commission consciously thought about this, to their
credit, back in 1989, 1992, when these statements were
written, and intended the rule to be exactly the way
it is. So those are a couple of things that rise
above the others in terms of our recommendations that
are tabulated in the letter that we'll be sending to
the NRC on Tuesday.
MR. ROSEN: Now, let me just focus on this
NEPA business for a minute, alternatives.
MEMBER POWERS: I think one of the things
that I recognized is haven't we opted out of NEPA? As
a committee, didn't we opt out of NEPA?
MEMBER KRESS: Yeah, we did.
MEMBER SIEBER: Yes, we did.
MEMBER KRESS: But that doesn't mean that
--
MEMBER SIEBER: But this is a rule.
MR. ROSEN: I'm going to ask a question
about, about what you, about your letter. The third
bullet or the second bullet on Page 6 of your letter.
It says the industry proposal is consistent with NEPA,
which requires consideration of alternatives, but does
not specifically require the NRC to consider
alternative sites, alternative generating sources and
the need for power.
Although the NRC has historically
conducted these reviews, they are not required by
NEPA.
MR. BELL: Right.
MR. ROSEN: So basically you're saying
we'll always hear that NRC has been going beyond the
burdens of NEPA?
MR. BELL: Yes.
MR. ROSEN: And NEI is saying here, stop
doing that, we suggest you stop doing that. Stop
going beyond the burdens of NEPA.
MR. BELL: It's time to reassess that.
We're about, hopefully we're on the verge of a
renaissance.
MR. ROSEN: How will the burdens of NEPA
be carried then, since it requires consideration of
alternatives. Where will that consideration be, who
does it?
MR. BELL: Closer to home. By the
applicant itself in concert with his state and local
governments and communities and the marketplace.
MR. ROSEN: Okay, I get it.
MR. BELL: Anything else? Thank you.
CHAIRMAN APOSTOLAKIS: Yes, Dr. Shack?
Back to me?
MEMBER SHACK: Back to you.
CHAIRMAN APOSTOLAKIS: Thank you very
much. We'll recess for 15 minutes.
(Whereupon, the foregoing matter went off
the record at 5:35 p.m.)
Page Last Reviewed/Updated Monday, August 15, 2016
Page Last Reviewed/Updated Monday, August 15, 2016