487th Meeting - November 8, 2001

                Official Transcript of Proceedings


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.
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                     + + + + +
                   487th MEETING
                     + + + + +
                 NOVEMBER 8, 2001
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                ROCKVILLE, MARYLAND
                     + + + + +
                       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.
                 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
                 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
           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
                                                    (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
                       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
                       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
                       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
                       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
                       CHAIRMAN APOSTOLAKIS:  Any comments or
           statements any of the members wish to make before we
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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 --
                       -- 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-
                       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
                       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
                       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,
                       MR. GRIMES:  I mean necessary and
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       CHAIRMAN APOSTOLAKIS:  I wonder whether
           you are hurt, too.
                       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.
                       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
                       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
                       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
                       MR. BURTON:  Yes.
                       MEMBER FORD:  Rather than a proactive
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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. 
                       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.
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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,
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       And if there are no questions in that
           area, I'll turn it back to Jason to discuss the LOCA
                       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
                       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
                       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
                       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
                       MR. CONNELL:  It's not a critical point. 
           It's a point that exhibited the largest percentage
                       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
                       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
                       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
                       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
                       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
                       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. 
                       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. 
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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.
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       That's all I had for containment system
                       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
                       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
                       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
                       MEMBER LEITCH:  Yes, that wouldn't --
                       MR. ARCHITZEL:  I was talking about the
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       MEMBER WALLIS:  Unhealthy wear rate.
                       MEMBER SHACK:  The increase is fairly
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       Whatever you say now is okay.
                       MR. RUBIN:  Maybe I've said enough.
                       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."
                       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 --
                       -- 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.
                       CHAIRMAN APOSTOLAKIS:  Very carefully
                       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
                       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
                       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
                       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
                       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
                       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
                       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 --
                       -- 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.
                       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
                     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
                       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
                       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
                 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
                       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
                       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?
                       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
                       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,
                       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
                       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
                       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
                       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
                       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
                       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.
                       MEMBER POWERS:  Not probably because of
           the research program.
                       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.
                       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
                       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.
                       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
                       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
                       CHAIRMAN APOSTOLAKIS:  Right.  So even
           though your budgets are going down, 13k -- all right
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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,
                       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
                       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
                       CHAIRMAN APOSTOLAKIS:  Have you read the
           letter of the committee on the revised oversight
                       MR. JOHNSON:  Say again?
                       CHAIRMAN APOSTOLAKIS:  Did you read the
           letter of the committee on the revised oversight
                       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
                       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
                       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
                       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
                       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
                       MR. JOHNSON:  -- this is a topic of the
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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.
                       MEMBER POWERS:  No, he believes in
           decision theory.  There is no hope for him.
                       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.
                       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
                       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
                       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.
                       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
                       MR. ROSEN:  I think the problem seems
           rather limited to you, George.
                       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
                       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
                       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-
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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,
                       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.
                       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
                       CHAIRMAN APOSTOLAKIS:  The mother of
                       MR. KING:  In a broad sense, the types of
           issues --
                       CHAIRMAN APOSTOLAKIS:  Yes, she was a
                       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,
                       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
                       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
                       MR. ROSEN:  It's a difficult question
           because in the way regulation is done in different
                       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
                       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
                       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,
                       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
                       CHAIRMAN APOSTOLAKIS:  Or different
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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.  
                       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?
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       CHAIRMAN APOSTOLAKIS:  Yeah, that's my
                       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
                       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,
                       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
                       MEMBER POWERS:  Allow is different than
                       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
                       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
                       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
                       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
                       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
                       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?
                       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
                       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
                       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
                       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.
                       MR. WILSON:  You're on my left.
                       CHAIRMAN APOSTOLAKIS:  Both literally and
                       MR. WILSON:  I think in terms of
           rottenness, I think we're --
                       MEMBER KRESS:  That's right, this is
           Attila the Hun.
                       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.
                       MEMBER SHACK:  I wanted to see how long
           the rope would string.  There's no limit, obviously.
                       CHAIRMAN APOSTOLAKIS:  I'm done, I'm done.
                       MEMBER SHACK:  This is a bungee cord.
                       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
                       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,
                       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
                       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
                       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
                       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.
                       MEMBER SHACK:  Dealing with grumpy old
           men, right.
                       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.
                       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?
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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
                       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