487th Meeting - November 9, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               487th Meeting

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Friday, November 9, 2001

Work Order No.: NRC-102                             Pages 357-596

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
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                                 + + + + +
                               487TH MEETING
                                 + + + + +
                             NOVEMBER 9, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
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                      The committee met at the Nuclear Regulatory
           Commission, Two White Flint North, T2B3, 11545
           Rockville Pike, Rockville, Maryland, 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
           STEPHEN L. ROSEN, Member
           WILLIAM J. SHACK, Member
           JOHN D. SIEBER, Member
           GRAHAM B. WALLIS, Member
           JOHN D. SIEBER, ACRS
           ALSO PRESENT:
           LARRY MATHEWS
           STEVEN MOFFAT
           ALLEN HISER
           ED HACKETT
           KEN BYRD
           ALEX MERRION
           RAJ PATHANIA
           DAVE GEISEN
           ALSO PRESENT: (CONT.)
           MARK REINHART
           TOM KING
           N. PRASAD KADAMBI
           ERIC J. BENNER
           JIM LYONS
           EDWARD McGAFFIGAN (Commissioner)
           TONY ULSES
           .                                 I-N-D-E-X
           Opening Remarks by the ACRS Chairman . . . . . . 361
           Circumferential Cracking of PWR Vessel
                 Head Penetrations  . . . . . . . . . . . . 362
           Licensing Approach for the Pebble Bed. . . . . . 476
                 Modular Reactor Design
           Meeting with Commissioner McGaffigan . . . . . . 529
           Staff Presentation on Power Uprate . . . . . . . 575
           Adjourn. . . . . . . . . . . . . . . . . . . . . 596
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:31 a.m.)
                       CHAIRMAN APOSTOLAKIS:  The meeting will
           now come to order.  
                       This is the second day of the 487th
           meeting of the Advisory Committee on Reactor
           Safeguards.  During today's meeting, the committee
           will consider the following:  circumferential cracking
           of PWR vessel head penetrations; licensing approach
           for the pebble bed modular reactor design; future ACRW
           activities/report of the Planning and Procedures
           Subcommittee; reconciliation of ACRS comments and
           recommendations; preparation for the meeting with the
           NRC Commissioners; proposed ACRS reports.  
                       In addition, the committee will meet with
           Commissioner McGaffigan to discuss matters of mutual
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Mr. Sam Duraiswamy is the designated
           federal official for the initial portion of this
                       We have received a request from the
           Nuclear Energy Institute for time to make oral
           statements regarding circumferential cracking of PWR
           vessel head penetrations.  
                       A transcript of portions of the meeting is
           being kept and it is requested of the speakers use one
           of the microphones, identify themselves and speak with
           sufficient clarity and volume so that they can be
           readily heard.
                       I would also like to remind Members that
           during lunch time we are scheduled to interview three
           candidates for potential membership on the ACRS.
                       The first item on our agenda is
           circumferential cracking of PWR vessel head
           penetrations.  Dr. Ford is the cognizant member and he
           will lead us through the discussion.
                       MEMBER FORD:  Thanks, George.  In July, we
           heard a presentation on the proposed bulletin relating
           to the vessel head penetration cracking.  At that
           time, we wrote a letter to Chairman Meserve indicating
           that the bulletin was both appropriate and timely. 
           Bulletin 2001-01 was issued on August 3, 2001.
                       In the response back to us from the staff,
           it was indicated that the update on the staff
           assessment will be given early next year.  That's
           2002.  Because of the urgency and importance of this
           issue, the committee decided to request an interim
           presentation on the status of various issues that came
           up in the July meetings.  These issues included risk
           assessment, prioritization algorithms, evaluation of
           inspection methods, responses to the bulletin and
           question of cracking initiation and kinetics, both for
           the axial and circumferential cracks.
                       Therefore, the purpose today is to hear
           generic discussion of these issues.  There's no plan
           at this stage to issue a letter.
                       As you heard from the Chairman, NEI has
           requested -- I'm just looking for the Member from NEI
           -- has requested to make a statement.  We'll hear that
           statement at the end of the industry presentation.
                       We'll begin with Larry Mathews from MRP.
                       MR. MATHEWS:  My name is Larry Mathews. 
           I'm with Southern Nuclear Operating Company.  I'm the
           Chairman of the Alloy 600 Issues Task Group of the
           Materials Reliability Program.  
                       I'm just going to provide an update on a
           few issues of where the industry is on some of these
           issues with respect to the head penetration cracking.
                       Some of the topics I'm going to address
           quite briefly is the crack growth rate in the annulus
           environment, not the details of what we're doing in
           that regard; the risk assessment, where we stand on
           that; inspection impacts on susceptibility.  We've had
           several plants inspected this fall.  Does that have
           any impact on our rankings?  Recommendations that we
           may be making for the spring outages and the ASME code
           activity that's going on.
                       In the area of crack growth rate, I'm not
           sure if I told you this last time, but I think, I
           believe I did.  We were convening an expert panel to
           try and assess what's the appropriate crack growth
           rate to use when evaluating this phenomena.  That
           panel, which consists of members from all over the
           world, convened for the first time in August, kind of
           an introductory, get to know what they're going to do
           meeting.  Then they had a second multi-day meeting in
           Airlie in October, the first part of October. 
           Numerous phone calls and discussions have taken place
           amongst those Members since then and they produced the
           first draft of a report on Alloy 600 on October 22nd.
                       As the industry reviewed that, we had
           many, many comments on the structure and the content
           of the report.  Those are being incorporated and not
           just us.  Dr. Shack had comments on the thing too, so
           those are being addressed.  The second draft is
           expected out next week and we're scheduling the report
           on crack growth rate from the expert panel for
           publication at the end of this month.
                       MEMBER FORD:  In terms of communication,
           ease of communication, has any of this information
           from this expert panel been transferred to the NRC
                       MR. MATHEWS:  I don't believe we've sent
           the draft to them yet.  Dr. Shack was on the committee
           and I believe he's seen the draft of the report, first
           draft of the report and so that's as far as it goes. 
           We haven't sent anything else yet, but we've gone back
           and tried to incorporate and I'll get into some of
           what we've tried to do.
                       MEMBER FORD:  The reason for my question
           is because of the urgency, I just want to make sure
           there's plenty of backwards and forwards.
                       MR. MATHEWS:  Yes.  I guess the extent of
           that is Dr. Shack has been given the draft and
           commented on it.
                       MEMBER FORD:  Sure.
                       MR. MATHEWS:  The process they went
           through was they established some data screening
           criteria.  There's lot of data out there on Alloy 600. 
           Not all of it is of the same quality so the expert
           panel established some criteria for selecting the data
           sets and then the data sets that were to be used were
           selected and initially a best fit curve was put in the
           report and that was it.  Some of the comments from the
           industry were we need to put in the kinds of curves we
           need to address, what the data is going to be used
           for.  So some of the curves that are being
           investigated at the moment are heat to heat
           variability, is there some effect there that needs to
           be accounted for; the widespread in the data, there is
           a very wide spread in the data; what amount of
           conservatism needs to be put into the curve if you're
           using it for deterministic evaluations; is that the
           right same curve or should you use a different curve
           if you're doing probabilistic evaluations?  And also,
           the annulus environment.  
                       One of the things -- the things the expert
           panel has determined is that the environment that is
           possible in the annulus after a leak established is
           about the same as a primary water as far as the impact
           on crack growth rate.  And it doesn't matter that much
           where the boiling transition takes place inside the
           crack, at the exit.  The only times there's potential
           any impact, as I understand it, is when the boiling
           transition is right at the crack.
                       MEMBER FORD:  I recognize you don't have
           very much time today and obviously we'll be having
           another meeting with the Materials Subcommittee.  We
           have a whole day to go through all the ins and outs of
                       Can you give us some feeling about where
           you stand right now in terms of the choice of a
           disposition curve for both axial and circumferential
           cracks?  Is it going to be a mean?  Is that the way
           you're moving?
                       MR. MATHEWS:  I doubt that it will be a
           mean for a disposition curve or for probabilistic,
           we're still trying to decide.  It may be a mean for a
           probabilistic evaluation, but even there you have to 
           -- we have to look at what's the effect of heat to
           heat, how do we really handle those kinds of
           variations and I don't think it will be a mean curve
           for disposition.  There will be some conservatism in
           a disposition curve, but then again we're not really
           talking about dispositioning a circ flaw above the
           weld.  Those will typically be repaired and so we're
           not going to find one and try and figure out how long
           we can run with it.  We can't run with it.  So what we
           do there will be different than if it's a short axial
           flaw and we're trying to disposition that then there's
           also the dispositioning of the hypothetical flaw and
           we've got to figure out how to handle all of that.
                       MEMBER FORD:  I was just looking through
           your presentation here.  This is the only slide there
           is because there's no data and there's a lot of
           technical discussion necessary.
                       When do you think you'll be ready to
           discuss this?
                       MR. MATHEWS:  We're intending to try to
           publish this by the end of the month and we will have
           discussions in our meeting that's scheduled with the
           NRC at the end of the month on the 27th.
                       MEMBER FORD:  Thank you.  
                       MR. MATHEWS:  The second draft is due out
           next week.  Hopefully, we will -- that will be the
           final one or shortly thereafter we'll be able to
           publish it.
                       One of the things we found out yesterday
           or it appears that there may be some differences in
           the data sets that have been used by the staff and the
           ones that the expert panel used, so those things have
           to be addressed very quickly I think.
                       MEMBER FORD:  Okay.  
                       MR. MATHEWS:  Anything else?
                       MEMBER FORD:  Well, there's lots and lots
           of questions.
                       MR. MATHEWS:  That is the only slides I
           have on the crack growth rate and that's a very
           important topic because it drives a lot of stuff and
           we need to reach resolution on that area and we
           recognize that and we're moving toward that as fast as
           we can.
                       In the area of risk assessment --
                       MEMBER POWERS:  Maybe I don't understand
           quite.  What is it that's so crucially dependent on
           knowing the crack growth rate?
                       MR. MATHEWS:  How long you have -- well,
           the crack growth rate can have impacts on reinspection
           intervals.  It can have impacts on how long you can
           run, once you find an acceptable flaw, how long does
           it remain acceptable and those kinds of things.  And
           it also has an impact on the probabilistic fracture
           mechanics that you fold into your industry risk
           assessment.  It drives and feeds into a whole bunch of
           aspects of this issue.
                       MEMBER POWERS:  Yes, as long as one is
           willing to operate the flaws, I see that.
                       MR. MATHEWS:  Yes.  Well, even if you're
           trying to assess the probability of core damage or the
           frequency of core damage on the mere presumption that
           there may be a flaw.
                       MEMBER POWERS:  It will usually come out
           three times the life of the universe or something like
                       MR. MATHEWS:  We hope so.
                       MEMBER POWERS:  Doesn't mean I believe
           them, but that's the way they always come out, so it
           doesn't matter what number you put in.
                       MR. MATHEWS:  Well, in the area of risk
           assessment, the preliminary work was performed for the
           various plant types, some preliminary work.  We had a
           meeting this week to finalize our approach for the
           industry and how to bring these various approaches
           that were put together.  
                       What we're looking at is using industry
           statistics for probability of a thru-wall flaw versus
           time to get -- that gives you then the probability of
           initiating a thru-wall flaw.  Then we're using
           probabilistic fracture mechanics to determine the
           probability of crack propagation versus time from the
           time of the leak to the thru-wall or the rupture.
                       The conditional core damage probabilities
           for results of LOCA and rod ejection will be assessed
           from either generic industry numbers or plant specific
           numbers and those should include any effects of
           collateral damage that may happen.  And then finally,
           the core damage frequency --
                       MEMBER POWERS:  I don't understand your
           language here.  You have probability fracture
           mechanics for probability crack propagation versus
           time from leak to thru-wall or rupture.  
                       I mean if it's leaking isn't it through
           the wall?
                       MR. MATHEWS:  There's a couple of ways to
           get a leak and if you had a leak through the weld, the
           thru-wall we're talking about here is thru-wall in the
           direction that could lead ultimately, if it grew far
           enough to an ejection.
                       You can get water on the outside in the
           annulus region by a leak through the weld that's an
           axial leak that does not threaten the ejection of the
           rod.  Then what we're talking about is using from the
           time you've got that leak to the time that the crack
           could turn circumferential and grow through the wall
           and/or grow all the way around until it ejects.
                       MEMBER POWERS:  It's really not thru-wall
           so much as being circumferential.
                       MR. MATHEWS:  Yes, thru-wall in the plane,
           that is a circumferential flaw.  You can get a leak
           from an axial flaw which has no -- does not threaten
           a LOCA or an ejection.  Once you get that, how does it
           grow back toward the potentially dangerous flaw of the
           circumferential flaw all the way around.  And the
           thru-wall component, they're talking about there, how
           does that crack propagate until it's a thru-wall
           position.  Well, it just goes -- we propagate it
           probabilistically all the way until it gets to the
                       MEMBER POWERS:  I'm trying desperately to
           remember language of general design criteria, but it
           seems to me once we have a leak, we are in violation
           of having a leak type primary piping system.
                       MR. MATHEWS:  Yes.  We're not arguing
                       MEMBER FORD:  Larry, at the meeting we had
           both to the Materials Subcommittee and then to the
           Full Committee earlier this year on this particular
           topic, you came under a fair amount of fire, I seem to
           remember, for the assumption that you made on
           initiating event frequency.  Since that time I know
           Oconee has given a public meeting here to the staff on
           that issue.  
                       Could you, for the members, give a kind of
           bottom line conclusion from that meeting?
                       MR. MATHEWS:  I'm not sure -- I wasn't
           there, and I'm not sure I know the specifics of what
           they presented at that meeting.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  They were -- I have seen
           numbers of -- in one of the approaches, one and a half
           flaws for an assumption, but that's for a given set of
           plants at a given point in time.  Most of the other
           plants were much, much lower on the susceptibility
           curve and therefore the probability of having a leak
           at this point in time.
                       And what we're trying to assess is that
           probability starting now and into the future for each
           and every unit and you can use the data that has been
           gathered on the plants that do have leaks and the
           plants that don't have leaks at this point in time to
           come up with some distribution and I believe there's
           a wide distribution that they're trying to use to come
           up with a --
                       MEMBER FORD:  But there will be a uniform
           industry argument on this particular risk assessment
           issue for discussion with the NRC staff?
                       MR. MATHEWS:  Yes, there will.  That's our
                       MEMBER FORD:  And that will be presumably
           by the end of this month, November?
                       MR. MATHEWS:  No, no.  That was the crack
           growth rate.  It's going to take a little bit longer
           to get all of this pulled together.  It's probably
           going to be in the January time frame.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  Before spring outages for
           the most part, we should have some results.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  We've seen this curve
           before, except that I've changed it a little bit and
           I put up there who has which units have leaks, which
           units have had cracks, but have not discovered leaks
           on their head, which units have done visual
           examinations with no leaks and then the ones that are
           later.  It's hard to see up close, so I got it blown
           up for the first 30 years.  This was our ranking of
           the units and when we put it together it was a quite
           simple ranking.  We all know time and temperature of
           the head and if you look at the plants that have had
           leaks to date --
                       CHAIRMAN APOSTOLAKIS:  Could you explain
           a little bit.  Don't assume we know.
                       MR. MATHEWS:  Okay, I'm sorry.  This
           bottom axis is the effective full power years that it
           would take a unit normalize to 600 degrees Fahrenheit
           head temperature to reach the same effective full
           power years calculated for Oconee 3 at the time they
           shut down and discovered their numerous flaws at
           Oconee 3.  So we use Oconee 3 as the base point and
           then we normalized all the plants to that same, to an
           effective full power year number that would be
           equivalent to an equivalent head temperature of 600
                       Using that then, we just ranked the plants
           as far as how far away they were in time until they
           would reach that same equivalent time at temperature.
                       CHAIRMAN APOSTOLAKIS:  So if I go to EFPY
           10 and I go up and I find 20 on the left --
                       MR. MATHEWS:  Okay that means --
                       CHAIRMAN APOSTOLAKIS:  What does that
                       MR. MATHEWS:  What that means is that the
           highest ranked 20 units in the country are less than
           10 years from being equivalent to Oconee 3.
                       CHAIRMAN APOSTOLAKIS:  The highest ranked?
                       MR. MATHEWS:  Right, or if you go up the
           left column, 20, the 20th ranked plant, if you rank
           them sequentially, the 20th ranked plant would be 10
           years away from Oconee 3.
                       CHAIRMAN APOSTOLAKIS:  They would be
           weighed in what sense?
                       MR. MATHEWS:  It would take 10 more years
           of operation, effective full power years of operation
           at their head temperature to reach the same time at
           temperature equivalent as Oconee 3 normalized to the
           600 degrees.
                       CHAIRMAN APOSTOLAKIS:  I see.
                       MR. MATHEWS:  So it's just a way that we
           could rank plants based on time and temperature, how
           far away are they from being equivalent to Oconee 3
           and the number up the side is just the rank order of
           the units.
                       CHAIRMAN APOSTOLAKIS:  Now what I see
           there at that point is a circle, a green circle and up
           there it says later.
                       MR. MATHEWS:  And that means that that
           unit has not had an outage done and inspection of
           their vessel head to date since Oconee 3 and since we
           put this February 2001 was our normalization point.
                       VICE CHAIRMAN BONACA:  Now I see a 6, I
           see one unit with a triangle there, a red triangle?
                       MR. MATHEWS:  Right, and that unit has
           done an inspection of their head.  I believe it was
           this fall and discovered a leak on their head, at
           least one.
                       VICE CHAIRMAN BONACA:  So although it
           would take 6 years for it to get to the same
           temperature --
                       MR. MATHEWS:  Same time.
                       VICE CHAIRMAN BONACA:  Oconee still has
           leaks.  Why wouldn't that plant -- I'm trying to
           understand that the reference is to Oconee.
                       MR. MATHEWS:  Well, we can change the
           reference.  If we change the reference all that does
           is move Oconee to a negative number.
                       VICE CHAIRMAN BONACA:  Okay, I see.  All
                       MR. MATHEWS:  We just selected Oconee 3 at
           that point in time because it was the worse cracking
           that we had observed to date at the time we put the
           initial --
                       VICE CHAIRMAN BONACA:  It's logical, all
                       MEMBER FORD:  At the time this was thought
           about, the temperature time algorithm was a reasonable
                       MR. MATHEWS:  Yes.
                       MEMBER FORD:  As you stand right now, are
           there any surprises from the algorithm telling you
           that there's something physically wrong with it?  In
           other words, just glancing at it, it seems that you
           don't have any red triangles all the way to the right. 
           Thank goodness.
                       MR. MATHEWS:  That's true.  There are no
           red triangles to the right.  We do have some blue
           diamonds to the left, at least one or two and have
           done visual exams of their head and not discovered
                       MEMBER FORD:  Right.
                       MR. MATHEWS:  We have some other green
           circles over there that haven't looked yet.  We have
           plenty of "haven't looked yets" right in here.  So --
           and on out.  So we don't see anything, I don't see
           anything here that really surprises me and says the
           model that we're using is just a totally ineffective
           way to address the issue.  The plants that have
           discovered leaks are the plants that are high in the
           susceptibility ranking here at time and temperature.
                       There are plants, we're starting to get
           into plants that don't have leaks or don't have
           observed leaks that are intermingled here.  It's not
           a perfect model by any stretch of the imagination, but
           we are starting to get to the point where we're seeing
           some that don't have leaks.
                       MEMBER FORD:  Is there anything in these
           observations that intimate that, for instance,
           different -- they're all hot head plants, but is there
           anything that would intimate that plants of a certain
           design would be more likely to crack than not at a
           given EFPY?
                       MR. MATHEWS:  Well, there are many leaking
           plants here.  Seven plants, I believe, here that have
           red triangles.
                       MEMBER FORD:  Right.
                       MR. MATHEWS:  Six of those plants are BNW
           design plants.
                       MEMBER FORD:  Yes.
                       MR. MATHEWS:  One of those plants is a
           Westinghouse-designed plant.  There's a wide variety
           of materials that were used to make the head
           penetrations throughout the industry, especially on
           the Westinghouse units.  So that's one of the things
           we're starting to look at, is there some segregation
           of the population that we could do.  One of the plants
           that did have a leak, their cracks were entirely
           contained in the weld metal and so we have to say
           well, do we know enough to talk about the specifics of
           the weld metal for all the rest of these plants or is
           time and temperature going to ultimately be the thing
           we use all along.  And we're not sure yet.  We're
           assessing the data continuously as it comes in.
                       VICE CHAIRMAN BONACA:  Given that you have
           this dependency evidently.  I mean most of the red are
           for one type of plant.  Is it reasonable still to put
           all these kind of different designs, etcetera on the
           same plot?
                       MEMBER FORD:  That's the reason for my
           question is can you read out from that that there is
           a --I don't know, a heat to heat or a fabrication
                       MR. MATHEWS:  Certainly, we hope to
           ultimately to be able to figure out what those
           parameters are and characterize them and start to sort
           this data into bins.  And we've already sorted -- not
           this data, but we're starting to look at well, who has
           what type of material, what type of tubes and as we
           get more inspection data, a lot of the types we don't
           have much inspection data on yet, but as we get more
           inspection data, we'll be able to say well, this
           doesn't look quite as susceptible as it should be, you
           know.  We should be seeing some indications here and
           we don't.  So we can maybe sort that out.  But at this
           point in time we don't think we have enough
           information to start to do those discriminations.
                       MEMBER FORD:  But based on the data you
           have so far, the historical data you have so far, it
           is real to suppose those three open circles run about
           3 EFPY if they were inspected, you would expect to see
           cracks, based on that data?
                       MR. MATHEWS:  I would say it wouldn't
           surprise me to see cracks there.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  Because they're not --
           there's material variabilities, etcetera there.
                       MEMBER FORD:  Sure.
                       MR. MATHEWS:  And it wouldn't surprise me
           to see some cracks, but it's not going to surprise me
           to not see some either.
                       MEMBER FORD:  Thank you.
                       MR. MATHEWS:  When we look around the
           industry we already have several plants that have
           decided that it's the right thing for them to do,
           based on their ranking and their decision making
           process, etcetera, that they should be doing some
           under the head NDE inspections and part of that could
           be tied to the difficulty that they would have doing
           a visual inspection because of their particular
           insulation package, but we have several of these
           plants that have already told us that they probably
           will be doing inspections this next spring and next
           fall and we have a draft industry inspection program
           under review where we're trying to say is this enough,
           we're looking at the ones that are volunteering and
           saying is this enough?  If not, what do we need to do
           as an industry and we're working on that right now and
           that program is under review and when we get through,
           if it's a published recommendation we'll be sharing
                       MEMBER FORD:  On that basis and I'm
           referring back to the previous one, do you remember we
           asked whether it was possible to improve this
           prediction algorithm.
                       MR. MATHEWS:  Yes.
                       MEMBER FORD:  Are there -- where do you
           stand on that right now or do you not see any reason
           to improve it at this time?
                       MR. MATHEWS:  We'd love to be able to
           separate the whole rest of the fleet from the ones
           with the red triangles, but do we have the data now to
           do that?  We don't.  We need some more data to be able
           to sort out and figure out which plants might be able
           to be separated and which ones belong in the same
                       MEMBER FORD:  I recognize it's a complex
           problem, but from a cost-effectiveness point of view,
           is there any point in continuing with that effort to
           try and improve on the --
                       MR. MATHEWS:  Improve on the modeling?
                       MEMBER FORD:  Yes.
                       MR. MATHEWS:  Well, it's pretty simple to
           do this model.
                       MEMBER FORD:  I'm sure.
                       MR. MATHEWS:  And as we get into it, you
           have to look at the parameters you're looking at.  If
           you've got great lab data on a parameter, but you
           don't know what it is in the field, there's no point
           in chasing it and so we're -- that's like the welds. 
           If we knew exactly what properties caused the weld to
           crack, that may or may not be of any benefit if you
           don't know what the properties are for all the plants.
                       MEMBER FORD:  Sure.
                       MR. MATHEWS:  So that's the kinds of
           things we're having to weigh, but right now we're
           still going with the time and temperature and trying
           to gather data.  We know what the subsets are as far
           as materials, etcetera, but right now we're still
           having them write this way.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  As far as the long range,
           NRC has indicated that the inspection criteria for
           head penetration area in the ASME section 11 code is
           potentially inadequate or has been over the years,
           although we haven't really had an action because of
           that, but they feel that it needs to be modified.  So
           Section 11 has established a working group to look at
           the Alloy 600 inspection requirements that are in the
           Section 11 code right now.  They met at the last
           Section 11 meeting and they'll be meeting again at the
           December meeting and I believe there's at least one
           draft of something that they'll be discussing at the
           December meeting.
                       I'm not sure how quickly the code moves,
           but ultimately, long range down the road, I believe
           Section 11 will have some requirements that they will
           put into place that will be a long range inspection
                       We need to work with them because some
           plants are replacing heads and they're using much more
           resistant material, so we need to figure is that the
           right -- make sure that whatever gets into the code
           for inspection doesn't overpenalize people who go into
           proactive or necessary head replacements.
                       That's all I have.  I have used my half
           hour almost exactly.
                       MEMBER LEITCH:  Just one quick question. 
           The visual with no leaks, the blue dots on your
                       MR. MATHEWS:  Yes.
                       MEMBER LEITCH:  Refresh my memory, what
           does that mean?  You looked for boron and found none? 
           That was the extent of the examination?
                       MR. MATHEWS:  Yes, that's what it means
           but it was at least an effective visual which means
           that you got a good hard look at metal to metal
           interface where the penetration goes inside the
           interference gap on the head.  And saw no evidence of
           leakage on all of those plants.
                       Now NRC's requirement was that we
           absolutely demonstrate for plants less than 5 years if
           you were doing a visual that it be a qualified visual
           which means you demonstrate it would leak and for the
           others out to 30 years they didn't require that
           demonstration at this point.
                       Some of these plants have done some work
           to demonstrate that they believe most, if not every
           single one of their penetrations would leak if they
           had a crack.  Others have not done that to date.
                       MEMBER LEITCH:  Okay, thank you.
                       VICE CHAIRMAN BONACA:  Just before you
           take it down, of these plants, how many of them have
           exhibited this circumferential cracks?
                       MR. MATHEWS:  I believe three plants had
           circ flaws:  Oconee 3, Oconee 2 and Crystal River.
                       VICE CHAIRMAN BONACA:  So they are spread.
                       MR. MATHEWS:  Two of them are real close
           and then the other one is out.
                       MEMBER FORD:  The uppermost triangle is
           Crystal River, uppermost red triangle?
                       MR. MATHEWS:  I believe.
                       MEMBER ROSEN:  You said that the small
           cluster is down between 0 and 5?
                       MR. MATHEWS:  These three.
                       MEMBER ROSEN:  If you found the plant in
           that group that had a leak, that it wouldn't surprise
           you, am I right?
                       MR. MATHEWS:  Right.  It would be
           consistent with the data from the other plants.
                       MEMBER ROSEN:  Now what about the next
           open circle that you see up around 6 or the next one
           after that, 7th.  If they had a leak, would that
           surprise you?
                       MR. MATHEWS:  It becomes more and more of
           a surprise the further to the right you go.
                       MEMBER ROSEN:  That's what I'm trying to
           figure out.  What is your crack definition?
                       MR. MATHEWS:  I don't have one.  I don't
           know.  The data is out there.  We're trying to gather
           the data to figure out where it is.
                       We didn't try to use this as a predictive
           model to say this plant will leak in X number of
           years.  What we were trying to do is say these are the
           plants that -- on a time and temperature basis any
           way, the highest in rank and they're the ones we
           really need to be concerned.
                       MEMBER ROSEN:  I know from listening to
           you that the ones below 5 would surprise you and I
           think if you saw a crack between 25 and 30 that would
           surprise you.  The ones between 25 and 30 would
           surprise you.  The ones between 0 and 5 would not.  So
           I have two points on the curve.
                       CHAIRMAN APOSTOLAKIS:  Are you plotting
           being surprised?
                       MEMBER ROSEN:  I'm trying to figure out
           when we should say oops, this isn't working.
                       MR. MATHEWS:  I think a leak in the 30-
           year time frame certainly would warrant, whoa, what's
           going on, a whole bunch more, no leaks down in the 5
           to 10 year range doesn't.
                       MEMBER ROSEN:  Yeah.
                       MEMBER FORD:  You are looking at how a
           scatter band of depths is impacting over time and so
           you expect if all the plants were exactly the same
           design, manufacture, there should be a clear cut, but
           they're not.  Is there any reason -- the reason I'm
           asking the question, between cracking and no cracking
           on that curve.  That's why I asked the question can
           you put a normal cut between, for instance,
           Westinghouse and Babcock on that?  
                       MR. MATHEWS:  Part of the unfortunate
           thing about trying to do something like that is all of
           the BNW units happen to be very high in the ranking on
           time and temperature.
                       MEMBER FORD:  Because of time primarily. 
           These are 600.
                       MR. MATHEWS:  Just from a time and
           temperature basis, they're very high in the ranking.
                       MEMBER FORD:  Right.
                       MR. MATHEWS:  They were all built fairly
           close together in time.  They all run with fairly high
           head temperatures relative to the rest of the industry
           and so when you couple those, it pushes most of the
           BNW units --
                       MEMBER FORD:  It is primarily time, isn't
           it, Larry, because most of these are 600 plus or minus
           2 head temperatures.  Is that correct?
                       MR. MATHEWS:  Well, some of these units
           are probably even on down into the 590, 580 range.
                       MEMBER FORD:  Okay.
                       MR. MATHEWS:  Well, maybe not these. 
           These may not be down in the 580, but some of the
           plants on the higher end up here are in the final --
                       MEMBER ROSEN:  Some are even lower than
                       MR. MATHEWS:  Yes.  If you look at the
           curve for the entire fleet it goes all the way out. 
           Most of these plants are designed such that their head
           temperatures are calculated to be very near the cold
           lake temperature.
                       MEMBER ROSEN:  Right.
                       MR. MATHEWS:  And these are either hot
           head or warm head plants.
                       MEMBER ROSEN:  Right.
                       MR. MATHEWS:  The Westinghouse design
           diverts a little of the cold lake flow up there and it
           varies from design to design.  But most of these
           plants out in here have what we call cold heads. 
           Their heads have enough cold lake flow diverted to the
           head and they're operating at significant lower head
           temperatures than most of the other fleet.
                       MEMBER ROSEN:  Okay.
                       MR. MATHEWS:  Now the BNW designs tend to
           be even on the high end of the head temperatures, over
           600 and most of the Westinghouse plants are a few
           degrees under 600, NCE plants.
                       MEMBER ROSEN:  Okay.  Have you got all the
           inspection results in for the fall outages that's
           shown on this curve?
                       MR. MATHEWS:  I believe North Anna 2. 
           Well, we've got all of them that are complete.  And
           we've got all of them that are -- I believe all of
           them that have discovered any leaks, even if they're
           not completely through with their exam is on there. 
           There's a few units that are down now that have not
           finished their exam and I don't know if they've found
           anything or not.  So --
                       MEMBER ROSEN:  I'm going to take your
           answer to mean there may be some new data yet from
           this set of fall outages.
                       MR. MATHEWS:  Absolutely.
                       MR. BANFORD:  There's one more green
           diamond in the less than 5 year.
                       MR. MATHEWS:  Green circle.
                       MR. BANFORD:  That we just became aware of
           about two days ago.  Warren Banford from Westinghouse. 
           So one of the three open circles in the 0 to 5 is now
           a green circle.  
                       MR. MATHEWS:  A blue diamond.
                       MR. BANFORD:  Or a blue diamond.  
                       MR. MATHEWS:  Visual with no leaks.  I
           guess that that's within the last two or three days
           that that came out.
                       Well, it won't change the color.  Oconee
           is down and I don't know how I'm going to plot this
           when -- if they come down and don't find anything this
           time, how do I plot that.  Successful repair.
                       MEMBER FORD:  I'd like to bring this one
           to a close unless there's any urgent questions.  But
           is it my understanding, Larry, that by December if we
           had a Materials Subcommittee meeting in December, you
           would have a full technical data presentation on the
           -- at least on the cracked assessment?
                       MR. MATHEWS:  Crack growth rate?
                       MEMBER FORD:  Yes.
                       MR. MATHEWS:  I think we can --
                       MEMBER FORD:  And the annulus would not be
           a waste of time, I believe to have a meeting at that
           time if that's what we decide.
                       Larry, thank you very much.  I'd like to
           call upon now Steven Moffat of Davis-Besse.  I think
           it's 10 minutes.
                       MR. MOFFAT:  Thank you.  I have a power
           point type presentation that starts with Davis-Besse. 
           Again, I'm Steve Moffat from Davis-Besse.  I'm the
           Director of Technical Services.
                       With me is David Geisen and Ken Byrd who
           are on our staff.  We also have several of our subject
           matter experts who contributed from an industry
           perspective to our discussion this morning with us in
           the audience.  First off, I'd like to sincerely thank
           the ACRS for allowing us this opportunity to give what
           could be characterized as a case study of some of
           these diamonds we just saw as relates to Davis-Besse.
                       Our objective today is to have ACRS
           consider additional industry information as it
           deliberates on the Control Rod Drive Nozzle cracking
           issue.  Obviously, this is an evolving issue.  There's
           information we recently got from the staff on
           positions relative to this issue and we'd like to
           include the additional information today in formal
           correspondence to the NRC that may be related to
           regulatory action.
                       As we heard Larry talk about consensus
           documentation at this point in time, what we have done
           is used the best industry data we could in order to
           determine what would be appropriate action for us
           based on the safe operation of our power plant.  Our
           reason for request is that Davis-Besse is considered
           a high susceptibility plant as discussed in Bulletin
           2001-01, specifically the time and temperature model
           puts us within three years of -- actually, slightly
           over 3 years of the adjusted Oconee 3 data that we saw
           a minute ago.
                       MEMBER FORD:  So you're one of those open
                       MR. MOFFAT:  We are one of the "to be
           inspected" --
                       MEMBER FORD:  To be inspected open
                       MR. MOFFAT:  Yes sir, that's right.  And
           as indicated here, we are the only high susceptibility
           plant that's ranked by the Bulletin that will not
           perform a visual inspection by December 31 of 2001 and
           we've used these subject matter experts, as I
           referred, to assess the impact of the continued safe
           operation of our plant until our next scheduled
           refueling outage which is currently scheduled for the
           end of March of 2002.
                       As far as Dave is essentially a
           deterministic engineer and Ken is a probabilistic,
           some of the discussions will go in that area in my
           brief presentation.  As far as the deterministic, we
           believe we have what could be characterized as
           qualified visual inspection that was performed in 1996
           and additional inspections in 1998 and 2000.  My
           reason for using that terminology is that we had done
           inspections of the head for other reasons, however,
           the people that did the inspections are available and
           we, in fact, videotaped the heads which we have
           subsequently reviewed in light of the information that
           evolved as part of Bulletin 2001-01.  So this provided
           us an opportunity to put a new set of eyeballs, if you
           will, on the historical issue at hand.
                       What we did with the 1998 and 2000 is
           essentially utilize that data, albeit limited in our
           probabilistic assessment of the risk associated with
           this issue.
                       As Larry indicated earlier, the majority
           of our nozzles through out own plant-specific finite
           element analyses show that they would open which
           essentially means the visual efficacy of the
           inspection was adequate.
                       MEMBER POWERS:  I guess, maybe I don't
           understand that quite.  I guess I have a couple of
           questions about that.
                       MR. MOFFAT:  Certainly.
                       MEMBER POWERS:  If I go in and I look at
           these regions and I don't see anything, what is the
           likelihood that there is, indeed, a crack there I just
           didn't see it. 
                       MR. MOFFAT:  The likelihood due to the
           fact that we did specific finite element analysis is
           extremely low because the analysis shows that should
           there be a crack and pressure --
                       MEMBER POWERS:  It has nothing to do with
           my vision and your finite element analysis.  If I go
           in and look at your head and I don't see anything,
           what's the probability that I just missed the crack?
                       MR. MOFFAT:  That human error probability
           Ken will discuss momentarily, Mr. Powers.  We did
           include that in our probabilistic safety analysis for
           essentially the ability of a human to detect that. 
           What this is is more of a mechanistic assessment that
           says should there be a flaw, would we be able to
           detect that with on head leakage.  That's what I'm
           referring to by the 56 and 69.
                       MEMBER POWERS:  Well, your finite element
           analysis shows what?
                       MR. MOFFAT:  We looked at the 69
           penetrations and of those, 65 of them would open up
           enough so that we would have a sense as characterized
           as qualified that we could detect a flaw through
           visible leakage boron deposit.
                       MEMBER POWERS:  All right.  Thank you.
                       MR. MOFFAT:  Additionally, we perform our
           own plant specific analysis that essentially would
           look at the end point as it relates to safety factor
           of 3 using the code we've discussed previously and
           have a number that's slightly bigger than the industry
           data to date as it applies to Davis-Besse.  That
           number is 302 degree flaw as safety factor of 3.
                       We also believe --
                       MEMBER FORD:  Excuse me, physically, what
           allows you to make that difference in material
           properties?  I mean what's the --
                       MR. MOFFAT:  I'll let you take that, Dave.
                       MR. GEISEN:  Well, we had the -- the
           analysis was done by Structural Integrity Associates
           and when they did their analysis they were looking at
           the -- using the fracture mechanics with the nozzles
           and looking at our worse case nozzle in our particular
           strengths of materials what does that take us out to.
                       MEMBER FORD:  So it's a larger qualifying,
           larger than you mentioned than who?  Industry average?
                       MR. MOFFAT:  Nominally 270 plus or minus
           several over here.  Quite a body of information
           yesterday, but that's the general characterization
           between roughly 260 and 272.
                       MEMBER FORD:  Okay.
                       MR. MOFFAT:  Additionally, in order to
           look back, as I said previously, with a new set of
           eyes, assumed an initial flaw size that would have
           occurred immediately subsequent to our 1996
           retrospective, if you will, and believe that we would
           still have a reasonable assessment that we can proceed
           until our refueling outage based on that initial flaw
                       And then finally the last deterministic
           aspect I'd like to go over briefly is just the fact as
           Larry was showing, we are over the three adjusted
           effective full power years plus at Oconee Unit 3. 
           Essentially, we're at roughly 6 EFPY as far as the
           EFPY, but as adjusted for time and temperature, we're
           a bit over 3.
                       VICE CHAIRMAN BONACA:  A question on the
           1998 and 2000 inspections, you said that they were
                       MR. MOFFAT:  Yes sir.
                       VICE CHAIRMAN BONACA:  What was the extent
           of the inspection?
                       MR. GEISEN:  I'll talk to that.  What we
           did is recognize -- this is Dave Geisen.  With regard
           to these inspections, recognize that they were not
           done looking for this particular phenomenon.  They
           were looking for other things.  The two inspections
           done in 1998 and 2000 were really looking for the
           impact of boric acid leakage from leaky flanges that
           we had subsequently repaired and what was the impact
           to that.  So the view that we got from those was in
           many cases some of the drives you couldn't even get a
           good view of.  
                       There were many cases, the camera angle
           was looking upwards because it was looking at the
           structural material of the service structure on top of
           the head.
                       When we looked at a 1996 data, you got
           more of a downward look at these nozzles because we
           were specifically following around a vacuum and probe
           that was looking for head wastage as result of the
           boron being deposited on head.  So what really comes
           down to it, the best video we have on this goes all
           the way back to 1996.
                       MR. MOFFAT:  So essentially those are some
           of the characteristics specific to our power plant as
           plant specific information, as we discussed, given
           that the body of knowledge related to this issue, what
           we've done is using Framatone and our own engineering
           staff, constructed a probabilistic safety assessment
           to help us gain an understanding of the significance
           of the issue as it pertains to our specific plant and
           for that, I would ask Ken Byrd to present.
                       MR. BYRD:  Davis-Besse has performed a
           plant specific risk assessment and we base this on the
           method developed by Framatone, however, we have worked
           with Framatone to make some improvements and we've
           also investigated some of the sensitivities to a
           greater extent with this method.
                       We acknowledge that there's a number of
           uncertainties with regard to some of the phenomena
           we're dealing with and in order to resolve those kind
           of uncertainties we had to make a number of bounding
           assumptions.  Consequently, the results we see here
           aren't necessarily consistent with our baseline core
           damage frequency.  These are actually numbers that
           would have to be looked at as kind of a bounding case
           for a core damage frequency.
                       I'll talk a little bit about how we did
           that.  Again, as more information is developed, we can
           hone this more accurately.  
                       Our results did come out.  Our core damage
           frequency, which again is a conservative number, came
           out in the category which would be considered small. 
           Our large early release frequency came out in the
           category that we considered very small and we did run
           this through our level 3 PSA and we came out with a
           negligible public health risk.
                       I might point out right now because
           results seem somewhat inconsistent with each other and
           we have a core damage frequency in one category and a
           large early release frequency, a public health risk
           that's much lower.  That's consistent with our plant-
           specific, what we would have expected.  We're a large,
           dry containment.  We have a relatively large
           containment relative to our core power.  The
           consequent that we placed on this was a medium LOCA
           and we would not expect a medium LOCA to have a
           significant impact on our containment.
                       For a large dry containment usually that's
           containment bypass or interfacing system LOCA or it
           could be kind of an event which affects a support
           system such as a loss of cooling or a station blackout
           and obviously this doesn't deal with any of those kind
           of circumstances.  It is not a significant release
           issue and certainly not a significant public health
                       Going on to my second page, what I did
           here was just listed a number of what I would consider
           the most significant bounding or conservative inputs
           that we use in order to deal with some of the
           uncertainty that's currently not been resolved yet. 
           Starting out with a nozzle leak frequency, we did base
           our nozzle leak frequency on information from the
           other BNW plants, but we applied this very
           conservatively so that our model estimates that right
           now we should have nine leaking nozzles and I think
           that bounds the rest of the BNW fleet.  Or actually
           that was the number that was found at Oconee 3 which
           is the maximum.  Obviously, that would be a lot of
           nozzles and we wouldn't expect that. 
                       The second thing we did was the
           probability of the outside dent diameter crack
           initiation.  We assumed that for every axial crack
           which gives leakage or every leaking CRDM nozzle, we
           would have an outside diameter crack initiated. 
           Actually, if you look at the data from the BNW plants,
           we've had 21 leaking nozzles.  Five of those have gone
           to circumferential cracking, so obviously not all of
           them have initiated circumferential cracking.  We're
           assuming in every case, we will get circumferential
                       MEMBER FORD:  Can I please interrupt for
           one second?  This hasn't been discussed with the staff
           yet, I understand.
                       MR. BYRD:  We've given them our analysis
           and presented and will discuss this afternoon.
                       MEMBER FORD:  That's just great.  
                       CHAIRMAN APOSTOLAKIS:  We have this
                       MEMBER FORD:  Could I suggest, this is
           really good input to the overall general thing which
           we're discussing today.  Maybe if you could just move
           to the bottom line.  You've obviously done a lot of
           work.  It's just fantastic.  And it's relevant, but it
           should be discussed with the staff.  Could I ask you
           to move to the end -- to your end conclusion maybe?
                       MR. BYRD:  Certainly.
                       MEMBER FORD:  Based on -- we read these
                       MR. MOFFAT:  I appreciate that.  I'll take
           it from here.  As Ken said, we've submitted this PSA
           to the staff and we are going to discuss it.  It is on
           the docket.  Looking at this as a topic, realizing
           that we are one of the ones within the three and where
           we sit from our understanding it becomes an issue
           essentially is our power plant safe to operate until
           March, as far as the basis between December 31st and
           March, as far as our best understanding of this issue
           and the expertise that we've brought to bear as a
           utility and a nuclear steam supply system, Davis-Besse
           nuclear power station believes that the plant is, in
           fact, safe to operate until March.  We don't believe
           that the distinctions between December 31st and March
           are an issue with regard to reasonable basis of
           safety.  So that's our bottom line that you asked me
           to get to.
                       MEMBER FORD:  I thank you very much
           indeed, sir, Mr. Moffat.
                       Are there any overall questions from the
           Members at this time, bearing in mind that it hasn't
           been discussed in detail with the staff.
                       Any questions?
                       CHAIRMAN APOSTOLAKIS:  I wonder what is
           the actual evidence of the plant regarding this issue? 
           I remember there were circuits there, but have you
           seen -- maybe I missed it, leaks or --
                       MR. MOFFAT:  What we were able to do, Dr.
           Apostolakis, by going back through the video tape was
           to do our best retrospective examination, knowing in
           light of what is known now of the characteristic which
           we not only call popcorn due to the nature of this
           leak.  You can tell, based on this body of evidence
           that we've acquired as an industry what it looks like. 
           So we essentially went back as best we could at those
           video tapes from 1996, 1998 and 2000 and that is the
           evidence that we have for the current condition of our
           plant.  We also use the Peter Scott model to then
           extrapolate what would bound that should something
           progress in that interim since we've had those visuals
           and that's some of the detail that we'll be discussing
           with the staff when Mr. Byrd has the opportunity
                       MEMBER ROSEN:  I'm going back to your
           second slide, your objectives.  
                       MR. MOFFAT:  Yes sir.
                       MEMBER ROSEN:  One was to have us consider
           the information that you presented here today and I
           think that clearly is being done.
                       Your second one was to include, have us
           include this additional information in formal
           correspondence to the Commission.
                       MEMBER FORD:  Well, we won't be doing that
           until the staff has come to us with their --
                       MEMBER ROSEN:  Yes, I don't think we're in
           a position to do that.
                       MEMBER FORD:  That is correct.  Not at
           this time.
                       CHAIRMAN APOSTOLAKIS:  It can still be an
                       What we do with it is a --
                       MEMBER POWERS:  As I understand it,
           they're fighting over four months.
                       MEMBER FORD:  Mr. Moffat, I thank you very
           much indeed.  I appreciate it.
                       MR. MOFFAT:  Thank you.
                       MEMBER FORD:  I'd like at this time to ask
           the representative from NEI, Alex Merrion to make a
                       MR. MERRION:  I'm Alex Merrion.  I'm the
           Director of Engineering at the Nuclear Energy
           Institute and I just have a couple brief comments.  I
           want to say something about the susceptibility model
           and my concern with -- and this is just an observation
           that people may be reading too much into it.  As Larry
           clearly indicated, it's a simple model primarily
           focused on two parameters, time and temperature, to
           try to represent an estimate of who may be susceptible
           to finding some kind of flaw should they do an
                       It's very simple from the standpoint of
           the kind of degradation mechanism we're talking about
           which is very complicated.  I think as we go through
           this, we need to keep that in mind because I find --
           I've seen where people in the industry have been
           looking at that susceptibility model as if it was
           founded in ground truth and try to make all kinds of
           conclusions from it.  I've also seen people outside
           the industry reading to much into it, so I felt
           obligated to make a comment about that.  
                       There was a public meeting held yesterday
           where the NRC staff provided their preliminary
           technical assessment on crack growth rate and I have
           to admit I thought it was an excellent meeting and
           it's not painful for me to make that admission, but it
           was very useful and I think beneficial from the
           standpoint of industry understanding what the staff's
           current thinking is and I think the NRC benefitted
           from some of the comments and interactions from that
                       And we will be providing comments to the
           NRC at a public meeting that's been scheduled for the
           27th of November on that.  We'll probably follow up
           with some formal communication with the staff and on
           that meeting on the 27th we'll provide a further
           update of the industry efforts of the material
           reliability project and deal with some of these
           questions that you raised regarding the chemistry and
           crack growth rate.
                       MEMBER FORD:  Excellent.
                       MR. MERRION:  And that's all I wanted to
           say and I thank you for the opportunity.
                       MEMBER FORD:  Any comments?  Thank you
           very much indeed.
                       MEMBER KRESS:  I have a question.  You
           mentioned that the susceptibility model is very simple
           for a very complex phenomena.  Am I to interpret that
           to mean it could go either way?
                       MR. MERRION:  Yes.  Yes, it can and we're
           in the process of collecting data.  That's why Larry
           was so cautious in making any kind of firm
           representation of what we know today because it could
           very well change with the next couple of inspections
           and it could go either way.
                       MEMBER FORD:  And I think it's also my
           understanding, however, that this idea of having more
           than just temperature and time, at temperature, in the
           algorithm to include weld conditions, heat conditions
           is very hard to do and many people have tried this
           over the last 20 years and have failed.  And this is
           the reason behind my question to Mr. Mathews, is it
           cost effective to try and improve on that?  Are you
           going to materially improve your prediction
           capability?  That was the reason.  You're absolutely
           correct, it's a question of whether we move forward.
                       I'd like to move on at this time to cover
           the NRC staff presentation.
                       MR. STROSNIDER:  I didn't have a lot to
           say as an introduction and given the time constraints
           we have, I just suggest that the staff start on the
                       I guess I could comment that this is a
           work in progress.  You've heard a little bit already
           with regard to need for some additional information,
           but we've been working with the data that are
           available and trying to pull that into some
           comprehensive models.
                       I'm Jack Strosnider from the staff and
           hopefully you'll get some flavor for that based on
           this presentation.
                       MR. HACKETT:  Good morning.  I'm Ed
           Hackett from the Office of Research and joining me at
           the table are Allen Hiser and Mark Reinhart from NRR.
                       We're going to try, as a team here, to
           give you a perspective for what the staff has been
           doing.  I guess especially since July as Dr. Ford
           mentioned.  So I was just going to start by
           summarizing a few items.  One was an independent group
           of experts, two of whom are here.  Your colleague, Dr.
           Shack, Dr. Gary Wilkauski here who assisted us in
           performing an independent evaluation of the cracking
           occurrences, Oconee and ANO.  We have also in the
           Office of Research continued to support NRR
           specifically in development of the technical
           assessment that was just mentioned that's in a state
           of development that's basically deterministic at this
           time point.  What I'm going to focus on briefly in
           this presentation is aspects of the probabilistic
           assessment in terms of probabilistic fracture
           mechanics, but the disciplines that are noted there
           are the ones that we're providing support on. 
                       If I could just mention briefly that the
           Office of Research has also provided inspection
           support to NRR, I believe for two inspections at Three
           Mile Island and also North Anna.  The bottom line of
           this presentation is that we're working towards and we
           did discuss this in July.  We have made some progress. 
           We're working on developing the elements of a
           probabilistic fracture mechanics assessment, as is the
           industry.  Structural Integral Associates has had the
           lead for the industry in that regard as far as I'm
           aware.  We had a conference call with Structural
           Integrity Associates led by Dr. Pete Riccadella on the
           27th of September.  I think that was very productive
           for both us and for the industry in terms of trying to
           get a baseline as to what's going on.  And Alex
           Merrion mentioned yesterday the public meeting we just
           completed which was also very beneficial.
                       Moving on, what we wanted to do is focus
           on some of the key considerations.  I think Larry
           Mathews and the representatives from Davis-Besse have
           covered a lot of this information.  In our
           deterministic assessment which the NRR deterministic
           assessment which was released yesterday, I believe,
           these are basically sort of the elements that went
           into what is Section 6 of that report, but obviously
           key to these types of assessments are the assumptions
           you're going to making on crack initiation and crack
           growth rates in specific.  In that particular area,
           Dr. Shack has had the lead for us in the contract work
           he's done.  There's also a lot of variability in the
           analysis of the stress state for this particular
           situation and the maintenance of the structural
           margins.  That's an area where Dr. Wilkauski and Dr.
           Richard Bass from Oak Ridge have helped us out
           significantly.  And then sort of the bottom line of
           this whole thing, that a number of the speakers have
           already mentioned is where does this go to in terms of
           inspection methods and maybe specifically timing is
           sort of the crucial element at this point for several
                       CHAIRMAN APOSTOLAKIS:  So what is the
           ultimate product of this analysis?  What is it going
           to be used for?
                       MR. HACKETT:  The ultimate product, at
           least in my mind, is a probabilistic assessment that
           would hopefully be able to give us guidance on exactly
           this bottom line, inspection methods and timing.  The
           actual, I think the representatives from Davis-Besse
           were heading there in their presentation and sort of
           where does this end up in risk space ultimately.  I
           don't think -- we're not ready to discuss that in
           detail today.  I don't think we're there yet and
           that's what I'm going to come to in the presentation,
           but I think that's where it's going.
                       CHAIRMAN APOSTOLAKIS:  So if I wanted to
           keep the probability of risk initiating event or
           frequency low, then this analysis will tell me how
           often I will have to inspect?
                       MR. HACKETT:  Yes.
                       CHAIRMAN APOSTOLAKIS:  And what to do?
                       MR. HACKETT:  Exactly.
                       CHAIRMAN APOSTOLAKIS:  And it will include
           things about the ability of the inspection method to
           get an accurate picture --
                       MR. HACKETT:  That would be factored in,
           would have to be.
                       MEMBER KRESS:  And what would the risk
           analysis tell you if you calculated just the
           conditional core damage frequency and the conditional
           large early release, given that you had the failure of
           these particular penetrations?
                       MR. HACKETT:  That's a good question and
           I might turn to my colleague, Mark Reinhart on that
                       MR. REINHART:  We've presented that just
           looking at the IPEs and updates of PSAs to date, the
           conditional core damage probability for the medium
           LOCA that we're projecting would result from this type
           of control drive mechanism ejection is in the 10-2, 
           10-3 range.  There's not a lot of debate on that.  The
           issue that Ed's really addressing is the initiating
           event frequency that we're having the problem with,
           but if you just assume one on that initiating event
           frequency, you end up with a CCDP.
                       CHAIRMAN APOSTOLAKIS:  So you will be able
           to say something about the frequency of a medium LOCA
           in this mechanism?  That's the whole purpose?
                       MR. REINHART:  That's where we're trying
           to go.
                       MEMBER KRESS:  But from an overall risk
           perspective, do your conditional probabilities tell
           you that it's not that big of a deal?
                       MR. REINHART:  I think 10-2, 10-3 is -- you
           can't just say that's not a big deal, if you have the
           event.  I think we're not comfortable just going along
           allowing this.  I think we want to --
                       CHAIRMAN APOSTOLAKIS:  Allowing this for
           how long?
                       MR. REINHART:  Right.
                       CHAIRMAN APOSTOLAKIS:  I mean allowing
           forever is --
                       MR. REINHART:  We don't want it to go
           undetected for --
                       MEMBER KRESS:  I was trying to decide
           whether there was a real urgency to the inspection and
                       MEMBER FORD:  I was about to address that
           specific point.  This is really a program management
           chart.  And if you look at Larry's temperature time
           plot, you can see that this is not a one off problem. 
           It's a generic problem and you're going to continue
           doing it.  So what is your timing on this to deliver
           this capability, analytical capability to the staff?
                       MR. HACKETT:  That's a good question.  I
           guess that one is mine.
                       CHAIRMAN APOSTOLAKIS:  The only ones you
           get here --
                       MR. HACKETT:  I'm looking at Gary
           Wilkauski at this one because we -- the short answer
           is we haven't exactly worked that out.  I think the
           sort of on-line answer to it would be I think pretty
           much we were hoping for around the same kind of time
           frame that Larry indicated, somewhere maybe after the
           turn of the year, but in all honesty, recognizing the
           complexity of this problem and we talked about
           surprises or not being surprised.  It wouldn't
           surprise me if we're still looking at some of this
           well into 2002, some of the aspects of it.  One of the
           things I'll come to and Dr. Ford as well, I think to
           really make some progress on this area Jack
           Strosnider, when we met last time talked about the
           dangers of the seductiveness of using a PFM analysis
           in this case and I think they're readily evident here
           that we're missing a lot of data is the bottom line
           and being able to generate all that data in the next
           six months or year, I don't want to be up here telling
           you we're going to do that.
                       MEMBER KRESS:  That's one reason I asked
           the question.  One way to prioritize would be the
           conditional probabilities, the ones that have a high
           condition probability you do first and you sort of
           bypass all this difficulty.
                       CHAIRMAN APOSTOLAKIS:  Well, there is
           another issue that, I don't know, maybe it's a 
           non-issue, but it just occurred to me, why should all
           these decisions be made on the basis of delta CDF and
           delta LERF?  
                       I mean the reactor oversight process tells
           me that the staff worries about the frequency of
           initiating events itself.
                       MEMBER KRESS:  Yes, but only because
           that's going to affect delta CDF and delta LERF.
                       CHAIRMAN APOSTOLAKIS:  They have declared
           that they don't want to see higher frequencies
           independently of what happens.
                       MEMBER KRESS:  That's a defense-in-depth.
                       CHAIRMAN APOSTOLAKIS:  Yes, 
           defense-in-depth.  So why don't we apply that here and
           say okay, the 10-2 or 10-3 conditional core damage
           probability is a useful input, but I really don't want
           the frequency of the medium LOCA to be too large.  So
           on the basis of that, I will also make a decision.  Is
           that -- are we just using regulatory guide 1174 here
           or are there more issues?
                       MR. STROSNIDER:  This is Jack Strosnider
           and I'd like to make two comments with regard to this
                       First of all, the question on schedule. 
           And I think with the problem this complex, it's clear
           that we can continue to do research and collect data
           and try to refine our analysis for a long time.
                       The practicality and reality of the
           situation is that we need to set some priorities and
           we're going to be looking at that such that we can
           have some analyses early next year that will help
           inform what the appropriate inspection intervals and
           timing is.  And I put that in the context of
           recognizing that the bulletin that's being discussed
           is just a one time action, right?  And the industry
           and the NRC still have to develop and come to
           agreement on what the longer term program is for
           managing this issue.  And that has to happen next --
           in 2002.  All right?  Because people will have to be
           making decisions in 2002, so we have to position
           ourselves in early next year to have the most
           important information and the best information we can
           to inform that decision.  And there may be additional
           work that continues to refine this and to better
           refine whatever that decision is, just as this fall,
           we're making information based on the best information
           we have available today.
                       And that gets to the second point which is
           from a regulatory decision making process, how do we
           deal with this and I would just point out that is it
           just Reg. Guide 1174 and we have a tendency when we
           think about 1174 to sort of focus on the quantitative
           aspects of that framework, but in fact, that's only
           one piece in there and if you look at the total five
           elements that need to be considered you need to
           consider traditional margins, defense-in-depth,
           monitoring and those other areas and we clearly will
           be taking those things into consideration with any
           regulatory decisions we make.
                       But again, getting back to this
           presentation, we need to get this technical work, we
           would like to put this into a 11174 quantitative
           framework as well early next year so that we can help
           inform the decision, so that's our goal.
                       MR. REINHART:  And maybe Ed, we have a
           suite of regulatory guidance that is guiding us,
           obviously, but we're certainly open to be thinking out
           of the box and as we go along we're looking for
           different ways to look at the data, look at the
           information, what's important, what's not important,
           so we're not tunnel vision, but we do want to work
           within not just 1174, there's a whole suite of guides
           that we have, and use that information as a place to
           start from the probabilistic aspects.
                       MR. HACKETT:  I think as a kind of
           illustration of what Jack and Mark were just talking
           about, you look at -- kind of two ways you could go
           about looking at crack initiation.  I've got them on
           the slide.  Two sort of processes that have been
           discussed or postulated for how this would progress in
           a mechanistic sense are really what those first two
           bullets are up here.  That would be the way you would
           like to go about doing this in a more purely
           scientific mechanistic way.  I think, in fact, we're
           probably going to be severely limited in that regard
           by lack of data and other difficulties, so when you
           come to the bottom bullet there, what Dr. Shack has
           done is consider laboratory data, supplemented or form
           of laboratory data for some of what we're looking at
           in initiation space, sort of conditioned by
           consideration of time to initiation from inspection
           data which is more of an empirical approach for going
           about this kind of thing.  But that's a good example. 
           I think the first two bullets there are something we
           could spend many master's theses and Ph.D. theses on
           exactly how these should be progressing.  And as Jack
           pointed out, that's not what we're about.
                       CHAIRMAN APOSTOLAKIS:  By the way, Dr.
           Shack's name has been mentioned many times this
           morning.  This is Dr. Shack of Argonne National
           Laboratory, right?
                       MR. HACKETT:  That's correct.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MEMBER FORD:  Ed, on just a definition. 
           Your definition of time initiation is the time it
           takes to get an environment in that annulus, is that
                       MR. HACKETT:  I might turn to Bill on
           this.  My own definition -- I don't know that we've
           really gotten into discussion of that would be the
           development, that plus the development of I guess what
           I would call an engineering crack that would be
           hopefully discernible through the --
                       MEMBER FORD:  For circumferential crack.
                       MR. HACKETT:  Right.
                       MEMBER FORD:  Okay.
                       MR. HISER:  I think also what you would
           need to look at, is going back to the very beginning,
           what is the crack that gives you the leak?  Is it
           through the J groove weld?  Is it an axial crack that
           goes through the wall?
                       MEMBER FORD:  That's why I'm asking the
                       MR. HISER:  There are several.
                       MEMBER FORD:  What do you mean by --
                       MR. HISER:  I think there actually several
           times that really are important.  I'd include all of
                       MEMBER FORD:  Okay.
                       MR. HACKETT:  The other one in this area
           that's obviously already been discussed this morning,
           that's been contentious to say the least is the
           annulus environment.  I think to sort of cut to the
           chase, I think we're in -- largely in agreement with
           the industry that this is hopefully a primary water
           environment for the reasons I state here.  We don't
           know that for sure is the bottom line.  But I think
           this is an area that's a tight crevice.  It's unlikely
           to be oxygenated.  Depending on where the flash point
           is when the fluid is exiting the crack that exists, if
           that's far enough away you're maybe not likely to
           concentrate as aggressive a species as we might
           otherwise and then the other thing is once these
           cracks go through wall, they now have a communication
           with the primary water environment that's hopefully
           causing some flushing.  This is key to the next slide
           because we are going on with the assumption that this
           would largely be a primary water environment.  We
           don't know that.
                       I'll just move real quick through --
                       MEMBER FORD:  Hold on.  Before you do
           that, because this came up for a lot of discussion in
           the meetings we had in July where it was arbitrarily
           decided that there was a primary environment without
           any justification.  
                       From what I understand, you can have pH as
           anything from 4.5 to 8.5 in that annulus.
                       MR. HACKETT:  That's correct.
                       MEMBER FORD:  And practically speaking,
           there's really no way that you can look at a specific
           CRDM housing and say the pH in that annulus is that. 
           There's no way you can do it.
                       You have data, I assume, that shows that
           it doesn't really matter.  Is that correct?  On
           cracking susceptibility, you can go from 4 to 8.5, do
           you have data that shows, hey, this uncertainly
           doesn't really matter.
                       MR. HACKETT:  Without a large impact for
           Canal 600, I'm caveating this, in a primary water
           environment, that's correct.
                       MEMBER FORD:  Okay, fine.
                       MR. HACKETT:  But that's why, actually,
           starting with the next slide I said the first
           statement that I did there.  The bottom line is we
           don't know exactly what this environment is.  To cut
           to one of these, there is -- I don't know where I
           guess I had on the previous slide, the -- one of the
           considerations would obviously be to go find out.  We
           discussed that with the industry that came up at the
           meeting yesterday to sample one of these environments.
                       MEMBER WALLIS:  Can't you make some
           calculations what happens in that crack in the
                       MR. HACKETT:  That has been done indeed. 
           Dr. Shack has done that.
                       MEMBER WALLIS:  I mean in terms of the
           fluid and chemical environment.  Has he done that too?
                       MR. HACKETT:  He's saying no.
                       So maybe not.
                       MEMBER POWERS:  Why don't you get yourself
           a new contractor.
                       MR. STROSNIDER:  This is Jack Strosnider. 
           I think there's some industry calculations that were
           done that were referenced in some of the work that Dr.
           Shack provided to us and is documented in the
           assessment report, but they were industry
                       MR. HACKETT:  This comes down to then the
           next step is for crack growth.  We're making the jump
           from the first one to the second one as Dr. Ford
           mentioned that the big jump there is that this is a
           primary water environment largely.
                       MEMBER WALLIS:  Intuition would be that it
           can't possibly be, boiling off the water, leaving
           behind whatever else is there.
                       MR. HISER:  I think it's described in the
           preliminary technical assessment, it may not be
           primary water initially, but as you get cracked
           opening and get additional leakage, there's enough
           communication with the bulk primary water.  I think a
           lot of the --
                       MEMBER WALLIS:  The water is continually
           disappearing by flashing.
                       MR. HISER:  Initially, yes.
                       MEMBER WALLIS:  It always is.  You're not
           squirting out water into the environment.  You've got
           a very dry environment on top of this crack.
                       MR. HACKETT:  I think what Allen was
           coming to, Dr. Wallis is that once the communication
           is there through wall --
                       MEMBER WALLIS:  I'd like to see -- it
           would be much more reassuring if someone would draw a
           picture to show that something else hasn't been done
           to justify these --
                       MEMBER FORD:  I think what's becoming very
           obvious, Graham, is that we are not going to have the
           answers to all of these questions.
                       MEMBER WALLIS:  It shouldn't be all that
           difficult to do some simple fluid dynamic diffusion,
           whatever is necessary, boiling analysis and get maybe
           some boundary estimates of what's there.
                       MR. STROSNIDER:  This is Jack Strosnider. 
           I just would comment that the technical assessment
           report that we just provided a few days ago actually
           has several page discussion referencing those sort of
           analyses, so there's a lot more detail in that report.
                       MEMBER FORD:  I think from the point of
           view of this meeting, all we're trying to get is a
           feeling that we are moving forward on this whole
           issue, all the parts of the issue.
                       MEMBER WALLIS:  I'm not feeling we're
           moving forward if we don't have some sort of analyses.
                       MEMBER FORD:  Well, put it this way.  I'm
           at the advantage, I've seen some of this data
           unofficially, and yeah, they are moving forward.
                       If we have another meeting, then we will
           be discussing all of these ins and outs.
                       MEMBER POWERS:  I think we ought not
           underestimate the complexity of doing a simple quote
           diffusion analysis in a crack environment and it's
           because not only do you have multiple species reaching
           saturation, but you have an incredibly high
           electromagnetic field in the vicinity of this crack
           surfaces, that I'm not sure you would really have the
           ability to calculate things like diffusion
           coefficients and things like that in that relatively
           narrow crack. 
                       You could put a diffusion coefficient in
           there for the ionic species, but I think you'd just be
           dead wrong.
                       MEMBER FORD:  Dana, you could well be
           right.  I'm trying to move this one on forward.  Where
           I stand, anyway, at this point is that all the
           analyses I've seen you're between 4.5 and 8.5.  That's
           four orders of magnitude of hydrogen ion concentration
           and you intuitively say that's going to make a big
           effect on cracking susceptibility.  If you have data
           and I understand there is data to show that you can go
           over that range and you're only going to change the
           crack propagation rate by a factor of two, then forget
           this problem for the time being.  Forget it, and let's
           move on.
                       That would be my technical view.  I think
           go back and revisit it later on.  But if you're going
           to move forward, scrub that out as a major issue at
           this point.
                       MEMBER ROSEN:  I'm having a great
           difficulty believing this is a primary water
           environment.  Primary water is under 2000 pounds per
           square inch pressure.  Clearly, that's not what's
           happening in this annulus.  So just from that
           standpoint alone, it's not a primary water
                       MR. HACKETT:  I think that's what Dr. Ford
           was getting to and I know you guys will want to move
           on, but we talked about this yesterday for many hours
           and in fact, we could probably devote an entire
           meeting to this subject easily.  
                       Maybe it's incorrect to be saying primary
           water, but maybe largely more that way than more
           concentrated, once the communication is there with the
           thru-wall crack.  I think that's where we're getting
                       To move beyond that, one of the things
           that's of interest here, if that is a problem, we have
           no data for that specific environment.  What we do
           have a lot of data for and that's one of the good
           aspects of this slide is there is a lot of data for
           Canal 600 in a primary water environment from a lot of
           sources.  There's significant variability in that
           data, but it's real variability.  It's actually data
           that we have as Dr. Ford has pointed out.  It's also
           appropriate, we think, to consider that variability on
           a heat basis as opposed to an actual per data point
           basis.  The net effect of that is it expands your
           uncertainty bounds when -- because you have fewer
           numbers of heats than you have total data points.
                       The overall problem is complicated by
           consideration for multiple initiation sites.  You
           could account for this in several ways.  At least one
           way is that you're multiplying your crack growth rate
           potentially and we certainly have seen the crack
           growth rates in excess of units per year are possible
           for this type of phenomenon.
                       In terms of the stress state, I think this
           is an area where we're still developing some details
           on some of the inputs.  I think the ones that are
           fairly straight forward, the first bullet are stresses
           due to primary pressure and crack face pressure. 
           However, the primary drivers in this particular
           phenomenon are really residual stresses and I've tried
           to summarize some of the sources there, the main
           source being welding.  Any time there's a welding
           process, there's potential for leaving up to yield
           level residual stresses from that process.  This is
           also a complicated manual weld which is done in a --
           it's basically a helical sort of situation.  The
           fabrication processes and sequences can change the
           residual stress state or affect it significantly.  The
           installation procedures for the penetrations
           themselves can result in residual stresses from
           straightening or bending that might have occurred when
           they were put together.
                       Modeling details can be fairly critical in
           how many passes are being modeled.  If you're looking
           at finite elements to try and figure out what the
           residual stress state is, how many elements do you
           need to go through the thickness there to get the
           refinement that you need.  And there's been -- the
           industry has done some work in pointing out the
           influence of thru-wall strength gradients that looked
           to be a factor at Oconee, for instance, with shifting
           the primary stresses, the larger stresses to the outer
           diameter of the penetrations. 
                       There's also -- these are the first two
           bullets are ones that have been considered so far in
           the analyses that we're aware of that we've done and
           that the industry has done.  Dr. Wilkauski has pointed
           out the two bottom sources that really haven't been
           considered thus far, that we're looking at, addressing
           in the analysis that the NRC is sponsoring.  One is
           differential expansion at the root of the J-groove
           welds.  You know, we've talked about and the industry
           I think has demonstrated pretty convincingly that
           there's a separation when the plant is under pressure
           and heated up between the penetration and the head
                       That's a good thing from the perspective
           of leakage, but what it does for people who are
           familiar with fracture mechanics, it induces basically
           a crack tip opening displacement at the bottom where
           the bottom of that annulus where it's joined to the 
           J-groove weld.  We haven't really assessed the driving
           forces from that.
                       There's also potential for a contribution
           from cyclic thermal stresses.  That was discussed
           yesterday at the meeting that we had with the
           industry.  Dr. Scott made some comments on that in
           terms of this may not be a principal driver for like
           fracture mechanics, but it may have the effective
           breaking of film in terms of the film rupture model or
           it may have initiation impact on the initiation. 
           Anyway, these are considerations that we still need to
                       MEMBER FORD:  On the residual stress
           aspect, I know you can do a whole lot of finite
           analyses to determine what these could be.  Are there
           any qualifying measurements?
                       MR. HACKETT:  Not that I'm aware of.  I
           turn that to --
                       MR. HISER:  Maybe somebody on the industry
           side could speak to that a little more.
                       MR. PATHANIA:  I'm Raj Pathania from EPRI. 
           I'm working on MRP project.  AS a part of this problem
           back I think about 7 or 8 years ago, measurements were
           done on CRDM nozzles in France and then those
           measurements were checked against the finite element
           stress residual stress models and there was reasonable
           agreement.  There's a published EPRI report on that
           and we can provide that report if anyone is interested
           in that.  There was reasonable agreement both with the
           residual stress measurements and the fact that when
           you weld these things, the tube goes over because of
           distortion and so the ovality measurements themselves
           are a reasonable way to check out your models.
                       And in addition, I believe Westinghouse
           has done some measurements also on the CRDM nozzles.
                       MR. BANFORD:  Yes, this is Warren Banford
           from Westinghouse.  We made some measurements of the
           ovality, of the tubes below the head.  Because of the
           weld, being on an angle, what it does it makes the
           tube go from circular to oval and we used finite
           element results that we got that we were using to
           predict residual stresses and we used those results,
           the predictions of the ovality and check with the
           actual ovality that had been measured in the field of
           tubes in that particular position and we found very
           good agreement.  So that was the way that we bench
           marked our finite element work, in addition to the
           French work which was further confirmation.
                       MEMBER FORD:  And the stuff that you were
           talking about was primarily x-ray?
                       MR. PATHANIA:  No these are strain gauge
                       MEMBER FORD:  Strain gauge, okay.
                       MR. HACKETT:  And moving on to address
           structural margins.  Obviously, there's a need -- one
           of the bottom lines of the analysis is Professor
           Apostolakis was getting to earlier is maintenance of
           appropriate structural margins.  Where we are with
           this is obviously with a PFM analysis, the intent
           would be to perform this on a best estimate basis.  In
           fact, what the second bullet goes is that at this
           state of development we have enough uncertainties in
           this that we're addressing that if we had to try and
           assemble this right now we would need to be adding
           margins in certain elements to address these
           uncertainties.  This is not the way you want to do
           this type of analysis.  That's where we would be right
                       What we're hoping to get to is obviously
           a greater level of refinement that we don't need to do
           that.  But in this case we had to do it, where to
           apply the margins and what the magnitudes would be
                       CHAIRMAN APOSTOLAKIS:  Is this where you
           disagree with the industry or do you disagree at all? 
           We heard earlier there was an estimate of delta CDF
           and so on that you have not examined yet, the
           calculations.  But is it a disagreement here
                       We are being presented with programs that
           will calculate this and that, difficult problems and
           so on, but in terms of real decision making in the
           next few months, is there a disagreement somewhere?
                       MR. STROSNIDER:  This is Jack Strosnider. 
           Let me interject this thought and with regard to some
           of the plant-specific information you heard earlier
           and we received that evaluation within the last week
           and it's under review by the staff now.  I think the
           plan is to meet on it next Tuesday and to go into some
           of the detailed discussions, so that review is in
                       I think from the generic point of view and
           from the development of this technology I don't' think
           there's disagreement.  There's technical issues that
           we need to share information on industry and NRC to
           make sure that we come up with the most reasonable and
           appropriate models to do this.  That's really what the
           purpose of putting out the preliminary technical
           assessment document was, so that people -- the
           industry and others could see where we're at in terms
           of this assessment.  And if there's information that
           can be brought to bear, if there are some assumptions
           or way we're interpreting information that people
           think is incorrect we want to hear it and we want to
           work that.  So I think if you get down into some of
           these specific technical areas, there's certainly room
           for discission.  If you want to call that
           disagreement, maybe there's some issues that need to
           be worked out, but that's the process we're working
           through in terms of trying to develop this model.
                       MR. HACKETT:   For the bottom line of
           where we're heading for this and where the technical
           assessment goes right now, is looking at the impact
           and Larry Mathews covered some of this earlier,
           inspection methods and particularly timing.  This goes
           to -- we had a lot of debate yesterday over when do
           the cracks start and how fast are they growing.
                       Certain inspection methods for this type
           of phenomenon have been quote unquote qualified.  One
           per the Bulletin is this qualification for leakage
           that was discussed earlier by the industry with the
           idea that you have the leakage path and you do have an
           access to the bare metal that you can make the
                       The other one is the previous phenomenon
           back in 1997.  There was an approved methodology for
           using Eddy currents inspection technology for looking
           at ID cracks on the penetrations themselves.
                       Moving down further, there are other
           methods that really remain to be qualified and I guess
           clarification is probably needed there and
           qualification in this case, I was probably looking at
           as an ASME PDI type qualification performance
           demonstration initiative, where you're looking at
           qualification of both methods and personnel to be able
           to detect and size some of these type of defects.  And
           in that case, you're looking at probably both surface
           and volumetric exams through the J-groove welds, also
           volumetric exams for the vessel head penetrations and
           being able to shoot through that wall to look at OD
                       Bottom line there is that the
           determination of the appropriation inspection
           intervals from PFM will obviously depend on the
           reliability and effectiveness of those inspections to
           at least some degree which is really -- remains to be
                       Allen is going to go into some more of
           this in detail, but just in terms of the tech
           assessment, but just to sort of summarize where we've
           been going, this has really been -- this is RES
           initiatives on reactor vessel head penetrations.  It's
           very much really been a team effort at NRC between RES
           and NRR and the research contractors to developing an
           integrated technical perspective on this, largely
           using a probabilistic fracture mechanics construct.
                       As I mentioned, the conclusion at this
           point is that the development so far indicates that
           there is some key inputs that are lacking appropriate
           data and/or are highly uncertain and some of that we
           may be able to do some things about.  Some of it may
           be just what we're going to have to live with, that
           the current state of development of these
           uncertainties do limit the ability of this type of
           assessment to do a lot for you.  And we're hoping,
           obviously, that the continued efforts in this area are
           going to result in reductions in these uncertainties
           and make this a more viable methodology for assessing
           the overall impact of this phenomenon in the future.
                       MEMBER ROSEN: Is this a separate, or a
           scientific search for truth or is it an attempt to
           ultimately be able to apply these techniques to plant
           specific situations?
                       MR. HACKETT: I guess we like to feel that
           we're always looking for the truth in terms of the
           research aspect of the thing.  But I think the answer
           is really more the latter, because I think we could be
           searching for the truth for a long time, probably at
           least the rest of a lot of careers that I can think of
           and in this case, we have some real practical problems
           to come to grips with near term as Jack was mentioning
                       So I think it's really going to be more
           the practical lean and there will obviously need to be
           compromises along the way in that regard.
                       MEMBER FORD: But my earlier question, you
           are planning by say early spring of 2002, you will
           have a defensible disposition algorithm?
                       MR. HACKETT: That would be the --
                       MEMBER FORD: That would be either
           deterministic or probabilistic.
                       MR. HACKETT: That would be the goal and
           then to have -- I think what we have now is Dr.
           Apostolakis asked about agreements, disagreements.  I
           think with the industry and the NRC, I think there's
           fairly wide agreement on the elements that need to go
           into this thing.
                       MEMBER FORD: Right.
                       MR. HACKETT: I think you've seen that
           today.  I think there's just really a question on some
           of the key input varies in discussions over
           uncertainties in those.  But I think the construct is
           there, and I think the answer is yes.  Hopefully we'll
           be in a position.
                       MEMBER FORD: And so that will have an
           effect, not on inspection periodicities, but it will
           also have a feedback into the completeness, if you
           like, of the prediction algorithm that you're
           currently using for privatization of inspections?
                       MR. HACKETT: That's correct.
                       MR. STROSNEYDER: This is Jack Strosneyder
           and I'd just comment with regard to the practicality
           of the work, and I think Allen's going to present, if
           we get through, the material that he has.  If we get
           toward the end of that, there's some curves that are
           in the technical assessment documents which were
           intended to present the results of the work done so
           far in a format such that it could be help to inform
           decisions, recognizing that there's uncertainties and
           it's not the best model for doing that because there
           are still uncertainties we need to deal with.
                       But we're trying to put this work into
           that framework so that it can be used to inform those
                       MEMBER FORD: Well, we've got to see those
           graphs.  I love graphs and we're going to do it by
           half past 10:00, so let's do it Allen.  
                       MR. HISER: Let me ask your guidance.
                       MEMBER FORD:  Get rid of all the pictures.
                       MR. HISER: No pictures?
                       MEMBER FORD: Yes, pictures.  Okay, I'm
                       MR. HISER: There are two parts of my
           presentation.  One is the preliminary staff assessment
           that you've had some time to look at.  The other is
           more an overview of the inspection findings and some
           photos of some of the visual exam results.
                       MEMBER FORD: Fine.
                       MR. HISER: Which one would you like me to
           start with?
                       MEMBER FORD: Provided that you'll promise
           me that we'll see some actual graphs.
                       MR. HISER: Okay, you'll see some actual
           graphs.  They may be short of background and we'll
           jump to graphs.
                       MEMBER FORD: Right.
                       MR. HISER: The first thing I'll start with
           is just an overview of the bulletin very briefly, the
           status of the inspections and things, and the status
           of our understanding at this point.  When we spoke to
           the committee, in I believe it was July, we were
           talking about a proposed bulletin.  The bulletin was
           issued in early August.  We did ask questions of all
           plants related to the plant specific aspects of
           susceptibility, the number of nozzles, things like
                       We were looking at what is the type of
           insulation on the head as it relates to the ability to
           do visual inspections, and also that's more the
           inspection side.  We also were asking what are the
           consequences and what structures, cabling, things like
           that are above the head that could be damaged if a
           nozzle were to become ejected.
                       For plant specific consideration, we did
           have questions related to the susceptibility of each
           plant, specific questions if they found cracking or
           leakage, what the extent of that was, what their plans
           and schedules for future inspections were, and then
           also how those plans would meet the regulatory
           requirements.  That's just a brief overview of the
                       Within the bulletin, we speak of a graded
           approach to doing examinations for plants that have
           varying levels of susceptibility to cracking, or have
           a history of cracking.  We think that it is
           appropriate to do different examinations.  The
           bulletin speaks of an effective visual examination,
           and effectively what that is, is that you have access
           to the bare metal where the nozzle intersects the head
           and you can detect boric acid deposits.  That assumes
           there's no insulation in the way, no other
           impediments, that there are no other boric acid
           deposits in all honesty.  It's hard to differentiate
           one from another.
                       So that would be, I guess if you will, the
           lowest level of examination.  The next would be a
           plant specific qualified visual exam that's been
           mentioned before.  That's a plant specific
           demonstration that you have a leak path, such that if
           you get a leak in the J-groove weld, that there is a
           way for deposits from that leak to come up to the
           head.  Then you can detect through an effective visual
                       The last inspection that's discussed in
           the bulletin is a volumetric exam and this one, again,
           is focused on the outside diameter of the nozzles to
           detect circumferential cracking at that point.
                       MEMBER WALLIS: Does what you see give you
           any indication of how far the crack has progressed? 
           If you see great big balloons of popcorn, that's going
           to tell you something that's different from just
           little clusters of popcorn?
                       MR. HISER: Within the results that we have
           to date, in particular going back to the Oconee 3
           results, we had 165 degree through-wall crack
           circumferential.  There doesn't seem to be any
           relationship to amount of deposit in extent of
                       MEMBER WALLIS: Okay.
                       MR. HISER: Now, the bulletin responses
           came in in early September.  The bulletin does bin the
           plants into four groups.  The first is those that have
           exhibited cracking or leakage.  That's five plants all
           together.  The other three bins, if you will, are
           based on the relative susceptibility ranking.  In each
           case, the bulletin provides some suggestions on what
           would be an appropriate inspection for each bin.
                       In particular, for those plants that have
           found cracking or leakage, the bulletin suggests that
           a qualified volumetric exam should be performed by the
           end of 2001.  Upon looking at the responses and
           additional consideration of things, what the staff has
           accepted is a qualified visual exam at the last outage
           as being a sufficient inspection method.
                       As you can see, as you go down in
           susceptibility, there are sort of reductions in
           intensiveness of the inspections.  The staff has
           addressed clarifications to some of the bulletin
           responses with specific licensees, and numerous
           licensees have provided either revised or supplemental
           bulletin responses.  We're still actually reviewing a
           lot of that information.  As Jack mentioned, some of
           it just came in earlier this week.
                       Now looking at the plants that have
           performed their metal visual examinations, in all
           cases except one these are plants that are either in
           the high susceptibility bin or have exhibited cracking
           or leakage at some point.  The one exception is
           Crystal River Unit 3.
                       What I'd like to indicate first of all, of
           the ten plants that have done their metal exams within
           the last twelve months, nine of them have come up with
           at least relevant visual indications and that really
           is the case for North Anna Unit 2.  It's the reason
           that their number's in parenthesis.  Those are visual
           indications that they're doing additional examinations
                       The other eight plants have confirmed
           cracks in the nozzles, in some cases, circumferential
           cracks.  At Oconee Unit 3, Oconee Unit 2 and Crystal
           River 3, a number of nozzles have been repaired. 
           There are a number of nozzles that have been left in
           service with  axial cracks at this point.
                       VICE CHAIRMAN BONACA: The bottom line here
           is you say that those plants at the bottom, Beaver
           Valley 1, et cetera, et cetera, have completed
           effective visual examinations.  How do they differ
           from bare metal?
                       MR. HISER: These are the plants that are
           in either high susceptibility -- 
                       VICE CHAIRMAN BONACA: Okay.
                       MR. HISER:  -- or had previously had
           cracked or leaking nozzles of the top, including
           Crystal River 3 in that population.  That's thirteen
           plants all together, so ten of them have looked, three
           have not.  Nine of them have found at least relevant
           -- eight have found cracking.  Robinson is the only
           plant at this point that has not found any evidence of
                       VICE CHAIRMAN BONACA: So the effective
           visual examinations on the bottom means bare metal
                       MR. HISER: Right.  Right, they have not
           done the analysis to show that leaks would put a
           deposit on the head.
                       VICE CHAIRMAN BONACA: Okay.
                       MEMBER FORD: Allen, as you look at -- put
           the next one up.  As you look at those, do you have
           any comments on the question I asked Larry?  Can you
           draw anything from this information about the
           difference between Babcock and Westinghouse reactors
           in terms of susceptibility, or is it purely a function
           of time at  600 plus or minus 2?
                       MR. HISER: I think it's too early to say. 
           The one comment that I can make, one observation,
           seven BNW plants exist in the PWR population.  Six
           have looked and found cracking.  Three of the six have
           found circumferential cracking.  At this point, we
           have not seen circumferential cracking in Westinghouse
                       But then again, the intensity of the
           examinations has not been as strong as the BNW plants. 
           That is what the bulletin was trying to get to, trying
           to increase the level of inspection so that we could
           determine whether there are any particular groups that
           are more problematic in this area.
                       MEMBER FORD: Now, I've heard it said that,
           maybe comment on the accuracy of it, that Babcock
           seemed to have been using more susceptible heat for
           whatever reason, and we don't know how to define
           susceptible physically.  Could you comment on that?
           Is there any basis for that or not?
                       MR. HISER: I would say that we really
           haven't looked at it to that level of detail.  We
           have, the industry has identified cracking in at least
           one Westinghouse plant.  That plant is doing repairs. 
           We really have not assembled the data and been able to
           try to look for those kind of conclusions.
                       MEMBER FORD: Okay.
                       MR. HISER: I think the one comment that
           I'd make on the -- and this is very similar to Larry
           Mathews' graph, just a little bit different colors I
           think, different color scheme.  The plants that are
           highlighted in the red circles have identified
           cracking recently.  The one plant, North Anna 2 has
           indicated maybe that will end up turning into a blue
                       The bulletin made a distinction of 5 EFPY. 
           The plants to the left of that were high
           susceptibility.  Those to the right were considered to
           be moderate susceptibility.  I think that the results
           generally support that.  The one plant in this area
           that the bulletin maybe didn't designate properly is
           the next plant in line.
                       MEMBER FORD: Crystal.
                       MR. HISER: That's right. Crystal River
           identified a circumferential crack.  So the
           circumferential cracks are here and here.  It seems to
           sort of span the --
                       MEMBER FORD: But the ISI 5 is purely
                       MR. HISER: Absolutely.  Yes, the 5 was
           just a first cut at trying to provide some data that
           would be useful to look at.  At this point, one plant
           in the high susceptibility zone has identified no
           cracking.  Two at this point have not performed a
           recent ISI.  But it does appear that these are the
           plants that are more susceptible.
                       As time marches on, you know, red circles
           will begin to populate out here.  This one plants was
           included in the first bin of plants that have a
           history of cracking, because I identified axial
           cracking in 1994.  
                       So my conclusion from this, susceptibility
           ranking is working as intended.  I mean, we don't have
           any plants that have identified cracking at 20 or 30
           EFPY.  So, that's a good sign.
                       MEMBER POWERS:  At 20 or 30?
                       MR. HISER: EFPY from Oconee Unit 3.
                       MEMBER POWERS: Have they looked?
                       MR. HISER: Some plants have looked using
           the effective visual exam.  They've looked at the bare
           metal on the head and have identified no relevant
           deposits.  These are two plants, Kewaunee -- the other
           two plants, I believe the one furthest out is about 22
           EFPY from Oconee Unit 2.
                       MEMBER POWERS: How long from the time a
           crack exists to the time you can find deposits?
                       MR. HISER: I think an expectation is that
           from the time that you get a through-wall crack in a
           J-groove weld, that the time to see the deposit is
           hopefully less than the time to initiate a
           circumferential crack.  We don't have any firm data in
           that regard.
                       Unfortunately what we're, you know, the
           bulletin was information gathering.  We wanted to try
           to find out the population of flaws that are out
           there, how severe is the problem.  What we're ending
           up with is a population that's sort of one-sided.  If
           you find a leak, you do additional inspections.  If
           you don't see a leak, you don't do anything.  And
           we're not sure if that, you know that clearly doesn't
           cover the full range of possibilities in terms of
                       Moving on from there, I just wanted to
           show some of the typical visual examination results
           from this fall.  In both of these cases, cracks were
           identified in the nozzles and so these would be
           classified as leakers in a classic sense.
                       For this one as well.  I don't know if you
           -- let me show this next one.  This is sort of the
           classic popcorn appearance that the industry speaks of
           in this area.  This is what we've seen at Oconee Unit
           3 and Unit 2 and ANO 1.  That's sort of the classic
           deposits.  In this case, I think this is easy to tell
           that you have popcorn deposits.  On some of these
           others -- How do you interpret that?  Is that a
           relevant -- is that popcorn?  Is that a relevant
                       CHAIRMAN APOSTOLAKIS: When you say "that",
           that is that?  
                       MR. HISER: These deposits.
                       CHAIRMAN APOSTOLAKIS: That's just -- okay.
                       MR. HISER: It clearly isn't just bare
           metal with the nozzle coming into the head.  I guess
           we don't have any on that one.  But the industry has
           treated nozzles like this in general as relevant
           visual indications, and they've done additional exams,
           volumetric surface exams.  I think they have in
           general done a very good job of following up
           indications like this.
                       The interpretation the industry has tended
           to put on this is they do not call this a leak until
           they confirm that through volumetric or surface
           examinations.  The difficulty comes in when you get
           things that look like this.
                       MEMBER ROSEN: Would you go back to that
           prior one.
                       MR. HISER: Sure.
                       MEMBER ROSEN: Because it just seems to me
           so clear what's going on here.  I'm sort of puzzled by
           you not saying it.  That looks to me like a very old
           leak that may have somehow dried up.  Clearly there's
           damage there.  It's not normal.  It's not the way it
           was built.
                       MR. HISER: One of the problems that many
           of the plants have is they have leaking CRDM flanges,
           CONO seals and canopy seals, and that provides boron
           on the head, differentiating is it from the nozzle,
           from under the head leaking out, or is it from an
           external source, is part of the difficulty in
           interpreting the visual exams.  
                       What the industry has consistently done is
           to say, this required more attention.  They're not
           sure if it's from a leak in a nozzle or from an
           external source, so they've done additional exams to
           try to determine the source.
                       This is the next one that I put up.  That
           looks similar to what we saw at Oconee and the early
           graph that I showed.  The problem though in a case
           like this, is trying to find where the crack is so you
           can fix it.  And, in some cases like this and also
           with this nozzle, this is the same nozzle.  These
           kinds of indications in that area are sort of
                       In the case of this nozzle, the licensee
           did extensive ultrasonic and surface exams, found no
           leaks, no surface cracking, no source of deposit.  The
           conclusion that they reached and that we agreed with,
           was that this came from an external source, in this
           case a CONO seal leak.
                       What I wanted to do is just give you a
           flavor for the kind of visual examination results that
           we're seeing and having to interpret.  I think
           overall, the industry has done a good job in following
           up relevant deposits.
                       MEMBER ROSEN: Would you go back to that
           for a moment?
                       MR. HISER: Sure.
                       MEMBER ROSEN: Why would you say that's a
           CONO seal leak?  Wouldn't you expect to see some
           evidence of it coming down from above?  And yet, that
           penetration looks perfectly clean to me above the area
           that you indicated.
                       MR. HISER: And in the case of this
           licensee, and I think again we're finding a lot of
           variations from plant to plant.  This licensee has a
           very high air flow rate through the upper head area,
           and the CONO seal leak deposits don't drop straight
           down, but they're blown every which way.  
                       Looking at videotapes of this head, you
           can see on some nozzles where there are streaks along
           the side of the nozzle, so the leakage comes down
           vertically, gets caught up in the air flow and is
           blended horizontally.  There tends to be boric acid in
           many placed on the head.  It tends to be fairly well
           localized, but it's not -- I think one could -- look
           at this case.
                       MEMBER WALLIS: The only place we see it in
           that picture is where you would see it if it came out
           of a crack.
                       MR. HISER: The deposits back here?
                       MEMBER WALLIS: Yes, that bottom one.
                       MR. HISER: You really have to see the
           videos to get a full appreciation for this, but there
           tends to be a lot of boric acid.  This does not look
           like the popcorn appearance that we've seen
           classically with the circumferential cracks in
           particular.  This has been followed up with additional
           exams.  No relevant cracking has been found.
                       MEMBER WALLIS: It could mean you don't do
           a good job of finding cracks.
                       MR. HISER: The inspection methods have
           been qualified with service cracks.  Clearly, there's
           a chance that that has happened as well.
                                   MEMBER FORD: Could I suggest we move on
                       Allen?  MR. HISER: Sure.
                       MEMBER FORD: I recognize that are
           scuppering you here, but looking through here, there's
           a lot of good information at the back here that I want
           these gentlemen to be exposed to.  Now, do I
           understand that we are allowed to go to a quarter to
           11:00?  George?
                       CHAIRMAN APOSTOLAKIS: I'm sorry?
                       MEMBER FORD: Can we go until quarter to
                       CHAIRMAN APOSTOLAKIS: No.  I'm sorry.  We
           have an absolute deadline of 1:30 with the
           commissioner coming.
                       MEMBER FORD: 10:30?
                       CHAIRMAN APOSTOLAKIS: So I can't move
                       MR. HISER: How would you like me to
           proceed.  I can jump to the bottom line more?
                       MEMBER FORD: Why don't you jump to the
           bottom line if we must leave at 10:30.  It's obvious,
           I think, that we're going to be having another full
           day meeting sometime.
                       MR. HISER: Let me speak a little bit to
           one of the areas of contention yesterday in our
           meeting.  The crack rate is an area that we don't have
           alignment if you will between the industry and -- at
           this point in time.  This is some data for Alloy 600. 
           The top curve illustrated here is what would be called
           a 95/50 confidence bound on the data.  The curve at
           the bottom I believe is a 50/50 analysis of a larger
           bulk of data.  
                       What the staff has used in its preliminary
           assessment is a 95/50 curve as an upper bound.  In
           addition, we have defined what I would call a high
           mean value.  What has been seen and has been
           hypothesized is that the heats of the material that
           are going to crack are the ones that are most
                       So instead of looking at the full
           population of data, one should really concentrate on
           the upper half of the data.  We've defined a high mean
           as the square root of the product of the 95/50 and the
           50/50 data, so it would be a curve that lies
           essentially in between.  In this case, I think it --
                       MEMBER FORD: From where you stand right
           now Allen, if you were asked what disposition curve do
           I use, would you choose the 95/50 or the 50/50, and
           what would the industry want to do?
                       MR. HISER: I won't speak to what the
           industry would like to do.  My guess is that, well
           what we recommend in the technical assessment is a
           95/50 curve.
                       MEMBER FORD: Good.
                       MR. HISER: I do not believe the industry
           would recommend the same curve.
                       MEMBER WALLIS: Where is K for your
           situation here on the picture?
                       MR. HISER: For the nozzles, we are
           generally in the range from 30 to 50 or 60 MPA root
                       MEMBER FORD: And I'm reminded there's a
           second. There's a centimeter in 100 days.  It's called
                       MR. HISER: The difference from the 50/50
           to the 95/50 is about an order of magnitude.
                       MEMBER FORD: Yes, but the top line is not
           insignificant crack.  It's pretty rapid.
                       MR. HISER: No, it's about an inch, 30
           millimeters per year on that order.
                       MEMBER FORD: That's right.  So again to
           come down to the bottom line where you stand right
           now, unless there's other information that comes
           available the next two months, you have been
           suggesting an inspection periodicity based on that
           10(-9) meters per second rate?
                       MR. HISER: Based on the 95/50.
                       MEMBER FORD: Yes.
                       MR. HISER: And that puts you in that sort
           of a crack root.
                       MEMBER FORD: PWR environment?
                       MR. HISER: Yes.
                       MEMBER FORD: In the PWR environment.
                       MR. HISER: Now there was a little bit of
           mention earlier about the annular environment, what is
           correct?   Is PWSCC really an accurate way to
           characterize what's going on in the environment?  The
           technical assessment indicates that if there are any
           upset chemistries in the annulus, the effect on crack
           root may be up to a factor of 2.  I think maybe the
           95/50 is one interpretation of it, is that it would
           account for things like that.
                       Looking ahead to Slide 17, the staff has
           looked at deterministic and probabilistic assessments
           and there's discussion of both of those in the
           preliminary assessment.  The parameters that we've
           used are here.  I think the numbers are not in
           substantial controversy on critical flaw size, about
           270 fora factor of safety of 2 or 3 on pressure; 342
           is what our analysis indicates for nozzle failure and
           possible ejection.  
                       As I mentioned for crack growth rate,
           we're using a 95/50 statistical bound.  We're looking
           at a temperature of 318°C for this conditions.  You
           get an A for the Scott Model as indicated there.  For
           the initial flaw size, we really don't know what the
           flaw size is.  Without inspection data, it's hard to
           draw conclusions on a plant specific basis.  
                       In lieu of that, our deterministic
           assessment uses a range of initial flaw sizes to see
           what the effect of that is.  In terms of uncertainty
           and sensitivity studies, we've looked at different
           statistical bounds to the crack root data, the effects
           of temperature and again, we're using an initial flaw
           size as a parameter.
                       CHAIRMAN APOSTOLAKIS: I was just informed
           that Commissioner McGaffigan is willing to come a
           little later.  So, you can have your fifteen minutes
           of glory.
                       MEMBER FORD: Thank you George.
                       CHAIRMAN APOSTOLAKIS: Thank the
                       MEMBER FORD: There's a lot of stuff here.
                       MR. HISER: This is an illustration of the
           K that we're using as a function of crack half length. 
           It peaks at about 60 KSI root inches.  This area is
           principally due to residual stresses, mainly from
           welding on the tail end of the curve is due to
           pressure stresses, and we've tried to model as best we
           can at this point in time what the K range or K curve
           would look like for the nozzles.
                       We talked about crack sizes.  Thus far,
           five circumferential cracks have been identified
           through inspections.  The first two were verified
           through destructive examination.  The last three have
           not.  In particular, I guess what I'd like to point
           out, the one destructively examined crack of 165&, the
           ultrasonic record indicated an inside diameter extent
           of 59ø.  
                       So clearly, there's a lot of uncertainty
           on the ability of the ultrasonic method to size these
           cracks.  But it would be very helpful from an
           analytical standpoint to have some sort of
           confirmation of cracks that occur in the future,
           instead of just the machining the cracks away, some
           way to confirm the size of those would be very
                       For the base case, again 318øC, 95/50
           crack growth curve.  That's illustrated here as a
           function of crack length.  The maximum growth rate
           would be about 1 3/4" per year down to about ‹‹" per
                       MEMBER FORD: Allen, could I presume just
           to tell you what to do, because I want to make sure --
                       MR. HISER: Sure.
                       MEMBER FORD:  -- all the members have time
           to ask you questions.  There's a tremendous amount of
           work here.  Could I suggest maybe you discuss Slide
                       MR. HISER: Okay.
                       MEMBER FORD: I'm really interested then to
           hear the bottom line on your inspection and what the
           next staff plans are.
                       MR. HISER: Okay.
                       MEMBER FORD: And then that would give time
           for all the members to ask any closing questions.
                       MR. HISER: Now, as a part of the
           uncertainty and sensitivity study, we have looked at
           temperature and statistical bound to the crack growth
           data as parameters.  What is indicated here is the
           operating time from an initial crack length to the
           nozzle failure, nozzle ejection, crack length.  We
           have different crack growth curves.  As an example,
           the 318øC bound curve would be at that temperature. 
           The 95/50 curve, the curves marked as M are not the
           50/50.  It's a curve that's between the 95/50 and
           50/50 curve, so it's more of a high mean value.
                       As you can see, there are affects of
           temperature.  If you go from 325ø, 318ø to 315ø,
           reducing the temperature increases the operating time
           to failure.  More substantially, I think, is the
           effects of statistical bound, if you go from a 95/50
           to a mean curve, you get very substantial changes.
                       CHAIRMAN APOSTOLAKIS: When you say 95/50,
           what do you mean?
                       MR. HISER: That means there's a 50 percent
           probability that you've bounded 95 percent of the
           data.  That's 50 percent confidence that you have 95
           percent bound.  As an example, the 95/95 would be 95
           percent confidence that you bounded 95 percent of the
                       Using the 318ø bounding curve, the 95/50
           curve for flaw sizes smaller than 120ø, you would have
           at least four years before you would reach a critical
           flaw size.
                       MEMBER FORD: Could you just comment on
           what you call the industry crack growth rate?
                       MR. HISER: The industry crack growth rate
           curve is 10 millimeters per year.  I'm not sure the --
           this came to us in at least one submittal and I think
           is more of a mean curve or maybe below mean overall.
                       MEMBER FORD: So obviously as we move into
           the future, there's going to be a lot of discussion
           between you and the industry as to which one of those
           curves is appropriate for a specific plant?
                       MR. HISER: Yes, clearly one of the ideas
           is that depending on the level of inspection could
           impact which of those curves would be appropriate for
           the plant to use.
                       CHAIRMAN APOSTOLAKIS: Let's see, all of
           them start at 300 and something degrees.
                       MR. HISER: Right, 324.
                       CHAIRMAN APOSTOLAKIS: What is that now?
                       MR. HISER: Okay, what this means, if I
           have a 60øC to start with and I'm using the 318øC
           95/95 curve.
                       CHAIRMAN APOSTOLAKIS: Oh.
                       MR. HISER: It means I would grow to
           failure in about eighteen months.
                       MR. Leitch: 324 is four phase.
                       CHAIRMAN APOSTOLAKIS: Okay, and the
           confidence you're referring to comes from the
           percentage of the distribution on a number of
           parameters of going to the mother, right?
                       MR. HISER: In this case, it's totally on
           the crack growth rate.
                       CHAIRMAN APOSTOLAKIS: Oh, just the crack
           growth rate.
                       MR. HISER: This only has crack growth rate
           as a parameter.  That's the only thing that we're
           varying in any of these curves.
                       CHAIRMAN APOSTOLAKIS: Right.
                       MR. STROSNEYDER: This is Jack Strosneyder. 
           I'm glad that point came up because I wanted to make
           it.  There's one random variable in the plot you're
           looking at here, and that is the growth rate for
           circumferential cracks.  All right.  
                       When we talked briefly about some of the
           other uncertainties with regard to what the stress
           levels are and certainties in the inspection and what
           might be left in service after inspection and those
           sort of things, that's not reflected in this analysis. 
           Those are the things we need to develop in order to
           come up with the full probabilistic assessment.
                       CHAIRMAN APOSTOLAKIS: The random variable
           is the operating time to failure.
                       MR. HISER: That's right.
                       CHAIRMAN APOSTOLAKIS: And the others are
           the uncertainty variables, and so far you have used
           only the crack growth rate.
                       MR. HISER: That's the one variable that we
           have sufficient data on that we feel we can do the
           sort of analysis.
                       CHAIRMAN APOSTOLAKIS: So, if I pick one
           value of the crack growth rates, say the 50th
           percentile, the median, what kind of a distribution
           have you assumed for the operating time?
                       MR. HISER: That's what this curve shows
           you that the median's plotted on there and you can
           look at --
                       CHAIRMAN APOSTOLAKIS: No, there's no one
           curve.  I mean, you're down horizontally.
                       MR. STROSNEYDER: Al, explain the 95/50
           where that's at for a 315 center.  Let's just pick
           that because it's an easy color.
                       MR. HISER: This would be a 95/50
           representation of the crack growth rate.
                       CHAIRMAN APOSTOLAKIS: When you say "this"?
                       MR. HISER: The green curve.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       MR. HISER: The green curve.
                       CHAIRMAN APOSTOLAKIS: Okay, 95/50.  So
           this is the 95th percentile on the operating time,
           using the 50th percentile for the crack growth rate?
                       MR. HISER: No, this is a deterministic
           calculation.  We take the crack growth rate that
           correlates to a 95/50 bound on the crack growth data.
                       CHAIRMAN APOSTOLAKIS: Which is a 50
           percent confidence.
                       MR. HISER: For each crack size, how long
           it will take to grow to the failure, to the nozzle
           failure crack.
                       CHAIRMAN APOSTOLAKIS: So this is not the
           95th percentile of the operating time?
                       MR. HISER: No.
                       MR. STROSNEYDER: No.
                       CHAIRMAN APOSTOLAKIS: Oh.
                       MR. HISER: The 95th percentile on the
           crack growth data.
                       MEMBER WALLIS: In the reactor environment.
                       MR. HISER: Assuming a primary --
                       CHAIRMAN APOSTOLAKIS: What is the 50 then?
                       MEMBER KRESS: It's the mean value of the
           95 percentile.  The distribution is about how well you
           know the 95 percentile, and this will be the mean of
           that distribution.
                       CHAIRMAN APOSTOLAKIS: Do you have a
           distribution on the crack growth rate?
                       MR. HISER: Yes.  It's humongous.
                       CHAIRMAN APOSTOLAKIS: That's one
                       MEMBER POWERS: It is an estimated
           distribution on that and yes on confidence on how
           accurate his estimate is.
                       CHAIRMAN APOSTOLAKIS: So that's what my
           second question was.  It's not one distribution then? 
           You have a family of distributions, each one with a
           different degree of confidence, is that it?
                       MR. HISER: Yes, that's correct.
                       CHAIRMAN APOSTOLAKIS: So you don't have a
           -- okay, so you don't have any other uncertainty
           coming into the calculation of the operating time.
                       MR. HISER: Right, and if you assume
           effectively a mean value of the crack growth rate, you
           would predict very long operating times to failure. 
           If you assume a statistical bound 95/50, then it
           brings it down substantially.
                       CHAIRMAN APOSTOLAKIS: So the mean value
           then of the crack growth rate is on the relatively low
           side, right?  That's what you're saying?
                       MR. HISER: Yes.
                       CHAIRMAN APOSTOLAKIS: And then you have a
           long tail?
                       MR. HISER: Right.
                       CHAIRMAN APOSTOLAKIS: And the fun begins
           when you move onto the tail.
                       MR. HISER: Absolutely.  And the philosophy
           that went into the assessment is, which nozzles, which
           materials are going to fail in service?  It's probably
           not the mean values we're concerned about.  The
           materials that are more sensitive, where the cracking
           would be more aggressive in the material.  So from
           that standpoint, like a 95/50 curve is more
           appropriate from a philosophical standpoint.
                       MEMBER POWERS: I mean, I appreciate it.  
                       CHAIRMAN APOSTOLAKIS:  
                       I don't understand it.
                       MEMBER POWERS: The qualifying statement,
           why not on a 95/95?
                       MR. HISER: At this point, I think that may
           be too extreme.
                       MEMBER POWERS: What I'm trying to
           understand is how do you decide?
                       MR. HISER: It's pretty much engineering
                       MR. STROSNEYDER: I would interject two
           thoughts on this.  One is -- this is Jack Strosneyder. 
           One thing when we look at the data, and Allen had put
           the plot up before and remember that it's on a log
           plot, so there really is a lot of variability, right. 
           But the other thing that comes into play here on these
           confidence levels is that when you do this by heat,
           there's a relatively small number, I think it's 20, 18
           or 20.
                       MR. HISER: 11, it's actually 11.
                       MR. STROSNEYDER: So of course the
           confidence amount is driven by the amount of data that
           are available too, so we want to capture what we think
           is the real variability in these data, all right.  But
           on the other hand, if you recognize you're dealing
           with a small amount of data and you use those high
           confidence levels, you can drive yourself to some very
           conservative values.  So, that's one way of looking at
                       MEMBER POWERS: I understand that.  I just
           am trying to understand what goes into the engineering
           judgment, that 95/50 is okay but 95/95 is too extreme.
                       MR. HISER: I think what we've seen so far
           is that the 95/50 operates as an effective upper bound
           to the data.
                       CHAIRMAN APOSTOLAKIS: So what is up curve
           now, 95/50?  Is it there?
                       MR. HISER: It's the ones marked B.
                       MEMBER POWERS: But if I looked at the
           data, I think in your 95/50 curve, I think I can find
           a data point.  I better be able to find a data point
           that's above it.
                       MR. HISER: That's correct
                       MEMBER POWERS: So the 95/95 would be even
           a better upper bound to the data.
                       MR. HISER: Correct.
                       MEMBER POWERS: I'm just trying to
           understand your engineering judgment.  I don't doubt
           your engineering judgment.  I'm just trying to
           understand exactly how it comes out.
                       MEMBER FORD: If I could interject here. 
           Allen, I apologize for asking to put this slide up,
           because it's started a whole lot of questions.  
                       CHAIRMAN APOSTOLAKIS: That's why you got
           15 minutes.
                       MEMBER FORD: But if the members just look
           at Chart 31, you can just see overall what the staff
           are planning and on that basis, I'd like to go around,
           remembering that his meeting, the objective of this
           meeting is merely to inform the full committee that
           things are moving forward and it's very obvious things
           are moving forward. 
                       CHAIRMAN APOSTOLAKIS: I mean, that's an
           interesting point.  Let's go back to that.  In
           documents like Regulatory Guide 1174, there is some
           guidance.  It says "use the figure with the bounds and
           the limits using the mean value" but as your mean
           value approaches some limit, there is increased
           management of tension, which means now you're looking
           at the tail, how much probability there is above the
           limit, and you know, you start sending RAI's.
                       Why can't we apply the same philosophy
           here.  Instead of saying we have to select the 95/50
           or the 95/62, apply some consistent approach and say,
           you know, maybe I'll go with the mean but then when
           something happens there will be increased management
                       MR. STROSNEYDER: This is Jack Strosneyder. 
           I just point out an application of this information,
           it's been pointed out there is only one random
           variable that's considered in this, and clearly some
           judgment needs to be involved in how you take this
           information and apply it on plant specific
           discussions.  And recognizing, not only how we're
           going to treat this random variable, but recognizing
           that some of those other variables and uncertainties
           are not yet included in the analysis process, which is
           the work that remains to be done.
                       CHAIRMAN APOSTOLAKIS: Are you going to
           include the model uncertainty as well?  Are not these
           equations --
                       MR. STROSNEYDER: I'm sorry, I didn't hear
           the question.
                       CHAIRMAN APOSTOLAKIS: The equation that
           gives you the operating time as a function of the
           crack growth rate, is that cast in stone or there is
           uncertainty about it?
                       MR. STROSNEYDER: That's two numbers moth
           planned together.
                       CHAIRMAN APOSTOLAKIS: That's all.
                       MEMBER KRESS: That's all it is.
                       MR. HISER: But in terms of the K that goes
           into determining what the crack growth rate is at each
           crack, that's a parameter.  I mean --
                       CHAIRMAN APOSTOLAKIS: My second comment is
           that, you know, I realize there is a language that is
           being used in this community, but again we're going to
           try to make it consistent with the language we use in
           the risk-informed approach.  This 95/50 business, I
           just don't like it.  I mean, we have terminology.
                       MEMBER KRESS: George, that's good
           terminology.  I like the terminology because it's very
                       CHAIRMAN APOSTOLAKIS: It covers the data? 
           What is that?
                       MEMBER KRESS: Yes, but I think you have a
           real good point George.
                       CHAIRMAN APOSTOLAKIS: There is no
           probability theory that says that.
                       MEMBER KRESS: Oh sure.
                       CHAIRMAN APOSTOLAKIS: If you open up a
           epistemic distribution with the percentiles and that's
           the state of normal distribution, that's all you do.
                       MEMBER POWERS: Nonsense.  This is well-
           developed analysis for experimental data.
                       MEMBER KRESS: Yes, absolutely.  Everybody
           does that with experimental data.
                       CHAIRMAN APOSTOLAKIS: Everybody does use
                       MEMBER KRESS: Yes, but --
                       MEMBER POWERS: Greenfield, developing
           experimental data uses that terminology.
                       CHAIRMAN APOSTOLAKIS: That type of data
           goes into the distribution.
                       MEMBER POWERS: I know PRA has never
           recognized experimental data, but the rest of us
           actually work with that.
                       CHAIRMAN APOSTOLAKIS: We're talking about
           bigger people here.
                       MEMBER FORD: If I could suggest --
                       CHAIRMAN APOSTOLAKIS: Give me one
           probability that talks about this.
                       MEMBER KRESS: Oh, I can show you two or
           three of them.
                       MEMBER FORD: I think I've lost control of
                       CHAIRMAN APOSTOLAKIS: Back to you, Mr.
                       MEMBER FORD: No, he's not ready yet.  
                       MR. HISER: Can I just make one comment?
                       CHAIRMAN APOSTOLAKIS: Final comment, yes.
                       MR. HISER: The intent is to do
           probabilistic fractured mechanics assessments.  What
           would go into that is this variety of crack growth
                       CHAIRMAN APOSTOLAKIS: I understand that.
                       MR. HISER: Along with other parameters. 
           So that would be considered under the PFM analysis.
                       MEMBER FORD: Okay.  The objective of this
           particular meeting was just to let the full, all the
           members know that we are advancing on this problem
           which is a generic problem in my view.  We were
           planning on having a material subcommittee full-day
           meeting on this in February sometime.  We may need to
           have it beforehand if we have any added value to the
           full process.
                       On that ground rules, I'd like to go
           around to the members and just ask if they've got any
           closing opinions, statements, on what they've heard so
                       MEMBER POWERS: I'm just tempted to say
           something abusive about Dr. Apostolakis' views about 
           the distributions.  I'll do that on the fly.
                       MEMBER FORD: Jack?  George?
                       CHAIRMAN APOSTOLAKIS: I have a lot to say
           but I think it's too late.
                       MEMBER KRESS: One point.  You know, we
           were debating about the source of which confidence
           level and which confidence on that we would use, and
           if you're going to use it in an overall probabilistic
           fractured mechanics, you ought to use them all to get
           a final distribution.  But that doesn't solve your
           problem because then you're going to have to look at
           final distribution and say which part of it is of
           interest to me?  
                       I'd like to point out that Dr. Apostolakis
           has said many times that this is good place to use
           formal decision theory in order to decide where to use
                       MEMBER POWERS: He's just as wrong about
           that as he is about unprobability distributions too.
                       MEMBER KRESS: Yes, so I just wanted to
           make that comment.
                       MEMBER FORD: Steve?
                       MEMBER ROSEN: I'd like to make a comment
           on the pictures being worth a thousand words.  The
           discussion that we had earlier seems to be
           extraordinarily tortured in trying to say that, for
           example, this picture is not in fact some evidence of
           leakage from a crack, and, I'm left very unconvinced
           of all that rationale.
                       MEMBER LEITCH: I'm a little confused by
           initial  crack size versus crack growth.  I don't have
           any idea -- I'm sorry.  I said I'm a little confused
           by initial crack size versus crack growth.  Do we have
           any idea that when these cracks occur, they go to some
           particular depth immediately.  
                       And, what we're talking about here is the
           growth after that initial cracking?  Until we know
           what that initial depth might be, is there any thought
           or discussion on that, or -- in other words, do they
           grow at the rates we've been talking about here from
           zero, or what I'm saying, isn't there an initial crack
           and then what we're talking about is growth rate? 
           That's what I don't quite understand.  I don't know if
           there's any information in that regard.
                       MEMBER FORD: Quickly within the next ten
                       MR. HISER:   There is uncertainty on
           exactly what is going on.  Clearly the crack growth
           rate that we're using is  fracture mechanics based. 
           It has certain assumptions to it, and does not apply
           from zero, from the incipient crack.  That is the kind
           of thinking that we need in a more phenomenological
           model to be able to extend this in a more scientific
           basis overall.
                       MEMBER FORD: Graham?
                       MEMBER WALLIS: All this is based on crack
           growth and PWR environments.  I think you need to do
           more on crack growth in a crack environment with the
           real, some assessment or enough assessment of chemical
           flow or electromagnetic, all the things that are going
           on there, and I don't have a good factor for it.  
                       But conceivably, you could have fluid
           coming out of there at Mach 5 or something, whatever
           it is, you know, drifting away to it.  I don't have a
           clue.  But you haven't really said anything about what
           happens to flow dynamically, chemically and all of
           that and that is part of the problem.
                       MEMBER FORD: I'd like to finish off just
           by thanking all the presenters and apologizing for
           pushing you so much.  We had only a little time.  The
           main objective, as I said before, was just to let the
           full committee know that we are moving forward on this
                       I think we have a material subcommittee
           potentially planned for February sometime, and if
           there's any value added, as I say, to our involvement
           before then, we're open.
                       George, I pass it back to you.
                       CHAIRMAN APOSTOLAKIS: Thank you, Peter. 
           We will recess until five minutes after 11:00.
                       (Whereupon, the above-entitled matter went
           off the record.)
                       CHAIRMAN APOSTOLAKIS: Okay?  The next item
           is licensing approach for the Pebble Bed Modular
           Reactor Design.  Doctor Kress will guide us through
           this topic.
                       MEMBER KRESS: All right.  There's two
           parts to this.  You say one of them talks about the
           future plant design workshop that Dana Powers and I
           have participated in on October 10th and 12th.  
                       I don't intend to say anything about that
           because Dr. Powers once again has issued a remarkable
           trip report on this, and I recommend to read it to get
           the summary of that.  I don't know if Dana wanted to
           say anything about that particular workshop more than
           his trip report or not?
                       MEMBER POWERS: No, I do note that Dr.
           Kress listed a set of 17 or 18 regulatory challenges
           that he distilled out of the meeting that also should
           be examined in conjunction with the trip report.
                       MEMBER KRESS: Yes, those didn't
           necessarily all come from that one workshop, but --
           yes.  Also, I remind the committee that during our
           October ACRS meeting, we had a presentation from
           Exelon giving us their proposed licensing approach for
           the next PBMR.
                       I won't have to remind you of what that
           approach is because I'm pretty sure the staff plans on
           reminding us of what it was.  I thought it was a very
           interesting approach and, in fact, I thought it was a
           pretty good one.  But today, we're hearing from the
           staff what their view of this approach is and perhaps
           what issues, policy and otherwise that it might raise.
           Then I guess I'll turn it over to who over here?
                       MR. LYONS: I guess I'll start off.
                       MEMBER KRESS: Okay.
                       MR. LYONS: I'm Jim Lyons.  I'm with NRR. 
           I'm the Director of the New Reactor Licensing Project
           Office.  Today, as Tom was saying, we want to come
           back and talk to you a little bit about the licensing
           approach that Exelon is proposing, and we've got a
           presentation to go through how we are seeing this. 
           Actually, here's Tom.  Do you have some opening
           remarks Tom that you want to make?  
                       MR. KING: You may hear a status report on
           what we think of the Exelon proposal for fitting their
           design, the Pebble Bed into today's set of
           regulations.  You're going to hear our thoughts on how
           we're looking at that, what criteria, thoughts we're
           using to try and make a judgment on whether that's
           okay or not okay, and again recognize that there's no
           final decisions.  
                       There's probably some policy issues that
           are going to come out of this that ultimately the
           commission's going to decide.  But at least it will
           make you aware of what they're proposing and what our
           thoughts are at this point on it.
                       CHAIRMAN APOSTOLAKIS: Okay.  
                       MR. KADAMBI:  Thank you.  Good morning Mr.
           Chairman, and members of the advisory committee.  My
           name is Prasad Kadambi.  This is Eric Benner and this
           is a joint NRR research presentation.
                       We had an abbreviated presentation last
           month and we'll try not to repeat some of the things
           that were covered in some detail.  This presentation
           is somewhat preliminary, only to the extent that we
           are looking for feedback from the committee, and we
           want to take into account whatever we can glean from
           the questions and comments, et cetera, so we can
           reflect it in the commission paper which is due this
                       We are looking for your questions,
           concerns about the proposed licensing approach, and
           our assessment of the licensing approach.  We'd like
           to --
                       CHAIRMAN APOSTOLAKIS: Excuse me.  We will
           review that document you will send to the commission?
                       MR. KADAMBI: Well, a predecisional draft,
           I believe, has been provided.  I mean, we are looking
           for this feedback during the meeting and a letter if
           you feel it's necessary, but we are not necessarily
           requesting a letter.
                       The presentation that we will make broadly
           follows the format of the paper.  The message that we
           got last month was that the ACRS wanted to hear more
           about the staff's overall approach, including any new
           ideas that we may bring to the table.  
                       Our overall approach is to use the
           commission's directions, decisions, and policy
           statements to build a foundation for the PBMR
           Licensing Review.  We found a lot of guidance in these
           documents and we feel that there is enough to proceed
           along the lines that we'll describe.
                       What we did not set out to do was, if I
           may so say, build a better mousetrap where, you know,
           we would start from a clean sheet of paper and try to
           invent a regulatory system or framework.  We believe
           that a separate effort is underway.  We don't know
           very much about it, but we believe that NEI is going
           to be undertaking something like that.
                       As we said, the licensing of Fort St.
           Vrain more or less began our venture into using the
           current regulations into licensing something that is
           not a lightwater reactor.  Eric, do you want to talk
           about that?
                       MR. BENNER: Yes, and again to emphasize
           what Prasad was saying, and I believe you heard some
           of this yesterday, that there are activities going on
           both with the DOE NERI Project and NEI and looking at
           building on 3, to look at a more clean sheet of paper
                       There's a commission paper due on that
           middle of next year to look at various options, and I
           believe one of the options that's going to be
           considered is, you know, how would you apply the
           current regulations with some other sources of
           information to see how they fit, along with the clean
           sheet of paper to see the relative merits of the
           different approaches.
                       Basically, the group that was accessing
           Exelon's approach looked at the licensing of Fort St.
           Vrain more to assure itself that there is a way that
           you could use the current regulatory structure to
           license a non-lightwater reactor, and the meat of that
           was really the applicability of the GDC, which for the
           most part are pretty general.  And, at that time, the
           staff also focused on some of these higher level
           topics of defense-in-depth and multiple concentric
           barriers to contain radiation.
                       This was sort of the stepping stone for
           the staff's look at Exelon licensing approach just to
           see whether there was merit to moving forward with
           using the existing regulations as a licensing
                       The next thing the staff looked at was the
           pre-application review for the MHTGR.  The meeting
           that took place in the mid-`80's, the MHTGR was a gas-
           cooled reactor.  At that time, it had a steam cycle
           and recently General Atomics has somewhat modified
           this design to make it direct cycle, and we're going
           to be talking about the application review of that
           sometime in the future with the ACRS.
                       But for this review, there was extensive
           staff work and DOE work on a licensing approach that
           was very similar to what Exelon is proposing, and at
           that time, the staff looked at conformance of the
           approach with the advance reactor policy statement as
           well as, just like in the case of the Fort St. Vrain,
           the NRC regulations, reg. guides and standard review
           plan that they found to be applicable.
                       Staff provided assessments in a new reg in
           1989.  After that time, there were the design
           certification reviews going on for AP600, ABWR, and
           System 80 Plus, and during those design
           certifications, whenever the staff distilled an issue
           that they thought would be applicable to the MHTGR,
           they kind of put it off to the side and tried to
           address it in the communications that were going back
           and forth between the commission and the staff.  
                       The staff basically wrapped all those up
           in a paper to the commission containing a draft new
           reg in 1985 and kind of discussed where they were
           applicable and how they were applicable to the MHTGR,
           and essentially the gas-cooled reactor technology.
                       So, we have used a lot of the findings
           that the staff provided at that time also as a basis
           for our review.
                       MR. KADAMBI: What we have tried to do in
           trying to identify the main considerations that would
           be the basis for the staff's review is to more
           specifically sort of identify the particular
           commission directives and decisions and the policy
           statements in the context of the agency's strategic
           plan and performance goals.
                       So what I'll try to do over here is try
           and describe the individual components that we feel
           are relevant in doing this.  The advance reactor
           policy statement in a sense provides a guidepost,
           although it's not a qualitative one, it does say that
           as a minimum, an advanced reactor should provide the
           same degree of protection as the current fleet of
           operating reactors.
                       CHAIRMAN APOSTOLAKIS: How do you mention
                       MR. KADAMBI: Well, in a sense that's a
           separate question which, you know, at this point I'm
           trying to in a sense define the problem areas.
                       CHAIRMAN APOSTOLAKIS: As a guidance?
                       MR. KADAMBI: Yes.
                       CHAIRMAN APOSTOLAKIS: Okay.
                       MR. KADAMBI: So, trying to just lay out
           the framework, if I can use that word, the policy
           statement also says that the commission expects that
           using simplified inherent passive or other innovative
           means that enhanced safety margins would be realized.
                       MEMBER WALLIS: How can you have the same
           degree of protection and enhance safety margins at the
           same time?  No, it's at least the same.
                       MR. KADAMBI: Yes.
                       MEMBER WALLIS: Oh, at least.  Okay.
                       MR. KADAMBI: And I believe that one way of
           looking at it, at least this is the way I look at it 
           and some of these things are my own thoughts right now
           is that you ought to have more confidence that you're
           achieving a given level of safety on some distribution
           when you're using these simplified methods, et cetera.
                       MEMBER WALLIS: Oh, you should go with the
           95/95 one.
                       MR. BENNER: During the design
           certifications that we did go through, some of that
           expectation was realized through some of the severe
           accident management expectations.  So that may be
           another way where we talk about enhanced margins for
           this particular advanced design.
                       MR. KADAMBI: In fact, the decisions that
           were taken on AP600, System 80 Plus, et cetera, do
           show us how the advanced reactor policy statement and
           the current set of regulations are brought together in
           order to accomplish what the commission wanted.
                       In all, this is what we perceive as
           essential to the role of defense-in-depth philosophy. 
           This can not be stressed enough.
                       MEMBER WALLIS: Sounds like a religious
           statement, invoking.
                       MR. KADAMBI: In many ways --
                       MEMBER WALLIS: It is.
                       MR. KADAMBI:  -- it has become that.
                       CHAIRMAN APOSTOLAKIS: Is what?  I didn't
           get it.
                       MEMBER WALLIS: Religious statement,
           invoking virtue by appealing to the sainthood so the
           sanctity of the defense-in-depth.
                       MEMBER POWERS: Yes, but it's --
                       MEMBER WALLIS: Sure, some of us.
                       CHAIRMAN APOSTOLAKIS: Raise the slide
                       MR. KADAMBI: It's such a vague thing.
                       CHAIRMAN APOSTOLAKIS: Put it higher, the
           slide itself.  
                       MEMBER WALLIS: Like saluting the flag or
                       MEMBER POWERS: Well, I don't know that I
           would agree with you that the depth is vague.
                       MR. KADAMBI: At least if I may, I'd like
           to go to what we have found from the commission's,
           again various documents that we have seen to identify
           the individual attributes that feed into defense-in-
           depth, and to some extent this is where, you know --
           we begin with the basic objective of finding a
           defensible basis for making an adequate protection
           finding, and because defense-in-depth is so key to
           that, there are several sources where we can find
           guidance on what we look for on defense-in-depth.
                       The white paper called Risk Informed and
           Performance Based Regulation, which was issued in
           March of 1999, you know, it was issued to the public
           and to the staff with the commission direction that it
           should be used.  You know, it says that defense-in-
           depth is the employment of successive compensatory
           measures of prevention and mitigation.
                       It is something that does not wholly
           depend  on any single element of design construction,
           maintenance or operation.  It's something that if it
           is done right would be more tolerant of failures and
           external challenges.  
                       MEMBER WALLIS: All of which needs to be
           quantified in some way.
                       MR. KADAMBI: Certainly as we get into the
           details of a given design, you know, these are the
           sorts of things that we would seek to quantify.
                       Further in specific applications, relative
           to the risk informing effort of Part 50, Option 3, the
           staff further identified elements of defense-in-depth
           that are dependent on risk insight and those that are
           independent of risk insight.
                       Examples of those that are dependent on
           risk insight are limiting initiating events, cold
           damage frequency releases, et cetera, and achieving
           the kind of safety function probabilities that would
           be consistent with what needs to be achieved.
                       The elements that are independent of risk
           insight are things like balance between prevention,
           containment, consequences, the avoidance of reliance
           on programmatic activities and, you know, adhering to
           the principles of the general design criteria.
                       So, you know, these sorts of things that
           we have done in the recent past give us, we believe,
           a sufficient high level of guidance on how we can deal
           with the concept of maintaining safety.
                       The next performance goal I'd like to
           address is increasing public confidence.  Again, I see
           some significance to the vector that's associated with
           the performance goal, that this is something that we
           want to increase, and I believe that increase would be
           relative to where we are on the current generation of
                       MEMBER POWERS: Before you go on to public
           confidence, could I come back to maintain safety?
                       MR. KADAMBI: Sure.
                       MEMBER POWERS: It seems to me that there
           is an element missing here and it's born of the fact
           that when you look for guidance from the regulations
           that have transpired over the last 25-30 years, you're
           looking at a fairly well established technology as far
           as the material.  
                       And yet, just minutes ago we heard a
           presentation on where this relatively established
           materials and technology is surprising those that have
           tended and cared for it, because things break that
           they didn't anticipate breaking.
                       Now, with some of these new concepts,
           either the gas-cooled reactor, you're wandering into
           an area of materials that you have relatively little
           experience with, relative to the kind of support
           infrastructure that you have with metals and things
           like that.  And I'm wondering if there isn't room in
           this for some appeal to a generally conservative
           design philosophy in your list of things that you're
           looking at?
                       MR. KADAMBI: I think --
                       MR. BENNER: One of the things we have been
           doing, and I can't speak for the staff in research,
           but I'm sure they're doing this, the material staff
           and NRR has been working with ASME to start talking
           about what some of the materials challenges are going
           to be for the licensing of future designs.  And as far
           as whether there will be, you know, that we'll try to
           employ general conservatism overall or just in those
           specific areas where we don't feel comfortable with
           materials, I don't think we've gone that deep into the
                       MEMBER POWERS: I think you need to
           recognize no matter how much talking with ASME you do,
           even they will not have the kind of database and
           experiential base that you have with the metals that
           you're using in the current fleet of reactors.
                       MR. BENNER: That's been a struggle is
           trying to get materials data and Raj Pathania of
           research has been working to get access to a graphite,
           a radiated graphite materials database from IAEA as
           one source, and obviously the staff's going to have to
           look at the available data and determine.
                       MR. KING: I think it's important to
           recognize that Fort St. Vrain was not the only
           graphite reactor run in this country, that there was
           a very large one up in the northwestern part of the
           United States, and that they have quite a lot of data. 
           Unfortunately you can't get their kind of graphite,
                       MEMBER POWERS: But I think what your point
           is how do you compensate for the lack of data, whether
           it's materials, graphite or anything else?  In
           principal, the way you do that is you develop a
           monitoring program that maybe is more extensive than
           you would if you had such data.  I think it's part of
           the research and part of looking at what we ought to
           do in licensing these plants.
                       I think monitoring is one aspect to it. 
           I think holding people to a more conservative design
           standard is another one.  There's probably a trade-off
           there someplace, but it's not a complete substitution. 
           A lot of what we're doing in the regulatory body
           nowadays could be interpreted as a liberalization born
           of the fact, you know, we have 3,000 reactor years of
           operating experience with the current fleet and we
           shouldn't leap to the belief that that liberalization
           is applicable to some new design.
                       MR. KADAMBI: I think we agree.  
                       MEMBER POWERS: I encourage you to
           articulate that.
                       MR. KADAMBI: I hope we will as we go
           through this.  I think it's really part of what
           underlies everything we have to say about how we will
           proceed with the review.  
                       Anyway, on the matter of increasing public
           confidence, again we believe the advance reactor
           policy statement did state that we should provide
           stakeholders a timely and independent assessment and
           that's one of the reasons we are trying to abide by an
           aggressive schedule to bring out, you know, what the
           current thoughts that the staff have are on this
           matter.  And also, we are of course being very careful
           to provide opportunity for feedback and comment on the
           part of all stakeholders at every opportunity.
                       Now in terms of increasing efficiency,
           effectiveness and realism, we find many of the
           elements that have been described in Reg. Guide 1.174,
           again the white paper, and the Option 3 Framework to
           be useful in proceeding.  Reg. Guide 1.174 does talk
           about using appropriately the exemption process.
                       Again, being consistent with defense-in-
           depth philosophy, assessing safety margins very
           carefully, paying attention to performance monitoring,
           the safety goal policy, all these things come together
           in terms of how the particular issues that were dealt
           with in Reg. Guide 1.174 were dealt with, even though
           that was really in the context of making changes to
           the licensing basis.
                       In the white paper, there is reference to
           performance based approaches and the staff has issued
           high level guidelines for performance based activities
           which in some matter may appropriately be applicable 
           in increasing efficiency effectiveness and realism.
                       The Option 3 Framework also stressed
           defense-in-depth philosophy, and consideration of core
           damage accidents.  By the way some of these things,
           you know, we just don't really know what the
           equivalent would be in a Pebble Bed reactor, but at
           least conceptually these are the things we would be
           looking for, and of course, the stress on all the
           different types of uncertainties that one should pay
           attention to.
                       On the fourth performance goal of reducing
           unnecessary regulatory burden, what we find is that
           the commission has over the years stressed the rule of
           the safety goal policy statement as defining -- I
           mean, at least providing a basis for saying how safe
           is safe enough?  You know, of course this raises
           policy issues  some of which we will talk about later,
           but in addition to this performance based approach,
           where appropriate could mitigate some regulatory
           burden by providing licensee flexibility, provided the
           margins are maintained.
                       Now this picture you saw last month and we
           wanted to make it available here just to provide a
           basis for how we are viewing this effort of screening
           of the regulations.  What we'd like to stress is, we
           will independently, you know, undertake the kind of
           screening required, but the process itself, the logic
           flow seems to be adequate to proceed.
                       CHAIRMAN APOSTOLAKIS: Now, let me
           understand this a little better.  I see under the
           diamond that says "compare completely applicable,
           partially not applicable, PBMR specific."  So, where
           is it that we're adding things, adding regulations to
           replace the ones that aren't applicable, under PBMR
                       MR. KADAMBI: Correct, although they may
           not be regulations.  They may be regulatory
           requirements through license conditions.
                       MR. BENNER: I think there are two things
           that go in that box, and there are some places where
           a regulation may not be applicable just on its face
           because of the language, but there's an underlying
           concern that drove the staff to move towards a
                       CHAIRMAN APOSTOLAKIS: Which was my next
           point.  If you go up to the left, it says "function
           level or intent of regulations."  So when it says
           "partially applicable" is it referring to the
           regulation itself or its intent?
                       MR. BENNER: The Exelon approach talks
           about partially applicable, as when you have a
           regulation that has three parts and two parts are
           applicable and one is not; whereas, there are like we
           just talked about, applications that on their legal
           face may not apply, but there's an intent there, and
           how that gets handled as applicable or have to come up
           with a PBMR specific license condition, we're still
           working with OGC on that.
                       MEMBER WALLIS: I'm a little bit puzzled by
           the logic flow here.  I don't see how you can design
           a PBMR if you don't know what the rules are.  You sort
           of assume the thing is designed and then someone
           figures out how to regulate it?
                       MR. KADAMBI: Well, I mean the design, I
           believe a case that's been presented to us so far,
           which is at a relatively high level, it doesn't have
           a lot of details in it, but it's based on certain
           physical principles that will --
                       MEMBER WALLIS: So what can you change, how
           it's operated or what?
                       MR. KADAMBI: I mean certainly at some
           point, you know, if we don't have sufficient assurance
           of some physical capability beyond the operational
           aspect may have to be changed.  But right now, we see
           the PBMR specific box being populated entirely by, or
           substantially by, you know, the right side of this
           diagram.  And so, you know, it's not that we don't
           know anything about the PBMR, but we certainly don't
           know enough to see --
                       MEMBER WALLIS: So a cynic might claim that
           you're going to be confronted with an existing design
           and you're going to be told "find a way to license
                       MR. BRENNER: Well, part of the pre-
           application review and part of the discussions we're
           having with Exelon is to, as we get some design
           assumptions, to determine what regulations are
           applicable so that they can make changes to the design
           now as opposed to when they come in during the
           licensing phase.
                       MR. KING: That's the main purpose of the
           pre-application phase to dig out these things up front
           before they've gone through and spent a lot of money
           to develop a final design.
                       CHAIRMAN APOSTOLAKIS: Part of the problem
           with this approach though, which you have not said you
           have accepted or whatever.  I realize you're
           presenting what Exelon has presented.  It's something
           I think Tom King also referred to yesterday.  If you
           just do it this way you may, you know, be gaining
           perhaps efficiency in the short term, but in the long
           term maybe not because now what do you do?  Next time
           you have an IRIS, then you do the same thing and now
           you have IRIS specific, then something else.
                       Wouldn't it be better to try to think a
           little more broadly and see what kinds of fundamental
           principles and requirements we want to have for all
           technologies, and then have the box that says this is
           technology specific, not technology specific.
                       MR. BENNER: I think that's the goal of
           where eventually we're trying to get to, because some
           of the people on the working group looking at this
           approach are also supporting and looking at Option 3
           and advance reactor regulatory framework so that
           hopefully in going through this, we're trying to keep
           our eyes open for where, you know, because of
           something that the staff and the applicant wrestled
           with, does a principle come out of that that needs to
           go up to the highest level.  And also, have we
           identified a gas cooled reactor specific requirement
           that needs to go  on the lower level, whatever it ends
           up being, whether it be a regulation or a guidance
                       VICE CHAIRMAN BONACA: It has to be high
           enough and flexible enough that it doesn't prevent
           innovation in designs.  What I mean is I totally
                       MEMBER KRESS: Well, they have two
           problems.  One of them, Exelon has come in with this
           as a proposed approach and they want to know what the
           staff thinks about it, so they have to focus on that. 
           But  how many times they've done, they can be thinking
           about how to have general principles that focus their
           attention on what they think about it.
                       VICE CHAIRMAN BONACA: Sure.
                       MEMBER KRESS: I think they're working both
           sides of it.
                       MR. KING: And the two compliment each
           other, because the PBMR illustrates a number of issues
           that we're going to have to deal with on future
           plants, containment issue, the emergency planning
           issue, a number of these key issues.  So, it's useful
           to have the two going on in parallel because they do
           cross fertilize each other.
                       MR. BENNER:  We can go on.  I think we've
           really covered most of what was on the slide in the
           discussion of the graphic.  So, basically it's screen
           the regulations, find out the applicable ones, apply
           them, and final determinations will be made by the
                       MR. KADAMBI:  You have seen this before
           also, and we just present it to refresh your memory on
                       VICE CHAIRMAN BONACA:  Yes.  One question
           I have on this.  This clearly is not -- we discussed
           it.  It was not a frequency consequence curve in the
           sense of integrating all of the results.  It is
           actually a very useful curve to determine initiators
           and frequency that should be associated with them. 
           Would you plan to have also a frequency consequence
           curve that provides the outcome?  I mean, when you
           integrate all of this?
                       MR. BENNER:  In one of the rounds of
           questions we had with Exelon we saw, as one of the
           things they need to do, was to somehow sum up the
           consequences of all the events, or at least show that
           the events they've identified represent the majority
           of the risk, and somehow compare that to the safety
                       CHAIRMAN APOSTOLAKIS:  So how is this
           curve going to be used?  Can you explain to me -- I
           mean --
                       MR. BENNER:  We see this, really, as a
           plot of the -- some of the high-level regulations that
           are applicable to the PBMR.  So it's useful to
           illustrate what some of the bounds are.
                       MEMBER WALLIS:  This is a continuous curve
           and events are all discrete.
                       MR. BENNER:  Discrete.
                       CHAIRMAN APOSTOLAKIS:  But if I enter,
           say, at .1 rem, right, on the horizontal axis, and I
           go up and I hit the mean frequency of 2.5 10-2 per
           reactor year, what does that say in terms of the
           design?  How am I going to use this?  That's what I
           don't understand.
                       MR. BENNER:  I think the way the staff
           sees this as being used as just -- we are going to
           apply the regulations that they reference as they are
           intended to be applied.  This just provides a
           graphical representation.  Basically, we identify, you
           know, events that need to be designed for in the
           design basis region, and they meet -- need to meet
           10 CFR 50.34.  
                       So there -- you know, that's why we don't
           really consider this a frequency consequence curve,
           because that regulation was designed to apply to
           discrete events.
                       VICE CHAIRMAN BONACA:  I mean, they were
           very clear that this was the equivalent of what was
           used in the FSARs when you set the categories, you
           know, anticipated transients and LOCA, and so on.  I
           mean --
                       CHAIRMAN APOSTOLAKIS:  But that doesn't
           make it right.
                       VICE CHAIRMAN BONACA:  No.
                       CHAIRMAN APOSTOLAKIS:  Because, again, you
           know, I have a lot of flexibility in defining the
           events.  That's the problem.  If you say -- you make
           it workable if you say all the events that may lead to
           .1 rem or greater must have a frequency smaller than
           the bound, then it makes sense.  So --
                       MEMBER ROSEN:  All the events individually
           or summed?
                       CHAIRMAN APOSTOLAKIS:  All together.
                       MEMBER ROSEN:  All of them, if you sum
           them up --
                       CHAIRMAN APOSTOLAKIS:  If you sum them up,
           their frequency should be less than 2.5 10-2.
                       MEMBER ROSEN:  Well, that's what this
           curve says.
                       CHAIRMAN APOSTOLAKIS:  No, no.  
                       VICE CHAIRMAN BONACA:  We're talking about
           individual it will be the frequency.  This is
           individual.  This is like saying, for example --
                       CHAIRMAN APOSTOLAKIS:  Pick one.
                       VICE CHAIRMAN BONACA:  -- assume you apply
           this to the current set of reactors.  You would say
           that a LOCA, which has a frequency of 10-4 cannot
           have, you know, a dose higher than -- and you go to
           the right and you find the dose limit for the LOCA. 
           Okay?  All LOCAs individually have a dose higher than
                       MEMBER ROSEN:  So if Exelon says it's --
           you take it event by event, and George has just
           postulated that different one, which is to sum all of
           the events, it should be --
                       VICE CHAIRMAN BONACA:  That's why I asked
           the question -- the first question about a frequency
           consequence curve that would, in fact, integrate.
                       CHAIRMAN APOSTOLAKIS:  That's right.  But
           that was the original intent of the Farmer curve.  It
           was confused and the interpretation was not clear for
           a number of years.
                       MR. BENNER:  We're looking at that two
           ways.  One is --
                       CHAIRMAN APOSTOLAKIS:  By the way, it will
           not be -- it doesn't have to be the same curve you are
           showing there if you interpret it correctly.  You may
           have --
                       MR. BENNER:  And that's one of the things
           we brought up with Exelon about the safety goals
           dealing with the integral.  The other thing we're
           talking about is maybe integrating somehow the area
           under this curve to see where that compares to the
           safety goals, so that while these will be a
           representation of the current regulations, it will
           also give us some guidance as to, you know, maybe for
           the future for developing a frequency response curve.
                       VICE CHAIRMAN BONACA:  I want to say
           actually that the existence of this curve -- it's
                       MEMBER WALLIS:  Do you rely on Exelon to
           determine what the events are, or are you guys going
           to tell them what the events are they must consider?
                       MR. KADAMBI:  Well, we will take full
           liberty to, you know, make sure that the events we
           think are important are considered, along with
           whatever that Exelon proposes.
                       MEMBER WALLIS:  Are you going to imagine
           all of the scenarios and then tell them they ought to
           consider these?
                       MR. KADAMBI:  In some ways, that's part of
           what goes into it is to imagine the scenarios and to
           -- to make sure that --
                       CHAIRMAN APOSTOLAKIS:  Which means to do
           a PRA, right?
                       MR. KADAMBI:  Well, yes.  Eventually,
           that's what it will all lead to.
                       MEMBER KRESS:  Basically, I think in your
           Chapter 15 for LWRs, you have a set of design basis
           events.  And these are things like you have holes and
           you lose coolant or you inject a rod or you have an
           ATWS event or loss of power, and various sets of
           events that have been chosen for -- to look at as
           design basis events.
                       Now, I viewed this as an attempt to decide
           what those events would be for the Pebble Bed Modular
           Reactor.  And you would start out by using similar
           type of things, I think.  Overall grand events like a
           -- like --
                       CHAIRMAN APOSTOLAKIS:  Let's not forget,
           though, that even for the design basis events, after
           we did the PRAs, we did extra things to mitigate, I
           think, consequences, didn't we?  The Level 2 stuff?
                       MEMBER KRESS:  Well, you had --
                       CHAIRMAN APOSTOLAKIS:  I mean, you can do
           the same thing here.
                       MEMBER KRESS:  You had principles like a
           single failure principle, and then you had to meet
           certain figures of merit.  And then, you know, there's
           questions about what --
                       CHAIRMAN APOSTOLAKIS:  The station
           blackout was not a design basis event, was it?
                       MR. KING:  No.  That came because of PRA
                       CHAIRMAN APOSTOLAKIS:  PRA, that's what
           I'm saying.
                       MEMBER KRESS:  Yes.  But now that we know
           that it was an important thing, we might look at it
           for this.
                       CHAIRMAN APOSTOLAKIS:  No.  The point is
           that, again, curves like this -- I mean, we have a lot
           of discussion in Regulatory Guide 1.174 about it
           should not be taken as absolutes with bright lines,
           and so on.
                       MEMBER KRESS:  Right.
                       CHAIRMAN APOSTOLAKIS:  And all of that
           stuff.  But I think that the question, how do you
           determine the so-called design basis events, or
           whether you actually need that, is a good one.  It's
           an important one.  One way of doing it is what Dr.
           Kress just suggested.  But there may be other ways,
           too, or a combination of ways.
                       VICE CHAIRMAN BONACA:  One thing I want to
           note is that to some degree that curve that we liked
           last time at the meeting creates confusion, because
           what I --
                       CHAIRMAN APOSTOLAKIS:  No, I didn't like
                       VICE CHAIRMAN BONACA:  No.  Because we all
           understood -- I understood there was, at the
           beginning, a frequency consequence curve and then we
           discovered it wasn't.
                       CHAIRMAN APOSTOLAKIS:  It was not.
                       VICE CHAIRMAN BONACA:  Typically, the
           expectation for it is to be that, and the fact that
           this is already on paper leads one to believe that it
           has been developed and it hasn't been developed. 
           So --
                       MEMBER KRESS:  But I think if you use that
           kind of curve to select design basis events in a
           particular way, and then you go to frequency
           consequence curves as your figure of merit --
                       VICE CHAIRMAN BONACA:  No, I understand.
                       MEMBER KRESS:  -- to see if -- see if
           these things are -- the design part of these events
           are acceptable.
                       VICE CHAIRMAN BONACA:  I completely agree
           with you.  I'm only saying that the fact that it was
           presented almost made everybody feel, oh, we got it. 
           And, well, we haven't got it.
                       MEMBER ROSEN:  Well, I see the value of
           this is that it avoids the arguments about when
           someone postulates a new event, someone typically
           reacts, "Well, that's well beyond the design basis. 
           We're not going to think about that."
                       MEMBER KRESS:  Yes.
                       MEMBER ROSEN:  And that -- this gets away
           from that completely.
                       MEMBER KRESS:  This -- yes, that gives you
           a way to --
                       CHAIRMAN APOSTOLAKIS:  But it has to be
           right.  It has to be -- the concept of having the
           curve does that.
                       MR. BENNER:  And I think that's a good
           lead-in to our concern about licensing basis events,
           that we do --
                       CHAIRMAN APOSTOLAKIS:  By the way, have
           you seen what the Dutch have done along these lines? 
           They had passed a regulation I think in the late '80s
           where they actually used frequency consequence curves
           in regulating nuclear and chemical plants.  And then
           a few years later somehow they got out of it or part
           of it for some practical reasons that came from
           experience.  So that probably would be another source
           of information for you.
                       MR. KADAMBI:  We'll make note of that.
                       MEMBER WALLIS:  To get back to Dana's
           point about conservative design, in trying to license
           water reactors there was a lot of experimental
           evidence in terms of LOF tests, and so on, and scale
           tests of this, that, and the next thing, because we
           didn't rely just on calculating things.
                       And the impression I get is that this is
           supposedly a more calculable system, so you don't need
           to do a whole lot of these tests?
                       MR. BENNER:  No, I think in -- in some of
           the documentation back to Exelon that we're struggling
           right now with what level of testing is going to be
           necessary to validate any assumptions they may be
                       MEMBER WALLIS:  So is there data on
           combustion of piles of graphite balls in various
           configurations, and so on?  All of that stuff is
                       MR. KING:  That's part of the -- part of
           what we're trying to do now is gather what information
           is out there that supports graphite behavior, fuel
           behavior, high temperature materials behavior, and
           then some judgment is going to have to be made on what
           the licensee or applicant has to do to expand that to
           apply to his design and what we, NRC, want to do to
           have some confirmation of what the licensee is telling
           us, or to push the margins and see where the cliffs
                       That's the thing we talked about yesterday
           when I said for the HTGR we're developing a research
           plan over the next several months, and we're going to
           come to the committee hopefully in February and talk
           about that.
                       MEMBER WALLIS:  But if it's something like
           the LOF tests, then this thing is dead in the water
           because there's not that much money around from the
           agency and the licensees to do those LOF-like tests.
                       MR. KING:  Yes. But maybe you don't need
           a LOF-like test for a helium reactor.  You know, maybe
           you need some smaller scale phenomenology-type test,
           fuel performance, graphite performance.  But those
           questions are still on the table and are going to have
           to be worked out.
                       Part of the pre-application review is to
           try and settle those things up front.  So the licensee
           or the applicant knows if we're expecting a large-
           scale test on some phenomena, that he knows that now. 
           He doesn't know that, you know, two years after he
           submits an application.
                       MEMBER LEITCH:  This mean frequency curve
           has units of per plant year.  Do you know if that --
           by that nomenclature is it meant a module?
                       MR. BENNER:  No, it's up to 10 modules.
                       MEMBER LEITCH:  Up to 10 modules.
                       MR. BENNER:  That's how they're planning
           on --
                       CHAIRMAN APOSTOLAKIS:  So you are
           automatically, then, doing what I suggested at the
           workshop that Exelon didn't seem to like.  You are
           reducing the goals per unit.  Are they aware of that?
                       MR. KING:  It's their proposal.  They came
           in and said that's the way they're designing.
                       CHAIRMAN APOSTOLAKIS:  Did they make it
           clear this is the plant or the unit, the module?
                       MR. KING:  No.  Exelon said, "We are
           considering a plant is up to 10 modules."  And,
           therefore, for an individual module --
                       CHAIRMAN APOSTOLAKIS:  Ah, for an
           individual module the curve --
                       MEMBER KRESS:  -- risk goals will be, you
           know, a factor of 10 less.
                       CHAIRMAN APOSTOLAKIS:  But that's not what
           Eric just told us.  This is for 10 --
                       MR. BENNER:  I thought they flipped it
           around, that these would be applicable to --
                       CHAIRMAN APOSTOLAKIS:  Ten modules.
                       MR. BENNER:  -- 10 modules.
                       MR. KING:  Yes, for common -- where
           there's common cause failures, you know, that they
           would expect all 10 modules to meet that.  Right.
                       CHAIRMAN APOSTOLAKIS:  As a group.
                       MR. KING:  As a group.
                       CHAIRMAN APOSTOLAKIS:  So, in essence, for
           -- on a per module basis, we're going down, the goals
           go down.  Right?
                       MR. KING:  Yes.  Certainly things like
           CDF, if we can define a CDF for this, it would go
                       MEMBER ROSEN:  It would seem to me
           irrational to do anything else.  I mean, you have 10
           nuclear reactors there.
                       CHAIRMAN APOSTOLAKIS:  That's right.
                       MR. KING:  Yes.
                       CHAIRMAN APOSTOLAKIS:  The problem is
           still -- they can come back and say, "Look, we may not
           build all 10 of them," so there may be a period of
           many years where there will now be two.  But, again,
           you know --
                       MEMBER ROSEN:  So you have two critical
           reactors on the site.  But you have to -- you can't
           say that we really -- if you have seven, that you
           really only have one.  That's irrational.
                       MEMBER POWERS:  Yes.  But I guess that
           raises the question, suppose I have one, but I may or
           may not have 10 in the future.  Does that mean while
           I have one I can run that sloppy, and I only have to
           clean my act up when I start adding other modules?
                       MEMBER KRESS:  That's a rationalist
                       MEMBER WALLIS:  The tenth one has to be
           absolutely perfect.  Pristine.
                       MR. BENNER:  I actually think we've
           covered most of this slide.
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. BENNER:  To the concern about being
           able to raise up additional --
                       CHAIRMAN APOSTOLAKIS:  Is licensing basis
           events a new terminology?
                       MEMBER KRESS:  It's like design basis.
                       CHAIRMAN APOSTOLAKIS:  I know.  But it's
                       MR. BENNER:  And it's supposed to cover
           the spectrum, both above and below design basis.
                       CHAIRMAN APOSTOLAKIS:  Well, I mean, it's
                       MEMBER KRESS:  That's right.
                       CHAIRMAN APOSTOLAKIS:  You have already
           assumed, then, that we need licensing basis events? 
           I mean, there would be other ways.
                       MR. BENNER:  Well, I think some of that
           gets into -- for licensing of the first PBMR using the
           current regulations as -- as the scheme.  That seems
           to be an inherent part of how the regulations work.
                       CHAIRMAN APOSTOLAKIS:  In any case, the
           licensing basis is broader, so you have a home there
           to add that in.
                       MEMBER KRESS:  If you had an FC acceptance
           curves you could use the whole spectrum of sequences
           as your --
                       CHAIRMAN APOSTOLAKIS:  On the other hand,
           there is a lot of value to the --
                       MEMBER KRESS:  Oh, yes.
                       CHAIRMAN APOSTOLAKIS:  You make it --
                       MEMBER KRESS:  It really helps --
                       CHAIRMAN APOSTOLAKIS:  It helps everybody
                       MEMBER KRESS:  -- focuses a lot of --
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. BENNER:  I think -- there is where we
           talk a little bit more about what would the licensing
           basis for the PBMR be, and we see it as the set of
           requirements that apply to all of your safety-related
           structure systems and components.  
                       One of the concerns we see in trying to
           assess the acceptability of the design is it relies a
           lot on inherently reliable passive components.  And
           you get into the concerns of what special treatments
           do you need to make sure that, you know, those
           inherently reliable components retain the quality that
           you're assuming of them.
                       Another aspect that came up in the design
           certification reviews was the concept that, you know,
           you would have a lot of these passive systems, which
           would be what you would rely on to mitigate an event,
           but you would also have active systems which would
           provide a defense-in-depth function.  And the
           Commission provided some guidance on how the staff
           should treat those -- those components.
                       One of the things that Exelon proposes,
           which the staff is struggling with, is component-level
           special treatment.  And in the development of the
           special treatment work done on South Texas Project,
           the staff found that that was virtually impossible. 
           That you could look at functions, you could look at
           system requirements, but to try and bring that down to
           the individual component level was very difficult.
                       Now, we're not precluding that.  It may be
           able to be done for the PBMR.  We're just raising that
           as a potential challenge.
                       VICE CHAIRMAN BONACA:  Although I think
           the considerations that Dr. Powers mentioned before
           very much apply here, that, you know, for a lot of
           these materials maybe you have to be more than
                       MEMBER ROSEN:  Well, I think in the case
           of South Texas, the argument was that we had a lot of
           performance-based information about equipment.  And as
           Dr. Powers said, we have a lot of new equipment here,
           and with no history or very little history.  So the
           conditions are different.
                       CHAIRMAN APOSTOLAKIS:  What is the third
           bullet, defense-in-depth also provided for non-safety-
           related SSCs?  What does that mean?
                       MR. BENNER:  That was a concept that was
           really brought up in the review of the AP600, where to
           call it a passive design, they wanted to identify only
           the passive systems as safety-related.
                       CHAIRMAN APOSTOLAKIS:  So that was the
           regulatory requirements for non-safety-related --
                       MR. BENNER:  Exactly.  That's exactly it.
                       CHAIRMAN APOSTOLAKIS:  And we are keeping
           the terminology of safety-related versus non-safety-
                       MR. BENNER:  I think at this point, yes.
                       MEMBER ROSEN:  Why?
                       CHAIRMAN APOSTOLAKIS:  But that's a
           problem now.  We are keeping everything from the
           existing regulations that in another arena we're
           trying to get rid of.  I realize the problem you are
           having, but at least say that it's something you're
           going to think about.  I realize that, you know, you
           really have to start somewhere and proceed.
                       MR. KADAMBI:  And also, this is part of
           what Exelon has proposed.  You know, they have kept
           the terminology, and they are defining it in a certain
           way, and we are looking at it in the context of, you
           know, can it be applied in the context that they
           are --
                       CHAIRMAN APOSTOLAKIS:  Well, is there a
           methodology in the existing regulations for defining
           what is safety-related?
                       MEMBER KRESS:  Sure.  It's what's needed
           to meet the figures of merit for the design basis --
                       MEMBER POWERS:  But, I mean, this does
           strike me as one of the areas I -- this is going to
           pain me to admit -- where -- that's the strength of
           the probabilistic-type analysis methods, were you can
           look at the plant in some sort of an integrated
           fashion and escape the problems that arise when you
           look at it in train-by-train fashions that it was done
           in the past.  It was done by necessity in the past.
                       It seems to me that this is one area that
           the -- where the rationalists and the structuralists
           really agree on this is this -- in the categorization
           of equipment is where the PRA really has a strength.
                       MEMBER KRESS:  And like they say, there's
           a problem doing that down at the component level.
                       MEMBER POWERS:  Because it'll show up in
           the PRA.
                       CHAIRMAN APOSTOLAKIS:  I must say, though,
           that I'm very happy that Dr. Powers has not entirely
           lost his ability to reason rationally.
                       MEMBER ROSEN:  He is a structuralist with
           some rational tendencies.
                       CHAIRMAN APOSTOLAKIS:  Flashes of
                       MEMBER ROSEN:  Flashes, yes.
                       Whereas I am a rationalist with some
           structuralist tendencies.
                       MR. KADAMBI:  We have tried to identify
           some potential policy issues.  At this stage, it's a
           little premature to present this to the Commission as
           policy issues.  We're still working on them.  We have
           to keep in mind that this is the review that we did of
           a submittal that we got in August -- on August 31st,
           and we are still, you know, developing information.
                       But the sorts of things that will
           certainly lead to policy issues are the use of
           probabilistic criteria, where maybe they have not been
           used before.
                       MEMBER KRESS:  Haven't we always done
           that, though?
                       CHAIRMAN APOSTOLAKIS:  For seismic, I
           think we have.  We've always --
                       MEMBER KRESS:  I thought we've always done
           that, even with the fully structuralist deterministic
                       MR. KING:  Well, we've done it
           qualitatively. I mean, everybody has sort of had, you
           know, something qualitative --
                       CHAIRMAN APOSTOLAKIS:  But that -- with
           one PRA, I mean --
                       MR. KING:  But, remember, what's being
           proposed are some quantitative frequency guidelines
           that you would decide what's in and what's out for the
           design, and that's going beyond what we've done in the
                       Now, maybe we've done it probably in a
           couple limited situations.  We've put some numbers in
           a Reg. Guide or a standard review plan.  But this is
           across the board, everything.
                       MEMBER POWERS:  But we always defined
           accidents and scenarios based on whether they were
           credible or not.  And some people I think define
           credulity with a number, but the fact is we've always
           used risk as a --
                       VICE CHAIRMAN BONACA:  But one thing I
           wanted to say is that it is also true that there are,
           for example, events -- and I think it's important for
           the presentation we had this morning, like rodejection
           accident.  At some point, it was a true proposal on
           the floor for years to eliminate it because it cannot
                       Well, I mean, we are not looking now at
           cracks in CRDM nozzles, and suddenly, you know, this
           exercise in reactivity insertion becomes more
           credible.  So I think -- I think it's a dilemma
           they're facing.  Sure, I mean, because at some point
           in time you might find something like this so unlikely
           that you just don't consider it.
                       CHAIRMAN APOSTOLAKIS:  But the thing is --
           I think Tom is right.  I mean, if you say go with
           option 3, which gives you high-level frequencies for
           core damage for LWRs and protection, and so on, then
           what do you do with that?  I mean, you have to keep
           going down to the design, right, and have some
           quantitative criteria or goals or guidance -- not
           criteria -- guidance for function level on
           availabilities, and so on.  And I think that's fine. 
           I mean, it is something that the Commission should
           explicitly comment on and decide on.
                       MR. KING:  But see, option 3 is looking at
           an existing set of regulations and hopefully approving
           them.  This is taking a clean sheet of paper and a
           design and saying, "I'm going to use probabilistic
           numbers to decide what we'll design for and what we
           don't design for."  That goes beyond where we've used
           probabilistic information in the past.
                       CHAIRMAN APOSTOLAKIS:  Yes.  But option 3,
           even for LWRs, I mean, it just says the core damage
           frequency should be this.  But, I mean, if you wanted
           to design in your reactor -- a new LWR with that, you
           will need some guidance how far down to go with these
                       MR. KING:  And you could take the option 3
           guidelines and design a reactor to those.  The policy
           question I see for the Commission is, do we want to go
           that far in applying probabilistic -- quantitative
           probabilistic guidelines?
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. KING:  And what other factors do we
           want to bring into this decision?
                       CHAIRMAN APOSTOLAKIS:  I think it's going
           to be a combination.  There's no question about it. 
           It's not going to be just the numbers.
                       MEMBER ROSEN:  I heard an answer from
           someplace over in the rational corner here.  But I
           want to -- the question I have is about the process. 
           Are we going to weigh in as ACRS on these questions?
                       MEMBER KRESS:  Oh, probably eventually,
           maybe not right now.  We're already weighing in a
           little bit.  But as I see it, Tom, the -- we -- these
           policy issues come head to head with our -- what our
           definition, and I consider it a limited definition, of
                       That's where there is a collision  here,
           and the question is, if you just use pure
           probabilistic criteria, you have to decide on where
           defense-in-depth fits into that choice to making these
           decisions.  I think that's the issue, and I think it's
           going to require a little bit different thinking than
           on what defense-in-depth is, more than what's in 1.174
           and more than what's in option 3.
                       MR. KING:  Yes, I agree with you.  And at
           this point, we're not asking for the Committee to
           weigh in on these policy matters, because we haven't
           reached a position yet on it.  Just for information,
           you know, that these are coming down the road at some
                       CHAIRMAN APOSTOLAKIS:  I think the first
           bullet, though, might scare people.
                       MEMBER WALLIS:  I don't understand the
           first bullet.  Do you mean --
                       CHAIRMAN APOSTOLAKIS:  Why don't you say
           use the risk-informed approach to selecting licensing
           basis events.
                       MEMBER WALLIS:  But you first have to
           analyze a whole lot of events.  Then you --
                       CHAIRMAN APOSTOLAKIS:  Well, the
           implementation is somebody else's problem.  But here
           they talk about criteria, which I think is going to
           scare everybody.  It would be a risk-informed approach
           to selecting the licensing basis events, right? 
           That's what you are talking about.
                       MR. BENNER:  Well, and I think that's part
           of our concern is that we see in the approach being
           proposed that it -- that it does have the use of
           probabilistic criteria --
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. BENNER:  -- where we're saying in the
           risk-informed approach idea that, well, you need to
           have some deterministic portion that --
                       MEMBER KRESS:  Yes.  And my point about
           defense-in-depth needing a new interpretation had to
           do with if you just look at the, say, frequency
           consequence type thing to get a selected event that
           you design against, I think you have to look very
           strongly at the uncertainties associated with each
           frequency, its contribution to the uncertainty.  And
           you can't just use the number as is, and that's where
           you go a little deeper in your defense-in-depth
                       MR. KING:  Yes, I agree.  What confidence
           level do you want?  And, you know --
                       VICE CHAIRMAN BONACA:  Well, and there has
           to be the balance there, because, I mean, again, I
           want to say that for extreme events that often times
           one could say you can't rule it out, the -- the
           assumption of those events, in the current generation
           of plants, led to -- to the design of certain
           parameters that served us very well for more probable
                       I'm trying to say, for example, all of the
           characteristics that we implemented in -- for negative
           coefficient reactivity, and so on and so forth, there
           were results of some evaluation of extreme events that
           we thought were very improbable or unlikely and maybe
           couldn't happen.  But the fact that you assumed it
           purely for the purpose of certain characteristics of
           the reactor, that it served you well for less severe
           accidents that are more probable.
                       So I think it's a very -- it's a very
           critical area, this one here.
                       MEMBER ROSEN:  But you will acknowledge
           the trap in that as well.
                       VICE CHAIRMAN BONACA:  Of course, I'll
           acknowledge the trap.  I'm only saying that in design
           -- when you design something, you don't assume
           necessarily only what is going to happen.  You assume
           you bound certain conditions so that you can define
           coefficients and certain characteristics of the plant
           that will serve you well for less severe but more
           probable events, and --
                       MEMBER ROSEN:  But never assume the vest
           of invincibility simply because you have --
                       VICE CHAIRMAN BONACA:  Of course.
                       MEMBER ROSEN:  -- created some design
           basis events, and, therefore, everything less than
           that is okay.  We know from bitter experience that
           that's not true, that you have to go event by event
           and think -- and think each event through.
                       VICE CHAIRMAN BONACA:  Well, and say that
           you do that, and --
                       CHAIRMAN APOSTOLAKIS:  Right.  Let's come
           back to these fellows.  Anything else you would like
           to say?
                       MR. KADAMBI:  I think we're about ready to
           wrap it up.
                       CHAIRMAN APOSTOLAKIS:  Very good.  Have
           you wrapped it up?
                       MR. KADAMBI:  Well, unless there are any
           questions, I believe that we are done.
                       MEMBER WALLIS:  My feeling is all of this
           sort of theoretical.  It's an approach, and I think
           that if you start looking at specific events which are
           unique to this particular system, like if we're
           getting into the compressor and there's a loss of
           compressor accident, what happens, see whether you can
           handle it using some of the ideas you've got here, or
           whether you come up against something else which you
           haven't thought of that you have to think about at the
           fundamental level.
                       MR. BENNER:  And that's what we've tried
           to feed back to Exelon, that we may not need a
           complete design to start exercising this approach, but
           if we wanted to take some -- you know, some select
           event and determine what --
                       MEMBER WALLIS:  There's things having to
           do with water reactors that you have to think about,
           just see how far you can go.  If you try to use --
           apply some of these things, you might find --
                       MR. KADAMBI:  The only thing I would add
           is that this exercise was, you know, put into practice
           for the HTGR to some extent.  You know, they did go
           through what they call bounding events which were not
           proposed by DOE at the time.  And, you know, it
           provided sort of a check of how well did the design
           accommodate or take -- tolerate these things.
                       So that's -- Mr. Chairman, that's our
                       MEMBER KRESS:  Well, I think --
           personally, I don't see the need for a letter at this
           time.  I think we've made -- given some feedback with
           our comments, and I don't know having them in a letter
           would be any more useful to you.
                       So I look forward to continuing the
           conversation with you as you get further along in
           this.  I personally think you're at least asking the
           right questions.  And so --
                       MR. KADAMBI:  Thank you very much.
                       CHAIRMAN APOSTOLAKIS:  Thank you.  We will
           start the interviews with the candidates half an hour
           from now, 12:40.
                       MEMBER WALLIS:  George?
                       CHAIRMAN APOSTOLAKIS:  Everything has been
                       MEMBER WALLIS:  George?
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MEMBER WALLIS:  Could you tell the
           membership that the staff is going to --
                       CHAIRMAN APOSTOLAKIS:  Yes.  Well, go
           ahead.  Go ahead.
                       MEMBER WALLIS:  I had a telecon with
           Exelon and GE about this business of the distribution
           of flux and fuel, and so on.  And it turns out that
           it's a real jungle.  It isn't the simple matter at all
           to say there isn't really flux flattening.  There's a
           very, very complicated fuel management program
           necessary in order to meet the regulations.  It's not
           -- there's no simple explanation that you can put in
           a few sentences and put in a letter.
                       And the staff agreed to come at 3:00, and
           in 10 minutes or so tell us how, with all of this
           complicated stuff going on, can they assure themselves
           that the core uprate -- this power uprate is okay.
                       CHAIRMAN APOSTOLAKIS:  And also, I remind
           you, the Commissioner is coming at 2:00.  That's why
           we have this flexibility.
                       MEMBER ROSEN:  He is pushed back a half
                       CHAIRMAN APOSTOLAKIS:  Yes.  His assistant
           was here.  He heard us talk about it, and I said
           absolutely.  He called the Commissioner, and he said,
           "I'll come half an hour later."  So the ACRS will have
           -- Dr. Ford will have more time to run over time.
                                   (Whereupon, at 12:14 p.m., the
                       proceedings in the foregoing matter went
                       off the record for a lunch break.)
                       CHAIRMAN APOSTOLAKIS:  Can we start before
                       MR. MCGAFFIGAN:  Is Graham Wallis still
                       CHAIRMAN APOSTOLAKIS:  He's coming.
                       MEMBER POWERS:  Yes, George.  You may
           start before 2:00.
                       CHAIRMAN APOSTOLAKIS:  We are back in
           session.  We are very pleased to have Commissioner
           McGaffigan with us for an exchange of views.
                       So we'll let you go first, Commissioner.
                       MR. MCGAFFIGAN:  Well, thank you.  You can
           see I've shown up with a blank piece of paper, so I
           don't have long remarks to make.  I'm here more to
           play a reverse role.  We get to sit in the Commission
           meeting room and ask you questions, so I'll make
           myself available so you can ask me questions. 
           Hopefully I will do as well as you guys do before us.
                       I will preface it.  I just heard Dana
           talking about I guess some of the discussions you had
           this morning about cracking and control rod drive
           mechanism housings and whatever.  There are some
           issues that are going to come before us I am not sure
           you are fully on top of.  That is whether we are going
           to shut down some people early by order.  Davis-Besse
           was before you.  They are probably the one with the
           most at stake.  There's one other plant that staff
           hasn't reached resolution with.  Earlier we were
           arguing with some plants over ridiculously small
           numbers of days, but I think in Davis-Besse's case we
           are arguing about 100 days or so compared to when they
           would like to go into their outage, and we might force
           them into an outage.
                       I am not an expert about control rod drive
           mechanism cracking.  I do know that we have some
           additional -- just orally, we have some additional
           data from TMI in recent days.  All the cracks were
           axial, not circumferential.  They were axial.  They
           are just going to be ground out, and that is going to
           be it.
                       I don't know where things stand, to be
           honest with you, except that the staff is working on
           this sort of two-parallel path process.  One, trying
           to negotiate with these two licensees who remain in
           their bullseye.  The other, drafting contingency
           orders for ordering early shutdowns to do inspections
           that they feel are appropriate, and I think we all
           would like to have inspection results.
                       It's a fairly profound question, whether
           you order somebody down early.  So if you all have any
           comments for me on that or for the Commission as a
           whole, nothing is going to happen until the end of
           December.  It would be interesting for us to hear
           those comments and understand your perspective.  This
           is a sort of hard technical issue that's exactly up
           your ally.
                       MEMBER POWERS:  Certainly the Davis-Besse
           folks came in and made a probabilistic argument to us
           today on why they should not be.  I guess I look at it
           a little bit and say well, OConee ran for at least
           half a cycle with these cracks.  Why do I want to
           worry about 90 days, or maybe it's 120 days?
                       MR. MCGAFFIGAN:  As I understand, again,
           I have heard these arguments.  The staff argument is
           that in an ideal situation, they would have liked to
           have already had the data.  So it is a matter of
           giving them an extra 90 days beyond where they feel
                       As I understand it, the issue has to do
           with the rapidity with which the circumferential
           cracks might grow.  There is a range of possible
           numbers.  The staff is taking a very conservative
           number in the absence of data.  They admit, and I
           think it's just true that there isn't a lot of data. 
           I think they also, as I understand it, would like to
           have some data.  What licensees are doing is they find
           anything, they are just repairing it and getting on
           with it rather than stay in outage to do science
                       MEMBER POWERS:  My initial reaction is to
           say their number isn't all that conservative.  It's
           what I would have picked.  Then I realized I am very
           conservative so --
                       MR. MCGAFFIGAN:  As I say, it's an issue
           that I think as you guys think about this stuff
           theoretically, there is this -- the way the staff
           process works is if they don't get to yes, with the
           two licensees, they will come to us with an order and
           we'll have sort of five days of negative consent on
           which to think about whether we want to go along with
           that order, because an order is an enforcement action. 
           For high visibility enforcement actions, that is the
           process that we -- so there isn't a Commission vote on
           it unless the Commission chooses to weigh in.  I doubt
           the Commission would weigh in unless there were strong
           technical arguments on the -- you know, that were
           presented to us as to why the staff was being overly
           conservative and we could wait the extra 90 days or
           100 days, whatever number of days we are arguing
                       I don't necessarily want you to tell me
           the answer right now.  It's just of all the technical
           issues -- you know, most of the other issues honestly
           before us at the moment start and end with security
           and physical protection.  Everything else is done on
           the side as we have time, but we are fairly consumed
           with the September 11th follow-up.  I don't know
           whether the staff has talked to you about -- and much
           of that is appropriately classified and we wouldn't be
           talking about it in this room.  I think you obviously
           all have clearances.  I think there could be a role
           for ACRS in thinking about design-basis threat
           adjustments and other things.  You know, obviously if
           we were to do rulemaking with regard to enhancing
           security at say spent fuel pools and ISFSIs, you all
           see rulemakings and can comment on them.
                       MEMBER KRESS:  We do have an interest in
           this of course.  We have one of our staff members
           taking part in most of the activities that are going
           on.  He is going to brief us later today I think.
                       MR. MCGAFFIGAN:  In a closed meeting?
                       MEMBER KRESS:  In a closed meeting.  Then
           we will of course have some subcommittee meetings
           later on.
                       MR. MCGAFFIGAN:  Yes.  We are trying to
           figure out how much funding we have in this area.  We
           have made a submittal to the Office of Management and
           Budget for some of the funds that are at the
           President's discretion.  We will need some significant
           funding.  There have been provisions.
                       One of the bills in the House, Heather
           Wilson has a provision that would require us to do
           something we would have done anyways which is,
           provided we have adequate funds, and even if we don't
           we'll reprogram some, to do some vulnerability
           assessments using the National Laboratories.  Sandia,
           Los Alomos and Livermore, are probably the three labs
           we'll primarily use for those analyses.  They have
           done work in the past for us, but they have also work
           for other sectors.
                       Sandia did some interesting work for the
           Gore Commission with regard to transportation, looking
           at the transportation system as a whole and how
           security could be -- airline transportation system,
           and how security could be enhanced.
                       So we are -- I think that is an area where
           -- I'm sure I'm not telling you anything, but that
           takes up most days.  We get about ye-thick set of
           documents to read, some of which are classified, some
           of which aren't, all of which are sensitive.  We plow
           through that.  The Chairman is in charge if it's fast
           moving, but if it's slow moving, the Commission as a
           whole deals with the issue.  As I say, we are looking
           at everything.  Everything is on the table.
                       Although I do want to say, and I'll say
           publicly, I mean I have had debates with Paul
           Levanthal sort of privately.  I believe that I am
           proud of the security system that we had in place on
           September 11th.  I think it provides the highest
           standard of security of any private sector enterprise
           in America and appropriately so because there are
           significant risks.  There is no chemical regulatory
           commission that looks at the petrochemical plants and
           has requirements for security that are inspected by
           chemical regulatory agency staff, and there are no on-
           force exercises, and none of the apparatus that we
           have in place is in place for much of the rest of the
           infrastructure.  It is quite clear that you can get
           catastrophic consequences in industries other than the
           nuclear industry.
                       That said, that we had a very, very high
           level of security on September 11th, and we have
           maintained it and obviously enhanced it, we are going
           to have to take into account the events of September
           11th and looking at security in the future.
                       One thing that we have stressed since
           September 11th is that we have to think in terms of
           what's appropriate for private security forces to do,
           and what is appropriate for the Federal Government to
           do.  If it makes sense to defend against air threats,
           diving commercial airliners, and I'll get back to
           that, then that clearly is not something that we are
           going to ask licensees to do.
                       I do think we have to worry about
           commercial airliners, but I think given that we have
           been attacked by four of them, but the way to handle
           that is with enhanced security on the airplanes
           themselves, the cockpit door reinforcement that has
           been talked about, enhanced security at the airports
           to prevent people getting materials onto the planes
           that could be used to attack the pilots and take over
           the plane, additional air marshalls, all of those
           sorts of security.
                       The notion of having -- I mean Paul
           Levanthal for a month, until I talked to him on
           October 18th, has been calling for the deployment of
           surface -- not surface-to-air missiles, of guns, of
           anti-aircraft guns.  I informed him on October 18th at
           our public meeting that the U.S. military doesn't have
           guns.  I mean the last guns I was aware of was in 42
           dusters that were in the New Mexico National Guard
           while I was working for Senator Bingaman.  Div-ad was
           cancelled.  In 1985, I was working for Bingaman then
           too.  It would have been a hell of a gun.  But all of
           our air defense forces are designed for the clash of
           tank armies on the battlefield in Germany as the
           Russians try to pile through the Folda Gap and we try
           to stop them.  They were not designed for defending
           the sort of 63 nuclear power sites.
                       So he has now amended it.  He has figured
           out that we only have surface-to-air missiles, so he
           is now correctly saying that he wants -- really
           correctly in the sense of what's available in the
           American inventory.  He wants surface-to-air missiles
           at the 63 sites.
                       I try to explain to Paul the command and
           control issues involved in having 63 surface-to-air
           missiles.  I also try to explain to Paul the mal-
           deployment of scarce defense resources that would be
           involved in trying to have -- having 63, you know,
           taking essentially all the Hawks and Patriots we've
           got and sticking them around a bunch of nuclear power
           plants that aren't particularly vulnerable.
                       Now you get into this issue of -- you
           know, we have not except at Seabrook we looked at FP-
           111 going into Seabrook because at Pease Air Force
           base nearby there were large numbers of FP-111s
           stationed until they were taken out of the inventory. 
           We looked at Harrisburg, at TMI we looked at 707s.  So
           we have not done an analysis.  We are clearly working
           on it, an analysis of what happens when a large
           commercial aircraft crashes into a containment dome or
           elsewhere in a nuclear power plant.
                       But you know, there's at least a pretty
           decent chance as I agree with Intergy, I think was in
           today's New York Times, is a pretty decent chance that
           these plants would survive famously.  Number one, it
           would take a hell of a pilot to hit some of these
           plants.  They are not the World Trade Center.  Number
           two, the main thing, the Germans and the Swiss do have
           regulations.  They looked at things like FB-111s. 
           What was it, the old, I think it was F-104s.  Yes, the
           F-104s Starfighters just routinely dropped out of the
           sky all through the 1970s.  People decided they better
           look at what happens when Starfighters hit them at
           high speed.  They look at speeds like 700-odd
           kilometers an hour.  It's the engine, whether it's a
           jumbo jet or it's a fighter plane that's the key thing
           that might penetrate.
                       Even if it penetrates containment, it
           isn't clear that you have an accident yet that you
           can't recover from.  So what has happened, thanks to
           Paul Levanthal and others, is this notion that if you
           hit anywhere, you have certainly got a catastrophe. 
           You know, they don't take into account the defense and
           depth of the plants.  You know, we can't rule out,
           just we can not provide perfect assurance, perfect
           safety to the American public.  But we have provided
           a very high level of safety.  We will continue to
           provide a very high level of safety.  A lot of the
           issues that some of these members of the public are
           trying to trot out are in my mind the sort of worst
           national security analysis one could possibly come up
           with.  You know, they are suddenly becoming national
           security experts.  If you follow their prescription,
           you will do a disservice to American defense, in my
                       But that is just a passing comment.  I do
           not really expect you guys to comment on that.  I just
           had to get, in case there's somebody from the press
           here, I get it out and let them report it if they
                       What else?  Risk informed regulation, one
           of you guys' favorite topics.  We are making slow
           progress, in all honesty.  I don't think any of us
           have dusted off the 50-46 paper we have in front of
           us.  I keep promising I am going to vote on the 50-44
           paper because it's relatively straight-forward, but I
           am under no pressure to do so because just about no
           one else has.  We are diverted at the moment.
                       So I think the staff continues to make
           progress.  The staff that's involved in the security
           issues isn't the same staff that works generally on
           risk informed regulation.  The staff has made good
           progress, as I understand it, at least they have a
           couple options out there with regard to how the option
           two would work, and I think are having this month
           discussions with the public about these various
           options for how they would deal with the special
           treatment requirements at the nuclear power plants on
           a generic basis.
                       The Commission has encouraged the staff,
           as you know, to put drafts out even before they come
           to us in order to expedite these rulemakings.  We will
           continue to do that.  I think that is one of the big
           changes that has occurred in recent years.  We learned
           from some of our rulemakings, the Part 70 rulemaking
           on the materials side, that sort of going closed for
           long periods of time and saying everything is pre-
           decisional and doesn't really help the process.  When
           the information finally comes out, you tend to have a
           big controversy.
                       So we are hoping -- we learned through the
           50-59 revision process was very open and transparent. 
           The maintenance rule revision, the A4 revision, as we
           called it, was open and transparent.  Now we are going
           to try to do that with these new risk informed rules.
                       But anything that requires a Commission
           decision in the near term, we are a fairly diverted
           and distracted Commission at the moment.  So things
           may get coagulated a little bit.
                       With that, and having taken about 15 of
           the 60 minutes, why don't I open myself up to your
           questions and see what you want to ask me about.
                       MEMBER POWERS:  Can we come back to the
           security issue?  I think one of the areas that the
           Committee could probably contribute on.  I don't think
           we can contribute to some of your more policy things,
           but I think one of the areas that the Committee
           probably could contribute in is looking at what the
           staff is doing and the depth to what it's doing then,
           especially if we had a better understanding of the
           kind of information that you would like to have on the
           threat posed by terrorists to the nuclear power
                       MR. MCGAFFIGAN:  I don't want to get -- I
           think you'd need to talk -- I mean I almost would
           volunteer except I'll be in a briefing about other
           things at 3:00, whenever you are going to get briefed
           by the staff.  But I could stick around some day in a
           closed session with you and go through some of the
           things that are in our minds as to where we might have
           to adjust our security posture.
                       One thing I will say to you in open
           session.  The spent fuel pool study last year, you
           know, the possibility that cannot be eliminated that
           however infinitesimal it may be, that years after the
           spent fuel is put in an ISFSI or left in the spent
           fuel pool, I guess you were talking about a spent fuel
           pool here, years after the stuff has been put in
           there, there is still an infinitesimal chance -- I'm
           using my words, not the study's -- that you possibly
           would get a zircoloy fire is now of course being used
           to say that there's a real vulnerability in spent fuel
                       You know, as you know, Commissioner Diaz
           and I and others at the time had problems with that
           because the assumptions where the staff went from
           there being a zero probability of an accident to there
           being some infinitesimal probability that therefore we
           had to relook the exemptions we already have.  You all
           said that wasn't a -- I think they said that that
           wasn't something that desperately needed to be done
           quickly.  We still haven't had any relook information
           from the staff about the exemptions previously
           granted.  But it's sort of -- I wish we could have
           brought that study further along to the point where we
           really had some sense as to whether there's a
           vulnerability there that really needs to be addressed.
                       My understanding was with the proper
           earthquake and the proper misalignment of the fuel and
           assuming that heat somehow doesn't get out, you could
           somehow get a zircoloy fire, but it was even if the
           stuff has been cooled for five years, I think it's
           related to the point I made earlier.  This sort of
           search for perfect security and perfect safety, you
           know.  Is the remote, remote, remote possibility of
           something, with significant consequences if you
           believe it, something that we should expend in this
           case regulatory resources on to try to prevent?  I
           don't know.
                       MEMBER KRESS:  I think you have the right
           take on that.  I think when we relook at it, we might
           ought to relook at it from the standpoint of how
           quickly can we get that stuff out.  Because it would
           be much -- you would be a better risk status if you
           could get the stuff out and put it in the dry cask
           because I think they are much less vulnerable to a
           sabotage event.
                       MEMBER ROSEN:  Better yet, put it in the
                       MEMBER KRESS:  Dry cask first.
                       MR. MCGAFFIGAN:  But you can't possibly
           put anything in the mountain because moving any spent
           fuel from here to anywhere is a mobile Chernobyl. 
                       I am not going to get into putting it in
           the mountain.  Clearly, you would be better off -- I
           think our view historically has been the spent fuel
           pools and the ISFSIs are protected of public health
           and safety.  I don't know how -- one of the things we
           will have to look at is the vulnerability of spent
           fuel pools to various sabotage and whether -- there's
           an additional argument now compared to before
           September 11th to get things into ISFSIs.
                       But the pools themselves are pretty darn
           safe.  A plane diving into one, it strikes me, you
           know, you have got a lot of time to add water if the
           worst thing happens.  I just don't -- you know, I
           don't -- compared to what one could do at various very
           soft targets around this country that aren't regulated
           by us, I am not sure that it is something that we are
           going to have to expend a lot of extra resources
           trying to regulate.  The Nevadans actually have tried
           to use the September 11th event to say see, you can't
           possibly move this stuff.  It has to stay where it is. 
           I think your comment is closer to the truth, that we
           clearly never envisioned having spent fuel in large
           quantities forever at the sites.  We would have been
           better off moving it off some time ago.  Not to
           reprocess, because processing is not economic at this
           time.  It may not be economic for a long time, given
           the price of uranium.
                       But the ideal world, we would have moved
           this material off of these sites as quickly as it had
           adequately cooled to make the transportation and the
           casks easy to carry out, the campaign easy to carry
           out.  But I don't know.
                       MEMBER KRESS:  I really like your view on
           this issue that the best thing you can do is control
           the initiating event frequency, but not dealing with
           the security of the airplanes.
                       I wonder what your view might be on, as
           part of that, having a no-fly zone over all the
                       MR. MCGAFFIGAN:  I am skeptical about no-
           fly zones, to be honest with you.  A plane traveling
           400 miles an hour travels six-and-two-thirds miles in
           a minute.
                       MEMBER KRESS:  That's not much warning
                       MR. MCGAFFIGAN:  At 12 miles, you have
           less than two minutes warning time.  You obviously
           aren't going to recognize it instantaneously either,
           so there's a delay time in the recognition.
                       We only in certain places have combat air
           patrol aircraft.  They will not be there forever. 
           Obviously they are there at the current time over the
           east coast and other places, and we have Strip Alert
           aircraft, but the Strip Alert aircraft aren't going to
           get there in 30 seconds or a minute, whatever time.
                       MEMBER KRESS:  I was thinking about
           warning time to the reactor operators so they might be
           able to do something to shut down the reactor scrams.
                       MR. MCGAFFIGAN:  To scram the plant,
           right.  Well, that requires again, a tremendous degree
           of capability that we some day could have there, but
           I don't think we have today.  In some places in the
           east coast, you are well inside FAA radar areas.  If
           somebody dips inside the zone, a controller would
           recognize it.  But you are talking about sort of real
           time communication from that controller to the
           reactor.  We don't have that capability today.
                       We have the event on October 17th at Three
           Mile Island.  We did shut -- the FAA did shut
           Harrisburg Airport.  This turned out to be a non-
           credible threat the next morning, but one we had to
           treat as credible that evening on the advice of the
           intelligence community.  But the airport was shut
           down.  That was announced actually, as I understand
           it, at O'Hare Airport, you know, Harrisburg has been
           shut down due to threat to Three Mile Island.
                       The combat air patrol aircraft were in the
           vicinity.  We had a specific time.  Once it expired,
           the airport reopened and the combat air patrol
           aircraft went away.
                       MEMBER POWERS:  Does the reactor being
           operated or shutting down if it's hit by an aircraft
           make any difference?  I think it makes no difference
           at all.
                       MEMBER KRESS:  I don't think it would
                       MEMBER POWERS:  They certainly would shut
           down by itself.  They shut down by themselves pretty
                       MEMBER KRESS:  It's assuming the control
           rods can go in.
                       MEMBER POWERS:  Even if the control rods
           don't go in, it will shut itself down.
                       MR. MCGAFFIGAN:  The other problems with
           no-fly zones, as I say, it isn't clear -- you get some
           seconds of warning time, which it isn't clear we could
           utilize today.  Some day we might be able to utilize. 
           But around many of the sites there are airports not
           far away, you know, where people like to fly their --
                       MEMBER KRESS:  You'll have to shut those
                       MR. MCGAFFIGAN:  Well, you tell the
           airline owners and pilots association you would like
           to shut down all the airports that are within X miles
           of nuclear power plants.  We were getting a lot of
           calls, and the FAA was getting far more last week,
           from Congressmen whose constituents were grounded. 
           They honestly don't feel that they are much of a
           threat.  These little pilots, you know, Lynchburg
           Airport down near the Cat1 Fuel facility in the
           western part of Virginia in the Shenandoah Valley. 
           That airport was shut down the week that FAA had the
           controls in effect.
                       That's another piece of analysis we are
           going to have to do.  I suspect it's going to be a
           straight-forward analysis, but people have suggested
           publicly that we need to look at small aircraft diving
           into the plant with explosives on board, sort of the
           air truck bomb.  If the analysis previously done about
           the engine being the most important part of the
           ability to penetrate containment, these plants aren't
           going to be moving that fast.  They don't have very
           massive engines.  The additional explosive may not
           make much difference on the outside of the
           containment. Most of the explosive force is going to
           go out.
                       MEMBER POWERS:  That's not where you want
           to hit the plant.
                       MR. MCGAFFIGAN:  You can think of better
           targets, and that is what Paul Levanthal has been
           saying publicly.  He can think of better targets, and
           I guess we all can.
                       No-fly zones just are something that it's
           sort of an example -- it's like the surface-to-air
           missiles.  You know, it's an example of an easy
           solution that people gravitate to.  In this case, the
           analogy early on was the first week we were protecting
           football stadiums during football games, you know, to
           the extent that no-fly zones protect them.  So if it's
           good enough for Oklahoma versus Nebraska, why isn't it
           good enough for the nuclear sites was the basic
           question being asked by the public.
                       The same sort of thing happened with the
           Coast Guard coming around some of the plants.  The
           Coast Guard, just as it's on high alert and wanted to
           know where the nuclear plants were, they put assets
           around several of the -- or at least they were
           patrolling near several of the sites.  As one of the
           staff -- one of the staff aphorisms around here is
           that no good deed goes unpunished.  When they actually
           wanted to take those assets out because they figured
           out that maybe they would be better utilized somewhere
           else in some of these busy ports where you have these
           large liquified natural gas tankers wandering through
           and whatever, there was uproar and human cry as to how
           dare you pull these Coast Guard assets from the
           nuclear sites.
                       A lot of the security people, and I'm glad
           Governor Hodges visited Catawba yesterday or the day
           before.  He came out of the plant very impressed with
           the security.  He visited with his director of state
                       Most of the people who go to our plants,
           you know, and see the capability that we have at the
           plants, especially in the state they are in at the
           moment, come away saying this is not the highest and
           best place to assign my marginal resources or that
           they are not particularly needy of National Guard
           assets compared to other places in that state.  That
           we have a very mixed bag.
                       I saw in today's press clips that the
           Governor of Illinois felt peer pressured into putting
           the National Guard at his sites.  I don't know whether
           he shut it down today or not.  Texas took their
           National Guard out of Comanche Peak, feeling that the
           capability was adequate.  I believe that's probably
           going to happen at Palaverde in Arizona.  Governor
           Hull had put National Guard assets in there, and I
           think is probably going to pull them out.  But these
           are decisions governors have to make, given the
           information that they have.
                       There are times when augmenting with
           National Guard, clearly augmenting -- we have
           encouraged since September 11th that there be these
           protocols in effect between the licensees and state
           and local.  They are sort of there always.  We have
           encouraged dialogue with the governors.  Some of our
           licensees have asked for National Guard augmentation. 
           That is fine.
                       But in many cases, Governors have gone in
           with their security folks and said, gosh.  I don't
           think it's needed.  I've got some state police there. 
           That is enough.  I don't need to put the National
           Guard in.
                       In Florida, we had two different utilities
           making two different choices.  Florida Power at
           Crystal River decided they didn't need the National
           Guard help.  Florida Power and Light accepted it at
           St. Lucy and Turkey Point.
                       We probably at some point need to, you
           know, as a Nation, think these things through.  They
           are clearly not decisions just for the NRC.  We are
           not the deployers of national security assets of the
           country.  But there is a real concern that we have
           that by focusing too much on the nuclear facilities,
           you are going to actually hurt overall security by
           raising vulnerabilities at these software chemical,
           petrochemical, et cetera, sites that would offer very
           attractive targets.
                       MEMBER SIEBER:  I was wondering, you spoke
           earlier about doing vulnerability studies.  It would
           be my impression that to really do good ones to try to
           redefine the design basis threat, it might take a year
           or two to do that.
                       MR. MCGAFFIGAN:  Well see, the
           vulnerability studies, I'm not sure will inform the
           design-basis threat.  If I am postulating that I
           personally do not think that we are going to add ever
           air strikes to the design-basis threat.  By
           definition, the design-basis threat is the threat
           against which licensees should have high assurance of
           being able to defeat.  Licensees have assets that are
           constrained by law as to what they can have.  I don't
           think even Charleton Heston, who we'll have to pry
           that gun out of his cold dead hands, wants surface-to-
           air missiles in licensee hands at these sites.  It
           wouldn't be Patriots, it would be Stingers.
                       You solve one problem that we may solve by
           other means and we create another.  Proliferation of
           Stingers around the country at a variety of sites, and
           god help us if somebody gets their hand on a Stinger. 
           That's the real way to bring down a commercial
                       So some of these vulnerability analyses
           are going to be more of interest to the Pentagon and
           the Office of Homeland Security in terms of trying to
           decide how important it is that they assign assets
           that are under their control to the defense of these
           plants.  Vulnerability analyses, the sort of analyses
           that we're going to have to -- the design-basis
           threat, we are going to have to decide about the
           numbers of attackers, and we are going to have to
           decide about the weaponry that the attackers are going
           to be hypothesized to have available to them.
                       We are going to have to decide how large
           the truck bomb.  We have a certain sized truck bomb in
           our design-basis threat at the moment.  We'll have to,
           as Mr. Levanthal requests, and I think we would do it
           in any case, look at whether a larger truck bomb will
           need to be protected against.
                       We will need to look at -- I mean there's
           legislation that you all should look at pending.  It
           is attached to the Price Anderson Act, reauthorization
           in the House, that would require the President to do
           a study in which he would parse.  It is the so-called
           Tauzin, Dingle, Markey amendment, in which he would
           parse threats into two bins, the design-basis threat
           bin and the enemy of the state bin.  Then the
           provision would require us to do regulations within a
           certain time period, I believe 275 days after
           receiving the President's report, to adjust our
           design-basis threat.  Then presumably the enemy of the
           state threat, that information would be used by the
           Pentagon and Office of Homeland Security and others to
           decide what they were going to do.
                       It also mandates that we will have
           essentially an OSRE type program, but an expanded OSRE
           type program, in that it defines sensitive nuclear
           facilities for which an OSRE will be required to
           include reactors, category 1 fuel facilities, the
           gaseous diffusion plants, spent fuel pools,
           decommissioned reactors, et cetera.  So you would have
           -- we have done OSREs in the past at the 63 or 64
           sites, depending how you count them, that we have,
           reactor sites.
                       We have not done OSREs -- we have force-
           on-force exercises at the 2 Cat 1 fuel facilities as
           well.  We have not done them at decommissioned
           reactors or spent fuel pool facilities that are
           independent of reactors.  So it envisions an expansion
           of the OSRE program, and in a sense, the design-basis
           threat analysis that they want us to do I think given
           the definition of sensitive facility, would also
           require that the Presidential study look at binning
           design basis threat and enemy of the state threats for
           this larger category of facilities.
                       MEMBER POWERS:  What was their force-on-
           force exercises?  The problem you always have with
           large-scale tests, you get to do one.
                       MR. MCGAFFIGAN:  We got to do four.  Each
           OSRE has four drills that are gone through.
                       MEMBER POWERS:  That's right.  It gives
           you a very limited view of what your actual defensive
           capabilities are, and does not allow much in -- if you
           find deficiencies in those defensive capabilities,
           your choice is to amend them, and then to go retest. 
           You don't have the facility for looking at lots of
           different options.
                       That is a problem that the Air Force
           encountered in defending lots of its bases.  There has
           been a fairly well developed technology of developing
           computerized scenarios, where you calibrate against a
           test for the facility and what not, and then you use
           these computerized capabilities to evaluate options
           and designs and what not, and make your testing along
           some sort of a progression where you improve actually.
                       MR. MCGAFFIGAN:  Right.
                       MEMBER POWERS:  I wondered if we shouldn't
           be thinking about bringing those technologies to bear
           here, rather than just going out and running lots of
           OSREs at every facility around the country at God
           knows what cost.
                       MR. MCGAFFIGAN:  I think we understand
           some of the limitations of force-on-force testing.  I
           would welcome any thoughts as to how to bring that
           technology.  Unfortunately, the dynamic that has been
           set up is, you know, the factoid out there is that 47
           percent of the time licensees over the last X number
           of years, ten years or so, have failed OSREs.
                       MEMBER POWERS:  I'd like Dick's response
           on that one too.
                       MR. MCGAFFIGAN:  I'm not sure what his
           response his.  The actual number is more like, you
           know, in terms of the four drills per site, licensees
           have actually succeeded 85 or 90 percent of the time
           in these drills.  When they have had problems, we fix
           them, like you say.
                       Does that mean that the whole strategy has
           been fixed?  It isn't clear.  It means that that one
           hole in the strategy that was tested that day in one
           of four tests has been fixed.  I don't know whether
           that -- I think we're better off having done OSREs
           than the chemical industry that doesn't have anything
           like this capability.  I think we do give hard tests.
                       These tests that the staff uses in an
           OSRE, they do a bunch of tabletops.  Then they detect
           what they think is a vulnerability.  Then they test
           against that vulnerability.  So these are fairly smart
           -- the four drills that are carried out, they can't
           all test the same vulnerability, but if they see a
           vulnerability in the tabletops in the licensee's
           defense posture, we go try to probe that vulnerability
           in the OSRE.  As I say, if we find it, as we did at
           Vermont Yankee or other places, we get it fixed
           promptly with compensatory actions.
                       But I think trying to find a way -- you
           know, I have come at OSREs a little bit from at Fort
           Irwin in the desert in California, we do force-on-
           force exercises at very large units.  The red team is
           pretty damn good, and they win.  It is better for our
           other units to learn in the desert in California than
           to learn in the battlefield in Iran or Iraq.  So there
           is a value to force-on-force because you are getting
           to make mistakes that don't matter, so that when it
           does matter, you are better able.
                       MEMBER POWERS:  I think when you get to do
           repetitive tests that that's true.  I think you are
           running into the problem of diminishing returns
           because in many respects you are playing got-you with
           the licensee here, because they don't happen that
           often at each one of them.  I think there is room for
           bringing an improved technology into this.
                       MR. MCGAFFIGAN:  Well, I would love to
           hear about it.
                       CHAIRMAN APOSTOLAKIS:  Can we move onto
           other subjects?
                       MR. MCGAFFIGAN:  Sure.  You guys are
           falling into the September 11th trap that we all are
                       CHAIRMAN APOSTOLAKIS:  Let me come back to
           something you mentioned in passing earlier and others
           also mentioned it in the public forum.  Risk informing
           the regulations is proceeding at a very slow pace or
           slower pace than anticipated.
                       I guess I am a little puzzled by that. 
           Can you elaborate?  I mean what should we have done by
           now to be able to say we are on schedule?
                       MR. MCGAFFIGAN:  I don't know.  In 50/46,
           there's some fairly complex issues, that paper for us. 
           You guys have it.  I forget if you sent us a letter on
           that paper, I forget whether you have.  You probably
           have.  It shows you how much I've read.
                       The problem is others are suggesting from
           the industry that the strategy in the 50/46 paper is
           not aggressive enough, and that we would do better to
           carve out a few things and to get some early success. 
           I have not -- you could use the next few minutes if
           you want to educate me as to why I should go back to
           my office and just check yes next to the approved
           column and move that paper along.
                       I thought that probably given all the
           letters that we have gotten from members of the
           public, mostly from industry to be honest with you,
           that it was worth my looking at them, thinking about
           them, and seeing whether the industry folks were right
           that there's some parts of this -- they also are
           disappointed, is my recollection, that we are not
           willing to -- they have been arguing, as I understand
           it, for an amendment to 50/46 that essentially would
           say you can change the large break loca.  We will
           entertain changes to the current double guillotine
           break large break loca design-basis accident.  You
           know, they fully expect that any change would have to
           be done with NRC approval.
                       They would like to get that regulation
           moving so that there's a regulation in place whereby
           owners groups could submit arguments for another
           design-basis accident, and we all could grapple with
           it.  As they see the staff proposal, it is going to be
           many years before they can even have the argument with
           us.  I don't know what the right answer is there.  So
           I am trying to figure out what the right strategy is
           on the 50/46, the various 50/46 options that are
           before us.
                       CHAIRMAN APOSTOLAKIS:  So it seems then
           that --
                       MR. MCGAFFIGAN:  On 50/44 it is going to
           be straight-forward.  When we all get around to voting
           on it, we are going to basically, I think, endorse
           what the staff, the revised approach the staff is
           taking.  I think that one will go reasonably rapidly. 
           50/69, or whatever the option two stuff, I think
           depends how these meetings go and whether the staff
           itself can come to consensus.  But if you, the staff,
           and the public were all to come to consensus that this
           is the right 50/69 option, that could go fairly
           quickly.  It's the 50/46 is the place where I see a
                       CHAIRMAN APOSTOLAKIS:  So as long as the
           first 50/46, not the overall.
                       MR. MCGAFFIGAN:  Not the whole thing.  As
           I say, I think a lot of people are working, the people
           who do risk-informed regulation on a day-to-day basis
           are out there trying to figure out how to do it.  They
           are having their meetings.  But I think it is the
           option three stuff that I see as going a little
                       MEMBER POWERS:  I think we have run into
           some technical challenges on 50/46 that made
           consideration of going for some of the gimmes in 50/46
           attractive.  I mean things like, for heaven sakes, why
           can't we update the decay heat curve.  That is kind of
           a gimmee.
                       MR. MCGAFFIGAN:  Well, see what Oshuk
           tells me in my office is well, not so fast,
           Commissioner, because that is clearly an area of over
           conservatism, but there may be a few places in 50/46
           where we're not being overly conservative.  By giving
           up the over-conservative here, are we somehow
           upsetting something.  So my understanding is, and the
           50/46 paper I think reflects this, that everything is
           connected to everything else.  So therefore, you can't
           do the gimmees because everything is connected.
                       I am skeptical about that, to be honest
           with you.  If you all were to come in and say take the
           gimmees, I think it would have a strong effect on how
           the Commission would think about this stuff if there
           was a consensus in this group.
                       But the staff's approach is that
           everything is connected and everything will only come
           together when everything comes together.  That could
           be some significant period of time.
                       MEMBER ROSEN:  That sounds to me like a
           prescription for not doing anything for a very long
                       MR. MCGAFFIGAN:  I worry about that, yes.
                       MEMBER POWERS:  I think there was merit to
           what the staff's approach was when it looked like you
           could move forward.  They have run into a real
           technical barrier in one aspect of it.  I think you
           need to rethink your strategy here and look for the
           gimmees in this thing.
                       Before, you know, they are right.  There
           are tentacles from 50/46 that go out and touch lots of
           places, but now that you have run in and found a hard
           spot, it is going to take some substantial work.  Why
           can't we go back and look for the ones where the
           tentacles are few in number and limited in extent.
                       MEMBER ROSEN:  The decay heat curve that
           you mentioned is one of those places.  It is merely
           being used as a -- we need to trade off something with
           it.  I don't think that's the right kind of thought
                       MR. MCGAFFIGAN:  I tend to agree with you. 
           You know, the staff is in this sort of let's make a
           deal mode.  I'll give you that if you will give me
           this.  I am not sure that that's -- there is clearly
           an awful lot of conservatism in 50/46.  There may be
           a place or two where there isn't, but there's an awful
           lot of conservatism in it.  It drives a lot of stuff. 
           It may not be the best place to expend resources.  So
           we need to think about it.
                       As I say, there is an opportunity for you
           there.  I will tell you, the number of commissioners
           who have voted on the 50/46 paper is a null set.  So
           you would be still timely if you have any additional
           thoughts you want to make on the 50/46 paper.  You
           have heard some of the comments, I suspect, from NEI
           and others in your deliberations in recent months.  If
           you have now come to the conclusion that we should
           think about gimmees, I think it could have an effect.
                       CHAIRMAN APOSTOLAKIS:  The difficulty you
           just raised I think is an important difficulty.  In
           the old traditional way of doing business, we put
           conservatisms in various places.  You should get them
           as a package as a whole.  You can't really start
           removing here without thinking about what happens
           somewhere else.
                       But the concern now, and I understand how
           that evolved because risk-informed regulations came a
           few decades after the original system was put in
           place.  What I am concerned about is that we are about
           to create a situation that will be very similar to
           this for the future reactors.  Again, there are good
           reasons for that, but maybe we should try to be a
           little more vigilant to avoid it.
                       The reason why people want to use as much
           of the existing system as they can, like Exelon, for
           example, is that of course it is much faster.  I mean
           if you use something that is already in the books and
           you modify it a little bit to accommodate your new
           design, then you have a hope that sometime you will
           see your license.
                       MR. MCGAFFIGAN:  Within a glacial time
                       CHAIRMAN APOSTOLAKIS:  Well, on the other
           hand, you are creating again a situation where we're
           perpetuating philosophies and approaches to regulation
           of the past.  Then we're going to say again, 10 years,
           15 years from now, my goodness now how do we remove
           burden, how do we -- I mean we are stuck again with
           safety-related and non-safety related components. 
           What do we do about it?  The year will be 2020.
                       So I don't know what to do about it,
           frankly, because I appreciate the difficulty or the
           concerns that the applicants have.  You know, we can't
           wait until you guys come up with a new system.  Right? 
           But it's really something I think that should be of
           concern to everyone.
                       MR. MCGAFFIGAN:  Isn't NEI talking about
           giving us a new part 50 for --
                       CHAIRMAN APOSTOLAKIS:  We have not seen it
                       MR. MCGAFFIGAN:  Part 53, whatever they
           call it, for new reactors?
                       CHAIRMAN APOSTOLAKIS:  The last time the
           representative was here, he didn't present anything.
                       MR. MCGAFFIGAN:  This is a new.  I mean it
           doesn't exist, but I thought they wanted to come up
           with some sort of risk-informed operating regime for
                       VICE CHAIRMAN BONACA:  We have heard the
                       MR. MCGAFFIGAN:  I haven't seen -- I've
           seen it in Inside NRC or Nuclear Next Week, reliable
           publications.  I assume they have sent it to somebody
           in public.
                       I understand what you are saying, George. 
           I don't know that -- there is at least, my
           understanding is that they are going to take an extra
           year to make their pebble bed decision or at least
           nine months.  So there is some extra time for us to
           try to put different regimes in place.  But there
           isn't a lot of -- that probably isn't the focus to be
           either Exelon's or the staff's work at the current
                       I see Graham Wallis.  I should mention I
           do like the work that you guys have been doing with
           regard to reviewing some of the staff's work on
           approving codes and whatever.  I see some of these
           hard-hitting letters.  I commend you for those
           letters.  I think somebody has to keep the system
           honest.  You guys are clearly doing that, so at least
           as one commissioner, I appreciate that.
                       MEMBER FORD: Can I ask you a question? 
           Going on from the risk-informed aspect.  Come back to
           the very first topic, CRDM housing.  Specifically,
           what do you want our advice on?
                       MR. MCGAFFIGAN:  Should we issue an order
           shutting down Davis-Besse 100 days earlier than their
           normal outage because there is the risk of allowing
           them to operate that extra 100 days does not provide
           reasonable assurance of public health and safety.  Or
           should we not issue an order and allow the 100 days to
           run and let them shut down at the normal time and do
           the inspections at their normal outage date.  That is
           the issue before us.  It is before the staff.
                       As I say, the staff is -- Davis-Besse is
           talking to you.  Davis-Besse is talking to the staff. 
           Davis-Besse is trying to argue -- I mean the undertow
           of what you guys were watching this morning was this
           dance between the staff and Davis-Besse.
                       If the staff isn't satisfied that they
           believe there is reasonable assurance of public health
           and safety during this 100 day period, they will
           sometime in December come to us with an order.  They
           won't come to us.  They will send us -- Ken Rogers is
           in the audience.  They will send us an email to one of
           our staff saying we would like to issue -- not hearing
           from the Commission otherwise, we will issue five days
           hence, an order to Davis-Besse and perhaps to this
           other facility telling them to shut down on December
           31st and get their inspection done.
                       I am capable of a lot of stuff, but I am
           not an expert in this.  So this is exactly where this
           group of people could tell us is the staff on the
           right track or should we give Davis-Besse the extra
           100 days.  You don't see a lack of reasonable
           assurance during that period.
                       If you were to send us that letter or just
           even threaten to send us that letter, the staff --
                       CHAIRMAN APOSTOLAKIS:  Actually, there may
           be some procedural problem here.
                       MEMBER FORD:  We really haven't had enough
           data.  I don't think we have really heard, we haven't
           heard formally from the staff on their position on
           this.  We have had in fact remarkably little
           information.  We have heard a lot of plans of what's
           going to happen.  So any advice we give you would be
           very, very --
                       MEMBER ROSEN:  I would offer one
           perspective, which is that when you're talking about
           100 days in the timeframe of this whole thing and
           saying it somehow goes against our analysis, it
           ascribes through our analysis a degree of precision
           that I'm not sure is really there.
                       MEMBER POWERS:  That's right.
                       MR. MCGAFFIGAN:  As I say, I'm open to
           whatever you guys want to advise.  But the issue comes
           down to how conservative do we want to be and when do
           we lose reasonable assurance.
                       If one of these circumferential cracks
           grew and the whole thing was severed, is that an
           accident that we would want somebody to have to endure
           and recover from?  My understanding is that that
           accident is well within the design-basis of these
           plants, and they should easily be able to handle it if
           it occurred.
                       MEMBER POWERS:  Provided it's just one.
                       MR. MCGAFFIGAN:  Provided it's just one,
                       MEMBER ROSEN:  And the consequence of the
           accident, it's a medium loca, are within the 
           containment.  So the public's health and safety is not
           at issue.
                       MR. MCGAFFIGAN:  Right.
                       MEMBER POWERS:  It's a medium loca with a
           failure to scram is what it is.
                       MR. MCGAFFIGAN:  That is the issue that is
           going to be before us.  There is a procedural problem
           in probably the Commission as a whole.  This one
           commissioner hasn't asked you guys your opinion.  But
           if you would want to be asked, I could work on getting
           you asked.
                       CHAIRMAN APOSTOLAKIS:  Soft vote.
                       MR. MCGAFFIGAN:  But that is an issue that
           of all the issues that are currently sort of kicking
           around that is so up your guy's ally and so not up my
           ally, that I would ask for any help I could get on it.
                       MEMBER LEITCH:  We haven't really had a
           chance to talk about this yet, but after hearing the
           Davis-Besse presentation this morning, this cracking
           phenomena, and I haven't bounced this off my
           metallurgical counterparts here, but the cracking
           phenomena is extremely proportional to temperature. 
           A relatively small reduction in temperature gives
           considerable relief from this phenomena.
                       I was just wondering -- chance to ask the
           Davis-Besse people this morning, but I don't know.  It
           seems to me that plant may be able to be operated --
                       VICE CHAIRMAN BONACA:  At lower power.
                       MEMBER LEITCH:  At lower temperatures, at
           lower power levels.  So perhaps --
                       VICE CHAIRMAN BONACA:  There's a
           compromise there.
                       MEMBER LEITCH:  A compromise position
           might be a -- I don't know what the temperature of a
           say, an 80 percent power might cause a reduction of
           seven degrees or something like that.  I mean I don't
           -- it might be of that order.
                       MR. MCGAFFIGAN:  And I don't know what the
           TMI data.  You know, the TMI data where they did not
           see circumferential cracks when they inspected.  We
           had the Oconee data.  These are all, what, BNW plants. 
           So we know we have the TMI data.  Does that mean that
           we should have more assurance now that we have the TMI
           data and there weren't circumferential cracks?  I
           don't know how you handle all that.
                       But as I say, it is clearly an issue that
           you are more capable than I of thinking it through,
           although I am willing to hear from anyone on the
                       Other questions?  I have almost used up my
                       MEMBER ROSEN:  Well, I was interested in
           your take on the whole question of advanced reactors
           and licensing of them.  Where do you think where the
           Commission is headed on it?
                       MR. MCGAFFIGAN:  I don't know.  We clearly
           are putting resources into it Congress has been happy
           to give us.  We did get 10 million dollars extra in
           our budget to help us deal with advanced reactor
           issues this coming year.  What's most important to the
           industry as a whole is what we need to work on, the
           early site permits.
                       My understanding, Intergy now has just as
           Exelon has lined up with the pebble bed, Intergy has
           lined up with the modular high temperature gas reactor
           General Atomics.  Others are still looking at the
           Westinghouse AP1000.
                       We just need to put adequate resources
           into doing the things we need to do.  We need to look
           at the PAR52 rulemaking, to update it on certain
           things that I think would expedite the process if it
           starts.  We're all a little skeptical, to be honest
           with you.
                       I mean a year ago when the price was up
           here, and it was easy to see these plants being quite
           economical.  We're about to go through a winter where
           the price of gas is going to be a lot lower, and I
           don't know what to predict for the long-term price of
           natural gas, which is one of the key things that
           utility executives look at when they try to make a
           decision to invest in a nuclear power plant.
                       So we're trying to put adequate resources
           into it.  If we get early site permits, we will try to
           run that process expeditiously as we have done the
           license renewal process.
                       I think the September 11th events -- we
           have 2 206 petitions before us.  We have various folks
           who are going to be trying to raise for anybody who
           does come in for an early site permit, some of these
           security issues.
                       Mr. Waxman -- there is a provision in the
           House version that was adopted unanimously by the
           House Energy and Commerce Committee that would require
           us to consult with the Office of Homeland Security
           before providing any Price Anderson indemnification to
           any new applicant.
                       That will require, if it becomes law,
           require us to put in place some procedures that we
           don't have today to get -- I'm sure our licensee will
           want to get that check off from the Office of Homeland
           Security very early in the process.  They are not
           going to want to build the plant and say, okay, give
           us our Price Anderson indemnity, and we say sorry,
           Homeland Security vetos your plant.
                       So it's an extra little bit of
           uncertainty.  I think it's handleable.  But if that
           becomes law, and as I say it was adopted by voice vote
           in the committee, and I don't believe the
           Administration is objecting to that provision in the
           statement of administration policy in the House bill,
           we will just have to build that into our process in a
           way that isn't there at the moment.
                       So I think if that is the only thing that
           results from September 11th, that isn't much of a
           burden and we'll handle it.  But I can't fully predict
           what's in the minds of utility executives at the
           current time in light of the price of gas going down
           and the climate being complicated by the security
           events, and the undue focus on vulnerability of
           nuclear assets.
                       General Atomics, and I'm not sure it's
           good for the industry as a whole, you know, General
           Atomics and Exelon have helpfully said that they could
           bury their plants.
                       CHAIRMAN APOSTOLAKIS:  And still produce
                       MR. MCGAFFIGAN:  And still produce power,
           right.  They can make these almost impossible targets
           if indeed we have to worry about it.  If they want to
           bury their plants, great.  I am not sure that as a
           regulator I am going to require them to bury their
           plants in order to take on diving commercial
                       Is that enough of an answer?
                       CHAIRMAN APOSTOLAKIS:  Any other questions
           for the Commissioner?
                       MR. MCGAFFIGAN:  Okay. Well, thank you
           very much.
                       CHAIRMAN APOSTOLAKIS:  Thank you for
           coming down here.
                       We'll take a five minute break.
                       (Whereupon, from 3:00 p.m. until 3:15
           p.m., the proceedings went off the record.)
                       CHAIRMAN APOSTOLAKIS:  Okay.  We are back
           in session.  We have an ad hoc presentation by the
           staff on the issue of power uprate.
                       MR. BAILEY:  Yes.  This is Stewart Bailey. 
           I am the Project Manager for Quad Cities.  We are here
           to try to answer some of the Committee's questions
           related to how Exelon is achieving the power uprate
           out of their BWR course.  So with that, I'll turn it
           over to Tony Ulses.
                       CHAIRMAN APOSTOLAKIS:  What's the name
                       MR. ULSES:  Tony Ulses.  How to do a power
           uprate in ten words or less.
                       CHAIRMAN APOSTOLAKIS:  Good.
                       MR. ULSES:  What I would like to start off
           with is -- well actually I'd like to not put that on
           right now, Stu.
                       I was kind of reviewing this material that
           you all got yesterday from GE.  I kind of see where
           the confusion is coming from here.  I would like to
           make a brief comment on it, and then try and avoid
           getting into it because I don't really understand all
           the details of how the information was generated.  I
           understand I will probably have limited success at
           that, but that is kind of where I would like to go.
                       Essentially what you are seeing here when
           you compare this information from cycle 17 to cycle
           18, what really is causing the confusion is that they
           are introducing a new type of fuel into cycle 18.  In
           other words, they are going from a nine-by-nine fuel
           in cycle 17 to a ten-by-ten fuel in cycle 18.
                       MEMBER SIEBER: Partially.
                       MR. ULSES:  Right, partially.  That is
           going to be the new batch that they are inserting, is
           going to be ten-by-ten.  That fuel in fact can run at
           higher total bundle powers than the nine-by-nine fuel. 
           That is how you can increase the average and not cause
           the peak average to go down because you are in fact
           increasing the peak maximum of bundle power, but you
           are not increasing the peak rod power, kilowatts per
           foot.  Because basically you have more rods to work
           with, you can make more power. That is basically what
           they are doing.
                       Also, another feature of the ten-by-ten
           assembly is that they have additional margin to
           minimum critical power ratio, which allows them to get
           this additional power out of the assembly due to
           changes in the assembly design, mainly in the spacers
           and the optimization of their axial location.
                       That is all I really wanted to say on
           that, unless there are any questions.
                       MEMBER WALLIS:  Well, ten times ten is 100
           and nine times nine is 81.  The difference is
           something like 19 percent or something, which is what
           they are asking for almost.
                       MR. ULSES:  Well, I think that might just
           be a coincidence.
                       MEMBER SIEBER:  It's the surface that
           counts there.  The surface doesn't go up by 20
                       MEMBER WALLIS:  I think they said this
           morning that the fuel is also more enriched.
                       MR. ULSES:  Yes.  They are running at a
           higher enrichment because they want to get more energy
           into the core.
                       MEMBER WALLIS:  And they play more tricks
           with Gadolinium.  They also put in pressure fuel more
           often.  So the more fuel, the more --
                       MEMBER SIEBER:  More assemblies, yes.
                       MR. ULSES:  Let me jump into the
           presentation here.  I have this stuff on the slides. 
           Let me go ahead and change this around, Stu.
                       All right.  How to do a power uprate.  So
           essentially they have to do three things.  They have
           to get more fissile content into the core.  They want
           to burn more U-235.  So they load more bundles.  Also,
           in this case the bundles happen to have a higher
           bundle average enrichment, although I don't know that
           that's necessarily generally true.  That means they
           withdraw more as well because they have a fixed number
           of locations.
                       MEMBER WALLIS:  The total level stays the
           same, but in each load they exchange more.
                       MR. ULSES:  Exactly.  They have a fixed
           number of locations.  Essentially they extract more
           and they add more fresh, which gives them a higher
           fissile content and they can burn it.
                       Now with this new fuel, they have to keep
           it within limits obviously.  So what they do is they
           use more changes in the Gadolinia loading, both
           axially and radially, and they also do a lot of radial
           enrichment and axial enrichment changes in the fuel as
           well.  These modern beauty bar fuel assemblies are
           extremely complicated.
                       MEMBER KRESS:  Tell me what the different
           Gadolinium loading means.  You add less of it in?
                       MR. ULSES:  Well, what it means is that
           within one bundle you could see different locations
           that actually have different Gladolinia concentrations
           radially and axially in order to shape the power. 
           Then within each type of bundle that they insert at
           the beginning of core, you could actually see actual
           different total Gladolinia loading as well.
                       MEMBER KRESS:  It might put more in the
           central channels and less in the --
                       MR. ULSES:  No.  What they are doing is
           putting in what they need where in order to maintain
           the power distribution.  You know, the concepts of
           doing like an outer middle, inner ring loading, that
           is not done any more.
                       CHAIRMAN APOSTOLAKIS:  But by fuel rod,
           fuel rod by fuel rod.
                       MR. ULSES:  Exactly.
                       MEMBER KRESS:  Pellet by pellet almost.
                       MR. ULSES:  Sure.  Right.  Well that's
           actually the truth, pellet by pellet.  You are going
           to see radial and axial enrichment changes, and also
           Gladolinia loading changes.  They also will increase
           the total load of gad in order to keep the reactivity
           down as they burn the core, because obviously they are
           going out to longer burnouts.  Well they are going out
           to higher -- the batch average burnouts are not
           increasing the fuel burnup over the limits.  I mean
           let me just get that out there.
                       MR. BAILEY:  Higher reactivity.
                       MR. ULSES:  And essentially they have been
           doing this for about 10, 15 years roughly.  It
           actually started with their later eight-by-eight
           products.  It is in the nine-by-nine products, and
           it's in the ten-by-ten products that are out there
           right now.  This is also not just done by GE, it's
           done by all BWR fuel vendors to a certain extent.
                       Now for EPU, which is basically the power
           uprates that get up in the 15 to 20 percent range,
           they are going to have to go to these newer fuel
           designs because they have to get more maximum bundle
           power.  You just simply can't get it out of the nine-
           by-nine assembly because mainly limits on the critical
           power ratio.  In other words, they are going to go
           into dry out in these assemblies if they run them up
           in power.
                       MEMBER KRESS:  Where do they get this
           extra space?  Do they actually cut down on the spacing
           of the fuel?
                       MR. ULSES:  What they do is they make the
           pin smaller.
                       MEMBER KRESS:  That's what I meant.
                       MR. ULSES:  Right.  They are actually
           physically smaller themselves.  Then they will
           increase the enrichment, they will offset any changes
           in the actual physical geometry of the assembly.  That
           allows them to run these bundles out to higher
                       Now like I said before, they are going to
           have to get more CPR performance out of these bundles
           or they won't be able to increase the maximum power,
           but that has been achieved over the years by changes
           in spacer design and by the physical changes of the
           geometry themselves.  But the key point here is that
           it is confirmed with prototypical tests.  They
           actually design a prototypical bundle with
           electrically heated rods.  They put it into their
           atlas test facility, and they do CPR testing in order
           to confirm the continued applicability of the
           correlation they use to predict critical power.  That
           is done for each fuel type that they manufacture.
                       Essentially just the last bullet there is
           just kind of the point that they made incremental
           design changes over the years, but if you look at the
           modern fuel, basically what they have done is they
           have grabbed everything that they have learned, and
           they have put it all into one place, which is really
           what is allowing them to get this extra power out of
           these assemblies and maintain the actual local limits
           on the assembly, which is how they are really
                       MEMBER WALLIS:  It's obviously a very
           complicated fuel management program.
                       MR. ULSES:  Extremely complicated.
                       MEMBER WALLIS:  If you look at these, you
           find 1.39 is beside .99, and then there's another
           1.15.  There's no pattern at all that makes any sense.
                       MR. ULSES:  It is extremely complicated,
           which is why if you look at the way they do the actual
           reactor design these days, they are going to take the
           core and they are going to do detailed calculations of
           the reactor as it burns out on its lifetime because
           they need to ensure that they are going to maintain
           thermal limits.
                       Actually, I have got a lot of --
                       MEMBER WALLIS:  The flux may not flatten. 
           The flux flattening is probably a red herring.
                       MR. ULSES:  But that is more consequence
           of what they are doing.  They are going to load more
           reactor fuel at the beginning of the life, and the
           flux has to flatten simply because they are loading
           more fuel and it's going to take up more locations,
           and the flux is going to have to flatten.  So I would
           say it's more of a consequence than a means to an end,
                       That is even more true when you are
           talking about inserting new types of fuel which can
           run at higher maximum bundle power.
                       MEMBER WALLIS:  Also the axial
           distribution varies tremendously from beginning to
                       MR. ULSES:  What I was going to say is
           that I have a lot of -- actually, I have a lot of
           background information up here which is actually GE
           proprietary.  I would obviously rather not get into it
           here, but if anyone wants to look at it, I can stay by
           after we're done here and I could show it to any of
           the members who would be interested in seeing
           information about the design.
                       MEMBER ROSEN:  The ACRS handles a lot of
           GE proprietary information during the reviews.  It was
           an innocent that was asked to try to follow just a
           little deeper in the proposal which said something
           like we're going to flatten the profile and that's how
           we are going to get a lot more power out of it.
                       So I asked for the profile.  Let me see a
           core map.  Let me see a beginning a live core map. 
           Let me see an end-to-live core map, the pre-EPU and
           post-EPU so I can get a sense of just taking it
           another level down so we understand.  That may have
           turned out to be the wrong question.
                       What I would like to know is, because I
           think we need to go another level beyond oh, we're
           just going to flatten the power.  That is all that was
           really said about how we're going to get all this
           power in this stack of documents this high.  I would
           like to go another level down below that, get a little
           more sense of sensible information.  I don't know the
           right question.  What is the right question?
                       MR. ULSES:  The right question to ask is
           will they maintain the bundles within their rating,
           within the thermal limits.
                       MEMBER ROSEN:  What are those?  Show me
           what your projections are and all that.
                       MR. ULSES:  If we look at how we license
           BWR fuel, it is very dependent on the local parameters
           because of the fuel channels.  The reactor fuel itself
           doesn't really care what's around it because of the
           channel.  All it cares about is what it sees at the
           inlet and the outlet.
                       So it is very local.  It is very specific
           on the assembly.  That is one of the reasons why they
           are able to do this, because they are able to using
           basically the tool of the Gladolinia, if you will, in
           this case it uses the tool, that they able to shape
           the power in the assembly such that they can keep the
           peaking within the assembly down as they burn the
           fuel.  They can stay within the applicable limits.
                       Let me go and jump to my next slide here,
           which is how we license fuel.  But as for your
           question about what you need to ask --
                       MEMBER ROSEN:  I am going to ask a
           question on the next EPU that comes through, and I
           understand there is going to be a lot of them.
                       MR. ULSES:  There will be.
                       MEMBER ROSEN:  I don't know exactly what
           the question is but I will certainly want to zero in
           on this. I would ask the staff to help me with that.
                       MR. ULSES:  Well I would say without
           thinking about it a great deal, the question that I
           would ask is, just like I said, I mean essentially are
           you maintaining the bundles within the design limits. 
           That information ought to be able to be provided to
           the Committee.  Essentially those limits are you have
           to maintain the LHGR limits.  You have to maintain the
           MCPR limits, and you have to maintain the maximum
           average planar linear generation rate.
                       What is in parenthesis here is what those
           limits are trying to protect.  Essentially you don't
           want to melt fuel.  You want to maintain good heat
           transfer, and you want to meet the 10 CFR 50:46
           exception criteria, which is what you have the maximum
           average planar linear generation rate for.  That is
           going to be set by your loca analysis.
                       MEMBER WALLIS:  Average planar is local?
                       MR. ULSES: It's an average planar, right. 
           That's the mapple hover.
                       CHAIRMAN APOSTOLAKIS:  Just one comment I
           have is that I think at least I was mislead in the
           statement of flatten out the power distribution.  You
           are assuming that that meant that the peaking factors
           go down.  That is not the case.  You are pushing it
           up.  Let me finish.
                       You are pushing it up axially at the top
           and bottom because the same strategy is being used by
           the PWR vendors.
                       MR. ULSES:  But actually the axial power
           profiles, but those have been used for many years. 
           That is not atypical.  That is in use right now.
                       Essentially what they are doing is they
           run the core early in cycle with a highly bottom
           peaked power distribution.  That allows them to
           spectral shift the reactor.  Then they start moving it
           up at the top because they want to burn the fuel out
           evenly.  In other words, they want to use all the
           uranium that's in the core.
                       If they went back to like what they used
           to do was like a hailing concept, but that is not used
           any more because it does not allow them to burn out
           all the fuel.  Essentially the utilities are spending
           money on enrichment that they are not using.
                       So what they do now is they go to these --
           is that they go to these management strategies that
           allow them to move the axial power distribution around
           a great deal during the cycle.  That is how every
           reactor that I am aware of currently operates right
                       MEMBER WALLIS:  What's LHGR?  Like the
           number here, .77.  What's that?  I am looking at these
           printouts we got, to relate them to your criteria.  It
           says LHGR .77.  That's not a temperature?
                       MR. ULSES:  What we need to do is look at
           the thing at the section called the thermal limits
           summary.  You look at maximum kilowatts per foot,
           which is for the one I'm looking at, is 10.14. 
           Another one is --
                       MEMBER WALLIS:  I think that's the second
           one on the list.
                       MR. ULSES:  It's actually the second to
                       MEMBER WALLIS:  What's rapid LHGR?
                       MR. ULSES:  I actually don't know.  That's
           a value that they probably use --
                       MEMBER WALLIS:  Same symbols as you have
           up there.
                       MR. ULSES:  Well, what they call a maximum
           kilowatts per foot is what I am referring to here as
           LHGR.  Other than the limits of what they are going to
           use is what are more than likely going to be used by
           the operator in the control room.  They try to come up
           with parameters in the control room that are really
           easy to understand.  They try to ratio the parameters.
                       MEMBER WALLIS:  This is less than 13 or
           something like that?
                       MR. ULSES:  The values vary from field
           type to field type, but that is a pretty good average
                       MEMBER WALLIS:  Where do I find MCPR?
                       MR. ULSES:  That is --
                       MEMBER WALLIS:  That's the 1.79.
                       MR. ULSES:  The one you are looking at,
           1.79.  Yes, that's going to be limited in the
           technical specifications.  The value is on average
           typically I want to say 1.09, 1.1.
                       Ed, is that about right?  In this
           particular case, yes.
                       MEMBER WALLIS: Then the other one, MCPR,
           is --
                       MR. ULSES:  The next one is the mapple
                       MEMBER WALLIS:  That must be the APLHGR,
                       MR. ULSES:  No.  That is actually going to
           be the one that is above the actual thermal limit
           summary which is on the order of 9.14 in this case,
           and on the other ones --
                       MEMBER WALLIS:  Somewhere else?
                       MR. ULSES:  Yes.  You have to go right up
           above the section that says thermal limits summary, to
           something called maximum APLHGR.
                       MEMBER WALLIS:  It says 9.11?
                       MR. ULSES:  Right.  In this case it's
           9.14.  I'm not exactly sure what those units are.  I
           assume they are probably kilowatts per foot.  That
           would make sense.
                       MEMBER WALLIS:  So what you guys do is you
           assure yourselves that all these numbers that are
           going to be varying throughout the cycle and with
           different fuel loads and all kinds of strategies,
           never go over some regulatory level?
                       MR. ULSES:  Exactly.  Those are specified
           in the fuel type and bundle-specific basis.  They are
           monitored continuously throughout the cycle.  The
           reactors, they are actually running online monitoring
           which actually runs a three-dimensional solution of
           the reactor all the time, comparing it to the in core
           instrumentation.  They are using that to ensure that
           they are meeting all applicable thermal limits on the
                       MEMBER ROSEN:  Maybe you could help me
           with the second question.  The first question is are
           you maintaining LHGR for fuel temp and for loca and
           MCPR below the limits?  The answer they give me is
                       MR. ULSES:  Yes.  That is the answer they
           have given us.  We have confirmed that through our
                       MEMBER ROSEN:  My next question is what
           should my next question be?  Show me, right?
                       MR. ULSES:  That would be my next
           question.  Show me.
                       MEMBER ROSEN:  What do I ask for?  What
           should they provide that shows me that they are doing
                       MR. ULSES:  They can give you a map, I
           suspect, just like you got with the normalized power
           distribution which has the kilowatts per foot on it
           for a bundle.  But the maximum value per pin in a
           bundle.  That would be useful information.
                       You can get the information about the
           minimum critical power ratio that's in the reactor. 
           You can also get the mapple hugger limits.
                       However, most PWRs are not going to be
           limited by mapple hugger.  They are typically limited
           by MCPR values simply because they have so much ECCS
           injection.  Normally loca is not a limiting factor for
                       But those would be the questions that I
           would ask if I wanted to convince myself, and those
           are the questions that we do ask when we want to
           convince ourselves that the power uprates are not
           going to exceed any applicable licensing limits on the
           fuel.  That information ought to be readily available
           to the Committee.
                       MEMBER SIEBER:  Actually, the way all this
           is licensed is a little bit misleading.  When you go
           for a change in license for a power uprate, you are
           basically using a demonstration bounding core to show
           that you can actually manipulate the fuel in order to
           get the power output.  Each time you refuel the
           reactor though there is a design process that goes on
           that specifies how each fuel assembly will be built,
           how it is to be oriented in the core, and where it is
           supposed to go, plus where all the other ones are
           supposed to go because you've shuffled them around.
                       Each time they do that, they send in an
           RSE, a reload safety evaluation, the licensee does,
           that says I have followed all the procedures that the
           staff approves and I have done all these calculations
           and this is a good core.  It's a 10-page document,
           which is what they get.  So the process is approved by
           the staff, and then each reload is approved by saying
           I followed the process.
                       MR. ULSES:  Right.
                       MEMBER SIEBER:  So that is the kind of
           paper flow.
                       MR. ULSES:  That is for a plant that's at
           a given power level and they are just reloading it.
                       MEMBER SIEBER:  Well, what will happen
           here too.
                       MR. ULSES:  Sure.
                       MEMBER SIEBER:  How they have licensed a
           plant to go to a higher power and they have changed
           their machinery around to achieve that, that the next
           reload that goes in is going to have an RSE that's
           going to be reviewed by the staff using the same old
           process as General Electric always used or
           Westinghouse or Siemens or whomever.  That is the
           process.  There is no change to the process and
           there's no change to the analysis that they will do. 
           They will use the same tools.
                       MR. ULSES:  The reason why they don't do
           an actual calculation on what they expect the real
           power uprated reactor to be is that when we're in the
           review process, they are not going to know what target
           they are shooting at because they don't know exactly
           where the actual real core will be at the end of a
                       So they try and do a generic analysis to
           give us an understanding of what it is going to look
           like, but then you are certainly right, that they will
           use the standard reload process.  We will get what
           actually nowadays is called a core operating limits
           report, but it's the same thing.  It basically
           describes the fuel that's in the reactor, the method
           used, and a summary of a few key results which are the
           thermal limits.
                       MEMBER SIEBER:  Then during core
           operation, you take flux maps or in core instrument
           readings to determine how well core is reproducing
           what the calculation showed in advance of refueling
           the core?
                       MR. ULSES:  Right.  Exactly.  Nowadays
           that is done online continuously.
                       MEMBER SIEBER:  So you get a map out of
           the computer that looks like the map they gave us,
           which is an analytical map as opposed to a flux map.
                       MEMBER WALLIS:  Do we have enough to go on
           those in Committee?
                       MEMBER SIEBER:  The change I would suggest
           is the same one I said yesterday.  All they have to do
           is change one word.
                       MEMBER WALLIS:  I have concluded that this
           power uprate is achieved by having a new fuel.
                       MR. ULSES:  That's true.
                       MEMBER WALLIS:  Ten-by-ten instead of
                       MR. ULSES:  That's correct.
                       MEMBER WALLIS:  And by using new fuel
           management techniques.
                       MR. ULSES:  That's correct.
                       MEMBER WALLIS:  Which are so complicated
           in detail that there's no way that this Committee
           should try to explain them in a letter.
                       MR. ULSES:  I definitely wouldn't try to
           explain them in a letter myself.  It is an extremely
           complex process that has evolved over several years.
                       CHAIRMAN APOSTOLAKIS:  Have we achieved
           what the purpose of this meeting was?
                       We certainly appreciate your coming down.
                       MR. ULSES:  No problem.
                       CHAIRMAN APOSTOLAKIS:  On such a short
                       MR. ULSES:  I hope that we have
           straightened this out.  Information on the first slide
           is basically a summary of what they are doing to
           achieve these power uprates.  You can have this
           information if anyone is interested.
                       CHAIRMAN APOSTOLAKIS:  Thank you very
           much.  You answered a lot of good questions.
                       Why don't we recess for 15 minutes.  Then
           we'll come back and do planning and procedures.
                       (Whereupon, at 3:36 p.m. the proceedings
           went off the record.)

Page Last Reviewed/Updated Monday, August 15, 2016