489th Meeting - February 7, 2002

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               489th Meeting

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Thursday, February 7, 2002

Work Order No.: NRC-214                               Pages 1-368

                   NEAL R. GROSS AND CO., INC.
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                                 + + + + +
                               489TH MEETING
                                 + + + + +
                             FEBRUARY 7, 2002
                                 + + + + +
                            ROCKVILLE, MARYLAND
                       The ACRS met at the Nuclear Regulatory
           Commission, Two White Flint North, Room T2B3, 11545
           Rockville Pike, at 8:30 a.m., George E. Apostolakis,
           Chairman, presiding.
                 GEORGE E. APOSTOLAKIS, Chairman
                 MARIO V. BONACA, Vice Chairman
                 F. PETER FORD
                 THOMAS S. KRESS
                 DANA A. POWERS
                 STEPHEN L. ROSEN
                 WILLIAM J. SHACK
                 JOHN D. SIEBER
                 GRAHAM B. WALLIS
                 B. JOHN GARRICK, ACNW, Acting Chairman
                 MILTON N. LEVENSON
           STAFF PRESENT:
                 MICHAEL T. MARKLEY
                 SAM DURAISWAMY
                 HOWARD J. LARSON
                 SHER BAHADUR
                 CAROL A. HARRIS
                 NOEL DUDLEY
                 JOHN T. LARKINS
           ALSO PRESENT:
                 VICTOR H. RANSOM, Invited Expert
                 MARK CUNNINGHAM
                 FRANK GILLESPIE
                 STEWART MAGRUDER
                 RICHARD BARRET
                 LAWRENCE KOKAJKO
                 SAMUEL J. COLLINS
                 ASHOK THADANI
                 WILLIAM D. TRAVERS
                 MARTIN VIRGILIO
                 GARY HOLAHAN.                              C-O-N-T-E-N-T-S
           Opening Remarks by the ACRS Chairman . . . . . . . 4
           Risk-Informed Regulation Implementation Plan . . . 7
           Meeting with EDO and Office Directors of NRR,. . .72
           NMSS, and RES
           Proposed Final Revision to Regualtory Guide. . . 181
           1.174 and SRP Chapeter 19
           PTS Technical Bases Reevaluation Project . . . . 249
           Adjourn. . . . . . . . . . . . . . . . . . . . . 368
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:34 a.m.)
                       CHAIRMAN APOSTOLAKIS:  The meeting will
           now come to order.  This is the first day of the 489th
           Meeting of the Advisory Committee on Reactor
           Safeguards.  During today's meeting the Committee will
           consider the following, this Conformed Regulation
           Implementation Plan, meeting with the ADO and the
           Office Directors of NRR, NMSS and RES, status report
           on the proposed final revision to Regulatory Guide
           1.174, and Standard Review Plan, Chapter 19, PTS
           Technical Basis Re-evaluation Project, Proposed ACRS
           reports.  ACNW Members John Garrick and Milt Levenson
           will participate in the meeting with ADO and the NRC
           Office Directors.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Dr. John T. Larkins is a designated
           federal official for the initial portion of the
                       We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's sessions.  A
           transcript of portions of the meeting is being kept,
           and it is requested that the speakers use one of the
           microphones, identify themselves, and speak with
           sufficient clarity and volume so that they can be
           readily heard.
                       I will begin with some items of current
           interest.  I'm pleased to announce that the Commission
           has approved the appointment of Dr. Victor Ransom to
           the ACLS, subject to final clearance review.  Dr.
           Ransom is attending this meeting as an observer. 
                       Amarjit Singh is going on rotation for
           three months as Senior Project Manager in the
           Probabalistic Risk Analysis Branch of the Office of
           Research, effective February 10th.  And I am happy and
           sad to announce that Mr. Noel Dudley is leaving the
           ACLS - will you stand up, Noel - to join the Office of
           Nuclear Reactor Regulation as a Senior Project Manager
           with the License Renewal Section, effective February
           10th, as well.  
                       Noel, as we all know, has been one of the
           most valuable members of the staff.  He has been with
           ACLS for eight years, and he has made significant
           contributions in several areas, including License
           Renewal, Steam Generator Cube Integrity, Materials and
           Metallurgy, the Licensing of AP-600, Safeguards and
           Human Factors.
                       I'm happy to congratulate Noel, but I'm
           also sad, as I said, that he's leaving us, and I think
           he deserves a round of applause.
                       MEMBER ROSEN:  I think we'll also miss Jit
           over the three months he  - 
                       CHAIRMAN APOSTOLAKIS:  Jit is coming back
           in three months.  I don't have to say too much about
                       MEMBER ROSEN:  Can I get a  - can I be
           sure of that?
                       CHAIRMAN APOSTOLAKIS:  Now one other item
           of interest, in the hand-out, those items of interest,
           please go to pages 34 and on, and find information on
           the Annual  - the 14th Annual Regulatory Information
           Conference, which will be held in Washington next
           March, March 5th, 6th, and 7th.  So if any members
           decide that they would like to go, please let us know.
                       MEMBER POWERS:  When is our meeting in
                       CHAIRMAN APOSTOLAKIS:  When is our
           meeting?  The last date.
                       MEMBER POWERS:  Yeah.
                       MR. DUDLEY:  I'd like to add to that that
           the registration form for the meeting is on  - is the
           last page of your package.
                       CHAIRMAN APOSTOLAKIS:  Yeah.
                       MR. DUDLEY:  You can also register on-
                       CHAIRMAN APOSTOLAKIS:  Okay.  Are there
           any comments or announcements from the members? 
           Hearing none, we'll proceed with the agenda.  The
           first item is Overview of Risk Informed Regulation
           Implementation Plan.  Dr. Shack, you will lead the
           Committee through this.
                       MEMBER SHACK:  Okay.  We've, of course,
           spent a lot  - 
                       CHAIRMAN APOSTOLAKIS:  Bill, your
                       MEMBER SHACK:  We've spent a lot of time
           discussing individual issues under Risk Informed
           Regulation.  I think this is the first time that I can
           recall reviewing the overall Risk Informed
           Implementation Plan, and I guess Mark Cunningham is
           going to lead the presentation for it.
                       MR. CUNNINGHAM:  Thank you, sir.  You're
           right.  I think  - if the Committee has been briefed
           on the Implementation Plan, it's been a long time ago,
           so I think the intent of our briefing today is to both
           give you some ideas of the general structure of the
           plan, and the rationale for the plan as it's laid out. 
           And then give you some  - describe some of the more
           important initiatives that are embedded in the plan.
                       I'm Mark Cunningham in the Office of
           Research.  With me is Stu Magruder and Frank Gillespie
           from NRR.  Joining us shortly will be Lawrence Kokajko
           from Office of Nuclear Materials Safety and
                       We've got four parts to the presentation
           today.  I'm going to give you an overview of the new
           Implementation Plan format and content, and some of
           the rationale of why it looks the way it does.  
                       The Implementation Plan, the substance of
           the Implementation Plan is organized by a strategic
           arena.  Frank and Stu will talk about the reactor
           arena work, including both major initiatives and
           challenges facing the staff right now, and at least
           one approach for identifying how we  - for how we
           would identify new areas, or new regulatory activities
           to be risk informed in the reactor arena.
                       Lawrence will then talk about the
           materials and waste arenas, again some important
           issues that are facing them, some upcoming milestones,
           and how they are now using  - what process they're now
           using to identify what else in NMSS they'd like to
           risk inform.  And then I'll come back at the end with
           some next steps that we're taking.
                       By way of background, those of you who
           have been on the Committee for a while may recall that
           there used to be a PRA Implementation Plan, and in the
           late 1990s, in 1999, we received some rather
           considerable criticism of that from the General
           Accounting Office, and the GAO advocated that to  - in
           order to really effectively implement NRC's PRA Policy
           Statement, we needed to develop a comprehensive
           strategy for risk informing NRC's Regulatory
           activities.  In 1999, the Chairman made a commitment
           that we would modify the plan, and try to accomplish
           what GAO was interested in.  Next slide.
                       We've gone through two iterations of the
           plan in the terms of the format of the plan since
           then.  We had a March 2000 version that went to the
           Commission, and the Commission gave us some guidance
           at that point on three specific areas.  They said they
           wanted to hear more about internal communications, of
           how we talk internally and bring the staff together on
           how the benefits of risk informing are requirements. 
           They also wanted  - 
                       MEMBER WALLIS:  Can I ask you something?
                       MR. CUNNINGHAM:  Yes, sir.
                       MEMBER WALLIS:  You have a plan.  Is it
           clear what the goals are?  Is it clear what the
           objectives are before you have a plan to get there?
                       MR. CUNNINGHAM:  I believe so.  Yes, sir. 
           We could give you some examples when we get done here,
           if you'd like.
                       MEMBER WALLIS:  Okay.
                       MR. CUNNINGHAM:  As I say, the  - at the
           high level, the purpose  - the  - what we're trying to
           do in Risk Informed Regulation is oriented to the
           strategic plan goals of the agency.  They're much
           broader than this, and everything that we talk about
           in the plan is linked to the accomplishment of a
           specific, what they call strategy, in the strategic
                       MEMBER WALLIS:  It just seems to be  -
           Risk Informing seems to be sort of a method rather
           than an objective.  Is more Risk Informing better, or
           is it itself a means to some other end, which is
           greater than itself?
                       MR. CUNNINGHAM:  It's a means to another
           end, which is  - and one way to think about it is to 
           improve the focus of our Regulatory activities on the
           most safety important issues and topics.
                       MEMBER WALLIS:  Okay.  Then you to have
           some measures of those successes.
                       MR. CUNNINGHAM:  Yes.
                       MEMBER WALLIS:  So you say we have Risk
           Informed this regulation, and in so doing, we have
           achieved some objectives which are measurable on some
                       MR. CUNNINGHAM:  That's correct.
                       MEMBER WALLIS:  It would be very useful to
           have that.
                       MR. CUNNINGHAM:  That's correct.  That's
           the  - 
                       MEMBER WALLIS:  We have reduced the number
           of pages in 10 CFR by 50 percent, or whatever.
                       MR. CUNNINGHAM:  Yes, that's right. 
           Probably the most obvious success so far has been in
           the new Oversight process used by inspection, where we
           are focusing our inspection activities on the most
           safety important issues, and that's led to a lot of
           challenges as well, but that's probably the biggest
                       CHAIRMAN APOSTOLAKIS:  I thought the most
           successful one was the Risk Informed In-Service
           Inspection.  They use a number of metrics, and it
           looks really good.
                       MR. CUNNINGHAM:  That's another one.  I
           think of it in terms of the  - how the  - there's a
           large number of inspectors in this agency out in the
           regions, and how they spend the time on a day-to-day
           basis is dramatically different now than it was five
           or ten years ago.  So in terms of NRC resources,
           certainly they're being allocated much differently
           today, and I think, to a much better focus on safety.
                       Okay.  So at any rate, in 2000, the
           Commission asked for better communications internally,
           a plan for better communications internally,
           explicitly talk about staff training requirements, and
           to come back to the Commission, and tell them of
           impediments that we see in progress for achieving the
           goals of the PRA Policy Statement, so that led to an
           October 2000 version.
                       In January of 2001, the Commission came
           back with more specific instructions to us.  They're
           shown on slide five.  They wanted to have a better
           idea of the priorities of individual activities within
           the Implementation Plan.  They wanted to see more
           detailed communications plans.  That really means
           activity specific communications plans.  They wanted
           to know what resources were being applied to what
           activities.  They wanted to bring in performance-based
           regulation for us to identify where performance-based
            - the performance-based policy aspects of what we're
           doing is brought into the Risk Informed areas.  
                       Also, to identify critical path items, and
           important, what they call cross-cutting activities,
           activities that have implications for a number of
           different Regulatory activities.  And so on slide six,
           you see the current version of the Implementation Plan
           that was sent to the Commission in December. SECY
           010218, does provide the priorities determined by the
           Implementing Offices.
                       MEMBER WALLIS:  I'm sorry.  This goes back
           to my question.  It's all about activities, isn't it?
                       MR. CUNNINGHAM:  Yes.
                       MEMBER WALLIS:  And you've got keep sight
           of where you're going.
                       MR. CUNNINGHAM:  Okay.  If you would hold
           off on that one slide, we'll try and come back to
           that, or a couple of slides.  
                       Again, we have added general and specific
           discussions of communication  - and project specific
           discussions of communications activities, resources
           for FY01 and 02, where it was appropriate to bring in
           the performance-based discussion, and identify cross-
           cutting activities.  
                       So in terms of what you have in front of
           you now, there's two basic sections to the
           Implementation Plan.  One is the background and basis
           for why we're Risk Informing our activities, and this 
           is a combination of the essence of the Commission's
           1995 Policy Statement, and the strategic plan that was
           issued a couple of years ago.
                       It also talks in general terms about how
           we decide what activities to Risk Inform.  There are
           factors  - there are a set of factors that are in
           there that are oriented towards making the decision
           whether or not to Risk Inform a particular Regulatory
           activity.  They're at a more general level.  Each of
           the arenas implements them in a somewhat different
           way.  Again, it provides communications plans,
           training programs.
                       Part Two is, again, much more specifically
           oriented with the strategic plan, and the details of
           the strategic plan.  If you recall, in the strategic
           plan, there are a set of agency strategic goals, and
           there are performance goals to accomplish the
           strategic goals.  And there are strategies to
           accomplish the performance goals.  What you'll  - 
                       MEMBER KRESS:  Where is it you discuss the
                       MR. CUNNINGHAM:  I'm sorry?
                       MEMBER KRESS:  Where is it you discuss the
           impediments that the Commission has asked for?
                       MR. CUNNINGHAM:  They come in in the  -
           probably the  - typically in the body of the
           Commission paper.  If we feel it's an impediment that
           the Commission can do something about, if it's
           necessary for the Commission to do something.
                       MEMBER KRESS:  It's in the Commission
           paper, not in the plan.
                       MR. CUNNINGHAM:  Typically, yes.
                       MEMBER KRESS:  Okay.
                       MR. CUNNINGHAM:  That's right.  The
           Commission  - in the impediments here, the Commission
           was  - I think  - I believe it was Commissioner
           McGaffigan, I'm going to say, if there's something
           that we can do to help move this along, tell us and
           we'll see what we can do.
                       MEMBER KRESS:  I see.
                       MR. CUNNINGHAM:  And Part Two is described 
           and is organized into two chapters, and focused by
           arenas.  The reactor safety arena is one chapter, and
           we have the materials and waste arenas combined in a
           second chapter.  
                       Going to slide eight, this is where, Dr.
           Wallis, we tried to get into how do we relate the what
           to the why, if you will.  This is kind of an example
           of the activity descriptions that you'll provide  -
           you'll see in the plan.
                       Up in the upper left corner are the agency
           performance goals and strategies that are relevant to
           a particular activity, so we've oriented the work that
           we're doing to say we need this body of work to
           accomplish this strategy that's laid out in the
           agency's strategic.
                       MEMBER WALLIS:  Well, what does it say
           there under the performance goals?
                       MR. CUNNINGHAM:  Well, let me pick  - I'll
           pick one as an example, see what  - 
                       MEMBER WALLIS:  I can't read it.  I'm sure
           you can't.
                       MR. CUNNINGHAM:  Well, I'll pick it  -
           I've got the book in front of me, so I'll try to  -
           okay.  Let's  - 8-8, there we go.  Okay.  So an agency
           primary performance goal, picking one example is,
           "maintain safety, protection of the environment and
           the common defense and security."  Very high level
           goal.  Okay.
                       There are a number of strategies that the
           agency has defined to accomplish that goal.  Strategy
           eight is, "We will continue to develop and
           incrementally use Risk Informed, and where
           appropriate, less prescriptive performance-based
           Regulatory approaches to maintain safety."   And so
           what you'll get out of that is a set of projects that
           are intended to accomplish that strategy.
                       MEMBER WALLIS:  It just seemed to me
           that's such a high level statement.  I'm not sure it's
           very useful for planning a particular activity.
                       MR. CUNNINGHAM:  The challenge  - I think
           the biggest challenge we faced in this is what is the
           necessary and sufficient set of projects needed to
           accomplish that strategy.  And this is  - and Frank
           will get into some of this later.  We have a set of
           activities  - 
                       MEMBER WALLIS:  Well, you said you're
           already doing that with the present regulations. 
           You've already met that strategy with the present
           regulations, so you've got to have something else
           which tells you what the payoff is for Risk Informing.
                       MR. CUNNINGHAM:  Okay.  Well, let's  - I'm
           not sure  - the strategic plan was something that  - 
                       CHAIRMAN APOSTOLAKIS:  Well, could you
           read the goals again?  It's safety?
                       MR. CUNNINGHAM:  The perform  - the higher
           level goal  - 
                       CHAIRMAN APOSTOLAKIS:  Higher level, yeah.
                       MR. CUNNINGHAM:  Maintain safety,
           protection in the environment, and the common defense
           and security.
                       MEMBER WALLIS:  We do that already.
                       CHAIRMAN APOSTOLAKIS:  That's not why
           we're Risk Informing the regulation.
                       MR. CUNNINGHAM:  I agree.
                       CHAIRMAN APOSTOLAKIS:  These are boundary
           conditions actually.
                       MR. CUNNINGHAM:  This is a very high
           performance goal, and there are many things that the
           staff does to accomplish that goal.  A subset of those
           are Risk Informed activities.
                       CHAIRMAN APOSTOLAKIS:  But shouldn't we
           say somewhere in there that the whole idea is to
           remove unnecessary burden and  - 
                       MR. CUNNINGHAM:  For example, on 1-H you
           have a secondary performance goal, which is to reduce
           unnecessary burden.
                       CHAIRMAN APOSTOLAKIS:  Yeah.  There has to
           be a goal somewhere.
                       MR. CUNNINGHAM:  That's correct.
                       CHAIRMAN APOSTOLAKIS:  Because that's
           what's driving all this.  We're not just conforming
           the regulations to maintain safety.
                       MEMBER KRESS:  Increase sufficiency of the
           regulation  - 
                       CHAIRMAN APOSTOLAKIS:  Yeah.
                       MEMBER KRESS:   - and to reduce burden
           where it's appropriate.
                       CHAIRMAN APOSTOLAKIS:  That's right. 
                       MEMBER KRESS:  I think we've stated those
                       MR. CUNNINGHAM:  That's right.  And I
           picked one activity out of a bunch of activities. 
           There are other  - that was  - the one I talked about,
           maintain safety, is a performance goal.  Another
           performance goal is to reduce unnecessary Regulatory
           burden.  And there's  - 
                       MEMBER WALLIS:  Well, I think that you
           ought to give the safety prong much more weight.  And
           my view is that if you really did Risk Informed
           Regulations, you'd have a far better idea, and the
           public would have a far better idea of how safety is
           really being maintained.  That's a much better goal
           than this rather diffuse thing of reducing burden and
           being efficient.
                       CHAIRMAN APOSTOLAKIS:  But these goals are
           not part of the plan.  Right?
                       MR. CUNNINGHAM:  Those goals are part of
           the strategic plan of the agencies.
                       CHAIRMAN APOSTOLAKIS:  The strategic plan. 
                       MR. CUNNINGHAM:  Not the Risk Informed
                       CHAIRMAN APOSTOLAKIS:  Yeah, so we can't
           really debate them.
                       MR. CUNNINGHAM:  If you'd like  - there's
           another set of people you can debate those with, if
           you'd like, but that's not us.
                       MEMBER WALLIS:  I'm trying to be helpful. 
           I think if you could get these objectives in a better
            - in a more specific form, it might be easier to plan
           the activities.
                       MR. CUNNINGHAM:  Agreed.
                       MEMBER WALLIS:  If you have something
           that's too general and too vague, then any activity
           will do.
                       MR. CUNNINGHAM:  And that's where you get
           down to the strategy, and then what you need to
           accomplish the strategy.
                       CHAIRMAN APOSTOLAKIS:  Well, I understand
           all this, but it seems to me that all this rests on
           the assumption that you already have the activities. 
           In other words, given an activity, I have these
           things, you know, how does it  - which goal does it
           serve, through which strategy, and so on. Isn't the
           most important part though, how to come up with the
           activities?  What to do?  I mean, given an activity,
           yeah, you can always give some justification.  Is that
           part of the plan?
                       MR. CUNNINGHAM:  Yes, it is.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. CUNNINGHAM:  In the sense of the plan
           as you see it in the Commission paper is the  -
           actually, the August 2001 version of the plan, there's
           a commitment in there, and there's a statement in Part
           One that says this is, in effect, what we're doing
           today.  And we're going to describe a process in Part
           One that says we're going to go out and continue to
           identify, seek out and identify whether or not there
           are other things, other Regulatory activities that
           need to be Risk Informed.  That is a very key piece of
           the Implementation Plan.
                       One of the big criticisms from GAO was
           you've given me a catalogue of what you're doing.  You
           haven't told me where you want to be and how you're
           going to get there, and that is a key piece.
                       CHAIRMAN APOSTOLAKIS:  So the selection of
           the activities.
                       MR. CUNNINGHAM:  The selection of the
           activities is a key piece.
                       CHAIRMAN APOSTOLAKIS:  Is a key piece
           which means what now?  There is a methodology for
           doing this, or  - 
                       MR. CUNNINGHAM:  There is a methodology in
           place in the waste and reactor arenas that you can  -
           you'll hear about later.  The methodology for that in
           the reactor arena is still evolving.  We have an IOU
           to the Commission, basically, the next version of the
           Implementation Plan, which is due in June, will
           describe in much more detail the process that we're
           going to use, and whatever results we have to date. 
           But you're right, to get at the real goal, to
           accomplish the policy statement, to accomplish the
           intent of the strategic plan, you have to have that
           piece of it.  And that has been a legitimate criticism
           of previous versions of this.  It didn't show that
           path forward.
                       I'm leading into what Frank wants to talk
           about this morning, because he has some ideas on how
           we could do that.  But the staff is working several
           different ways, in several different activities to lay
           out that future looking part of the plan.
                       MEMBER KRESS:  Do you plan to talk about
           the waste arena today too?
                       MR. CUNNINGHAM:  Yes.  Yes.
                       MEMBER KRESS:  I understand, they don't
           plan to use PRA.  How can you risk inform any activity
           without PRA, is the question I might have.
                       MR. CUNNINGHAM:  One of the challenges in
           trying to bring together all three arenas is a history
           of different terminology and things.  And they say  -
           they may say we don't use PRA, but we use performance
           assessment.  And then how is  - then you get into how
           is that different, and first blush, I'm not sure it's 
           very different.  They've evolved separately.
                       MEMBER KRESS:  They may, in fact, have
           some sort of a risk analysis, you're saying.
                       MR. CUNNINGHAM:  Yes.  That's correct. 
           They just may not call it that, if you will.  And then
           when we get into the materials arena, again they are
           thinking of how risk assessment is to be used there. 
           And you'll hear about how they're going to develop
           safety goals and that sort of thing, so that we're
           trying to bring things that have been done separately,
           under a common set of  - a common footing, if you
                       So at any rate, the intent of the plan as
           we show on slide eight is to link activities to the
           strategic plan, performance goals, and to the more
           detailed strategies.  Basically then, we provide a
           consistent set of information on individual
           activities, and so that becomes, if you will, the
           description of  - for the Commission of what we've
           said are the priorities, and what the resources are
           associated with individual activities.
                       Perhaps I'll just go on from there, and
           just say what we can do now is maybe turn to page  -
           slide nine, which is the reactor safety arena.  And
           we'll get into some more of the substance, some
           initiatives, and their ideas on how they're going to
           proceed to identify other activities.  Frank or Stu.
                       MR. GILLESPIE:  Yeah.  I'm going to start
           off, because I was told I have to absolutely put what
           you're about to hear in context.  And the context is
           it has no management approval, other than having been
           shown to people.  And what we're groping with is not
           in any way in conflict with the plan, the four
           strategic goals of the agency, the four strategic
           goals.  And you might say when you pick a task,
           whether you want to do that task or not, is how it
           contributes to efficiency, and effectiveness, and
           burden reduction.  So those goals help prioritize, but
           not necessarily select.
                       The other thing we were grappling with,
           and what I'm suggesting is this is the rule making
           group  in NRR grappling with risk as integral.  When
           you change one rule, have you made the other rules
           more important?  There's some fundamental questions
           you have to address when you start picking things one
           at a time.  And I think you know that I was kind of
           involved in the early part of  - the first nine months
           anyway, of the oversight process.  And what we've done
           is looked back on that and said what did we learn from
           that?  How did we structure it?  And I actually went
           back and looked at the old NEI white paper, and what
           we ended up with didn't look like anything what they
           had suggested in the first place.  The pieces were
           there, but it came out different as it evolved.
                       So what you're about to hear is our best
           thinking as reflected on some view graphs, to try to
           structure or develop a structure that is a whole, that
           is going to have to have some lower level objectives
           that would allow us to explain how things fit
           together, because we found ourselves doing 50.46,
           50.44, petitions on heat curves, Zircaloid, Zirca, and
           how does all this fit together?  And how does it fit
           together with things like the safety goal, the
           subsidiary safety goals we use.  Where do all these
           things fit?  How do we structure what we're doing so
           we know what we're either creating or destroying, and
           we can explain it, so this is very preliminary
                       We're happy to have feedback.  This has
           not been displayed virtually to anybody.  We sent
           these view graphs around yesterday, but it will give
           you an idea where Stu, who is kind of project
           managing, how do we organize rule making together in
           a Risk Informed manner.  Tried to understand some
           discussions we had, so this is very preliminary.  No
           one owns it but the rule making group right now, so
           I'm going to let Stu go through it, and let's see if
           we can answer some questions.  I hope it does provoke
           some questions, because we need an active dialogue on
           how this all fits together.
                       MR. MAGRUDER:  Thanks, Frank.  Let me
           first go through some of the significant items from
           the reactor safety arena, if I could have slide number
           nine.  There it is.  
                       These are just a sample of the many
           activities from the plan, but we just wanted to
           highlight these, and see if the Committee had any
           questions about the status of any of these real
                       We like to think that Risk Informed
           Technical Specifications are one of the successes that
           we've had in this area, that would fall under what we
           term Option One of the 98300 Plan.  No rule changes
           are required for this.  However, within the current
           regulations we're making a lot of progress, and
           getting a better safety focus on tech specs.
                       We've talked briefly about the oversight
           process, the significance determination process is
           evolving in that area.  And Mark talked a lot about
           how the inspection have been more focused on safety
           important equipment.
                       Option Three, in general, is changes to
           the Technical Requirements, and Part 50.  The 50.44
           rule making, which you've heard about before, is close
           to proposed rule stage that should be coming out
           within a month or two for comment.  50.46, there's
           been a lot of discussion recently about how to
           approach that, how to break that down into more
           manageable pieces, maybe, but that's progressing as
                 50.69, which is the proposed name for Option Two 
           Rule Making.  I'm sure you've had a lot of discussion
           on that.  That is progressing, although there's some
           challenges in there we'll talk about.  And obviously,
           the significant work on the PRA Standards with ASME,
           ANS, and NEI on guidance.  Slide ten, please.
                       MEMBER SHACK:  One of the things that, you
           know, we always come back to is, you know, how much
           risk information do you have to Risk Inform with.
                       MR. MAGRUDER:  Uh-huh.  
                       MEMBER SHACK:  And as I went through the
           plan, I tried to sort of sum up everything that was
           involved in getting risk information, you know.  And
           I came up with a tenth of an FTE on the standards
           work, you know.  Now I see that's one of the major
           initiatives, and it gets a whole tenth of an FTE.  You
           know, 1.5 for SAPHIRE, two for SPAR which is, you
           know, sort of fundamental for my level three analysis. 
           It just doesn't seem like, you know  - we make the
           words that the significance determination process is,
           you know, the key ingredient we have to be working on
           in the ROP, and yet I can come up with maybe three
           FTEs out of the whole effort that seem focused on
           improving the SDP process.  You know, I hear words,
           and then somehow the resources connected with them
           don't seem to be commensurate.
                       MR. CUNNINGHAM:  Okay.  Just to be clear
           on the standards, the large fraction, the vast
           majority of the work going on in PRA standards is
           being done outside of NRC, by ASME and by ANS, and so
           it's not that it's not important, but our role in that
           is rather limited.
                       MEMBER SHACK:  No, but the notion of how
           the standards and the whole PRA Review Process are
           incorporated  - you know, one of the difficulties we
           have every time there's a Risk Informed application,
           somebody trots in a PRA, you know.  What is it good
           for?  Is it good enough?  And somehow, I don't see any
           emphasis in here on how we're going to use the
           standards, we're going to use the review process as
           part of a tool for the NRC to make that judgment as to
           whether the PRA is applicable.
                       MR. CUNNINGHAM:  Okay.  Now one of the
           challenges of the Implementation Plan is how do you
           capture inter-relationships among activities.  The PRA
           Standards work is our support to the standards setting
           organizations.  How we use that is in another activity
           in the Implementation Plan, which is Risk Inform,
           develop of guidance for Risk Informed applications, or
           something like that.  So it goes  - it's another area
           of the plan.  
                       One of the real frustrations we've had is
           how do you show those types of relationships, so that
           somebody picking up the document would understand that
           there's more than just that tenth of an FTE associated
           with making the decisions on how we use PRA in
           licensing.  That being said, that's one of the
           continuing challenges with the plan. 
                       That being said, after lunch, I guess
           you're going to hear about where we're going on Reg
           Guide 1.174.  And that  - you'll hear a lot this
           afternoon on how we intend to endorse the ASME
           Standards, and ANS work, and how we're going to bring
           the NEI 0002 into this, and all that sort of thing,
           and that's going to be discussed after lunch.  And
           it's different than what shows up in the plan, because
           the work has evolved considerably in the last  - our
           ideas on how to do that have evolved considerably in
           the last six months or so.  That's another challenge
           for the plan, how do you maintain a current, if you
                       MR. BARRET:  If I could interrupt, my name
           is Richard Barret.  I'm with NRR. I'd like to just
           take a second to address your statement about the
           Reactor Oversight process, Significance Determination
                       There is a fair bit of effort, and a lot
           of thought going on right now on the subject of where
           are we going in the future with the Significance
           Determination process.  We have a Phase Two  - a Phase
           One methodology that we're happy with.  We have a
           Phase Two methodology that is a work in progress, very
           much a work in progress.  And we have a Phase Three
           methodology, which also is a work in progress.
                       We are currently having discussions within
           the staff as to how much emphasis we would give to
           Phase Two versus Phase Three.  And also, where our
           priorities and our resources will go in developing and
           finalizing particularly the Phase Two tool, but also
           the SPAR models.  And questions are being raised as
           to, for instance, do we want to accelerate the bench
           marking of those methodologies, so I just want you to
           know that the question of the quality of the
           Significance Determination Process Tools is very much 
           on our radar screen right now, and we  - 
                       MEMBER SHACK:  It doesn't seem to be
           highlighted very well in the plan though.  You know,
           I look at  - you know, they've got like a priority of
           six or seven for the SPAR stuff  - 
                       MR. CUNNINGHAM:  Yes.
                       MEMBER SHACK:   - which sort of says yeah,
           okay.  You know, we'll think about it when we get to
                       MR. CUNNINGHAM:  Yeah.  You're right.  In 
           August of 2001, that was a reflection of where the
           agency was and the importance of the SPAR work. 
           Again, one of the challenges is that perspective has
           changed considerably over the last three or four  - as
           we've developed more experience with SDP, so the plan
            - and so the challenge is how do you continue to
           reflect that, and somebody can look at this plan and
           see that it's up to date.  SPAR, I think it's
           recognized, as Rich was alluding to, there's a much
           better recognition today of the importance of the SPAR
           models in the context of the three phases of the SDP. 
                       MR. MAGRUDER:  Okay.  Real quickly, on
           page 10, I just wanted to highlight that there are
           obviously some challenges ahead of us in Risk Informed
           Regulation, and these are just some of the areas that
           I wanted to highlight.  You can look through those.
                       The last one, I think, Dr. Wallis, we'll
           address in the next couple of slides here, which is
           how we see this all fitting together.  This is  - as
           Frank said, these are preliminary views of this.
                       MEMBER ROSEN:  Did you skip the third one
           for a reason?
                       MR. MAGRUDER:  Just for time, but I'd be
           happy  - if you have a question about it.
                       MEMBER ROSEN:  I don't know what it means.
                       MR. MAGRUDER:  The Risk Informed
           Environment is an effort within NRR to  - well, it's
           got several phases.  Basically, the goal is to try to
           make risk information more available to the staff and
           have the staff more open to using Risk Informed
           Regulation  - Risk Informed methods in their day-to-
           day work.
                       MEMBER POWERS:  If I'm a Project Manager,
           let's say in NRR, and say I'm  - I have a job, maybe
           power upright maybe, and I say gee, I want to know
           whether this is a risky operation.  How do I get  -
           how do I find out?  Say it's  - let me just be very  -
           to be specific  - 
                       MR. MAGRUDER:  Uh-huh.  
                       MEMBER POWERS:  Say I've got Indian Point
           II and they want to power upright.
                       MR. MAGRUDER:  Right.
                       MEMBER POWERS:  How do I go about getting
           risk information on Indian Point II?
                       MR. MAGRUDER:  Well, I think Rich will
           probably talk  - if I can impose on Rich to talk some
           more about that, but I think generally, the Project
           Manager goes to Rich's staff in NRR, and ask them to
           look at the submittal from the licensee.
                       MR. BARRET:  Dana, we have  - I guess we
           could say there are two classes of license amendments
           like that, those that come in that are flagged by the
           licensee as being Risk Informed license amendments. 
           And then, of course, it's obvious that they should be
           reviewed by the risk staff.  But then there's another
           class, a much larger class of license amendments that
            - oh, and by the way, that first class  - no, let me
           not say that.  That's not true.
                       MEMBER POWERS:  Well, I'm  - regardless of
           what the licensee has submitted, I just want to know. 
                       MR. BARRET:  You mean, just woke up one
           morning and you just want to know about  - 
                       MEMBER POWERS:  I got a thing in front of
           me from this licensee, wants to do something.
                       MR. BARRET:  Okay.
                       MEMBER POWERS:  He's got his case laid
           out, perhaps using risk information, perhaps not.  I
           just want to know  - 
                       MR. BARRET:  Right.
                       MEMBER POWERS:  Because I've got  - I
           mean, you've already made a decision that if I want
           this information, I can get it.
                       MR. BARRET:  Yes.
                       MEMBER POWERS:  Okay.  And now I want to
           know whether I should be asking for more or less,
           because I want to know if it's risky, because it's
                       MR. BARRET:  Yeah.
                       MEMBER POWERS:  It's changed the plan.
                       MR. BARRET:  Yeah.  And that's  - one of
           the things we did in SECY 98300 was we raised this
           very issue, and that is, what if a licensee submits
           something, and it meets all of our regulations, and it
           looks like it's consistent with our current design
           basis, and it looks like something we should just
           approve based on our deterministic regulations.  And
           yet, you have  - you wonder, is this risky anyway. 
           And we put in place a process for questioning that,
           and it's  - without going into a lot of detail, it's
           sort of a three step process where we first ask
           ourselves does this represent a special circumstance?
                       MEMBER POWERS:  I mean, I understand what
           you have to do if you want to go to the licensee, or
           you want to factor it in.  I just want to know.  I
           haven't decided yet whether this is risky or not.  I
           don't know.
                       MR. BARRET:  They would come to our staff. 
           They should come to our staff, the Probabalistic
           Safety Assessment Branch, and get a read on it from
                       MEMBER POWERS:  And you do that by running
           a SPAR model, or  - 
                       MR. BARRET:  Well, you know, it depends on
           the question.  You know, there are  - as you all know,
           there are many questions where  - 
                       MEMBER POWERS:  I'm in the last bastion of
           the risk ignorant.  All I know is there's a thing
           called risk, and I want to know what it is for my
           particular plant and things like this.  I haven't got
           a clue what question to ask.
                       MR. BARRET:  Right.  And you have the
           license amendment in front of you, and I  - you know,
           as you know, a risk analyst can kind of look at an
           issue and pretty quickly get a sense of whether it
           tends to be risk significant, or it tends not to be
           risk significant.  And it may not go any farther than
           that.  It may be that we could say right off the bat
           that this doesn't  - this is not in the range of the
           risk significant  - 
                       MEMBER POWERS:  Okay.  Suppose the
           licensee says gee, the NRC is making me inspect the
           upper heads of my reactor vessels all the time.  And
           boy, that's a super pain to do because I've got all
           this insulation on there.  What I'm  - the licensee is
           proposing to do, is he's going to change out this
           insulation that he's got for this new micro porous
           insulation that's kind of elevated above a head, and
           you can get it off real easy, and do this inspection
           all the time.  
                       How do  - and so the Project Manager wants
           to know whether that's  - that has any risk
           significance or not, because I mean, it's change but
           it doesn't seem like a very big change.  I mean, one
           insulation for another.  How does he find out?
                       MR. BARRET:  He would come to us, I would
           say, if he had that curiosity.  And we would look at
           the issue, and you know, ask ourselves some key
           questions about what affect would this have on
           initiating events, what would have on the availability
           and reliability of systems?  Would it have any affect
           on operator actions, containment performance, you
           know.  And if there was some plausible impact on risk,
           then we might look deeper.  We might look at the SPAR 
           model  - 
                       MEMBER POWERS:  You think your risk models
           that you have model something as detailed as the
           insulation on the upper head?
                       MR. BARRET:  Off the top of my head, I
           don't think that example would be in a PRA.  In fact,
           a great de al of what you might see in the way of
           license amendments you would not find explicitly
           modeled in a PRA.
                       MEMBER POWERS:  And suppose I told you
           that this micro porous insulation that's proposed to
           use is extremely friable, and in a blow down system
           will produce a lot of particulum?  
                       MR. BARRET:  You know, I think that would
           be one of the questions that we would ask ourselves,
           for instance.  You know, we  - we're cognizant of the
           work that's being going on with strainer blockage and
           the  - now that we're working on the PWR sumps issue,
           so that would be one of the questions.  Sure, we would
           ask ourselves that.
                       CHAIRMAN APOSTOLAKIS:  Well, when we say
           risk information, do we all understand the same thing? 
           I  - the reason why I'm saying this is I was surprised
           recently in talking to some industry people that they
           don't think that uncertainty analysis is necessary,
           and the staff is not using it.
                       MR. CUNNINGHAM:  That would be a surprise
           to me too.
                       CHAIRMAN APOSTOLAKIS:  Well, I mean, if we
           look at the petitions from the industry, the risk
           informed things, are they doing explicitly risk  - I
           mean, uncertainty assessments, or is it a qualitative
           discussion as it is in 1174, which says if you come
           close to the boundary, management will pay attention,
           will do something and thing about it.
                       MR. CUNNINGHAM:  I suspect 1174 is  -
           today is as precise a characterization of how to deal
           with uncertainties as we've got.
                       CHAIRMAN APOSTOLAKIS:  So if I go with
           1174, then I don't need to do it explicitly.
                       MR. CUNNINGHAM:  It depends on what the
           issue is, and what the decision you're trying to
           achieve is.
                       CHAIRMAN APOSTOLAKIS:  But does NRR, for
           example, when you review a request, you look for
           explicit statements of uncertainty, or is it a
           qualitative discussion is good enough.
                       MR. BARRET:  It's generally qualitative
           discussion.  I mean  - 
                       CHAIRMAN APOSTOLAKIS:  Ahh, see.
                       MR. BARRET:  Well, again I want to make
           sure we're talking about the same thing.  I mean, when
           we say qualitative you want to know if you're close to
           an edge, if you're close to a catastrophic change in
           the picture, or are you looking at something where if
           the temperature is five degrees higher everything
           changes, or you know  - 
                       CHAIRMAN APOSTOLAKIS:  Yeah, these are
           sensitivities really, but I mean  - 
                       MR. BARRET:  Some of them have to do with
           margin, for instance.
                       CHAIRMAN APOSTOLAKIS:  Yeah.  Doing
           standard uncertainty analysis, standard means that
           you're right on something, is that kind of stuff.
                       MR. BARRET:  Right.
                       CHAIRMAN APOSTOLAKIS:  It is a trivial
           matter these days.
                       MR. BARRET:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  I mean, with the
           computer programs that are available and so on.  And
           yet, you know, from talking to people I get the
           impression that they don't think that that's something
           that's necessary.  And why is it not necessary,
           because the staff does not request it.  And that came
           as a surprise to me.  Now I know when we're developing
           rules here, we're thinking about uncertainty all the
                       MR. BARRET:  Yes.
                       CHAIRMAN APOSTOLAKIS:  But when it comes
           to interacting with the licensees, evidently there's
           a different philosophy.
                       MR. CUNNINGHAM:  Again, there's an element
           of  - 
                       MEMBER ROSEN:  But later today we are
           going to talk about the PTS.
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. CUNNINGHAM:  And then there's a
           tremendous amount of thinking about uncertainty.
                       CHAIRMAN APOSTOLAKIS:  Because that's us. 
           The industry is not submitting anything there.  We are
           doing that. And as I said, we are very sensitive to
           that issue when we are developing studies ourselves.
                       MR. CUNNINGHAM:  In a sense, that gets at
           the point of what's the decision being made.  The
           change for an individual license, associated with an
           individual license amendment may not necessitate that
           sophisticated of analysis.  The change of a rule that
           could affect whether or not we have a PTS rule for a
           dozen or 15 plants looking for life extension, license
           extension is  - 
                       CHAIRMAN APOSTOLAKIS:  I hope you could
           resolve that in the ASME Standard.  That was a major
           issue of disagreement.
                       MR. CUNNINGHAM:  I hope it is too.  I'm
           not  - I suspect it is not.
                       CHAIRMAN APOSTOLAKIS:  Is not.  I mean,
           it's true that we can do a lot of things without a
           rigorous uncertainty analysis.  It's very true.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  I don't doubt that. 
           The thing that's missing, like in many other places,
           is under what conditions can you do that, under what
           conditions can you do something else.  And we don't
           seem to be paying attention to these things.
                       MR. CUNNINGHAM:  I guess conceptually the
           three column approach in the ASME Standard is a step
           towards trying to lay out when you could do very
           simple, and when you need to do more sophisticated, or
           very sophisticated analyses.  Whether it accomplishes
           it for  - in this particular area, I'm  - 
                       CHAIRMAN APOSTOLAKIS:  Well, it's been a
           while since I saw that, but the I mean, the second
           column said use mean values.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  And I don't know
           how you can use mean values if you haven't done an
           uncertainty analysis.
                       MEMBER KRESS:  Yeah, and that  - 
                       CHAIRMAN APOSTOLAKIS:  If you declare them
           that they are mean values, then it's okay.  All right.
                       MEMBER KRESS:  That brings another
           question to mind, and that is what we normally see
           from the submittals are "best estimates", which they
           declare to be a mean.  They don't declare it, but it's
           understood that this is a mean.
                       I've never seen a study by this
           organization, or any other, that actually took what
           would be a best estimate, which to my mind, you go in
           with all the parameters that you can  - as input and
           part of the code that does it, and you try to pick
           your mean values for those, and end up with the final
           product, is my view of what that best estimate is. 
           I've never seen a study that really compared that
           number to the real mean that you would get by
           quantifying the full uncertainty.  Is that anywhere in
           your plan, because it seems to me like a key issue
           these days.  You don't really know what you're getting
           from these things unless you have that.
                       CHAIRMAN APOSTOLAKIS:  Exactly.
                       MEMBER KRESS:  And I just don't see that
           task in the plan anywhere.
                       MR. CUNNINGHAM:  Okay.  No, that  - 
                       CHAIRMAN APOSTOLAKIS:  Sensitivity
           analysis is used a lot.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  Which is really not
           used, it's abused, so  - 
                       MR. CUNNINGHAM:  I guess there's two
           things to Dr. Kress' point.  There were studies done
           ages ago to look at that issue, and I don't know  - I
           don't even know that it was really documented very
           extensively but, you know, this was perhaps 15 or 20
           years ago.  I can remember somebody looking at that
           issue and saying the difference was a factor of two or
           three in the value, if you will.  Whether that has any
           substance today, I don't know.
                       MEMBER KRESS:  It would be useful to dig
           that out.  I didn't realize that existed.
                       MR. CUNNINGHAM:  There had been work on
           that ages ago, and I'm not trying to defend it or
                       CHAIRMAN APOSTOLAKIS:  Yeah.  And this is
           part of our confusion.  I mean, you don't know. 
                       MR. CUNNINGHAM:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  It depends a lot on
           how complex a problem is.
                       MR. CUNNINGHAM:  Exactly.  Exactly.  And
           the characteristics of the underlying distributions,
           and all that sort of thing.
                       MEMBER KRESS:  But if I knew I was no
           further off from the mean than a factor of two, for
           example, I wouldn't worry much about it.
                       MR. CUNNINGHAM:  Again, that was an
           example done years ago, and probably with the WASH
           1400 PRA Models, and all of the baggage that goes with
           those, if you will.  But the issue  - 
                       MEMBER KRESS:  But is there a general
           conclusion, like if you did the central estimate, you
           end with the best estimate, can you make a statement
           like you always end up with a number that's higher
           than the mean?
                       CHAIRMAN APOSTOLAKIS:  No, I don't think
                       MR. CUNNINGHAM:  No.
                       CHAIRMAN APOSTOLAKIS:  I don't think so.
                       MR. CUNNINGHAM:  I suspect if you did the
           mean, you would  - 
                       CHAIRMAN APOSTOLAKIS:  The kind of study
           you want has not been done.  I agree with Mark that
           there have been pieces here and there.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  But the
           comprehensive study that looks at that has not been
           done, and I'm not sure it can come up with general
           conclusions, because it will depend a lot on what
           functions you're dealing with.
                       MR. CUNNINGHAM:  Yeah.  I think typically
           you tend to see mean values being higher than  - in
           the few examples I can think of, the mean values to be
           higher  - 
                       CHAIRMAN APOSTOLAKIS:  The rigorous mean.
                       MR. CUNNINGHAM:  The rigorous mean  - 
                       MEMBER KRESS:  Has to be higher than this.
                       MR. CUNNINGHAM:  Higher than the best
                       MEMBER KRESS:  Okay.
                       CHAIRMAN APOSTOLAKIS:  Also, it depends on
           how you handle the correlations and all of that.
                       MR. CUNNINGHAM:  Yes.  Yes.
                       CHAIRMAN APOSTOLAKIS:  It is true though,
           it seems to me, that the industry does not feel that
           they have to do uncertainty analysis when they come to
           you, or not to you, to NRR.  And again, we see that
           right now in the NEI document on Option Two.  You will
           find the word sensitivity many, many times, but not
           uncertainty.  And I don't know why they feel that by
           putting everything at the 95th percentile and carrying
           out the calculation is more meaningful than doing an
           uncertainty analysis.  I just don't understand that,
           but we will discuss that with them when the time
                       MR. MAGRUDER:  Okay.  Let me move on  - 
                       CHAIRMAN APOSTOLAKIS:  But does the risk
           information, in your mind, include the uncertain?
                       MR. CUNNINGHAM:  In my mind?
                       CHAIRMAN APOSTOLAKIS:  Yeah.
                       MR. CUNNINGHAM:  Every time.  Yes, sir.
                       CHAIRMAN APOSTOLAKIS:  So all these
           documents will do that.  Rich?
                       MR. BARRET:  Well, I think there's a lot
           of value in sensitivity analysis, and it tells you  -
           if you combine it with some sense of how wide, you
           know, the variances might be.  I mean, if I believe
           that reliabilities might go down by a factor  - or
           unreliability might go up by a factor of ten, then I
           do a sensitivity analysis around that estimate, I
           think I've learned something from that.
                       CHAIRMAN APOSTOLAKIS:  But it's not a
           substitute for uncertainty analysis.  I mean, you
           learn something from sensitivity.  In fact, if you do
           a rigorous uncertainty analysis, and you can structure
           your sensitivity analysis around that by not just
           changing point values, but maybe changing
           distributions and so on, which would be a much more
           meaningful thing.
                       MR. BARRET:  Right.
                       CHAIRMAN APOSTOLAKIS:  But as a rule, I
           don't think you guys require rigorous uncertainty
                       MEMBER KRESS:  And along that same thing,
           Rich, I'm not sure I know or have seen any written
           material of what constitutes a rigorous uncertainty
           analysis.  I mean, rigorous sensitivity analysis,
           because what's usually done, you take various
           parameters you think you might have a sensitivity to,
           and you change them one at a time.  Sometimes you
           change all of them together.
                       MR. BARRET:  Yes.
                       MEMBER KRESS:  But I don't know what
           constitutes a rigorous sensitivity analysis.  Those
           two don't do it for me at all.  And, you know,
           sensitivity is a whole output space.
                       CHAIRMAN APOSTOLAKIS:  Actually, the place
           will have done a lot of sophisticated sensitivity
           analysis and performance assessment.  There are all
           chapters there where they do all sorts of things.  In
           fact, they are so sophisticated that simple minds like
           ours have difficulty following what they are doing,
           because they had, you know, statisticians develop, you
           know, using the latest methods.  So there is a gap, I
           think, you know, between doing very trivial stuff and
           very sophisticated stuff, doing something in between. 
           And for reactors I haven't see that, that kind of
                       MR. CUNNINGHAM:  Yeah, that's true.  And
           as you alluded to earlier, the PTS work that we're
           doing is closer  - 
                       CHAIRMAN APOSTOLAKIS:  It's closer  - 
                       MR. CUNNINGHAM:   - on the scale to the
           performance assessment work  - 
                       CHAIRMAN APOSTOLAKIS:  Yeah, among us boys
           again.  I mean, I will  - 
                       MR. CUNNINGHAM:  That's right.  You know,
           and as part of that project we're trying to sort out,
           now how do you capture the importance of the
           uncertainties, the relative importance of different
           uncertainties in the process, and all of  - 
                       CHAIRMAN APOSTOLAKIS:  For example, in
           Option Two, we are categorizing systems and components
           using the expert panel with a very input, being the
           importance measures.  Now the importance measures are
           uncertain themselves.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  And that's nowhere
           to be found.
                       MEMBER POWERS:  George, one of the things
           that you've raised is the relative weakness of
           performance measures as a tool for understanding what
           the risk assessment is telling you.  Is anyone trying
           to develop better tools for telling you what the risk
           assessment is commenting on these things, since we use
            - I mean, we have a lot of work going on now that
           involves the categorization of things in both events
           and hardware.  And Professor Apostolakis has written
           magnificently on why one should not attach great
           significance to things like fusel vessely or risk
           achievement worth, and risk reduction worth.
                       MR. CUNNINGHAM:  Yes, there actually is. 
           There's some work going on in my group.  Using as an
           example, the categorization process used for South
           Texas to say, you know, that as you've said before and
           others have said, the fusel vessely and the other
           importance measurements were designed for a particular
           purpose, and now we're kind of using them for a
           different purpose.  And we're asking the question in
           this project of given how things were done in the
           South Texas example, if you will, is there a better  -
           an alternative formulation of an importance measure,
           an importance calculation that might make more sense
           given that application.  We're doing some work in that
           area right now, but  - partially at Brookhaven and
           partially at the University of Maryland.  At some
           point, it may be appropriate to come back and talk to
           the Committee about that.
                       MEMBER ROSEN:  I think South Texas would
           have an interest in it, as well.
                       MR. CUNNINGHAM:  That's probably true. 
                       MEMBER POWERS:  Minor.
                       CHAIRMAN APOSTOLAKIS:  Shall we go on?
                       MR. MAGRUDER:  Sounds good.  Let's go to
           slide eleven, please.  As Frank mentioned, the NRR
           rule making group has been looking at how our rule
           making, or what the next steps should be for risk
           informed rule making, along with discussions with
           Office of Research, obviously.  And this is
           preliminary information here, but one of the goals
           that we think should have is to proceed with risk
           informed regulations such that our rules start to
           converge with the processes that we have in place.
                       We perceive that there may be a gap
           between some of the activities in place, and the rules
           to support the activities, and I'll talk a little bit
           about that in a couple of slides here.  And of course,
           with the  - we want to follow the principles that we
           have laid out, dimension depth, safety margins, and
           consistency with the safety goals that the Commission
           laid out.
                       MEMBER WALLIS:  Now I read this slide
           ahead of time and tried to think about what it meant,
           and I don't really understand it.  And it seems to me,
           you're always going to have some measure defense in
           depth, you're going to have some round of safety
           margins, but the regulations never tell you what
           defense in depth is, how you measure it, or what
           safety margins should be, or how you measure them, so
           it seems to me that they need to be risk informed. 
           You need to  - when you ask the question how much
           defense in depth is necessary, that should be a risk
           informed decision.  And when you ask the question how
           big should the safety margins be, that should be a
           risk informed decision, so they're not on some other
           plain or some other measure.  And you should be risk
           informing those ideas themselves.
                       MR. MAGRUDER:  If we could go to the next
           slide  - 
                       MEMBER WALLIS:  Otherwise, you'll always
           be arguing, or someone will always say well we need
           more defense in depth.  You'll never reach a
                       MR. GILLESPIE:  I think  - 
                       MR. MAGRUDER:  Graham, we're in violent
                       MEMBER POWERS:  Well, maybe I'm not.  You
           know, I worry.  We create this intellectual construct
           called risk information, which in examining it
           closely, you find all these deficiencies.  I mean,
           there are uncertainties here, there are uncertainties
           there.  We don't know whether this is included.  You
           know, you go through and you do an uncertainty
           analysis.  George will just excoriate you because all
           you've done is do parameter uncertainty, and you
           haven't worried about model uncertainty, things like
           that.  And at some point, you have to ask what if I'm
           just completely wrong about all this stuff?  And I
           think that that's where you start asking for defense
           in depth.  And if you try to justify defense in depth
           based on the construct you're trying to protect
           yourself from, you're going to get into a paradox
           that's going to leave you vulnerable, I think.  And so
           I'd be very careful about using risk information to
           guide my selection of defense in depth.  
                       Now you will find on this august buddy
           certain people called rationalists, and I encourage
           them to think carefully about self-referencing sets
           before they try to advocate the use of risk
           information to guide themselves on defense in depth.
                       MEMBER WALLIS:  Well, what you're simply
           saying is that you've got to be more sophisticated
           about how you interpret and use risk information.  But
           essentially, when you make decisions about defense in
           depth, it's made to change the risk.  And you're
           making it  - because  - if you make it on some other
           basis than using PRAs, it's because you don't believe
           the PRAs, and that's information, that's risk
           information too.  You're still making decisions based
           on  - 
                       CHAIRMAN APOSTOLAKIS:  It seems to me that
           Option Three provides an example of  - I mean,
           actually set certain criteria, you know, attribution,
           prevention, mitigation quantitatively, so there is
           some degree of quantitative judgment already
           established in regulation, so are you referring to
           that here, or  - 
                       MR. GILLESPIE:  Yeah.  If  - let me ask
           Stu to jump in.  Let me jump to the problem we had. 
           The problem we had was  - 
                       MEMBER WALLIS:  Well, Frank, you were in
           violent agreement with me, so  - 
                       MR. GILLESPIE:  Yeah, I am.  No, actually
           I'm kind of  - we're groping with those same
           questions.  And, Dana, I think we're also in agreement
           with you, which is why we started in the last 
           several  - 
                       MEMBER POWERS:  You didn't frown at all.
                       MR. GILLESPIE:  Which is why we started
           this kind of construct.  If you noticed, the first two
           view graphs were a list of rules, and they were being
           treated as independent rules.  And I'll give you an
           example.  Top of a report in the Pass said you didn't
           need a sampling system.  Well, that was because we had
           a sampling system required by the Hydrogen Rule.  And
           for a year and a half, the Hydrogen Rule people wrote
           a rule that said you didn't need a sampling system
           because the Pass people had it.  And after about two
           years of work, got these two people to talk to each
           other, and we realized what we really needed was a
           single sampling system, not two.
                       What's that evidence of?  That's evidence
           of when you start getting so many individual efforts
           going, and you haven't fit them into any kind of
           construct.  And it's not that the one we've got up
           here is the right one, it's kind of the first one that
           Stu and I kicked around, and some smart people gave us
           some input on, to try to start to pull things
           together.  And the next step in this is to fill in
           some information.  You'll see on there that we've got
           the  - under "Accident Prevention", we've got the
           surrogate safety goal, if you would, of 10 to the
           minus 4.  What we did was just to put some plugs in of
           where some things fit that currently exist.  You could
           see the oversight cornerstones in there.  Those blocks
           are in there.
                       We went to a slightly lower level just in
           this picture, and the concept would be to try to
           balance things like defense in depth, is to write an
           objective for each of the blocks you would see, or
           however this might evolve.  It would be kind of a
           regulatory objective.  What's our objective?  And we
           took initiating events, and just chatting about it
           with some brainstorming we said well, you know what,
           there's transients and there's accident events, like
           true events.  What rules do we have that deal with
           transients, which might be like station blackout,
           things that happen that we don't necessary have all
           the regulations on, but we have some.  And what
           regulations fit under each of these categories.
                       And then if you  - and I don't mean by
           whole regulation, by 50.46, or 50  - I mean by
           subparagraph, so that you get the truly like things
           that deal with phenomena together, recognizing that
           one regulation like single failure criteria could
           actually go across the board.  And then when you
           change something, if we change 50.44 you can ask
           what's its affect on all the other objectives.
                       What we're trying to do is kind of link  -
           in DOT process is link our current body of
           regulations, which people would agree are not
           necessarily written in a risk informed context,
           although safety was in the context of the minds of the
           writers, with some set of risk informed objectives. 
           And I say risk informed objectives because, just
           because an initiator is so low, doesn't mean you
           shouldn't have a mitigation function for it.  So what
           we're trying to do is provide a structure in which to
           consider defense in depth.  It's not totally driven by
           the PRA, it's driven by some of our deterministic
           thinking which we might not have totally let go of.  
            But the important piece of where we're going with
           this, or where we think we might be going if it
           matures further, would be to write objectives for each
           of these blocks, sort the rules, the pieces of rules
           under this, and say now let's look at it.  Is that
           rule needed to meet that objective?  
                       The important piece, as we found in the
           ROP, was coming up with a consensus objective of what
           is containment there for.  And coming up with that one
           or two sentence objective was, once we did that in the
           ROP program, the rest was easy.  The rest was actually
           quite easy.  It was implementation.
                       So in trying to organize our thought
           processes, this was our first cut.  You can see under
           the LERF box, we've got less than E minus 5.  Well,
           that's not a conditional number, we recognize.  That's
           kind of an absolute number, but there's also some
           conditional numbers, and we didn't  - Stu didn't have
           a chance to find it, but there used to be like a
           conditional number on containment that was thrown
           around in some literature in the agency also.  And 
           so  - I think it was .1, so what we're doing is right
           now is kind of searching around  - 
                       MEMBER KRESS:  That was for the full
           conditional failure.
                       MR. GILLESPIE:  Full conditional failure,
           yeah.  So what we're doing now is searching around for
           all of this policy guidance and saying how can we
           create a structure and fit it in?  How can we then
           take the next step and create an objective for each of
           these blocks which is risk informed, and it may be
           qualitative, it may be a number, it may be both.  And
           we picture kind of a database  - a spreadsheet with
           little Xs as a starting point to index our thinking
           relative to grouping the regulations, and then say
           does this regulation  - is it needed to meet that
           objective?  Can these two be combined with a more
           performance oriented wording, like the example I used
           on sampling systems, to meet the objective?
                       If I take this rule out, am I more
           dependent on the other rules for meeting the
           objective?  And it's those kind of questions that
           we're running into as we're dealing with things in
           isolation one at a time.  
                       This doesn't compete, by the way.  You
           prioritize what you work on by the four agency goals,
           which is what's in the plan.
                       MR. MAGRUDER:  Right. 
                       MR. GILLESPIE:  This is a thought process 
           to help us make sure we structure things.  And if we
           destroy a rule, we know its impact is a synergistic
           affect in the whole.  Let's skip to the next slide.
                       MEMBER SHACK:  Didn't the research try to
           do that with their framework document?
                       MR. GILLESPIE:  Well, we did.  We took  -
           we scavenged a lot, you'll see in here, from the
           research document which was used to prioritize Option
           Three.  But this thought process is the body of rules,
           and it's kind of independent of Option Two/Option
           Three.  And we're not using it to prioritize.  What
           we're doing is using it kind of like an analytic
           approach, or an analytic tool to say do we really know
           what we're doing when we change this rule, or this
           paragraph, and know what its impact is overall, in
           kind of a risk informed structure.  I'm not saying
           it's perfect, but it's a risk informed indexing, and
           now let's go in and change things, but let's
           understand how the impact is.  Let's have something
           that helps us display and understand the impact.
                       MR. MAGRUDER:  Yeah, this is  - I guess
           this is kind of an expansion of the framework
                       MEMBER WALLIS:  Have you used this for
           something like 50.46?  And I can see looking at  - I
           can see doing it with one regulation like 50.46.  The
           difficulty though is, how does that relate to all the
           other regulations because I don't  - bringing all the
           regulations into this kind of a box you just showed us
           is going to be very difficult.
                       MR. GILLESPIE:  Well, I think the first
           cut is not that difficult.  It's a matter of just
           sitting down and taking the various subparagraphs, and
           separating them in some logic manner, grouping the
           phenomenological things together.
                       MEMBER WALLIS:  But they're also dependent
           on all the other regulations, so the interaction is
           not going to be  - 
                       MR. GILLESPIE:  And that's what I'm
           concerned with, is we're trying to get a handle as
           those interactions.  When I destroy a rule, have I
           become more dependent on the rest?  And so this is our
           thought process.  I picture the next thing being the
           bottom row of blocks here along the top of a database,
           and all of our regulations in some logical subset,
           because you can't deal with them in big pieces. 
           Otherwise, you've kind of got to get them down, and
           also recognize underneath each one of those little
           paragraphs in the regulations is a big body of
                       I'm not saying it's simple, but what we're
           trying to do is get our thought processes away from
           thinking in isolation, and thinking in context, and
           take advantage of some of the thinking that went into
           the ROP and its development.  And going to the next
           step, I'll tell you what I think the importance of
           being able to articulate what the objective of
           containment is, what the objective of protecting the
           fuel is, or protecting the primary circuit.  What are
           our expectations?  Is in the next diagram  - 
                       MEMBER KRESS:  Before you go to that
           Polish firing squad diagram, I have a comment about
           this one I'd like to  - 
                       MR. GILLESPIE:  Remember, this is only me
           and Stu, and Cindy.
                       MEMBER KRESS:  If you look at the row of
           initiating events, mitigation, containment, emergency
           planning, that's sort of a shorthand for PRA.  
                       MR. GILLESPIE:  Uh-huh.  
                       MEMBER KRESS:  That's what goes into a PRA
           when you calculate the risk.  And what you  - I
           understand your thinking is that you're going to look
           at the body of regulations you now have to see where
           you deal with these things, and see how you might risk
           inform that part of it.  The problem  - the partial
           problem I have with that is, the assumption  - there's
           an implied assumption there that what you now have is
           the right balance among those things.  Let's talk
           about balance as a defense in depth concept.
                       MR. GILLESPIE:  Okay.
                       MEMBER KRESS:  Now I'm going to reveal my
           rationalist viewpoint here, but what  - when I look at
           this, and if I did this in a PRA for each individual
           plant, I would get different contributions along those
           from each plant to establishing its risk status at  -
           with risk, some thing at the end of the PRA.  And I
           would get different numbers, different contributions
           for those depending on the reactor, and the type, and
           so forth.  And so, I have to ask myself, what is the
           contribution among those that I find acceptable from
           the defense in depth standpoint?  That's a question I
           ask myself over and over.  And I've never seen a
           rationalization of any kind of criteria, other than
           what we already have, which is kind of 10 to the minus
           4, with nothing  - with no sequences that really  -
           outstanding versus  - and 10 to the minus 5.  Those
           are the only two.  Why are those appropriate in my
           mind, and what do they have to do with the
           uncertainties in the determination of each point along
           the line? 
                       Now as a rationalist, I would say when I
           ask myself what if I'm wrong as a defense in depth
           concept?  What if I'm wrong, and how do I accommodate
           that?  I rephrase the questions and say what
           confidence do I have in my answer in the PRA?  And
           that gives me a measure of how much I think I'm wrong,
           if you do the uncertainty wrong.  So I think the
           rationalist approach can accommodate a structurist
           thinking, because I think you can answer that
           question, what if I'm wrong, to some extent.  And how
           wrong am I, and then I can have a handle with which to
           tie how much defense in depth I need, or where does it
           need to be put.  And I don't see that in here at all,
           that handle.
                       MR. GILLESPIE:  I agree with you, because
           that's  - kind of our next step would be  - and let me
           go back to what I said.  No matter how low you can
           force initiating events down in the mathematical
           modeling, mitigating the core damage frequency
           accident is still a requirement, which means you need
           to set up a set of objectives.  This is what we're
           grappling  - this is why you don't see an objective
           written down there.  It's just a title right now, is
           independent of how good you can make your plant, it
           doesn't matter.  WE still expect this, this is being
           able to mitigate the accident, and this in being able
           to contain it.  And I think some of that thinking went
           into writing the regulations over the years, but no
           one wrote it down.  It wasn't in a structured,
           necessarily, way.  And what I'm suggesting is this how 
           we and the staff are trying to at least get some
           structure to our thinking, to start putting those
           questions on the table, because that would get to,
           well what is the objective of mitigation systems?
                       CHAIRMAN APOSTOLAKIS:  Now I have a
           problem here.  At 10:00 we have the Officer Directors
           coming, and you, gentlemen, have to wrap it up in two
                       MR. GILLESPIE:  If I could just jump to
           the next slide  - 
                       CHAIRMAN APOSTOLAKIS:  Tell us what the
           most important thing is from your presentation.
                       MR. GILLESPIE:  Okay.  The next slide  - 
                       MEMBER ROSEN:  You're going to wrap up the
           entire discussion, or just the reactor arena
           discussion, because we had two subjects, and we've
           talked about  - 
                       CHAIRMAN APOSTOLAKIS:  This section is
           being wrapped up in two minutes.  
                       MEMBER ROSEN:  We talked about half of
           what we came to listen to.
                       CHAIRMAN APOSTOLAKIS:  Well  - 
                       MR. GILLESPIE:  Let me jump just to the
           next slide so I can wrap up our piece, and why I think
           the first slide is important.  The first slide, which
           sets up a set of objectives, basically starts setting
           up a standard.  And in this slide you see some of the
           things going around the outside that we've been doing
           kind of in isolation.  And one would ask, why does the
           ASME Code have a low categorization in ISI and IST,
           which could be different from Option Two's Risk Three,
           and why are they treated different?  And what's the
           relationship between that and configuration management
           under A-4, which also has a scheme for having
           something that's called just leave it to the skill of
           the trades?  And why are all those thresholds
           articulated in a different way, all in different
           places?  And this is an endeavor to say as we're
           becoming more risk informed, we need to bring all of
           these things we've put out in the last three or four
           years together, and start using the same thresholds if
           they're, in fact, supposed to represent the same
           safety level of action or inaction.  And we would see
            - the first picture I showed you is actually fitting
           in, is kind of being the common risk informed
           objectives that would fit into this kind of central
                       It does mean going back and looking at how
           we articulated some other things in the past.  For
           example, on A-4, because the way we did it might not
           have been the right way.  We might be more informed by
           some of the things we're doing in Option Two right
           now, is we do need to bring these things together, and
           a central set of objectives is one way applying it
           across the board to do that.  Creating those
           objectives, I recognize, is going to be difficult
           because defense in depth is a balance.  How do you
           consider uncertainty?  But I need a structure to
           answer those question  - to even ask those questions,
           and I'd like to have a structure I can put the
           questions in, so that when I get the answers, I know
           how they fit together.  And that's what we're trying. 
           I just thought I'd put this on the table as  - it's a
           little different.
                       MR. MAGRUDER:  I'm sure we'll talk a lot
           about this, but we need to turn over to Lawrence.
                       CHAIRMAN APOSTOLAKIS:  I don't know for
           how long. 
                      MR. KOKAJKO:  I can do it very quickly.  My
           name is Lawrence Kokajko.  I'm the Section Chief of
           the Risk Task Group in the Office of Nuclear Material
           Safety and Safeguards.  I have not appeared before the
           ACRS before, but I have appeared before the ACRS/ACNW
           Risk Sub-Committee, and so some of what I'm going to
           talk about, they have already heard.
                       Just very briefly, NMSS through the RIRIP
           has embarked on a way to modify the regulatory
           framework across a spectrum of regulated activities,
           all the way from small seal sources devices, all the
           way through spent fuel, storage, transportation, fixed
           gauges, the gaseous diffusion plants, fuel fabrication
           facilities, and others.  It's not the homogenous group
           that NRR is.  And consequently, we have to be a little
           more creative in how we risk inform the regulatory
                       MEMBER ROSEN:  I'd say it's even less
           homogenous than the reactor safety arena.
                       MR. KOKAJKO:  Even less.
                       MEMBER ROSEN:  Yes.
                       MR. KOKAJKO:  We like to think we're the
           more interesting program in all this.  We have gone
           through conducting eight case studies recently.  We've
           developed some final screening considerations, and
           implementing guidance to help us to determine what is
           amenable for risk informing within the office.  We've
           initiated staff training like NRR has, and we're
           looking forward to training, perhaps  - having
           advanced training later on for the staff.  And we've
           completed a number of our activities in December.
                       We are now looking at implementing a Phase
           Two approach, where we're looking at what is amenable,
           and looking at cross-cutting measure.  I believe
           Margaret Federline has appeared before you some months
           ago, and she indicated that.
                       We are going to categorize any
           improvements through the PBPM process and prioritize
           them to see which ones are most effective.
                       CHAIRMAN APOSTOLAKIS:  Through what
                       MR. KOKAJKO:  PBPM, Planning, Budgeting,
           and Program Management Process.  It's the way to
           prioritize the  - what we should do next.  Although
           this work is ongoing, we will implement it in a Phase
           Three, there are things that are going on within NMSS
           right now, which we're taking advantage of.
                       A couple of things that we will  - that
           are being worked on is changing the inspection manual
           chapter for the fuel cycle facilities to be risk
           informed.  Also, for Uranium recovery we're doing the
           same thing.  Part 72 Geological and Seismological
           Siting Criteria in SFPO is  - will be risk informed. 
           It will also match what is going on in the reactor
                       CHAIRMAN APOSTOLAKIS:  In June you're
           going to issue another plan, version of the plan. 
                       MR. KOKAJKO:  Yes, sir.
                       CHAIRMAN APOSTOLAKIS:  And we will meet
                       MR. KOKAJKO:  I hope, yes.
                       CHAIRMAN APOSTOLAKIS:  So then we'll start
           with you.
                       MR. KOKAJKO:  Okay.  That would be fine. 
           Hopefully by June, we will have some other products
                       CHAIRMAN APOSTOLAKIS:  Good.
                       MR. KOKAJKO:  The other thing I'd like to
           say is we are working on developing draft safety goals
           with the Office of Nuclear Regulatory Research.  The
           Sub-Committee, we've presented the three-tiered
           approach, and I think it was received pretty well.
                       We'll also be going to PSAM in June, and
           we're looking forward to that.
                       CHAIRMAN APOSTOLAKIS:  You'll do what in
                       MR. KOKAJKO:  We're going to make about  -
           I think we're going to have about 12 presentations at
           PSAM in June.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. KOKAJKO:  That's it in a nutshell.
                       CHAIRMAN APOSTOLAKIS:  You choose good
           conferences to do it.
                       MEMBER ROSEN:  Well, it certainly was
           quick.  Right?
                       CHAIRMAN APOSTOLAKIS:  But no, we will
           have another occasion to discuss these things  - 
                       MEMBER ROSEN:  I think this is a very
           important area.
                       CHAIRMAN APOSTOLAKIS:   - in the next few
                       MEMBER ROSEN:  And we gave the full
           Committee, really a very short shrift of it, and I
           think it deserves a lot more discussion.
                       CHAIRMAN APOSTOLAKIS:  If we can only
           settle the issue of defense in depth, then everything
           will be going very quickly at these meetings.
                       MEMBER POWERS:  It'S very well settled. 
           We know what it is.
                       CHAIRMAN APOSTOLAKIS:  Dr. Shack.
                       MEMBER SHACK:  It's back to you.  I guess
           we're done.
                       CHAIRMAN APOSTOLAKIS:  Thank you very
           much, gentlemen.  We'll recess until 10:00.
                       (Off the record at 9:52 a.m.)
                       (On the record at 10:04 a.m.)
                       CHAIRMAN APOSTOLAKIS:  We're back in
           session.  Well, on behalf of the ACRS, I would like to
           welcome the Executive Director for Operation, Dr.
           Travers.  Director of the Office of Research, Ashok
           Thadani.  Director of the Office of  - 
                       MEMBER SHACK:  It says NMSS in there,
           doesn't it?
                       MR. COLLINS:  I got a promotion on way
                       CHAIRMAN APOSTOLAKIS:  Nuclear Reactor
           Regulation, Mr. Sam Collins.  And the Director of the
           Office of Nuclear Material Safety and Safeguards, Mr.
           Marty Virgilio.  We're looking forward to discussing
           items of mutual interest with EDO and the Office
           Directors, and I understand this is the first time
           that either committee has had such an opportunity to
           exchange ideas and thoughts on both ongoing and future
           high priority activities with the Directors.  I
           understand Dr. Garrick, Acting Chairman of the ACNW
           also has a few opening comments.
                       MR. GARRICK:  Thanks, George.  Good
           morning.  My name is John Garrick, the Acting Chairman
           of the ACNW.  The reason that I'm Acting is that
           neither our Chairman, George Hornberger, nor our Vice
           Chairman, Ray Wymer, could join us today.  They do
           send their regrets.  I am joined by the very able
           Committee Member, Milt Levenson, and he will  - he and
           I will have to do the best we can to represent the
                       I would like to add my welcome to that of
           Dr. Apostolakis.  This happens to be an extremely
           timely event, because the ACNW will be holding its
           retreat, its planning activity later this month, and 
           one of our goals is to select a limited number of high
           priority issues for the Committee to concentrate on
           the next year, and beyond.  And these presentations,
           I'm sure, are going to be very helpful in that whole
           selection process, to ensure that the Committee and
           the NRC Staff share the same high priority issues, so
           we look forward to that very much.  Thank you.
                       CHAIRMAN APOSTOLAKIS:  Bill.
                       MR. TRAVERS:  Thank you very much.  Mr.
           Chairman, a limited number of high priority issues is
           a goal we have.  We haven't managed to get to that
           point yet, but we do appreciate the opportunity to be
           here before both committees.  There was a time in
           NRC/AEC history when we used to report to a joint
           committee of Congress, and some look forward, or look
           fondly on those days, but we are certainly happy to be
           here today with you to talk about some of our current
           issues, some of the issues that you've been
           addressing, and have a discussion, a dialogue on some
           of the activities that we see, and perhaps you see
           going forward.
                       Each of the Office Directors with me
           today, and I should mention that Bill Kane and Carl
           Paperiello, my Deputies, are here as well, are looking
           forward to a dialogue.  We have a presentation.  I'd
           like to make just a few brief comments at the outset,
           and leave plenty of time for the dialogue to following
           after the presentations.  
                       I have to tell you that we are in the
           midst of an awfully dynamic time.  I think you
           recognize that.  It's, in my estimation, probably one
           of the most dynamic periods in NRC history. 
           Certainly, we've had some of those in the past, after
           Three Mile Island, and at other times.  But if you
           look across the spectrum of activities that we are
           involved in, and certainly you are involved in in your
           role, it is a daunting scope, and we are anxious to
           continue to make progress in many areas.
                       Let me begin by just touching on some of
           the areas where I think we have been particularly
           benefitted by activities of both the ACRS and the
           ACNW, and just touch on a few of those.  I think we'll
           probably touch on some of these in the presentations
           to follow, as well.  
                       Certainly, in the area of advanced or
           future reactors, ACRS has been significantly involved,
           and we've been the beneficiary of some of your
           thinking in that regard.  The ACRS workshop in June of
           2001 on the regulatory challenges for future reactor
           design was helpful.  I've seen Dr. Powers' report
           recently on the PBMR, which raised a number of issues
           that I'm sure will be of interest as we likely get
           into further reviews on that reactor design.
                       There have been  - there has been
           participation by at least a member or two on the
           research sponsored workshop on the high temperature
           gas cooled reactor safety and research issues in
           October of last year.  In the area of core power
           uprates, the ACRS has been a contributor in our review
           of license amendment requests.  And we'd like to note
           that your positive support for the reactor fuel
           confirmatory research program is helpful, as well.
           As I said, I'm going to mention just a few topics. 
           There are many more.
                       Turning to ACNW  - 
                       MEMBER POWERS:  Well, before you advance,
           could you touch upon those where you think the advice
           from the Committee was of limited help?
                       MR. TRAVERS:  That's an interesting
           challenge.  We like to take all  - 
                       MEMBER POWERS:  I know you want to put a
           positive spin on it  - 
                       MR. TRAVERS:  That's right.
                       MEMBER POWERS:   - but, I mean, telling us
           what we've done good, it's nice and we appreciate it. 
           But we're not going to get better if you don't bring
           to our attention the things that haven't been helpful.
                       MR. TRAVERS:  Well, let me propose that I
           start with where we've gotten good things.
                       MEMBER POWERS:  Okay.
                       MR. TRAVERS:  And perhaps the more
           appropriate place to go further than that would be in
           the discussion that follows, if that's acceptable.
                       CHAIRMAN APOSTOLAKIS:  If, of course,
           there are any.
                       MR. TRAVERS:  In the area of  - let me
           continue positively, if I may.  In the area of license
           renewal, the ACRS has been involved in the review of
           the generic documents that have been produced,
           including the Sandia Review Plan, in our efforts to
           institutionalize some of the lessons learned in the
           generic age and lessons learned document.  
                       I was going to mention in the ACNW's case,
           a number of positive interactions have occurred as
           well, including the input on the Draft Policy
           Statement on Decommissioning Criteria for the West
           Valley Demonstration Project.  This has really helped
           us in our sense to identify areas where clarifications
           that should have been made, were made.  
                       We've had interactions, as well, with ACNW
           on the development of the Decommissioning Standard
           Review Plan.  We think those have been particularly
           productive.  And I'd have to comment on our very
           positive view of the recommendations that ACRS made,
           and ACNW made separately, on the safety and waste
           research plans in the Office of Research.
                       As you know, we largely agreed with the
           key recommendations in those reports.  And, in fact,
           we've incorporated many of the ACRS' recommendations
           into our planning and budget process for the outlying
                       One thing that I personally would like to
           thank you for, and in concluding my opening statement
           is, your efforts at my request to look at a differing
           professional opinion, a rather complex one that had
           been under review for quite some time, we took the
           rather unusual step of asking the Committee if they
           would act as a technical review of this issue.
                       We take these issues that are raised by
           our staff very, very seriously.  And we think that the
           effort that you put into the review of those technical
           issues was very well done, and has helped not only put
           some closure to that issue, but identify a path in
           some activities moving forward to help further assure
           ourselves with confidence that we have, in fact, those
           steam generator issues well covered.
                       MEMBER POWERS:  Let me interject.  You're
            - just to remind everyone that the only reason it was
           possible for the ACRS to arrive at any conclusion in
           that area was the fact that your staff and the
           differing professional opinion authors could provide
           such effective support, and effective presentations,
           forthright, frank, complete description of their
           various technical opinions, in a very clear fashion. 
           When we get that kind of support from your staff, I
           think the Committee is far more effective, than if we
           have to delve into things, and try to find them for
           ourselves.  We're not very good at that.
                       MR. TRAVERS:  I should ask you for areas
           where we haven't done well, but perhaps we could take
           that up  - 
                       MEMBER POWERS:  Well, we'll go into a
           couple of them by day's over.
                       MR. TRAVERS:  Well, I think the last thing
           I'll mention in terms of our interactions with ACNW,
           and certainly things we see moving forward, are the
           interactions that relate to our identification of the
           key technical issues in the Yucca Mountain project. 
           I know the Commission has asked for some insight from 
           ACNW on these issues.  WE're happy to work with you on
           a roll-up of those things, a discussion of the
           significance of the various items that are on that
           list, and talk about a path moving forward.
                       So with that sort of brief and positive
           beginning, why don't I turn to Marty Virgilio, who is
           going to begin a presentation that we have planned in
           each of the program offices.  Marty is going to talk
           about, obviously, NMSS programs.  Ashok is going to
           talk about research, and Sam will, aside from what it
           says on his placque, he will talk about the Office of
           Nuclear Reactor Regulation.  Marty.
                       MR. VIRGILIO:  Good.  Thank you, Bill. 
                       Good morning, and thank you all for this
           opportunity to meet with you today to discuss some of
           NMSS' current and ongoing activities that we consider
           of high priority, and the ones that we value your
           input on, continuous dialogue and advice.
                       There are a number of high priority issues
           for NMSS that we'll be discussing with you today. 
           Many of these issues represent what we consider
           technical resolutions to first of a kind applications
           for radioactive waste transportation and storage, and
                       New standards are being developed around
           these issues, with what I consider worldwide interest. 
           Compliance with these new standards are being
           demonstrated for the most part through modeling, with
           assumptions where we lack empirical data.  That makes
           it rather challenging for all of us, I think.  And
           there's a high degree of public interest in all of
           these activities.
                       MEMBER POWERS:  Actually, that easy to do
           it. If you've got no data, and you just have to live
           on assumptions, those kinds of models are great to
                       MR. VIRGILIO:  Difficult to defend.
                       MEMBER POWERS:  Difficult to defend.
                       MR. VIRGILIO:  Right.  We acknowledge that
           you've already provided us good advice in a number of
           areas involving high level waste, as Bill alluded to
           in his opening remarks, particularly on the KTIs.  And
           we appreciate your continued feedback to us on the
           total system performance assessments, and some of the
           issues that we're dealing with there.  And we just
           recently got a memo from you dated January 17th on
           this topic.
                       In the interest of time, I want to focus
           on just a few of the current and future issues that I
           see as the most significant, so if we could have slide
           two, please.
                       Today, these represent the four issues
           that I want to spend my time on, your time on.  These
           are activities in the nuclear waste safety arena, and
           related programs that we believe will require
           continued ongoing discussion and consultation with,
           between the NMSS Staff and the ACRS and ACNW.
                       The first pertains to high level waste and
           repository issues, particularly the resolution of the
           KTIs, and subsequent performance confirmation. 
           There's ongoing and increased interest in this area
           involving waste package, transportation safety issues,
           and our reviews in this area, and some of the other
           studies that are planned and ongoing, and I'll touch
           on them.
                       The second activity involves
           decommissioning and site cleanup issues, as well as
           technical issues related to demonstration of
           compliance with the license termination rule.
                       The third activity pertains to
           enhancements of NMSS' risk informed approaches.  And
           the fourth area includes anticipatory and confirmatory
           research areas in the waste arena.
                       There's this over arching need that I just
           want to make sure that you're sensitive to within
           NMSS, that we continue to make continuous improvements
           to our program, that we continue to challenge
           ourselves to seek most efficient and effective
           solutions to the problems that face us.  And I just
           want to make sure that you're as sensitive to that as
           we are.  If I can have slide three, please.
                       DOE now has officially announced its
           intent to recommend Yucca Mountain to the President,
           and so now we continue to prepare for the license
           application in light of that announcement.  There are
           a number of important activities underway today with
           the staff, and you have interacted with us on several
           of these.  First, the key technical issues.
                       The focus of the key technical issues and
           related agreements, when I think of those together, is
           to make sure that when we finish that, we have
           provided DOE guidance on the information they need to
           submit a sufficient license application.  The scope
           and level of detail is based on what would be needed
           to provide the requisite confidence regarding
           demonstration of compliance with 10CFR Part 63. 
                       The performance assessment approach which
           is embodied in the Yucca Mountain Review Plan has been
           used to derive the risk insights for prioritizing and
           integrating these key technical issues.  The key
           technical issues themselves add a varying complexity.
                       While DOE must satisfactorily address the
           KTIs to prepare a sufficient license application, it
           must take into account the risk significance in
           defining the scope of its response on each of these
                       The relative importance of these key
           technical issues and related agreements may be
           qualitatively assessed using a combination of factors,
           such as the risk significance of the associated
           structures, systems and components, and the processes,
           the number and complexity of the agreements associated
           with each of the KTIs, and of course, stakeholder
           issues and concerns, as well.
                       The agreements that we've reached with  -
           between NRC and DOE in the pre-licensing application
           process are based on extensive staff review of DOE's
           technical case, and subsequent identification of gaps
           in DOE's supporting information.  So our future
           technical meetings with Doe will continue to focus on
           these gaps and provide strategies and answers that
           will help close each of these gaps.
                       MEMBER POWERS:  You guys prepared and
           developed a program of, I hesitate to call it, so much
           research as technical investigations let's call it,
           because I think it was a mixture of research and
           technical support, around a set of what you call KTIs,
           Key Technical Issues.  And I think the Committee wrote
           a report some time back, saying gee, what a great idea
           this is, and how useful this is.  They very much liked
           it.  Is that kind of an approach still going on?  I
           mean, do those KTIs evolve, or they  - they're the
           ones that you set up a long time ago, and you see no
           reason to change them?
                       MR. VIRGILIO:  The KTIs have not evolved. 
           What I think are some of the sub-issues, and how we
           are focusing on the sub-issues that I think have
           evolved is we've gained more information and more
           insights about the site.  So if you look at the ten
           KTIs, or nine technical plus the performance
           assessment, they have held constant for the  - you
           know, for as long as I've been associated with the
           program.  But what has evolved is our thinking around
           some of the sub-issues.
                       MEMBER POWERS:  Uh-huh.  
                       MR. VIRGILIO:  While the titles haven't
           changed, I think the way we've looked at them, the
           scope and depth, the amount of energy we've put in
           them has changed based on our assessment of their
           significance, and how that's changed as we've gotten
           more information, as we've worked through these
                       MEMBER POWERS:  Have you thought about
           applying that kind of an approach to things like the
           transportation issues?  I mean, many of our
           transportation regulations and approaches for safety
           in transportation are fairly geriatric, and people are
           interested in perhaps upgrading those.  Have you
           thought about applying that in that same area?
                       MR. VIRGILIO:  No, I think we're going to
           approach that from a different perspective.  What I'd
           like to do there is take a more risk informed
           approach, instead of setting out at the front end
           saying that there are this set of a dozen particular
           issues that I want to focus on.
                       What we're working cooperatively with
           research today, is to get more insights around
           storage, dry cast storage, and working on
           transportation issues as well, in a more risk informed
           approach right from the beginning, and focus our
           attention based on what the risk information is
           telling us.  Where we have large uncertainties, for
           example.  Well, overall the system might not be posing
           a large risk, the value of doing these kinds of
           assessments is to tell you where you've got large
           uncertainties, where you've got margins that you might
           be able to focus on, and where you've got maybe small
           margins  - 
                       MEMBER POWERS:  So instead of KTIs, you'll
           have LUIs, Large Uncertainty Issues and things like
                       MR. VIRGILIO:  I don't know  - 
                       MR. THADANI:  Then I will touch on this
           issue  - 
                       MEMBER POWERS:  Good.
                       MR. THADANI:   - when I brief you about
           what we're doing, and it's really basically along the
           lines of what Marty is saying.  And one of my issues
           is going to be, this is an area where we're going to
           interact with you, and make sure that if there are any
           issues we're not considering, that we have the benefit
           of your thoughts on that.
                       MEMBER POWERS:  Well, the  - I just
           comment that the KTI approach, since I have limited
           overlap with the issues of Yucca Mountain, was an
           extremely effective way, I think, of persuading me
           where the research needed to be done, because it had
           been  - it was systematic and whatnot.  Doing it with
           risk I think is no less systematic, and maybe more
           justifiable, but the articulation of these things was
           just a very effective  - 
                       MR. THADANI:  Since you're on this issue,
           the approach we are using, of course, is phenomena
           identification ranking table type of an approach, so
           I think it's fairly systematic.
                       MEMBER POWERS:  Yeah.  I mean, a similar
           sort of thing.
                       MR. THADANI:  Yeah.
                       MEMBER POWERS:  Yeah.  That  - I have to
           say that that  - your staff has been effective in
           taking a concept focused largely in thermal
           hydraulics, and seeing how they can apply it in other
                       MR. THADANI:  Yes.
                       MEMBER POWERS:  And it's very impressive. 
           I mean, that  - I think when people ask is there
           creativity in the NRC Research Program, that's one of
           the areas I'd point to.
                       MR. TRAVERS:  I just have to comment on
           one thing mentioned, and one part of your statement
           indicated that there are those who would like to see
           changes in those requirements, and some would like to
           see risk informing.  There are others, however, who
           really aren't looking for change in the regulatory
           scheme, so sometimes there's a balancing of what we're
           doing in the context of stakeholder interest on the
           part of the industry.
                       MEMBER POWERS:  Making that judgment is
           why you get the big bucks, sir.
                       MR. TRAVERS:  It's a balancing act at
                       MR. VIRGILIO:  Just to close on the KTIs,
           I wanted to recognize that there's international data
           and experience that we're trying to draw on as we work
           forward on the high level waste repository issues.  I
           believe that the NRC Staff and the Committee, as well,
           needs to utilize the experience gained by the Finns
           and the Swedes to the maximum extent possible, so not
           only leveraging our dollars, but also leveraging our
           decision making, and I think it has an opportunity to
           enhance public confidence, as well.
                       That's really all I wanted to say about
           that issue.  If we could move on to slide five,
           please.  There's been increased national attention on
           spent fuel transportation and storage issues.  These
           have been stimulated by the Baltimore Tunnel fire.
                       CHAIRMAN APOSTOLAKIS:  Why did you skip
                       MR. VIRGILIO:  Oh, I'm sorry.  I think I
           covered it.  It was all covered in my notes.  I'm
           sorry if  - 
                       CHAIRMAN APOSTOLAKIS:  Well, I've got a
           question on the fourth. 
                       MR. VIRGILIO:  Sure.
                       CHAIRMAN APOSTOLAKIS:  Can we go back to
                       MR. VIRGILIO:  Yes, please.
                       CHAIRMAN APOSTOLAKIS:  This issue of
           uncertainty and realistic assessment and all that
           stuff, I'm pretty sure you have significant model
           uncertainties in the performance assessment, and we do
           also in reactors.  Now the way we are handling them to
           the extent that they can be handled is using defense
           in depth.  How do you guys do it?
                       MR. VIRGILIO:  We also use the defense in
           depth  - 
                       CHAIRMAN APOSTOLAKIS:  Is that defense in
           depth, really?
                       MR. VIRGILIO:   - approach for the
           repository.  That is part of the process.
                       CHAIRMAN APOSTOLAKIS:  Multiple barriers,
           and that's it?
                       MR. VIRGILIO:  Multiple  - yeah, an
           approach that looks at multiple barriers, that looks
           at the fuel, the waste package, and it also then takes
           into consideration the repository, the transport. 
           Each of those provide a certain measure of defense in
           the process.
                       CHAIRMAN APOSTOLAKIS:  And people compound
           this  - 
                       MEMBER POWERS:  It's a good approach,
                       CHAIRMAN APOSTOLAKIS:  Huh?
                       MEMBER POWERS:  It's a good approach,
           defense in depth.
                       CHAIRMAN APOSTOLAKIS:  Well, I'm not so
           sure.  I think it's a very different application of
           defense in depth in barriers.
                       MR. VIRGILIO:  Yes, it is.  We've written
           several papers on it that we'd be happy to share with
           you, if you  - 
                       MEMBER KRESS:  The only variable you have
           access to there in terms of what you can do is the
           cask.  I mean, you've got the fuel.  It's already put
           into some sort of form.  You've got the repository
           external, so the defense in depth you have access to
           is what you  - how you design the cask.  Now my
           question is, how do you know how good of a cask you
           define to get the appropriate defense in depth you
                       MR. VIRGILIO:  It is not limited alone to
           the cask.  I think you have to look at the entire
           system.  I think there are things that you can do with
           regard to how you store the waste, how you back fill
           behind the waste.  There are a number of variables
           that you have in addition to the natural barriers that
           are provided.  Am I sorry.  Your question then was?
                       MEMBER KRESS:  My question was how do you
           know when you've got enough of that, including those
           other things?
                       MR. VIRGILIO:  Through tests and through
                       MEMBER KRESS:  You have a criteria for how
           much change in some risk measure that you want this
           cask to give you?
                       MR. VIRGILIO:  You can do sensitivity
           analysis, and you can do modeling in terms of  - you
           know, what would be the affect of you decrease the
           performance of the cask, for example.  Take the
           package, and so you make some assumptions about how
           well it's going to perform.  You can model and
           decrease, you know, the performance around a
           particular element.
                       MEMBER KRESS:  The performance is measured
           by some release somewhere, or some contamination  - 
                       MR. VIRGILIO:  By the standards that have
           been established and incorporated in our rules.  The
           standards are established by EPA.  DOE brings forward
           the license application.  NRC assesses that
           application, so there are a number of federal agencies
           involved in this.  But EPA has set the standards that
           really are looking at what the affect might be on some
           hypothetical resident in the vicinity of the facility.
                       MEMBER KRESS:  So you do sensitivity
           analysis to  - 
                       MR. VIRGILIO:  Yes, in part to understand
           the contribution and affect.
                       MEMBER KRESS:  Contribution, and do you
           know  - when you do a sensitivity analysis do you -
           what?  Put some parameters at their 95 percentile
           values or something like that?
                       MR. VIRGILIO:  And vary them?  Yeah.
                       MEMBER KRESS:  Vary them.
                       MR. VIRGILIO:  As to what degree of
           performance you're getting, for example, out of the
           cask, or out of the package.
                       MEMBER KRESS:  Okay.
                       MEMBER ROSEN:  On your third bullet, how
           relevant is that experience to the plans at Yucca
           Mountain.  In the reactor safety area we update PRAs
           with relevant experience from many thousand years of
           reactor experience.  Is there analogous value to that
           data that you're getting out of others experience in
           repository performance?
                       MR. VIRGILIO:  I think that it's coming in
           now in terms of what we're getting from the Finns and
           the Swedes, and I think that we'll see more from WIPP
           as we get more involved in what DOE has done, so there
           is some experience.  But we rely heavily on the
                       CHAIRMAN APOSTOLAKIS:  What is consistency
           in treatment of uncertainties?
                       MR. VIRGILIO:  One of the things that we
           want to make sure that we're doing is in approaching
           the KTIs in a somewhat consistent manner, in terms of
           not having more conservatism in one, and less in
           another, for some of the same factors.  It's a
           reconciliation of how we're approaching this.
                       Try to put everybody on the same playing
           field, where we can.  That's  - I think it's a very
           important factor that we don't unnecessarily treat or
           use conservatisms around certain assumptions, which in
           your last letter to us, I think the over arching issue
           there was, because it can bias the results.  And I
           think that's very appropriate guidance.
                       MR. GARRICK:  I think one thing that might
           be important to Tom Kress' question is the very
           different situation that exists with respect to the
           activity called site characterization, very different
           from the reactor problem.
                       The site characterization program is
           designed to really deal with the question of how much
           protection are we getting from the natural setting,
           and so that's a component of the defense in depth.
                       MEMBER KRESS:  It seems like it's a highly
           uncertain  - 
                       MR. GARRICK:  It is a highly uncertain,
           but on the other hand, if you look at the work that's
           going on, that's where most of the work is taking
           place, is in better understanding the performance of
           the natural setting.  There's a lot of emphasis on the
           waste package, and that is very much an engineering
           effort, but the activity associated with the site
           characterization is very involved, and very extensive,
           and has been going on for many years, and there have
           been many lessons learned.  And one of the lessons
           that probably is the most important from that whole
           process is that it is very difficult to quantify the
           uncertainties associated with the performance of the
           natural setting.  But I think that in general, they
           have learned along the way what is more important, and
           are focusing on those barriers, and those parts of the
           natural setting that are going to have the greatest
           impact on performance, such as how water moves through
           the mountain.  And so I think that, to pick up on
           Marty's response, that it comes from both places, it's
           clearly correct, that there needs to be a component of
           defense in depth with respect to the engineer portion,
           which is primary what is called the near field, and
           primarily what is called the waste package.  And there
           needs to be an expose of the ability of the natural
           setting to provide backup when and how a source term
           is actually developed.  When you see the billions of
           dollars that are spent, most of it is spent in just
           trying to go as far in the direction as reasonable, to
           quantify the geological setting.
                       MR. VIRGILIO:  Okay.  If we can then move
           on to slide five.  Okay.  There's been increased
           national attention on spent fuel transportation.  And
           as I said earlier, this has been stimulated by the
           Baltimore Tunnel fire, the terrorist acts of September
           11th, and other things, including DOE's announcement
           of Yucca Mountain.  Staff is, and will continue to
           seek the ACNW's views and guidance on critical safety
           issues pertaining to spent fuel transportation issues.
                       The staff itself has been engaged in
           review of spent fuel transportation packages, and the
           performance of spent fuel transportation packages in
           severe design basis accidents, beyond design basis
           accidents, what we call the package performance study. 
           And we've been working very cooperatively with
           research in this area. 
                       We've developed a test plan that will be
           issued in the near future for comment.  In addition,
           the Staff is also going to be involved in activities
           to validate the structural computer models that we use
           in risk assessment around transportation of spent
                       We've also recognized at the National
           Academy, The National Research Council Board of
           Radioactive Waste Management, will begin a broad
           transportation based study focused on spent fuel
           issues.  This study is going to start in April of this
           year, and Staff will solicit the Committee's comments
           on the study.
                       NRC may also conduct additional
           transportation vulnerability studies in response to
           the terrorist attack of September 11th, and our
           proposals are currently before the Commission in that
                       MR. LEVENSON:  I have a question on
           transportation.  You've listed it under high level
           waste.  What about other  - at the moment, the big
           transportation process going on is stuff going to
           WIPP.  It turns out that in many cases, it isn't the
           NRC licensed cask that's controlling much of anything,
           but DOT regulations.  What's  - do we have the same
           fuzzy area with high level waste?
                       MR. VIRGILIO:  No, that  - I don't  -
           well, first of all, I don't think it's very fuzzy at
           all. I think that the roles and responsibilities
           around transportation of waste in this country are
           fairly clear with regard to NRC's responsibilities,
           Department of Transportation's responsibilities.
                       With regard to high level waste, this is,
           you know, NRC and DOE responsibilities.  This is not
           going to involve the Department of Transportation, to
           the same extent that you see for low level waste, and
           for other materials that are being transported around
           the country today.  They still have some
           responsibilities associated with the conveyance, be it
           the truck or the rail conveyance, but there's a lot
           more NRC requirements, if you will, around high level
           waste transportation.
                       That's changing though.  I will recognize
           that there's a lot of change going on today around
           transportation of low level radioactive waste as well. 
           We're working cooperatively with the Department of
           Transportation, Customs, and other organizations to
           make sure that we understand and refine all the
           different levels of protection, if you will, around
           transportation packages.  That's, in part, being
           stimulated by our response to the terrorist attack.
                       MR. LEVENSON:  Is there some regulation,
           or rule, or law that decreases the role of DOT for
           high level waste, compared to the waste going to WIPP?
                       MR. VIRGILIO:  I'd have to get back to you
           on that.  I'm  - 
                       MR. LEVENSON:  Because the issues  - I
           mean, the shipping container for WIPP is licensed by
           NRC.  It's an NRC DOE and that's fine, but DOT has all
           kinds of miscellaneous requirements arising from the
           conveyance, which is  - I just spent the last two days
           in an Academy meeting on WIPP.  And the controlling
           thing resulting in maybe hundreds of millions of
           dollars per year additional expenditure rises from
           requirements of DOT, not NRC.  
                       MR. TRAVERS:  DOT will still have those
           conveyance requirements, as applicable to high level
           waste as they are to the WIPP shipments.  I think what
           we were trying to convey was that in the context of
           the detailed reviews that are going to be conducted
           associated with high level waste transportation,
           they're more rigorous.
                       Certainly, we went through a certification
           process for the cask or the  - is that what it's
           called at WIPP?  And I guess I'm not familiar with the
           specific DOT issues that may be limiting, or causing
           greater expense in connection with WIPP, but we think,
           when it comes to high level waste, it's much more
           likely that the reviews and the technical requirements
           of NRC are likely to dominate, if you will, versus
           some of the safety conveyance requirements of DOT. 
           They're going to be applicable.  DOT still has a
           principal, primary role in transportation throughout
           the country of anything that involves hazardous waste
                       MR. LEVENSON:  Who is responsible, or is
           anybody, for looking at that interface, because I know
           I've seen what the problem has arisen at WIPP, that
           there's some DOT requirements  - right now, the big
           issue is because remote handled waste going to WIPP
           can't necessarily be handled and looked at.  You can't
           necessarily meet the DOT requirements, and with spent
           fuel, you're going to have that in spades.
                       MR. TRAVERS:  Yeah.  If you look at what
           historically has been the case, we've actually shipped
           high level waste around in this country.  Not that
           much, but it's happened over the years.  And am I
           saying there won't be issues associated with a much
           larger project?  I'm not, but I think we have fair
           experience in the interaction of NRC requirements and
           DOT requirements as they apply to high level waste
           shipments in the country.
                       I don't know if any are actively going on
           right now, but they have over the years.
                       MR. VIRGILIO:  There are a handful per
           year, moving fuel from one facility to another right
           now, so we do have some limited experience. 
                       MR. TRAVERS:  But it's a good issue, and
           I think it's one when you envision a much larger
           expansive project, that is worthy of consideration,
           and we'll take that as a challenge.
                       MR. VIRGILIO:  Any other questions?  If we
           can move on to slide six.  In the area of
           decommissioning, NMSS Staff is currently evaluating
           activities and looking for ways to further risk inform
           our technical reviews.  Here's an area where we
           believe that the ACNW input and guidance has been and
           will continue to be helpful.
                       We're currently working on a consolidated
           decommissioning guidance project, where we'll update,
           and risk inform, and improve our technical reviews. 
           The consolidated guidance project is a three volume
           set covering decommissioning process, characterization
           surveys, and radiological criteria, financial
           assurance, recordkeeping, and timeliness of our
                       The ACNW review of the consolidated
           guidance will help ensure that we achieve a clear,
           complete, and comprehensive set of guidance.  The
           first volume of this three volume set has just been
                       Staff is also actively engaged in
           evaluating options for long term stewardship for
           decommissioned sites, and financial issues pertaining
           to cleanup activities, and will be continuing to
           interact with the Committee on those issues.
                       Dose modeling for complex sites, and
           consistencies, and conceptual models, as well as the
           selection of parameters, and probabalistic dose
           analysis are being addressed today in collaboration
           with other federal agencies.
                       Important issues here are being addressed
           as well involving partial site releases and
           radionuclide transport and pathways.  We'll continue
           to interact with the Committee around some of these
           issues.  If I could move to slide seven.
                       CHAIRMAN APOSTOLAKIS:  Now you mentioned
           long term stewardship of decommission site.  How long
           is long term?
                       MR. VIRGILIO:  For hundreds of years, as
           a matter of fact  - 
                       CHAIRMAN APOSTOLAKIS:  Wow.
                       MR. VIRGILIO:   - for some of the sites
           that we have, some of the complex decommissioning
           sites that we're looking at.  We're  - right now we're
           looking at Department of Energy for taking some of
           these sites.  However, there are other options being
           considered for some of the sites.  We're looking at
           states for some of the sites.  We're looking at Tribal
           Governments.  We're looking at a number of options in
           terms of ensuring enduring institutional controls, and
           forcible institutional controls, responsibility for
           the long term care and protection of these sites.
                       CHAIRMAN APOSTOLAKIS:  Interesting.  
                       MR. VIRGILIO:  It's a very significant
           issue for us today.
                       CHAIRMAN APOSTOLAKIS:  I know it's a
           significant issue for DOE, for their side.  I didn't
           realize it was significant for you, as well.
                       MR. VIRGILIO:  Yes.  And we're working
           with DOE and the states, and the Tribal Governments to
           try to find a success path around some of these
                       CHAIRMAN APOSTOLAKIS:  So we're going to
           have again long time periods.  Right?
                       MR. VIRGILIO:  Possibly.  With, you know
            - yes, with institutional controls on some of these
           sites.  On slide seven, I just wanted to  - and I know
           we've met several times with the Joint Committee
           around risk informing the NMSS programs.  We are
           continuing to work to further risk inform our decision
           making.  We've briefed you in the past on this issue.
                       Today we're engaged in integration of case
           studies that were done, eight case studies, and I
           believe the staff has briefed you on this.  We're
           addressing lessons learned and exploring applying a
           risk informed approach to other activities within
                       One of the most significant tasks that
           we're working on today is to develop risk metrics and
           safety goals appropriate for the materials and waste
           arena activities.  We see this as very challenging,
           but we've been collaborating with the Joint Committee
           around these issues, and will continue to work with
           you as we move forward.
                       MEMBER POWERS:  When you speak of risk
           metrics, could you clarify what you mean by that?
                       MR. VIRGILIO:  Some of that is somewhat
           preliminary at this time, but  - 
                       MEMBER POWERS:  Well, just give me the
           analogy to reactor world that you're  - 
                       MR. VIRGILIO:  If you look at the safety
           goals at the fairly high level for reactors, those are
           some of the same things we're looking at in terms of
           societal risk, individual risk, those type of measures
           in metrics.
                       MEMBER POWERS:  Yeah, I know what you mean
           now.  I'm looking at things like risk achievement
           worth, or something like that.
                       MR. VIRGILIO:  Not to that level of detail
           or sophistication.
                       MEMBER POWERS:  I understand.
                       CHAIRMAN APOSTOLAKIS:  Let's say deep
                       MR. VIRGILIO:  Yes.
                       CHAIRMAN APOSTOLAKIS:  Period.
                       MEMBER ROSEN:  Useful detail.
                       MR. VIRGILIO:  We're also continuing with
           our training program to make sure that we're uniformly
           and consistently applying some of these risk informed
           decision making across NMSS.
                       The last slide I wanted to just touch on,
           confirmatory and anticipatory research.  And I met
           with the Committee before on this, and so has
           Margaret.  If you think about high level waste, Sub-
           Part F of Part 63 requires DOE to submit a performance
           confirmation plan as part of their application.
                       This plan should, in fact, lay out a
           program that identifies some of the key assumptions
           for the overall site performance assessment.  The plan
           will also take into account some risk insights, and
           develop new and continuous analysis, tests and
           experiments that probe and challenge the assumptions
           and technical basis for the licensing case.
                       Anticipatory  - and we'll continue to work
           on that issue.  As far as the anticipatory research,
           I think we need to consider what could be needed in
           the future, and most importantly, prioritize what
           should be done, prioritizing the funding for
           anticipatory research needs to integrate external
           stakeholder input, the ACNW/ACRS recommendations, and
           NMSS views, and of course, researches, technical
           insights and planning.  
                       Margaret Federline and I have both
           discussed this issue with the ACNW in the past, and we
           look forward to further discussion around these
                       IN closing, I just welcome your continued
           contributions and guidance to the Staff.  Your
           critical review contributes to ensuring public health
           and safety, and enhancing public confidence in the
           NRC, so we appreciate your continued interactions. 
           And I thank you for the opportunity to meet with you
                       MR. TRAVERS:  Sam, we're going to continue
           with your presentation, if that's all right.
                       MR. COLLINS:  Very good.  Good morning. 
           I'm Sam Collins.  I'm the Director of the Office of
           Nuclear Reactor Regulation.  I believe I've had the
           opportunity in various capacities to speak to you as
           individuals.  I'd like to welcome Steve Rosen.  Steve
           and I have worked at a couple of forums together, the
           most recently being South Texas.  And I think it's an
           indication of your stage in career when you have been
           at least two places working with one person through
           your various stages, but it does lend perspective. 
           And I think on Steve's part, I never really envisioned
           you to be a government employee, but I welcome you.
                       MEMBER ROSEN:  Thank you very much, Sam. 
           I'm a special government employee.
                       MR. LEVENSON:  Special means no benefits.
                       MEMBER ROSEN:  That's exactly one of the
           things it means.
                       MR. COLLINS:  What I hope to accomplish in
           the next period of presentation and questions, is to
           provide a broad overview of some of the areas within
           the purview of the Office of Nuclear Reactor
           Regulation that are of interest to the Committees.
                       We have a very large span of control in
           the Office of Nuclear Reactor Regulation, most of them
           being programmatic, so our processes are areas that we
           focus on, as well as the technical decision making
           within those processes.
                       In the past, the ACRS has been involved in
           both of those forums, and we do have continuing
           challenges to achieve success, as we define it.  And
           I will clarify some of those as I go through.
                       We appreciate the opportunity to continue
           what I would call constructive exchange.  And clearly,
           that means an exchange of views, in some cases
           differing views with perspectives taken into
           consideration, and we recognize that both our staffs
           play a key role in defining issues.
                       Here with me today I have members of the
           Executive and Leadership Team from the Office of
           Nuclear Reactor Regulation.  They're here not only to
           gain perspective from the presentations and the
           questions, but if necessary, to help support responses
           to your questions.  
                       I will address a number of cross-cutting
           issues today within the areas of presentation, and I'd
           like to acknowledge that the three offices here really
           work in partnership to address many of the agency's
           challenges.  We rely heavily on the technical
           expertise within the Office of Research to support the
           decision making with our programs, and Marty and I
           have cross-cutting arena areas in the area of
           decommissioning, and we're working on those program
           structures also to become more efficient and
           effective, and to align those processes between the
                       Let me go into the areas of interest, and
           begin by talking with technical specifications. 
           Technical specifications are probably the most
           important guidance that's provided to the facilities
           within the bounds of operation of the plants.  Those
           of you who have experience with testing research
           reactors in the power reactor community, understand
           that this is where the regulations are applied in the
           control room 24 hours a day, under varying conditions.
                       We do have guidance from the Commission. 
           It's one of the areas of challenge, to risk inform
           programs.  I think Ashok will be talking about that
           also.  Marty has mentioned it in his arena, and along
           with our efforts to standardize the technical
           specifications, we are embarking on a program to risk
           inform various areas of the technical specifications.
           This is one of our fundamental focuses now in
           improving that technical specification tool.
                       We do have risk informed decision making
           guidance, and Marty responded to a question of Dr.
           Apostolakis having to do with risk informed decision
           making.  And we have Reg Guide 1174, was developed in
           partnership primarily by the Office of Research, which
           does include a fairly prescriptive decision making
           process, although some of the inputs to those process
           might not be prescriptive, of how to consider the
           deterministic aspect, as well as the risk and the
           consequences in those variables to come to a good risk
           informed decision.  We've had some revisions to that
           process in the past, and I think it will continue to
           be refined as we apply the program itself.
                       In the area of technical specifications in
           that risk informed decision making process, we're
           really going to focus today on two areas that we
           believe the ACRS involvement will be important. 
           Although we have one proposal on missed surveillances
           that's been approved by the staff, and two others
           which are modified in state and mod change flexibility
           should be complete by the end of the summer.  There
           are two areas, one being configuration risk management
           for completion times, which would permit managed
           temporary extension of existing completion times
           within a limiting condition of operation, and that
           concept is currently under development.
                       The second being the risk significant
           scope for technical specifications, which would review
           tech specs to remove systems, are included solely
           because they were judged as risk significant at one
           time, and have now been shown by analysis not to be.
                       Those two initiatives under the eight
           total initiatives under risk informed tech specs will
           be provided to the Commission, as a part of our
           process, as major policy areas.  And we will  - 
                       CHAIRMAN APOSTOLAKIS:  What exactly is an
                       MR. COLLINS:   - be giving those to the
                       CHAIRMAN APOSTOLAKIS:  Sam, when you say
           initiative, what do you mean?  Do you mean the
           agencies doing this, or the industry has requested
           that something like this happen, and they are
           proposing something?
                       MR. COLLINS:  Right.  That's a good
           question.  We have been working with the industry and
           our stakeholders, primarily through NEI as leveraging
           the industry to provide the input to the areas that
           they believe the risk informed decision making could
           be applied.  We're focusing on eight of those areas. 
           This is being done in a stakeholder environment. 
           We're continuing to involve not only the industry
           through NEI, but the other stakeholders with public
           meetings on the progress of these initiatives.  And,
           of course, as changes to the tech specs, they would be
           subject to public comment.
                       In the process sense, we're using a new
           implementation, or a revised implementation process
           which provides for what we would call a pre-screened
           amendment review, in that we put out a template, and
           as the licensee meets that template, then they are
           automatically allowed to change their technical
           specifications, but that's on the process end.
                       CHAIRMAN APOSTOLAKIS:  So configuration of
           risk management for completion times, that means that
            - what, that something has failed, and I'm looking at
           the new configuration during my risk assessment.  And
           I decide that, you know, the risk would be acceptable
           if I completed repair or whatever is required by such
           and such time?
                       MR. COLLINS:  Yes.  I think you have
           captured it.  Right.
                       CHAIRMAN APOSTOLAKIS:  Now the  - you
           know, this creates an interesting problem.  It seems
           to me that PRA was done, as was done in the early 70s
           and the last 25, 30 years, was not really developed
           for this kind of thing.  It was developed for a study
           state long term kind of assessment, developing
           frequencies of core damage or accident sequences and
           so on.  And now we are rushing into applications for
           which the baseline risk information was not intended. 
           That doesn't mean that it's inappropriate, but that's
           not why it was developed in the first place.  And in
           particular, talking about time dependent situations  -
           I mean, I don't think PRA was really very good at
           that.  We are averaging too many things.  We are
           averaging the input of periodic tests, this and that. 
           Now when it comes to real time applications, I don't
           know that we really have thought about it very well. 
           And this is just one example where we're  - I think we
           are rushing into applications for which the original
           tool was not designed.
                       Now some  - that doesn't mean that, you
           know, it's useless.  Most of the information is there,
           but I think we need to really be careful, and pay
           attention to the fact that now it's a different
           application.  Now you've been trying to say something.
                       MR. THADANI:  I'll touch on  - 
                       CHAIRMAN APOSTOLAKIS:  Sam, yes.
                       MR. COLLINS:  I think your caution is
           appropriate.  However, I'm not sure rushing into it is
           the right connotation.  I think if we were to look at
           the history of the maintenance rule, which is really
           configuration management giving risk insights, that
           was a fairly deliberate process.  I would call it
           deliberate.  The industry would call it excruciating
           probably, and it's not that different, other than the
           conditions set by operational conditions, which would
           result in corrective maintenance, rather than the
           prescriptive  - the conditions that are pre-planned
           for corrective maintenance.  So the configuration is
           a little more tenuous, perhaps, and less able to be
           pre-planned, so the process is twisted that way.  But
           I do think that we have a history with the maintenance
           rule that would indicate that these tools are
           appropriate, but the input has to be correct.
                       MR. THADANI:  George, I understand the
           point you're making, and I recognize that time
           dependence is not built into today's PRAs, and so
           there are some limitations in what we have in front of
           us.  On the other hand, we have much better
           understanding of where the significant risks might be. 
           We have these tools, in spite of the imperfections and
           uncertainties in these analyses.  I think these tools
           are very valuable in bringing better discipline to the
           set of requirements that are embodied in the technical
           specifications.  Particularly, as you know, the tech
           specs were developed with the concept of one change at
           a time.  Reality is different than that, so
           configuration management, to the extent one can take
           advantage of the plant models, so to speak, I think is
           a step forward, is the right thing to do, as long as
           we're sensitive that there are some limitations in the
           tools that we're utilizing.  So it's progress, and we
           need to be looking at the issues of dynamic aspects as
           we go forward.  I think this is the right direction to
           go in, and not to wait until we finish everything.
                       CHAIRMAN APOSTOLAKIS:  I agree that it is
           the right direction.  It's just the availability of
           the appropriate tools that worries me.
                       MEMBER POWERS:  Well, I guess the question
           I'd ask is, do we even have the appropriate tools
           right now?  You've gotten -- the IPEEE insights
           document comes out.  It says gee, all these
           operational things that you guys are talking about,
           that's half the risk.  I mean, is it appropriate to do
           analyses of configuration management taking into
           account half the risk?
                       MR. THADANI:  I think the answer to that,
           in my view, is yes.  External initiators are going to
           look at, and the same way as you would internal
           initiators.  I think I can agree with you that half
           the risk may be from external initiators.   That does
           not mean that the components, and systems, and
           structures within the plant, you shouldn't look at
           from the best risk perspective you can get.  And the
           industry, I think to me that's progress.  Industry is
           making better use of IPEs and IPEEEs, and that mode. 
           I recognize the limitations.  You recognize the
           limitations.  I mean, the spectrum of these studies
           and analyses, but nevertheless, I mean is there
           something better we can use to risk inform various
                       MEMBER POWERS:  Well, let's make sure  - 
                       MR. THADANI:  I don't think there is.
                       MEMBER POWERS:   - we understand, that one
           of the external initiators you're talking about, it's
           actually an internal fire.
                       MR. THADANI:  Yes, I understand that.
                       MEMBER POWERS:  And it seems to me that we
           have  - I mean, the IPEEE insights document is a wake-
           up call that says you've got a problem when you're
           using the conventional PRA tool, that you're ignoring
           half the risk.  And I think there's no question if
           your current PRA tool comes back and says this
           component is important, or this configuration is
           important.  The answer is yeah, it is.  It's when it
           comes back and says well, you can live with this, that
           you have the question because of the incompleteness of
           your tools.
                       CHAIRMAN APOSTOLAKIS:  John, you wanted to
           say something.
                       MR. GARRICK:  Well, I just wanted to
           comment that I think that as far as this time
           dependent question is concerned, it's correct that
           most of the logic diagrams are static models.  But it
           is also important to note that a lot of the
           applications have been with respect to dynamic
           situations.  And the way that is often addressed is in
           the context of discretizing that dynamic situation in
           such a manner that you can assemble a set of so-called
           steady state or static models, in a manner that will
           represent a dynamic representation.
                       Examples of that, and where it's done more
           than in the reactor field, is in the chemical field
           when you're trying to do a risk assessment of a
           process, where you fundamentally divide that process
           up into a series of unit operations.  And you connect
           the individual unit operations with pinchpoints that
           logically and reasonably defensible.
                       The same thing is true with respect to
           developing a risk assessment of something like the
           space shuttle, where you map an entire mission.  And
           the way that's often been done is with some clever
           discretizing of the model, and defining of the input
           and output states, that do a reasonable job of
           representing what's going on.  So my only comment is
           that there's a great deal of ingenuity being applied
           to some of these models that goes beyond what we're
           having described here.
                       CHAIRMAN APOSTOLAKIS:  Yeah.  My concern
           was not so much how to handle time, because I agree
           with John, that discretizing has worked very well.  My
           concern with configuration management is when I change
           the configuration, and we saw that in the calculations
           of the risk achievement work, which actually does do
           some of that.  When I change the configuration, and I
           use now the new PRA, which is usually a variation of
           what I already have, am I doing it correctly?  Because
           if one component is down, or more than one component
           are down, several terms in the PRA are affected.  And
           some of them in a subtle way, and I'm not sure that we
           have  - I'm not saying we cannot do it.  I'm just
           saying we have not really thought about it very
           carefully, and  established rules how to do it and so
           on.  The time dependent part I agree with John with. 
                       In other words, don't misunderstand me. 
           I'm not saying we should go to the dynamic PRA that
           some groups are proposing.  So far we don't seem to
           have that compelling reason to do that, but the
           configurations worry me a little bit.
                       VICE CHAIRMAN BONACA:  Well, one thing we
           have to also reflect is what's in tech specs right
           now, and what is the basis for them.  And typically,
           there isn't a basis. I mean, it's just  - there were
           numbers often times coming from  - so I totally agree
           on the need of cautiousness.
                       Mr. APOSTOLAKIS:  But this is true for  -
           there is no logical basis for anything that's not PRA
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. COLLINS:  Okay.  Again, the goal here,
           as Dr. Powers indicated, I guess I would debate the
           words that the goal is to live with this.  The goal is
           really to acknowledge that there is a trade-off
           between the risk of taking an action with a dynamic
           power plant that's called for by the license, which
           may be ramping down in power, as opposed to a steady
           -state operation with a calculated length of time that
           provides for recovery of the equipment, so that's the
           balance we're trying to achieve.
                       The next area I'd like to focus on - and
           I thank you for your questions.  It's good debate - is
           rule making.  This is clearly an area where the
           agency, again, is interdependent.  I'm going to talk
           about a few areas, specifically 50.44 and 50.46 that
           are part of the Option Three Rule Making Area where
           research has leave to define the criteria.  I'm in
           rule making space now, which is really when we're
           talking to the ACRS concerning the application of
           these tools themselves.  And clearly, many of these
           are of interest to the ACRS, and will likely be
           activities that we will bring to the ACRS.
                       50.44 is combustion gas control systems. 
           We're looking at a final rule in early fiscal year
           `03.  50.69 is a risk informed treatment of structure,
           systems and components.  It's called the Option Two. 
           South Texas, which you're familiar with, we understand
           the issues from the ACRS having to do with South
           Texas.  We could call that a proof of concept, but
           there are some differences between the approaches to
           50.69.  We are wrestling, as you are, with the
           categorization and the treatment balance.
                       CHAIRMAN APOSTOLAKIS:  We have a Sub-
           Committee  meeting scheduled for later this month to
           discuss the NEI document.
                       MR. COLLINS:  Okay.  We have proposed rule
           in spring of 2002, final rule in fiscal year `03.  We
           are getting feedback from South Texas on the
           application of the South Texas proofer concept which
           was a license exemption, and we're continuing to learn
           from that process also.
                       The ECCS acceptance criteria 50.46, the
           technical reviews are ongoing.  Ashok has lead for
           that.  We're looking at what we call an "unbundling"
           of the technical issues which is the separation of the
           interdependencies in that area.  We do have a paper
           that was provided to the Commission in July of 2001. 
           It's SECY 0133, and as a result of the recent arena
           update to the Commission which occurred last week, we
           anticipate that we'll be requested to update that
           paper, and that will provide for clarification of the
           challenges that the staff has in looking at 50.46.
                       50.61, pressurized thermal shock.  The
           technical reviews are ongoing.  And again, we'll rely
           on the input from research.  There's a possible
           proposed rule in fiscal year `03 in that area.
                       50.48, fire protection rule making. 
           Again,  the regulatory framework in the adoption for
           NFPA 805 and the proposed rule in fiscal year `03.
                       MEMBER POWERS:  Sam, do you think anybody
           is going to take advantage of NFPA 805?  Is there any
           advantage to the 805 to take?
                       MR. COLLINS:  I think it's going to have
           to be looked at on a case by case basis, where
           licensees would look at the ability to bring realism
           to the code, if you will.  Where fire protection
           systems already exist, there will be a balance between
           maintaining those systems, and/or modifying those
           systems, and there has to be a value associated with
           that, so the answer to your question, I think, right
           now is indeterminate.  And I think it relies fairly
           heavily on how the staff use the implementation
           guidelines with the fire code.  How much leeway will
           we allow for a mix and much, if you will, of the
                       MEMBER POWERS:  Pick and choose among the
                       MR. COLLINS:  Right.
                       CHAIRMAN APOSTOLAKIS:  I'm a little bit  -
           I'm confused actually.  I don't understand how a major
           technical society can come up with something that is
           not very useful to a major technical agency.  In fact,
           it's almost useless.  I don't understand that.  How
           can that happen?  Do you have any thoughts on that? 
           I mean, the ASME Standard on PRA, we have
           disagreements with them, I mean the staff does, but
           there is some substance there.  You can see what
           they're doing.  The other guys are  - I mean, in one
           of the earlier versions you're supposed to do the
           deterministic stuff, and then you, you know, do a risk
           assessment on top of it.  I mean, a complete
           misunderstanding of why one does a risk assessment. 
           It's a mystery to me how that can happen.  I mean, are
           we approaching fire protection in such a different way
           from the National Fire Protection Association, or they
           don't know what risk information means?
                       MR. COLLINS:  Let me ask Gary to respond
           to that.
                       MR. HOLAHAN:  Gary Holahan, NRR.  First,
           George, I think  - we've had some of these discussions
           before.  The first point is that NFPA 805 is the Fire
           Protection Agency's  - I mean, it is the consensus
           among the fire protection experts of the country as to
           how to approach these issues.  And I think it's not a
           proper characterization to say that the approach is to
           have deterministic requirements, and on top of it do
           a PRA.
                       CHAIRMAN APOSTOLAKIS:  At some point it
           was, now maybe not now.
                       MR. HOLAHAN:  I think at this point  - in
           fact, 805 has been  - was published last year.  The
           way 805 works is to have identified those areas in
           which the technology exists to risk inform specific
           parts of fire protection requirements.  Okay.  And
           those are specifically identified, and then what the
           fire protection community felt, there was no
           technology available to risk inform it.  They
           identified what were, in effect, deterministic
           requirements.  Okay.  So the document has areas that
           can and should be risk informed, and those for which
           there ought to be deterministic requirements.
                       In the NRC's endorsement of this rule, it
           is likely that we will accept that as the current
           state of the art, but then also recognize that where
           that state of the art is changing, where a licensee or
           an industry group wants to come in and say some of
           those things which 805 is not risk informed, we now
           have developed the technology to do that.  We will be
           receptive to those, as well.  And the rule that we
           write, which is still in the formative stage, but the
           rule that we write will be receptive to using the risk
           informed pieces of 805, but also be receptive to
           additional risk informed activities in some areas that
           are not currently developed.  But it will send a
           signal that we're receptive to those, and it will give
           a rule that will allow us to do those things without
           going through an exemption process.  So I view it as
           a step forward within the existing technology.  Okay. 
           But an invitation to stretch the technology, as well. 
           And I think the previous comments about usability and
           who will use this, frankly, we don't have a pilot
           plant who wants to try this out.  And it may be, at
           least early on, that licensees will only want to pick
           and choose pieces of 805 and the new rule, you know,
           as it suits them, or as they have changes to their
           programs, they will pick up pieces.  But the fire
           protection community, you know, was highly involved,
           something like 60,000 fire protection engineers around
           the country, you know, voted on this thing, so I think
           they think it's useful.  But I think utilities will
           pick and choose the pieces of this that they find
                       CHAIRMAN APOSTOLAKIS:  I think that's a
           clear case where you see how this agency differs from
           everybody else.  I mean, there is a much higher
           appreciation of risk information within this agency
           than in other places.  And I think that was part of
           why 805 was not  - 
                       MR. THADANI:  George, to round out this
           discussion, I think  - I suspect you know, but in case
           the Committee doesn't know, there's been healthy
           debate about to what extent 805 really does consider
           risk information, provides guidance and how to go
                       The American Nuclear Society has got
           effort  - they're initiating an effort to develop  -
           I believe they have decided - I may be wrong on that. 
           I need to confirm - to initiate an effort to develop
           a standard for conducting fire risk analysis.
                       CHAIRMAN APOSTOLAKIS:  So that says a lot.
                       MR. COLLINS:  We would view any effort in
           this area that's a consensus agreement as a better
           place than the existing requirements for the fire
           protection that we have, so that's one of the impetus
           that we have in this area.
                       MR. TRAVERS:  Sam, could I make one
                       MR. COLLINS:  Yes.
                       MR. TRAVERS:  While we're on the rule
           making slide here, I thought I might make note of the
           fact, and it's probably not surprising to you that
           we've gotten just recently a rule making petition on
           50.46 from NEI that focuses on just the size of the
           break.  And that's clearly been the focus of industry
           stakeholders up until now, so we'll be treating that
           in the process that we use for considering those
           things.  Of course, our effort has been broader in
                       MR. THADANI:  Yeah, let me just  - I was
           going to get into it later on, so maybe this is the
           right place.  The scope of 50.46 in the paper that Sam
           referred to that's in front of the Commission, issued
           in July, had certain options in it.  The first piece
           had to do with models, the Appendix K models versus
           should we look at the decay heat curve, clad water
           interactions and so on.  The break size, to what
           extent we can rely on single failure criterion versus
           functional reliability systems, so we broke it down in
           three pieces.  And the first piece had to do with sort
           of models, analysis, functionality.  There is actually
           a petition even on that.  Industry had a petition to
           modify the  - get rid of 1971 decay heat curve and use
           1994 decay heat curve, which is clearly more
           realistic, and the `71 curve is conservative.  But
           there are issues regarding Appendix K models, and we
           were trying to make sure we took an equal look at
                       The second piece was some of the
           assumptions that go in the analysis, such as large
           break, along with loss of off-site power and so on. 
           We thought that was an area we could handle based on
           what we have in the near term, so we had hoped to
           complete that work next summer.  There's been a delay
           of two to three months because of the September 11th
           follow-up activities.  But the final issue, which is
           defining what's an appropriate break size, we
           identified a number of areas that we need to work on,
           and we felt it was going to take some time, so in the
           paper to the Commission we said it probably will take
           us on the order of three years to get to a new, what
           I call design base accident for current plans.  We now
           have a petition which would clearly require that we
           take another look and see where we can go.
                       MR. COLLINS:  Okay.  Thank you.  As you
           know, these are integrated activities, as demonstrated
           by the discussion here today, and they are coordinated
           to the Risk Informed Regulatory Implementation Plan,
           latest update of that was December 5th, 2001.
                       MEMBER POWERS:  Sam, if I were you  - had
           your job, I'd be a very frustrated individual.  You've
           got a list of rule making activities here.  I bet
           you've got another list that you fear on the horizon,
           and every single one of them has all this risk
           information that you're supposed to take into account. 
           And you've got a Commission that's telling you to be
           more risk informed.  But the way your staff goes about
           getting risk information strikes me as clumsy.
                       As I understand it, if they want risk
           information, they go down to Rich Barret and talk to
           him about risk information.  It's always useful to
           talk to Rich Barret.  I know, I always learn something
           from him.  But, you know, Rich gets busy.  And he's
           got a lot of other things, and you've got to kind of
           wait for him to deliver the risk information that you
           need.  He might have to go over to research because he
            - it's a question beyond what the capabilities he
                       Your staff can't dial up risk information
           on a particular plant at any time they want one.  Have
           you thought about what your staff needs to really
           facilitate this risk information move to make it
           convenient to address all these risk informed things
           that are coming down the pike at you?
                       MR. COLLINS:  I guess you put a challenge
           in front of me that I didn't realize existed to the
           extent that you express it.  We have a risk informed
           group within the Leadership Organization that cuts
           across all divisions, and the risk informed activities
           themselves are really centered in David Matthews'
           organization.  Rich Barret is an expert in that area,
           but most of our risk application is really in the
           process area, how do you consider risk.  
                       Plant specific information, we rely on the
           tool that in large part are provided by research,
           whether they be the SPAR models, or the SAPHIRE
           models, or the different phases of the workbooks for
           the significant determination process.  But ultimately
           to make regulatory decisions, we need the input from
           the licensee if we're going to make what I would call
           regulatory decision, as opposed to a programmatic
           process definition, if that makes sense to you.
                       MEMBER POWERS:  I think what you're
           telling me is that you're comfortable relying on
           getting all your risk information from outside
           sources, and never playing with it yourself.  I mean,
           just taking this as truth, and having all answered,
           and he's characterized for you satisfactorily all the
           contingency plans that  - for you by the outside.  And
           that the individual in your organization that's
           actually formulating them, and it goes through a lot
           of processes and consideration, but there is somebody
           making the initial determination of actions to take,
           that he can rely on this, and he doesn't need direct
           access to risk information.
                       MR. COLLINS:  Well, we have risk
           information that's available to us in the form of the
           tools that's been provided by research.  We make
           Rich's decisions day to day in the Operating Events
           Analysis Group, where we get the event reports from
           the licensees.  We do a rough cut of the event
           significance to determine what's our response.  The
           region does the same based on their input to the
           plants themselves.  That's a very different decision,
           and uses a different tool, than a long term, long term
           being up to a year approval of a risk informed license
           amendment would be.  In which case, we would rely on
           the licensee to submit the portion of the PRA that's
           most applicable to the area of the license that they
           in fact want to change, so it's a graded approach. 
           And I think the graded approach is the tool we have
           today.  Now can we improve that?  I think the answer
           to that is yes, and it will be improved by the PRA
           standard being applied by the working agreements that
           we have with research to upgrade the tools for the
           field, as well as for those decision makers in NRR. 
           But I'm trying to contrast a difference, Dr. Powers,
           in the dynamic decision making that's done as a result
           of events so we know how to respond in the short term,
           as a result of the more programmatic reviews which are
           done with the aid of the licensee's information.
                       Ultimately, when we make a regulatory
           decision in enforcement space, for example, or in the
           significance determination process, we use our
           internal tools, and we rely on the licensee to bring
           their information to the table, and then we reconcile
           that.  And that's ultimately what prevails.
                       MR. THADANI:  Let me just comment on what
           was just said.  Coming from the culture I come from,
           I think what you described I will characterize as  - 
                       MEMBER POWERS:  Well, the culture you come
           from is his culture.
                       MR. THADANI:  And we  - I don't think we
           have reached that stage at the agency, obviously, but
           I don't  - I want to make sure you know the effort
           that's ongoing in developing SPAR models that cover
           all 70 sites, and the process we're going through to
           make sure they're technically appropriate and can be
           used by all the staff at NRR and regions, and so on. 
            So I think that's an important step towards I believe
           what you're describing.
                       MEMBER POWERS:  Well, I guess it is and,
           you know, we discuss these SPAR models and argue over
           well, are they good enough and things like that.  And
           quite frankly, I think we both believe that perfect is
           the enemy of accomplishing anything here.  And first
           steps are worthwhile, and the SPAR models are  - it's
           just that my comment is driven by if I were doing  -
           working for Sam, I  - and I knew he was being hammered
           with all these people saying take risk information and
           do more with it, and things like that, you know, I'd
           want that SPAR model yesterday, and I'd want it
           continuously better so that I could play with it and
           understand risk, rather than having to rely on
           somebody else because Sam is a very good
           Administrative Assistant to hold me accountable as
           somebody working for him for what I produce.  And
           maybe it's effectively taken care of, but like you
           say, maybe we can improve it, and maybe the SPAR
           models help.
                       CHAIRMAN APOSTOLAKIS:  I wonder whether we
           should look at the clock every now and then.  We want
           Mr. Thadani to have enough time, as well.  Although,
           I'm sure that  - 
                       MR. COLLINS:  Well, he's taken some time
                       CHAIRMAN APOSTOLAKIS:  There will not be
           as many questions for him.  
                       MEMBER POWERS:  The program is in such
           good shape you can't have any questions then.
                       MR. THADANI:  I will be very efficient.
                       MEMBER POWERS:  Unfortunately, we won't.
                       MR. THADANI:  I didn't say that.
                       CHAIRMAN APOSTOLAKIS:  You are risk
                       MR. THADANI:  Yes.
                       MR. COLLINS:  I'll move quickly so you can 
           get  - 
                       CHAIRMAN APOSTOLAKIS:  Okay.  I don't want
           to rush you, but I will do it any way.
                       MR. COLLINS:  New reactor licensing, in
           response to the Commission's request, we provided the
           Commission in October of last year, future licensing
           and inspection readiness assessment as SECY 0188.  And
           that assessment identified several areas that may need
           to be performed in support of new reactor licensing.
                       Now I would have to indicate to you, as
           you well realize, that one of our challenges in this
           area is the uncertainty in the plans of the potential
           applicant.  And having said that, there are areas that
           the Office of Research, and the Office of NRR are
           focusing on as we move forward in providing products
           to the stakeholders.  One of those, I believe, is
           within the purview of the ACRS, as you well realize,
           is the pre-certification and the certification review 
           of the AP1000. 
                       During the week of January 28th, we
           completed the Phase Two evaluation, having to do with
           the scaling analysis, and we met with Westinghouse on
           the 23rd of January on two issues that Westinghouse
           has agreed to respond to as a result of that Phase Two
           review.  The report is in preparation as a result of
           the review at this time.
                       On the 15th of this month, Jim Lyons'
           organization, the new reactor licensing project office
           is scheduled to brief a sub-committee on the
           applicability of the AP600 standard design, analysis
           code and test program as it applies to the AP1000
           standard design.  WE're expected to brief the full
           Committee on these issues during March 14th and 15th,
           I believe.  
                       We also have a challenge in defining Part
           52, and those areas that need policy guidance from the
           Commission.  WE have a tentative date right now for
           ACRS briefing on November 2002, and that timing of the
           ACRS interaction is dependent on when an SRM is
           received on the proposed rule itself.
                       The ACRS interaction on NEI proposed
           alternative regulatory framework for advanced reactor
           designs will be determined after staff has received
           the NEI white paper, and is currently expected in the
           second quarter of 2002.  ACRS interaction will
           probably be late 2002 or 2003.  Research plays a key
           role in that area.
                       The application reviews for the Pebble Bed 
           marginal reactor, the AP1000, the GTMHR are expected
           to involve several policy issues that most likely will
           require ACRS interaction.  And again, these schedules
           and policy issues are dependent on the application
           schedules and the applicant's willingness to support
           the work from the staff.
                       The PBMR application review is expected
           approximately in 2004.  The AP1000 standard design
           certification review is expected this year in 2002,
           and the gas turbine modular Helium reactor, GTMHR
           combined license application is expected in late 2004.
                       Also within our budget assumptions, we
           would be receiving requests for early site permits
           this year and in 2003, and all of those are in the
           budget assumptions that have been provided to the
           Commission itself.
                       CHAIRMAN APOSTOLAKIS:  Are you going to
           get into this shop in your presentation as well?
                       MR. THADANI:  Yes.  I'm going to talk
           about what the research plans are.
                       CHAIRMAN APOSTOLAKIS:  Okay.  So we
           shouldn't be asking those questions now.
                       MR. COLLINS:  And I can chime in, if
           necessary, if you want to just consolidate the
           questions in one area.  That would be sufficient.
                       Licensing issues, there are three broad
           areas I'd like to bring to your attention.  One, of
           course, is familiar to you, and that's power uprights,
           and we've had presentations in front of the Committee
           for power uprights.  We think the first presentation,
           the staff had a few missteps in support for ACRS in
           that area, and we did recover in our subsequent
           presentation.  We are in receipt of the ACRS
           recommendation to consider a standard review plan in
           this area.  We have it under advisement.
                       I would want to relay to you that that's
           a balancing of needs within the office now.  We have
           taken a rough look at what it would take to formulate 
           a standard review plan, and the time frame necessary,
           which essentially would be this year given the amount
           of power uprights that are coming in in 2002, 2003,
           that's when really the application would be.  Against
           the use of the revised topical, which is currently
           under review by the NRR staff, as well as the
           initiative to use an already approved power upright as
           a template for the SER, and we will balance those and
           come to a weighted decision and provide that back, not
           only to the ACRS, but the Commission has asked us for
           that consideration also.
                       MEMBER WALLIS:  While we're on power
           uprights, you're aware we've had some correspondence
           about the safety evaluation report, and this is, of
           course, the written technical justification for
           decisions made by the Commission.  And I think both of
           us, or all of us are very concerned, are very
           interested in it being as clear a document as
           possible, giving all the reasons for the decisions
           that are relevant.
                       MR. COLLINS:  We agree, and I think we've
           made some revisions to the SER to provide for that
           standard, as indicated by the ACRS.
                       MEMBER WALLIS:  Okay.  
                       MR. TRAVERS:  There's been a similar
           comment, Graham, that we got from the IG, noting that
           while we're getting to the right technical conclusion,
           very similar to your recommendation that there is a
           need to revisit, and NRR is developing an initiative
           to do that, looking at the characterization of those
           conclusions and the basis for them in SERs that we  -
           we agree with you that they're fundamental in a whole
           host of ways to the products that we put out.  And I
           know Sam and his folks are working very hard on that.
                       MR. COLLINS:  Right.  The issue there is
           the basis for the decision, as you well indicated.
                       MR. TRAVERS:  Not the bottom line.
                       MR. COLLINS:  Right.  We currently have
           eleven power uprights under staff review, including
           four extended power uprights, so this is a business
           line of our's which is very active.  WE've completed
           22 uprights during our review processes, including
           five extended power uprights.  That total for all
           power uprights is about 3,200 megawatts of
                       License renewals, you're well familiar
           with license renewals.  Again, that's a premiere
           product line.  The Commission, as well as the ACRS, is
           very interested in that.  Under review we have Turkey
           Point, North Inniserry (phonetic), Catawba, McGuire,
           Peach Bottom, St. Louis, and Fort Calhoun.  Next
           decision on license renewal is Turkey Point.
                       The generic guidance has been issued to
           assist the NRC and the future applicants in improving
           the effectiveness and efficiency of the reviews.  And
           the first applicant to use this guidance fully is Fort
           Calhoun, we expect.
                       You should be aware that we're assuming a
           33 percent efficiency in this area.  It's part of the
           staff initiatives, and Marty mentioned the program
           office goal of NMSS of efficiency and effectiveness,
           and this is one of the assumptions that we have made
           in refining our processes, going from about eighteen
           and a half to about twelve and a half FDE per license
                       We're also looking at potential plant
           reactivations.  Brown's Ferry is under consideration,
           and to a lesser extent, WMP1 completion study is
           underway.  These initiatives are not new licensing
           organization responsibilities under the project
           office.  Those will come under John Zwalinsky in the
           licensing area, but those are challenges at this point
           that we have not budgeted for, although we do have a
           general knowledge of what it would take, particularly
           in the case of Brown's Ferry, for the recovery given
           the other two units that have been recovered.  There
           would be additional challenges to the staff.
                       CHAIRMAN APOSTOLAKIS:  But you have had
           some indications that somebody is thinking about it,
           but you may get some application?
                       MR. COLLINS:  Our understanding, and I
           think it's been announced that a decision on Brown's
           Ferry would be expected in the early spring, in the
           April time frame.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. COLLINS:  And there have been ongoing
           technical reviews for approximately the past year at
           that site.
                       MEMBER ROSEN:  Have you heard anything
           about Zion?
                       MR. COLLINS:  I've heard, Steve, probably
           what you have about Zion, and that's only in the trade
           press.  Let me move on to the summary.  We have a
           great deal of work on our plate, as does the ACRS. 
           I'd like to acknowledge the benefit in the exchange of
           staff with the ACRS.  We thank you for Noel Dudley. 
           He will be a great addition to our staff.  We welcome
           him back.
                       MEMBER POWERS:  We hate you for this.
                       MR. COLLINS:  Well, we'll donate it in
           other areas.  John and I have a healthy exchange on
           the support for ACRS, and we believe that it is a
           worthy rotation for our staff to understand not only
           the issues, but the perspectives that the ACRS brings
           to those, and we're working on rotational development
                       We are meeting our commitments.  We were
           very successful last year in our performance goals. 
           And again, that's indicative of the support between
           the offices.  One of our challenges is to find a way
           for the ACRS to understand some of the resource
           constraints that are facing the staff, and I think
           that is an area of a challenge for us to exchange. 
           And that's a little bit of realism into the
           application of the answers.  It's always good to think
           broadly, and to deal conceptually.  And we welcome
           those inputs.
                       The Offices of NMSS and NRR are really
           where we have to apply the issues, and we're under
           fairly strict time constraints as mandated by the
           Commission in many of these areas, so I would believe
           that there's room for us to enter into a constructive
           conversation in that area, particularly when we're
           talking about refinement of programs.
                       MEMBER POWERS:  It's one of  - I mean,
           it's a challenge that I don't know that the ACRS can
           ever meet on this.  You know, we just don't know what
           your constraints are, and we can't evaluate it, so I
           think that's the most valuable when you respond to
           some of our suggestions.  And you say well, look, you
           know, this is  - it's just a constraint of time, or
           manpower or things like that, you know, that's one we
           just have to accept from you, because there's no  - we
           just don't have the time or expertise, it seems to me,
           to go into that.
                       MR. COLLINS:  I understand.
                       MEMBER POWERS:  And I think it would be
           unwise for the ACRS to temper its comments by mentally
           --  suppressing them by mentally taking that into
                       MR. COLLINS:  Right.
                       MEMBER POWERS:  I mean, it's far better
           for you to come back and say well, I just can't  - I
           just don't have the manpower to do this.
                       MR. COLLINS:  That's a fair observation. 
           I think it's information that we owe to the ACRS, and
           that is put in perspective in  - 
                       MEMBER POWERS:  Yeah, I mean it's  -
           everybody has to somehow live within their budget
                       MR. COLLINS:  Right. And I do believe
           additionally there is a role, and it may be a by-
           product but its one that we would want to be sure
           you're aware of, of the ability of the ACRS in your
           decision making, in your input to help us with our
           public confidence goal.  And again, that public
           confidence is not directly in the context of promoting
           nuclear power.  It's in the context of the NRC as a
           strong credible regulator.  And the role of the ACRS
           in looking at the products, and challenging the staff,
           and in providing for that independence, I think is
           important.  It may not be well known, but  - and I
           think to some extent the staff ourselves can work with
           you on the right context to place that in.  We don't
           want to leverage it overly, but I do believe it's
                       MR. GARRICK:  Sam, a while ago you
           referred to the collaboration between NRR and NMSS. 
           One thing that occurred to me is that over the past
           four or five years in particular, the two Committees
           have written numerous letters to the Commission on
           this whole issue of risk informing the regulations,
           and risk informing the process.
                       You also mentioned a little earlier about
           a cross-cutting group in the risk area.  I'm curious
           if somebody is looking at these letters from the
           standpoint of consistency of advice, consistency of
           application.  In particular, our Committee has been
           very focused on the issue, some very fundamental and 
           philosophical issues associated with what constitutes
           risk assessment, having to do with transitioning from
           assumption based to evidence based analyses, having to
           do with reasonable, as opposed to conservative,
           unnecessarily conservative.  
                       The reason we want to do uncertainty
           analysis is because we don't have to make the choice
           of being conservative or non-conservative.  We put
           forth our best shot at what we think the risk is.  
                       These are very fundamental ideas and
           issues, and I just wonder if somebody is looking at
           that database, if you wish, and tracking the
           consistency of advice that the Commission is
           receiving.  That would seem to me to be a very useful
           platform of collaboration in this rather important
                       The other thing I just wanted to mention
           before we got into the research area, is that Dana had
           referred to earlier, alluded to the difficulties of
           getting your arms around all of the risk informing
           activities that are going on.  One of the things that
           this Committee found very useful was the Commission
           white paper of three or four years ago on risk
           performance based regulation.  That paper was
           refreshing in that it reached out more than any I had
           ever seen to deal with the issues of what was meant by
           risk assessment, what was meant by performance based,
           and what was meant by defense in depth, and
           precipitated a whole list of very important points
           that we found very useful in using as a kind of a
           starting point for subsequent advice on risk and what
           have you, so those two things.  
                       One, is somebody looking at the advice in
           terms of the consistency on these rather critical
           issues.  And second, what prospect is there for maybe
           a sequel to the white paper, an update on the white
           paper that went beyond the rigid and formal structure
           of rules and regulations, and indicated some sense of
           how the Committee  - how the Commission was thinking
           about these extremely important issues.
                       MR. COLLINS:  The  - I'll defer to Ashok
           here in just a moment, but the forum we have to
           integrate our risk informed activities is the Risk
           Informed Implementation Panel and the Steering
           Committee, which Ashok is the Chairman of, and which
           Marty and I are also members.
                       Now in direct answer to your question, do
           we take the ACRS letters and look at those, and
           compare those?  I think the answer to that is no. 
           Each office does that individually.
                       MR. GARRICK:  Uh-huh.  
                       MR. COLLINS:  I think what we would have
           to do is take that under advisement, and it could
           easily be done by the panel as an order of business.
                       MR. GARRICK:  Well, what triggered it was
           your reference to a cross-cutting group.  It just
           seemed to me this might be a useful exercise.
                       MR. COLLINS:  I think it's the right forum
           for that.
                       MR. GARRICK:  Yeah.  Right.
                       MR. COLLINS:  Right.  Yeah.  
                       MR. THADANI:  John, just to add to what
           Sam was saying, we  - today we do not really have a
           systematic process in place to look if various
           decisions are consistent in terms of risk information.
                       We are applying at least areas where we in
           research are involved, and for example, work on the
           cask.  We're trying to make sure that there's
           consistent application of risk informed thinking as we
           go forward.  Marty indicated that we're starting out
           on a number of areas just now, within NMSS activities,
           and research is engaged in that to make sure that
           again, if there are going to be differences in
           applications and decisions, we understand what those
           differences are, and able to account for those
                       In addition to that, actually Marty's
           initiative, there is a PRS Steering Committee that I
           Chair, of the Program Officers who are members of the
           Committee.  Louise Reyes from Region Two is a member. 
           OTC is a member and so on.
                       Marty has actually brought to table a
           number of initiatives within NMSS just for that
           purpose, to share with the Committee, to see if there
           are some inconsistencies, there may be some
           inconsistences.  At least offer an opportunity for
           discussion of those, but I could tell you, we're just
           barely starting.  Marty may want to add to that, but
           I think it's just an initial stage where we are.
                       MR. COLLINS:  Yeah.  Let me just finish by
           clarifying a comment that Ashok made, and that is that
           in the Office of NRR, when we make risk informed
           decision making, we do attempt to go back and do a
           quality check.  For example, in the revised oversight
           process, or the significance determination process, we
           make those decisions as provided for by the ROP, the
           Revised Oversight Process.  Research does an
           independent check of those after the fact, and
           provides us an input into whether that consideration
           was appropriate or not.
                       MR. THADANI:  That's through our accident
           sequence precursor program.
                       MR. COLLINS:  Right.  So that's kind of  -
           that's how we're trying to balance that, but your two
           points are still appropriate for us to take away.
                       MR. THADANI:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  One last question
           on the letters, since the issue of the letters came
           up.  We are discussing among ourselves what, you know,
           the best way would be to communicate with you.  And
           there are several ideas regarding the structure of the
           letters.  And in fact, in the last several years we've
           been using that structure that has the recommendations
           up front, or the conclusions and recommendations, and
           then a discussion, which we believe is an improvement
           over past practices, where you really had to look all
           over the place to find the recommendations.  
                       But one of the things that's happening is
           that in some issues where there are disagreements
           among committee members, the letter has to be written,
           you know, at some point, so the easy way out is to
           eliminate as much as we can the controversial issues,
           and come up with the lowest common denominator and say
           this is a conclusion now.  And some members feel that,
           you know, there is a lot of useful  - there are a lot
           of useful ideas and maybe possible recommendations
           that are eliminated that way, so you guys never know
           that some members felt that way, and others countered
           with counter arguments.
                       So what  - do you think that the letters
           are better if they have clear recommendations without
           any controversial debates, or they would be improved
           if some of the issues that the members have been
           discussing in the open forum here were actually
           reflected in the letter, but diluting the
                       MR. TRAVERS:  Yeah.  Maybe I can start,
           and I'll be happy to  - 
                       CHAIRMAN APOSTOLAKIS:  Sure.  Sure.
                       MR. TRAVERS:   - hear conflicting views. 
           But from my vantage, it's helpful to have a clearly
           articulated recommendation.  It  - from a number of
           perspectives, not the least of which is being able to
           track our responsiveness to that.  You know, clearly
           identify where, in a consensus sense, the Committee
           has come down on an issue.
                       Having said that, I don't think we'd look
           askance at additional information that bore on your
           deliberation on any particular issue, including views
           by members, as long as, you know, it was sort of
           illustrative of the debate or discussion that sort of
           was carried out in connection with that.  But I  -
           from our  - you know, from a management standpoint,
           it's very helpful to be able to start with a consensus
           or majority view, however it's done here.  I believe
           it's majority, and be able to work that top level view
           as we deem appropriate, and certainly be able to
           respond to you in the context of how we're doing that. 
           Or if we disagree, why and what the constraints may be
           that force that view on our part.
                       MEMBER KRESS:  From that standpoint, what
           do you do when you get a letter from us that has
           additional comments from particular members, that may
           be either giving additional information, or may be
           contrary to what's in the main body of the letter? 
           What do you do with that sort of information?
                       MR. TRAVERS:  I think it's a matter of us
           considering that in an informing sense as we go about
           our duties and responsibilities.  Any information of
           that sort, I think, can be helpful, and it may shed
           some additional light on the recommendation and
           conclusion that you reached.  You know, it's
           illustrative, I think, of a healthy discussion/debate
           here on the part of the committees.
                       MR. COLLINS:  In summary, I've covered the
           major areas I believe are of interest, although I've
           been very specific in the topics.  Other areas that
           might be of interest for future discussions, one might
           be a presentation by the Steering Committee on Risk,
           for example, if that would be beneficial in response
           to some of the lines of questioning today.
                       Revised Oversight Process is clearly of
           interest to the ACRS Committee, including the use of
           PIs, the Significance Determination Process and the
           Colors.  We do have materials engineering challenges
           with the cracking in the control rod drive mechanism. 
           We have other areas that we're looking at, stress
           corrosion cracking in general.  Do appreciate the
           ACRS' involvement in the proposed orders that were
           formulated for the CRDM cracking.
                       License renewal I talked about a little
           bit.  In response to the September 11th attack, and
           the resources and the focus of the program offices, I
           think will cascade down to some of our products, and
           we'll be talking to the ACRS, if necessary, on
                       Managing human capital is not necessarily
           an area of ACRS purview.  I think it is a challenge
           for the agency right now to staff up to the levels
           that are necessary to support the new work in response
           to the event of 9/11, as well as new reactors.  And
           improving our business practices, including defining
           performance goals is an area that I believe the ACRS,
           at least, should be aware of to know that we are
           accountable for our products, and our outputs, and our
           outcomes, and ACRS in many cases is an integral part
           of that.  As you are in our definition of work as far
           as our work flow diagrams, ACRS is integrated into
           that processes, and we need to be coordinated to be
           successful.  So that concludes my remarks, and I would
           leave the remaining five minutes to  - 
                       MR. THADANI:  Okay.  Well  - 
                       MEMBER POWERS:  Never draws any
                       MR. THADANI:  As always.  Let me also
           start out with some positive thoughts here.  Every
           time I meet with you, the committees always walk away
           learning things, and recognizing there are areas that
           maybe I need to pay a little more attention to, so I
           find these dialogues extremely valuable and, I think,
                       I particularly want to acknowledge what I
           think was a tremendous amount of effort on your part,
           look at research programs and the document that you
           produce.  It's, in my view, a masterpiece.  It is
           extremely well thought out.  As I have indicated to
           you before, I think we were in agreement in most of
           the areas.  There were some small differences of
           views, but they were not fundamental in nature.  It
           was just a matter of relative timing of what we do
           with some of the recommendations that you had in your
                       Similarly, this, of course, has some
           aspects of waste in it, as well.  I also wanted to
           note that the February 5th letter, in particular, from
           the ACNW had a number of recommendations about
           research that were taking to heart there are things we
           can do, and there are things we cannot do.  So to the
           extent we, as an office, can address those, we are
           doing that.  And, in fact, we've made progress in some
           of those areas.
                       What I will do since I only have about ten
           minutes, I think I have eight or nine charts.  I'm not
           going to talk about everything.  Let me briefly take
           each chart and see if I can't make what the key points
           may be, and we can move on.  And I'll certainly try to
           answer whatever questions you may have on the topics
           that you will see.  Let me go to the first  - may I
           have the first chart, please.  Okay.
                       This is a list of  - I mean, this is not
           a complete list, but what I call major issues that we
           have been working with the committees, and we expect
           to continue to work on, different specific areas, but
           for the next two to three years, this is going to take
           a lot of attention and our time, and I expect a lot of
           interactions with you.
                       I'm not going to say anything about the
           follow-up to 9/11 activities, except that there is
           significant ongoing effort in the Office of Research. 
           Much of it is classified, and I do expect down the
           road that there will be some interaction with the
           Committee in terms of what we're doing here.
                       Let me go on to the next chart.  Advance
           reactors, the two parts that I want to highlight first
           in terms of the importance of trying to make sure we
           have a reasonable framework in place, which would
           guide our activities, would define how far we go in
           certain areas, what the boundaries would be.  And this
           is clearly  - this would include the role of safety
           goals.  Obviously, safety goals alone would not be
           sufficient.  The discussion is ongoing, and I know
           you're looking at issues of frequency consequences
           approach, and what's the role of deterministic
           thinking in this process.  And then how to account,
           when you go to designs that are pretty unique and new
           to us, how are we going to account for lack of data,
           inexperience, and that would impact the quality of
           PRAs and the role of PRAs, and whatever decisions have
           to be made.
                       We're pulling together a research plan,
           and the scope of the research plan is going to cover
           PBMR, the GTMHR, AP1000, and IRIS.  What are some of
           the key technical issues?  How would we go about
           making sure we have appropriate tools to help us make
           those independent decisions as an agency?  What sort
           of resources would be necessary, schedules?  And this
           would be a living plan.  It's one that we would hope
           to have a draft later this month.  We have sent out
           the first version for comments, but we expect to have
           our initial discussions with you on the plan in April. 
           That means we'll get you a draft some time in March so
           you would have an opportunity to have looked at it.
                       Just to give you a sense of what's in it,
           if I can be brief.  This is a snapshot.  AS I said,
           this is a living plan.  And I think you will recognize
           some similarity cornerstones approach that you're very
           familiar with.  The idea here was that we want to take
           what I would call a systems approach to defining what
           we need to do in terms of research.  And you will note
           that this includes also the fuel cycle issues, because
           we need to look up front from beginning to end, and
           not necessarily continue with the ways of the past, so
           to speak.
                       This  - the whole idea here is the idea of
           completeness.  We want to make sure we lay out all the
           issues that may be important, and some of which may
           require research effort.  Our intention is to go
           through this process in a very systematic way, the
           kind of thinking that I talked about, part type
           thinking has to be applied to each of these issues as
           we go forward.
                       CHAIRMAN APOSTOLAKIS:  So you worry about
           the aging for future reactors?
                       MR. THADANI:  Absolutely.  Sixty years.
                       MEMBER POWERS:  Well, if you're radiating
           graphite, you're better to learn about aging real
                       MR. THADANI:  Exactly.  I would use the
           same example, and there are some very interesting
           technical issues from aging of graphite which could
           have very significant bearing on the design, I think. 
           I'm not going to go through this.  We will be
           discussing a lot of this with you in April.  Let me go
           to the next chart.
                       On risk informed initiatives, obviously we
           can spend an awful lot of time, but let me make just
           a few comments.  This is an area where we have very
           extensive interactions with you, and I anticipate will
           continue for the next three years, so  - but just to
           give  - to bring to your attention that we have a Risk
           Informed Regulation Implementation Plan.  We updated
           it, and Sam mentioned that last version went to the
           Commission December 5th.
                       It includes everything that we at the
           agency are doing in terms of applications, risk
           informed thinking.  I think that's a very good thing
           to do, because it does bring us together in terms of
           communication and so on.  It includes prioritizing
           activities, identifying necessary tools, resources,
           and integration activities, as well.
                       We're trying to identify in that plan what
           are some of the most critical milestones that need to
           be completed before one can go on to some place else,
           and what some of the cross-cutting issues are.  I
           think we need to do better than what we've done up to
           now, but it is a good start, I think.  It does
           identify what some of the cross-cutting issues are.
                       Another effort that's good in this
           document, we often talk about risk informed
           regulations, and performance based to the extent
           practical.  WE've always said that.  Here's a document
           we're trying to make sure as we go forward, and with
           any future rule makings, we systematically consider
           factors, but we can, in fact, be performance based in
           the articulation of our regulation.  So that's  - I
           think that's a good move.  It's  - to me, I look at it
           like a handbook.  It's a good handbook, I think.  And
           on individual pieces, of course, you may have to go
                       In terms of the PRA quality, you know
           about the standards.  I won't dwell on it.  WE're
           looking at all the standards, the ASME/ANS, as well as
           looking at the NEI peer review document.  We're
           planning to pull together a guide that will help us
           integrate the role of the standards, role of the peer
           review, so there's one place one can see how these
           things are going to be utilized.  And our intention is
           to pull that guide together, and we'll be meeting with
           you on that guide.
                       I won't say anything about PTS because I
           know you're up to speed, 50.44, 50.46.  We had the
           discussions.  Human reliability analysis, I guess I
           just want to make sure you know that we're sunsetting
           ATHENA this year.
                       CHAIRMAN APOSTOLAKIS:  You're what?
                       MR. THADANI:  We're going to sunset
           developmental activities within ATHENA.  We're
           applying it, as you know, in the area of  - 
                       CHAIRMAN APOSTOLAKIS:  Speaking of cross-
           cutting and working with other offices, I saw the
           slides the two gentlemen from NMSS were using
           recently, two, three weeks ago in a presentation to
           the staff on human performance for NMSS.
                       MR. THADANI:  NMSS, yes.
                       CHAIRMAN APOSTOLAKIS:  They went back to
                       MR. THADANI:  They went back  - 
                       CHAIRMAN APOSTOLAKIS:  No mention of
           ATHENA, no mention of  - 
                       MR. THADANI:  Uh-huh.  
                       CHAIRMAN APOSTOLAKIS:  THERP, way back.  
                       MR. THADANI:  That went to THERP.  Okay. 
           That's good input.  I told you, I always learn things
                       CHAIRMAN APOSTOLAKIS:  I know that you
           guys have been doing this, or they studied it and they
           said this is not helpful.
                       MR. THADANI:  Yeah.  Yeah.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. THADANI:  Yeah.  Good thinking.
                       CHAIRMAN APOSTOLAKIS:  This is always a
           question that comes to mind.
                       MR. THADANI:  Yes.  Thank you.  It's a
           message that's well received, and will be followed up
           on.  The only point I wanted to make sure you knew
           under human reliability analysis reach plan, that
           there are some boundaries that we're not crossing. 
           We're not looking at the issues of safety culture. 
           We're not looking at the issues of organization and
           management, but we are monitoring what's happening in
           the international community.  And I think you know the
           next piece very well.  We've got significant efforts
           going  - 
                       MEMBER POWERS:  Let me just inject, Ashok. 
           We've been holding off on looking at this, your
           current human reliability analysis research program
           because we had the perception that your staff was a
           little busy to come talk to us about this with other
           activities, and I still want to do that, if not to
           impose on them, but I don't want to hold you up
                       MR. THADANI:  Yeah.  In fact, I'm glad you
           raised that. I think we sent you a draft plan some
           time ago.
                       MEMBER POWERS:  Yes.
                       MR. THADANI:  It's got to be revised, I
                       MEMBER POWERS:  Okay.
                       MR. THADANI:  And that's the issue.  I
           think we need to revise it, and then get it to you,
           and then have meetings with you.
                       CHAIRMAN APOSTOLAKIS:  Ashok, we spent so
           much time reading it, now you're revising it?
                       MR. THADANI:  When I say revised, certain
           elements.  So you haven't read it as  - 
                       MEMBER POWERS:  Tell him completely from
           top to bottom, throw away all those comments that he
                       MR. THADANI:  I just wanted to note that
           I think you know all the work that research is doing
           to support NRR, in terms of looking at operating
           experience, and how it can be utilized, the analysis
           of this experience on a number of initiatives that NRR
           has ongoing.
                       CHAIRMAN APOSTOLAKIS:  I have a comment on
           this.  The rest of the slides deal with engineering
           issues and so on, so maybe this is the best place to
           raise it.
                       MR. THADANI:  Sure.
                       CHAIRMAN APOSTOLAKIS:  We made the
           recommendation  - well, I'm not going to raise
           decision theory when we talk about fuels.
                       MR. THADANI:  Right.  Fine.
                       CHAIRMAN APOSTOLAKIS:  When you talk about
           risk informing initiatives, making decisions  - 
                       MR. THADANI:  Uh-huh.  
                       CHAIRMAN APOSTOLAKIS:   - and we had a
           recommendation in the research report  - 
                       MR. THADANI:  Yes.
                       CHAIRMAN APOSTOLAKIS:   - that formal
           methods have existed for quite a while now, and we
           recommended that your staff investigate the
           possibility of taking advantage of this work that
           people have done.
                       MR. THADANI:  Uh-huh.  
                       CHAIRMAN APOSTOLAKIS:  And we don't see
           anything here.  And I want to make it clear, that we
           are not really proposing that you use formal decision
           theory in all your decision making activities.  I
           mean, that would be absurd, but there should be, I
           think, some appreciation of what these methods can do
           within the Office of Research, at least.
                       MR. THADANI:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  And for example, in
           the last bullet with the performance indicators, you
           would have found this expertise useful. It would have
           helped you do certain things better than they were
           done in the documents we saw.  And there may be other
           places where you may also take advantage.
                       MR. THADANI:  Sure.
                       CHAIRMAN APOSTOLAKIS:  In other words,
           here is a decision making agency that's using risk
           information, which means uncertainty estimates all the
                       MR. THADANI:  Uh-huh.  
                       CHAIRMAN APOSTOLAKIS:  And it's trying to
           risk inform its regulations, and there is this large
           body of knowledge that tells you how to use these
           uncertainty estimates in a rational way.  And we are
           not really taking advantage of that.  I mean, this is
           really where we're coming from.  It's not that we want
           you to say well, gee, you know, Sam has a problem
           tomorrow.  He has to make a decision, oh formal
           decision.  No, not at all.  But there is a lot of
           information there that could be useful.
                       MR. THADANI:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  In fact, it would
           be.  I know it would be, and we are not really using
           that.  Now I know you have asked one of your staff
           members to do some investigation.  That's not good
           enough, in my view.
                       MR. THADANI:  Well, I  - 
                       CHAIRMAN APOSTOLAKIS:  We should take it
           a bit more seriously in the sense of at least there
           should be a bullet there saying that you're thinking
           about it.
                       MR. THADANI:  Well, let me say that we're
           thinking about.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. THADANI:  If that satisfies you.
                       CHAIRMAN APOSTOLAKIS:  You will take
           appropriate action in the future.
                       MR. THADANI:  Yes.  In addition to that,
           I have asked, and Dr.  Johnson happens to be sitting
                       CHAIRMAN APOSTOLAKIS:  I know.
                       MR. THADANI:  He is looking at what I
           would call looking at the state of the art, to what
           extent we can utilize these methods, which approach is
           maybe  better, and so on.  I can tell you that we're
           not embarked on an extensive evaluation.  Until we do
           an initial assessment, then we'll have to decide how
           far we can go, or can't go in certain directions, but
           it is a first step.  And once we get done with that
           first step, maybe I can come back and tell you more
           about where we are planning to go.  
                       I just wanted to make a note here, you
           have in the past raised some concerns about the need
           to do a peer review of SAPHIRE, and we have  - I mean,
           you had this discussion just two weeks ago.  And we've
           looked at all the information, and we think that we
           will go forward with peer review this year.  The scope
           and so on is yet to be decided, but I've asked the
           staff to come and meet with you before we initiate any
           peer review, because I want to be sure that we are, in
           fact, properly focused on whatever issues there may be
           in terms of applying  - 
                       CHAIRMAN APOSTOLAKIS:  You are aware of
           the fact that some NASA Manager have volunteered  - 
                       MR. THADANI:  Yes.
                       CHAIRMAN APOSTOLAKIS:   - to participate
           in this.
                       MR. THADANI:  Yes, I am.  Yes.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. THADANI:  But I just wanted to let you
           know, because this is just recently we decided we'll
           go forward.
                       CHAIRMAN APOSTOLAKIS:  Yeah.
                       MR. THADANI:  Let me go to the next chart,
           and I think many of you are so familiar with this,
           that let me just say that much of  - in terms of the
           MOX fuel, the high burnup fuel, we've had a number of
           PIRT meetings.  WE're going to have a draft report
           next month, and we'll be assessing various models. 
           We'll be looking at taking advantage of data from
           different countries in terms of where we go.  And this
           is one of those ongoing interactions with the ACRS.
                       MEMBER POWERS:  Are we ever going to get
           the French data on MOX, and high burnup fuel?
                       MR. THADANI:  Well, we  - I hesitate to
           say that we have reached that agreement, but I'm
           hoping we're there.  I'll have to  - I don't think we
           have yet reached that end point, but I'm hoping we'll
           get there.  And we have to  - we're discussing options
           of how can we provide the necessary resources to get
           the data from the French.
                       MEMBER POWERS:  Well, wouldn't  - and you
           might want to be aware that we've invited the  - some
           of the investigators from the PHEBUS Program to come
           speak to the Committee in May.
                       MR. THADANI:  In May?  Okay.  I didn't
                       MEMBER POWERS:  About both the current
           PHEBUS Program and some of their plans for follow on
           programs.  Not that the Committee is taking any
           action, just for information purposes.  
                       MR. THADANI:  Yeah.  We're hoping,
           depending on how `03 budget comes out in the end. 
           We're hoping to continue our relationship with the
           French on PHEBUS Program.
                       MEMBER POWERS:  That raises one of the
           questions.  We've been very supportive of your efforts
           in the high burnup fuel area, and I note that you've
           even expanded those activities beyond what they
           originally convened, and they seem to be progressing
                       MR. THADANI:  Yeah.
                       MEMBER POWERS:  I mean, there are some
           hiccups in just getting available fuel but, you know,
           those things happen in research, and that's why you
           have lots of white hair, undoubtedly.
                       One of the questions that's going to come
           up is that you're doing a lot of experiments on single
           rod, specialized experiments, and they look very
           useful.  The question is, is that going to be enough? 
           Do we have to go to multi rod experiments to
           understand things?
                       MR. THADANI:  Let me  - because of my, you
           know, limited time, let me take that as a question to
           get back to.
                       MEMBER POWERS:  Yeah.  I mean, you don't
           have to give me an answer now.  It's one of those  - 
                       CHAIRMAN APOSTOLAKIS:  Speaking of that,
           Bill, is it okay to go to fifteen  - 
                       MR. TRAVERS:  Sure.
                       CHAIRMAN APOSTOLAKIS:  Okay.  Great.
                       MEMBER KRESS:  Ashok.
                       MR. THADANI:  Yes, Tom.
                       MEMBER KRESS:  Before we get off of the
           question of the French data, if you ever get the
           VERCORS data  - 
                       MR. THADANI:  VERCORS  - 
                       MEMBER KRESS:   - I would be very
           interested  in getting it as soon as  - letting me
           know as soon as I could.
                       MR. THADANI:  Okay.  All right.
                       MEMBER KRESS:  Because I could use it
           right now.
                       MR. THADANI:  We're also talking to the
           Japanese, of course.  I think you know about the VEGA. 
           Okay.  Another thought here that I just want to make
           sure and capture, is that we are looking at the burnup
           and correlation affects on cladding, cladding of
           various designs, Zircaloy 2, 4, Zirlo, M-5 and so on,
           so this is something that various types of testing,
           and trying to make sure that there are no surprises
           there for us.  This talks a little about HTGR.  I just
           wanted to make sure that you knew that this is going
           to be captured in the plan.  
                       The next chart, in fact, I'm not sure that
           I need to say any more.  We've had very extensive
           discussions with the Thermal Hydraulics Subcommittee,
           and we  - I think you're up to speed on where we stand
           in terms of assessment of TRACM and so on, and what
           some of our continuing efforts are going to be.
                       A point I'd like to highlight here is that
           I think this is an area where I'd like for us to be
           proud that we've got pretty good in-house capability,
           and I hope it's coming through to you, as well.  We've
           got a pretty strong group of people in this area.
                       MEMBER KRESS:  Are you doing anything in
           severe accident area  - 
                       MR. THADANI:  Yes.
                       MEMBER KRESS:   - on air ingression
                       MR. THADANI:  Yes.  We are now discussing
           with an Eastern European country to see what kind of
           test could be done at very reasonable cost to get some
                       MEMBER KRESS:  You have good ideas.
                       MR. THADANI:  Well, I am assuming you know
           we're looking at similar approach for severe accident
           codes, such as MELCORS, as we were with the DPA type
           activities.  Next chart, please.
                       I mean, this is an area where NRR and
           research are very tightly integrated, I would say. 
           Very significant information that's coming out of
           operating reactors, examples that Sam used, that
           clearly require that we be prepared to support NRR in
           dealing with some of those issues.  And the work at
           Argonne and some international arenas has been very,
           very valuable, and I want to thank you for the support
           that you've given us.  
                       Our focus now is largely on a radiation
           assisted stress corrosion cracking, crevice chemistry,
           and some of those fundamental mechanisms that may be
           involved, and trying to see how we can make sure we
           are prepared, that we can do appropriate  - we, as an
           agency, can do appropriate inspections, and know
           what's really going on.
                       The  - again I'll not say much about
           advanced reactors in this area, other than to just
           note that high temperature metals, Graphite and the
           containment confinement are going to be significant
           challenges that we're going to have to deal with this
           perspective as well.
                       Steam generators, we're following the plan
           that, Dana, you know about, and we're on course. 
           Digital I and C, we've got a plan that's been
           discussed with you, so let me just move on to the next
           chart, unless you have questions.
                       Waste issues is sort of  - some of the
           issues that we're involved in.  You touched upon dry
           cask.  You raised a question earlier, Dana. 
           Obviously, we're looking at structural material
           systems and probabalistic considerations in an
           integrated fashion.  And we're doing a PRA.  I'm happy
           to note much of the work is actually being done in-
           house by our staff, so it's very important.
                       We do have some cooperative efforts with
           the Electric Power Research Institute, and Department
           of Energy to looking at fuels, for example, various
           burnup levels, trying to get the right data.  The idea
           behind this, of course, is to support NMSS and their
           decisions on license extensions from 20 years, to 40,
           to 60 and so on, so this is sort of a time dependent
           element of this, how fast we can go.
                       Very quickly, package performance studies
           is related to transportation cask beyond  - looking at
           beyond design basis types of events.  Marty indicated
           that, and we're looking at things like high speed
           impact, and fires and so on, as part of the  - when I
           say we're looking at, I'm sorry.  Let me clear it  -
           clarify it.  We developed a plan, and we need to get
           international support to  - we can elaborate our
           resources, and a number of countries have indicated
           very strong interest, and I don't anticipate a big
           problem in moving forward on that.
                       Radionuclide transport, John, there was
           very extension discussion, workshop.  Let me not  -
           I'm looking forward to your report on that workshop
           because it would be very useful to get your insights
           on where you see things are going.
                       I already touched on the whole issue of
           looking at the full cycle for these new reactors.
                       MEMBER KRESS:  Are you doing anything more
           on spent fuel pools?
                       MR. THADANI:  Spent fuel pools, some of
           the work we're doing can be  - let me say, I can't
           talk about what we're doing as a following to the 9/11
           event.  We're doing some work there, but in terms of
           the source term, some of the other work we're doing
           can be of value to spent pool fuel issues.
                       Let me just quickly say that both  - you
           know, the expert panel which was headed by
           Commissioner Rogers and others, have clearly indicated 
           need that we in the Office of Research need to do a
           better job of telling what we're doing, why, and how
           it can be of value to the agency and the public at
                       There's sort of a synopsis.  I think you
           know of the paper that we prepared, lay out, vision,
           mission, role and responsibilities of research.  And
           I think you know what is confirmatory, and what is
           anticipatory.  Let me highlight two or three points.
                       We're going to  - we are embarked on a
           plan to do a much better job of communication,
           internal and external to the agency.  And a number of
           initiatives that we have, planned, some of them
           planned, others are ongoing.  But in terms of the
           internal communication, we have  - I think the biggest
           step that has helped us in terms of better
           communication has been what I call  - what I guess we
           call leadership team meetings.  At the division
           levels, there's very frequent contact between the
           offices, NRR and research in particular.  And I know
           Cheryl meets with NMSS folks on a weekly basis to make
           sure there is proper communication taking place.
                       I think that has improved our
           understanding of the challenges NRR has, and NRR's
           understanding of how the work we do fits in in terms
           of the decisions they have to make.
                       The other part that's I think helping us,
           and that we still have to go further is the Research
           Effectiveness Review Board.  I think you know
           generally what the plans are.  They've been focusing
           in largely on the user needs, and the process of user
           needs and follow through.  And that's going to
           continue, and I think it can only be of value to us. 
                       I want to highlight one item under
           anticipatory research.  You criticized us, and I think
           it was George, you in particular.  And I notice that
            - I wanted to get your attention, and actually it was
           Rogers Expert Panel also, that in anticipatory
           research, we were too inward looking, that we didn't
           seek ideas and concepts from a broader spectrum of
           audience, so I have just this week sent letters, first
           internally to NRR/NMSS regions, to research staff,
           briefly giving background, and seeking ideas from
                       I've also sent letters to Nuclear Energy
            - Nuclear Engineering Department Heads Organization,
           to NEI, to EPRI, to UCS, Nuclear Control Institute,
           and also in Federal Register Notice, making sure that
           we're not interested in just a lot of ideas.  We're
           interested in ideas which are focused on the areas
           we've identified.  And also, ideas that have a
           reasonable chance of success in terms of getting
                       We may well get some good ideas.  Clearly,
           we're not going to be able to consider them for this
           budget cycle, because we have to provide our input in
           a matter of six weeks or so, so it can't be done.  And
           I wanted to make sure that various organizations had
           enough time to really think about these things.  I'm
           seeking input by June 1st, and we will then set up a
           group that will evaluate the recommendations and
           ideas, and then we will consider them for the
           following budget cycle.  It's taken a year longer than
           I had hoped, but nevertheless, we are moving in that
                       The other point that I want to make that
           I think is helping in coordination is that we're now
           giving a number of briefings, for example, program
           review committee briefing and our research did it
           jointly, NMSS and research did it jointly.  I think
           these are good steps forward.  It's working better. 
           I think coordination is improved.  We need to go
           further, but it's going in the right direction.  With
           that I will stop.
                       MEMBER SHACK:  There's one exercise here
           that I happen to be the guinea pig that you did once
           upon a time, and it's never been repeated, but I
           thought it was quite successful, where you had a
           research program with an open meeting with the public.
                       MR. THADANI:  Yes.
                       MEMBER SHACK:  And then we had people from
           the NRC  - 
                       MR. THADANI:  Yes.
                       MEMBER SHACK:   - utilities, owners
           groups, and intervenor groups.  And I thought it was
           very successful.  I think the intervenor groups went
           away with a much better feeling that the NRC was
           getting some independent information.  They had a
           chance to ask questions, which you never can ask
           questions of a report, and all in all, it was a pretty
           successful thing.  And then, you know, it sort of  -
           we tried it once, and  - 
                       MR. THADANI:  Yeah.  I think you're
           exactly right.  I know when that meeting was held, and
           it went very, very well.  We have done a little bit
           more of that, but I think it's clear, and I'm glad you
           brought it up.  We need to maybe expand in that area,
           as well.
                       MR. TRAVERS:  That is a good point, as you
           probably.  I'm sure you know, that increasing public
           confidence is one of our four agency strategic goals,
           so we're always looking for some good ideas on how to
           achieve that. And frankly, it's a difficult thing to
           get your arms around in any particular forum. 
                       That does complete our presentation. I
           wanted to respond though.  I didn't mean to keep you
           waiting, Dana, on any negatives that we had, hold you
           in any suspense.  But the answer quite simply from a
           significant negative perspective, at least on our
           part, is that we don't have any.  We think we enjoy
           today the kind of professional relationship that is
           advantageous to our separate, but very related
           responsibilities, under statute.  Can we do better? 
           We can always do better.  Can we do better from our
           standpoint in providing documents in a timely way,
           getting input from you in a timely way to support some
           of our activities?  Of course.  But I think what I
           would like to send as a final message is that we very
           much appreciate the relationship that we do have.  We
           think its value added, frankly, from our perspective. 
           Do we agree with everything you recommend?  No, but we
           try to get back to you with reasoned basis for not
           agreeing in all instances.  But I would say that in
           many, if not most instances, we take and implement
           much of the recommendations and  - 
                       MEMBER POWERS: Well, I think the message
           I give you here is that I, certainly, and I think the
           Committee as a whole is not adverse to you coming back
           and saying something was not helpful.  Okay.  Some
           direction that we're taking, some approach that we
           take, something like that.  I mean, we can disagree
           with you too, but it's useful for us to know the
           downside, as well as the bright side.  And, I mean,
           some mechanism to just indicate something is not
                       MR. TRAVERS:  Okay.  That's fair.  I think
           we do have mechanisms for doing that, and we'll take
           that as a  - 
                       MEMBER POWERS:  Sure.
                       MR. TRAVERS:  Thank you.
                       CHAIRMAN APOSTOLAKIS:  Okay?  Well, any
           members have any comments, observations they would
           like to make?
                       MEMBER POWERS:  Ashok, you mentioned
           letters and a Federal Register Notice that you were
                       MR. THADANI:  Yes.
                       MEMBER POWERS:  Could we get a copy of
                       MR. THADANI:  Absolutely, yes.
                       MEMBER ROSEN:  I have one, George.
                       CHAIRMAN APOSTOLAKIS:  Sure.
                       MEMBER ROSEN:  I was struck by the fact
           that you did not ask the stakeholders directly, the
           licensees for input on the research program.  You did
           it through NEI.  I think it might be valuable for you
           to think about that.
                       MR. TRAVERS:  Thanks, Steve.  Yeah, I
           will, and I think I understand the message there.
                       CHAIRMAN APOSTOLAKIS:  Any other comments? 
           All right, gentlemen.  Thank you very much.  WE really
           appreciate your taking the time to come to talk to us,
           and let's hope that we'll do this again, maybe in the
           not too distant future.  Okay?  Thank you very much.
           We're recessing until 1:30.
                       (Whereupon, the proceedings went off the
           record for a lunch break at 12:35 p.m.)
           .                 A-F-T-E-R-N-O-O-N  P-R-O-C-E-E-D-I-N-G-S
                                                   (1:35 p.m.) 
                       CHAIRMAN APOSTOLAKIS:  Do we have a
           quorum?  One, two, three, four, five, six.  All right.
                       We're back in session.  The next item on
           the agenda is the Proposed Final Revision to
           Regulatory Guide 1.174 and SRP Chapter 19.
                       Ms. Drouin?
                       MS. DROUIN:  Okay.
                       My name is Mary Drouin with the Office of
           Research, the Probable Risk Analysis Branch.
                       CHAIRMAN APOSTOLAKIS:  Excuse me, Mary. 
           I was suppose to make an announcement.
                       MS. DROUIN:  Sorry.
                       CHAIRMAN APOSTOLAKIS:  You have this
           hand-out number 10 in front of you, members?  Number
           10?  You all have this?  It's very thick. 
           Reconciliation of ACRS Comments and Recommendations. 
           Please take a few minutes to read it today.  We're
           going to discuss it tomorrow.  It includes the EDO's
           response to our letter on the reactive oversight
           process, steam-generated, tube integrity.  There's a
           lot of good stuff here.  So please do that.
                       Okay, Mary.  Sorry.
                       MS. DROUIN:  Are we ready?
                       CHAIRMAN APOSTOLAKIS:  Yeah.
                       MS. DROUIN:  Okay.  I'm Mary Drouin with
           the Office of Research.  And today I'm here to give
           the committee a status of where we are in terms of our
           update on Regulatory Guide 1.174.  Part of that is
           also a status in the plan for endorsing the PRA
           standards.  For example, the ASME PRA standard, which
           is going to be coming out public very imminently and
           the industry program, particularly in the NEI-00-02,
           which is the Peer Review Certification Program.
                       We're here today not just to, of course,
           give you a status, but, as always, we solicit and
           welcome the committee's input on our work.  Because as
           we go through, we're going to go into detail what our
           plan is beyond updating Reg Guide 1.174.  And so we're
           in the midst of formulating this plan right now.
                       A lot of the basis for a plan -- before we
           get into it and where we are on the Reg Guide -- is
           that I think it's very important that we spend just a
           few minutes going back historically and why we are
           where we are today.  And this had a lot of input into
           some of the decisions we made in terms of our update
           and how we plan to endorse the standard.
                       If we go back to April 18th of 2000,
           that's when we received direction from the Commission
           that said the staff should provide its recommendations
           to the Commission for addressing the issue of PRA
           quality until the ASME and ANS standards have been
           completed, including the potential role of an industry
           peer certification process.
                       So a lot of that got started.  And we went
           through a very intensive effort.  And we issued
           SECY-0162, that I know the ACRS looked at.  And we
           actually received comments from the ACRS on that
                       But if you look at 162, what I've put here
           are four of the major things that the staff committed
           to in that SECY document, which are very important in
           terms of how we decided to update Reg 1.174 in our
           plan for endorsement of the standards.
                       First of all, one of the things that was
           in SECY-0162 is that we went through and we identified
           the scope and the minimal technical attributes at a
           functional level that were necessary to ensure that
           the PRA is capable of providing certain results.  And
           we listed those results, like core-damage frequency
           LERF, what the dominant contributors are out of a PRA
           on both a relative and absolute basis.  And all of
           that information was contained in that Attachment 1 to
                       Also in that document we had indicated to
           the Commission that, if appropriate, the staff would
           endorse them, meaning the standards, in an updated
           Regulatory Guide 1.174 -- but what's also important --
           or elsewhere to support other risk-informed
           activities.  Also, we indicated in that document that
           during our endorsement we may take exception of
           provide additional criteria in those places where we
           thought the standard or the industry program was not
                       And lastly, that the information that was
           contained in SECY-0162, particularly the two
           attachments, that we would include those in the update
           of Reg Guide 1.174.  And the basis for including that
           in there, because at the time I thought was to endorse
           the standards in the updated Reg Guide 1.174.
                       We did receive an SRM from that SECY.  And
           the main points that came out on this SRM is the
           Commission did tell us to proceed forward.  They
           wanted timely resolution to this.  And that we should
           expand our discussion on further examples.  In fact,
           we received a similar comment from the ACRS, the
           examples that were in Attachment 2, that if we could
           do more in that area, that would be good.
                       But that's all I was going to go in terms
           of background, and then I'll get right into where are
           we in terms of our status of Reg Guide 1.174.
                       We did issue a draft update of 1.174 and
           SRP Chapter 19 in June of 200, and we went out for
           public review and comment.  That update, there were
           four major changes that were included in that update.
                       The first one was, where we had new,
           unforeseen hazards, we would potentially ask for more
           information in that area.  Also, in regards to
           increasing in power level and fuel/burnup, there was
           some concern in terms of their impact on LERF, and
           that we may need to provide some additional guidelines
                       MEMBER ROSEN:  Is there something missing
           from that Number 2?  "Levels above megawatt thermal,"
           it says.
                       MS. DROUIN:  Oh, sorry; 3,800 I believe
           was -- 
                       MR. CUNNINGHAM:  Okay.
                       MS. DROUIN:  Also included in the update
           is, we took that information from Attachment 1, which
           was identification, a description of the minimal
           technical attributes.  That was added to the Reg Guide
           and to the SRP.  And also, the information from
           Attachment 2, which was a discussion on example
           applications using risk insights in the
           decision-making process.
                       MEMBER ROSEN:  Can you say something quick
           about how you picked that number?  3,800 I mean.
                       MS. DROUIN:  No.  This is not an area that
           I was involved in.  But let Mark answer that.
                       MR. CUNNINGHAM:  This is Mark Cunningham.
                       Traditionally, there's been an implicit,
           unofficial limit to the allowable reactor power for
           lightwater reactors that's been floated around the
           Commission.  And that was 3,800 megawatts.  It's not
           a legal restraint or anything like that.  But it's
           been the presumed maximum legal power that -- 
                       MEMBER ROSEN:  So it's a legal thing,
           really, not so much impact on LERF.  I mean, because
           nothing happens between 3,800 and 3,801 to LERF.
                       MR. CUNNINGHAM:  That's correct.  The
           interest was, if you wanted to go to 4,000 or
           something like that.  At some point, the LERF
           criterion would be affected.  And this was putting a
           proviso in for public comment that we may need to
           revisit that if you went substantially above 3,800. 
           You're right.  If it went to 3,801 or 3,860 or
           something like that, we don't expect it would change.
                       MS. DROUIN:  If you look at the second
           sub-bullet there, it does indicate that it's not
           expected to have an effect.  But there is some -- from
           my understanding, there are some experts out there
           that aren't necessarily in agreement, so this is still
           a topic under discussion.
                       MEMBER ROSEN:  Well, that's not what the
           second bullet says, Mary.  I beg to differ.  It says,
           "increases in fuel/burnup beyond 40,000 megawatts." 
           So it doesn't talk about the power level.
                       MS. DROUIN:  You're right.  You're
           correct.  You're correct.
                       MR. CUNNINGHAM:  The concern was -- in
           effect, the original concern was the combination of
           perhaps going to higher powers, plus burnup, plus the
           potential in there for use of mixed-oxide fuel.  So a
           combination of several things that led to the concern
           about LERF.
                       MEMBER ROSEN:  Okay.  Thank you.
                       CHAIRMAN APOSTOLAKIS:  Now, in the
           discussion of example applications using these
           insights in the decision-making process, are you the
           staff prepared to ask the industry to do an
           uncertainty analysis, the standard uncertainty
           analysis, in all applications, considering that as
           part of the risk insight?
                       MS. DROUIN:  If you look at Reg Guide
           1.174, there is a discussion there on certainty, and
           they are suppose to address uncertainties.  The level
           at which you're going to address the uncertainty is
           not going to be the same on every application.
                       CHAIRMAN APOSTOLAKIS:  But the propagation
           of uncertainty is due to uncertainties in failure
           rates and frequencies of initiating events.  It's sort
           of a routine kind of thing now with the computer
           programs that are available.
                       Why don't we ask everybody to do that? 
           And then the rest of it can be addressed as
                       CHAIRMAN APOSTOLAKIS:  When it comes to
           your parameter uncertainties, the standard right now
           does ask for them to do that.
                       CHAIRMAN APOSTOLAKIS:  In all
                       MS. DROUIN:  Well, the standard doesn't
           get into applications.  It's application-independent.
                       CHAIRMAN APOSTOLAKIS:  But I remember
           there were three columns.  In one column they said,
           mean values are good enough.  That's not true anymore?
                       MS. DROUIN:  The middle column of the
           standard, which is your best practice, does ask them
           to do that.
                       CHAIRMAN APOSTOLAKIS:  To do uncertainty?
                       MS. DROUIN:  Yes.
                       CHAIRMAN APOSTOLAKIS:  Okay.  Wonderful.
                       MEMBER KRESS:  Mary, before we leave this
           slide, I just now got through reading Number 2 under
           your second bullet.  And the second sub-bullet under
           there, what's the basis for saying that "increases in
           fuel/burnup are not expected to have an appreciable
           effect on LERF guidelines"?
                       MS. DROUIN:  Again, I'm going to turn this
           back over to Mark.  You're out of my area of expertise
           on this one.
                       MR. CUNNINGHAM:  In effect, what the
           committee's getting at is the same issue that was
           raised in public comment, that this is a rather vague
           type of -- perhaps we need to do this if you go above
           this.  And it wasn't very well founded as to why
           3,800, why 40,000, and that sort of thing.  And Mary
           will come back later to how we're dealing with that
           public comment.
                       We got the same comments.  And I think
           we've decided we're going to take an action to be much
           more definitive about this, that say we'll do some
           work to say, is there any reason to believe that the
           LERF criteria in 1.174 would be compromised if we went
           substantially above these things.  We're putting the
           burden back on us  in effect.
                       MEMBER KRESS:  I don't even like the way
           it's stated, because, of course, it's going to be an
           effect if you go beyond -- you meant to say
           substantially beyond 70,000 or something?
                       MR. CUNNINGHAM:  Yes.  Yes, exactly.
                       MEMBER KRESS:  Well, you'll need to come
           up with some level of burnup where you think the LERF
           criteria ought to be corrective.
                       MR. CUNNINGHAM:  Yeah, that's right.
                       MEMBER KRESS:  That's the idea.
                       MR. CUNNINGHAM:  And in effect, that's
           what we're doing.  We're going to take the
           responsibility back on ourselves to do that sort of
           calculation, rather than have this sort of vague
           guidance out there that licensees, perhaps, wouldn't
           know what to do with, or probably would not know what
           to do with.
                       MEMBER KRESS:  Are we going to take
           advantage of the PIRT that's undergoing?
                       MR. CUNNINGHAM:  Yes.  That's the expert
           panels, the rest of that -- 
                       MEMBER KRESS:  Oh, that's what you mean. 
           That's what you're talking about.
                       MR. CUNNINGHAM:  That's right.  That's a
           veiled reference to the PIRTs that have been going on. 
           Yes, sir.
                       MEMBER KRESS:  Okay.  I appreciate that.
                       MEMBER ROSEN:  I think you've said all the
           right words now.  But licensees who are at 3,800
           megawatts -- and I know one in particular -- will need
           to know ahead of time what they're about to run into
           if they want to increase their power level.  What are
           the additional requirements implied by these bullets?
                       MR. CUNNINGHAM:  Yes.  And, again, that
           was the type of comment we got, and it's a legitimate
           comment. And we're going to have to resolve that
           separately.  And again, given what we know about LERF,
           we don't expect if they went from 38 to 39 -- 
                       MEMBER KRESS:  Before you leave this slide
                       MS. DROUIN:  It's the same slide.
                       MR. CUNNINGHAM:  But we need to clarify
                       MEMBER KRESS:  I have one more comment on
           this business of LERF and 1.174.  1.174 doesn't seem
           to deal with sites that have multiple units on it,
           more than one plant.  It's my view that LERF is a site
           criteria.  And that 1.174 ought to recognize that, and
           talk about the effect of multiple units on a site in
           terms of your LERF criteria that you're going to use
           in 1.174.  That's a comment you need to think about.
                       MR. CUNNINGHAM:  You're right -- 
                       MEMBER KRESS:  In multi-unit sites, it
           ought to have some influence on your LERF criteria.
                       CHAIRMAN APOSTOLAKIS:  Which is really 
           relevant to PBMR.
                       MR. CUNNINGHAM:  Understood -- advance
           reactors are -- 
                       CHAIRMAN APOSTOLAKIS:  No, but it's the
           same idea.
                       MR. CUNNINGHAM:  Oh, I understand.  Yes.
                       CHAIRMAN APOSTOLAKIS:  You have 10 modules
           there, I mean, you can't expect the criteria to be the
           same as if you had one.
                       MR. CUNNINGHAM:  Yes.
                       MEMBER KRESS:  And if you had more than
           one reactor on the site, you couldn't expect the same
           LERF criteria.
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MS. DROUIN:  Continuing with the same
           discussion, all I've shown on the next slide is the
           comments we did receive in these four areas in terms
           of the unforeseen hazards, we didn't receive any
           comments from the public.  And as the discussion's
           been going on, you aren't surprised by the comments we
           got.  We know that there was no justification for it. 
           We know we needed to provide -- if we have that in
           there, to provide additional step guidance.
                       And then we also, in terms of the
           information from 162, the two major comments we got is
           that there was inadequate explanation of discussion
           for the purpose and use of the information,
           particularly, as it pertained to the information from
           Attachment 1, which got into the minimal technical
           attributes, and also a lot of comments we got that
           this was the inappropriate document to include that
           information in.
                       So based on that, where we are in terms of
           the update for Reg Guide 1.174 in those four areas, is
           that in terms of endorsing the PRA standards and the
           Peer Review Program is that we would endorse that
           elsewhere in a different document and not in Reg Guide
           1.174.  So our plan at the moment is to issue Reg
           Guide 1.174 with three of those changes.  And one of
           them is still iffy.  We have some work to do to
           determine whether or if we're going to be doing it.
                       First, in terms of the unforeseen hazard,
           as I said, we've received no comments on that, so that
           part of the updates to Reg Guide 1.174 would remain. 
           In terms of SECY-0162, the information from Attachment
           1, which is the minimal technical attributes, that
           information has been stripped out.  But we are leaving
           in the information in terms of the examples.
                       In terms of the increase in the power
           level and fuel/burnup, as Mark indicated, we still
           have some more discussion ongoing to determine if we
           will keep that in there; and if we do, to what extent
           to how we will have it in the document.  So the
           decision hasn't been made yet on that particular item.
                       MEMBER ROSEN:  Mary, your first bullet, I
           would have expected that to say, "Endorse industry
           standards/Peer Review Program," rather than "or,"
           since the Peer Review Program is embedded in the
                       MS. DROUIN:  I'm sorry.  That is a typo. 
            That should not be an "or," it's an "an."
                       MEMBER ROSEN:  It should be?
                       MS. DROUIN:  That's an "an."  Thank you.
                       MEMBER ROSEN:  Okay.  Now I'm happy.
                       MS. DROUIN:  It's not an "or."
                       MEMBER ROSEN:  Right.  The Peer Review
           Program is part of the industry standard, right?
                       MS. DROUIN:  Yes.  Thank you.
                       MEMBER KRESS:  Your first sub-bullet under
           the second bullet, when you may call for more
           risk-related information, do you see that as a
           sufficient handle for you to get the information when
           you need it?  If you -- I don't know.  If I had a PRA
           that told me that the increase in risk were something
           beyond which I'm comfortable with, then I could say I
           need a PRA.  It's a circular argument.
                       How do you make these judgments without
           having a PRA in the first place?
                       CHAIRMAN APOSTOLAKIS:  You mean the first
                       MEMBER KRESS:  The first sub-bullet under
           the second bullet.
                       CHAIRMAN APOSTOLAKIS:  Yeah, risk-related
                       MEMBER KRESS:  Yeah.  You need to know
           what the risk implications are before you ask for the
           risk information.  I'm having trouble figuring how you
           do this circularity.
                       CHAIRMAN APOSTOLAKIS:  I'm troubled for
           this, but for an additional reason.  1.174 is intended
           to apply to risk-informed applications, not to general
           applications.  So I don't understand what that means.
                       MR. CUNNINGHAM:  If I might, we might go
           back a year or two in history on this.
                       This issue was subject to committee
           meetings and a commission paper, and an SRM probably
           a year-and-a-half or so ago.  The starting point of
           the potentially circular argument is, a licensee
           chooses to come in with a proposed license amendment,
           and the licensee does not choose to use risk
                       CHAIRMAN APOSTOLAKIS:  And that's what's
           confusing me.
                       MR. CUNNINGHAM:  Yes.
                       CHAIRMAN APOSTOLAKIS:  Because then 1.174
           does not apply.
                       MR. CUNNINGHAM:  However, this is a
           statement in 1.174 that said, "if the licensee does
           not submit the information, the staff has the
           authority to request the information on the risk" --
                       CHAIRMAN APOSTOLAKIS:  It's already
           something in the books that says, if it's an issue of
           article protection, you can do that.  Does this go
           beyond that?
                       MR. CUNNINGHAM:  This is a clarification
           of that in effect.
                       CHAIRMAN APOSTOLAKIS:  So it goes beyond,
           because this doesn't have to be article protection.
                       MR. CUNNINGHAM:  I believe so. 
                       CHAIRMAN APOSTOLAKIS:  Oh.
                       MEMBER SHACK:  So it's not new policy.
                       MR. CUNNINGHAM:  This is not new policy.
                       CHAIRMAN APOSTOLAKIS:  But the original
           policy was you had to justify it in terms of article
                       MEMBER SHACK:  Undue -- what's the word?
                       CHAIRMAN APOSTOLAKIS:  Undue risk is the
           same thing.
                       MR. CUNNINGHAM:  That's right.  And we
           didn't come in prepared to go back to the discussions
           from a year or two ago.  But all of that was discussed
           in the commission paper of a year or two ago that -- 
                       CHAIRMAN APOSTOLAKIS:  It seems to me this
                       MR. CUNNINGHAM:  You may remember Bob
           Halep was the staff contact on that.
                       CHAIRMAN APOSTOLAKIS:  I remember that. 
           And the whole thing had to do with undue risk or,
           equivalently, article protection.
                       MR. CUNNINGHAM:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  And now it seems
           it's going beyond that, which is fine with me.  It's
           going in the right direction.
                       MEMBER ROSEN:  I was wondering if you were
                       CHAIRMAN APOSTOLAKIS:  No, I'm not
                       MR. CUNNINGHAM:  This is an incorporation
           of what the Commission approved about a
           year-and-a-half or so ago into this regulatory guide.
                       CHAIRMAN APOSTOLAKIS:  I'm just wondering
           why it's here and not somewhere else.  It should be in
           the deterministic guides, regulatory guides.
                       MR. CUNNINGHAM:  It may go there as well.
                       CHAIRMAN APOSTOLAKIS:  You're coming for
           this.  But because of this, we want you to also do
                       MR. CUNNINGHAM:  This is not the only
           place that this comes in.
                       CHAIRMAN APOSTOLAKIS:  Ah.  It's a
           multiplicity of things.
                       MR. CUNNINGHAM:  There are a multiplicity
           of places that this guidance shows up.  I believe the
           principal place is to go over to the people who would
           -- guidance to those people.
                       CHAIRMAN APOSTOLAKIS:  You're going in the
           right direction anyway.
                       This business of integrated
           decision-making process, where the analysts -- not the
           analysts -- the staff has to take into account risk
           information, difference in depth philosophy, margins
           and so on, we never really told them how to do that. 
           And I understand that in the revised version it's also
           -- I mean, that you have not touched.
                       Are people comfortable about this?  I
           mean, it's so subjective it seems to me.  Not that I
           know how to do it better, but should we be trying to
           understand a little better the whole process and go a
           little beyond?  I mean, we're just giving five boxes
           now with arrows.  And we're saying there's going to be
           this integrated decision-making in the middle, somehow
           taking into account the margins, somehow taking into
           account difference in depth, and somehow taking into
           account the risk insights.
                       Can we be a little more explicit some time
           in the future?
                       MR. CUNNINGHAM:  I think we could.
                       CHAIRMAN APOSTOLAKIS:  And there is a
           beautiful discussion on uncertainty.  And then, of
           course, the staff was not requesting uncertainty
           estimates, but now you're saying you will.  So that's
           a good thing.
                       MR. CUNNINGHAM:  The ASME standard does. 
           But, yes.
                       CHAIRMAN APOSTOLAKIS:  Which is good.
                       MR. CUNNINGHAM:  Yes, which is good.
                       CHAIRMAN APOSTOLAKIS:  Not because I can't
           see you disagreeing with -- let's go to a subcommittee
           meeting if you do.  But this issue of decision-making
                       MR. CUNNINGHAM:  Yes.  One of the issues
           that has kind of -- well, the ACRS raised it last year
           in their report on research, and we've been mulling it
           around, of kind of lessons learned from these
           decisions or similar types of decisions-- is there
           something that could be done better or clear guidance
           provided and that sort of thing.  It's a fair
           question.  And we're formulating our research budget
           for next year and things now.  And that's one of the
           things that's on the table-- is there value to that
           work in that area.
                       MEMBER ROSEN:  I happen to have a problem
           with that.  I think, George, what you're asking for is
           some guidance on how to think.
                       MEMBER POWERS:  I definitely need that.
                       MEMBER ROSEN:  I serve on one of these
           expert panels still, and have for a long time.  And I
           think what it is, is that it's a process of
           integrating all of these issues -- 
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MEMBER ROSEN:  -- with a lot of experience
           and knowledge of a particular subject matter.
                       CHAIRMAN APOSTOLAKIS:  But Steve, it was
           the same thing with the senior management.
                       MEMBER ROSEN:  But I wouldn't know how to
           follow a procedure to do that.
                       CHAIRMAN APOSTOLAKIS:  Well, it doesn't
           have to be a procedure.  The senior management was
           doing the same thing, and the industry objected as it
           being too opaque.
                       MEMBER ROSEN:  Yeah.  But that was in the
           regulatory process.
                       MEMBER KRESS:  Now the public's going to
                       CHAIRMAN APOSTOLAKIS:  So the more
           transparent you make the process, the better off you
                       I repeat, I don't know of any methodology
           that will do this, but it seems to me that it's
           something that we ought to be thinking about.
                       For example, all this debate we've had
           among ourselves regarding the rationalist approach and
           so on.  That's part of what I have in mind-- let's
           understand better the margins.  Maybe one of these
           days it will dawn upon us that we should quantify
           those margins in terms of probabilities.  And then
           difference in depth and margins will not be so
           different.  But that's not something for tomorrow.
                       VICE CHAIRMAN BONACA:  But there are some
           rules, I guess, that come in as the stuff -- looks at
           these things coming in, I guess.  I tend to think the
           way that Steve does.
                       CHAIRMAN APOSTOLAKIS:  I'm not saying
           these are wrong -- this is the way to do it.
                       MEMBER ROSEN:  No.  There are clearly some
           rules.  And you, one of the authors of the papers that
           we've used -- hate to flatter you -- no, that's okay.
                       MEMBER KRESS:  Go ahead.
                       CHAIRMAN APOSTOLAKIS:  I'm above that.
                       MEMBER ROSEN:  We use papers by you and
           others on expert elicitation techniques in training of
           the members of the panel so they know what's going on
           when the chairman says, stop, I haven't heard from
           you, Tom, pooling out the quiet guy.
                       CHAIRMAN APOSTOLAKIS:   That's part of
           structuring the process.  Yes, all these things are
                       MEMBER ROSEN:  So it's not like these
           panels are operating without any guidance.
                       CHAIRMAN APOSTOLAKIS:  And I never said
                       The other issue -- there's a beautiful
           discussion -- in the original 1.174.  The model
           uncertainty, uncertainty and incompleteness.  And then
           what?  I mean, it's a demonstration that somebody
           understands these issues, but was it ever used by the
           staff.  And that's where these case studies of large
           measurement would be enlightening.
                       Did anybody open it up and say, well, when
           you Mr. Utility come here, look what we're saying
           here, have you tried to do this, say something about
           model uncertainty or incompleteness and all that?  Is
           it being used, or was it just something that was
           placed there to show that we have good people on the
                       Mary, why don't you continue?
                       MS. DROUIN:  Okay.  Well, if we aren't
           going to endorse -- 
                       CHAIRMAN APOSTOLAKIS:  You are going to
           endorse?  Whoa.
                       MS. DROUIN:  Let me finish my sentence. 
           If we are not going to endorse it in Reg Guide 1.174,
           what is our plan for endorsement?  And so that's what
           we're going to talk about now.
                       CHAIRMAN APOSTOLAKIS:  The standard.
                       MS. DROUIN:  The standards and NEI-00-02.
                       Well, if you look at the various
           risk-informed activities that we're involved in, you
           will see a lot of them use PRA information in their
           decision-making process.  And that leads you that
           there is a common element dependency.  And it leads
           into the question that the Commission keeps raising on
           PRA quality and trying to understand or get to know
           what is the level of confidence of the PRA results
           that you're going to use for your insights.
                       So this is a common thread, whether you're
           looking at Option 3, whether you're looking at
           licensing actions using Reg Guide 1.174, tech spec
           changes, your categorization.  They all have this
           common dependency there.  And we do feel very strongly
           that the PRA standards and that the Industry Peer
           Review Program can help in this area in terms of
           identifying your strengths and weaknesses.
                       So where we finally came to is that we
           felt there ought to be this single supporting reg
           guide and SRP to bridge that gap and answer that
           question that would kind of cross and support all
           these activities.
                       MEMBER KRESS:  Do you envision the reg
           guide to be binding on the SPAR models?
                       MS. DROUIN:  I'm sorry?
                       MEMBER KRESS:  Do you envision such a reg
           guide that would dictate the quality of the SPAR
                       MS. DROUIN:  I do know that when we sent
           out internally the Reg 14A.  And it didn't just start
           then.  But I know that Pat did look at the SPAR models
           to see how did they match up against the standard. 
           And there were some places that wasn't a match.  And
           my understanding is that it's his intent to correct
                       MEMBER POWERS:  Mary, the industry-review
           approach kind of goes through and looks at a
           licensee's PRA.  And comes back and says, well, you
           get an A here and a B here and a C here.  Then it
           says, this is good for this class of applications.  Is
           my characterization correct?
                       MS. DROUIN:  They don't give an overall
           classification for the entire PRA.  They give it on a
           -- I don't think they call it an element.  They call
           it -- I can't remember the word they use, but I'll use
           the word "element."  But on an element by element. 
           And they have like 110 elements in there that they
           look at.  And they grade it on an element-by-element
           basis.  But at the end they don't come in and say,
           this PRA can support; they do it on the individual
                       MEMBER KRESS:  If you were to endorse that
           and want to use, then, such a PRA that had these
           grades and the various elements, and you're wanting to
           say, now I want to use this PRA to do this with, how
           would you make that jump?
                       MS. DROUIN:  Well, that's no different --
           that challenge there is no different than the
           challenge we have on the ASME standard because the
           ASME standard also has the three categories.
                       MEMBER KRESS:  The three categories. 
           That's right.
                       MS. DROUIN:  For any given application,
           you do not need to have the same level of detail for
           every element.  You might have an application that's
           just dealing with, say, ATWS.  That doesn't mean,
           then, that you necessarily have to have a very
           detailed, robust LOCA analysis.  Maybe but for some
           other application you might need the LOCA, and you
           don't need the ATWS.
                       So for any given application, to have that
           vertical slice and say you need it to the same level
           of degree is not -- so you have to look at it on an
           element-by-element basis.
                       MEMBER KRESS:  So you identify which of
           those elements are important to your application, and
           see what grade you got in those.  Now, suppose four of
           them were important.  And one of them got an A, one of
           them got a B, and two of them got C's?  Do you take
           the lowest, and say, since we got C's in two of them,
           and they're important, I can't use it for this?  Or do
           you have a process for doing that?
                       MEMBER ROSEN:  Let me try to answer your
           question.  Mary, just step back for a minute.
                       MS. DROUIN:  Okay.
                       MEMBER ROSEN:  The persons who are
           submitting this application to the staff is the
           licensee.  He very well knows the grades he has in
           those areas, because he's already been peer certified. 
           And what he's probably done is made some priority cut
           on his certification and said, these five things I
           better fix right away because I've got applications
           that will be affected by them.  And the rest of them
           I don't care about for a while.  So he's made that
           judgment, and then improved his PRA in those areas,
           presumably, to support the applications he has in
                       MEMBER KRESS:  Does he have to go in and
           get another peer review?
                       MEMBER ROSEN:  No.  No.  But he does have
           to come to the staff.  At that point, he comes to the
           staff and says, okay, I want to this, risk-informed
           application.  The staff says, well, let me look at
           your peer certification.  He shows them that.  And he
           shows them, presumably, what he's done to fix the
           areas if they were in the area that have an effect on
           his pending application.  But that's the way I would
           see the process working.
                       MEMBER KRESS:  That could probably work.
                       MR. CUNNINGHAM:  So the fundamental tenet
           here is that a PRA doesn't have to be perfect in every
           area in order to do some small thing, to do something. 
           It's very application-specific and site-specific and
           application-dependent.  And that was where the
           industry and the staff could come together and agree. 
           Now we'll see how that plays out in implementation. 
           I think it will play out along the lines that I just
                       CHAIRMAN APOSTOLAKIS:  But they will not
           come to a staff and say, you don't need to review this
           element because we've got an A.
                       MEMBER ROSEN:  No.  Of course not.  I
           mean, they can say that, but I don't think they will.
                       CHAIRMAN APOSTOLAKIS:  The staff may
           choose not to pay much attention because of the A, but
           having an A doesn't mean much.
                       MEMBER POWERS:  If I'm an A and a 1, and
           I want a power uprate, and I want to do that on a
           risk-informed basis; and I come in and I say, okay,
           well, here's my analysis of operational events with my
           PRA with and without this power uprate, and I don't
           have a fire PRA, that's going to be okay?
                       MEMBER ROSEN:  I don't know how to answer
           your question.
                       MEMBER POWERS:  Well, say yes.
                       MEMBER ROSEN:  That's a heuristic device
           so you can say that's ridiculous?
                       MEMBER POWERS:  So I can go, aha, put the
           risk down in a term, and the risk assessment for N01
           is fire.
                       CHAIRMAN APOSTOLAKIS:  All because you
           don't know it's the risk because you haven't done the
                       VICE CHAIRMAN BONACA:  You are getting
           ahead of me.  The application you are quoting as an
           example, that's pretty broad.  I would expect that you
           would want to have a pretty complete PRA, if you want
           to make statements on risk information, because it's
           really a full licensing of the plant at the higher
           power level.
                       CHAIRMAN APOSTOLAKIS:  The point is that
           the A, B, C's are for the licensee.
                       MEMBER ROSEN:  1, 2, 3's.
                       CHAIRMAN APOSTOLAKIS:  The licensee gets
           an A from his peers.  He knows that when this element
           is done, the state-of-the-art work, the staff is not
           constrained.  The staff can review it and say we don't
           like it, right?
                       MEMBER KRESS:  So there's no need for the
           staff to endorse the peer review process then.
                       CHAIRMAN APOSTOLAKIS:  No.  Well, in
           principle, really, no.  I guess the industry wants to
           have some feeling that whenever they're doing all this
           effort, there is some receptivity.
                       MEMBER POWERS:  Here's what I'm concerned
           about, George.  We come in and we say, those parts of
           your scope that you've done and you've got an A on,
           but the real issue is whether the scope is right.
                       MEMBER KRESS:  You get an F on that.
                       MEMBER POWERS:  Sure.
                       CHAIRMAN APOSTOLAKIS:  I assume they
           thought about that.
                       MEMBER ROSEN:  That's right.  Was your PRA
           -- is it good in the areas that are important to the
           application you're proposing.  Staff will judge that. 
           And certain members of the staff -- and particularly
           sitting in front of us -- were active in the ASME PRA
           standard development; were you not?
                       CHAIRMAN APOSTOLAKIS:  Many was active.
                       MEMBER ROSEN:  Yes.
                       MS. DROUIN:  I was active.
                       MEMBER ROSEN:  So she has a good knowledge
           of the PRA standard -- 
                       MS. DROUIN:  I thought I might just have
           one meeting where I wouldn't hear those words.
                       MEMBER ROSEN:  I chose to use the words
           "active" and "lady."
                       CHAIRMAN APOSTOLAKIS:  She was the easiest
           person on the staff -- 
                       MEMBER KRESS:  We're not debating the lady
           part.  I mean, that goes without saying.
                       CHAIRMAN APOSTOLAKIS:  But don't forget
           those, Steve; that even if the staff along,
           ultimately, some of these things will come before us.
                       MEMBER ROSEN:  Yes.
                       CHAIRMAN APOSTOLAKIS:  And we're not bound
           by A's and B's and C's.
                       MEMBER ROSEN:  No.  You're not bound by
                       CHAIRMAN APOSTOLAKIS:  The meeting is
           getting out of hand.
                       MEMBER KRESS:  It's deteriorating.
                       CHAIRMAN APOSTOLAKIS:  Let's come back. 
           It's rapidly degrading.
                       MS. DROUIN:  Okay.  Well, let's try and
           explain a little bit of what our vision is for this
           new regulatory guide that we plan on putting together.
                       CHAIRMAN APOSTOLAKIS:  And which we will
           have an opportunity to review at some point?
                       MS. DROUIN:  Absolutely.
                       CHAIRMAN APOSTOLAKIS:  Good.
                       MS. DROUIN:  When we get to the schedule,
           you're going to see places where we've noted where
           we'd like to come back to the ACRS.
                       CHAIRMAN APOSTOLAKIS:  What is the status
           now regarding the 1.174, Mike?  Are we going to look
           at it again, or it's out now?
                       MR. MARKLEY:  Well, George, we don't have
           a document to review right now.  But the last letter
           we wrote was July 20, 2000, and it was a Larkins
           Graham.  And the committee has no additional comments
           or concerns on the proposed final revisions.  That's
           where we were.  You basically agreed with the license
           amendment process and using risk information when it
           was deterministic submittal if the staff felt the need
           to do more in terms of risk analysis.
                       CHAIRMAN APOSTOLAKIS:  So what we
           anticipate is that we may have to write another
           Larkins Graham or something?
                       MR. MARKLEY:  If and when the document -- 
                       CHAIRMAN APOSTOLAKIS:  If and when the
           document.  Okay.   Thank you.
                       MS. DROUIN:  Okay.  In the reg guide, the
           main body -- because we are proposing appendices with
           this reg guide.  But the main body is going to provide
           the guidance to the licensees on how to use the
           standards or the NEI-00-02 document, such that we
           would have the level of confidence of the results for
           that particular application.  So it's going to go
           through a lot of the discussion that ya'll just had in
           trying to answer those kind of questions.
                       But given that it's telling you how to use
           the standard -- and still at some point we need to say
           whether we agree technically with the standard or with
           the NEI-00-02.  If, for example, the standard came out
           and said on their initiating event analysis only look
           at transients for your initiators, well, we would
           disagree with that.  You can't just look at
           transients; you've got to consider all your
                       So that would be an example of something
           that would go into the appendix.  And that's where we
           would provide clarification or additional criteria so
           that we think that the document itself is technically
                       So our envision is that -- for example,
           Appendix A would address the ASME standard; Appendix
           B, NEI-00-02.  And as you know, ASME is not covering
           the full scope.  So as each of the different pieces of
           the standards would come out, those would be added on
           into another appendix.
                       MEMBER ROSEN:  Now, Mary, I'm sure you
           know of the OMB circular that talks about the desire
           of the federal government to use industry consensus
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MEMBER ROSEN:  Now, here you're talking
           about a process to not use industry-consensus
           standards, to go beyond them.
                       CHAIRMAN APOSTOLAKIS:  No.  The law is
           that industry-consensus standards should be used as
                       MS. DROUIN:  As appropriate.
                       CHAIRMAN APOSTOLAKIS:  And she's
           elaborating on the "as appropriate."
                       MEMBER ROSEN:  Yeah.  And I'm elaborating
           on that by saying that, certainly, the NRC staff's
           participation was extensive and welcome, most of the
           time.  Even when it wasn't, it was still given, and
           used, and ultimately reconciled.  And I will look very
           hard at anything that's in these appendices beyond
           what's in the standards.
                       Now, I'm talking about the standards, the
           industry-consensus standards, not NEI-00-02.  That's
           in a different class.  But anything beyond the
           standards -- where the staff feels it absolutely must
           take exception to or elaborate of the standards -- we
           really ought to be given a very hard look by NRC
                       MS. DROUIN:  And it is.  You go back to
           the letter on Reference 14A.  You might have seen
           Scott Newberry's signature, but trust me.  A lot of
           people beyond Mr. Newberry reviewed that letter. 
           Because we were transmitting here's where our concerns
           are on this final version.  So this is taken very
           seriously in terms of if we take exception.
                       VICE CHAIRMAN BONACA:  And it seems to me
           it is a little bit of a problem, because if I remember
           some of the early applications we saw with 1.174, some
           of the SERs were going at length to explain why
           something in the application was deficient, but you
           could endorse it because of consideration of this and
           that.  It seems as if the burden was on the staff to
           provide the reasons why the risk information coming
           from the application was justifiable; it was
           sufficient.  So I think it would be good to at least
           set the minimum standard of what you expect so that
           the reviewers don't have to -- are not forced to have
           that kind of degree of individual support of the
           application when they come through.
                       I understand your concern, Steve.  And I'm
           only saying, some of the early applications to me were
           not very satisfactory, the SERs.
                       MEMBER ROSEN:  Well, we're all learning. 
           But I think the best possible result would be to have
           a standard that the NRC was able to endorse without
           qualification.  And we may not get there, but we
           really need to minimize, if we can, somehow the degree
           to which the staff needs to put on additional
           requirements beyond the industry-consensus standard.
                       CHAIRMAN APOSTOLAKIS:  Actually, I think
           this someone had mentioned earlier.  But it's not
           clear to me, really, what the word "endorsement" means
           in this case.  And I don't know what you guys are
           going to do if in the future somebody comes before you
           and says, I have done what the standard says.  You
           have endorsed it.  I expect an answer from you in a
           week.  You don't have to review it.  What are you
           going to do?  Are you going to say no? 
                       MEMBER POWERS:  That's a good answer.
                       CHAIRMAN APOSTOLAKIS:  No?
                       MEMBER POWERS:  The answer is no.
                       CHAIRMAN APOSTOLAKIS:  So why all this
           fight, then, about endorsement?  I mean, if that's the
           case.  It's really internal to the industry document
           telling them, look, this is what the staff expects of
           you.  But you prefer to go through a review if they
           choose to do that.
                       MEMBER POWERS:  This is an acceptable
                       CHAIRMAN APOSTOLAKIS:  But that's what I'm
           saying.  If they tell you I met all your requirements,
           therefore, it's acceptable.  Don't review it.
                       MEMBER POWERS:  Well, you've got to find
           out if they, in fact, carried out the method properly.
                       MEMBER SIEBER:  Or used some other ones.
                       CHAIRMAN APOSTOLAKIS:  Then you come back
           and you say, look, for common-cause failures, you
           really did this and should have done something else. 
           The standard doesn't say anything about that.  The
           standard says, do a common-cause failure analysis. 
           Isn't that what it says? 
                       MS. DROUIN:  Well, it says a little bit
           more than that.
                       CHAIRMAN APOSTOLAKIS:  It goes beyond
                       MR. DUDLEY:  Just as a matter of public
           record, in case someone wants to look up what the
           circular says, it's OMB Circular, A-119.  But what
           Mary's describing is really somewhat consistent with
           how we endorse industrial standards and have for year. 
           If they're exceptions and clarifications, we usually
           note it in the body of the supporting document.
                       MEMBER POWERS:  And Steve is going to
           scrutinize that, for these exceptions and
                       CHAIRMAN APOSTOLAKIS:  Anyway, we'll have
           to wait and see the standard itself.
                       MS. DROUIN:  I mean, at this point in
           time, whether or not we have exceptions, I can't
           answer that.  We're in the midst of reviewing the
           final version.
                       All we are trying to show on this figure
           is looking at it and trying to show the relationship
           of all these different documents and activities that
           we're talking about.  If you start there at the top
           level where you have some regulatory activity -- this
           is not meant to be complete; this is just an
           illustration with some examples shown there.  But if
           you have some examples -- like licensing actions,
           categorization, Option 3.  Those were the three
           examples I picked.  And if you come there across the
           right, if I look at Option 3, 5046 right now, we're in
           the midst of risk-informing the ECCS reliability
           requirements.  Underneath that you'll see inputting
           into it, there will be some regulatory guide that will
           go with that rule.
                       If you look at your licensing action,
           somebody does something where they want to come and
           make a change to their licensing basis, there's a
           regulatory guide supporting that, Reg Guide 1.174.  On
           your tech specs, say they're going to do a
           risk-informed techs spec change, there's a regulatory
                       So the point is, is that you got these
           things here, but also in the decision-making process
           for all of this is that they're using PRA information
           as one of the inputs.  And so that's where we talked
           about there's this common element for all of these. 
           And that's why in our mind, to endorse the standards
           in this document didn't make sense, because the
           questions that you're dealing with are the same kind
           of questions here and here, and potentially elsewhere. 
           And that's why we thought coming up with a single
           regulatory guide that would feed into all of these
           just make practically a lot more sense to us.
                       And that's where we divvied it up.  This
           is all the same guide.  This is just the appendices
           that supports that.  And this would provide the
           guidance on how to use the standards in the Peer
           Review Program.  And then if we wanted to take
           exception or add clarification on a particular
           standard, that would be in the appendix.
                       CHAIRMAN APOSTOLAKIS:  Mary, the box on
           the left, "Determine the confidence with which PRA
           results demonstrate," and so on.  Now, if the PRA has
           done parametric uncertainty analysis -- parameter
           uncertainty analysis -- essentially, what you're
           saying there is, you're asking them to think in terms
           of model uncertainty.  How good is the PRA in other
           words?  Right?  That's what you're asking them to do,
           but not in so many words.  Is that the level of, when
           we say, determine the confidence with which the PRA
           results demonstrate the technical attributes have been
                       MS. DROUIN:  Were needed.
                       CHAIRMAN APOSTOLAKIS:  Were needed.  Yes,
           were needed.  But this is really a question of model;
           isn't it?  Model adequacy?
                       MS. DROUIN:  Not necessarily.  I mean, to
           me, that would also be a question of data.
                       CHAIRMAN APOSTOLAKIS:  If I do a parameter
           uncertainty analysis, and I have a scarce data, I'll
           have a wide distribution.  But I have quantified.  Is
           that sufficient to answer this requirement, determine
           the confidence?  Is this my confidence, or I have to
           go beyond that and say, well gee, now they have used
           an HRA model which I know is kind of soft, and maybe
           I should be a little more cautious, without really
           saying how cautious you're going to be?
                       MS. DROUIN:  When we use the word
           "confidence" here we aren't using this confidence in
           the sense of your uncertainty analysis that would get
           into your levels of confidence.  That's not what that
                       CHAIRMAN APOSTOLAKIS:  Well, confidence in
           general means that.  It means how uncertain are you,
           how much do you believe, right?
                       MS. DROUIN:  Yes.
                       CHAIRMAN APOSTOLAKIS:  And what I'm saying
           is that you're asking them there to reflect on the
           whole thing.  Is there a need for a structuralist
           defense, in-depth approach?  And I wonder why we don't
           say that.
                       MR. PARRY:  George, can I -- 
                       CHAIRMAN APOSTOLAKIS:  Because that's
           really what you're asking them to do.
                       MR. PARRY:  -- can I put my two-cents
           worth in here?  This is Gary Parry from the staff.
                       I think the way to think about that box,
           rather than to worry about the technical attributes is
           to say, basically, it's to determine the confidence of
           which the PRA results have shown compliance with the
           acceptance criteria or guidelines that you're going to
           use in the decision-making.
                       CHAIRMAN APOSTOLAKIS:  It's either way.
                       MR. PARRY:  And it's specific -- but it's
           specific, though, to the PRA aspects of it.
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MR. PARRY:  So I think you're right in
           saying that what you're requiring here is actually
           what we describe in Reg Guide 1.174, where we say,
           show that the results that you have -- the conclusions
           that you're drawing are robust with respect to the all
           the sources of uncertainty that you can identify.  And
           that's really what that statement means.
                       CHAIRMAN APOSTOLAKIS:  But it's model -- 
                       MR. PARRY:  It's model uncertainty, and to
           some extent incompleteness as well.
                       CHAIRMAN APOSTOLAKIS:  Well, for me that's
           model -- but you are asking to reflect on that aspect.
                       MR. PARRY:  Absolutely.
                       CHAIRMAN APOSTOLAKIS:  And what I'm saying
           is that maybe it's time to start naming it, so people
           will know that you're interested in that.  And maybe
           six years from now people will start doing something
           about it.
                       MR. PARRY:  I suspect -- 
                       CHAIRMAN APOSTOLAKIS:  As long as you
           don't name it, people will not be aware of it.  That's
           what you're doing.
                       MR. PARRY:  I suspect the main body of the
           reg guide will actually address this.
                       CHAIRMAN APOSTOLAKIS:  Or in a footnote.
                       MR. PARRY:  No.  No.  I think in the
                       CHAIRMAN APOSTOLAKIS:  I mean, if I do a
           fire risk assessment -- I know some members here feel
           that this is the perfect PRA, but even there are
           weaknesses.  Right?  Dana, you agree?
                       MEMBER POWERS:  There are weaknesses in
           fire risk assessments.  Sure.
                       CHAIRMAN APOSTOLAKIS:  So they're doing
           all these funny things.  The domain of influence of
           fire down there is a cone with a 35-degree angle and
           all that.  Now, nature doesn't work that way.  It
           doesn't say I'm going to burn things that are inside
           the cone but not the ones that are outside.  That's an
           approximation.  That's a model approximation, right?
                       Now, if you ask me to quantify, I don't
           think anybody knows how to quantify that.  But it
           shakes my confidence in the results.  Okay?  So you're
           asking me to think about it.
                       MR. PARRY:  Right.
                       CHAIRMAN APOSTOLAKIS:  So that's a model
           uncertainty.  So please name it so people will know
           that you worry about it.
                       MEMBER KRESS:  Now, which word do you want
           to you use?  "Model"?
                       CHAIRMAN APOSTOLAKIS:  "Model
           uncertainty." Not "modeling."  "Model uncertainty."
                       MEMBER KRESS:  You want to use "model
                       CHAIRMAN APOSTOLAKIS:  Model uncertainty.
                       MEMBER KRESS:  Not some other name.
                       MEMBER ROSEN:  George?
                       CHAIRMAN APOSTOLAKIS:  No.  Model is part
           of our understanding.
                       MEMBER POWERS:  Come up with a good Greek
           word, would you?
                       CHAIRMAN APOSTOLAKIS:  We have enough
           problems with understanding.
                       MEMBER ROSEN:  Beyond this, just quickly,
           do you understand regulatory guides are not
                       MS. DROUIN:  Absolutely.
                       MEMBER ROSEN:  And the standard paragraph
           is going to go in the front of this regulatory guide. 
           It says, "Anyone caught using this will" -- 
                       MEMBER POWERS:  Something else.
                       MEMBER ROSEN:  Sure.
                       MEMBER POWERS:  And as a lot of times,
           money can come in -- 
                       CHAIRMAN APOSTOLAKIS:  This is an
           acceptable way.
                       MEMBER ROSEN:  An acceptable way.
                       CHAIRMAN APOSTOLAKIS:  Oh, you don't know
           how many times I was told that when we were developing
           1.174.  It's an acceptable way.
                       MEMBER ROSEN:  Well, this is the same --
           I understand how difficult that is.
                       CHAIRMAN APOSTOLAKIS:  It is very
                       MEMBER ROSEN:  But I'm thinking about --
           I'm really thinking of an advanced reactive area. 
           Some of this may not work so well.  So I don't know
           how general this is.
                       CHAIRMAN APOSTOLAKIS:  I think they have
           LWRs in mind when they do this.  Let's not try to be
           as general as we can in everything.  It's too much. 
           It's too hard.  But this is really LWR.
                       MEMBER ROSEN:  But my point is, that out
           is what made -- the advance reactive people may need
           to use them at those outs.  They may not be able to
           comply with a regulatory guide.
                       MS. DROUIN:  I can tell you right now, in
           terms of the ASME standards -- I certainly wasn't
           involved in any discussion with ANS, and I can't speak
           for NEA-00-02.  But as part as the writing team on the
           ASME, it was decided very clearly that this would only
           apply to LWRs.  That was a very deliberate decision
           made up front.
                       MEMBER ROSEN:  Okay.  Then I'm right.  I
           guess what I'm saying is that, if the ASME standard
           only applies to LWR, then this regulatory guide, which
           refers to the standard, obviously, can't apply to the
           advance reactive.
                       CHAIRMAN APOSTOLAKIS:  Although the
           standard itself, I don't see why you could not apply,
           or most of it anyway.
                       MEMBER SIEBER:  Does it say that
           specifically in the standard?
                       MS. DROUIN:  I know one version did.
                       CHAIRMAN APOSTOLAKIS:  Well, the reason
           why they might say it, Jack, is to avoid debate.  You
           know, stop thinking about future reactors; have we
           covered everything.  And I think they did the right
           thing if they say so.
                       MEMBER SIEBER:  If somebody was going to
           buy a future reactor, and didn't know what the rules
           were, though, I think that would put another bundle of
           uncertainty into whether that would be a good
           investment or not.
                       CHAIRMAN APOSTOLAKIS:  I doubt that the
           availability of an ASME standard to do a PRA would --
           would change their purpose.
                       MEMBER SIEBER:  Well, it's really a
           philosophical question.
                       CHAIRMAN APOSTOLAKIS:  No.  But you see
           why I'm saying that.  They've had a lot of problems
           proving this one for LWRs.  Now, if you ask them to
           think about future reactor applicability, they'll
           never finish.  And there is some urgency to this.
                       MEMBER SIEBER:  Well -- 
                       CHAIRMAN APOSTOLAKIS:  I mean, somebody
           else might want to -- 
                       MEMBER SIEBER:  I consider that a lot of
           conceptual elements, or a conceptual design of a new
           type reactor, would rely on some of the aspects of PRA
           as applied to that, and whether you have to contain it
           or not, for example.  They can almost add 30 percent
           on to the cost of the plant if you decide that that's
           what you're going to have to do to get the PRA spec.
                       So it should be versatile enough to be
           able to at least have some kind of an idea as to what
           kind of regulatory space you're in when you propose a
           new concept, it seems to me.
                       CHAIRMAN APOSTOLAKIS:  I would tie that to
           having a risk-informed licensing process.  Think about
           all that stuff there and go revisit the ASME standard,
           and say, yeah, most of it applies.  But I would think
           that as a separate activity because of its importance.
                       MEMBER SIEBER:  Okay.  Thank you.
                       CHAIRMAN APOSTOLAKIS:  That's what I would
           -- I don't know.  You want to think about future
           reactors in this context?
                       MS. DROUIN:  Well, I mean, I can just --
           I can give you my personal opinion.  I can also share
           with you some of the decisions that went into the
           standard.  I mean, the decision was made that this
           would not cover future reactors.  One of the reasons
           -- there were a lot of reasons.  But one of the main
           reasons is that this was not a standard to do a PRA. 
           This was a standard to support risk-informed
                       So if this were to be written as a
           standard that you wanted to pick up, and you were
           starting with a blank piece of paper and wanted to do
           your PRA, a lot of this would have looked a lot
           different.  It would have -- 
                       CHAIRMAN APOSTOLAKIS:  If the licensee was
           to come with an application, say for the PBMR, and
           they say, we did a PRA using the ASME standard.  Even
           if the standard says -- 
                       MEMBER SIEBER:  It would require
           additional review -- 
                       CHAIRMAN APOSTOLAKIS:  Some additional
                       MEMBER SIEBER:  -- to assure its validity. 
                       CHAIRMAN APOSTOLAKIS:  But it would carry
           some weight.  So they did comply.
                       MS. DROUIN:  Well, they could comply with
           some of it, but some of it's just not going to be
                       CHAIRMAN APOSTOLAKIS:  Exactly.  And they
           will decide.
                       MS. DROUIN:  Right.  Okay.
                       Now, given that we have this new
           regulatory guide, we wanted to just talk a little bit
           about how does this fit in, in terms of -- because,
           again, the ASME standard is just part of it.  What
           we're trying to show you is all the different pieces
           ultimately of where we'll be down the road.
                       As you can see, the ASME was only covering
           Level 1 and only part of a Level 2, full-power,
           internal events, excluding fire.
                       MEMBER KRESS:  Is any thought given to
           adding a late-containment failure criteria in 1.174? 
           You know, we had that big debate over whether late
           containment is a regulatory objective that ought to be
           part of the licensing changes.
                       MS. DROUIN:  Well, we're certainly going
           to deal with some aspects of late-containment failure,
           because -- we did have a meeting with NEI.  And they
           came in and was showing their interpretation of some
           stuff out of 1150, showing that late-containment
           failure was less than zero to your LERF.
                       MEMBER KRESS:  Of course.  But the point
           is, you don't want late-containment failures either. 
           And it seems to me like there ought to be some
           guidance in 1.174 related to late-containment
           failures.  If somebody comes in with a licensing
           change request that significantly affects that part of
           their protection, it seems to me that you guys would
           think that was important.
                       MS. DROUIN:  Absolutely.  I don't
           disagree.  I think this is an issue -- 
                       MEMBER KRESS:  Yeah, well, this seems to
           me like something that ought to be discussed in 1.174
                       MR. PARRY:  It's sort of there.  If you
           look closely, it's there in the concept, difference in
           depth, from maintaining the containment function.  And
           that's the approach that's being used.  And that's the
           approach I believe is going to be incorporated in
           NEI-00-04 to address things to like containment
                       MEMBER KRESS:  Yeah.  I would have rather
           seen some -- we've got something called LERF, large
           early.  I would like to see something called
           late-containment failure or LCF, and have a guideline
           on it that's numerical and deltas on that.  Another
           one of your created darkness charts.
                       MEMBER ROSEN:  Now, what distinguished
           early from late is late means after the implementation
           of moving people out of the way.
                       MEMBER KRESS:  Sure.
                       CHAIRMAN APOSTOLAKIS:  Basically.
                       MEMBER ROSEN:  Basically.  So when you
           crack to the adequate-protection standard, protection
           of the public's health and safety, the public are
           already gone.  So now you've got a whole different set
           of issues.
                       MEMBER KRESS:  You've got two safety
           goals.  One of them deals with prompt fatalities and
           one of them deals with latent fatalities.  This is a
           latent fatality issue.  It's also a land contamination
           issue.  And in NRC has that within their regulatory
                       MEMBER ROSEN:  I agree with you.  With
           respect to the land contamination issue, clearly we're
           on the same page.
                       MEMBER KRESS:  Yeah.  And there ought to
           be some criteria in 1.174 that deals with that.
                       MEMBER ROSEN:  We're not arguing.  All I'm
           saying is that there's a whole different set of
           considerations in order to develop -- 
                       MEMBER KRESS:  Oh, yeah.  You've got to
           have new guidelines, new deltas, new metrics.
                       MEMBER ROSEN:  New metrics, new
           guidelines, thresholds, et cetera.
                       MEMBER KRESS:  But it seems to me like
           1.174 is where they belong.  It deals with changes to
           the licensee basis.  And these are things you're
           interested in preserving, or preserving adequately. 
           And it's always bothered me that there's nothing much
           in there with respect to that, other than words like
           "you will also meet all the other regulations," and
           things like that.  You can construe that to have some
           meaning.  It seems to me that it ought to be in there
           explicitly.  But that's just my opinion.
                       MEMBER SHACK:  It's included more
           explicitly in the framework document.
                       MEMBER KRESS:  Oh yes.
                       MEMBER SHACK:  I don't see why you
           couldn't bring that right into -- 
                       MEMBER KRESS:  Yeah, the framework
           document definitely has it.  And that would be a good
           place to look to see how maybe to incorporate it in
                       CHAIRMAN APOSTOLAKIS:  And there's no need
           for a standard for Level 3 PRA because it's done so
           well, right?
                       Okay.  Shall we go on, Mary?  Twelve?
                       MS. DROUIN:  This one just shows right now
           what the status of these documents are.  ANSI has
           voted for the standard for ASME.  So that should be
           coming out imminently in the next couple -- they've
           got to go through a check-editing process, but it's on
           the way out the door is the point.  They're on
                       NEI-00-02.  We met with them because our
           initial review, they had asked us to review it.  But
           in the context of Option 2 applications only, we
           received a letter in December from NEI asking us to
           expand our review to all applications.  We are in the
           midst of doing that.  We plan to have preliminary
           comments back to them in March and final comments in
           May.  But that's still a preliminary schedule.
                       ANS.  Their schedule right now is to have
           a fire published standard by the end of December of
           this year for low-power shut down.  That's a year
           away.  In terms of the fire, they're only right now
           putting together their writing team for the standard. 
           So there's no schedule right now that's established
           for the fire part of it.
                       MEMBER ROSEN:  Mary, could I ask a
           question of our staff?  I don't remember seeing
           NEI-00-02.  Has it been distributed to the ACRS?
                       MR. MARKLEY:  We reviewed it about a
           year-and-a-half ago.
                       MEMBER KRESS:  It wasn't 02 then, was it?
                       MR. MARKLEY:  Yes, it was.
                       MEMBER KRESS:  Was it?
                       MR. MARKLEY:  Yeah.
                       MEMBER KRESS:  I thought it was 99-02.
                       MEMBER ROSEN:  I guess I wasn't in the
           loop at that time.  Would you see about getting me a
                       MEMBER POWERS:  You may be right, Tom. 
           But it's a 0002.  That I know.  And all members of the
           Fire Protection subcommittee have several copies of
                       CHAIRMAN APOSTOLAKIS:  And the one that
           applies to Option 2 is 0004.
                       MEMBER ROSEN:  Right.
                       CHAIRMAN APOSTOLAKIS:  What happened to 3?
                       MEMBER ROSEN:  They only do even numbers.
                       MEMBER POWERS:  Let me ask you a question,
           Mary.  You're a knowledgeable student of
           risk-assessment culture in this country.
                       Have there been enough prior PRAs done? 
           Has there been enough debate within the academic
           community to write something like a standard?
                       MS. DROUIN:  Personally, I think there is. 
           Is it going to be the ultimate standard?  No.  But I
           don't think you have to have every "i" dotted and "t"
           crossed before you can start writing a standard, in my
                       CHAIRMAN APOSTOLAKIS:  I guess the problem
           is that we don't even know where the i's are; let
           alone dot them.
                       MEMBER POWERS:  It seems to me that -- I
           think I'm not in an unusual situation of planting
           myself in total agreement with the chairman here, that
           whereas in PRA for normal operational events, lots of
           people do them.  And there are big conferences held
           often in lovely hotels.  One of the best, of course,
           is in Beverly Hills, I believe, and set a new standard
           by which such conferences were held in which people
           debate various aspects -- 
                       CHAIRMAN APOSTOLAKIS:  That was a Beverly
           Hills standard.
                       MEMBER POWERS:  Beverly Hills standard,
           right.  And it's been through a crucible of technical
           discussion of some magnitude.  Whereas, in the area of
           fire PRA, I find, first of all, less, and that that
           debate has largely been in the hands of those with a
           probablistic bent, and that my friends and
           acquaintances in the fire protection community have
           not weighed in to this discussion, whether
           phenomenologically things are about right; whether
           this cone that Dr. Apostolakis, should be 35 or 37
                       That kind of interchange -- I question
           whether that kind of technical debate, discussion,
           what not, has taken place to the point that you could
           write a standard with any confidence, that it would
           put useful constraints and guidance on the writers of
           a fire PRA.
                       MS. DROUIN:  Well, I think when you write
           any standard, I mean, I think it's obvious you've got
           to have the right people in there to get a decent
           standard.  And you want to make sure that you get a
           good cross-cut of all the different aspects with the
           different knowledge and the different variance and
           expertise involved in the process.
                       MEMBER POWERS:  So will this writing group
           have probabilists or will it have fire protection
           people, or will it have it both?
                       MS. DROUIN:  I hope it would have both, in
           my opinion.
                       CHAIRMAN APOSTOLAKIS:  I think it should
           have also people who understand fire phenomena.  I
           mean, there is a whole community out there.  I don't
           think they call themselves fire protection people.
                       MEMBER POWERS:  That's right.
                       CHAIRMAN APOSTOLAKIS:  It's fire safety
           scientists or engineers, familiar with all the
           experiments that have been done, the correlations that
           have been developed.  These are extremely important
           people to be represented in an effort like this.
                       MS. DROUIN:  I don't disagree.  I have no
           say so who's on this writing team.
                       CHAIRMAN APOSTOLAKIS:  We understand.
                       MEMBER ROSEN:  I do.
                       CHAIRMAN APOSTOLAKIS:  We understand.
                       MEMBER ROSEN:  I'm on the Steering
                       CHAIRMAN APOSTOLAKIS:  Oh, okay.
                       MEMBER ROSEN:  So I'm listening.
                       MS. DROUIN:  But I think it's critical
           that you get all these -- 
                       CHAIRMAN APOSTOLAKIS:  I mean, it would be
           a big mistake if you have only the PRA types and fire
           protection types.
                       MEMBER ROSEN:  Well, we're just getting
           started.  I'm speaking now for the ANS-RISC Committee,
           Risk-Informed Standards Committee.
                       CHAIRMAN APOSTOLAKIS:  Oh, just like the
           Option 2 risk?
                       MEMBER ROSEN:  Yeah.  It's called the
           RISC, which I'm on.
                       CHAIRMAN APOSTOLAKIS:  So you were
                       MEMBER ROSEN:  And what we're trying to do
           is put together a team now to write this.  So it's
           helpful to have these thoughts.
                       MEMBER KRESS:  I would spell it R-I-S-K.
                       MEMBER ROSEN:  It's a committee, and you
           don't spell committee with a "K."
                       CHAIRMAN APOSTOLAKIS:  Ms. Drouin, let's
           move on.
                       MS. DROUIN:  Okay.  We're very close to
           being done.  I just have one more slide after this
                       Some other related efforts that are
           ongoing, but they're a part of all of this.  You've
           probably heard about it.  I know you haven't seen
           anything.  But we have been working on what we call a
           data handbook that is to compliment the ASME, the
           standards that are ongoing.  And this handbook is
           getting more into -- it's a methods book, covering the
           sources and methods for doing your data, covering
           initiating events, components, failure rates, and
           equipment, non-recovery probabilities.  The thing I
           want to point out is it's not covering common cause,
           because there is a separate document that the NRC has
           produced.  So we aren't trying to replicate work
                       MEMBER KRESS:  I think it's a great idea,
           by the way.
                       MS. DROUIN:  Thank you.
                       The date there, though, for July.  Sorry,
           that's a typo.  That should have been August.
                       Another effort that's also ongoing to
           support the standards effort, is when you go and you
           look at Reg 1.174, also the standard.  The ASME
           standard refers to NUREG 6595 as an acceptable
           approach for LERF.  It's the document that gets them
           -- how to do a simplified LERF.  But it only covers
           full power.  We're in the midst of updating that to
           also cover low-power shut-down conditions to support
           the standards effort.  And we plan for that to go out
           in August of this year.
                       MEMBER KRESS:  Can we get it before it
           goes for public review?
                       MS. DROUIN:  You will receive it when it
           goes out for public review and comment.  Yes.
                       MEMBER KRESS:  At the same time?  Yeah. 
                       MS. DROUIN:  So in wrapping up, this is a
           tentative, preliminary schedule we've put together. 
           We did have a public meeting on Tuesday.  In fact, the
           schedule --  because of information we got from the
           public meeting, we revised the schedule as you see it
           today.  It might go through some more revisions. 
           That's why we're just saying it's preliminary.  We've
           met with ACRS today.
                       But right now what we're thinking about is
           that in March we will have a SECY that goes forward to
           the Commission.  Now, that date, though, is firm in
           terms of the SECY for transmitting the updated Reg
           Guide 1.174.  That will go forward.  Also attached to
           that SECY would be the plan for our endorsement of the
           standards in the industry peer review, which we've
           talked about today.
                       We also were thinking at that time -- we
           have been reviewing NEI-00-02 for all applications in
           submitting preliminary comments to NEI at that time. 
           One of the reasons that the comments wouldn't be final
           is one of the things we did learn at the public
           meeting is that NEI is working on a document that
           would show the differences between NEI-00-02 and the
           standard.  And we felt having that information, and in
           terms of our review of it, would be very important. 
           So we were changing the schedule to try and integrate
           that in there.
                       So we were saying preliminary comments in
           March, and then going final comments to NEI-00-02 in
           May.  Give them time to come back to us with their
           response.  And then in July we would go forward to
           release the draft reg guide, plus the appendices.  So
           we would have two appendices at that time-- Appendix
           A which would address the ASME standard, and Appendix
           B which would address NEI-00-02, and, of course, our
                       At the same time, we would go out with our
           draft version of the data handbook and a draft of
           NUREG-CR-6595, Rev. 1.
                       MEMBER KRESS:  What's the status of that? 
            Has it been started?
                       MS. DROUIN:  The status of what?
                       MEMBER KRESS:  The NUREG CR-6595, Rev. 1.
                       MS. DROUIN:  We started it about six
           months ago.  So it's been in progress.
                       MEMBER KRESS:  Is there some sort of a
           rough draft available?
                       MS. DROUIN:  Not at this point, not enough
           to -- 
                       MEMBER KRESS:  Would there be one
           available by, say, April?  I would really love to see
           that, even though it's draft and rough and not been
           approved, et cetera.  If I could get one.  But it
           would have to be in April.  It would be too late to
           get it after that.  I have a reason for wanting to
           look at it.
                       MS. DROUIN:  I don't know what our
           position is.  I mean, in terms of coming, to have it
           to a form to show the ACRS, I hesitate to say -- 
                       MEMBER KRESS:  No, I don't want it for --
           this is not for the ACRS; this is for me.  Just for
           personal use.  For my edification.
                       MS. DROUIN:  Well, we can talk off line on
                       MS. DROUIN:  He promises not to share with
                       MEMBER KRESS:  Yeah.  I promise not to
           even let them know what it is.
                       MS. DROUIN:  Okay.
                       MEMBER ROSEN:  Mary, what is the title of
                       CHAIRMAN APOSTOLAKIS:  It's the peer
           review document; isn't it?
                       MEMBER KRESS:  Yes, the peer review -- 
                       CHAIRMAN APOSTOLAKIS:  The peer review
                       MS. DROUIN:  It's a long title.  You know,
           Steve, I apologize.  I just don't remember.
                       MEMBER ROSEN:  But it's a -- 
                       CHAIRMAN APOSTOLAKIS:  Something like
           that.  Industry guidelines for peer review.
                       MEMBER ROSEN:  It's the one that lays out
           the peer review process.
                       MS. DROUIN:  Yeah.  It's the Peer Review
           Certification Program.
                       CHAIRMAN APOSTOLAKIS:  And up until now,
           it has been the only document that addresses the issue
           of quality PRA, right?  No, ASME had not been
           approved.  The only document out there -- because I
           know the foreign organizations are using N-00-02 to do
           peer reviews, because that's the only thing that's
                       MEMBER ROSEN:  Right.  But the substance
           of it, before it was called NEI-00-02, was part of the
           BWR Owners Group.
                       MS. DROUIN:  Is the BWR Owners Group.
                       CHAIRMAN APOSTOLAKIS:  That's right. 
           Well, that was a long time ago.
                       MS. DROUIN:  They're essentially the same.
                       Okay.  In August we were planning on
           coming back to the ACRS -- 
                       MEMBER POWERS:  You'll come alone.
                       CHAIRMAN APOSTOLAKIS:  Well, we aren't
           really meeting in August.
                       MEMBER KRESS:  We won't be here.
                       CHAIRMAN APOSTOLAKIS:  You can come.
                       MEMBER POWERS:  It's a terrific meeting. 
           You'll get no objections, and your presentation will
           go very quick.
                       MS. DROUIN:  Well, then, I love that idea.
                       I know when he had talked, the schedule
           looked differently then.
                       MEMBER ROSEN:  Yeah, that's June.
                       CHAIRMAN APOSTOLAKIS:  June?
                       MR. MARKLEY:  Yes, she's changed it to
                       CHAIRMAN APOSTOLAKIS:  Now when you say
           ACRS, you mean the full committee, right?  You don't
           mean the subcommittee?
                       MEMBER KRESS:  We could have a
                       CHAIRMAN APOSTOLAKIS:  PRA subcommittee?
                       MS. DROUIN:  No.  I think in August we
           were talking subcommittee.
                       CHAIRMAN APOSTOLAKIS:  Subcommittee?
                       MEMBER KRESS:  Oh.  Well, that's possible
                       MR. MARKLEY:  She's sliding the June
           subcommittee back to August.
                       MS. DROUIN:  Yes.
                       CHAIRMAN APOSTOLAKIS:  We have
           subcommittee, if that's what you'd like.  We're trying
           to avoid it.
                       MEMBER KRESS:  We're trying to avoid it,
           but we do.
                       MEMBER POWERS:  We only have subcommittee
           meetings in August when we know that Professor
           Apostolakis is in Greece.
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MEMBER ROSEN:  But he's not.  He's in
                       MR. MARKLEY:  Would late July do okay?
                       MS. DROUIN:  We'll get back with you. 
           We'll work something out.
                       Anyway, in our October -- sorry.  Back to
                       CHAIRMAN APOSTOLAKIS:  Yes?
                       MS. DROUIN:  We're also planning very
           quickly after releasing these documents for public
           review, is having a workshop to walk people through
           the documents.  This is a lot of information we're
           going to be putting out.  If it was just the reg
           guide, that would be -- but we have the reg guide. 
           Just to show you.  Here's the data handbook; it's a
           thick document.  You know, we're going to have NUREG
           CR-6595.  So a lot of information.  So we really
           thought having a workshop and walking everyone through
           these documents was going to be very important.
                       MEMBER POWERS:  Why don't we instead of
           having the subcommittee meeting in August just go to
           their workshop?
                       CHAIRMAN APOSTOLAKIS:  That's an idea.
                       MS. DROUIN:  That's -- 
                       MEMBER ROSEN:  It probably be more useful.
                       CHAIRMAN APOSTOLAKIS:  It also increases
           the presence of ACRS members to meetings.
                       Is the workshop going to be in Washington?
                       MS. DROUIN:  No decisions have been made,
           but I would like to think so.
                       MEMBER POWERS:  Or Las Vegas, someplace
           like that.
                       MEMBER ROSEN:  In August?
                       MEMBER POWERS:  Yeah.
                       MEMBER ROSEN:  412 degrees?
                       MEMBER POWERS:  It's 112.  What's wrong
           with that?  Relatively cool.
                       CHAIRMAN APOSTOLAKIS:  There's a
           suggestion by your vice chairman here.
                       VICE CHAIRMAN BONACA:  What about Crete?
                       MS. DROUIN:  Anyway, in August, we're
           talking about a 60-day public review and comment
           period.  And then hopefully come October, we would
           have all the comments back and hopefully time to go
           through them and understand them, and come to a
           resolution, and have another public meeting at that
           point to share what our position is on the comments. 
           And then come December, have  a SECY that would
           transmit this to the Commission for release.
                       CHAIRMAN APOSTOLAKIS:  Very good.
                       MEMBER KRESS:  Very good.
                       MS. DROUIN:  So that's -- 
                       CHAIRMAN APOSTOLAKIS:  Any questions for
           Ms. Drouin?
                       Well, thank you very much, Mary.
                       MEMBER KRESS:  Thank you.
                       MS. DROUIN:  Thank you very much.
                       CHAIRMAN APOSTOLAKIS:  We'll see you in
                       MS. DROUIN:  Right here.
                       CHAIRMAN APOSTOLAKIS:  We'll be back at
                                   (Whereupon, the foregoing matter went off
                       the record at 2:53 p.m.)
                       CHAIRMAN APOSTOLAKIS:  Okay, we're back in
                       The next item on the agenda is the PTS
           Technical Bases Reevaluation Project.  Dr. Ford, would
           you be kind enough to lead us through this?
                       MEMBER FORD:  George, this is a good
           engineering project. It was --
                       MEMBER POWERS:  How can it be a good
           engineering project, when it's got epistemic and
           aleatory --
                       MEMBER POWERS:  -- ain't no fire.
                       MEMBER FORD:  The last time we heard --
           the full committee heard about this project was about
           16 months ago.  Last month, the materials subcommittee
           had a full 1-1/2 days briefing on the progress on
           this, and you will find it very exciting.
                       However, we only got two hours, and
           therefore we're going to restrict comments to
           technical basis for changing the frequency of through-
           wall quick cracking.  Discussions on things such as
           acceptance criteria, that will be covered in a meeting
           in May. So --
                       MEMBER POWERS:  What is that --
                       MEMBER FORD:  -- I'll pass it on to Ed at
           this point, Ed Hackett.
                       CHAIRMAN APOSTOLAKIS:  I would like to --
           I was -- oh.
                       MEMBER POWERS:  You said, what part was
           going to be deferred to --
                       MEMBER FORD:  The discussions on, for
           instance, changing acceptance criteria due to
           containment failure, source terms, etc.  That will be
           put off until May.
                       CHAIRMAN APOSTOLAKIS:  And I would like to
           see a recent example of model uncertainty
           quantification in an HRA.  I looked at the viewgraphs
           from the subcommittee, and I'm not sure I found the
                       MR. HACKETT:  Why don't I go ahead and
           read off a few things while we're working through
                       First off, just to introduce the table,
           I'm Ed Hackett, and I'm Assistant Chief of the
           Materials Branch in the Office of Research.  To my
           right is Alan Kolaczkowski, and he's an expert in
           probabilistic risk assessment from Sandia National
                       To my left immediately is Mark Kirk, who's
           also in the Materials Engineering Branch.  And his
           expertise is in probabilistic fracture mechanics.
                       And also, Dave Bissett from the Simsab
           Branch in Research is with us also, and his expertise
           is thermal hydraulics.  So that's trying to represent
           -- you know, get the key disciplines aligned here for
           you so we can go through this.
                       It looks like we're close on slides here.
                       In addition to that, I can reference that
           there's -- these are the front people, particularly
           speaking for myself, for what's a fairly large team of
           people at NRC in general, including NRR, including our
           contractors, and also including the industry.
                       This has been kind of a first for us to do
           this on as participatory a basis as we have with the
           industry, and I think that's something that's really
           worked very well for us.
                       The other thing I just mentioned that's
           been very key to this has been the backing.  We've
           had, especially from our senior management in the
           Office of Research, particularly my division director
           Mike Mayfield, who's taken this on with a sort of
           personal vengeance -- those of you know Mike, you know
           what that means it brings to a project.  And also, a
           shift tonight.  So, we've had a lot of support, is the
           bottom line.
                       I guess we'll go ahead and go to the next
                       I really wanted to do three things for you
           today, and maybe I'll start by addressing a comment
           George made in the opening.  This is a very condensed
           version of a presentation or series of presentations
           that we did about a month ago for the subcommittee,
           where we tried to walk through the uncertainty
           treatment in the project that I believe was almost 180
           slides.  So, you'll see a much condensed version of
           that today.
                       I don't know if we'll get to exactly what
           Professor Apostolakis was looking for.  If we don't,
           we'll try and cover that some way.  But we'll make a
           good stab at that, and Alan especially will be here to
           address the human reliability aspects.
                       But, just a couple of quick things because
           I don't want to belabor, you know, my opening here. 
           The overall project status -- we started this, as some
           of you remember, in 1999.  There have been a lot of
           challenges along the way, both technical and
           otherwise, and still continue to be.  Also, schedule
                       I mentioned the industry participation
           that's been key to this thing.  We expect right now
           that the tech basis will complete this year in 2002,
           and we will do sort of a parallel handoff with NRR to
           initiate rulemaking activities. So hopefully later
           this year is -- that's part of the plan right now.
                       The second bullet there is, we're going to
           be, in this presentation, giving you results and
           insights from analysis of Oconee Unit 1, which was the
           first of four plants that are being evaluated in the
           process.  I guess I'll emphasize up front that these
           results are preliminary.  They also look, in our
           opinion, pretty good at this point, but we'll get to
           that in a minute.  But they are preliminary.  We're
           still working through finalizing that.
                       And then, a key part of this is describing
           the modeling process and the uncertainty
           quantification, particularly in the three areas of
           PRA, thermal hydraulics and probabilistic fracture
           mechanics.  I appreciate the help we got previously
           with the subcommittee.  There was some good dialogue
           there and some good comments, and it probably glazed
           over the members by the end of a day and a half worth
           of PTS.
                       One of the things we talked about in the
           way of some business aspect -- with Dr. Ford, we
           talked about the last time that we would probably be
           looking for a letter from the committee this time
           around.  If nothing else -- it's been a long time. I
           think Dr. Ford, when he led off the subcommittee
           meeting, had indicated that the last time there had
           been formal correspondence I think was about a year or
           a year and a half.
                       MEMBER FORD:  October 20, 2000.
                       MR. HACKETT:  Okay.  So probably at this
           point, we're -- it would be appreciated to have a
           letter from the committee.
                       I sat in this morning when you guys were
           grilling Shook and Sam and company. And Shook said you
           guys were up to speed on this, so I'm hoping that's
           the case.
                       We'll go to the next slide, which is --
           what I wanted to do here -- we had a day and a half
           the last time with 180 slides, so we came up with our
           emergency summary slide, just in case.  It's not quite
           an emergency here yet today.
                       MEMBER ROSEN:  I hope you change the
                       MR. BESSETTE: We did.
                       MR. HACKETT:  Oh, you did.  Well - never
           mind.  I still had "emergency summary slide".
                       So, also we translated to try and give it
           to you guys up front, where this is heading in plain
           language space.  The transients are obviously --
                       MEMBER WALLIS:  That's a wonderful
           development -- plain language space.  Please do it
           some more.
                       MEMBER POWERS:  But Graham, if you look,
           the end sentences were prepositions -- God help us. 
           This is all --
                       MEMBER WALLIS:  This is all one sentence. 
           It's all one sentence.
                       MEMBER POWERS:  If this is plain language,
           we're in trouble.
                       MEMBER WALLIS:  That's what plain language
           is.  Plain language does end sentences with a
                       MR. HACKETT:  You should have seen the
           other slide.
                       MEMBER WALLIS:  I think it's the only
           thing I can listen to.
                       MEMBER KRESS:  I think it's written in
                       MR. HACKETT:  But we do have Terry Dixon
           on the project.
                       MEMBER KRESS:  Oh, that's where it came
                       MR. HACKETT:  I don't know if we have
           Terry on the phone today; probably not.  But Terry's
           been another key member of this project at the
           Oakridge laboratory.  But I guess these kind of speak
           for themselves.  I won't necessarily go over those
           point by point.
                       The last point, though, on the cracks --
           our colleagues in the industry wanted me to make sure
           to say we are actually seeing more cracks as a result
           of -- or, I should say defects by virtue of the
           analyses that we've done, but they are more benign and
           not as large as we'd assumed before with the Marshall
           distribution.  You'll hear some more about that.
                       The four bullets that you see there are
           fairly consistent with what we figured would be the
           expectations on this project when we went into it, so
           we're happy to see the vector's in the right
                       MEMBER POWERS:  I haven't got a clue what
           the second one means.  Round operators --
                       MEMBER WALLIS:  It's all one big sentence
           with commas in it.
                       MR. HACKETT:  It is all kind of -- I'll
           apologize for it.  The English is not precise, I
           suppose.  But it's --
                       MEMBER WALLIS:  That's because it's plain.
                       MR. HACKETT:  Because it's plain.  It's
           colloquial and plain.
                       MEMBER POWERS:  Well, it's confusing.  A
           round operator --
                       MR. HACKETT:  We were paraphrasing from --
           we were paraphrasing from a summary that Bob Hardees,
           our industry colleague, did to the Water Reactor
           Safety Meeting about two years ago.  Really, it's in
           the presence or having operators that performed better
           than we gave them credit for because we didn't give
           them any credit previously.
                       MEMBER ROSEN:  In plants with operators,
                       MR. HACKETT:  There are a lot of ways to
           make the English better, yes.
                       CHAIRMAN APOSTOLAKIS:  Can we move on to
           the second or third slide.  This one creates more
           discussion than it deserves.
                       MR. HACKETT:  Let's go to "Project
           Status".  This is the one you'll see replicated
           throughout the presentation.  The approach -- and this
           has been discussed with the committee several times
           now.  The approach is really broken into the three
           primary technical areas:  PRA and event sequence
           analysis, thermal hydraulics and probabilistic
           fracture mechanics.
                       What we've tried to capture down in the
           matrix there is to show you where we are, and we're
           about done with Oconee.  It's -- in all the boxes,
           it's listed as "draft", but that should be about to go
           final this month.  The other ones are pretty much
           where you see them.  There's work beginning in all the
           other areas for the other plants.  And again, the
           schedule challenges are to have a lot of that done by
           basically the middle of this year --
                       MEMBER ROSEN:  I'm going to interrupt you. 
           I have read all this and all that.  And the main
           question I come up with is, what are you doing here? 
           Where are you going with all of this?
                       MR. HACKETT:  We'll get to that today. 
           And I guess, depending on the information that's
           you've had, where you are going -- to cut to the chase
           is a revised 10 C.F.R. 50.61 that will be less
           restrictive than it is now, hopefully, is where the
           thing's heading at the moment.
                       I might as well jump to the next slide.
                       That said, there's plenty of work
           remaining to get there -- to Dr. Rosen's question. 
           One of the things that Dr. Ford focused on the last
           time in terms of work remaining is QA, quality
           assurance, for the project.  We have work going on in
           QA, in all three key areas, and there were some
           comments from the subcommittee meeting on that.
                       The internal events analyses are really
           the thing that's going to create a lot of the schedule
           challenges for us in getting those done on time, and
           that's for the remaining plants -- primarily,
           Palisades, Beaver Valley and Calvert Cliffs.
                       Another issue came up -- and we'll get
           into this to some greater degree, too.  Because the
           initial risk --
                       MEMBER WALLIS:  Remind me -- these are
           only CE plants, is that it?
                       MR. HACKETT:  They're not.  Actually, they
           represent all the --
                       MEMBER WALLIS:  So, why just these plants? 
           Why not all plants?
                       MR. HACKETT:  A couple of reasons, and you
           get to one of the key questions in terms of
           generalizing this thing.  We attempted to replicate
           the work that was done before in the 1980s on the --
                       MEMBER WALLIS:  Because these are typical
           plants for covering all the major categories in the
                       MR. HACKETT:  Covering the major and
           triple-S vendors -- BNW Combustion, Westinghouse --
                       MEMBER WALLIS:  And if these are okay, you
           decide the others are okay, is that the idea?
                       MR. HACKETT:  We're going to try and make
           that argument.  And that's not going to be easy,
           either.  But that's -- resource-wise, that's going to
           be one of our constraints.
                       MEMBER FORD:  But Ed, you might also point
           out that two of them, Oconee and Calvert Cliffs, are,
           according to the (inaudible) regulations, fairly safe.
                       MR. HACKETT:  They are.
                       MEMBER FORD:  Whereas, Palisades and
           Beaver Valley are not.
                       MR. HACKETT:  Palisades and Beaver Valley
           -- just to get into that, by the current criteria in
           10 C.F.R. 50.61, Palisades and Beaver Valley are okay
           to the end of their current licenses, but they're just
           right there at the end of those licenses.  In those
           cases, it's 2011 and 2016, if I remember right, so we
           do have some time here before anyone is impacted, even
           in the current license period.
                       With the extended license period, we could
           get into probably a bit of debate or discussion over
           which plants may or may not be impacted.  But the
           bottom line is, we have some time to deal with this.
                       MEMBER KRESS:  The previous study just had
           Oconee and Calvert Cliffs and Monticello?
                       MR. HACKETT:  The previous study had
           Oconee, Calvert Cliffs and H. B. Robinson. 
           Unfortunately, we were not able to get -- the Robinson
           plant had some difficulties with participating, so we
           picked up Beaver Valley instead.
                       The external risk piece is an interesting
           piece for us.  We are just getting to addressing that
           now because we have -- right now with Oconee, one of
           the things you'll see is, we think we're a couple of
           orders magnitude down in the overall risk from where
           we thought we were, which is a good outcome.  But that
           also necessitates that we consider the impact of
           external events on the risk contribution.
                       The good news is, we have a funded task
           underway with Alan at Sandia that we're hoping is
           going to have some results probably this spring
           timeframe somewhere.  So, that work will be under way.
                       The last piece is the integration of this
           whole thing with regard to the risk criteria.  And
           there, we also have -- we're not prepared to discuss
           that in detail today, but we have some work in
           progress that's to result in a SECY paper, again,
           about the March, April time frame that's going to lay
           out the staff views on the risk criterion for the --
                       MEMBER WALLIS:  Is this going to lead to
           a reg. guide or something?
                       MR. HACKETT:  There are two pieces. 
           There's -- the main piece, of course, would be a
           revision to the rule itself, to 10 C.F.R. 50.61. 
           There's an associated regulatory guide, which is
           1.154, which takes you into the plant-specific case.
                       Right now, if it goes the way we're seeing
           things are going right now, we may end up with a
           situation where it might not be worth the resources to
           re-do the reg. guide.  If the screening criteria is
           relaxed to a great enough degree, it might be that
           nobody would ever engage with that reg. guide.  They
           haven't yet either, so I think that's one of the
           things we're going to have to look at in resource
                       MEMBER KRESS:  Let me ask you about the
           second bullet; I wasn't at the second subcommittee
           meeting.  We have these plants that are being
           irradiated, the vessels, and going on with time.  And
           they have these transients occasionally, but not very
           often, and thermal shocks, for example.  And so, your
           answer (inaudible) was, the vessel's going to survive
           at a certain level of risk over its lifetime.  It
           would seem to me like external events don't enter into
           that picture.
                       MR. HACKETT:  We're hoping it's a very
           small contribution.  I think --
                       MEMBER KRESS:  Can't you almost rule it
           out before you start by looking at frequencies?
                       MR. HACKETT:  -- I'll defer to Alan on
           that one.
                       MR. KOLACZKOWSKI:  I think it's a little
           difficult to do, the reason being that external
           events, as we all know, can have common cause types of
           effects, wherein in the internal -- as a 'for
           instance' -- where maybe you're worried about a
           turbine bypass valve staying open and therefore
           starting to cool the plant, and then the operator does
           or does not throttle, etc., they're pretty much
           independent actions.
                       But you could imagine -- take a fire, for
           instance causing hutch shorts in such a way that not
           only does it force the TBV to stick open but it also
           shuts down the reactor coolant pumps.  And now you,
           first of all, with one single event -- granted at a
           lower frequency -- but now one single event has caused
           multiple things to occur.  A cool-down effect -- and
           you've shut down the reactor coolant pumps because you
           affected the circuits nearby, and now you're also
           introducing the possibility of stagnation on top of
           the event that normally would have been another
           independent failure.
                       So, I think just on the surface, you can't
           just say, well, external events, we don't have to
           worry about.
                       MEMBER KRESS:  Okay.  I can see the
           possibility of the fire being one, but I think I would
           rule out earthquakes and floods and tornadoes, just
           right off the bat.
                       MR. KOLACZKOWSKI:  We certainly have some
           insights.  For instance, Calvert Cliffs has a current
           PRA that has PTS involved along with the rest of the
           PRA, the normal station blackout and all these other
                       If their analysis is any indication, it
           looks to them that, from an external event point of
           view, the two that you need to worry about are fires
           and internal floods.  Now their results, just taken on
           the surface, do suggest that external events do not
           contribute as much as internal, but that's something
           we want to check out and verify.
                       But it's not necessarily, should I say, so
           insignificant that you can just rule it out right off
           the bat.
                       MEMBER KRESS:  Thank you.  That helps.
                       MR. HACKETT:  I guess what I'd say in
           closing this opening piece, I guess what I'd like to
           focus on -- we're going to go into giving you the
           results and insights from Oconee.  But I think the
           focus really needs to be on the modeling process and
           quantification on the uncertainty, which is really
           what we tried to do in detail at the day-and-a-half
                       So, we're going to try and keep that
           focus.  If we don't, let us know.  We may need more
           time to do that.  If we need to come back, we'll do
           that.  But that's going to be the focus.
                       With that, I'll hand it off to Mark Kirk
           to --
                       MR. KIRK:  Do you want to do the Oconee
           part now?
                       MR. HACKETT:  Yeah.  We might as well do
           the Oconee part now.
                       MR. KIRK:  Okay.  You've seen this graphic
           before.  This just orients you in terms of the various
           steps in the process that PRA defines the sequences
           and the sequence frequencies.  That feeds into TH,
           which gives us pressures and temperatures to run
           through the PFM model, which generates conditional
           probabilities of vessel failure that are then
           mathematically in mind with the sequence frequencies,
           to give us an estimate of the yearly frequency of
           through-wall cracking, complete with uncertainties.
                       MEMBER KRESS:  The PFM analysis has inputs
           that are like fluence --
                       MR. KIRK:  Oh, yeah.  Yes. Yes.
                       MEMBER KRESS:  -- and crack size and
           growth rates and things like that?
                       MR. KIRK:  That's right.  There's a whole
           host of details under this, and we'll get to expanding
           that later.  That's absolutely right.
                       Just in terms of -- and I think this will
           get to that -- some of the higher level things in each
           of these analyses.  In PRA, we start off with
           something on the order of 10,000 sequences, just for
           reasons of --
                       MEMBER WALLIS:  It says there are 100,000.
                       MR. KIRK:  100,000.
                       MEMBER KRESS:  That has to do with the
           number of crack sizes you have?
                       MR. KIRK:  Number of what?
                       MEMBER KRESS:  Crack sizes.
                       MR. KIRK:  No.  Number of possible
           initiating events in the plant.
                       MR. KOLACZKOWSKI:  Number of scenarios --
           just various combinations of valve sticking open/not
           sticking open, both on the primary/on the secondary,
           operators doing things/operators not doing things. 
           You look at all the possible combinations.  Right now,
           we've modeled something like 100,000 different
           scenarios that could lead to overcooling.
                       MEMBER KRESS:  Okay.
                       MR. KIRK:  But in order to make the
           computation tractable, that has to get partitioned
           down into something on the order of a hundred
           different bins that somehow, by the process that we go
           through in PRA and in SAPHIRE, that represent these
           hundred-thousand sequences.
                       MR. KOLACZKOWSKI:  Dave over there doesn't
           want to have to run 100,000 RELAP runs.
                       SPEAKER:  I can't imagine why not.
                       MEMBER KRESS:  When you -- you bin these
           by similar consequences and add up the frequencies?
                       MR. KIRK:  Basically, yes.
                       MEMBER KRESS:  Okay.
                       MR. KIRK:  And when we get into more of
           the details about how the computation's being done. 
           Alan will be describing these more.  But just, again,
           to get the high points, in this analysis we use the
           most recent data coming out of the plants, give credit
           where credit is due for recent training and
           procedures, and as I said, human reliability credit,
           as appropriate.
                       That then feeds into the thermal hydraulic
           analysis where, for the particular case of Oconee, we
           had approximately 150 transients for which we actually
           performed RELAP runs.  Of those, approximately 50 of
           them just got based on an inspection of the --
           pressures and temperatures got screened out, meaning
           they never got passed on to PFM.  You could just look
           at the transient and tell that it was adequately
           benign, that it was really not a PTS precursor.
                       Of the remaining 100, approximately half
           of them then fell into the base case and half of them
           got used to assess --
                       MEMBER FORD:  Sorry.  Did you -- I know
           more than you just were saying.  I just want people to
           be aware that there were quantitative criteria as to
           which ones you threw out.
                       MR. KIRK:  Yes.  Yes, certainly.
                       MEMBER FORD:  I did have more on a certain
           Delta T in a certain time.
                       MR. KIRK:  That's right.
                       MEMBER FORD:  Anything above that was
           chucked out.
                       MR. KIRK:  The criteria for falling into
           screened, not further considered, was based on some
           very conservative, deterministic, probable -- I'm
           sorry -- fracture mechanics calculations.  And we, in
           a sense validated those criteria because, of course,
           having screened things out, some things weren't
           screened that were right on the line.  When we
           actually ran the Oconee calculations, we found that
           those had absolutely zero contribution to the
           conditional probabilities.
                       MEMBER POWERS:  As I look at this chart,
           you have this PRA event sequence, and that's
           metaphysics.  You can't experimentally validate that.
                       You have thermal hydraulics.  That's a
           well-established discipline.  You can have models that
           are experimentally validated for the thermal
                       Probabilistic fracture mechanics is
           metaphysics that has some hope of being experimentally
                       MEMBER ROSEN:  You're just fantastic. 
           It's the same old PRA.
                       MEMBER POWERS:  The interface between
           thermal hydraulics and the probabilistic fracture
           mechanics -- you have some model.  There's some model
                       I guess what I'm struggling with is, has
           there ever been an undercooling event at any pressure
           vessel, thick-walled pressure vessel that led to a
           failure that gives you some confidence that that model
           you had between the thermal hydraulics and the
           probabilistic fracture mechanics was -- it was a valid
                       MR. KIRK:  In the in-service, no.
                       MR. HACKETT:  In the in-service, no.
                       MEMBER POWERS:  Well, experimentally.
                       MR. KIRK:  Experimentally, yes.
                       MR. HACKETT:  Experimentally, yes, we
           could say a few things because you're going to the
           issue with the deterministic aspect of this thing. 
           And there, we have the benefit of a lot of historical
           tests that were run at  the Oak Ridge Laboratory for
           the NRC research program, where we did in fact do
           that.  And the state of the art at the time predicted
           with varying degrees of success.
                       But most recently, we've had the NRC staff
           and the contingent from the Oak Ridge National
           Laboratory has been very successful in predicting the
           behavior of these large-scale reference experiments
           that have been run under the NESC program, the
           European Network on Evaluation of Steel Components.
                       In fact, I think Richard Bass is the
           principal of the HSST program for us, and the staff
           predicted the crack behavior of the NESC One spinning
           cylinder test in the UK, I think just about dead on. 
           And again, that's a deterministic problem, so that the
           probabilistics get you off into the other --
                       MEMBER POWERS:  Metaphysics, yes.
                       Okay.  I mean, that's something that
           people don't always recognize is that the interfaces
           between models as a model.  That has to be validated,
           and it seems like you've taken care of that.
                       MEMBER FORD:  Well, Dana, you bring up a
           very good point, could deterministic validation of the
           failure could, as it existed before you put all the
           probabilistic stuff in.  You mentioned one point, the
           spinning test in the United Kingdom.  What about the
           70 other odd tests that have been done around the
                       MR. KIRK:  Recently -- the answer is, you
           know, if you ask me to pull out a report and give it
           to you, I can't do that right now.  It certainly is
           possible to be done and I think we need to look into
           that because approximately a year ago, under the HSST
           program, we asked them to summarize, like you said,
           the 70-odd reference experiments that are well
           documented in structural scale.
                       Certainly, it would be possible, and I
           think necessary here, to go back and use the --
           there's a switch in FAVOR, where you can turn off the
           probabilistic aspects and just use it as a fancy
           deterministic calculator and use it to predict the
           results of some of these well-known, well documented
           reference experiments.
                       As Ed pointed out, we've been through that
           exercise a number of time in the past, dating back to
           the 1980s, using FAVOR precursors, which did well
           using technology of the time.  We haven't done that
           with the current version of FAVOR.
                       MEMBER KRESS:  As I recall, Dana, there
           was almost a museum of huge thick-walled vessels at
           Oak Ridge with impressive cracks.  The thing I
           remember though -- I may have a faulty memory and you
           guys can correct me here -- it was extremely hard to
           create those vessels with the embrittlement
           characteristics that you get from the radiation. And
           it's also kind of hard to reproduce the thermal
           transients that you get.  You had to do some things
           with both of them.
                       MR. KIRK:  There were some things that you
           clearly had to do in the laboratory environment that
           you couldn't entirely mock up to simulate the full
           scale exactly.
                       And in the case of the embrittlement, what
           was done was actually a long series of studies that
           were done at Oak Ridge and elsewhere to try and
           simulate the radiation embrittlement damage with
           changes in the treatment of the steel so that there
           was work done there.
                       In terms of simulating thermal transients,
           in a lot of cases, you know, things like liquid
           nitrogen had to be used to get some of the type of
           Delta Ts that you think you would see or had seen in
           the operational experience.
                       MEMBER KRESS:  And they had to introduce
           artificial cracks.
                       MR. HACKETT:  Absolutely.
                       MEMBER FORD:  But in the spinning tests in
           the United Kingdom, though, they didn't simulate a
           real PTS event.
                       MR. HACKETT:  That one was very similar
           because -- the spinning cylinder test, for those who
           aren't familiar, they generate the stresses in the
           wall by spinning a fairly large cylinder that had a
           flaw embedded in the wall.
                       In that case, they induced the thermal
           shock with the water spray that's fairly severe.  And
           that crack did initiate and run, and the deterministic
           version, as Mark said, of the FAVOR code used at that
           time, which is not the current version of FAVOR,
           pretty much predicted that event right on.
                       There have also been the predecessor to
           the NESC program.  NESC evaluations are still ongoing,
           or actually there's a son of NECS.  Shah's here; he
           knows what the name of that program is.  But the
           predecessor to that was something called FALSIRE --
           Fracture Analysis of Large-Scale International
           Reference Experiments -- if you like acronyms.  And
           there was actually a FALSIRE 1 and a FALSIRE 2
                       Those programs looked at these -- I don't
           know what the number is -- 50, 60, 70 experiments that
           were fairly large-scale, some done at Oak Ridge, some
           done in the U.K., Japan, also Germany, I know at least
           were participants in that study, and then, looking at
           the international contribution, their approaches to
           taking this thing on, too.
                       Our approach is, as Mark said, would be to
           have used FAVOR when we had it, or the FAVOR
           predecessors, which were VISA and VISA 2D and OCA and
           OCA-P, which were developed at Oak Ridge.   So I guess
           the bottom line of all of this is that there has been
           a lot of work done in that area.
                       MR. MALIK:  Yes, I would like to add to
           Ed's comments.  We have a report recently put out
           about -- as (inaudible) explained -- we have combined
           together in a single report.  And that would be aspect
           to go over and see how many we can predict with the
           new code.  We're going to look into that.  But the
           comprehensive report gives a little bit of detail over
           all 70.  Each individually would report on it's own
           self, and we'll be trying to see how much it can do
           under the new code.
                       During that earlier work, we have gone
           through with all the (inaudible) as well.
                       MEMBER WALLIS:  Now, Dana asked a question
           about whether there were experiments to back up this
           interrelationship.  And he implied that we knew
           everything we needed to know about thermal hydraulics. 
           But are we going to hear later about the experiments
           that back up the analysis that goes into the thermal
                       MR. BESSETTE: Well, later, yes.  Not
           today, though.
                       MEMBER WALLIS:  Not today?
                       MR. BESSETTE: Well, there's not time,
           really, to go into --
                       MEMBER WALLIS:  Is that because you don't
           have the evidence or you just don't want to show it
                       MR. BESSETTE: No.  I think we have enough
           evidence now.
                       MEMBER WALLIS:  So you can reassure us
           that you do know what you're doing with thermal
                       MR. BESSETTE: We can do that, yes.  I
           think we're capable of doing that.  We are able to do
           that.  We're in the position to do that.
                       MEMBER WALLIS:  You're waiting for the
           right moment.
                       MEMBER FORD:  But just following on from
           that, do we have any back-up -- maybe we're jumping
           into what you talk about later one.  But the RELAP
           code will give you the temperature, pressure and heat
           coefficient variations as a function of time of the
           liquid, which you say can be corroborated with data.
                       What about the similar corroboration of
           the material temperature, stress, biaxial and triaxial
           stresses, as a function of time and distance?  Do we
           have that data?
                       MR. KIRK:  You mean simply a validation of
           the thermal stress analysis?
                       MEMBER FORD:  Correct, as a function of
           variations of residual stress?
                       (Comments off-mic.)
                       MEMBER FORD:  Well, I know, but everybody
           keeps on saying that's an easy kind of exercise to do,
           but has anyone validated it?
                       MEMBER SHACK:  Well, there've been a lot
           of thermal analysis tests that tell you know how to do
           thermal analysis.  You convert them into stress.
                       MEMBER KRESS:  I don't think that's -- but
           the question about the thermal hydraulics and its
           uncertainties I think is a real legitimate one because
           I don't think you can calculate these things as RELAP.
                       You use RELAP to set up -- to tell you
           when, in a thermal hydraulic sequence, you want to end
           up being stagnant.  And then you use something else to
           calculate the thing, don't you?  You don't use RELAP
           from there on, do you?
                       MR. KIRK:  Well, FAVOR calculates its own
           stress field, and we don't take that from RELAP. I
           mean, RALAP will give you a temperature -- wall
           temperature, but we don't use that wall temperature.
                       MEMBER SHACK:  Yeah -- but you're right.
           If you've got temperature and pressure, you can feed
           it in.  But to get that temperature and pressure, you
           don't use RELAP, do you?  That was my question.
                       MR. BESSETTE: We provide the boundary
           condition at the vessel inner wall, but not the
           conditions within the vessel.
                       MEMBER WALLIS:  No, you give an H in a
           heat transfer coefficient temperature, and the
           pressure is the pressure of the volume.
                       MEMBER KRESS:  And that comes from RELAP?
                       MR. BESSETTE: Yes.
                       MEMBER KRESS:  What ever happened to
                       MR. BESSETTE: Remix --well, we used RELAP
           -- you've heard about 150 calculations.  Those were
           all done by RELAP.  We have some supplemental
           calculations done with REMIX, but basically REMIX was
           created because of the concern about the plume.  And
           since we've shown that the plume is gone --
                       MEMBER KRESS:  But you don't that.
                       MR. BESSETTE: We don't the supplemental
           calculations to provide the boundary conditions.
                       MEMBER WALLIS:  I think what you're saying
           is that RELAP makes various assumptions about how well
           mixed the nodes are, and so on.  And you have done
           separate tests to verify that those assumptions are
                       MR. BESSETTE: That's correct because RELAP
           cannot model plumes.
                       MEMBER KRESS:  That was basically my
           question, how did you deal with it. And I understand
                       MEMBER WALLIS:  Then the question about
           how well will that model the whole transient and
           whether or not it predicts its stagnation right is a
           big question, isn't it?
                       MR. BESSETTE:  That is the big question. 
           That -- you are correct.
                       MEMBER WALLIS:  And that's the question
           you're not proposing to answer today.
                       MR. BESSETTE: We don't -- I don't have --
           I can't show you all the evidence for that --
                       MEMBER WALLIS:  There's no way you can win
           a prize on this show today, then.
                       VICE CHAIRMAN BONACA:  Although there have
           been a lot of applications or views of RELAP 5 by
           vendors in those specific applications, and they have
           submitted a lot of comparisons to experiments to
           justify the use, and it's been approved by the staff,
           so there should be available information by the staff
           on the different applications done with RELAP 5.
                       MR. BESSETTE: All the risk-significant
           transients that have shown up in the Oconee study have
           been LOCAS.  Speaking generally, we do have quite a
           substantial validation base to speak about with RELAP
           for LOCAS that we can reference.
                       MR. KIRK:  And I think the other piece, in
           response to Dr. Wallis's question, is that there are
           experiments that David had run at APEX.  And I know
           the committee got to visit out there.  And I think the
           evaluation of that in detail is still in process, and
           there will be information obviously available.
                       MEMBER WALLIS:  I was just wondering about
           what you're going to get in our letter about thermal
           hydraulics if you didn't tell us anything.
                       MEMBER KRESS:  We may have to just -- we
           may have to punt on that until later.
                       MR. HACKETT:  I guess we'll have to wait
           and see how David's piece of this goes.
                       MEMBER WALLIS:  I don't know how you'd
           punt thermal hydraulics.
                       MEMBER KRESS:  You say, we didn't discuss
           thermal hydraulics and we'll comment on that later.
                       MR. HACKETT:  I guess in the interest of
           getting to the key part of this thing on the
           uncertainty evaluation, we'll try and forge ahead
                       MR. KIRK:  I think the intent here was
           just to provide a sense of what goes in the boxes, and
           we're going to do that in more detail later, so we'll
           go on.
                       One question that invariably gets asked --
           and this of course can be gone into in any level of
           detail one would desire -- is what's changed since the
           analyses that established 10 C.F.R. 50.61 in the mid
           1980s.  So here, we've summarized the major
           contributions and shown at least qualitatively by way
           of the arrows what are the things that are driving the
           risk of vessel cracking down, shown by the green
           arrows, and what's driving the risk of vessel cracking
                       Again, we'll be going into more detail,
           but just to provide a sense of -- one of the biggest
           things in PRA is the fact that we're now discretizing
           these hundred-thousand events into many more bins than
           we used to.  Before, there was something like a
           countable number of bins on two hands, whereas now
           we've got something more on the order of hundreds.  A
           hundred still sounds pretty coarse when you looking at
           an overall population of 100,000, but in getting them
           into those bins, we have to make a lot fewer
           conservative assumptions, and that has a very positive
           impact on driving the risk numbers down.
                       MEMBER WALLIS:  Isn't "PRA data" sort of
                       MR. KIRK:  Or perhaps a metaphysical oxy-
           moron.  I'll pass on that one.
                       We have done some things --
                       CHAIRMAN APOSTOLAKIS:  What do the arrows
                       MR. KIRK:  The arrows mean that generally,
           considering that factor or what we've done there, the
           green arrows indicate that it would be driving the
           risk down, whereas red arrows indicate it's driving
           the risk up.  So, for example, in PRA we've considered
           acts of commission.  You did the wrong thing that we
           never considered.
                       CHAIRMAN APOSTOLAKIS:  I think they don't
           necessarily indicate that that's what happened.  This
           is what you would expect --
                       MR. KIRK:  In some cases -- for example,
           external events.  We haven't considered external
           events.  We would expect that it would drive it up. In
           fact, you know a priori it has to drive it up because
           you didn't consider it before.  You can't drive it
           down if you didn't consider it.
                       CHAIRMAN APOSTOLAKIS:  But it may not
           drive it up significantly.
                       MR. KIRK:  It may not drive it up
           significantly, that's correct.
                       CHAIRMAN APOSTOLAKIS:  This is what you
           would expect.
                       MR. KIRK:  In some cases, they are
           results.  For example, if you look in PFM, the first
           arrow -- these aren't scaled, also.  The first arrow
           in PFM should be huge.  We've removed a significant
           conservative bias in the toughness model in the index
           temperature.  That's resulted by itself in at least an
           order of magnitude reduction.
                       We've recognized the spatial variation in
           fluence, whereas before the entire vessel was burdened
           with the peak fluence. That's a major drop.  Most
           flaws are now embedded, rather than being on the
           surface; again, a huge drop.  And those are all
                       So, in some cases, there are expectations. 
           In other cases like external events, which we haven't
           considered, it's an expectation.
                       MR. KOLACZKOWSKI:  Mark, let me even
           clarify further for Dr. Apostolakis.  With the
           exception of the external events arrow, every one of
           those other ones are results.
                       MR. KIRK:  That's true.
                       CHAIRMAN APOSTOLAKIS:  During the
           subcommittee, I asked a question regarding, at some
           point, getting information for -- quantitatively a
           (inaudible) to get a sense of what comes from the PRA. 
           Because much of that has to do with eliminating a
           number of limiting sequences, based on critical
           (inaudible) action and getting a sense of how much
           you're getting from PFM, because that's more
           thermalistic in part.  And I wonder if you have --
                       MR. KIRK:  We haven't got that
           quantification at this time, but that's something
           that's definitely a stay-tuned document, and that
           question is clearly on everybody's mind.  What our
           current goal is, is to get through -- Ed presented the
           status -- turn the draft on Oconee into final.  And
           then a number of questions along those lines have come
           up that I think represent the definition of
           sensitivity studies that we're going to be needing to
           do to better flesh that out.
                       MEMBER POWERS:  Before you leave that
           previous slide, or maybe after you're -- if I have a
           PWR and I operate it with higher burn-up to fuel,
           higher burn-up, and I sustain an axial offset anomaly,
           do I change my fluence distribution in a way that you
           have not taken into consideration?
                       MR. KIRK:  The fluence distributions -- I
           believe the short answer is yes.  The fluence
           distributions right now -- we have fluence maps that
           were calculated at Brookhaven, at two different
           fluences, I believe 32 and 40 years.  Those are then
           -- the other fluences that we analyze are extrapolated
           from those, which is to say that we're assuming that
           the fuel loading remains the same.
                       MR. HACKETT:  Yes.  If the burn-up -- of
           if we were to address mocks or something like that and
           it was to significantly change the neutron spectrum,
           this project doesn't address those factors at this
                       MEMBER ROSEN:  But Dana, an axial
           significantly skewed profile due to an axial offset
           anomaly is not something that's going to be sustained
           for 20, 30, 40 cycles.  It's something that happens
           potentially, but then the plant says "whoops" and
           corrects it in the next cycle.
                       So, I don't know that it has an integrated
           effect on fluence that's -- it doesn't have a
           substantial effect on the integrated fluence because
           it's corrected.  It's not something that's sustained
           over the life of the plant.
                       Am I correct on that, Ed?
                       MR. HACKETT:  I would think that would be
                       MEMBER POWERS:  I'm gratified at the
           assurances but I'd like to know what it does do to
           your mark.
                       MEMBER FORD:  I think a much bigger fate
           would be the fluence attenuation in the pressure
           vessel vault, which has not been qualified, as I
           understand it.
                       MR. HACKETT:  That was one of our due
           dils. from the last meeting.  It hasn't been
           quantified in an experimental sense by taking section
           through a wall.  And indeed, it would be very
           difficult to do that in a statistical sense to get a
           valid comparison.  But there has been a lot of
           modeling work that went into that.  It's largely the
           work of, I guess, Professor Odet and others.
                       But you're right.  That's an area that's
           also ripe for some more work in the future because
           we're not proposing this project changing that
           attenuation function.
                       MEMBER SHACK:  But I think there's general
           agreement that your attenuation function is a
           conservative one.
                       MR. HACKETT:  Yes.
                       MR. KIRK:  Yes.
                       MEMBER SHACK:  But how can you say that,
           Bill, if you haven't done any experiments?
                       MR. HACKETT:  People have done
           experiments.  They haven't done those experiments but
           people have measured attenuation in steel.  You know,
           there are models for this and, you know, the model
           that they've used is I think generally considered to
           be a conservative one.
                       MEMBER FORD:  Well, I know they've done it
           -- they've measured in stainless steels, but have they
           done it in ferrittic?
                       MR. HACKETT:  Like Bill said, it's been
           done in a modeling sense.
                       MEMBER FORD:  I guess I'm being nitpicky,
           but the point is that it does have a big impact on the
           rest of the crack -- the specific fluence attenuation. 
           You know, that's a big output from this overall model.
                       MEMBER WALLIS:  Isn't this just simple
           physics about how neutrons behave in steel, and it's
           all well understood --
                       MR. HACKETT:  It's certainly physics.  I
           think there is probably a lot of contention about the
           simple part I guess.
                       MEMBER POWERS:  The neutron, we
           understand.  It's the steel that we don't understand.
                       MR. KIRK:  Well, I think to follow up on
           Dr. Shack's point, I think -- I mean, clearly it's not
           within the scope of this project, although many people
           would like to, myself included, whack up a vessel wall
           into sharpies and test it through the thickness.  That
           would be very satisfying.  Unfortunately, it would,
           you know, consume the entire RES budget.
                       But, I do think it's incumbent upon us to
           do what Dr. Shack suggested, which is to better
           document the common engineering assumption that the
           Reg. Guide 199 rev. 2 fluence function is
           conservative.  Again, ask me to pull out the document,
           I'll say, no, I can't do it.  But that's something
           we're looking into putting together because I think,
           you know, absent the experimental proof or the right
           answer --
                       SPEAKER:  Where's Art Lowe when you need
                       MR. KIRK:  I've got a Ouija board, if you
           need it.
                       MEMBER WALLIS:  Well, maybe -- the fluence
           to me is just what the neutrons are doing.  Their
           effect on the steel is another question.
                       MR. HACKETT:  I think Dr. Lewis from NRR
           has some comments.
                       MR. LEWIS:  Yes.  I think we do know a
           little -- my name is Lambrose Lewis.  I'm from the
           (inaudible) branch.  We do know a bit more than what
           you assumed previously.
                       We've had dosimetry inside and outside the
           pressure vessel, so we know how many neutrons go in
           and how many get out on the other side.  What does
           change, however, is the spectrum -- namely, those that
           are left behind and exit the other side are much, much
           harder, as they are a much harder spectrum. 
           Therefore, they cause percolision much greater damage.
                       However, there is several DPA -- the
           function -- which one can quantify the damage per
           neutron as it goes through.  Therefore, we do have a
           function which tells us how much damage has been done
           from inside out; not only the number of neutrons but
           also how much damage they caused in that.  So, there
           is a quantifiable function that we have.
                       Now, there are some measurements on the
           cross-sections of steels that have been exposed -- not
           pressure vessels but other steels -- that only refer
           to, as far as I'm aware of, to hardness.  People
           measure hardness and say, well, yeah, roughly they
           correspond to each other.  So, to that extent there is
           some rudimentary experimental evidence.
                       MR. HACKETT:  Thanks, Lambrose.  That's
           what you get when you ask some metallurgist to try and
           answer about dosimetry, it seems, and it's helpful.
                       MR. KIRK:  We just had two fairly high-
           level slides on the current results from Oconee, and
           I should point out that these were results that were
           generated back in December.  As with any good
           engineering calculation -- or maybe I should just say
           any engineering calculation -- you go through and you
           find that there are certain things that you should
           have done better or maybe shouldn't ought to have
           done.  So these calculations will be redone next week.
                       Having said that, I'm not sure that any of
           the overall results will change.  This takes, now, yet
           a higher level view of the 100,000 sequences that were
           reduced into 150 thermal hydraulic bins and gathers
           them together yet further, because we find as a result
           of the analysis that approximately nine or ten of the
           individual bins contributed over 90 percent of the
           probability of through-wall cracking.
                       Just as a class, LOCAs are contributing by
           far the largest part.  They're responsible for well
           over 50 percent of the crack initiations.  However,
           they're not as dominant in vessel failure simply
           because the larger the LOCA break gets, the pressure
           drops and the crack can't go through the wall.
                       The red section and the green section
           provide an interesting example of the effect of human
           reliability credit.  Over on crack initiation, the red
           and the green essentially all represent the same
           starting sequence -- I'm sorry.  The red and the green
           all represent the same starting sequence.  The
           difference between the red and the green is that in
           the case of the red we've got a stuck open pressurizer
           safety valve that the operator, for whatever reason,
           didn't intervene at all, and the valve simply re-
           closes automatically.  Whereas, with the green
           section, we've got two variants of that transient,
           where the operator throttled HPI at different times in
           to the transient.
                       So, in this case, in the red you've got
           one initiating event that produces a few initiations
           but produces a whole lot more failures because HPI was
           never throttled, whereas here you've got two of the
           same starting events, which produced, of course, more
           initiations.  But because the operator was of course
           doing the right thing, it didn't get as bad in terms
           of punching through the wall.
                       This, of course, is just one snapshot --
                       CHAIRMAN APOSTOLAKIS:  So this is -- this
           would be a matter of omission, would it not?
                       MR. KIRK:  This would be -- the red would
           be an error of omission, yes.
                       CHAIRMAN APOSTOLAKIS:  That could have
           been done reasonably well in the '80s.
                       MR. KIRK:  Yeah.
                       CHAIRMAN APOSTOLAKIS:  It was not?  It
           didn't included human error in those studies?  Pure
           human action?
                       MR. KOLACZKOWSKI:  The general answer --
           if you look at the 1980s work, you will find that with
           a few exceptions, a little to no credit for the human
           doing anything at all was in those models.
                       CHAIRMAN APOSTOLAKIS:  So in your previous
           slide with the summary of changes --
                       MR. KOLACZKOWSKI:  Correct.
                       CHAIRMAN APOSTOLAKIS:  -- you should have
           -- oh, no.  I'm sorry.  You have it.  Good.
                       MR. KOLACZKOWSKI:  Generally, as you give
           operator credit, it makes the risks go down.
                       CHAIRMAN APOSTOLAKIS:  So what is the
           number now that you use for that?  Will you talk to us
           about it later?
                       MR. KIRK:  The number for what?  For human
                       CHAIRMAN APOSTOLAKIS:  Yes.  That's coming
                       MR. KOLACZKOWSKI:  Yeah.  I mean, we can
           show you some examples, if that's what you want to
                       CHAIRMAN APOSTOLAKIS:  Yeah, that's what
           I want to see.
                       MR. KIRK:  All right.
                       MR. KOLACZKOWSKI:  By the way, Mark, those
           will be on some back-up slides.
                       MR. KIRK:  Okay.
                       These are, of course, results at just one
           embrittlement level.  We've run the calculations for
           a number of embrittlement levels, and what you see on
           this plot --
                       CHAIRMAN APOSTOLAKIS:  You should add more
           information to this.  It's too simple.
                       MR. KIRK:  We've already removed a lot of
                       CHAIRMAN APOSTOLAKIS:  Ah, it depends on
           your starting point, right?
                       MEMBER SHACK:  It's only the distribution
           of epistemic frequencies.
                       CHAIRMAN APOSTOLAKIS:  He's got only the
           95th percentile.  We need superimposed upon this an
           epistemic distribution of --
                       CHAIRMAN APOSTOLAKIS:  I'm looking.
                       MR. KOLACZKOWSKI:  We have it.
                       MR. KIRK:  The curves here represent the
           95th percentile of the vessel failure distribution. So
           that's some measure of an upper bound.
                       CHAIRMAN APOSTOLAKIS:  The frequency of
           vessel failure?
                       MR. KIRK:  Yes.  Yes.
                       CHAIRMAN APOSTOLAKIS:  Due to any -- all
                       MEMBER ROSEN:  No, no.  PTS.
                       MR. KIRK:  PTS.  All PTS causes, yes.
                       CHAIRMAN APOSTOLAKIS:  PTS.
                       MR. KIRK:  Everything. The points to take
           away here -- as we started off by performing a
           calculation of the Oconee Plant at -- I used to say at
           the end of their current license period, but that's
           not correct because NRR's granted them an extension. 
           So, at the end of their original operating license,
           this analysis was estimating their 95th percentile
           through wall-cracking frequencies, down on the order
           of 1E minus ten, 1E minus 9.  Relative to our current
           risk criteria, that's about four orders of magnitude
                       If we take that same plant and crank up
           the fluence so that the most embrittled axial weld and
           the most embrittled circ weld cross our current 10
           C.F.R. 50.61 screening limits, we find out that even
           at that level of embrittlement -- and this is perhaps
           the more important point for purposes of revision of
           the rule.  Previously we associated -- we would have
           thought that the plant would have gone through these
           screening limits at 5E minus 6, whereas for this
           plant-specific analysis at Oconee, they go through it
           more like 5E minus 8.  So, we're again two orders of
                       MEMBER SHACK:  Oh, you thought your
           scoping criteria would limit to you to your acceptance
           criteria?  That's an interesting concept.  I was going
           to say, how much margin did I expect my scoping
           criteria to have, and the answer is none, right?
                       MR. KIRK:  That would have been my answer. 
           But that's a personal view.
                       MEMBER SHACK:  Oh, okay.  A different
           answer -- or a different notion of a screening
           criteria than I normally would accept.
                       MEMBER FORD:  Could you point out where
           the 60 --
                       MR. KIRK:  Sixty is just the --
                       MEMBER FORD:  Next one up?
                       MR. KIRK:  -- yeah.
                       MEMBER WALLIS:  So, in plain language, the
           real story is down in the orange or whatever color
           that is --
                       MR. KIRK:  Yes.
                       MEMBER SHACK:  The real story is up in the
                       MR. HACKETT:  The real story is where you
           force it up to where the --
                       MEMBER WALLIS:  But you have to force it
           up there.
                       MR. HACKETT:  Yeah.  Well, that's where it
           would be.
                       MEMBER SHACK:  If the vessel is
           embrittled.  Everybody agrees that if you don't have
           an embrittled vessel, PTS is not going to give you
           much of a failure.  The real crit is, do we have the
           criterion to describe embrittlement.
                       MR. KIRK:  That's right.
                       MEMBER SHACK:  And the answer seems to be
           that our current criterion give you a conservative
           answer.  Just how conservative it is seems to be a
           matter of --
                       MR. KIRK:  Or how conservative it needs to
                       MEMBER WALLIS:  Well, the criterion is
           conservative by a factor of 100, but the actual
           operation is even more conservative because you never
           get near the criterion.
                       MR. KIRK:  That's right.  And the actual
           operation for Oconee is down here.   Now, we might see
           some differences, as Dr. Ford pointed out, in the four
           plants that we're analyzing, if you walked up to your
           random materials person in the street and said
           Palisades, Calvert Cliffs, Beaver Valley I and Oconee
           I, which ones are closer to limit now?  You'd say
           Beaver Valley I and Palisades.  So when we do those
           analyses, it will be interesting to see how they
           compare with these.
                       MEMBER FORD:  Now, there are a lot of
           assumptions in this whole process.  What are you going
           to do if you find that is not the case?
                       MR. KIRK:  Well --
                       MEMBER FORD:  In other words, what do you
           throw out?
                       MR. KIRK:  Well, if you made me bet some
           of my own money right now, I would conjecture, at
           least from a materials viewpoint, they're all going to
           be coming in pretty close to each other because of the
           changes that we've made.  The change -- right now, we
           think about plants relative to the PTS screening
           criteria using the embrittlement correlation in the
           current reg guide.
                       In these calculations, we're using, of
           course, the updated embrittlement correlation -- and
           I see you have that report open, so you know about
           that.  That reshuffles the deck chairs, to the point
           that now -- I mean, certainly it doesn't make Beaver
           Valley and Palisades, you just say, well, why do you
           ever worry about them?  But the plants move around and
           some of them become closer to whatever the screening
           criteria might be than others.
                       And when we look at the distribution of RT
           NDT values in the four plants that we're looking at,
           they're much more similar than we would have
           previously thought them to be.
                       MEMBER FORD:  Okay.
                       MEMBER SHACK:  Now, where would the mean
           be?  Here's the 95th percentile.  Where would the mean
           be?  Is it a decade lower, or --
                       MR. KIRK:  Not too much -- it's a very
           skewed distribution, so not too much further down.
                       MEMBER ROSEN:  Are you going to let us in
           on what magical change -- shuffle the deck chairs, as
           you say.
                       MR. KIRK:  We could go through that again
           in an immense degree of detail, but the differences
           between the Reg. Guide 199 rev. 2 Embrittlement
           Correlation and what we have now are, well,
                       The old correlation was essentially just
           an empirical curve fit to about 150 surveillance
           points made in the mid 1980s.  Since that time, we've
           evolved to what I would call a physically motivated,
           empirically calibrated model, where we use our
           understanding in the physics of irradiation damage to
           set the functional forms and use the surveillance data
           to calibrate it.
                       So, I think the opinion of the technical
           community would be that we've got a more robust
           correlation now, and that it's tied to physics.  And
           what you find out is that because the old
           embrittlement function was simply a curve fit, and a
           very simple gross curve fit to all the data, some
           situations were assessed more optimistically than they
           should have been, and some were assessed more
           pessimistically than they should have been.
                       MR. HACKETT:  I guess I'd add in the
           interest of moving on, Mark has gotten into some of
           the PFM details.  We do have at least a little bit of
           the segment of the presentation here today on that, so
           hopefully we'll get into some of those.
                       MR. KIRK:  I think we've commented on most
           of these.  These were just a few observations that we
           wanted to share coming out of the Oconee analysis. 
           We've already pointed out that the dominant scenarios
           are all primary system LOCAs.  The second point
           follows from that, in that realistic accounting of
           operator action has significantly mitigated the
           influence of secondary system events on the total
           failure probability in this plant.  I've learned a lot
           about PRA practice in going through this, and it's
           been commented that we may not find this to be true in
           the other plants.
                       One thing that I think came as a surprise
           to many of us, but we've been able to understand, is
           that main steam line break and steam generator tube
           rupture, both of which were very dominant events in
           early analyses, no longer occur, or no longer show up
           as being dominant.  That's occurring for a number of
           reasons, perhaps most primarily being the fact that
           those scenarios were dealt with very conservatively
           before, and so their influence was artificially
                       MEMBER WALLIS:  Within the LOCAs, are
           there big variations in the effects of different kinds
           of LOCAs?
                       MR. KIRK:  Certainly break size is a
                       MEMBER WALLIS:  Is it a big actor?
                       MR. KIRK:  Yes.
                       MEMBER WALLIS:  So which LOCAs are the
                       MR. KIRK:  Small to medium.
                       MEMBER WALLIS:  Small --
                       MR. HACKETT:  Small to medium.
                       MR. KOLACZKOWSKI:  Yeah, small to medium.
                       MEMBER WALLIS:  So, if someone came along
           and said we should forget about large breaks, that
           wouldn't be significant as far as PTS is concerned?
                       MR. HACKETT:  I think it's probably
           premature for us to say that, since I know, as Shook
           mentioned to the committee, we were embarking on maybe
           a couple of years worth of effort to look at
           redefining large break LOCA.  And I concur with that.
                       In this particular case, it goes fairly
           obviously to the -- small to medium break LOCAs are
           the ones that you're going to focus on because you
           have the possibility for the repressurization with
           HIPSI.  And also, not to mention the stuck-open valve
           scenarios, too -- safety relief, stuck open valve
                       MEMBER ROSEN:  Did the overly conservative
           treatment of main steam line break and steam generator
           tube rupture lie mainly in what the operators were
           credited with and what they were not credited with?
                       MR. KOLACZKOWSKI:  There were actually two
           effects.  And I know we have some back-up slides on
           this, but I'll try to answer it quickly, and if that's
           sufficient, great.
                       There were two effects -- first of all,
           you're right. They basically gave the operator no
           credit in the '80s work, whereas, if you account at
           all for the fact that once a severe depressurization
           on the secondary is recognized, that once the operator
           stops the feed to the bad steam generator, it's over.
                 `And we're finding out from the thermal
           hydraulics that 10, 15 minutes into the accident is
           how much time the operator has before it would even
           begin to be what we would categorize as a challenging
           event from a PTS standpoint.  And believe me, when
           operators have 15 minutes to do something, that's a
           lot of time.
                       MEMBER ROSEN:  And what they have to do is
           figure out which steam generator is faulted --
                       MR. KOLACZKOWSKI:  Correct.
                       MEMBER ROSEN:  -- which is practically
           screaming at them.
                       MR. KOLACZKOWSKI:  Oconee also has some
           unique indications to help them.
                       MEMBER ROSEN:  -- and then trip the feed
           to that steam generator.
                       MR. KOLACZKOWSKI:  Yeah.  All they've got
           to do is recognize which one it is, stop the feed to
           the generator, the event's over.  He basically is
           performing the same function of a main steam isolation
           valve, if the break is downstream of the valve.  But
           of course, he's doing it a different way.  He's
           stopping the feed, rather than stopping the steam exit
                       MEMBER ROSEN:  So he reaches up and trips
           the feed to that steam generator.
                       MR. KOLACZKOWSKI:  Yeah.  I mean, it's --
           in the case of this plant, it's -- there's a couple of
           things.  The main steam line break circuitry will
           probably stop main feed already, automatically.  But
           even if you allow for that failure, all he's got to
           trip the pumps.  And, then if ox-feed comes on, it's
           a one-handle action, and ox-feed is off.  So, once he
           recognizes to do it, it takes no time to do it.
                       MEMBER ROSEN:  And we'll assume that he's
           trained in that.
                       MR. KOLACZKOWSKI:  Absolutely.  The BNW
           plants in particular are very sensitive to overcooling
           because they know they've got, you know, as much more
           sensitive plant than perhaps Westinghouse and CE,
           where --
                       MEMBER ROSEN:  Trained and drilled in the
           simulator on it.
                       MR. KOLACZKOWSKI:  Yeah.  We watched -- I
           don't know if we can get into some of this other
           stuff, but as part of all this work and coming up with
           the human reliability numbers, etc., we had the
           licensee involved in coming up with these estimates. 
           we observed four to five simulated events on their
           simulator at Oconee of overcooling events.
                       So, we got a feeling for operators, have
           fast it can respond to certain things, what is the
           lay-out, what are some of the problems with the
           layout, etc.  It was not just a bunch of PRA geeks
           sitting around in an office somewhere and saying, I
           think the human reliability number's 10(-2).  We did
           a lot more than that.
                       VICE CHAIRMAN BONACA:  Why would you think
           it would be so much plant-dependent?  I mean --
                       MR. KOLACZKOWSKI:  Well, in terms of this
           particular kind of accident, as has been pointed out,
           the key is recognizing that you've got a
           depressurization of which steam generator it is, and
           then just how many actions does it take to isolate the
           steam generator.
                       VICE CHAIRMAN BONACA:  Sure.
                       MR. KOLACZKOWSKI:  I would say the simpler
           those are, the more likely of success or the less
           probability of failure.  And as part of the
           generalization step, what we're going to have to look
           at is what are the training and typical layouts of
           those kinds of indications at other plants?  If
           they're similar to Oconee, we would expect similar
           results.  If they're vastly different, then we'll have
           to account for that.
                       VICE CHAIRMAN BONACA:  Yeah, the reason
           why I brought it ups is the susceptibility of the
           steam generators at Oconee is, you know, much higher
           than other steam generators, where you have a pot of
           water.  And so that's why.  But I'm saying that the
           expectation would be that you would find similar
           trends in other NPRs.
                       MR. KOLACZKOWSKI:  Anyway, to finish
           answering your question, giving human reliability
           credit is one reason why these accidents went away,
           generally speaking.  They don't completely go away,
           but they're not among the dominant anymore.
                       And the other reason is, again, remember
           that we mentioned that we're doing 100 to 150 bins,
           whereas before in the early work they were using 10
           bins.  So whether it was a small steam line break or
           a large steam line break, it got treated as a large
           steam line break, it got treated as a large steam line
           break in the early work.
                       So, the cooling transient was much worse,
           etc.  Just by virtue of separating those two and
           making a small class and a large class, that by itself
           made some of it not be as dominant because now you're
           treating it more realistically, rather than treating
           all breaks very conservatively.  So, just the nature
           of adding more bins made some of the conservatism go
           away and made the main steam line breaks go away, for
           instance.  So there are actually two things that are
           causing that to happen.
                       MEMBER POWERS:  Let me return to your main
           steam line break conclusion.  In the not-too-distant
           past, the committee has been entertained by the
           description of a main steam line rupture.  And in that
           description, the speaker decried the ability to model
           those events because he describe shockwaves, motions
           of equipment and piping systems of a substantial
           nature, if the thing really moved around on you.
                       Do you take those into account when you
           come to this conclusion that the main steam line break
           is not a contributor to this?
                       MR. HACKETT:  I think -- let me try and
           answer for Alan.  He could probably give a more
           precise answer because I think know what Dr. Powers is
           referring to, which was an incident, as I recall, at
           Turkey Point Plant, and I think the answer is now.
                       And I know, when that came up I think it
           was presented as part of the steam generator action
           plan, resolution of the DPO.  In that case, there were
           some potentially very significant distractions to the
           operators that I don't believe we accounted for.
                       MR. KOLACZKOWSKI:  Actually, if that's
           what we're really getting at, I know when we came up
           with the human reliability numbers that we decided to
           use for failure of operators to, let's say, isolate
           the faulty steam generator, that was one of the
           contexts that we considered.
                       We said, you know what?  There could be a
           major distraction out there; maybe they're finding out
           their best buddy was just killed in the accident, etc. 
           Wouldn't that affect, potentially, the human
           probability of isolating because he's at least
           momentarily distracted  with, let's say, other issues
           that he finds equally important.  In fact, we tried to
           consider that in our quantitative assessment for human
                       MEMBER POWERS:  Well, then how about just
           the mechanical loads on the vessel?
                       MR. HACKETT:  Yes.  In that case, I guess
           I'd say a couple of things.  It's interesting.  I
           didn't know the points that Alan was making prior to
           that.  In the case that I think that Dr. Powers was
           referring to, there were significant motions of
           associated structures, and then I believe sonic booms,
           things of that nature, referred to.
                       And it sounds like your opinion would be
           that that is something that, despite that, these
           operators and training that they received would still
           enable them to do the isolation and mitigate the
           situation effectively.
                       MR. KOLACZKOWSKI:  Yes, if the question
           you're getting at is, are there new things added to
           this scenario now that create some kind of new LOCAs
           out in the secondary side that can't be isolated or
           something like that, well, then clearly the answer
           would be no.  But again, if the major crux of your
           concern is, did we consider it at least in the
           operator response, I would say, yeah, we tried to do
                       MEMBER POWERS:  I'm more interested in the
           mechanical response.
                       MR. KOLACZKOWSKI:  Yeah, if you're worried
           about pipe whipping and the effect on the other
           equipment, etc., obviously I would have to say that we
           didn't think about that on the PRA side.
                       MR. HACKETT:  I think as I understand the
           concern that was voiced as -- again, this is a mixture
           of things in the steam generator area.
                       I don't believe that that would result --
           some of the concerns that were voiced were things like
           oscillation of the steam generator tubes and potential
           for fatigue damage and so on.  I don't believe any of
           that would result in any additional overcooling that
           would impact the reactor vessel.
                       MEMBER POWERS:  How about shockwaves
           traveling through the steel affecting the crack
                       MR. HACKETT:  Again, as far as -- I would
           see that that could affect the steam generator and the
           steam generator shell could affect and probably would
           affect the steam generator.  I would not think there
           would be a huge impact -- no pun intended -- on the
           reactor vessel.  And again, this is intuitive on my
           part. I don't have any analysis to back that up, nor
           have any been conducted that I'm aware of.
                       MEMBER POWERS:  I guess that until you
           have some substantiation, I'd be cautious about the
                       I think you're probably on better grounds
           on your steam generator tube rupture, but until we
           understand better what these dynamic effects -- sonic
           booms, things like that -- are on the main steam line
           break, I'd be cautious about the conclusion.
                       VICE CHAIRMAN BONACA:  That's why I was
           asking the relative contribution because there is a
           question -- again, I mean, from the defense in-depth
           set point the reliance on operator action has to be
           examined because you're going to give a lot of credit
           to the vessels.
                       MR. HACKETT:  Good point.
                       MEMBER FORD:  Ed, just looking at time, I
           guess we'd better move ahead.
                       MR. HACKETT:  Yes.  I guess what I was
           going to say, we've already effectively handed off to
           Alan, so we'll just let Alan continue with the main
           topic here, which is the uncertainty treatment with
           PRA HR --
                       MEMBER POWERS:  Possibly being a
           controversy associated with --
                       MR. KOLACZKOWSKI:  No.  There couldn't be
           any controversy.
                       First of all, to start this subject off,
           let's keep in mind what the PRA part of this is trying
           to do and what its contribution is to the overall
           analysis.  I tried to succinctly describe that here
           with this bullet.
                       What the PRA is really trying to come up
           with is the frequencies of a wide range of
           representative plant responses, which we'll call
           scenarios, that are each described by some set of T-H
           curves, which will describe the pressure, temperature,
           heat transfer coefficients of the resulting scenario
           -- as the result of mitigating equipment successes and
           failure, as well as operator actions that result in
           various degrees of overcooling of the reactor vessel
           downcomer (phonetic) wall.
                       So, really, if you think about it, there's
           just two things that we're really trying to -- that
           the PRA part is trying to address.  What are the
           scenarios?  And, what are the frequencies of those
           scenarios?  When you start getting into that, there
           are really two sources of uncertainty.  There are
           modeling uncertainties in trying to represent what are
           the plant scenarios of interest, and then ultimately
           there's uncertainty associated with the frequency of
           each one of those modeled scenarios.
                       Let's go to the next slide.
                       From the modeling standpoint, again, just
           think of the fact that each scenario is really a
           collection of events.  It starts with initiating
           event, then the systems do certain things.  Certain
           ones work; certain ones don't.  Operators do certain
           things right or wrong.  That collection of events ends
           up resulting in some sort of a scenario.
                       As I told you, we have something like
           100,000 scenarios or something modeled in this PTS
           model.  One of the things we had to introduce, because
           the operator plays such a key role in when the
           challenge ends or at least get mitigated to some
           extent, etc., that we had to look at various timings
           of operator action.  Obviously, as the event starts
           and the downcomer (phonetic) wall begins to cool down,
           if the operator takes an action five minutes into the
           event, that leads to a very different challenge than
           if he waits to take that action 20 minutes into the
                       So, we actually had to take many of the
           actions and put into the model -- and we picked
           certain discrete points to look at, of operators
           taking actions ten minutes into the event, 20 minutes
           into the event, etc., and therefore had to come up
           with probabilities of each one of those.
                       CHAIRMAN APOSTOLAKIS:  So these times are
           sequence dependent?
                       MR. KOLACZKOWSKI:  yes.
                       CHAIRMAN APOSTOLAKIS:  I mean, you don't
           have a 10-, 20-minute --
                       MR. KOLACZKOWSKI:  Necessarily over
           everything, no.
                       CHAIRMAN APOSTOLAKIS:  Could you give us
           an example of this now?
                       MR. KOLACZKOWSKI:  Yes.
                       CHAIRMAN APOSTOLAKIS:  How did you get the
           -- pick any example you want -- the probabilities for
                       MR. KOLACZKOWSKI:  Probably what we ought
           to do -- now the one that is dominant --
                       CHAIRMAN APOSTOLAKIS:  It's not in your
           main presentation.
                       MR. KOLACZKOWSKI:  It won't be here,
           George, but to try to answer your question, one of the
           most dominant scenarios is a transient where by a
           safety relief valve when the pressurizer gets demanded
           -- it sticks open.
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. KOLACZKOWSKI:  It stays open for a
           while, and as the pressure comes down it finally re-
                       CHAIRMAN APOSTOLAKIS:  Yes.
                       MR. KOLACZKOWSKI:  That's an extremely
           challenging event for the operator because once the
           SRV re-closes -- you've got to remember, a high-
           pressure injection's probably on full at this point
           because the SRV at Oconee is big enough that he needs
           about all the HPI that he can put in.  He's not
           necessarily throttling it yet.  And suddenly the SRV
           re-closes, so the system begins to refill, of course,
           right away and the pressure goes up through the roof. 
           And we're talking over minutes of time.  It's not very
                       In talking with the Oconee operators and
           training staff, they acknowledge this is an extremely
           challenging event for the operator to catch because
           he's also not allowed to throttle HPI until he meets
           certain criteria -- five degrees sub-cooling and
           roughly a hundred inches in the pressurizer.
                       Well, a the sub-cooling comes back up
           after the SRV is re-closed, and the level starts
           coming back up, etc., believe me, you go through that
           sub-cooling and that level real, real fast.  And
           before he knows it, he's got 50 degrees sub-cooling
           and the pressurizer level's up through the top of the
                       We recognized that that event was
           happening so fast, George, was that we did was we
           said, okay, this is an action where we ought to come
           up with a probability for the operator failing to HPI,
           one minute after reaching the throttling criteria; ten
           minutes after reaching the throttling criteria; and
           then we said, or, we're going to assume that if he
           doesn't do it by ten minutes, he never does it.
                       And so, we came up then with recognizing
           what indications would there be?  What did the
           procedures tell him to do?  How is he trained?  Etc. 
           We came up with probabilities of the operator failing
           to throttle at one minute after reaching the
           throttling criteria, ten minutes, or then we assume
           never, as opposed to a slower transient, or maybe, as
           I mentioned, a main steam line break -- w e don't even
           get concerned until ten minutes.  So we didn't even
           choose our first time until ten minutes into the
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MR. KOLACZKOWSKI:  So the times were
           dependent on which scenarios we were looking at.
                       CHAIRMAN APOSTOLAKIS:  As they should be.
                       Now, this evaluation of the probability,
           this was done by asking experts, describing the whole
           thing -- that's what you say in one of the slides on
           the separate meeting.
                       MR. KOLACZKOWSKI:  Yes.  Oconee was done
           in the following way.  NRC contractors got together. 
           We talked about the context of each scenario -- I know
           you've heard this from another project that I won't
                       CHAIRMAN APOSTOLAKIS:  That was my next
                       MR. KOLACZKOWSKI:  We talked about the
           qualitative context, etc.  What's going on?  What are
           the indications doing?  Where are we in the step? 
           Remember, we had observed certain simulations, so we
           had some idea, how long does it take operators to get
           to certain steps, and things of that nature.  What if
           an instrument has failed?  How much would that add as
           a confusion factor?  We may want to put that on the
           tail-end of our distribution.  We talked about a
           number of contexts.
                       Contractors then get together and made an
           estimate with regard to a mean and an uncertainty
           bound on the failure probability.
                       CHAIRMAN APOSTOLAKIS:  (inaudible).
                       MR. KOLACZKOWSKI:  I'm sorry?
                       CHAIRMAN APOSTOLAKIS:  All (inaudible).
                       MR. KOLACZKOWSKI:  Yes.  And there, we
           limited it to four different values.  We said .5, .1,
           .01 or .001.  That had some quantitative definitions
           associated with it.
                       MEMBER ROSEN:  What were those numbers?
                       MR. KOLACZKOWSKI:  .05, .1 --
                       MEMBER ROSEN:  No, no.  What are those
           frequency --
                       MR. KOLACZKOWSKI:  Those were the failure
           probability of the human to take that action at
           whatever time we were looking at.
                       MEMBER ROSEN:  Yes.
                       MR. KOLACZKOWSKI:  We then took that
           information -- after we quantified all the human error
           events in the model, we then provided that to Oconee
           and actually went back down to Oconee and spent the
           day with their training and operator staff, and we
           said what do you think?  We tried to calibrate them in
           probability and so forth, because they also
           understand, this is likely to happen or this is not
           very likely to happen.
                       MEMBER ROSEN:  right.
                       MR. KOLACZKOWSKI:  And you have to ask
           them, well, what does not very likely mean?  Does that
           mean one in a thousand crews would fail, or one in ten
           thousand, or one in a hundred.  So there was a little
           bit of a calibration that had to go on. 
                       But nevertheless, we got through that and
           then we asked Oconee for their comments.  They
           provided comments on our human error probabilities. 
           I would say that they agreed with probably 50 percent
           of them.  The other 50 percent -- generally, they did
           not have too much in the way of major problem with
           most of our means.  In some cases, they thought our
           upper bound was too high.
                       MEMBER ROSEN:  They claimed to be not as
           good as you thought they were?
                       CHAIRMAN APOSTOLAKIS:  No.
                       MR. KOLACZKOWSKI:  No.  They generally
           claimed to be a little -- to be better.  The worst
           crew would be better under the worst conditions.
                       Quite frankly, we agreed with them on a
           few cases but in other places we held our ground and
           said, no, we still think that the range is this wide
           because of the following reason.
                       In other words, Oconee had a change to
           basically review our human error probabilities,
           provide their input to that.  And to some extent we
           changed things; to some extent, we didn't.
                       CHAIRMAN APOSTOLAKIS:  I think that what
           you describe is reasonable.
                       Now, maybe it's not related to this
           project, but we have been told several times that
           ATHENA is being implemented this year in a very
           successful way in the PTS project.
                       MR. KOLACZKOWSKI:  That's in Palisades.
                       CHAIRMAN APOSTOLAKIS:  What -- so you
           didn't do it for Oconee?
                       MR. KOLACZKOWSKI:  Well, I explained what
           we did for Oconee, which is kind of going along the
           lines of where ATHENA was trying to get to.  Remember
           now, it still relies on expert elicitation.  In this
           case, the experts were the NRC contractors, but then
           Oconee did a review.
                       In the case of Palisades, we've already
           done our first cut at the human error probability of
           the Palisades PTS model.  In that case, we did it
           differently.  We actually went up to the plant. In
           three to four days, we had three licensee trainers and
           one operator crew member as experts, and then we had
           two NRC contractors who actually had five experts, and
           we together went through contacts, etc., developed
           probability, got them calibrated, developed
                       And in that case, we did not limit it to
           the .5, .1, etc.  We actually asked for a complete
           distribution -- a one percentile, a 25 percentile, a
           50 percentile, etc.
                       So I guess I would say, as we keep trying
           to apply ATHENA and where it is going better and
           better each time, we're getting more rigorous, and in
           the case of Palisades, we actually wrote down
           everything about the context -- which ones are
           aleatory uncertainties, which ones are epistemic? 
           We're trying to keep doing this better and better as
           it goes, but again, the underlying quantification
           mechanism is an expert elicitation process.
                       CHAIRMAN APOSTOLAKIS:  So in the case of
           Oconee, then, you did not use ATHENA.
                       MR. KOLACZKOWSKI:  I would you say we kind
           of use it.
                       CHAIRMAN APOSTOLAKIS:  You didn't.  What
           you just described is what competent HRA analysts or
           anyone in the world would do.  They understood the
           situation and then they said, this is our best
           judgment.  Now we try -- you know, what do you think,
           and so on.  I mean, there's nothing --
                       MR. KOLACZKOWSKI:  That's true.
                       CHAIRMAN APOSTOLAKIS:  -- I'm not trying
           to put it down.  It's just that it's --
                       MR. KOLACZKOWSKI:  No.  That's true.
                       CHAIRMAN APOSTOLAKIS:  I understand that
                       So, the other thing I have to understand
           is modeling.  Now, by the way, this is human error of
           omission because they don't throttle.
                       MR. KOLACZKOWSKI:  For the most part --
           oh, yeah.  The ones I've been talking about are like,
           failed to isolate a steam generator.  That's an
           omission. Failure to throttle is an omission.
                       CHAIRMAN APOSTOLAKIS:  Is that a
           commission error or something?
                       MR. KOLACZKOWSKI:  We did find one or two
           commission errors that we modeled, such as
           inadvertently tripping reactor coolant pumps when you
           don't want to.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. KOLACZKOWSKI:  That tends to make
           things more stagnant.  And we did look at conditions
           that operators might get fooled into thinking that
           they should do that, and we tried to quantify those.
                       CHAIRMAN APOSTOLAKIS:  And you -- through
           the same process of evaluating it and so on?
                       MR. KOLACZKOWSKI:  The same process.  Now,
           you also find that the procedures do cause acts --
           I'll call them acts of commission that will worsen a
           PTS event by procedure.  But it's because they're
           trying to prevent core damage.  They're trying to
           prevent undercooling.
                       As an example, say you have no feed to the
           steam generators at all.  Well, what they're supposed
           to do is depressurize the plant in sort of an
           emergency mode, open up all the turbine bypass valves
           and try to get condensate into the steam generator. 
           Well, when you do that, it cools down the plant. 
           That's a procedure-driven commission.  It's not an
           error in the sense --
                       CHAIRMAN APOSTOLAKIS:  Right.  So how did
           you handle that?
                       MR. KOLACZKOWSKI:  We handled that and
           basically said, well, he's going to do that.  So, for
           all practical purposes, that's close enough to a 1.0
           probability that that's what's in the model.  He will
           do what his procedures tell him to do.  It turns out,
           it's worse for PTS, but that's handled in the model.
                       CHAIRMAN APOSTOLAKIS:  Okay.  So now we
           have to find another example of modern uncertainty
           that's not related to human errors.
                       MR. KOLACZKOWSKI:  But there are some.
                       CHAIRMAN APOSTOLAKIS:  Yeah, and I'd like
           to see how you quantify those.
                       MEMBER WALLIS:  Do the thermal hydraulics
           people give you ways to predict uncertainties,
           modeling of thermal hydraulics?  Oh, you've -- there
           must a more logical way to do it than that.
                       CHAIRMAN APOSTOLAKIS:  There are
                       MR. KOLACZKOWSKI:  Oh, yes.  I mean, the
           T-H uncertainties are handled in a different way. 
           Now, they end up potentially affecting our model.
                       Let me give you an example.  Actually, it
           will address some of the things that are in the
           presentation anyway, so -- again, the SRV's stuck open
           and re-closes.  We don't know when it's going to re-
           close.  If it re-closes very quickly into the
           accident, again, it's relatively benign from a PTS
           standpoint.  If it re-closes very late in the accident
           and then this sudden repressurization happens, much,
           much worse.
                       So what we did was, we took the possible
           continuum of when the valve could re-close.  And I'll
           grant you, this is very crude, but we basically said
           we're going to discretize out into two points.  It re-
           closes at 6,000 seconds in to the event or it re-
           closes 3,000 seconds into the event.  And we can get
           a little bit into why we picked those particular
                       CHAIRMAN APOSTOLAKIS:  The reason why you
           use seconds is because it's thermal hydraulics?
                       MR. KOLACZKOWSKI:  That's right.  As soon
           as you go to RELAP, everything's in seconds, rather
           than minutes or hours.
                       MEMBER ROSEN:  If it says minutes, you're
           in HRA.
                       MR. KOLACZKOWSKI:  Or, HRA is in minutes. 
           That's correct.
                       MEMBER WALLIS:  These are uncertainties in
           the inputs to RELAPs.  They're uncertainties in the
           RELAP itself.
                       MR. KOLACZKOWSKI:  Yes.  That's a whole
           other issue that Dave can address to some point here.
           But I'll just point out that what we did was we then
           did was discretized the time into two times and ran
           thermal hydraulic runs for the 3,000-second case and
           the 6,000-second case, and then ran those through the
           fracture mechanics code to see how different the
           results would be, and treated that as basically an
           aleatory uncertainty.
                       We don't know when it's going to re-close. 
           We're going to say there's a 50-percent chance it
           closes around 3,000 seconds and there's a 50-percent
           chance it closes around 6,000 seconds.  That's trying,
           if you will, capture the aleatory uncertainty in when
           is it going to close.
                       CHAIRMAN APOSTOLAKIS:  Then you have a
           epistemic on the 30 percent.
                       MR. KOLACZKOWSKI:  But then you have
           epistemic on the 30 percent as to what the frequency
           of that --
                       CHAIRMAN APOSTOLAKIS:  You did that, too?
                       MR. KOLACZKOWSKI:  That is correct. Yes.
                       CHAIRMAN APOSTOLAKIS:  And that was,
           again, by calling expert people?
                       MR. KOLACZKOWSKI:  Yeah.  You had the HRA
           uncertainty, which I described.  You had the
           uncertainty of initiating event frequency, the
           uncertainty of failure probability --
                       CHAIRMAN APOSTOLAKIS:  -- But I meant, for
           the timing of vessel re-closure.
                       MR. KOLACZKOWSKI:  Yes.  You called people
           to get those distributions.  I mean, it was an expert
           opinion kind of --
                       MR. KOLACZKOWSKI:  Yes, but in this case,
           as I said, it was a pretty crude one.  We just said,
           we're going to discretize all the times into two
           times; 3,000 seconds and 6,000 seconds.
                       MEMBER ROSEN:  The fact of the matter is,
           the only thing that knows when it's going to re-close
           is the valve.
                       MR. KOLACZKOWSKI:  That's correct.  And
           it's purely random.  It's not an epistemic
                       MEMBER ROSEN:  It depends upon how it was
           set up and how old it is and what it's commission is,
           and maybe 20 other things.
                       MEMBER FORD:  Could I again -- I assume
           you don't want to go much beyond five.
                       MEMBER ROSEN:  We're having a lot of fun.
                       CHAIRMAN APOSTOLAKIS:  This is stuff we
           have to understand. I  mean, there's --
                       MEMBER FORD:  I know, but there's also a
           whole lot on thermal hydraulic uncertainties, too.
                       CHAIRMAN APOSTOLAKIS:  But I thought they
           were not going to discuss thermal hydraulic
                       MR. HACKETT:  That's one of the things we
           may need some guidance on, given the time, because we
           were shooting towards five, too, for everybody's sake,
           I guess, and Alan has --
                       MR. KOLACZKOWSKI:  Let me go to the last
                       CHAIRMAN APOSTOLAKIS:  That's an excellent
                       MR. KOLACZKOWSKI:  Let me just go to the
           last line -- the one after that.
                       MEMBER POWERS:  We'll make sure that you
           don't make your time limit.  You have listed down here
           operator actions were treated as random events, but
           they would seem to have a strong covariance with the
           initiating event and the mitigating successes or
           failures.  Is that true?
                       MR. KOLACZKOWSKI:  Yes, that's true.  I
           mean, I guess to say that they're purely random,
           that's not the case.  Obviously, training and
           procedures direct certain kinds of actions, and so you
           would expect to see them as more prevalent, that is
           true.  But, yes.  You're right.
                       MEMBER POWERS:  And later on in the slide,
           you say you used Latin hypercube sampling, and that
           means, ipso facto, you have a variance there.
                       MR. KOLACZKOWSKI:  Yes.
                       MEMBER POWERS:  If you're going to turn
           around and use the 95-percent confluence bound on
                       MR. KOLACZKOWSKI:  No.
                       MEMBER POWERS:  That means you much have
           -- well, I mean, you present everything in 85
           percentiles that I've seen.
                       MR. KOLACZKOWSKI:  Yeah, but we gave the
           entire resulting uncertainty distribution to the PFM
                       MEMBER POWERS:  Yeah, but in the end
           they're going to come up with a 95 percentile that
           they're going to show us, right?
                       MR. KOLACZKOWSKI:  Well, that's what
           they're shown you but they can show you the whole
           distribution if we so desire.
                       MEMBER POWERS:  But you haven't got tails
           in the distribution right, because you used Latin
           hypercube sampling.  Your details are all short
           compared to the real details.
                       MR. KOLACZKOWSKI:  Yes --
                       MEMBER POWERS:  Your distributions are all
           peaked.  That's what Latin hypercube sampling does for
                       MR. KOLACZKOWSKI:  Yeah.  It makes a
           process more efficient.  I don't know if I agree --
                       MEMBER POWERS:  -- you get a narrowing of
           the distribution any time you use a Latin hypercube
                       MR. KOLACZKOWSKI:  Not being a
           statistician expert, I've got to think about it.  Yes
           -- but, okay, if you're suggesting that we ought to go
           and also use Monte Carlo or something?
                       MEMBER POWERS:  Monte Carlo will do the
           same thing for you; it just doesn't it as bad.
                       MR. KOLACZKOWSKI:  Well, we can certainly
           use other sampling techniques.
                       MEMBER POWERS:  You can sample until you
           turn blind.  You'll still end up with narrow
           distributions relative to what you'd have if you went
           to an infinite sample distribution.  You've got to
           have some measure of how bad you are.
                       MEMBER FORD:  And to help you with your
           timing, Bill, are you agreed that you have no
           questions on the PFM?
                       MEMBER SHACK:  No.  I think that's rocket
           science compared to the rest of this.
                       MEMBER FORD:  So you don't have to do
           anything on PFM?
                       CHAIRMAN APOSTOLAKIS:  Is PFM an accepted
           approach by the experts?  Is that something that's
           been validated?
                       MR. KOLACZKOWSKI:  Yes.
                       MR. KIRK:  Yes.
                       MEMBER FORD:  There's a whole lot of
           questions I have, which will be --
                       MEMBER SHACK:  Well, there's PFM and
           there's PFM.  I mean, what part of PFM are we talking
           about?  The probability or the fracture mechanics?
                       MEMBER POWERS:  But as a discipline, not
           only is it relatively well established, some of the
           gentlemen involved in this study were part of those
           that established it.
                       MEMBER FORD:  Really?  So, why don't we
           concentrate on this last slide and on then on the
           thermal hydraulic --
                       MR. HACKETT:  All right.
                       MR. KOLACZKOWSKI:  I just want to point
           out that ultimately, what is being provided to the
           fracture mechanics part, the T-H part, essentially the
           output of the PRA part is -- and actually it's coupled
           with the T-H.
                       Imagine that what's being provided as a
           set of T-H curves, which of course are developed from
           the thermal hydraulics portion of this, that
           correspond some scenarios that we say -- okay, these
           scenarios are indeed representative of this particular
           set of T-H curves.  And then, what's the frequency of
           that bin when you add up all the scenarios that are in
           that bin?  What does the frequency of that bin look
                       We described that frequency via histogram
           that then went on to the fracture mechanics people,
           who then sampled this histogram for a given sequence,
           and then of course sampled across all the sequences
           that cause overcooling.
                       When you're sampling across all the
           sequences, you're essentially addressing, if you will,
           the aleatory uncertainty and all the ways overcooling
           an occur.  Then when you sample from the individual
           frequency histogram, you're trying to address the
           epistemic uncertainty in that frequency, when you go
           and ultimately develop the uncertainty in the PFM
                       So again, what's being provided here as a
           bin, a frequency, and that frequency for that bin is
           being described by a histogram, and of course you're
           doing that for some number of scenarios.
                       CHAIRMAN APOSTOLAKIS:  Now, there's an
           interesting comment in one of the viewgraphs from the
           subcommittee meeting.  It said that there were
           situations where uncertainty types were mixed.  And I
           was wondering how you guys handle that.  That was
           slide 64, Current Toughness and Embrittlement models.
                       MR. KIRK:  We fixed that.
                       CHAIRMAN APOSTOLAKIS:  You fixed that. 
           You separate it.
                       MR. KIRK:  We separated it.
                       CHAIRMAN APOSTOLAKIS:  And how did you do
           that?  I mean, was there --
                       MR. KIRK:  I forgot my wizard's hat.
                       MR. KIRK:  We want to do that?  I mean, we
           may as well --
                       CHAIRMAN APOSTOLAKIS:  They were in the
           embrittlement model?
                       MR. KIRK:  Yes.
                       CHAIRMAN APOSTOLAKIS:  I would expect them
           to be there.
                       MR. KIRK:  What we did was we used a
           process, which is shown here -- apparently, I can't
           get my slide show working any more -- whereby we use
           physical models to help to identify -- well, we took
           apart the process to identify where the uncertainties
           are, and then we referenced our non-toughness data,
           which is what mixed the uncertainties, to real
           toughness data to help us to separate out the aleatory
           and epistemic parts so that we could treat them
           separately.  So then, each of the major variables in
           the toughness model -- the index temperatures, the
           toughest variables themselves, were individually
           identified as being aleatory or epistemic.
                       CHAIRMAN APOSTOLAKIS:  When you say either
           one or the other, you mean situations where one
           dominated the other?
                       MR. KIRK:  Yes.  And in reality, one
           dominated.  For example, in the toughness variables
           themselves, the K1-c and K1-a, were dominantly
           aleatory, and so we propagate those uncertainties as
           distributions of the models, whereas the index
           temperatures were predominantly epistemic.  So those
           are sampled.
                       MEMBER KRESS:  Let me see if I understand
           your uncertainty on the frequency again.  You don't
           have to go back to the slides; I'll just ask the
                       You have identified something like
           several, a hundred thousand sequences.  You've binned
           it into 150.  So each of those bins has a lot of
           sequences in it, and somehow each of those sequences
           in that bin has associated with it a frequency, and
           you convert that into a histogram.  Where did the
           frequencies come from in the first place?
                       MR. KOLACZKOWSKI:  Because a scenario is
           a combination of events, they're essentially a
           multiplication of initiating event frequency, time-
           certain failure probabilities of certain equipment,
           time-certain failure probabilities of operator
           actions, each of which has a mean and uncertainty,
           etc., so you end up --
                       MEMBER KRESS:  So you took all hundred
           thousand of these and got their --
                       MR. KOLACZKOWSKI:  Well, no, because of
           course what you find out is that among a hundred
           thousand sequences, there are 500 that really matter. 
           You've got to remember that we threw some sequences
           because --
                       MEMBER KRESS:  Okay, so that histogram may
           have -- for each bin, they have several hundred
           sequences in it?
                       MR. KOLACZKOWSKI:  Some may be as many as
           that.  Some may be as few as just a few sequences.  It
           just depends.
                       MEMBER KRESS:  Now, the frequency of this
           sequence is -- that histogram you had.
                       MR. KOLACZKOWSKI:  Yes.
                       MEMBER KRESS:  Was that just the
           initiating event frequency, or --
                       MR. KOLACZKOWSKI:  No.  That's ultimately
           -- imagine that, if you will, as to all the sequences
           that are in that bin mushed together to get what is
           the frequency of that bin and the uncertainty in that
                       MEMBER SHACK:  It's sort of the frequency
           of the thermal hydraulic event associated with that
                       MR. KOLACZKOWSKI:  Yes.
                       VICE CHAIRMAN BONACA:  So there's specific
           trend, pressure temperature.
                       MEMBER SHACK:  The depreciating
           frequencies have all been narrowed down, and you're
           coming up with eight.  What you're really getting is
           a frequency of a thermal hydraulic event.
                       VICE CHAIRMAN BONACA:  Right.  All the
           bunches of sequences in the bin will have a pressure
           temperature behavior that resembles the one that
           you're --
                       MEMBER SHACK:  And he's got an epistemic
           distribution because all of his frequencies -- in
           fact, he doesn't have any number.  He's got a
           distribution for each of his frequencies.  He's got a
           probability that something will happen, but each of
           those probabilities has an epistemic distribution.
                       MEMBER KRESS:  And he takes the mean of
                       MR. KOLACZKOWSKI:  Well, ultimately it
           calculates the mean.  We don't really pass the mean
           necessarily along, although we could.  We provide --
           the resulting distribution goes to the PFM folks.  If
           they want to know what the mean is, they can figure it
           out, but we give them the whole distribution.
                       MEMBER POWERS:  What you send to them is,
           in fact, a histogram, right?
                       MR. KOLACZKOWSKI:  That  is correct.  We
           send them the histogram.
                       MEMBER POWERS:  And I think that because
           you send them a histogram, what they get is an
           artificially narrowed distribution.
                       MR. KOLACZKOWSKI:  I've taken your note on
           that.  We will do some other sampling techniques and
           see how much it changes.
                       CHAIRMAN APOSTOLAKIS:  Now I'm curious. 
           You have all these -- I mean, you said earlier that
           the dominant model uncertainty was quantified using
           expert judgment and that was one of the most --
                       MR. KOLACZKOWSKI:  For example, when the
           SRV re-closes.
                       CHAIRMAN APOSTOLAKIS:  -- and so on.  So
           if I go now to the early slide that showed -- yes, the
           preliminary results for Oconee 1, and you recognize,
           or you conclude, that there are orders of magnitude --
           the current results are four orders of magnitude lower
           after 40 years of operation, two orders at the current
           screening -- yes, exactly.
                       And knowing that a lot of this stuff
           really depends on expert judgment, if I were a
           structuralist, I would ask myself, what if I'm wrong. 
           And I would leave Regulatory Guide 1.154's criteria
           alone because if I'm wrong, I'm wrong -- right?  So,
           would Dr. Powers agree with this kind of thinking?
                       MEMBER POWERS:  No.  This is not one where
           I'll go along with you.
                       CHAIRMAN APOSTOLAKIS:  I'm a structuralist
           and I recognize that they've done an excellent job,
           but my goodness, they depend on expert judgment a lot,
           and experts have been wrong.
                       MEMBER POWERS:  They certainly have a
           history of being wrong more often than they are right. 
           That is absolutely true.
                       CHAIRMAN APOSTOLAKIS:  So I'm scared now. 
           I want to be a structuralist.
                       MEMBER POWERS:  Okay.  You're going to be
           a very conservative structuralist.
                       CHAIRMAN APOSTOLAKIS:  Oh, now we have a
           new classification.
                       MEMBER FORD:  But George, surely, now
           you're arguing about what that risk criteria should
                       CHAIRMAN APOSTOLAKIS:  No, I'm not arguing
           with them.  I'm arguing with him.
                       MEMBER FORD:  Oh, okay.
                       MEMBER SHACK:  You're still arguing over
           the frequency.  We haven't even gotten to the risk
                       MEMBER FORD:  That's my point.  Let's my
                       MR. KOLACZKOWSKI:  George, we're trying to
           be risk-informed.
                       CHAIRMAN APOSTOLAKIS:  But if I'm a
           structuralist defense in-depth (inaudible), then I'm
           not risk-informed.
                       VICE CHAIRMAN BONACA:  Well, no but if a
           structuralist wants to know what the consequences are,
           then --
                       CHAIRMAN APOSTOLAKIS:  And then say, what
           if you're wrong and goes back --
                       VICE CHAIRMAN BONACA:  Well, no, he tries
           to be reasonable.
                       CHAIRMAN APOSTOLAKIS:  Oh.
                       MEMBER POWERS:  That's why we have a
           containment building.
                       MEMBER FORD:  I'm trying to get through by
           five o'clock here, George, and we've got all the
           thermal hydraulic stuff here.
                       CHAIRMAN APOSTOLAKIS:  That would mean
           it's just too much work --
                       MEMBER POWERS:  It's a well-established
                       CHAIRMAN APOSTOLAKIS:  It's a well-
           established science.
                       VICE CHAIRMAN BONACA:  Oh, yes.  Cracks
           propagate, then it could be trouble.
                       MR. BESSETTE: I'll try to go quickly
           through thermal hydraulics.
                       MR. KOLACZKOWSKI:  Yeah, you're going to
                       CHAIRMAN APOSTOLAKIS:  Let me understand
           this.  You said earlier in answering a question that
           we will not discuss thermal hydraulics today. What is
                       MEMBER FORD:  I said we wouldn't discuss
           the criteria today.
                       CHAIRMAN APOSTOLAKIS:  No, no, no.
                       MEMBER SHACK:  Just the fundamental
           verification of the RELAP code today.
                       MR. BESSETTE: Yes.  We wouldn't talk about
           the general validation of RELAP, overall assessment
                       MEMBER SHACK:  This now assumes that RELAP
                       MR. BESSETTE: Yes.  This assumes that
           RELAP has some connection with reality.
                       CHAIRMAN APOSTOLAKIS:  It says, RELAP 5
           Internal Model Uncertainty.
                       CHAIRMAN APOSTOLAKIS:  So you recognize
           the uncertainties.
                       MR. BESSETTE: So we were faced with --
           first of all, we tried to classify what we were
           dealing with.  And so, we categorize things into
           events, sequence modeling and mapping, just basically
           trying to determine what bins we're dealing with.
                       We realized early on that what was
           dominating the outcome, or the uncertainties, in these
           events was not the physical remodeling of RELAP but
           rather the definition of the sequences.  And there, we
           worked a great deal with the PRA people.
                       So, my breaking down the sequences into
           finer bins, we were getting much better -- you know,
           a greater return on our --
                       CHAIRMAN APOSTOLAKIS:  I don't understand. 
           I'm confused now.
                       MEMBER WALLIS:  I think what you're saying
           is there's much more uncertainty in the PRA modeling
           than there is in the RELAP.
                       MR. BESSETTE:  That's right.  If you
           strain the sequence a little bit, you can get
           significantly different outcome, in terms of does the
           operator act or not act, does the valve open or not
           open.  It's much greater determinant to these key
           factors of temperature and pressure than the physical
           models within RELAP. So, we put a great deal of effort
           into expanding and defining the bins. That's one thing
           we spent a great deal of time on.
                       Then you get into the use of RELAP itself,
           and again, we can categorize that according to the
           uncertainty in the hundreds of physical and empirical
           models that comprise RELAP and basically in the
           preparation of the input deck, how you model the
                       The first category of this thing is, we
           treated -- we tried to decide what are the dominant
           modeling features of RELAP that would affect the
           answer.  With regard to the latter, we simply tried to
           model the plant as best we could using standard
           practice of globalization --
                       MEMBER WALLIS:  How do you put numbers on
           that say RELAP 5 Internal Model Uncertainties?
                       MR. BESSETTE: Well, what we do is we go
           through it like a PIRT process.  We go through a PIRT
           process to try to identify the most important physical
           models and the most important boundary conditions that
           would affect the things we're concerned with, which is
           temperature and pressure. So, we tried to decide that
           we have a proper list to do our sensitivity studies.
                       CHAIRMAN APOSTOLAKIS:  Didn't you get some
           expert opinion or recitation by (inaudible)
                       MEMBER WALLIS:  That's what it is.
                       MR. BESSETTE: We did that.  We had
           available -- two prior PIRTs that were done for
           perforized thermal shock -- one at the time of Yankee-
           Rowe and one for H.B. Robinson.
                       CHAIRMAN APOSTOLAKIS:  But the PIRTs do
           not quantify uncertainty, do they?
                       MEMBER WALLIS:  No.
                       MR. BESSETTE: The PIRTs, no.  The PIRTs
           simply list things that are thought to be most
                       CHAIRMAN APOSTOLAKIS:  So you went to
           experts after that to get probabilities, to do what
           Alan did, or you did not do that?
                       MR. BESSETTE: So, for each thing you think
           is important, then you decide how much you want to
           arrange it.
                       MEMBER WALLIS:  So you arrange things like
           correlations?  Do you put a fudge factor on heat
           transfer correlation or something?
                       MR. BESSETTE: That's right.
                       MEMBER WALLIS:  Well, I can understand
           doing that work, but I don't know how you get this
           Internal Model Uncertainties in RELAP because of the
           way it, itself, is structure.  It has certain
           conservation laws that no one ever seems to question
           the way they're formulated.  But they lead to
           uncertainties because they are great simplifications
           of what's actually happening.
                       MR. BESSETTE: Well --
                       MEMBER SHACK:  One example might be this
           break flow calculation.  That's sort of one explicit
           way you treated a model uncertainty, isn't it?  You
           got that one?
                       MR. BESSETTE: We lost you.
                       MR. BESSETTE: This is the list we came up
           with.  On the left-hand side, we have the
           uncertainties -- the dominant uncertainties in terms
           of the boundary conditions of the analysis.  That's
           things like break size, break location, decay heat,
           the temperatures of the --
                       CHAIRMAN APOSTOLAKIS:  So these were
           treated --
                       MR. BESSETTE: These were each --
           everything that you see on this list here was treated.
                       MEMBER WALLIS:  But there's nothing here
           about the code itself.  Well, the right-hand side
           related --
                       MEMBER WALLIS:  If you put a heat transfer
           coefficient, you put it into this big machine called
           RELAP, there's nothing here about how uncertain RELAP
           itself is because of the way it's built.
                       MR. BESSETTE: Well, you know, I think
           there you're going back to the question of the
           relationship between RELAP and reality -- things like
           flow regime maps and conservation equations, which
           rely on a much broader --
                       MEMBER WALLIS:  But you can quantify that,
           too, by comparison with date.  That's what we make
           people do at CSAU.
                       MR. HACKETT:  I think Dr. Wallis is
           exactly right.  Jack Rosenthal was here at the last
           meeting with the subcommittee, and I'm certainly no
           expert in this area, but I think he assured us that
           the RELAP -- I'm sure Dr. Wallis knows this -- has
           been extensively benchmarked by experiments, and --
                       MEMBER WALLIS:  I'm sorry, but that sort
           of benchmarking usually consists of people looking at
           data and saying, well, the line isn't too far from the
           data.  We're in a  more sophisticated world now.  We
           actually want quantitative measures of those
                       MR. HACKETT:  That's correct.
                       MEMBER SHACK:  One thing they did when
           they  made the presentation to the subcommittee was --
           just take the break flow as one example.  There are
           various models for the break flow.
                       CHAIRMAN APOSTOLAKIS:  Where is that? 
           What are you looking at?
                       MEMBER SHACK:  It would be page 51 of the
           big viewgraph package that you have.
                       CHAIRMAN APOSTOLAKIS:  The big viewgraph,
           from the subcommittee meeting.
                       MEMBER SHACK:  From the subcommittee.  And
           so the different break flow models gave you different
           flow rates.  The way they handled that was essentially
           to vary the break flow area.  You know, you can either
           have a different -- for a given break flow area, you
           can have a different break flow model but instead,
           because you can't do that all that handily, they took
           one model and varied the break flow rate.
                       MEMBER WALLIS:  I understand all that, but
           there's this -- the assumption is that the machinery
           of RELAP is deterministic and exact once you put these
           various uncertainties and --
                       CHAIRMAN APOSTOLAKIS:  But the question
           is, if they do that -- they say they varied the break
           area by 30 percent to account for model differences. 
           Was there a probability assigned, then, to the
           different curves?
                       MR. KOLACZKOWSKI:  George --
                       CHAIRMAN APOSTOLAKIS:  That's the issue
                       MR. KOLACZKOWSKI:  The answer is, we
           varied those by the amounts that we decided.
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MR. KOLACZKOWSKI:  And then basically we
           did a run -- well, suppose it's 30 percent greater;
           suppose it's 30 percent less.
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MR. KOLACZKOWSKI:  If we found that it
           wasn't going to make much difference in the
           temperature or pressure or heat transfer coefficient
           response, in fact it was entirely dropped.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. KOLACZKOWSKI:  Only if it was making
           a big change, then we went through this more -- as you
           say, a process of saying, okay, let's capture that
           uncertainty, let's weight it by some expert opinion,
           etc.  And that was done on a few variables that seemed
           to really matter.
                       CHAIRMAN APOSTOLAKIS:  Okay.  All right. 
           All right.  But that's what --
                       MR. KOLACZKOWSKI:  I think that one of the
           things that Dave was trying to get at, which is fine,
           is that the things that really matter are more when
           the operator does the action; probably not
           uncertainties in the actual RELAP code.
                       MEMBER WALLIS:  These aren't internal
           modeling uncertainties in RELAP, though.
                       MR. KOLACZKOWSKI:  Sorry.
                       MR> WALLIS:  These are not internal
           modeling uncertainties in RELAP itself.
                       MR. KOLACZKOWSKI:  No, although -- and
           again, these are surrogates in some cases to try to
           get at what those uncertainties might be.
                       CHAIRMAN APOSTOLAKIS:  but you did try to
           quantify some of the internal model uncertainties --
                       MR. KOLACZKOWSKI:  Yes.
                       CHAIRMAN APOSTOLAKIS:  -- even though the
           operator actions dominate.
                       MR. KOLACZKOWSKI:  Yes.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. BESSETTE:  So we go through these
           multi-step -- we go through the operator uncertainty
           and --
                       CHAIRMAN APOSTOLAKIS:  So the general
           approach was, you know, identify -- not only here but
           in the full project -- identify what's important and
           then subjectively, through expert judgment and
           dissertation, assign --
                       MR. KOLACZKOWSKI:  Do the uncertainties on
           the things that were important enough to do it on, and
           not on everything.
                       MR. HACKETT:  I think that one of the
           things we mentioned at the subcommittee meeting that
           we didn't mention at the start of this -- of course,
           that treatment is not equal across the disciplines. 
           In some cases, we had the benefit of a lot more rigor
           and a lot more data; in other cases, we didn't.
                       CHAIRMAN APOSTOLAKIS:  Well, presumably
           that's reflected on the uncertainties.
                       MR. HACKETT:  Yes.
                       CHAIRMAN APOSTOLAKIS:  okay.  I think we 
           understand.  At least I understand.
                       MEMBER WALLIS:  Well, I don't understand,
                       CHAIRMAN APOSTOLAKIS:  All right.  Ask
                       MR. RANSOM:  Just one quick question --
                       CHAIRMAN APOSTOLAKIS:  Please identify
                       MR. RANSOM:  Victor Ransom.
                       When you plot the temperature versus time,
           is that the code link temperature in the affected
                       MR. HACKETT:  It should be the downcomer
                       MR. RANSOM:  Well, then I'm wondering how
           you have four loops presumably mixing together, and
           then in RELAP 5 these are all mixed into a one-
           dimensional downcomer.  That wouldn't give you the
           worst-case temperature that you might see at the
           entrance of the code link to the downcomer.  I'm
           wondering, how did you account for that effect?
                       MR. BESSETTE: Well, we -- our focus is on
           the temperature in the downcomer in the region
           adjacent to the core.  What we found was that by the
           time you get down there, things are pretty well mixed. 
           We don't see a lot of circumf- --
                       MEMBER WALLIS:  Azirmuthal.
                       MR. BESSETTE: -- azirmuthal variation.
                       MR. RANSOM:  That would surprise me.  I
           would think you'd find the maximum temperature and
           overcooling near the entrance of the *code link that's
                       MR. BESSETTE: Yes, but we don't care about
           that so much. It's not that temperature we're focused
           on.  Our focus is on the downcomer temperature.
                       MEMBER SHACK:  It's the worst temperature,
           but the vessel is tough up there, so you have to look
           where the vessel is brittle.
                       MR. RANSOM:  Okay.
                       MR. KOLACZKOWSKI:  You have to go down
           significantly lower, where the fluence is high and the
           embrittlement is happening.
                       MR. RANSOM:  So you attempt to use the
           mass mean temperature, I guess, at that point, huh, in
           the downcomer?
                       MR. BESSETTE: Yes.  We supply a single
           temperature boundary condition to the fracture code.
                       MEMBER WALLIS:  Do you give it
                       MR. BESSETTE: That's the -- that was the
           uncertainties --
                       MEMBER WALLIS:  But you don't give
           uncertainties based on sort of input parameters, not
           the way the code works itself?
                       MR. BESSETTE: Well, we try to do both.  We
           try to take into account both things like temperatures
           of the safety ejection water.
                       MEMBER WALLIS:  Well, there's nothing
           there that says that modeling of conservation laws in
           RELAP contributes uncertainty.
                       MR. BESSETTE: Other than when the
           treatment of the --
                       MEMBER WALLIS:  That leads to
                       MR. BESSETTE: Yes.  So we did consider
                       MEMBER WALLIS:  Well, you say they were
           validated.  That's not a measure of uncertainty.
                       MR. BESSETTE: What we validated is when
           the assumption -- did not contribute significantly to
                       MEMBER WALLIS:  Well, you've got to say
           how much uncertainty it contributes, and the
           validation should end up in a measure of uncertainty,
           which is quantitative, not --
                       MR. KOLACZKOWSKI:  Dave, go to the slide
           that has six, seven and eight on it -- Uncertainty,
           two out of three.
                       I mean, what they did was, they ran a
           whole lot of cases, which is what's trying to be
           illustrated on the left-hand side.  Different break
           flows, different -- summer or winter -- whatever,
           which, granted, is not directly getting at some of the
           code on certainties but is trying, in a surrogate way,
           address some of that.
                       MEMBER WALLIS:  I understand what's you've
           done, but if you'd run a different code, you know, a
           different structure, a different way of handling
           conservation laws, one-dimensionality -- on these,
           you've got different answers, irrespective of all this
           stuff.  That's sort of what I'm getting at.  It's
           something which I don't think the Agency knows how to
           handle yet.
                       MEMBER KRESS:  One of the things they do,
           Graham, is they take situations which they know
           analytical solutions, and then they run the code to
           see how well it does it.  And it gives you a little
           bit of confidence that the code, as a structure put
           together, is doing something correctly.  That doesn't
           lead to quantification of what you're talking about,
           but it gives you a little more confidence, if they do
           enough of that with enough known results.
                       But I agree with you.  If you used a
           different code to do all this, you'd get a different
           result, but it may not be that much different.
                       MR. BESSETTE: Of these 150 calculations,
           we did run five -- the selected five of them were ran
           on TRAC.  Well, you can say, well, TRAC is not a
           different code, but we got similar results.
                       MR. HACKETT:  I guess I'd interject at
           this point and --
                       CHAIRMAN APOSTOLAKIS:  Regarding the
           transients you use, I saw LOCAs and steam line break
           becoming -- I know the French have had a concern about
           cooldown in a low-power and shutdown condition, where
           you have repressurization.  And they. in fact, are
           making planned changes for that.  Have you looked at
           those kind of scenarios?
                       MR. KOLACZKOWSKI:  Yes.  And in fact,
           among the low power, that same SRV re-closure event
           is, again, a pretty bad event.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. KOLACZKOWSKI:  Of course, you're being
           helped by the fact that the portion of the year that
           you're at low power is a lot less, so it tends to
           drive the frequencies down.  But nevertheless, yes,
           it's included in the model, and in fact it's among our
                       MR. HACKETT:  I guess what I was going to
           say is, I guess we'd need, at this point, maybe to
           take an action that -- we're suffering, obviously,
           here from trying to condense an awful lot into too
           short a time frame.  It's probably overly ambitious. 
           I apologize for that.  I think we need to come back
           and at least address the thermal hydraulics area in
           greater detail in a separate meeting, if we don't want
           to hold people over who have other obligations.
                       MEMBER FORD:  I agree.  The purpose of
           this meeting was to just get a feeling as to whether
           you're going the right direction and whether there are
           any fundamental errors in the way that you're
           proceeding.  And I've got a draft letter going on
           those lines.
                       If we do have outstanding question that
           seem to be relating on the uncertainty aspect, maybe
           we've got a different meeting to address those
           specific issues.
                       MR. HACKETT:  We'll be glad to so that.
                       MEMBER FORD:  Do you have a summary slide
           to --
                       MR. HACKETT:  We have a plain-language
                       CHAIRMAN APOSTOLAKIS:  Oh, the plan
                       MR. HACKETT:  Or the lack of plain
                       CHAIRMAN APOSTOLAKIS:  We've seen that.
                       MR. HACKETT:  You've seen that.  In case
           we had had an emergency in the day and a half, we had
           this prepared.  To go to Dr. Rosen's point, where is
           this all going, where we're hoping this is going at
           this point is, we have a lot of work to do, is the
           bottom line.  We have three more plants to analyze, an
           awful lot of runs of a lot of codes to do, a lot of
                       I think that one of the questions came up
           is, once we get all these four plants, we need to make
           the sort of quantum jump to generalizing that result
           to the whole PWR fleet.  So we have a fair bit of work
           ahead of us, I think it's fair to say.  and probably
           at the -- I'd be willing to go so far as to say, end
           of the summer time frame, we might be in a position to
           have a lot of that done and be ready to speak to that
           in a more generalized sense.  In the meantime, we're
           happy to come back and hit any one of these in more
                       MEMBER FORD:  If I could make a suggestion
                       MEMBER ROSEN:  You didn't answer my
           question, exactly.  My question was, when you're done
           with all of that, what do you do?  Do you propose a
           Notice of Proposed Rulemaking to amend 50.61.
                       CHAIRMAN APOSTOLAKIS:  Your microphone --
                       MEMBER ROSEN:  My question was, at the end
           of all that, do you go to a proposed rulemaking to
           address revisions to 50.61?
                       MR. HACKETT:  Yes.  I'm sorry.  I started
           rambling there and didn't close that loop.  The
           schedule that we're proposing right now, that we're
           still in some debate with amongst the management, is
           that we would have a technical product that's the
           technical basis that's the result of all this work
           we're talking to you about here in about the November
           time frame, at which point we would that hand that
           product off to NRR.
                       NRR has already budgeted resources to
           initiate rulemaking  on a revised 50.61.  We would
           continue some of the technical work to finalize that
           in parallel, and we would be working closely with NRR. 
           That, in and of itself, as you know, is probably two-
           to three-year process in and of itself.
                       MEMBER FORD:  If I could make a
           suggestion.  In the shorter term -- i.e., the next
           three months --
                       MEMBER POWERS:  Peter, you have to use
           your microphone, just like everybody else.
                       MEMBER FORD:  Aye, but he understands me. 
           He comes from the right country.
                       MEMBER POWERS:  And you come from the
           North, which is considered somewhat less than
                       MEMBER FORD:  If I could make a
           suggestion.  I think the subcommittee -- we had a full
           one and a half days and we went into a lot of detail;
           maybe not quite so much detail in some of the thermal
           hydraulics and the PRA.  But I think that we've got
           enough of a background to write an informative letter
           for EDO tonight, or in the next couple of days.
                       But I do suggest that within the next two
           months, we do have a subcommittee meeting with the PRA
           and thermal hydraulics people to go over the
           outstanding questions.  I don't think, quite honestly,
           they're show stoppers, but I do think that it could
           give us some useful advice.
                       MEMBER WALLIS:  Could I say something
           about thermal hydraulics here?
                       MEMBER FORD:  Yes.
                       MEMBER WALLIS:  I think that these codes
           like RELAP, historically, have been validated by
           looking how assumption and so on affect figures of
           merit for court damage, such as peak clad temperature. 
           And we had all these justifications that RELAP's okay
           because you can change all these assumptions and peak
           clad temperature doesn't change.
                       But we're not talking about peak clad
           temperature.  We're talking about temperature in a
           downcomer, and I don't quite know how well RELAP's
           been validated for that, so that's the sort of thing
           I will ask at the next meeting when we talk about
           thermal hydraulics.
                       MEMBER FORD:  Okay.  I'll pass it back to
           you, George.
                       CHAIRMAN APOSTOLAKIS:  Thank you, Peter.
                       When I see a slide like this, I'm
           wondering if we're doing this again 20 years from now. 
           Where do you think your successors will say, this and
           this and this is better or worse than we thought it
           was?  "Thought" meaning what you think now.  Where is
           your major uncertainty here that might be revised?  I
           mean, your colleagues of 20 years ago were doing also
           a good job at the time, right?
                       MR. HACKETT:  Actually, I guess maybe some
           combination of us can answer that. I can speak to a
           few pieces at least, and there I'll give credit to our
           predecessors.  I think 20 years ago, it was recognized
           that the flaw density and distribution was a major
           player in this thing, with the work that came out of
           the U.K. with the Marshall Committee.  They did a
           tremendous body of work on that.  They did as good as
           they could at the time.
                       They did as good as they could at the
           time.  We've had a lot of resources brought to bear on
           that, since -- where we've cut up reactor vessel
           welds, for instance -- and we've seen what flaws are
           there that's helped refine this thing and make it more
                       But that's been a huge impact on this
           project because previously we were assuming from the
           Marshall Distribution there were some very large
           flaws, and we didn't know what else to do at the time
           in fracture mechanics, so we put them all on the
           surface.  A huge conservatism in the project -- that's
           just --
                       CHAIRMAN APOSTOLAKIS:  But they knew that
           it was a major concern?
                       MR. HACKETT:  They did.  That was one that
           I think that the folks sitting around back in the
           early '80s would have said -- in fact, when I read the
           Marshall Report, they said, don't use this for very
           long.  Unfortunately, we did.  We didn't have the
           wherewithal to get the research done in as timely a
           fashion as we like.
                       But one of their cautions was, you know,
           we're pretty far out on a limb here, so don't be
           utilizing this ten years from now, and we were.  So,
           we're only getting to that point now, so we're late
           but I think we've finally gotten there in the right
           way, and that's just one example.  I think there are
           many in the --
                       CHAIRMAN APOSTOLAKIS:  But the cooldown
           rates were the same.  I mean, everybody knew 20 years
           ago that they were excessive and I don't know why, in
           fact, it wasn't questioned further.  I mean, there was
           no operator action to intervene.  there was nothing
           that --
                       VICE CHAIRMAN BONACA:  -- going forever
           until simply the system couldn't cool down anymore.
                       MR. HACKETT:  Good point, too.  The other
           ones we're familiar with, at least speaking in the PFM
           area, the material -- we've made some assumptions that
           the material I think frankly was probably a lot more
           embrittled than it really is, in general terms.
                       There were some conservatisms that came
           out of the foundations of ASME code, Sections 3 and
           11, and I think we're find out that they were indeed
           conservative, that these materials are, on balance,
           significantly tougher than we've given them credit
           for, and we now have the science and the refinements
           in fracture mechanics to bring some more accuracy to
           that area.  And that's not the only area.
                       MEMBER POWERS:  And it seems to me that
           what you're saying -- and correct me if I'm wrong --
           is that we've researched these vessel materials and
           their irradiation to the point that we have a
           satisfactory understanding of that material?
                       MR. HACKETT:  I think that's always a good
           question because I don't want to shoot our research
           program in the foot.
                       MR. HACKETT:  We have been challenged --
           Dr. Powers knows this, I'm sure -- we have been
           challenged as to why we're still looking at vessel
           materials 30 years after we initiated the project at
           Oak Ridge.  And the answer to that is, of course, it's
           a dynamic situation.  We didn't know at the time that
           project was initiated what a bad actor copper was in
           welds.  We didn't know what synergisms of manganese
           and nickel. So, there are things that have changed
           over time and valid reasons to continue to work.
                       I think, you know, for those of you
           familiar with this technology S curve, we're way up on
           the curve when it comes to understanding the material
           behavior, if not on a plateau, very close to it.  So,
           we are, I think, at some point reaching a level of
           diminishing --
                       MEMBER POWERS:  A point of diminishing
           returns where maybe that -- resources could be
           redirected toward more 00
                       MEMBER ROSEN:  This is a conclusion about
           the heavy section steel technology program?
                       MEMBER KRESS:  All right.
                       MEMBER ROSEN:  Or are you moving towards
                       MEMBER POWERS:  Something -- redirect
           those resources to something more useful, like --
                       MEMBER ROSEN:  ATHENA --
                       MEMBER POWERS:  understanding ATHENA --
                       MR. HACKETT:  That said, I feel it
           incumbent on my position to make a plug for the HSST
           program, or should I say what remains of it, in
           reflecting that in the RES budget.  The HSST program
           funding has declined significantly, I think exactly
           for that reason.
                       At one point, the committee will probably
           remember that was a major multi-million dollar effort
           where we were doing a lot of testing of large-scale
           specimens.  The effort now is on the order of $4- to
           $500,000 per year that's mainly aimed at analytical
           and advanced fracture mechanics. so, I think that has
           been reflected in the RES budget, and in our budget
           assumptions.  It's a lesser effort than it used to be.
                       MEMBER KRESS:  Yeah, but you didn't really
           answer George's questions.  What you said that I heard
           was that these are the things in the original --
                       CHAIRMAN APOSTOLAKIS:  Right.
                       MEMBER KRESS:  -- that we knew were bad,
           and now we've improved that.  Twenty years from now,
           what is going to be the theme?
                       MR. KIRK:  I think you'll probably many of
           the same things.  For example, we've, you know --
                       MEMBER KRESS:  You can improve these
                       MR. KIRK:  Further improve -- I mean, Ed
           correctly pointed out that we've gotten significant
           benefit from our advanced understanding of fracture
                       Having said that, you know, I know there's
           a factor in the simulation right now, where we've got
           an uncertainty programmed in -- I can show you the
           equation -- of 180 degree Fahrenheit on the transition
           temperature, that if you made a more direct
           measurement of the vessel, which is -- it's possible
           to do it today but it's simply not practical to
           require it of the licensees.
                       But if you made a more direct measurement
           and had the stated knowledge that you could ensure
           that that more direct measurement adequately
           represents the material in the vessel, you could take
           that 180-degree uncertainty and turn it off.
                       So, there's a fairly substantial and I
           think quantifiable benefit that one could derive from
           going from what is certainly a more state of knowledge
           in fracture mechanics, but still predominantly
           empirically based to one that's more driven by the
           physics, so that we know the origin of these
           uncertainties.  And I'm sure there are examples in
           other areas.  But I suspect that the answer is, again,
           you know, more of the same.
                       MR. HACKETT:  I think also, to elaborate
           on that, based on these advancements in all three of
           these areas, one of the things to look forward to with
           the next generation with the advanced plants is, I
           don't think we need a PTS rule for those plants.  So
           probably -- I mean, and there are our colleagues --
                       MEMBER KRESS:  They're going to control
           the chemistry in the vessel and stop the fluids.
                       MR. HACKETT:  -- our colleagues in the
           Navy who have been doing this and had the advantage to
           build new machines, they know how to do it.
                       CHAIRMAN APOSTOLAKIS:  Are you requesting
           a letter?
                       MR. HACKETT:  Yes.  I think what we talked
           about with Dr. Ford was a letter at least indicating
           generally, you know, how the committee felt about the
           key areas would be indicated.
                       CHAIRMAN APOSTOLAKIS:  Okay.  Any other
           comments from the members?
                       (No response.)
                       CHAIRMAN APOSTOLAKIS:  Thank you very
           much, gentlemen.
                       MR. HACKETT:  Thank you.
                       MR. KIRK:  Thank you.
                       CHAIRMAN APOSTOLAKIS:  I suggest we take
           a short break this time and then come back and discuss
           a few things of great importance.  How about 5:30,
           we'll be back.
                       (Off the record at 5:21 p.m.)

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