492nd Meeting - May 2, 2002

                    Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               492nd Meeting: OPEN SESSION

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Thursday, May 2, 2002

Work Order No.: NRC-356                         Pages 1-48/60-226

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433             UNITED STATES OF AMERICA
                     + + + + +
                   492ND MEETING
                     + + + + +
               THURSDAY, MAY 2, 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            Member
                 THOMAS S. KRESS          Member-at-Large
                 GRAHAM M. LEITCH         Member
                 DANA A. POWERS           Member
                 VICTOR H. RANSOM         Member
                 STEPHEN L. ROSEN         Member
                 WILLIAM J. SHACK         Member
                 JOHN D. SIEBER           Member
                 GRAHAM B. WALLIS         Member           ACRS STAFF PRESENT:
           JOHN T. LARKINS       Executive Director, ACRS/ACNW
                                 Designated Government Official
           SHER BAHADUR          Associate Director, ACRS/ACNW
           HOWARD J. LARSON      Special Assistant, ACRS/ACNW
           SAM DURAISWAMY        Technical Assistant, ACRS/ACNW
           PAUL A. BOEHNERT
           ALSO PRESENT:
           ZENA ABDULLAHI        NRR
           TONY ATTARD           NRR
           GOUTAM BAGELI         NRR
           S. SINGH BAYWA        NRR
           HERB BERKOW           NRR
           TAMMY BLOOMER         NRR
           RALPH CARUSO          NRR
           ED CONNECE            NRR
           RAJ GORJ              NRR
           JOHN GOSHEN           NRR
           DONNIE HARRISON       NRR
           GARY HOLAHAN          NRR
           T.W. C. HUG           NRR
           EDWARD D. KENDRICK    NRR
           RALPH LANDRY          NRR
           ALSO PRESENT: (Cont'd)
           RICHARD LOBEL         NRR
           KAMAL MANOLY          NRR
           L.B. (TAD) MARSH      NRR
           RALPH MEYER           NRR
           BRENDA MOZAFARI       NRR
           YURI ORECHWA          NRR
           K. PARCZEWSKI         NRR
           ANNE PASSARELLI       NRR
           ROBERT PETTUS         NRR
           J.H. RAVAL            NRR
           HERALD SCOTT          NRR
           MOHAMMED SHUMBI       NRR
           DAVID TERAD           NRR
           D. THATCHER           NRR
           N.K. TREHAN           NRR
           S.D. WEERAKKODY       NRR
           ERIC WEISS            NRR
           JARED WERMIEL         NRR
           JIM WIGGINTON         NRR
           ALAN LEVIN            OCM/RAM
           FAROUK ELTAWILA       RES
           JOCELYN MITCHELL      RES
           JASON SCHAPEROW       RES
           ALSO PRESENT: (Cont'd)
           CHARLES TINKLER       RES
           LEONARD R. BELLER     Progress Energy, CP&L
           TOM DRESSER           Progress Energy, CP&L
           PAUL FLADOS           Progress Energy, CP&L
           C.J. GANNON           Progress Energy, CP&L
           MARK GRANTHAM         Progress Energy, CP&L
           ROBERT KITCHEN        Progress Energy, CP&L
           MARK A. TURKAL        Progress Energy, CP&L
           MICHAEL S. WILLIAMS   Progress Energy, CP&L
           BLANE WILTON          Progress Energy, CP&L
           FRAN BULGER           GE Nuclear Energy
           CARL HINDS            GE Nuclear Energy
           DAN PAPPONE           GE Nuclear Energy
           JASON POST            GE Nuclear Energy
           GEORGE STRAMBACK      GE Nuclear Energy
           CHARLES BRINKMAN      Westinghouse Electric Company
           WILLIAM SLAGLE        Westinghouse Electric Company
           PETER HASTINGS        DCS
           LAWRENCE LEE          ERIN Engineering
           JAMES F. MALLAY       Framatome ANP
           JOE MIHALCIK          Constellation Energy Group/EPRI
           AGENDA                                          PAGE
           Opening Remarks by the ACRS Chairman             6
           Brunswick Steam Electric Plant, Units 1 & 2
           Core Power Uprate
             By Carolina Power & Light Company
                 Graham B. Wallis                           8
                 Robert Kitchen                           8, 77
                 Tom Dresser                               36
                 Blane Wilton                              60
                 Mark Grantham                             64
                 Dan Pappone                               68
             By NRC Staff
                 Tad Marsh                                 84
                 Brenda Mozafari                           90
                 Ralph Caruso                              91
                 Zena Abdullahi                           103
           Expert Panel Recommendations on Source Term
           for High Burnup and Mixed Oxide Fuel
             By RES
                 Jason Schaperow                          123
           Confirmatory Research on High Burnup Fuel
             By NRR
                 Ralph Caruso                             155
                 Ralph Meyer                              212                           P-R-O-C-E-E-D-I-N-G-S
                                                      8:32 a.m.
                       CHAIRMAN APOSTOLAKIS:  The meeting will
           now come to order.  This is the first day of the 492nd
           meeting of the Advisory Committee on Reactor
           Safeguards.  In today's meeting, the Committee will
           consider the following:  Brunswick Steam Electric
           Plant, Units 1 and 2 Core Power Uprate, Expert Panel
           Recommendations on Source Term for High Burnup and
           Mixed Oxide Fuel, Confirmatory Research Program on
           High Burnup Fuel, Subcommittee Report regarding MOX
           Fuel Fabrication Facility, Safeguards and Security
           Activities, Proposed ACRS Reports.
                       A portion of the meeting will be closed to
           discuss General Electric proprietary information
           applicable to the Brunswick Plant core power uprate. 
           the entire session on safeguards and security
           activities will be closed to protect national security
           information and safeguards information.  This session
           will be held in T8E8.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Dr. John Larkins is a designated
           federal official for the initial portion of the
           meeting.  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 have a short announcement before we
           start.  Mr. Jit Singh, stand up, please.  He's leaving
           us.  He'll be joining the Office of Nuclear Regulatory
           Research as a Senior Reliability and Risk Analysis
           Engineer in the Division of Risk Analysis and
           Applications, and this will be effective May 6, which
           is next Monday.
                       As we all know, Jit has provided very
           valuable service to this Committee for seven years,
           about seven years, especially in the area of fire
           protection.  And there will be a farewell luncheon in
           the Subcommittee Room tomorrow at lunchtime.  That's
           when usually luncheons are held.  And we are all
           invited.  That's my understanding.  Is that correct,
           Jit?  Okay.  We wish you well.
                       Okay.  The first item on the agenda is the
           Brunswick core power uprate, and Professor Wallis is
           the cognizant member.  Please.
                       MR. WALLIS:  Good morning.
                       CHAIRMAN APOSTOLAKIS:  Good morning.
                       MR. WALLIS:  This is a power uprate of a
           BWR to roughly 20 percent above its original power
           level.  It's very much like what we've seen before
           with Duane Arnold, Dresden and Clinton, and I think it
           needs no more introduction from me.
                       MR. KITCHEN:  Good morning.
                       MR. FORD:  Excuse me.  I'd like to declare
           a conflict of interest being a GE retiree.
                       MR. RANSOM:  And I have to declare a
           conflict of interest because I still haven't sold my
           GE stock, but I'll get rid of it shortly.
                       MR. WALLIS:  I'll give you ten bucks a
                       MR. KITCHEN:  Good morning.  My name is
           Bob Kitchen.  I'm the Project Manager for the power
           uprate at the Brunswick Station.  I'd like to take a
           few minutes and just talk to you about the project in
           total and a few items for the overview, also to give
           you a reference of where Brunswick is today relative
           to where we're trying to go.
                       Currently, we -- we previously had done a
           stretch uprate, which is a five percent increase in
           power above the original licensed power level.  So we
           currently operate at 105 percent relative to original
           power.  We're also a two-year operating cycle, 24
           months, which I think we are the first licensee for
           the ACRS review that is a two-year fuel cycle.  Our
           increase is actually to raise power to 120 percent
           above licensed power level, which represents a 15
           percent power rise above our current power level.
                       The implementation of uprate at Brunswick
           will be very similar to those you've seen before, with
           a two-step uprate.  The first being about 112 to 115
           percent, and then the second being up t 120 percent.
                       These are some parameters that you can
           look at to see the change in power.  Currently, we're
           2558 and going to 2923.  You can see the steam flow,
           and feed flow, of course, would increase
           proportionately to that.  Also, the reactor pressure
           change we had previously done for the five percent
           uprate, increasing it up to 1045, there is no pressure
           increase associated with this uprate, which you've
           seen simplifies the analysis somewhat.
                       We have several modifications very similar
           to previous uprates in terms of the type of
           modifications that we're doing.  We only have two that
           are safety related modifications.  The first which was
           of interest is our Standby Liquid Control, our SLC
           System.  We are increasing the boron concentration to
           support cold shutdown.  We are making a modification
           to implement that.  That's going to be done actually
           with the second fuel load of GE14.  We have to change
           our fuel type to support the two-year fuel cycle from
           GE13 to GE14.  Along with the higher energy, the
           significant power increase, we're going to be changing
           our boron concentration in SLC.
                       MR. SIEBER:  Is it necessary that you make
           that modification, that change, to accommodate this
           core?  Or are you doing it just to gain greater
           control and ease of operation?
                       MR. KITCHEN:  The change is necessary. 
           The degree of the change is somewhat -- there is some
           flexibility there.  We need to achieve a 720 ppm boron
           concentration in-vessel.  Currently, the requirement
           is 660.  And we could do that in several ways.  We are
           going to do that in such a way to support, as we'll
           show later, right now we require a two-pump SLC
           operation to achieve shutdown.  The way we're doing
           this modification will enable us to reach success
           criteria with one pump.  So we have to do a
           modification, but the type of modification or the
           degree that we're doing it there's some flexibility.
                       MR. SIEBER:  On the other hand, you could
           just increase the concentration and continue to use
           two pumps, and you would still be safe, right?
                       MR. KITCHEN:  Yes, sir.
                       MR. LEITCH:  This modification occurs --
           is necessary to support what we'll call Phase 2, that
           is, the ultimate uprate power, or is it necessary to
           support Phase 1?
                       MR. KITCHEN:  Actually, it's required for
           the second load of GE14 fuel.  And the reason I
           distinguish with that is that we actually loaded GE14
           on Unit 2 at our previous refueling.  So our first
           uprate outage on Unit 2 will be our second load of
           GE14.  So really the requirement is tied to the fuel
           loading as opposed to the uprate stages that we're
           planning to do directly.  We have a commitment, which
           I'm sure the Committee has seen, we've made a
           commitment to the Commission to make that change and
           also to make the change in such a manner that one pump
           will support success criteria for SLC.
                       MR. LEITCH:  You have committed to do
                       MR. KITCHEN:  Yes, sir.  Since the ACRS
           Subcommittee, we have provided a commitment to the
                       MR. LEITCH:  Thank you.
                       MR. KITCHEN:  The other safety related
           modification relates to our electrical buses.  Our
           emergency buses are powered from off-site through our
                       MR. LEITCH:  Just before we leave this,
           I'd like it if we could --
                       MR. KITCHEN:  Yes, sir.
                       MR. LEITCH:  Is there another modification
           associated with the relief valves on the SLC pumps? 
           Is that part of what you're speaking -- in other
           words, does what you say just refer to the boron
           concentration or is the same timing and all involved
           with the relief valve modification?
                       MR. KITCHEN:  The relief valve
           modification is not tied to -- not really an uprate
           requirement.  It is tied to an issue with under ATWS
           conditions where depending on how quickly you inject
           you can result in relief valve lifting.  Mark, I can't
           remember if that's --
                       MR. GRANTHAM:  This is Mark Grantham,
           Carolina Power & Light.  We are planning to replace
           the relief valves with a higher lift pressure that
           will gain us 50 psig in relief valve margin.  That is
           currently planned for the next Unit 2 outage and the
           following Unit 1 outage.  There is no formal
           commitment for that, but right now that is planned
                       MR. LEITCH:  Very good.  I understand. 
           Thank you.
                       MR. KITCHEN:  The second safety related
           modification that we show here is tied to our
           electrical load supply.  As I mentioned, the emergency
           buses are powered from off-site through our balance-
           of-plant buses, and with the higher loads that we are
           putting on our balance-of-plant buses to support
           uprate, larger pumps and motors, et cetera, that are
           required, there's a bit more of a challenge on our
           voltage support for degraded grid voltage reset; in
           other words, to be able to maintain the off-site power
           support to the emergency bus, which is obviously
                       To support that, we're putting in what we
           call a Unit Trip Load Shed.  This is a tiered support. 
           We can select certain standby balance and plant loads,
           for example, a standby condensate pump, standby
           condensate booster pump, to trip or not to start --
           excuse me, their standby to not autostart in the event
           we have a unit trip.  So that prevents large loads on
           balance-of-plant from starting and further lowering
           the voltage.  This modification involves a select
           switch which is key-locked on the individual loads
           that are selected to not start in the event of a unit
           trip.  And it will ensure that we maintain required
           voltage to the E buses under unit trip conditions from
           off-site power.
                       MR. LEITCH:  That autostart defeat does
           not interfere with the normal autostart on, say, loss
           of low suction pressure or something like that.  In
           other words, if you lost a condensate pump but didn't
           trip the unit, you'd still be able to start the other
                       MR. KITCHEN:  That's correct.  It does not
           affect autostart under normal conditions.
                       MR. LEITCH:  It's only after the unit has
           tripped --
                       MR. KITCHEN:  Yes, sir.
                       MR. LEITCH:  -- that this comes into play.
                       MR. KITCHEN:  That's correct.
                       MR. LEITCH:  Thanks.
                       MR. ROSEN:  In reading the staff's safety
           evaluation on this uprate, it was not clear to me
           whether or not this Unit Trip Load Shed would be
           required if you were not making an uprate.  Can you
           help me with that?
                       MR. KITCHEN:  That's correct.  The uprate
           raises horsepower requirements on the load supply by
           balance-of-plant buses.  And that's the reason for the
                       MR. ROSEN:  The only reason.  There were
           no grid reasons to not -- if Brunswick was not making
           this uprate that you wouldn't go ahead with these
           changes anyway, changes to the switchyard and other
           changes to help with grid stability in the region?
                       MR. KITCHEN:  Not for the Unit Trip Load
           Shed.  Now the grid stability, yes, and that's the
           second -- that's a balance-of-plant modification.
                       MR. ROSEN:  Well, maybe you could help me
           when you get to that to --
                       MR. KITCHEN:  Sure.
                       MR. ROSEN:  -- clarify that.
                       MR. KITCHEN:  This would not be tied to
           the grid situation; this is tied to uprate.
                       MR. ROSEN:  Okay.
                       MR. KITCHEN:  balance-of-plant, as I
           mentioned, we're going to be doing the uprate in two
           phases.  There are a number of balance-of-plant
           modifications.  I think the Committee will see these
           are very similar in type to the others that we've
           looked at -- turbine replacements.  One that we've
           asked about was the power system stabilizer and out-
           of-step protection, and that is related to grid.  It
           is related to uprate, it is also tied to grid loads in
           the area.
                       And there are a couple of -- I'm sure
           there are many -- factors that lead to instability
           situations.  One is tied to the unit load itself.  The
           larger the R load, the more susceptible we are to grid
           instability.  Also the larger load in our area, the
           more susceptible the grid instability.  So even with
           that uprate, we could have conditions which might make
           us want to make these modifications to ensure
           stability.  But the driver for these is really the
           uprate itself.
                       The power system stabilizer is basically
           a feedback loop on our excitation to stabilize any
           oscillations on the generator.  The out-of-step
           protection is just that.  If we end up with an out-of-
           phase situation or leading to an out-of-phase, we'll
           trip the generator rather than end up tripping off-
           site breakers to ensure not only generator protection,
           which in this case is really secondary, but really to
           ensure that we don't have a cascading grid failure.
                       MR. POWERS:  Why wouldn't it be prudent to
           go ahead and make these changes to the grid stability,
           allow that to sort itself out for a while and then go
           the power uprate?
                       MR. KITCHEN:  Well, in effect, we are
           doing that.  We've already made these changes on Unit
           1.  The power system stabilizer and out-of-step is
           already installed on Unit 1, and testing was conducted
           in association with the startup.  Of course, we have
           not uprated.  We plan to do that shortly after this
           meeting.  But we have done testing at current power
           levels with these modifications.
                       MR. POWERS:  Then why not allow things to
           operate for a cycle, two cycles?
                       MR. KITCHEN:  It's already -- I mean these
           types of modifications are not unique to the uprate. 
           They're fairly common in the industry.  The testing
           that we perform demonstrates the -- clearly
           demonstrates the performance of the system.  And if we
           had a problem with the system, we could maintain
           current power levels or simply remove them from
           service if required.  So there really wouldn't be any
           benefit in delaying the uprate implementation one
           cycle and test it.
                       The Phase 2 modifications at the plant are
           really not quite as extensive, although they are major
           modifications to the main transformers, other
           additional feedwater heaters and moisture separator
           reheaters.  And both of those are tied to uprate
           because of not only performance but also to support
                       As you well know, the uprate leads to
           degraded margins.  We'll talk about those quite a bit
           in our presentation today.  But I wanted to point out
           also there are some things that we're doing that will
           either regain or maintain margins in the operational
           area.  Just to give you for examples, we've talked
           about the standby liquid control modification, and
           we're doing a little more than you would say you have
           to to maintain our margin on SLC.  We're going to go
           from the current two-pump to a one-pump requirement
           for operability there.  That's definitely an
                       We also are changing our Power Range
           Instrumentation System, and that does a couple of
           things for us.  Currently, we operate on thermal-
           hydraulic instability solution E1A, which is a prevent
           solution.  With the new powering system, we're going
           to option three, which provides detect and suppress,
           a SCRAM, based on instability and detection, which we
           see as an enhancement, particularly for the operator
           interface.  It's a little better digital controls
           interface, as well as reducing maintenance
           requirements, less surveillance is required, the
           system eliminates half SCRAM.  So there are some
           benefits there with this modification.
                       Also, I think you may have seen some
           uprates where condensate, condensate booster pumps all
           were required to operate to support uprate.  We
           elected to improve the system to maintain our standby
           pump capability.  We didn't want to give that up with
           the uprate.
                       And, finally, we've talked about the power
           system stabilizer, but that will, as was pointed out,
           not only because of uprate but also because of grid
           growth would be a mod that would be desirable to
           maintain margins.
                       The Subcommittee asked about the interim
           operation, because with the two-step implementation we
           would get the license for reactor power operation up
           to 120 percent and then be plant-limited by balance-
           of-plant equipment.  And the question was how do you
           control this in the interim?  There are a couple of
           aspects of that.
                       One, during the startup and the power
           ascension for implementation of the uprate, we are
           going to do testing, as you've seen before, response
           testing on our controls for the turbine and response
           of the digital feed controls, as well as performance
           monitoring on balance-of-plant equipment.  And we'll
           be looking at where we have predictions based on our
           analyses on the system, where we expect parameters to
           go.  But we'll be looking closely at the actual plant
           performance to assess that we're not limited in some
           criteria before we expect it.
                       We'll translate that procedurally to an
           operational guidance as far as plant control, because
           you want the operators to be able to operate the plant
           on something they're looking at in the control room as
           opposed to a BOP limit in the plant, although that's
           what will really limit it.  And the way I look at
           this, it's really not different today than if I were
           to have a component out-of-service in the plant, like
           a condenser water box, for example, which would limit
           us in reactor power.  It's really the same type of
           operational control that we would have.
                       So these are the plans we have for our
           transition, just to basically test, monitor and then
           establish guidelines.
                       MR. LEITCH:  You referred to turbine
           testing.  Could you say a word more about exactly what
           kind of turbine testing you plan to do?
                       MR. KITCHEN:  Well, during the startup, of
           course, we did the routine vibration and over-speed
           checks, but the testing I'm specifically talking about
           are controls tests.  We do pressure regulator fail-
           over.  We have backup and primary controls that
           pressure regulators will fail the primary over.  We'll
           do step changes in pressure to verify the valve
           response is correct.  And we'll also monitor the
           system response, it's called incremental regulation,
           to make sure that the valve position response is as
           you would expect based on the power increase.
                       MR. LEITCH:  Now, will the EH -- I'm just
           a little confused -- is the EHC system going to be
           modified prior to Phase 1 or prior to Phase 2?
                       MR. KITCHEN:  It's part of the mod
           requirements for Phase 1 and --
                       MR. LEITCH:  Phase 1.
                       MR. KITCHEN:  -- it's part of the --
           really, it's tied in with the high pressure turbine
           modification.  Specifically, we operate in partial
           ARC, 3-ARC control today, and we'll be going to 2-ARC
           control, partial ARC with uprate.
                       MR. POWERS:  Do I understand correctly
           you're going to train the operators from what they do
           now to what you do at an interim, and you're going to
           untrain them on that and train them for what you'll do
           at the final power up?
                       MR. KITCHEN:  We started training
           operators actually last year on the modifications that
           are being installed.  In fact, the modifications that
           are installed in the Unit have been installed in the
           simulator, and the operators have trained on the
           equipment itself.  We're training this phase, which
           started this week, on the actual uprate -- the license
           change, the technical specification changes and the
           allowed operation.  So, really, operationally, the
           only change is the modifications and then the licensed
           power.  They will train on transients associated with
                       MR. POWERS:  So right now we have a
           situation where the operators have a plant that they
           run with one set of limits and are training on a
           different set of limits?
                       MR. KITCHEN:  They are -- well, we always
           train on the current plant operation.  The operators
           are training on what the limits will be in terms of
           power operation with uprate approval.  Now, the
           parameters that control like our average power range
           monitor trips, main steam line flow set points, those
           will only change one time.  They will change with the
           uprate, and they will be that way for both stages.  So
           really it's a lower power level training up to full
           power operation.
                       MR. ROSEN:  Before you get too far away
           from it, let me ask, have you something in your
           presentation this morning, some more insight that you
           can offer us on the power range instrumentation
           changes?  Of is what you said about it all that you
           plan to say?
                       MR. KITCHEN:  That's all I planned to say. 
           We could talk through that more if you like.  The
           system that we're installing is the General Electric
           NUMAC System.  It's a digital system that installs not
           only with the change in the instrumentation itself,
           but it also provides a change in our instability
           solution protection.  We call it Operate E1A which has
           areas that the operators avoid and areas where there
           would be an automatic SCRAM, just based on where you
           are located in the power operation region.
                       With Option 3, the stability solution is
           tied to what's called period-based algorithm which
           looks for certain frequencies which are representative
           of thermal-hydraulic instability and has a threshold
           based on the number of cycles counted and the
           amplitude of those cycles.  If it meets those
           criteria, there's an automatic SCRAM.  So regardless
           of where you are operating, if the system sees an
           instability, there would be an automatic SCRAM.
                       MR. SHACK:  I thought there was a problem
           with actually implementing Option 3 at the moment
           because of a Part 21 --
                       MR. KITCHEN:  There is an industry issue
           with the Option 3 stability solution.  There is a Part
           21.  Under certain circumstances, the generic curve
           that is used to determine the set points for the
           operating cycle can be non-conservative.  And along
           with that Part 21, the GE resolution or the GE interim
           guidance provided where there are certain calculations
           the fuel folks can do to determine if, for our
           specific operating cycle, if that curve bounds our set
           points; in other words, if they are conservative.
                       For Unit 1, which we've installed Option
           3 on, those calculations have been performed and prove
           that the curve bounds Brunswick Unit 1, that the
           systems installed are operable on Unit 1 today and
           will be operable through the cycle.  So Part 21 still
           applies, but for our specific application it's not
                       MR. POWERS:  How many cycles do you have
           to go through before the system actuates?
                       MR. KITCHEN:  Don't know the answer to
           that.  Jason, the question is how many cycles of
           instability before a trip?
                       MR. POST:  Yes.  This is Jason Post of GE. 
           It has to establish a base period within a criteria
           which takes a half a cycle and then every half cycle
           after that it adds one count.  So you have to -- it
           will take you about five and a half or six cycles to
           reach a count of ten or 11 counts.  And then it also
           has to reach an amplitude set point.  So, typically,
           1.1 peak over average, and then the SCRAM will occur. 
           So it could be, with a two-second period, we're
           talking around -- I think around ten seconds or so.
                       MR. ROSEN:  How do you test that in the
                       MR. KITCHEN:  Actually, the system has
           some self-test features in the digital system.  We
           actually tested similar to what we would do other
           systems.  We can remove a channel from service and
           perform the set point verifications for the trips,
           also check the sensitivity of the system for a
           response to instability and the thresholds. 
           Basically, it's not unlike any other system that we
           would test.  It does have an advantage in that
           currently if we remove a channel for testing, we have
           to put in a half SCRAM.  And with the new system, the
           logic is set up such that we can take one channel, one
           APRM channel out of service and not have a half SCRAM. 
           So it's a pretty significant advantage.  It reduces
           significantly the number of half SCRAMS that we have
           for routine testing.
                       MR. ROSEN:  Well, you've described
           checking the set points and those sort of things, but
           do you actually check the oscillatory counting
           procedure algorithm in the software?
                       MR. KITCHEN:  There's one.  Jason, go
           ahead, address that.
                       MR. POST:  Yes.  This is Jason Post with
           GE.  There's various parameters in there that cause
           the -- even with normal noise and the REM variation in
           the neutron flux signal, you will get periodic counts
           from your system.  So there are some tuning
           parameters, and we make sure that the system is tuned
           adequately to give an adequate level of response for
           normal noise.  It's a procedure we use to confirm
           system operation for an actual instability that
           occurred at Liebstadt.  So we ensure that the system
           is adequately responsive during normal operations so
           we've ensured that when an actual instability does
           occur, we will get the counts.
                       MR. POWERS:  I think what you said is that
           there is no test for this system, this Plant.
                       MR. POST:  It's continuously being tested. 
           You notice the -- as I said, during normal operation,
           there is some level of counts.  In fact, one of the
           original surprises when we put the system in was we
           got more counts than expected.  It was being very
           responsive during normal noise, and you could get
           single channels that would give you five, six, seven
           counts just from normal noise and the random nature of
           that.  So it is -- you know continuously that it is
                       MR. POWERS:  Do you understand that,
                       MR. ROSEN:  Only marginally, Dr. Powers.
                       MR. POWERS:  It seems to me that when you
           find you've got a noisy channel and you suppress the
           noise, you also suppress its ability to respond under
           actual event.
                       MR. ROSEN:  Well, that comes down to the
           operating procedure.  If they are suppressing noise
           that way, you're right.  If you get five or six or
           seven counts during normal operations just because of
           random variations of the signal and you need ten or 11
           to trip the plant, I would suspect the operators are
           starting to get a little nervous.
                       MR. KITCHEN:  But the tuning procedure
           that Jason is talking about is really set to verify
           that we have appropriate response so that the operator
           has enough time to take action if there's an
           instability.  But the system will still provide
           protection, and also not so low that we have -- you
           don't want a lot of nuisance alarms associated with
           the system.  So that's the band that you tune it
           within, but there's not a situation where you tune it
           to a point where you eliminate protection from the
           instability of that.
                       MR. LEITCH:  It actually takes two
           parameters for the system to actuate.  You know, it
           can be counting forever, but if the signal's not --
           the variations are not big enough, it won't make a
           protective action.
                       MR. KITCHEN:  That's correct.
                       MR. LEITCH:  So when you look at noise all
           you're doing is seeing whether it counts or not.
                       MR. POST:  Just to reinforce that point,
           that's exactly one of the concerns with the Part 21
           issue is that if we lower the amplitude set point too
           far, you'll come too close to where a normal noise
           event could cause an unnecessary SCRAM.
                       MR. KITCHEN:  The power uprate for
           Brunswick is -- we do have a few exceptions to the
           ELTR.  Generally, the guidance in the ELTR was
           complied with totally.  There a few exceptions.  Three
           of these are related to the constant pressure nature
           of this uprate and some of the simplifications which
           are warranted.  We feel that these can be discussed
           later in proprietary section.  These as well as the
           fourth one I've identified up there, which is large
           transient exception, are similar to what have been
           presented before with other uprates.  Basically, the
           large transient testing is associated with the MSIV
           closure and generator load reject, and we would like
           to waive both of those tests.
                       MR. ROSEN:  Some of the other plants that
           have come before us have included a re-circ runback
           feature.  I don't see that in your proposal.
                       MR. KITCHEN:  The ones that I'm familiar
           with, sir, are associated with the condensate system
           itself in that they need to run all the condensate
           pumps to support operation.  In that situation, if you
           have a pump trip, you need to reduce power to
           basically the original power level, and they do that
           with a re-circ runback.  In our case, with a standby
           pump, the standby pump would start, and there's no
           need for runback.
                       MR. ROSEN:  Right.  And I was waiting for
           you to make a further comment on large transient
                       MR. KITCHEN:  Certainly can.
                       MR. ROSEN:  There have been a number of
           questions raised about the need for that testing by
           members of the staff and also by this Committee.  And
           there are currently considerations in the staff of
           setting up some criteria for when large transient
           testing might be required.  Are you aware of those
                       MR. KITCHEN:  I'm aware there's been quite
           a bit of discussion about the large transient testing. 
           I'm not familiar with the specific Committee
                       MR. ROSEN:  Well, the staff established a
           panel to look into the need for integrated testing for
           extended power uprates.  And that Panel has concluded
           its report, which sets up --
                       MR. MARSH:  Mr. Rosen, we may into an area
           which is not publicly released yet, okay?  This is the
           area of the Panel and how the Panel looked at it.  So
           can I ask you to forebear till we get into a --
                       MR. ROSEN:  Oh, I see.  Is the staff going
           to address some of this?
                       MR. MARSH:  To some extent.
                       MR. ROSEN:  And the implications of that
           to the Brunswick --
                       MR. MARSH:  We're going to discuss with
           you what our plans are regarding that Panel and what
           its recommendations are and how we're going to
                       MR. ROSEN:  Well, it seems to me that
           there's a question here as to whether or not the
           outcome of all of that will be applied to Brunswick.
                       MR. MARSH:  Let's see, what can I say?  We
           are going to consider the extent to which the decision
           in the guidance that will be made should be back-fit
           to this Plant or to any plant that's already gone
           through this process.
                       MR. KRESS:  Will that require back-fit --
                       MR. MARSH:  It involve looking backwards
           into the back-fit type of procedure, that's right.
                       MR. ROSEN:  So that would be clearly true
           for plants whose license uprate has been approved.
                       MR. MARSH:  Yes, sir.
                       MR. ROSEN:  For Brunswick, which is not
           quite there yet, would it apply to them?
                       MR. MARSH:  Yes, it would.
                       MR. ROSEN:  In other words, as a back-fit
           to them or --
                       MR. MARSH:  Yes, it would.
                       MR. ROSEN:  -- or in their case, as part
           of their approval, should they be -- should this
           request be approved?  Do you see the difference I'm
                       MR. MARSH:  We recommend we continue on
           the same track that we've been on, because the
           guidance isn't yet developed nor has the back-fit
           analysis been done.  So we recommend continuing along
           the track that we've been on, which is to approve --
           grant a request to waive those tests.  Staff will
           develop guidance, will apply back-fit analysis to that
           guidance to find out whether this Plant and others
           should do the large transient testing.  Have I
           answered your question?
                       MR. ROSEN:  Not exactly, because it would
           seem to me that plants to which you have to apply the
           back-fit rule, 5109, I assume --
                       MR. MARSH:  Right.
                       MR. ROSEN:  -- would have a higher
           threshold in terms of whatever the criteria turn out
           to be than a plant which was licensed for uprate with
           the understanding that when the tests criteria were
           determined that they would be applied to Brunswick. 
           And depending on whether they fell within the criteria
           or not, they would either be applied to them or not.
                       MR. MARSH:  Right.  Well, we haven't yet
           decided whether large transient testing should be
           done, okay?  That is still part of the charge that
           we're being given by the Office Director.  And once
           the decision is made, then a guidance is developed as
           to whether it should or should not be done.  Then
           we'll apply the back-fit to it.  So we would be
           premature to condition this license or in any way use
           that criteria beyond what the staff's acceptance
           criteria is now.
                       MR. KRESS:  In order to apply the back-fit
           regulatory analysis, you have to determine the risk
           REMS that you offset by this.
                       MR. MARSH:  Sure.
                       MR. KRESS:  How in the world can you ever
           do that for something like large transient testing?
                       MR. MARSH:  That's just one of the tests
           that's embodied in the 109.  There are other tests
           that are there.
                       MR. KRESS:  I know, but if it fails -- I
           mean you have to pass that test too.
                       MR. MARSH:  Sure.  Sure.
                       MR. KRESS:  And I just don't see how you
           can actually do that.
                       MR. MARSH:  We'll have to develop -- we'll
           have to study it in detail, which is what the charge
           is all about, and develop regulatory guidance and
           decide whether or not it should be done, and then
           that's a forward-looking issue.  And then in terms of
           backward-looking, we'll have to apply the 109 test to
           find out whether it should be done, whether the gain
           is worth the cost in terms of REM, in terms of safety
           margins and if it comes to be an adequate protection
           issue, if that's where it is.  But that is the charge.
                       MR. ROSEN:  It seems like we're working on
           a very short fuse here, from my reading of the
           information, which I now understand is not released

           yet.  But that all of this is very near-term stuff.
                       MR. MARSH:  Our charge from -- I was going
           to do this at the beginning, but I'll be glad to do it
           now.  The Office Director has asked us to develop a
           plan to give back to him by the end of this month with
           how we will formulate the staff guidance and the
           extent to which we'll apply the back-fit.  We'll be
           glad to, of course, brief the Committee on that and
           how we do that.  We haven't yet set the time frame
           when we will do that, but it's thought to be this
           year.  This is a this year type of an effort.  So it's
           a short-term effort.
                       MR. KRESS:  Have you already decided this
           is not a compliance issue and therefore is a back-fit?
                       MR. MARSH:  It's premature to say that. 
           I think we have to hold out on that.  We have to think
           about that.  My impression is that it would not be
           since we are, at this point, saying this licensee is
           in conformance with the regulations, go forth without
           testing.  So unless some other regulatory requirement
           emerges when you look at the back-fit analysis, if you
           judge that they're not in compliance with the
           regulation, then you'd be in the compliance exception,
           but we'd have to study that in more detail.  I don't
           believe so.
                       MR. KITCHEN:  Can we move on?
                       MR. SIEBER:  Yes.
                       MR. KITCHEN:  There are a few unique
           aspects of Brunswick uprate I just wanted to point out
           to the ACRS.  First, we do have, as we talked about,
           some actions that we're implementing to enhance grid
           stability.  Secondly, we are, I think, the first plant
           you've reviewed that's hydrogen water chemistry versus
           normal metal chem.
                       Finally, we have significant energy
           requirements to support our operating cycle.  We are
           asking for 120 percent power operation relative to our
           original license, and we are a two-year fuel cycle. 
           We also operate at 97 percent capacity factor.  That's
           our design criteria, and we've done quite well at
           Brunswick.  So those things combined give a pretty
           significant energy load for the cycle.  And those
           impact, of course, our fuel design.
                       With that, we talked about fuel.  So, Tom?
                       MR. DRESSER:  Good morning.  My name is
           Tom Dresser.  I work for CP&L's BWR Fuel Engineering
           Group, and I'm going to discuss very quickly five
           different topics related to the reactor core.  The
           first two, the fuel bundle and the core design and the
           ATWS, are performed completely consistent with the
           previous mils and with the generic methodology of ELTR
           1 and 2.  The last three, the transient analysis,
           thermal-hydraulic stability and LOCA analysis, each
           take some kind of exception to the generic
           methodology, which I'll discuss when we get there. 
           And those last three topics do contain material in my
           presentation, which is proprietary to GE, so we'll
           pause from the second and third topic and go to closed
                       The fuel bundle and core design that is
           performed in support of the power uprate itself to
           provide the input to all the fuel-related tasks is
           done for a full equilibrium cycle.  And the design
           targets to be achieved by that equilibrium cycle are
           similar to what's been seen by the ACRS for other
           plants.  As Bob mentioned, Brunswick is a higher
           energy cycle because of the 24-month refueling outage
           and the excellent operations.
                       That forces us to do a number of physical
           changes to achieve the energy requirements.  The first
           is that we need to change our fuel design from GE13 to
           the ten by ten GE14 fuel design.  Now, amongst many
           other attributes, the GE14 is a heavier bundle with
           about five percent more uranium in each bundle loaded. 
           Additionally, we have to increase the enrichment on
           the order of four-tenths weight percent in that new
           fuel, and we have to increase the number of new fuel
           bundles substantially.  The reload pressure goes from
           about 39 percent to about 47 percent to achieve this
           extra 15 percent power.
                       Now, by making all three of those changes,
           we do get the required energy for the two-year
           refueling cycle, but it does make for a more reactive
           core.  So by the time we get to the full equilibrium
           cycle, we do need to make the Standby Liquid Control
           System boron equivalent change.
                       MR. ROSEN:  What did you say about
           enrichment, would you repeat that?
                       MR. DRESSER:  Yes.  The enrichment must be
           increased.  Of course, it's -- I can't give you one
           single number to cover everything, but the range of
           the enrichment increase is on the order of 0.4 weight
                       MR. ROSEN:  The increase is 0.4.
                       MR. DRESSER:  The increase is 0.4.  It
           goes from the highest sub-batch.  The fuel goes from
           about 4.0 to about 4.4 weight percent.
                       MR. ROSEN:  Okay.  Now I understand. 
           Thank you.
                       MR. DRESSER:  And as Bob mentioned, we
           will need to make a change to the effective boron
           concentration of about ten percent, to go from about
           660 ppm to about 720 ppm by equilibrium.
                       The last change that we need to make is
           pretty trivial.  The tech specs power at which we
           start monitoring thermal limits decreases from 25
           percent to 23 percent, but that is just to maintain
           the same absolute bundle power calculational basis as
           used generically for GE BWRs in the fleet.
                       MR. SIEBER:  It seems to me that the per
           rod duty is going up substantially in this fuel.  And
           if you look at GE13, that's like spaghetti, and GE14
           is like vermicelli.
                       MR. SIEBER:  From the standpoint of
           bending and --
                       MR. DRESSER:  That's true.  The bending
           moment in that kind of thing is going to be smaller
           for the GE14.  The linear heat generations is a lot
           less for the GE14, and the limit goes down and the
           actual amount of linear heat generations goes down
           even more.  One thing that going with these very large
           reload fractions it's not possible to design the fuel
           cores with the same fuel efficiency that we've been
           used to in the past.  And so the average exposure on
           the fuel goes down a lot.  So whereas our batch
           average exposure limits are 50,000 megawatt days per
           ton and we had been able to design our lead sub-
           batches and bundles to go up to the 48 or even
           sometimes over 49 megawatt days per ton, with this new
           core design, our lead bundle burnups are in the range
           of 45, 45.5.  So it's a whole lot less exposure on the
           fuel, and that should improve the --
                       MR. SIEBER:  On the other hand, you're
           going to have maybe six percent of the bundles that
           will be in core for three cycles?
                       MR. DRESSER:  That's correct.  And that --
                       MR. SIEBER:  What is the peak bundle
                       MR. DRESSER:  Those are the bundles that
           contribute to that 45.5.  There are also bundles which
           are substantially less exposure.  So the high bundles
           are in the range of 45.5.  And that's because a lot of
           these bundles spend time near the outside of the core
           where the flux is less.
                       MR. SIEBER:  Thank you.
                       MR. POWERS:  Tom, you just recently
           experienced the fuel leak, I believe.  Was that in
           GE14 fuel?
                       MR. DRESSER:  Yes.  We did have two GE14
           fuels that have leaked.  We've removed those from --
           this is the Unit 2 Plant.  Those have been -- the
           Plant was shut down and those bundles were removed. 
           They'll be tested.  We'll go examine those bundles in
           about two months to --
                       MR. POWERS:  Okay.  So you don't yet know
           the nature of that --
                       MR. DRESSER:  That's correct.
                       VICE CHAIRMAN BONACA:  Did you shadow
           those failed pins?
                       MR. DRESSER:  Yes, we did.  They failed
           nearly a year ago, and we did power suppression
           testing and then suppressed those bundles.  It was
           fairly effective in controlling the degradation of the
           fuel.  And the bundles were located in a vicinity that
           had been identified.
                       VICE CHAIRMAN BONACA:  So you must have
           lost quite a bit of cycle length.
                       MR. DRESSER:  Well, because this -- we
           shut down the Plant in the middle of a cycle, and so
           we will lose, I think, on the order of a week, not too
                       VICE CHAIRMAN BONACA:  You shut it down? 
           All right.
                       MR. DRESSER:  We did shut it down and we
           threw those out and we've started the Unit.
                       The first actual power uprate cycle is in
           Unit 1, Cycle 14.  I'm going to go through this
           relatively quickly.  The design goals are similar. 
           They were all met.  It required a slightly smaller
           relay fraction to achieve the energy, about 46 instead
           of 47 percent of the core.  Otherwise it's not that
           different from the equilibrium cycle.
                       One big difference is that there is, as
           Bob mentioned, no need to modify the Standby Liquid
           Control System boron concentration for the cycle
           because of the single reloaded GE14 fuel.  One thing
           that's interesting about both this and equilibrium
           design with those large batch fractions is that the
           power -- the radio power distribution is very, very
           flat for Brunswick, and that will affect many things
           that we look at today.  One of the things it affects
           right here in this cycle is the safety limit MCPR must
           be increased from 1.10 to 1.12.
                       MR. ROSEN:  Do you have some way of
           characterizing this very flat versus what it was
                       MR. DRESSER:  Yes.  I have a couple -- I
           have a visual which I'm going to share with you.
                       I'm going to respond to this in two ways. 
           I'm going to show you a visual first and then give you
           some numbers.  This is an open session.  I think is
           probably not proprietary.  This is last cycle.  This
           is a radio power distribution for the bundle peak
           powers.  The blue is the highest power density, 1.2 to
           1.4, and peach is 1.0 to 1.2.  And then as we go
           progressively further out along the radius of the
           core, the power densities get less and less.  That's
           basically what the non-power uprate cycle looks like.
                       Now, if we go to the current cycle, the
           first power uprate, we see some migration of power
           towards the outside and a little bit lower power
           density towards the interior of the core.  And then if
           we look at the full equilibrium cycle, it's more
                       Now, to put some numbers on that, the
           highest sub-batch power fraction for Cycle 14 is about
           1.22.  By equilibrium, it goes down to about 1.19. 
           And in comparison, I think that the last plant that
           came before the ACRS and showed a flat power
           distribution that corresponding number was about 1.26. 
           So this is the flattest power distribution that has
           been seen.
                       MR. ROSEN:  You know, visually, if you put
           -- somehow maybe you could show the first and the last
           one on the same -- the blue is the high power regions,
           am I correct?
                       MR. DRESSER:  That's correct.  That's the
           highest power.
                       MR. ROSEN:  Okay.  So if you just look at
           -- do some sort of mental integration of that --
                       MR. DRESSER:  To me, the numbers might be
           a little bit easier to understand, the 1.26, 1.22,
           1.19.  I can look at this and see visually that the
           equilibrium is lighter, it's not as dark as the
           current cycles.
                       MR. ROSEN:  I believe you.
                       MR. WALLIS:  Did you average in the --
                       MR. SIEBER:  That's a first.
                       MR. WALLIS:  You're pushing the power up
           towards the edge, you can see that.  The edge is the
                       MR. DRESSER:  That's correct.
                       MR. WALLIS:  That's the clearest thing you
           see from that visual integration.
                       MR. ROSEN:  The edges, is that what you
           were looking at?
                       MR. WALLIS:  Yes.  Power towards the side
           is raised.
                       MR. DRESSER:  Would you like to see those
                       MR. ROSEN:  Yes.  Would you go back to
                       MR. WALLIS:  I'm just trying to help you
           with your integration.
                       MR. ROSEN:  I was looking at the blue.
                       MR. WALLIS:  Yes, but the blue is
           misleading.  Look at the edges.  You find those
           skinny, it's a yellow region.  So that the low power
           regions are lower.
                       MR. ROSEN:  Yes.  Now I see that.
                       MR. WALLIS:  Of lower extent.
                       MR. ROSEN:  Okay.  Thank you.
                       MR. DRESSER:  To conclude for the fuel
           design itself, it's necessary to make some physical
           changes to the plant and load much more fuel and make
           a change to the Standby Liquid Control System.  But in
           order to maintain the types of design margins that we
           typically expect, it does not require any change to
           our methodology or expectations.
                       The second topic would be ATWS.  This
           analysis was done consistent with the ELTR as well so
           that the four limiting ATWS events were analyzed.  The
           one that's of greatest interest is going to be the
           pressure regulatory failure open event, which shows a
           peak vessel bottom pressure increasing to about 13
           pounds less than the ASME service level C limit. 
           Licensing-wise, I guess that's 12 pounds and change
           more than it has to be in terms of margin.  But it
           appears pretty close.  What offers comfort in that
           amount of margin here is that this analysis is done
           not with normal transient, best estimate kind of
           inputs, but the estimates are conservative.  The set
           points and things are biased to be towards the worst
           allowable value limits.  Also, the SRV capacities,
           which would be very important to this, are only 90
           percent of the actual capacities.  And this analysis
           does assume one SRV is out of service as well.
                       Then the final thing is that these
           calculated results are using GE's ODYN code.  If we
           had recalculated these using GE's more sophisticated
           and accurate TRAC-G code, that, by itself, would
           produce well over 100 pounds additional margin.  So
           though the numbers appear fairly close to the design
           limit, there really is no concern with respect to
           actual safety here.
                       MR. WALLIS:  So you know what track it
           would predict without actually running it?
                       MR. DRESSER:  Well, G's got a lot of
           experience with TRAC, so that's just a rule of thumb
           kind of number.  It produces much lower results.
                       In the interest of time, I'll just comment
           that the other three analyses show a great deal of
           margin to be respective limits, and unless we have
           particular questions about that, I'll --
                       MR. ROSEN:  Well, only that the peak clad
           temperature goes down.  Would you want to comment on
                       MR. DRESSER:  Yes.  The peak clad
           temperature goes down.  There are a couple other
           facts, but probably the most important thing for the
           ATWS is that with power uprate we have a higher void
           fraction and a much more bottom-peaked flux
           distribution so the peak node is lower in the core
           where there is more water and less void in the power
           uprate case, and you get a better heat transfer out.
                       These results, in general, for the ATWS
           show that the ATWS analysis for Brunswick is done
           consistent with the standard generic methodology, and
           there is no requirement to support the ATWS now.  It's
           just to make changes to the Standby Liquid Control
           System boron concentration.  There's no need to make
           changes to the actions that the operators take, and
           the standard designs are satisfied.
                       Next, we're going to want to go to the
           final three topics, and we'll need to go to closed
                       MR. BOEHNERT:  All right.  If we can have
           anyone from the public please leave the room.  It will
           be, I don't know, a short time.  There's not too many
           slides.  I will come out if there's anyone here. 
           Nobody here.
                       Okay.  Well, let's proceed to closed
           session then.  And, Transcriber, if you'll go to a
           closed session transcript, please.  Thank you.
                       (Whereupon, the proceedings went into
           Closed Session.)
                                  MR. WILTON:  Good morning.  My name is
           Blane Wilton, and I'm the Supervisor of Reactor
           Systems at Brunswick Nuclear Station.  I'd like to
           discuss the reactor vessel and internals,
           specifically, the effects and impacts of power uprate
           as it relates to the internals.
                       What we found is the reactor vessel and
           all the internals were addressed in accordance with
           ELTR.  The impacts that we found were our PT curves,
           our pressure temperature curves, were impacted.  Our
           current curves that we're operating on are good
           through March of 2003, have been approved with the
           effects of power uprate included.  We have a
           commitment to resubmit PT curves to the staff for
           review by June of 2002 with the new fluency
           methodology, in accordance with Reg. Guide 1.190
                       Fluency was also affected by power uprate. 
           What we saw is that fluency did not increase
           proportionally with the power increase.  There was a
           greater than a 20 percent increase.  The reason for
           that is just the core configuration going to an
           equilibrium core, pushing the power farther out to the
           periphery of the core, increased the fluency that we
                       Embrittlement.  Embrittlement was
           affected.  We're an older Plant, so we don't have full
           SHARPIE test data on our vessel materials.  Ten CFR 50
           Appendix G requires that you meet certain criteria for
           both initial plate materials as well as end-of-life
           materials.  If you don't have full materials, you can
           do what's called an equivalent margins analysis.  We
           redid that for our Plant, found that we met all
           requirements.  We also did a plant-specific one on our
           N16 nozzles because those are in close proximity to
           the beltline region, and they met all limits also. 
           So, therefore, embrittlement was okay.
                       Fatigue.  Fatigue is also affected.  We
           did a fatigue evaluation on our limiting components,
           and what we found is that all fatigue values are met
           through end-of-life plus 20 years.  We looked at the
           20 years just to make sure, because we are looking
           down the road at life extension.  But we met it for
           end-of-life, plus we met it for end-of-life plus 20
           years on all of our components.
                       MR. SHACK:  Just in your --
                       MR. WILTON:  Sure.
                       MR. SHACK:  You're in a normal hydrogen
           water chemistry, so are you continuously monitoring
           ECP somewhere in the vessel?
                       MR. WILTON:  We do not have ECP monitoring
           installed.  We don't have ECP probes.  What we do is
           we have run models of plant-specific models of our
           Plant; we've done that.  We also monitor parameters
           like main steam line rad monitors, radiation --
                       MR. SHACK:  So you monitor N16.
                       MR. WILTON:  Yes.
                       MR. SHACK:  Do you monitor oxygen coming
                       MR. WILTON:  We don't monitor oxygen, but
           we monitor hydrogen concentration in our feedwater.
                       MR. SHACK:  Have you run the radiolysis
           model with the higher fluency?
                       MR. WILTON:  Yes, we have.  And what we've
           found is that our protection -- host power uprate is
           actually better, at least as good or better with the
           high fluency, because the radiolysis model is affected
           by fluency.  The higher the fluency, the more
           efficient the recombination reaction is.  And,
           therefore, what you see is that your protection
           actually goes slightly more negative.  And when we saw
           that, we questioned that, and we went back through
           EPRI and had them validate our model for us.  And what
           we saw is that we actually had at least as good or
           better protection under power uprate conditions than
           we currently have.
                       MR. SHACK:  Now, in your feedwater lines,
           because you have hydrogen water chemistry, do you have
           any more difficulty in maintaining a reasonable oxygen
           level in the feedwater?
                       MR. WILTON:  We haven't seen that, no.
                       MR. SHACK:  What do you maintain, 20 ppb?
                       MR. WILTON:  Yes, 20 ppb oxygen in our
           feedwater lines.  And we inject at 39 and a half SCFM,
           which equates to about 1.0 to 1.05 ppm in our -- so we
           are a moderate hydrogen water chemistry plant.  And
           our plan is to continue maintaining hydrogen at our
           current levels.  Now, how we validate that is we have
           an extensive inspection program.  So we're following
           the guidelines of the VIP, we maintain our water
           chemistry in accordance with the VIP guidelines, and
           our model shows what our ECP levels are, our
           inspections, then validate that.  What we've seen,
           we're not -- where we do have cracking we're not
           seeing crack growth, which is what our models show --
           say that we should have.  So our inspection program is
           really a validation of what our models and all show
           us.  And we've committed -- you know, we will continue
           to do our inspection program through end-of-life.
                       MR. FORD:  Just a curiosity question.  Do
           you inject oxygen into the condensate?
                       MR. WILTON:  Yes, we do.
                       MR. WALLIS:  May I ask a question for
                       MR. WILTON:  Certainly.
                       MR. WALLIS:  Are you a noble chem?
                       MR. WILTON:  No, we are not a noble chem
                       MR. WALLIS:  Do you plan to be?
                       MR. WILTON:  No.  At this point we do not.
                       MR. ROSEN:  You say you inject oxygen.  Do
           you really do that or do you -- are you injecting air
           with oxygen in it?
                       MR. WILTON:  It's air.
                       MR. ROSEN:  It's air.
                       MR. WILTON:  Yes, I'm sorry.  Any
                       MR. GRANTHAM:  Good morning.  I'm Mark
           Grantham.  I'm the Design Superintendent on our Power
           Uprate Team.  I'll be talking about our containment
           analysis that was performed and the impact of that
           analysis on MPSH for ECCS pumps.
                       The containment analysis was performed in
           accordance with the ELTR.  For data comparison
           purposes, what we have is actually the first data
           column, and all these columns are 102 percent of
           reactor thermal power.  The first column provides
           actually our current UFSAR values.  We re-ran the
           analysis at 102 percent of our current licensed
           thermal power using the same assumptions that were
           used in our power uprate analysis.  And what this does
           it provides a direct comparison for the uprate to
           provide basically the overall impact to the
           containment analysis strictly from the power increase.
                       Reviewing the data, drywell pressure under
           EPU conditions goes up to 46.4 psig.  The acceptance
           limit is 62.  Drywell space temperature 293 degrees F
           versus an acceptance limit of 340.  Wetwell pressure,
           31.1 psig versus an acceptance limit of 62. 
           Suppression pool temperature, 207.7 degrees F versus
           an acceptance limit of 220.  So we still maintain a
           substantial margin under uprate compared to the
           acceptance limits.
                       VICE CHAIRMAN BONACA:  What's the
           difference in methods between the FSAR and the
                       MR. GRANTHAM:  There's four main
           differences.  The FSAR analysis was performed using
           the homogeneous equilibrium model for determining
           blowdown flows.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. GRANTHAM:  The power uprate model used
           Moody slip critical flow model.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. GRANTHAM:  The original FSAR analysis
           used nominal decay heat values, whereas the power
           uprate analysis applied a two sigma uncertainty adder
           to those values.
                       VICE CHAIRMAN BONACA:  Okay.  Thank you.
                       MR. SIEBER:  This is, Mark, one
                       MR. GRANTHAM:  That's correct.  The impact
           of that on net positive suction head -- currently,
           Brunswick is a Safety Guide 1 plant which currently
           does not allow credit for containment overpressure. 
           As a result of the power uprate and in accordance with
           the allowances of the ELTR, we will, after the uprate,
           require credit for containment overpressure.
                       We actually looked at a short-term and
           long-term MPSH requirements.  Short term is for the
           first ten minutes when operator action is not
           credited, and the pumps are assumed to be at run-out
           conditions.  Under the first ten minutes, there is no
           credit for overpressure required.  After ten minutes,
           the flows on RHR and course-rate pumps are assumed to
           be throttled back in accordance with the approved
           operating procedures.  For the long-term analysis, the
           peak required overpressure is 3.1 psig.  The actual
           available overpressure is 11.3 psig.  In the license
           submittal, we've actually requested five psig to
           account for future changes and provide some margin
           between the limit.
                       The analysis that determined this was a
           conservative analysis in that for determining wetwell
           pressure, we assumed containment sprays were used,
           which actually resulted in a lower wetwell pressure. 
           For suppression pool temperature, we assumed direct
           pool cooling was used, which actually results in a
           higher pool temperature.  So for the MPSH evaluation,
           we actually have a combination of two different
           analyses, resulting in a worse-case condition -- lower
           pressure in the wetwell air space and higher pool
                       MR. WALLIS:  Are we ready to move on?  We
           are somewhat behind the original schedule, but it's
           because my colleagues are asking questions.  I think
           it's appropriate that you continue to ask questions. 
           But let's see if we can move along.
                       MR. PAPPONE:  Well, I'll try to get
           through this as quickly as Ken.  I'm --
                       MR. WALLIS:  You're an old hand at this,
                       MR. PAPPONE:  I'm Dan Pappone of General
           Electric.  I'm the LOCA Process Lead, and I'll be
           going through a couple of things here.  One is the
           feedwater and recirculation line break loading on the
           reactor internals, and then later on I'll go through
           the Appendix R.
                       What I've got here are the -- what I'm
           showing here are the external loads that come into the
           -- from the pipe break that come into the defective
           reactor internals that a set of loads that are due to
           the break itself.  The jet impingement is from the
           pipe end of the break, the flow from the pipe end of
           the break hitting the vessel.  The jet reaction is the
           break flow coming out of the vessel pushing.  The
           annulus pressurization load, that break flow is --
           some of that break flow is going into the space
           between the reactor vessel and the shield wall and
           pressurizing that region.  And there's an asymmetrical
           loading trying to push the vessel over.  And then
           there's also a pipe whip restraint on the pipe to keep
           the pipe from flailing around out in the drywell
           space.  And those restraints are on the shield wall. 
           The loads from the shield wall then get transmitted
           through the stabilizer to the vessel.
                       MR. SIEBER:  That would be what we would
           consider the nozzle load?  Or is the nozzle load
           something different there?
                       MR. PAPPONE:  When you're saying the
           nozzle, you're talking about the reactor vessel
                       MR. SIEBER:  Right.
                       MR. PAPPONE:  At this point, we've severed
           the pipe completely, so --
                       MR. SIEBER:  So you're assuming there is
           no nozzle load.
                       MR. PAPPONE:  There isn't a nozzle load at
           that point.  We're not looking at --
                       MR. SIEBER:  Something less than severing
           it completely would create a big nozzle load and maybe
           a complete severing of the pipe would not be the most
           restrictive case?
                       MR. PAPPONE:  On the nozzle, right. 
           Right.  That's what I'd say --
                       MR. SIEBER:  Sooner or later you would end
           up with a total break after the nozzle fails, right?
                       MR. PAPPONE:  Right.  Or, actually, most
           likely it would be a junction between the pipe and the
           safe end on the nozzle.
                       MR. SIEBER:  Right.  Right.
                       MR. PAPPONE:  And then the other part that
           wasn't shown on there was internal loads that are
           going to affect the vessel.  We've got blowdown
           pressure difference loads between the regions, which
           we have flashing through the different regions.  And
           also flow-induced and acoustic loads.  In the
           Subcommittee discussion, the flow-induced and the
           acoustic loads were really the topic of interest.  And
           for those loads, we're looking at the recirculation
           line break as the limiting location.  That break is
           down low in the subcooled region of the vessel.  The
           other pipe breaks -- the other large pipe breaks are
           up in the saturated region.  And the acoustic wave
           propagation isn't very good in saturated water
           compared to the subcooled water.  Down in the recirc
           nozzle location, we've got a fairly restrictive area
           in that down-comer region, so that's where we get the
           flow-induced loads.
                       MR. WALLIS:  Why should this change with
                       MR. PAPPONE:  What changes with EPU is
           that because we've got a little more steam flow going
           out of the vessel, we've got a little more feedwater
           flow coming in, and even though the feedwater
           temperature is a little bit higher because we've got
           more flow coming in, when we mix that, we end up with
           a little bit lower down-comer temperature.  And with
           lower temperature things like the flow loadings and
           the acoustic loadings get a little bit worse.
                       When we look at -- the components that
           we're looking at when we're looking at the flow-
           induced and acoustic loads are the jet pump and the
           core shroud and the shroud support.  In the shroud
           support, we're only looking at the acoustic loads
           there.  It doesn't see -- it's not in the flow field,
           so we don't see any flow loads on that.
                       And the approach that we take when we're
           evaluating these loads on the internals is we first
           try to fit within the original load definitions with
           the break flow driving source term.  If we can do
           that, we stop there, because if the load definitions
           don't change, the structural stresses don't change. 
           And if we can't fit within those envelopes with 
           pencil sharpening, we go to the next stage.  We look
           to see how much margin we have in the stresses to the
           allowables, and we eat into some of that margin.  And
           the third step is to look at the actual stresses
           themselves from the original stress calculation and
           look for some conservatisms in that calculation.
                       So the original calculation may have used
           whatever the most conservative ASME structural
           approach is, and there may be another allowed approach
           that doesn't take out some conservatisms or may have
           done simple summing of both the first time you do the
           square root.  Some of the squares may separate the
           loads into whatever their timing is.  Like the
           acoustic load is in the first few milliseconds, and
           that's before the flow-induced loads come along.  So
           we can separate those loads.  They don't have to be
                       MR. SIEBER:  For all these steps that you
           went through to -- that I would call pencil sharpening
           steps, how far did you have to go with Brunswick under
           EPU conditions to come up with a reasonable answer?
                       MR. PAPPONE:  That's the next slide.  The
           components that do see an increase of load are the
           ones that are in that core flow and steam flow path. 
           They're the ones that see an increase in the loads. 
           And for most of the components, like shroud heads and
           dryers and the like, we have margined the allowables,
           so we were able to just accommodate those without
           having to do any pencil sharpening.
                       The acoustic loads we've refined our
           analysis technique down to a very fine mesh, basically
           water hammer calculation and reduced that driving
           forcing function.  And on those components, the shroud
           head -- or the core shroud, the shroud support and the
           jet pumps are the ones that benefit from that.  And we
           did do some pencil sharpening on the feedwater line
           break loads to get that down below.  That wasn't
           fitting in the --
                       MR. SHACK:  So for those you just refined
           the thermal-hydraulic analysis, and you didn't have --
                       MR. PAPPONE:  That's right.
                       MR. SHACK:  -- to mess with the stress
                       MR. PAPPONE:  That's right.
                       MR. SIEBER:  I presume that the more
           severe of these is the recirc line break, right?
                       MR. PAPPONE:  Right.
                       MR. SIEBER:  Okay.
                       MR. PAPPONE:  Well, for the pressure
           difference loading, it's the steam line break that
           gives us highest load there because of the rapid
           depressurization and the very rapid --
                       MR. SIEBER:  It's a bigger line.
                       MR. PAPPONE:  Right.  Well, it's about the
           same size pipe, but because it's up in the steam dome
           it pressurizes the vessel very quickly.
                       Okay.  Next I'll be going through the
           Appendix R, and the case that was presented in the
           Subcommittee is really more of a what if beyond
           licensing basis case.  So it's the only case where
           there's a heat up.  In all of the Appendix R scenarios
           that in Brunswick's licensing basis, they have the
           RCIC system available.  So there would be no core and
           covering heat up.  But this is a postulated scenario
           that's a what if the RCIC didn't work or something
           like that, even though it's a protected system.
                       So conservatisms in this particular -- or
           the scenario for this analysis is we've got the loss
           of off-site power, ramp the feedwater down, no credit
           for the RCIC and standard with the Appendix R
           calculations we've got the nominal core power level
           and a nominal decay heat, realistic decay heat.
                       There are three relief valves that are
           used for the blowdown, and we're assuming that the
           operators initiate that blowdown at 40 minutes when
           they get a diesel started back up so that they have a
           low pressure coolant injection pump available for
           cooling once the vessels depressurize.
                       The conservatism in the analysis -- the
           biggest conservatism is that 90 percent of the actual
           relief valve capacity being used in the analysis,
           we're using the tech spec value as opposed to the
           actual valve capacity.  With the Appendix R analysis,
           since this really is truly -- it is a nominal
           analysis, we could have taken credit for the full
           valve capacity.  The ECCS performance values, the pump
           flow rates in the valve stroke times and what not,
           took those from the LOCA licensing analysis.  And
           those again are minimums where we could have used
           nominal values and not taking credit for the RCIC.
                       And the results of this analysis, we've
           got a temperature of 1458 degrees.  We've got an
           acceptance criteria for the Appendix R analysis of
           1500 degrees, and that's based on no fuel damage.
                       MR. ROSEN:  You said 1450, but your slide
           says 1468.
                       MR. PAPPONE:  Fourteen sixty-eight.  I
           misread it there.  This was about 250, 300 degree
           increase over the current power case, and that's
           primarily due to the limited relief valve capacity,
           only using three relief valves.  And, say, the
           standard Appendix K small break LOCA analysis were
           taking credit for five or six valves.
                       MR. SIEBER:  Yes.  But you assume three
           valves because you're operating from the standby panel
                       MR. PAPPONE:  That's correct.
                       MR. SIEBER:  -- and it probably only has
           three valves on it.
                       MR. PAPPONE:  It only has three valves on
           it, but the thing is with the three valves, we're more
           sensitive to a change in core power, because we're
           generating more steam.
                       MR. SIEBER:  That's why you can't
                       MR. PAPPONE:  Right.  And these results
           are consistent with what we've seen for the other
           power uprates in the Appendix R.
                       MR. SIEBER:  It would have been better off
           to add another valve to the standby panel except for
           the fact that you would have to protect that division,
                       MR. PAPPONE:  We'd have to --
                       MR. SIEBER:  Which would be probably
                       MR. PAPPONE:  Right.  We'd have to protect
           the cabling and add the logic to it.  And the other
           part is that this really is a what-if calculation,
           because all of their Appendix R scenarios they've
           already protected the RCIC, so --
                       MR. SIEBER:  Every calculation is what if
           until it happens, right?
                       MR. PAPPONE:  That's true.
                       MR. SIEBER:  Okay.
                       MR. PAPPONE:  Back to Bob.
                       MR. KITCHEN:  This is Bob Kitchen.  I just
           want to close, discuss briefly the operator impacts
           and PSA results.  The operator impacts -- of course,
           the testing that we have planned, as we've discussed,
           is per the ELTR with the exception of large transient
           testing.  The operational changes that we see we've
           talked about the change in instability solution for
           the operators.  The nature of the power uprate where
           we're operating on the power flow map is more
           restrictive than our core flow window, so that results
           in more power reductions to make rod pattern change. 
           This is an impact the operators will see.  So this is
           more of what we've been doing.
                       Then, finally, there is some small
           response in -- small reduction in operator response
           time.  What we're talking about here is the just the
           higher power operation, you know, higher feed flow,
           higher steam flows.  The transient simulations that
           we've run in the simulator is really almost
           imperceptible to the operator, and we don't see a
           significant impact there.
                       MR. ROSEN:  What did you say about more
           power reductions?  I lost track of that.
                       MR. KITCHEN:  We were operating on a
           powered flow map in an area that's more restrictive. 
           There's less core flow variation allowed just because
           of where we are.  And that necessitates rod pattern
           changes more often to maintain full power.  And to
           make the rod pattern change, we'll be doing more power
                       MR. ROSEN:  Come down, make the rod power
           change and go back up, and you'll have to do that more
                       MR. KITCHEN:  Yes, sir.  So really, all in
           all, the operator impacts are relatively small.
                       The PSA results, just to show you,
           basically, the PSA review showed no change in success
           criteria or accident sequences.  There were no
           significant changes in procedures so no significant
           impacts.  And the hardware changes are like in-kind. 
           Really, in terms of impact, there's a very small PSA. 
           There were some slight decreases in operator response
           time in the PSA analysis associated with HPSI and RCIC
           level control in ATWS, but they were small:  30
           minutes currently, 24 minutes under uprate; a six-
           minute reduction.
                       When we look at the PSA results, just the
           bottom line, across the top here is a current values
           for core damage frequency and large early release. 
           With EPU, our psi review showed basically about 1.6
           increase in CDF and about a four and a half percent
           increase in large early release.  But as we --
                       VICE CHAIRMAN BONACA:  Did you do an
           uncertainty analysis on these or are these point
                       MR. KITCHEN:  I'll let Larry Lee address
           the analysis.  Larry's with ERIN Engineering.
                       MR. LEE:  Hi.  This is Larry Lee from ERIN
           Engineering.  Yes.  These are point estimate
           evaluations.  We didn't do a detailed classic
           uncertainty analysis.  We did do sensitivity studies.
                       VICE CHAIRMAN BONACA:  So how -- I mean
           look at the difference -- 255, 259.  You're talking
           about four tenths to the minus seven difference, and
           this comes from a point calculation which can be off
           by a factor of two.
                       MR. LEE:  True.  We didn't do -- because
           this wasn't a risk-informed submittal, we didn't do a
           classical uncertainty analysis.  We believe the
           uncertainty analysis would be similar to the
           uncertainty shown in NUREG 1150, and we don't believe
           that the Brunswick PSA has any unique plant features
           that would change the results from that uncertainty
                       MR. KITCHEN:  The other point is that when
           we factor in the SLC boron concentration increase,
           which we have committed to since the ACRS Subcommittee
           meeting, with that change, we go from -- and ATWS is
           a highly weighted accident PSA.  When we make that
           change alone, going from two-pump required success
           criteria to the one-pump required success criteria, as
           you can see it reduces the impact.
                       MR. ROSEN:  To what do you attribute the
           slight increase in the EPU case, in the point
                       MR. LEE:  The increase in the point
           estimate is due to some decreased time for available
           operator actions related to level control.  So the
           decreased time available showed resulted in a slight
           increase in some human error probabilities.
                       MR. POWERS:  Are we looking at a balancing
           of negative and positive things?  I mean it seems to
           me you've done some -- you're doing some things
           stabilizing your grid, which clearly should reduce
           your risk.  At the same time, you're decreasing the
           opportunities for the period of time available for
           operator actions, which apparently increases your
           risk.  Is the magnitude of that increase masked by
           some of the grid stability things that you've done?
                       MR. KITCHEN:  We didn't -- Larry, we
           didn't credit the --
                       MR. LEE:  No.  We did not credit any
           potential positive impacts by increasing grid
           stability.  Like, for example, decreasing the loss of
           off-site power initiating event.  The only one we --
           in sensitivity studies, we took credit for the SLIC
           modification.  We also did a sensitivity where we
           increased the turbine trip frequency by ten percent to
           account for any uncertainties in any potential
           increases in SCRAMs due to Plant modifications or
           potential decreases in SCRAM margins.
                       MR. KRESS:  What is your conditional late
           containment failure probability?
                       MR. KITCHEN:  I'm sorry?
                       MR. KRESS:  The conditional late
           containment failure probability?  It's a Mark 1
           containment.  Usually those things are done around
                       MR. LEE:  We didn't recalculate the late
           containment failure probability for the Level 2
                       MR. KRESS:  Well, it probably doesn't
           impact it except it gives you a late containment
           failure frequency which is basically equivalent to
           your CDF, which would make it like two times ten to
           the minus five.  I just wondered if that gives anybody
           any pause for reflection other than me.  Late
           containment failures we know of impact on either.  I
           recognize that Reg Guide 1.174 doesn't talk about late
           containment failures, which is one of the things I
           think's wrong with it.  But I just wondered if the
           staff looked at that and gave them any pause for
           reflection at all?
                       MR. WALLIS:  Are you going to ask the
           staff that?
                       MR. KRESS:  Pardon?
                       MR. WALLIS:  Are you going to ask the
           staff that when they --
                       MR. KRESS:  Well, I think that's a staff
           question.  Did they think about that and did it give
           them any serious heartburn at all?
                       MR. HARRISON:  If I can -- I think the
           answer is fairly quick.  This is Donnie Harrison from
           the PRA branch, and I'll give you two parts to the
           answer.  The first one is we didn't look at it.  The
           second part is that it is something that's being
           thought about, but it's not in the guidance now.  And
           it's something that the staff does need to think
           about.  Under what conditions would you really want to
           look at the late containment failure probability?  And
           I think unlike South Texas, on their exemption, there
           was a case where we didn't want them having some
           systems that only come into play on the late
           containment getting dropped.  So there will be cases
           where that is looked at, but it's something I think
           the staff needs to think through completely to come up
           with some guidance on when you would apply it and when
           you wouldn't.
                       MR. KRESS:  That might be some sort of
           update to the Reg Guide 1.174 at some time maybe?
                       MR. HARRISON:  I'm not involved in that,
           but I would hope in that revision they think about
           that type of thing.  And I'll take that back to them.
                       MR. KRESS:  Okay.
                       MR. WALLIS:  So let's just clarify. 
           That's since we met you a week ago, you have agreed
           with the staff that you will install the SLIC
           modification.  That's part of your application now?
                       MR. KITCHEN:  Yes, sir; that's correct.
                       MR. WALLIS:  Okay.
                       MR. KITCHEN:  And installed in such a way
           that it results in single-pump --
                       MR. WALLIS:  Single pump, right.
                       MR. KITCHEN:  -- success criteria.
                       MR. WALLIS:  Thank you.
                       MR. KITCHEN:  This concludes the
           presentation that we have prepared.
                       MR. WALLIS:  Any more questions for the
           presenters?  I'd like to move on to the staff
           presentation.  Thank you very much.
                       MR. MARSH:  I'm going to go ahead and get
           started while people are shuffling around.  Good
           morning.  My name is Tad Marsh, and I'm the Acting
           Deputy Director of the Division of Licensing Project
           Management in NRR.  We are here today to summarize our
           review for the extended power uprate application for
           the Brunswick units.
                       The staff has conducted a thorough review
           of the Brunswick Plant and those areas potentially
           affected by the power uprate, with the focus of our
           review --
                       CHAIRMAN APOSTOLAKIS:  Excuse me.  Who is
                       MR. MARSH:  Oh, I'm sorry.
                       CHAIRMAN APOSTOLAKIS:  Dr. Wallis, are you
           going to need extra time?
                       MR. WALLIS:  I'm not taking any time.  The
           staff is taking the time.  I think the staff may need
           some extra time, because --
                       CHAIRMAN APOSTOLAKIS:  We're supposed to
           finish at 10:30.
                       MR. WALLIS:  That's right.
                       CHAIRMAN APOSTOLAKIS:  Twenty minutes is
           enough time?
                       MR. WALLIS:  Tad Marsh has no -- how much
           time do you need?
                       MR. CARUSO:  We had assumed that we would
           have an hour.
                       MR. WALLIS:  No, you weren't even allowed
           an hour originally.
                       MR. CARUSO:  Forty-five minutes.
                       MR. WALLIS:  Can you do it in a half an
                       MR. CARUSO:  We can give our presentation
           in a half an hour.
                       MR. WALLIS:  The problem is our colleagues
           asking questions.
                       CHAIRMAN APOSTOLAKIS:  Well, the whole
           idea is --
                       MR. MARSH:  We probably need a half an
           hour to go through our slides.  If there's no
           questions, we can go through it --
                       PARTICIPANT:  If we're not going to ask
           questions, there's no point having a meeting.
                       CHAIRMAN APOSTOLAKIS:  No, no, no.  We
           should ask questions.
                       MR. CARUSO:  We'll try to be efficient and
                       CHAIRMAN APOSTOLAKIS:  Huh?
                       MR. CARUSO:  We'll try to be efficient and
                       CHAIRMAN APOSTOLAKIS:  Well, the best way
           is to actually skip some slides.  Can you do that
           sitting there?
                       MR. CARUSO:  We'll try.  We'll try to go
           through --
                       CHAIRMAN APOSTOLAKIS:  Or does he have to
           go through five letters of review?
                       MR. MARSH:  Why don't we --
                       MR. WALLIS:  Maybe, Tad, we could cut down
           your introduction.
                       MR. MARSH:  That would be fine, but I do
           want to make some comments.
                       MR. WALLIS:  Sure, certainly.
                       MR. MARSH:  Okay.
                       MR. WALLIS:  So let's try to --
                       MR. MARSH:  I do have some things I need
           to say.  Okay.  I'll skip some of the boilerplate, but
           I do want to concentrate on the large transient
           testing statement.  And I want to reemphasize what I
           said earlier regarding the large transient testing. 
           And as you know, the licensees have proposed not to
           conduct such tests for EPUs.  And as I said earlier,
           the Director of the Office of Nuclear Reactor
           Regulation has tasked the staff to develop generic
           guidelines for testing programs, including power
           uprates.  And this effort will formulate guidance to
           determine whether or not such tests are to be
           conducted, including the large transient tests.
                       During previous meetings with power
           uprates, the Committee has commented that such
           guidance should be developed to provide the staff,
           licensees and the public with clear criteria for
           evaluating these requests related to testing.  We
           intend to provide the plan to the Office Director by
           May 31, 2002, and we will of course keep the Committee
           involved in those discussions.
                       I want to emphasize, though, that the
           charge from the Office Director was not to require
           tests, it was to develop criteria such that the staff
           can evaluate in some more routine manner whether they
           should be conducted or not.  The charge was also not
           citing that there was any immediate safety concerns
           absent those tests.  So I wanted to emphasize that.
                       Now, as I said, we'll be glad to discuss
           this with you further, but because of the nature of
           the issue and how it arose and how it's being pursued,
           we should probably conduct it in a manner different
           than having a public meeting.  And we'd be glad to do
           that with you and for you at your choosing.
                       With that, Mr. Chairman, I'll turn it over
           to Brenda who's going to go through our presentation.
                       MR. ROSEN:  The difficulty I have with
           that is that the Panel's recommendations may or may
           not be applied retrospectively, and then that -- I
           think the Committee needs to understand that point.
                       MR. MARSH:  Yes.  What could I say?  The
           Office Director, in transmitting this thing to Brian
           Sheron and asking him to develop criteria said to use
           the normal process for deciding whether this should be
           back-fit or not.  It said to use your budgeting
           process in terms of laying out the time frame period
           to be done and the endorsement of the Panel's
           recommendation.  The Panel's recommendation itself was
           to develop the criteria, as opposed to require
           testing.  So there was not an endorsement to require
           testing, rather to develop the criteria.  And there
           was no criticism specifically of the final judgment
           that has been made in these past cases; rather it was
           the process by which the decision was made.
                       MR. ROSEN:  Try to make this clear.  If
           the Panel's recommendations are accepted and
           ultimately criteria are developed that would apply to
           Brunswick and require large transient testing, how
           would that end up being applied to Brunswick?
                       MR. MARSH:  We would have to go through a
           50.109 process.  We would have to go through a back-
           fit evaluation to decide whether to change the
           licensing basis for this Plant, unless there's an
           adequate protection issue or there's a compliance
           issue.  But we have to go through --
                       MR. WALLIS:  Is this assuming that they've
           already been given the license?
                       MR. MARSH:  Yes.  Yes.
                       MR. WALLIS:  But suppose the license has
           not been modified by then, what do you do?
                       MR. MARSH:  As I said earlier, if the
           license were not, then it would have to be -- the
           outcome would depend upon what the evaluation said. 
           If you haven't issued the license yet, then you could
           theoretically apply that judgment in a forward manner
           as opposed to a backward manner.
                       MR. WALLIS:  Does that answer your
                       MR. ROSEN:  Yes, that answers it.
                       MR. MARSH:  Let me just -- we're on
           difficult grounds here because of the nature of the
           issue and the nature of how it arose.  I want to just
           call your attention to the memo that you have before
           you and the safety perspective that was embodied in
           that Panel recommendation.  I think that's an
           important element, and it was an important
           characterization from the Office Director to the
           Associate Director in terms of the timing of how this
           thing should be developed.  There was no urgency
                       And those are my statements, Mr. Chairman. 
           I'd like to turn it over to Brenda Mozafari to
                       MS. MOZAFARI:  Okay.  My name is Brenda
           Mozafari.  I am the Project Manager for the Brunswick
           review.  I'm going to skip over the overview, just
           make a few comments to the effect that they provided
           the application last August and for the most part it
           follows ELTR 1 and 2.  Exceptions were noted in their
           application.  It is not a risk-informed submittal, and

           it did base a lot of issues in their submittal on
           previously accepted aspects of previous EPUs.
                       Now, I just show -- just so that you can
           see, there were reviewers and reviews done in all
           these areas, and those you saw reflected in the safety
           evaluation.  But we tried in this presentation, albeit
           a little shortened, and it was presented during the
           Subcommittee meeting, but we tried to focus on some
           aspects of the staff review and certain areas that the
           ACRS seemed to have some potential added interest.  So
           with that, I'd like to turn it over to the Chief of
           the Reactor Systems and Fuels Group of NRR, Ralph
                       MR. CARUSO:  Since my boss is sitting
           here, I should explain that I'm not the Chief of the
           Reactor Systems, Brenda.
                       MS. MOZAFARI:  Oh, excuse me.
                       MR. CARUSO:  I'm only the --
                       MS. MOZAFARI:  Section Chief.
                       MR. CARUSO:  I'm only the Section Chief of
           the BWR Nuclear Performance Section.
                       MS. MOZAFARI:  I promoted you.
                       MR. CARUSO:  This is not the moment for a
                       What I wanted to talk to you about, and I
           wouldn't be here -- the reason I'm here is that
           there's an issue that keeps coming up during these
           discussions with the Committee and involves the
           applicability of the analytical methods that are used
           in doing these power uprates.  And I would like to
           discuss -- start the discussion this morning with a
           review of this issue and a restatement of discussions
           that we've had in the past on code applicability.
                       This is the fourth significant BWR power
           uprate that we've done:  Duane Arnold, Dresden, Quad
           Cities, Clinton and Brunswick.  And I wanted to
           describe to you today code applicability.  I want to
           discuss code applicability and how we assure that the
           codes are used appropriately.
                       I'd like to open first with a discussion
           of our review scope.  How do we decide to review and
           to look at what we review?  This point in the process
           we are gaining most of our -- making most of our
           review decisions based on experience from prior
           reviews, the three that we've done so far.  Now we've
           got a fourth.  They give us a lot of experience.  They
           give us a lot of ideas about what to look for in the
                       We have some guidance documents, we have
           a Standard Review Plan, we have Reg Guides, and we
           have the topical reports that are used to -- that
           describe the approved methodologies.  We use those
           guidance documents as well as -- as far as they go.
                       MR. WALLIS:  Now this SRP is a general
           SRP, it's not for uprates.
                       MR. CARUSO:  This is not for uprates, but
           realize that the SRP -- it's a general SRP.  It was
           designed originally to license these plants, so it
           includes all the areas that would normally be
           considered if you were going to relicense this Plant,
           start from zero.  And therefore, theoretically, it
           should be applicable to reviews for power uprates.  So
           we use that guidance in the SRP and in the regulatory
                       We are also doing, simultaneously with
           these power uprates, other licensing actions.  We're
           doing tech spec amendments, we're doing topical report
           reviews, we're doing lots of other licensing actions,
           and we learn from them.  We have information from them
           that we consider.
                       Fourth, we look at operating experience
           and feedback from the field.  We get licensee event
           reports, we get deficiency reports from licensees. 
           All that information is considered.  And, finally, all
           this information is put together by knowledgeable
           people, people that are paid to do this job and
           exercise their judgment to decide what's important and
           what's not important.
                       So this is where we get the idea about
           what to review and what not to review.  And you should
           realize that what we don't review is a lot.  The vast
           overwhelming majority of the information that's
           developed for these power uprates is not reviewed by
           the staff.  GE has 40 people working on each power
           uprate.  Licensees have probably another 100.  I have
           three people.  I can't review everything they do.  I
           can't even review a significant fraction of what they
           do.  So I have to make a choice.
                       Now, one of the issues that's come up is
           how do I know the codes are the right codes to use? 
           Once again, this is judgment, but there's actually a
           bit of a basis to this.  This is a BWR and the BWR
           methods have been applied across the entire BWR range,
           from probably Big Rock Point all the way up to Grand
           Gulf.  And the power uprates that we've seen so far
           have all been within the range of applicability for
           which there are already plants operating at those sort
           of power levels and power densities.  So these codes
           are not being applied outside a range of applicability
           for which they're already in use right now.
                       MR. WALLIS:  I guess a question that
           several of us raised was, yes, it's an approved code,
           but you know that how you use the code can make a
           difference to the answer.  So you have to worry about
           how the code is used.
                       MR. CARUSO:  That's in my second slide. 
           I'll get to that in a second.
                       The second part of this was we're not
           using any new codes.  There was a big flap about power
           uprates about eight years ago at Maine Yankee because
           someone decided to use -- among other things, a
           licensee decided to use a new code for a power uprate,
           and it hadn't been well-validated.  We're not using
           new codes for these power uprates.  They've been in
           existence for a while, and they're mature.  So there's
           not a Maine Yankee scenario here.
                       In addition, even though the codes have
           been around for a while, GE has been making
           modifications to them continuously.  We recently
           completed a review of a change to the SAFER/GESTER,
           we've looked at the ODYSY code, and we have ongoing
           experience with TRAC-G.  We completed a review for
           AOOs about a year that we discussed with the
           Committee.  So the staff has kept in touch with these
           codes and these methodologies.
                       Now, I'd like to go on to the question of
           how do we know that they're being used appropriately? 
           And I'll start by asserting that the vendors use the
           codes rigorously.  The limits for using the methods
           are described in topical reports.  For GE, there's a
           topical report known as GESTAR.  It's a massive
           document.  It describes in intricate detail how to do
           the calculations.  GE takes these limits from the
           topical reports and it develops procedures so that it
           can do production calculations.  And that's an
           important phrase -- production calculations.
                       These production calculations are done by
           knowledgeable engineers, they're done in accordance
           with written procedures.  They have to be done that
           way in order for them to be done efficiently.  And
           those procedures are checked by internal quality
           assurance people in GE, reviewed by several levels of
           management, they're attached to a large Appendix B
           quality assurance program, they're reviewed by
           licensees who have a vested interest in making sure
           they're done properly, and the inputs are controlled. 
           GE has a central database.  The inputs are also
           checked by licensees.  So there are a lot of controls
           on the use of these codes to prevent them from being
           used too creatively.
                       MR. SIEBER:  It's my impression that GE
           does all the calculations necessary for these kinds of
           analyses with the same group.
                       MR. CARUSO:  Yes.
                       MR. SIEBER:  And that -- for all BWRs? 
           And that licensees don't do any of these calculations
           independent of General Electric.  Is that true?
                       MR. CARUSO:  I don't know.  You're talking
           -- that's probably going to a plant-specific issue. 
           There may be some licensees that do some containment
           calculations of their own, for example.
                       MR. SIEBER:  I accept that.
                       MR. CARUSO:  The fuel calculations,
           though, I believe are done by the fuel vendors, and I
           don't know of the other -- how much technology
           transfer goes on between the other vendors, but I
           believe GE does not do much, if any.
                       MR. SIEBER:  Okay.
                       MR. CARUSO:  I'd have to ask them, but I
           believe they don't do it.
                       MR. WALLIS:  It does mean that they're
           very dependent on the results prepared by GE.  They
           are the source of the numbers, which are quoted and
           approved and all that.  Nobody else is.
                       MR. CARUSO:  Well, GE is responsible for
           the results, but they depend on inputs that are
           received from the licensees about the plant
                       MR. WALLIS:  Right.
                       MR. CARUSO:  About the operating
           procedures, about the assumptions for operator action
           times.  So there is -- it's not all done by GE in a
           black box; the licensees interact with them.
                       MR. ROSEN:  Accepting that point, could we
           have the GE guy tell us how much is done by the
           utilities --
                       MR. CARUSO:  Fran?
                       MR. ROSEN:  -- in Brunswick, in
           particular, but more generally if you can.
                       MR. BULGER:  This is Fran Bulger from GE. 
           We have made these codes that are used in these
           licensing analyses available to the licensees, and
           most all of them have, at least to some extent, some
           of the codes.  At least -- most all have the core
           design codes, and many have the transient analysis
           codes.  A number of them actually have done in-house
           training with some of these licensing codes, so they
           try to see if they can reproduce some of the GE
                       We've held training up in Raleigh with
           some of the CP&L staff to get into some more of the
           details of the transient codes.  The CP&L has a number
           of the GE codes.  A number of the utilities send their
           staffs to GE and do actually perform some of the
           licensing analysis at our site.
                       MR. CARUSO:  So you see that the licensees
           and GE work together on this.  This is not something
           that's done by GE in a vacuum.
                       MR. WALLIS:  But there is no independent
           calculation made by somebody else.
                       MR. CARUSO:  That is correct.
                       MR. SIEBER:  It was my impression --
                       MR. CARUSO:  At least not by the staff.
                       MR. SIEBER:  -- that if the licensee, on
           its own volition, wanted to perform the calculations
           and make those calculations the record calculations
           for the plant, they would have to have all this
           infrastructure that GESTAR discusses, including an
           approved topical that describes how they will do the
                       MR. CARUSO:  That's correct.
                       MR. SIEBER:  And that's a big hurdle to
           jump through.
                       MR. CARUSO:  I believe at this point that
           we have not approved the use of any of the GE methods
           by any licensees.  Is that correct, Fran?
                       MR. BULGER:  That's not correct.  Southern
           Nuclear is approved to use GE methods.
                       MR. CARUSO:  Okay.
                       MR. SIEBER:  That's pretty helpful.
                       MR. CARUSO:  That's something I did not
                       MR. BULGER:  That's the only utility that
                       MR. CARUSO:  Is that the only utility?
                       MR. BULGER:  For the GE methods.  Excellon
           had been using some of the GE methods to do slow
           transient analysis and some of the core design work. 
           Recently they've decided to contract that out to GE.
                       MR. ROSEN:  This is, of course, not true
           in the PWR side.
                       MR. CARUSO:  That's correct.  That's why
           I'm careful about saying this.
                       MR. ROSEN:  Numerous PWR utilities do
           their own calculations and have approved topicals, as
           far as I know.
                       MR. CARUSO:  That's correct.
                       MR. SIEBER:  Some do, some don't.
                       MR. ROSEN:  Some do, some don't, but there
           are quite a few that do have approved topicals and do
           their own calculations.
                       MR. DRESSER:  This is Tom Dresser with
           CP&L.  Though CP&L does not do licensing calculations
           independently from GE, we do, as part of our own
           review and oversight program, we do quite a bit of
           independent calculations.  We have to access to some
           of the codes from GENNE, and we also have independent
           neutronic methodology.  So it's -- we do, in addition
           to oversight of the vendor, we do alternate
           calculations for our own review purposes.
                       MR. CARUSO:  So the licensees -- in this
           case, this licensee does do some independent checks,
           independent calculations, but the staff does not for
           these normal -- for these sort of applications where
           a licensee or GE is using an approved methodology in
           an appropriate way, in a way that is not, as I put it,
                       MR. RANSOM:  Ralph, I think you said that
           they have made some changes to these codes?
                       MR. CARUSO:  They make changes on a
           periodic basis, yes.
                       MR. RANSOM:  Have you looked at their
           review procedure or quality control or quality
           assurance procedures, I guess, to assure that these
           changes do not change past results?
                       MR. CARUSO:  The changes that I was
           talking about have been reviewed by the staff.  They
           submit a revision to the topical report, and we review
           that, and we assure that the change does not -- well,
           it usually affects the results in some way, but we
           assure that it's an appropriate change, that it's
           justified and documented and it has a basis.
                       And then my last two items here we've been
           doing audits of these calculations as part of these
           power uprates, where we will go to GE Wilmington or GE
           San Jose and we have a team of five people who
           actually look at the detailed design record files for
           selected calculations.  Based on their judgment, they
           decide, "I want to go look at LOCA this week.  I want
           to look at ATWS next week.  Next time I want to look
           at Standby Liquid Control System."
                       MR. RANSOM:  I guess my concern was that
           they have a procedure in place such that someone
           cannot simply put in an ad hoc change that a
           particular individual wants.
                       MR. CARUSO:  It's my understanding that
           the proceduralization of the analysis process is done
           to prevent that from occurring.  That's a major sort
           of change, and they don't like to do that.
                       MR. SIEBER:  It's my understanding that
           the vast majority of the changes are basically
           corrections that have somehow or other been discovered
           through the use of the codes, and they're required to
           be submitted annually.
                       MR. WALLIS:  I'm going to be in great
           trouble with my Chairman if we don't proceed.
                       MR. CARUSO:  I'm sorry I'm taking so long. 
           I'm just about done here.  This has been philosophy. 
           Zena is going to talk about two areas where during our
           review we actually did identify some problems and
           pointing out the value of doing these audits and doing
           them in a targeted fashion.  And she's going to
           explain to you what she found.
                       MS. ABDULLAHI:  Good morning.  My name is
           Zena Abdullahi, and I'm the Reactor Systems -- one of
           the Reactor Systems Reviewer for the Brunswick EPU
           application.  I'm going to try to skim through my
           notes and try to speak fast since we are pressed for
                       In the previous EPU presentation, you
           asked us to discuss specific areas of review that
           would give you a sense of our review process. 
           Therefore, we did decide -- we decided that we will
           pick up two areas of examples and try to present it to
           you to show you to the detailed level that sometimes
           we look into things.  We've decided to address today
           ATWS and Standby Liquid Control.
                       In the ATWS case, one of the reasons we
           selected ATWS because it was -- the peak pressure was
           high.  The PUSAR reported a peak pressure of 1492 psig
           compared to 1500.  And we decided, therefore, to look
           further and to check since it's a two-unit application
           and the units have many similarities but they do have
           also some differences, including bypass capacities and
           the orifice sizes of the units.
                       We then decided for the ATWS to make sure
           that, at least in terms of peak pressure, that the two
           units the most limiting is used in terms of plant
           condition.  And we found out that in fact, yes, the
           analyses were based on Unit 1, which had a bypass
           capacity of about, I think, 20.6 percent.  This is the
           turbine bypass capacity.  And that for Unit 2, in
           fact, which has a larger bypass capacity of 69.6
           percent for the EPU rated thermal power, that for a
           specific event, called the pressure regulator failure
           open, that Unit is in fact more bounding.
                       The reason the Unit would be more bounding
           would be that you would have a failure of the pressure
           regulator to maximum demand.  It would open faster, it
           would steam out through the bypasses, and the unit
           that actually depressurizes through the lowest --
           pressurizes earlier would be the one that would have
           MSIV close earlier.  And, as such, then you would have
           the pressure go up, the boards collapse, the power go
           up, and that would be the unit that in terms of peak
           pressure would be more bounding.
                       We have asked the Licensee, and they have
           confirmed that, yes, this unit -- the analyses were
           based on Unit 1 in which the loop and the MSIV closure
           were the bounding case, and they reanalyzed the Unit
           2 using the Unit 2 bypass capacity.  However, they do
           actually use plant-specific parameters in order to try
           to reduce the conservatism.  And one of the things
           that they have done is they changed the pressure --
           the SRV set point, and instead of using the GE value
           of 44 psig, they used three percent tolerance, which
           is the plant-specific value, in which case that comes
           to 34 psig.  Then you would end up having ten valves
           popping open earlier, which will help you reduce the
           peak pressure.
                       And as a result, the peak pressure that --
           it basically compensates for the impact that you would
           have got from the larger bypass capacity.  And from
           that they did in fact come up with a lower peak
           pressure of 1487 as opposed to 1492.  However, the
           staff did go through the details officially that we're
           comfortable with the value that they came up with and
           can say that, yes, they do meet ATWS, and the peak
           pressure is acceptable as long as it's below the 1500.
                       I'll go faster.  With the --
                       MR. POWERS:  Let me ask a question about
           your calculation.
                       MS. ABDULLAHI:  Yes.
                       MR. POWERS:  You indicate that they
           changed the set point away from that recommended by
           General Electric.  Is there any possibility of error
           in making those set points?
                       MS. ABDULLAHI:  You mean the tolerance
           value or error in -- for the set points, yes.  I mean
           if set point drift goes up, their ATWS analysis would
           not work.  But the GE value of 44 psig was based on
           certain type of valve that they knew had a propensity
           for high drift.
                       MR. POWERS:  What I'm asking you, or I'll
           get around to asking, I guess, is that do you do a
           calculation and say, "Oh, what if by mistake the put
           their set points in incorrectly?"
                       MS. ABDULLAHI:  Oh, you mean the numbers.
                       MR. POWERS:  Yes.
                       MS. ABDULLAHI:  Well, we are relying on
           their analysis.  What we actually check is key
           parameters, limiting conditions, limiting components
           out of service.  We look more on the sequence, and we
           look if the result makes sense and if there's
           sufficient margin.  But we have not inputted the
                       Having said that, from the audit point of
           view, I don't see that it's such a far-fetched thing
           that -- the way we do it we look at the plant-specific
           and then we also look at GE methodology.  And I don't
           see that it's not possible that at one point we would
           actually go to that degree of some other audit, but we
           haven't done it this way.
                       MR. POWERS:  So the impression I'm getting
           is that you look at what they have done, and you say
           is that acceptable, but you don't do what my colleague
           here is suggesting is you might say, "Why don't you go
           back and make some other assumption?"
                       MR. CARUSO:  We don't do our own
           sensitivity studies to look at the potential errors
           that might be made in input values by licensees or by
           GE, no.
                       MR. MARSH:  Just a reminder these values
           are technical specifications, and they're, of course,
           bound by those, and they have LERs and other reporting
           criteria should they find these out of specification.
                       MS. ABDULLAHI:  I think I have time to say
           a few things about the SLC.
                       MR. WALLIS:  I think we're all interested
           in that one.
                       MS. ABDULLAHI:  Oh, I see.
                       MR. POWERS:  It's not for lack of
                       MS. ABDULLAHI:  Maybe I should skip it. 
           All right.  The SLC issue, the PUSAR did not contain
           an SLC relief valve margin evaluation.  And the
           objective for us presenting this to you is to tell you
           that we do not only look most cases at only what is
           discussed in the ELTR 1 and 2.  If there is an
           information notice or other information that would
           tell us some issue, we would actually carry it
           through, because we would think what would be the
           impact for the EPU, and then we would look into it. 
           And this is the case that we have done that.
                       In this particular case, the concern is
           that the SLC System would -- okay, what we would like
           to know is whether the SLC System could inject into
           the reactor at the assumed time, in the analytically
           assumed time, based on the predicted pressure and
           without lifting of the SLC relief valve.  Because
           there's a set point in which the SLC relief valve will
           lift, and if the pressure in the ATWS analysis is at
           some point, then you might end up getting the relief
           valve lifting.
                       And in the initial we asked the Licensee
           to do that evaluations, and in the initial evaluation,
           the Licensee did come back and say that, "Well, the
           value -- we have actually no margin."  And as a result
           of it, they went again and recalculated their two-pump
           system losses.  The original system losses was based
           on 1984 GE evaluation.  So they substituted that with
           their own system loss test.  They also calculated the
           plant-specific using plant-specific elevation head
           calculations, and then they came up with a better
           margin.  And it's a positive value, but it was still
                       The staff could not, at that point -- the
           staff accepted it for several reasons.  One reason is
           the value is positive, and the margin belongs to the
           licensee.  However, the staff felt that it was small
           and had several discussions, and the Licensee did
           recognize it.  The Licensee did recognize it, and they
           actually are going through with their own system
           upgrades.  And as a result of that, they will --
           informed us, "Yes, we will increase the margin by
           changing out the valves."  However, it's their own
           call to make.  We can only encourage and support.  And
           we have been told that, yes, they are making it.  We
           have a letter that they sent us in which they told
           that, "We have already ordered the valve change-out
           and we will change."
                       MR. SIEBER:  Actually, restructuring SLC
           operations to one pump is a benefit from the
           standpoint of margin.
                       MS. ABDULLAHI:  Yes, it is, because if,
           for instance -- let me first make another point of
           view addition to that.  Even if they go to one-pump,
           single-valve success criteria and they will be able to
           shut down the reactor, the Licensee intends to stop
           both pumps, because they do not want to change their
           EOPs or retrain their operators.
                       MR. SIEBER:  On the other hand, that means
           there's greater chance that you'll lift a relief valve
           with two pumps.
                       MS. ABDULLAHI:  Exactly.  What would
           happen is if one pump can do the job and you stop both
           pumps, even if the relief valve pops open and recycles
           back to the tag, you still would put in enough boron
           concentration to shut down the reactor, probably more
           than usual.  So we have accepted it.
                       However, there are two license conditions
           that are in the easy application.  And the two license
           conditions basically deal with the fact that when they
           load the second batch of GE14 fuel, they would need to
           increase the boron concentration, and as such we would
           like to have an amendment request submitted in advance
           before they do the load -- load in the GE14.  So
           there's that amendment request license condition.
                       Secondly, the Licensee had decided to
           commit to the single-pumps with valve success criteria
           in a sense of having a sufficient boron concentration
           to be able to achieve shutdown using one system.  And
           that is also a license condition for the application. 
           Thank you very much.
                       MR. WALLIS:  Now, I'm trying to see what
           would the ACRS might say about this, the letter.  You
           have agreed with the Licensee, it seems, since our
           last meeting, they will install these modifications. 
           So this -- first we need to say less to encourage
           this.  Has it already happened?
                       MS. MOZAFARI:  It's happened.
                       MR. WALLIS:  Okay.  Thank you.
                       MR. SIEBER:  Go ahead with your
           conclusions.  I have something to say after you're
                       MS. MOZAFARI:  Okay.
                       MS. ABDULLAHI:  We have reviewed the
           Licensee's application for EPU, and we have concluded
           that -- from all the reviews, we have concluded that
           BSEP units can be operated safely to 2923 megawatt
           thermal, and the Licensee's analysis has been
           demonstrated it can support this uprate.
                       MR. LEITCH:  I take it by that statement,
           then, you have no problem with allowing credit for the
           five pounds containment pressure?
                       MS. ABDULLAHI:  I am not --
                       MS. MOZAFARI:  She's the reactor --
                       MR. MARSH:  That's next.  That's not this
           one -- that's not reactor systems, that's containment
                       MR. WALLIS:  It's very similar to what was
           granted at another plant.
                       MS. MOZAFARI:  Richard?  Richard can speak
           to that, Richard Lobel.
                       MR. LOBEL:  This is Richard Lobel from
           Plant Systems Branch.  No, we don't have a problem
           with it.  It was considered in the review.  It's a
           small fraction of the total containment pressure which
           was calculated to be conservatively low.  And what
           we've done on this review is consistent with what
           we've done in other reviews and what we've discussed
           with ACRS in the past.
                       MR. ROSEN:  My comment is that this is an
           excellent piece of work, and the reviews that have
           been done have found important things, and I want to
           commend you on that.  One of the concerns of the
           Committee has been one central aspect of core design
           for these uprates and the limited amount of review we
           actually do.  You described you do fairly little, but
           we do only a piece of what we could do is small also. 
           So it seems to me that I derive considerable comfort
           from the fact that you are out looking at these
           analyses, but this a bad news/good news story.  The
           good news is you're out looking, the bad news is you
           found some substantive things that were wrong.  So my
           encouragement is to keep looking and to make sure that
           you do -- I think this Committee has made this point
           in the past, that these audits that you do have great
           value and should be continued.
                       MR. CARUSO:  For the BWRs, because of the
           interest, because of the large amount of the power
           uprate, we do intend to do that.  And we do intend to
           do it on a focused basis.  We don't intend to look at
           the things that are listed in the guidance documents,
           because everyone knows that's what we're going to look
           at.  So those are the ones that are always right. 
           We're looking at the things that aren't -- we're
           trying to look at the things that aren't listed in the
           guidance documents, and we get hints about where to
           look by --
                       MR. MARSH:  Operational experience plus
           any types of other evaluations that come up in the
           safety evaluations.
                       MR. CARUSO:  By thinking about these
                       MR. MARSH:  Right.  I did want to point
           out that in terms of the SLIC review they've just gone
           through, this was a topic that came up as part of an
           operational experience.  So operational experience
           vectored us into, and that's why we focus on this
           topic, which is building on Ralph's thought of that
           being a source of staff scope concerns.
                       MR. CARUSO:  We look at as much as we need
           to look at to make a decision.  And we're comfortable
           with the level of review at this point.
                       MR. MARSH:  Ralph mentioned three staff. 
           I want to say something about three staff.  If the
           Agency felt like there was an operational experience
           that warranted more staff to be devoted to this type
           of audit or confirmatory calculations, the Agency
           would devote the staff that it needed to do these
           things.  So I want you to understand which comes
           first, the chicken or the egg.  Ralph has three staff
           because that's what we think is needed at this point. 
           If more staff were needed, we would go through a
           budget process and decide whether it were needed and
           devote more staff to it.  So we are driven in
           resources by the safety concerns that these staff are
           looking at.
                       MR. WALLIS:  So somebody made the decision
           that for all these uprates having to do with GE
           reactors, that the ELTR 1 and 2 and all that were so
           good that you didn't really need any kind of work to
           check those.
                       MR. MARSH:  Well, you've heard some
           independent calculations beyond ELTR 1.  You've heard
           Rich talk about some containment calculations which he
           has done beyond what the ELTR 1 leads you to do.  The
           SLIC work that's here is not -- the SLIC doesn't tell
           Zena to do the type of reviews that she does.  This is
           beyond -- this is -- the ELTR doesn't tell Ralph what
           to do in audits.
                       MR. CARUSO:  Interestingly enough, in the
           SLIC case, it's not a question of the methodology
           changing, it's a matter of what point they pick on the
           curve to assume as the peak pressure.  And there were
           some assumptions made about when the operators would
           start the SLIC system and the pressure at that point. 
           And that's not a calculational issue, that's a much
           bigger, what we would call, methodology issue.
                       So doing an independent calculation would
           not have told us anything in the SLIC area.  We had to
           look at what they did with the numbers and what
           judgments they made with the numbers.  And we looked
           at the operating experience and what the operating
           experience told us about the assumptions.  So you have
           to fit them all together.  That's why you need
           somebody, a person who's knowledgeable and can make a
           judgment about what's necessary.
                       MR. MARSH:  The importance of Ralph's
           audits going beyond, looking over the fence, can't be
           understated too.
                       MS. MOZAFARI:  Right.
                       MR. MARSH:  He goes beyond what you would
           expect to be looking at to see whether those other
           areas that are of concern, and if concerns were found
           in that area, that would widen the staff's scope
           depending upon the safety significance.  And, also, we
           rely on Part 21, we rely on licensee event reports, we
           rely on a lot of elements to determine our scope.
                       MR. CARUSO:  In the area of core design,
           we have been spending I believe Ed Kendrick, who's
           here, did look at some core design issues during
           Brunswick review or during one of the earlier ones. 
           So we have been looking a little bit at the core
           design, but in a lot of cases we just don't think it's
           worthwhile to look at calculations that have been done
           on a routine basis for a long period of time using
           well-established methodologies.  It's just not
                       MR. WALLIS:  Ralph, can we move quickly
           through the rest of the slides?
                       MR. CARUSO:  I'm sorry, excuse me.
                       MS. MOZAFARI:  Ralph's going to cover the
           appendix, our evaluation from the fuel --
                       MR. CARUSO:  I don't have the slide in
           front of me, so I'm going to have to read from the --
                       MR. WALLIS:  I think we've all read it by
                       MR. CARUSO:  We've seen this?
                       CHAIRMAN APOSTOLAKIS:  Yes.  We've read
           it, and the last bullet is your conclusion.
                       MR. CARUSO:  I'll make one more point
           about this.  There was a concern about the increase in
           the temperature from less than 1200 to close to 1500. 
           It's our understanding that the less than 1200 number
           was not actually a calculation but was an estimate. 
           So we would say it's not really fair to make a
           comparison between an estimate and a calculation and
           say the value went up by 300 degrees.
                       And I agree with the points that Dan
           Pappone made.  Those are reasonable assumptions made,
           using a reasonable code, and they came up with an
           answer that is reasonable, and we accept that.  We
           don't see any reason to redo the calculation.
                       MR. WALLIS:  Okay.  Thank you.
                       MR. CARUSO:  Thank you.
                       MR. MARSH:  Okay.  Mr. Chairman, would you
           like us to go through the mechanical engineering
           presentation?  Would you like us to focus on
                       MR. WALLIS:  I think the bottom line is
           that you think is everything fine.
                       MR. CARUSO:  Yes.
                       MS. MOZAFARI:  That's the bottom line.  So
           you're not interested in hearing it?  That's fine.
                       MR. CARUSO:  Okay.
                       MR. WALLIS:  So you believe Dan Pappone's
           analysis about acoustic loads?  You're happy about the
           acoustic loads issue?
                       MR. MANOLY:  Yes.  I just want to correct
           -- this is Kamal Manoly from the Mechanical Branch. 
           Apparently, there was some misunderstanding about the
           magnitude of the loads from the pipe break, and
           they're dependence on the pressure and the temperature
           in the line and not the flow rate.
                       MR. WALLIS:  Right.  It depends on the
           pressure in the line mostly, isn't it, and not the
           flow rate.  Yes.
                       MR. MANOLY:  And the temperature.
                       MR. WALLIS:  Right.
                       MR. MANOLY:  And I looked at the tables --
           my lead reviewer is not here this week, but I looked
           at the tables of the results of the difference in
           pressure.  Slight, very slight increases in pressure.
                       VICE CHAIRMAN BONACA:  Please speak into
           the microphone.
                       MR. MANOLY:  Yes.  There's very slight
           increases in the pressure, the differences in the
           internals.  So the stresses increased are fairly
                       MR. WALLIS:  So you have checked this
           point raised by the Subcommittee, and you've come to
           the conclusion it's not an issue.
                       MR. MANOLY:  Right.
                       MR. WALLIS:  I think that's all we need to
           know really.
                       MR. LEITCH:  I just have a question about
           the overall efficiency of the process, and we
           discussed it a little bit at the Subcommittee meeting. 
           But I suspect that there are going to be a large
           number, perhaps almost all, of the BWRs in this cube
           to get power uprate.  And it seems to me that this has
           taken an inordinate amount of time, a very large
           number of RAIs involved in the process, and I just
           wonder if we can't learn something from the license
           renewal process, which seems to be running much more
           smoothly with a fairly low number of RAIs.  Is there
           a more systematic way in which this type of a review
           could be conducted?
                       MR. CARUSO:  I believe that for the BWRs
                       MR. MARSH:  Let me give it a try from
           here, because I want to answer it globally.  I talked
           a little bit about it at the Subcommittee --
                       MR. LEITCH:  Yes.  That was my question
           was really a global one.
                       MR. MARSH:  Yes, sure.  Let me try, Ralph. 
           We are committed -- as you say, we are committed to
           get to the Commission by March 26 with some effort to
           try to improve the efficiency and effectiveness of the
           reviews.  And we are going to talk with the Commission
           on July 10 at a Commission meeting with license
           renewal.  Because they've charged us to look at the
           license renewal process as they improve their
           efficiency to see whether we can draw from some of the
           benefits that they have found in terms of the process. 
           So we are charged to do that.  And we hope to meet
           with you and talk with you about that process before
           we meet with the Commission; that's our intent.
                       A couple things.  CPPU, the reliance on
           CPPU as a process will help us in some respects.  It
           will help us in terms of efficiency.  The number of
           RAIs we're looking at that carefully.  We're making
           sure that the scope that we're looking at, how we look
           at them is the appropriate number, the appropriate
           number of questions.  And I think licensees are
           learning also as we go through this process for what
           we are interested in.  And they're focusing their
           submittals on the issues that we have sought through
                       We need to be more efficient.  We've spent
           a great deal of FTE on power uprates last year -- over
           11, 11.5 FTE in the licensing area.  That's a large
           number.  So we need to be better, and we're committed
           to doing that, and we're going to be discussing it
           with you.
                       MR. LEITCH:  Good.  Thank you.
                       MR. WALLIS:  Anything else?  We've lost
           our Chairman.  I'd like to hand the meeting over to
           the Vice Chairman.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. WALLIS:  Thank you very much.
                       VICE CHAIRMAN BONACA:  Any other questions
           from members?  If not, we'll take a recess for 15
           minutes.  We'll actually get back again, we're kind of
           late, so maybe at ten after 11.
                       (Whereupon, the foregoing matter went off
                       the record at 10:57 a.m. and went back on
                       the record at 11:12 a.m.)
                       VICE CHAIRMAN BONACA:  Okay.  The meeting
           is called to order again.  We have now the -- the
           purpose of this meeting is to review the findings and
           observations of the Expert Panel convened by RES to
           assess the applicability of the NUREG-1465, accident
           source term for light water reactors to high burnup
           and MOX fuels.
                       Two ACRS members, Dr. Powers and Dr.
           Kress, were members of this Panel.  Therefore, they
           will not participate in discussions on the potential
           finding of the Committee, although they are not
           prohibited from providing the Committee with factual
           information on the subject.
                       The staff has not requested a letter on
           this issue, in part, because the information is quite
           preliminary.  We are running late, so I would like to
           understand how much time you think you need.  I think
           you have half an hour allotted for the presentation?
                       MR. SCHAPEROW:  Yes.  I've got about 16
           slides, but it shouldn't take too long.
                       VICE CHAIRMAN BONACA:  So I think we
           should be able to stay within the hour that we have --
                       MR. SCHAPEROW:  Certainly.
                       VICE CHAIRMAN BONACA:  -- scheduled for
           the presentation and questions.  So with that, I'll
           introduce Mr. Schaperow?
                       MR. SCHAPEROW:  That's correct.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. SCHAPEROW:  Thank you for pronouncing
           it like that.  My name is Jason Schaperow.  I'm
           Project Manager for some of the agencies who do
           accident research.  My presentation today will cover
           a research effort in the area of fission product
                       The objective of this research was to
           assess the applicability of the revised fission
           product source term to high burnup and MOX fuels.  The
           approach we took involved holding a series of Expert
           Panel meetings.  Panel membership included experts who
           had developed the basis for the original revised
           source term a number of years ago.  At these meetings,
           the experts suggested source term values for high
           burnup and MOX fuel, identified source term issues and
           recommended needed source term research.
                       The next couple of slides provides the
           background for this research.  First, I would like to
           briefly review the revised source term.  Now, the
           source term is defined as the fission product release
           into the containment atmosphere which is available for
           release to the environment.  Now, RES published the
           revised source term, also known as the alternative
           source term, and adopted it and called NUREG-1465 back
           in 1995.
                       This revised source term is more realistic
           than an earlier source term called the TID-14844
           source term.  The revised source term is aerosol
           except for about five percent of the iodine which is
           vapor.  Now, the TID source term was mainly vapor. 
           Also, the revised source term has a four-phase
           release, which is broken down as follows:  Gap, early
           in-vessel and ex-vessel release, which is during core
           concrete interactions, and finally the late in-vessel
           release from the reactor coolant system.  This takes
           place over several hours.  The TID source term,
           however, is instantaneous at the start of the
                       Also, the revised source term is actually
           two source terms:  One for a PWR and one for BWR. 
           There's not a lot of difference, but there are a few. 
           The main difference, I believe, is the release timing
           for the iodine.  In the BWR, the iodine release occurs
           a little later as a result of the BWR's lower power
                       The revised source term is used in a
           number of regulatory applications.  In particular, the
           first two release phases, basically up to the point of
           lower head failure, is used for LOCA design basis
           accident analysis.  And I've listed here five ways in
           which we've used this.  It's used to assess doses for
           the Exclusion Area Boundary, the Low Population Zone
           and in the control room.  It's used for the
           containment isolation valve closure time requirements,
           and in this particular use is just used as a start
           time on the gap release.  It's been used in a fashion
           as an integrated dose of the source term.  It's been
           used to qualify equipment in the containment.  It's
           been used for post-accident shielding, sampling and
           access.  And, finally, it's been used to evaluate the
           hydrogen generated by radiolytic decomposition of
           water during an accident.  And all four phases of the
           source term may be used for severe accident risk
                       The effect of the revised source term on
           licensing, as well as the risk impacts, were evaluated
           in our rebaseline project a few years back.  After the
           rebaselining project, the staff, NRR in particular,
           developed a rule to allow licensees to implement the
           revised source term.  Now, their baselining analyses
           identified that there would be a number of safety and
           cost benefits that would result from implementing the
           revised source term.  And as you can see here, a lot
           of licensees have opted to voluntarily implement the
           revised source term.  So far NRR has issued license
           amendments for ten plants and seven more plants in
           process right now for getting their license amendment.
                       VICE CHAIRMAN BONACA:  Most of -- I mean
           all of these applications have to do with the first
           two phases, right?
                       MR. SCHAPEROW:  That's correct.  They have
           to do with the first two phases.
                       VICE CHAIRMAN BONACA:  The first two
           phases.  Okay.  So just gap release and in-vessel.
                       MR. SCHAPEROW:  And early in-vessel.
                       VICE CHAIRMAN BONACA:  Early in-vessel. 
                       MR. SCHAPEROW:  That's correct.  The
           approach we took to assess the applicability of the
           revised source term for high burnup and MOX fuels
           involved holding a series of Expert Panel meetings. 
           These meetings were held over the last six months, and
           in these meetings, the Panel members were requested to
           judge the applicability of each aspect of the revised
           source term.  If the Panel members judged a particular
           aspect to not be applicable, then we would request of
           them to propose an alternative.  As part of this
           effort, Panel members considered recent data from
           international tests.  They discussed physical
           phenomena extensively that affect the source term and
           for high burnup and MOX fuels.  And also they did
           quite a bit of work in the area of identifying and
           prioritizing source term research.
                       MR. WALLIS:  Was this a PIRT sort of
                       MR. SCHAPEROW:  We didn't go through the
           PIRT process.  We identified phenomena and ranked
           them.  It was an expert elicitation, but we did --
           there were extensive discussions of physical phenomena
           that would affect the source term for high burnup and
                       This slides lists the Panel members and
           the other main players in this research.  And as the
           Chairman mentioned, two of the ACRS members were
           involved in this work.
                       MR. WALLIS:  Kress is one of those
           international consultants?
                       MR. LEITCH:  Yes.  He's from the country
           of Tennessee.
                       MR. KRESS:  I'm not supposed to say
           anything.  I've got a conflict of interest.
                       MR. SCHAPEROW:  For the experts to assess
           the applicability of the revised source term for high
           burnup fuel, it was necessary to specify certain
           parameters, such as how high of a burnup we are
           talking about.  This is the decision we made.  We
           decided to go ahead with a Panel assessment based on
           a maximum assembly burnup of 75 gigawatt days per ton. 
           Currently, the maximum assembly burnup is on the order
           of about 60 gigawatt days per ton.  We also decided to
           go ahead with the assessment based on a core average
           burnup of about 50 gigawatt days per ton.  For PWR,
           the assessment was based on cladding made of Zirlo,
           and for BWR, Zircaloy cladding.
                       And, finally, the assessment of fission
           product release fractions, which is part of the
           overall source term assessment, was based on a low
           pressure scenario.  Now, this minimizes RCS retention
           and is the same approach that we took in developing
           the original revised source term.
                       MR. SHACK:  Explain to me the low pressure
                       MR. SCHAPEROW:  In a low pressure
           scenario, such as, let's say, a two-inch break,
           because the pressure is low, and in these scenarios is
           a fairly direct release path to the environment. 
           There's no recirculation in the system to allow
           deposition.  For example, in a station blackout
           scenario, the system sits there for a while with water
           low in the vessel.  And so the steam recirculates and
           fission products deposit throughout the system but in
           a low pressure scenario as a whole, and it just comes
           out -- goes out of the --
                       MR. ROSEN:  Low pressure refers to low
           pressure in the containment.
                       MR. SCHAPEROW:  No, low pressure in the
                       MR. SHACK:  So any LOCA would be a low
           pressure scenario.
                       MR. SCHAPEROW:  That's correct.  Any LOCA
           of a size --
                       MR. SHACK:  A big one.
                       MR. SCHAPEROW:  -- to open up a hole so
           that the fission products could flow right out without
           having to circulate through the system.  A PORV type
           of LOCA, where the PORV opens and closes, that would
           basically keep the reactor's coolant system in tact,
           and the steam would circulate the fission products and
           it would deposit.  So that would maximize deposition. 
           And the types of deposition we're talking about for a
           low pressure scenario is about 50 percent of the
           fission products released from the core and deposited
           in the reactor coolant system.  In a high pressure
           scenario, it could be a lot higher.
                       MR. SHACK:  For those first two stages,
           you really do retain 50 percent of the stuff.
                       MR. SCHAPEROW:  That's what we believe. 
           That's what the experts believe, excuse me.  I was not
           on the Panel.
                       MR. WALLIS:  Even a large-break LOCA you
           deposit 50 percent of the stuff?  It gets out of the
           core and deposits somewhere else in the --
                       MR. SCHAPEROW:  I believe so.
                       MR. WALLIS:  Where does it go?
                       MR. SCHAPEROW:  Well, there are structures
           in the reactor, there's pipe -- mainly reactor
                       VICE CHAIRMAN BONACA:  I think much is in
           aerosols too, right, inside in some other structures?
                       MR. WALLIS:  I think maybe 50 percent is
           an expert guess between zero and 100.
                       MR. SCHAPEROW:  Well, a lot of those
           calculations were actually done quite a number of
           years ago with a search and code package by Jim
           Gieseke who's one of our Panel members.  We had, I
           think, about 30 cases that were run for five different
           plant designs to look at deposition.  We really didn't
           tackle that subject much in these Expert Panel
           meetings.  We really did focus in on the fuel.  That's
           what we're really changing here.  In one case, we're
           letting the burnup go a lot higher; in the other case,
           we're changing to a mixed oxide fuel.
                       VICE CHAIRMAN BONACA:  But TMI also was a
           good data point, right?  And it was a high pressure
           scenario.  I mean it was a small break, TMI?
                       MR. TINKLER:  TMI was characteristic of
           those sequences where you would get more deposition --
                       MR. LEITCH:  Charlie, identify yourself.
                       VICE CHAIRMAN BONACA:  And I'm saying the
           deposition inside was --
                       MR. TINKLER:  Was quite high.
                       VICE CHAIRMAN BONACA:  -- quite high.  It
           was higher than 50 percent.
                       MR. TINKLER:  Jason, if I might, I might
           point out that --
                       MR. LEITCH:  Charlie, please identify
                       MR. TINKLER:  Charles Tinkler from RES
           staff.  There is some variability within large LOCAs. 
           The very largest LOCA, if it were a double-ended hot
           leak break, for example, where it was a direct path
           out of the vessel, you would get retentions of less
           than 50 percent.  But when this Panel considered large
           LOCAs, all large LOCAs aren't double-ended hot leak
           breaks.  Cold leak breaks where the path is through
           the steam generator or back up through the down-comer,
           you get larger amounts of deposition.  And not all
           large LOCAs are double-end guillotine breaks.  So I
           think it's true to say that the Panel considered LOCAs
           as a general group and thought that the 50 percent was
           reasonably --
                       MR. WALLIS:  But if you had a hole in the
           vessel head, I think most of it would come out.
                       MR. TINKLER:  Which would be pretty close
           to a double-ended hot leak nozzle rupture too, and
           there wouldn't be a great deal.  You might see
           retentions in those cases of maybe ten, 20, maybe 25
           percent, but, like I said, they're --
                       MR. KRESS:  You have to keep in mind that
           these are source terms to be used primarily with
           design basis accidents.  They're not to be used for
           PRA for the whole sequence of accidents.  And so you
           ask yourself what should be in design basis space. 
           Then you go from there to --
                       VICE CHAIRMAN BONACA:  No, 1465 actually
           allows you to assess variations depending on the
           scenarios you're addressing, right?  I mean I read it
           recently and it says that the licensees can propose --
                       MR. KRESS:  If they want to justify some
           different source term --
                       VICE CHAIRMAN BONACA:  Exactly.
                       MR. KRESS:  -- they can --
                       VICE CHAIRMAN BONACA:  They can do that. 
           So there is a condition that the scenarios for the low
           pressure used here is not all bounding, it just simply
           is the most likely scenario you're looking at and
           you're using it.
                       MR. SCHAPEROW:  The low pressure scenarios
           were found to be just as -- about as likely as the
           high pressure scenarios.
                       VICE CHAIRMAN BONACA:  Yes.
                       MR. SCHAPEROW:  So in NUREG 1465, they
           said, "Well, geez, in that case we're going to go with
           the retention of the low pressure scenario, because
           it's conservative."
                       VICE CHAIRMAN BONACA:  It's conservative,
           that's right.
                       MR. SCHAPEROW:  They tilt it towards
                       VICE CHAIRMAN BONACA:  But it doesn't
           preclude the use of less conservative approach if you
           can justify it.
                       MR. SCHAPEROW:  That's correct.  Actually,
           I think the regulation in the Regulatory Guide speaks
           directly to that.
                       VICE CHAIRMAN BONACA:  Exactly that, yes.
                       MR. SCHAPEROW:  Okay.  This table, taken
           directly from the Panel's draft report, shows the
           Panel members' recommendations for a PWR.  The first
           row shows the recommendations for the durations of
           each release phase.  For example, the Panel
           recommended a gap release phase duration of 0.4 hours
           while the revised source term duration, in parentheses
           next to it, is 0.5 hours.  The Panel's release phase
           duration recommendations are about the same, or
           exactly the same in some cases, as the revised source
                       In the cases where not all the experts
           recommended the same value, the value recommended by
           each expert was recorded.  For example, in the second
           row, the noble gas row, for the gap release you'll see
           that there were four values listed there that are
           ranging from 0.05 to 0.07.  For the so-called volatile
           groups, the noble gases, the halogens and the alkali
           metals, the release fractions are about the same as
           the revised source term.
                       MR. SHACK:  Just out or curiosity, were
           these differences from 1465 due strictly to the high
           burnup fuel or were they revising 1465 on the fly too?
                       MR. SCHAPEROW:  They thought about both
           things, because we have recent test data.  We've got
           the French have run a fission product tests and the
           Japanese have run a couple of fission product tests in
           the last few weeks.  And I'll go into that a little
           bit.  In the next slide, I go into a little more
           detail what I thought were some of the main points
           that the Panel raised.
                       VICE CHAIRMAN BONACA:  In fact, it's an
           important point.  This is an important point you're
           making, Bill.  Probably that's the best -- biggest
           lesson learned from the report is that 1465 may have
           to be looked at.
                       MR. SHACK:  See, I didn't have a chance to
           read any of it, because --
                       VICE CHAIRMAN BONACA:  Yes.
                       MR. SHACK:  -- I've been off --
                       VICE CHAIRMAN BONACA:  And I'm saying that
           it's interesting that it went from eight groups in
           1465 to 14 groups here.
                       MR. SCHAPEROW:  Well, the experts believe
           that we learned something.  I think there was general
           agreement that we could go ahead and break it further
           down, because there is -- even into these groups,
           these heavier groups, there is a range of -- I'm
           sorry, originally we had noble metals group, but the
           experts felt that the Molybdenum and Technetium
           releases were a bit higher, and they felt that it
           would be worthwhile this time to go ahead and break it
                       MR. WALLIS:  It's interesting, when they
           don't know, they like numbers like one percent or one
                       I mean the number one or two appears an
           awful lot.
                       MR. SCHAPEROW:  Yes.  Well, there is a lot
           of uncertainty associated with the last three groups. 
           The last three groups are the ones which are generally
           released in the smallest amounts.  We haven't focused
           on them in the past, and they generally -- I don't
           think that they generally have a huge influence on
           dose, but --
                       MR. WALLIS:  There's no expert who has
           some data and calculation and can say it's 0.00957 or
           something like that?
                       MR. SHACK:  I'm sure his computer will say
                       MR. SCHAPEROW:  Actually, in the original
           revised source term, there was a question as to
           whether we should specify more than one figure.  And
           we did actually go to two significant figures.  For
           example, the halogen release was 0.35, and they said
           -- it was one of these a five but not a one or a two. 
           It was a 0.35 but not 0.33.
                       Now, this slide provides an overview of
           the results of the Panel assessment for high burnup
           fuel.  Now, the Panel members generally expected the
           physical and chemical forms to be applicable.  Only
           small changes in the release-phase duration and the
           release fraction were expected as a result of going to
           the burnups we talked about.
                       However, the Panel did identify some
           issues that were based on recent tests that were
           independent of burnup.  The first issue was the
           potential for enhanced Tellurium release, and I'll
           talk about that in my next slide a little more.  As I
           just mentioned, there's also a continued uncertainty
           in the releases of the heavier elements, the noble
           metals, the Cerium and Lanthanum groups.  Also, recent
           data does suggest it may be worthwhile to subdivide
           those three groups into additional groups.
                       Now, related issues, which the Panel
           members discussed, which I'd like to talk about
           briefly, were, as you heard about at this point, BWR
           power uprates and BWR fuel design.
                       VICE CHAIRMAN BONACA:  One point I would
           like to make here is just simply this is very clear
           for them to have -- there are lessons learned for 1465
           here, burnup-independent issues.  The report doesn't
           really speak so clearly about that, and I think you
           want, at some point, to -- the report should say
           something about 1465 because there are these changes
           here and they're burnup independent.  So it's left a
           little bit with the open question when I was reading,
           so what was going to happen to 1465?  Is there some
           lessons learned that is going to be communicated
           within this report?
                       MR. SHACK:  Fourteen sixty-five Rev 1.
                       VICE CHAIRMAN BONACA:  Yes.
                       MR. SCHAPEROW:  That's a reasonable idea,
           I think.
                       VICE CHAIRMAN BONACA:  The report doesn't
           say, doesn't put it this clearly.
                       MR. SCHAPEROW:  The report is just the
           results of the expert elicitation.
                       VICE CHAIRMAN BONACA:  Understand.
                       MR. SCHAPEROW:  Exactly.  And then the
           research at NRR, I will -- when this is finished we
           will -- we do have a number of comments in.  We're
           revising the report now.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. SCHAPEROW:  But that is a good point. 
           Now I'll talk a little bit about the Tellurium issue. 
           With regard to the Tellurium, the revised source term
           specifies an early in-vessel release of Tellurium of
           five percent.  This is supported by Oak Ridge tests
           performed a number of years ago indicating that
           Tellurium gets sequestered in the tin, and the
           Zircaloy cladding is not released until a high
           fraction of the cladding is oxidized.  And by high
           fraction, we're talking numbers about 90, 95 percent
           cladding oxidation.
                       MR. WALLIS:  What do you mean by "gets
                       MR. SCHAPEROW:  It's get bound up, bound
           up with the tin.
                       MR. WALLIS:  It gets bound up during the
           accident or --
                       MR. KRESS:  Tin Telluride tries to escape
           its way through the cladding.
                       MR. WALLIS:  As it tries to escape it gets
                       MR. KRESS:  Yes.
                       MR. WALLIS:  Things aren't happening too
           quickly for that?
                       MR. KRESS:  This, of course, is a
           speculation because the Tellurium was found associated
           with the tin in the clad in tests at Oak Ridge, and
           they didn't get a lot of release of the Tellurium
           which was a surprise because Tellurium is very
           volatile.  So it's a speculation because it was found
           associated where the tin was, but there was never any
           determination that it was Tin Telluride.
                       MR. WALLIS:  You'd think if things are
           happening quickly, it would just escape, it wouldn't
           have enough time to get caught up with the tin.
                       MR. KRESS:  Well, the reaction could go
           pretty fast, but these things aren't as fast as you
           might think, these transients.
                       VICE CHAIRMAN BONACA:  Yes.
                       MR. WALLIS:  It's a diffusion process.
                       MR. SHACK:  Now, would the tendency in
           modern clads to go lower tin change this at all or are
           is there still so much tin?
                       MR. SCHAPEROW:  That's one point the Panel
           raised.  They said, "Well, we think we need -- we'll
           probably need some more research.  We may need to run
           some tests with -- some source term tests with
           cladding that doesn't have tin in it."  This is the M5
           cladding if I'm not mistaken.
                       MR. SHACK:  Well, even modern Zircaloy the
           tin goes with that.
                       MR. SCHAPEROW:  There are some more recent
           tests that have been conducted in France that indicate
           that the Celerium release could be larger, could be
           somewhere to that iodine, on the order of about 30
           percent.  And so this was a contentious issue among
           Panel members.  We spent quite a bit of time
           discussing this to see if we could get any sort of --
           if any of the Panel members might agree on this, and
           the answer was no.
                       MR. ROSEN:  You've got two of your own
           Panel members to get agreement.
                       MR. SCHAPEROW:  Well, this was not a
           consensus process, but we did want them to discuss it
           amongst themselves to try to flesh out the issues.
                       MR. SHACK:  Well, except for early in-
           vessel, there was one rugged holdout.  Everybody
           seemed to line up.
                       VICE CHAIRMAN BONACA:  I think even more
           striking is the fact that over the four phases you're
           showing a release of 95 percent, practically all
           Tellurium being released, while in the original, in
           1465, it's only about 25 percent.  So that's another
           big issue that says what's -- because some of the
           processes by which you see the differences, like for
           example, late in-vessel has to do with oxygen entry,
           but that's true also for low-enriched fuel.  I mean
           you have -- in the phase of the accident, you have
           integration and you have oxygen coming in.  So there
           is a big discrepancy there which is even larger than
           the five percent to 30 percent.  It's really 25
           percent to 100 percent that has to be reconciled.
                       MR. SCHAPEROW:  This issue was raised when
           we originally developed the revised source term.  If
           you look back at the old document, we had a draft of
           NUREG-1465 ion 1992, and three years later we had a
           final, and the Celerium release went down.  I think,
           if I recall, it was 15 percent in the draft, and it
           went down to five percent in the final.  So this issue
           has been hanging around for a little while, but it's
           been brought to the forefront, as I said, by some of
           these more recent tests that were conducted in France.
                       MR. WALLIS:  What's the effect of higher
           burnup?  Is it that the fuel is more porous or
                       MR. SCHAPEROW:  Break sizes go down,
           fission products inside the pellets.
                       MR. WALLIS:  So you'd expect more release,
                       MR. SCHAPEROW:  Earlier, earlier.  For the
           volatiles, earlier.  For the volatiles, things get out
           anyway in either case, so we expect to kind of shift
           things.  The gap release phase, which ends when the
           pellets start releasing fission products, so the gap
           release ends a little earlier for the high burnup
                       I don't think I quite finished this slide. 
           I wanted to mention for the BWRs the Panel members
           pretty much stuck with Tellurium release in the
           revised source term.  They felt that the Zircaloy fuel
           channels would tend to limit cladding oxidation.  Now,
           this wasn't a fuel that had Zircaloy cladding, so
           there was tin, and you also had the Zircaloy fuel
           channels to limit the oxidation, because the release
           doesn't occur until the oxidation gets pretty high.
                       There are two other source term issues
           related to high burnup that I would like to mention. 
           One is power uprates for BWRs.  We had one -- one of
           our experts said he didn't think we should change
           anything, he thinks it's okay the way it is, no basis
           for significant effect.  However, at least one other
           expert said they thought things would be changed, they
           thought that that flux-profile flattening associated
           with the power uprates could increase the releases for
           the outer assemblies.
                       The second issue I'd like to mention
           involves BWR.  Our NUREG-1465 specifies actually two
           different source terms:  One for BWR and one for PWR. 
           However, the Panel members noted that the
           characteristics of the more recent BWR fuel rod
           designs are closer to the PWR fuel rod
           characteristics.  The BWR rods have smaller pellet
           diameters and thinner clads.  So the Panel felt that
           similar rod designs would tend to result in similar
           source terms and tending to maybe not be such a big
           difference between a BWR and a PWR source term.
                       The Panel also assessed the applicability
           of the revised source term for MOX fuel.  This slides
           gives the condition that we used for our expert
           elicitation.  We assumed that we're using MOX in a
           PWR, which is consistent with what has been proposed
           by Duke, Cogema, Stone & Webster, and that the MOX is
           distributed fairly uniformly throughout the core. 
           That's what I mean by about half of the core.  It's
           not just all bunched up around the outside or bunched
           up in the middle.
                       The typical MOX assembly burnup, and this
           is meant to represent sort of a maximum, this 42
           gigawatt days per ton, the assessment was based on M5
           cladding and, again, a low pressure scenario for
           assessing RCS retention.
                       MR. SHACK:  Now that's a much higher level
           of MOX than DOE's proposing to use.
                       MR. SCHAPEROW:  That's correct.  They're
           proposing I think it was a maximum of 40.  The point
           here was just to say that it's basically throughout
           the core, and it's going to experience the same
           temperatures that the rest of the core would.  It sees
           the same thermal accident, the same heat-up as all the
           other assemblies.
                       VICE CHAIRMAN BONACA:  For that
           information on MOX, I mean a lot of the elicitation
           ended up with N/As because there is not sufficient
           information to make -- oh, you have that.  Okay.
                       MR. SCHAPEROW:  Next slide.  This slide
           provides an overview of the results of the Panel
           assessment for MOX.  Again, physical/chemical forms
           were not expected to be an issue.  The release-phase
           duration and the more volatile releases -- noble
           gases, iodine, Cesium -- were expected to be about the
           same.  Same Tellurium issue as for high burnup fuel. 
           Some experts felt that we would have a higher
           Tellurium release.
                       One difference, as Mario just pointed out,
           from the assessment for high burnup fuel is that in
           this case, for MOX, some of the experts did not
           recognize release fractions for some of the groups. 
           In particular, the Barium group on down to the
           Lanthanum group.  And we don't have data, that's the
           problem.  Right now the only data that at least the
           Panel had available was a test result for Cesium, and
           the French chose not to show a scale on the y-axis. 
           They wanted to -- they're not ready to give us that
           information yet, I guess, for whatever reason.
                       VICE CHAIRMAN BONACA:  They don't know.
                       MR. KRESS:  The y-axis was the fission
           product release fraction.
                       MR. SCHAPEROW:  I'm sorry.  Thanks, Tom. 
           I just blocked out data.  We generally assumed that
           the top of the axis was a one, because it was Cesium,
           and we have some idea that Cesium is pretty -- would
           come out under those conditions.
                       The Panel also considered what source term
           research is needed to complete the Panel
           recommendations, particularly in MOX, and to confirm
           the other Panel recommendations, the high burnup and
           MOX source terms.  In this slide, I've tried to list
           -- I've listed the Panel members' recommendations for
           the highest priority research.
                       MR. WALLIS:  Isn't the most important
           thing to get some data?  Isn't that the most important
           thing when you have almost no facts to go on?  It's
           all expert judgment.
                       MR. SCHAPEROW:  I think that's -- four of
           the five research items here are data.  The top one is
           that we have a little bit of recent data which we're
           validating against right now, the PHEBUS experiments
           in particular.  We've got some calculations with our
           severe accident codes.  The other four are data.
                       One issue is the air ingress issue, which
           needs to be addressed at some point.
                       VICE CHAIRMAN BONACA:  The French are
           doing a lot of work on fuel.  I understand we are not
           participating in some of them.
                       MR. SCHAPEROW:  In the severe accident
           source term area, they have two programs ongoing:  the
           PHEBUS program, which we are participating in and we
           do have some data from.  The other one is the VERCORS
                       VICE CHAIRMAN BONACA:  That's right.
                       MR. SCHAPEROW:  -- source term tests,
           which are based on the Oak Ridge source term tests. 
           I understand that they had requested some of our
           experts to come over and help them get started, and
           those are the ones that we haven't gotten the data
           from.  We've asked for it and we're working with them,
           but --
                       VICE CHAIRMAN BONACA:  We will get the
           data from them.
                       MR. SCHAPEROW:  Pardon?
                       VICE CHAIRMAN BONACA:  We will get the
                       MR. WALLIS:  Do they have several results
           of VERCORS or is it so complicated that they just run
           a couple of tests and that's it?
                       MR. SCHAPEROW:  Oh, VERCORS is a small-
           scale test on the order of a few pellets.
                       MR. WALLIS:  They do a lot of tests,
           different issues?
                       MR. SCHAPEROW:  A few of them, maybe three
           a year.
                       MR. WALLIS:  Three a year.
                       MR. SCHAPEROW:  Basically, a take off from
           what we had done at Oak Ridge.
                       MR. WALLIS:  How do they get high burnup
                       MR. SCHAPEROW:  I assume they either get
           it from a test reactor or maybe a lead test assembly. 
           I'm not sure.
                       MR. KRESS:  Some of its BR3 fuel, which is
           -- some of it was high burnup.  They've tested up to
           65 gigawatt days per metric ton.  So they weren't
           going to get it out of old reactors.
                       MR. WALLIS:  Well, I think it would be
           great if you could go beyond this and sort of lay out
           what needs to be learned and what needs to be done to
           learn it in a more specific, detailed way.  I mean is
           a few tests going to do the job or not, and do you
           need ten times as many tests over a bigger range or
           whatever?  Would someone lay out what are the
           requirements for knowledge here and what needs to be
           done to get it?
                       MR. SCHAPEROW:  Well, we are thinking
           about that, and it's going to depend on what burnup
           levels people want to go to, for one thing.  So it's
           going to be application-dependent in the end.  We
           thought about having some sort of a larger plan, but
           in the end it's --
                       MR. WALLIS:  Isn't the time for thinking
           about it over and the time to do something here?
                       MR. KRESS:  These are kind of expensive
                       MR. WALLIS:  Yes.  But we're going to be
           having high burnup fuel and MOX fuel and decisions
           have to be made about it, so we need to know.
                       MR. KRESS:  But I think the idea was to
           leverage as much you can with these tests that have
           already been run and are continuing to be run.
                       MR. WALLIS:  Otherwise you will be letting
           people do things and establishing criteria afterwards.
                       MR. KRESS:  Well, we pretty much know what
           needs to be done.
                       MR. POWERS:  Tom, I don't know why you're
           so concerned.  I understand that high burnup fuel is
           irrelevant to regulatory decisions.
                       MR. KRESS:  That's the next presentation
           after lunch.  That doesn't have anything to do with
           this presentation.
                       MR. WALLIS:  It's high priority research
           but it's unnecessary, is that it?  It's irrelevant.
                       MR. SIEBER:  Irrelevant.
                       MR. KRESS:  That's the next presentation.
                       MR. SCHAPEROW:  Finally, a brief status. 
           We got comments from the Panel members on the draft
           Panel report, and we've got a bit of work to do to
           revise it and get the thing into final form.  We do
           plan to issue a final report by June.  And as we just
           discussed, our feeling is that the results of the
           assessment will be used to help address reactor safety
           issues as they arise for most applications for high
           burnup MOX fuel, which we anticipate will be used for
           severance and risk assessment and other applications,
           such as the ongoing vulnerability assessment.  That
           concludes my presentation.
                       MR. SIEBER:  It seems to me that when you
           try to redefine the source term for existing plants,
           whether it's high burnup or MOX fuel, that the TID-
           14844 source term was so severe that it would envelope
           anything you would come up with since, right?
                       MR. SCHAPEROW:  Well, actually, not every
           aspect.  Now, the chemical form, the physical/chemical
           form, the vapor does tend to envelope things.  The
           timing not necessarily.  The timing -- having
           instantaneous release can cause you to do a lot of
           things you really shouldn't be doing.
                       MR. SIEBER:  Yes.
                       MR. SCHAPEROW:  And also on the release
           magnitudes, that was more of a judgment call, the 50
           percent iodine release.
                       MR. KRESS:  Actually, the TID-14844
           reduced that to 25 percent.
                       MR. SCHAPEROW:  That's correct.
                       MR. KRESS:  So these are actually a little
           more severe going into containment.
                       MR. SCHAPEROW:  These are 30 and 40
           percent for B and a P.
                       MR. KRESS:  But also there's little
           consideration of gap release in TID-14844 either.
                       MR. SIEBER:  Would this have some generic
           impact on the things like controlling dose?
                       MR. KRESS:  Yes.  In general, the new
           source terms are a little less severe in terms of
           things you have to do in dose in the TID-14844.  So
           you're right.
                       MR. SIEBER:  Okay.
                       VICE CHAIRMAN BONACA:  I think for the
           purpose of the report, which is the one addressing
           burnup, I think it's very complete.  Again, my only
           suggestion would be although you don't want to address
           1465 but to state very clearly that what you wrote in
           that Slide Number 10, that a number of those lessons
           learned are not independent, because that message then
           will be taken once the report is issued, and it will
           have to be evaluated, I think, to see if changes to
           1465 should be implemented.
                       MR. KRESS:  Yes.  I think the Tellurium in
           particular is significant, because it has -- there's
           a lot of it in there, and it has high biological
                       VICE CHAIRMAN BONACA:  And it goes to
                       MR. KRESS:  Yes, it goes to iodine.  And
           it may go to it in a way that makes it vapor instead
                       VICE CHAIRMAN BONACA:  Okay.  Any
           additional questions for Mr. Schaperow?  You're not
           expecting a report from the CRS at this stage.
                       MR. SCHAPEROW:  No.  This is only for the
           Committee's information.
                       VICE CHAIRMAN BONACA:  Okay.
                       MR. SCHAPEROW:  Only for your information. 
           We'll let you know of some of the fine research people
           we have going on in the Research Office.
                       VICE CHAIRMAN BONACA:  All right.  If
           there are no additional questions, then thank you very
           much for the presentation, and the meeting is
           recessed.  We'll reconvene at ten minutes of one.
                       (Whereupon, the foregoing matter went off
                       the record at 11:50 a.m. and went back on
                       the record at 12:50 p.m.)
                                A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                     12:50 p.m.
                       VICE CHAIRMAN BONACA:  Back to order. 
           This is going to be a presentation on high burnup fuel
           research and regulatory issues.  Dr. Kress?
                       MR. KRESS:  Thank you.  I don't have a lot
           of introductory remarks.  The Committee might recall
           that there was an exchange of letters to the places
           that high burnup fuel research.  Probably not needed
           and we wrote a letter asking for some clarification
           for that position, and I think this is a briefing to
           tell us what's been going on in that area and to fill
           us in.  And I guess with that, I'll turn it over to
           one of the two Ralph's.
                       MR. CARUSO:  This is Ralph Caruso.  I'm
           going to start the briefing this afternoon, and Dr.
           Meyer is going to finish it.  I'd like to open my
           presentation by, first of all, acknowledging that the
           letter that we sent -- it was sent from Sam Collins to
           Donnie back in January of this year.  It included some
           wording that we do consider to be unfortunate.  The
           use of the word, "irrelevant," was probably not
           advisable.  The Office of Nuclear Reactor Regulation
           does consider that the work that's done by research is
           valuable, and we do support it.
                       Notwithstanding that observation, there
           are different types of research that are done in the
           Office of Research.  There is research that is
           requested by the various offices, there is
           confirmatory research, there is anticipatory research,
           and we're here today to talk to you about one aspect
           of the high burnup fuel research program.  Actually,
           I'm going to give you a little bit of an overview,
           some background on high burnup fuel.  Dr. Meyer is
           going to talk to you about the program itself.  I'm
           going to give you a little bit of history, and I'm
           going to talk about the 280 calorie per gram limit and
           where we stand on that particular aspect of that in
           regulatory space.
                       MR. POWERS:  How about the 180 calorie
           gram per limit?
                       MR. CARUSO:  I get into that as part of
           this -- 170.
                       MR. POWERS:  Hundred and seventy.
                       MR. CARUSO:  I'd like to start with the
           first slide, which is background about -- an NRC user
           need request was sent to the Office of Research in
           1993.  At this time, the Agency was receiving a number
           of requests from the vendors to increase burnup
           limits, to go from numbers that were in the 30s and
           the 40s at that time, up to about 60 or 62.  And NRR
           at that time decided to send a user need request to
           Research to update a number of different regulatory
                       One of them was the NRC fuel performance
           models.  These are included in various computer codes
           that are used by the Agency to perform independent
           calculations of fuel behavior.  In addition, there was
           a request to revise some models for stored energy
           during LOCAS and evaluate the impact of these models
           on LOCA analyses.
                       We also requested research to reevaluate
           some of the fuel failure thresholds that are used for
           normal operations and RIAs.  This is the 280 calorie
           per gram limit and the associated 170 calorie per gram
           limit that I'm going to talk about later on.
                       Nineteen ninety-six, after a bit of work
           had been done by the Office of Research, a Commission
           memorandum was sent that talked about some low
           enthalpy fuel failures that occurred in some research
           reactors.  And it talked about a new complete rod
           insertion issue that was becoming evident in a number
           of operating plants.
                       In 1997, we sent another Commission
           memorandum talking more about the regulatory
           guidelines and licensing criteria for high burnup
           fuel, talking about high enrichment, because at that
           time there was some evidence that some licensees and
           vendors might want to go to high enrichment.  And we
           were also talking about spent fuel issues, because the
           higher burnup fuel is causing some difficulties with
           storage and transportation.
                       In 1997, Research issued a research
           information letter.  This RIL, as it's called,
           proposed some changes to the RAA criteria that were
           used -- that were, and still are, contained in Reg
           Guide 1.77 and in the Standard Review Plan, Section
           4.2.  The RIL discussed the history of some tests at
           some test facilities -- CABRI and NSRR.  And discussed
           how the criteria could be changed in order to
           accommodate this data.
                       Eventually, the Agency put together a
           program plan in 1998 that included these revised
           interim proposed limits, and laid out a larger program
           for the Office of Research to perform confirmatory
           research to verify and validate a number of fuel
           performance models, computer codes and fuel
           performance data.  It also looked at transportation,
           dry storage, source term, whole bunch of issues.
                       This program plan made it clear that the
           body of the plan that the NRC Research would be done
           to confirm material properties and fuel behavior for
           burnups up to 62 gigawatt days per metric ton.  The
           body of the report -- the body of the memorandum
           stressed that it would be the industry responsibility
           to develop the criteria -- I'm sorry, excuse me.  For
           the criteria that they don't -- and the models for
           burnup higher than 63 --
                       MR. WALLIS:  Excuse me, Ralph.  What was
           actually the burnup which was being achieved in
           reactors at that time?
                       MR. CARUSO:  Let's see, in 1998, we had
           already licensed at that point most of the fuel to 62.
                       MR. WALLIS:  And then you were doing
           confirmatory research to check that --
                       MR. CARUSO:  Yes.
                       MR. WALLIS:  -- you'd done the right
                       MR. CARUSO:  That was the intent of the
           Agency high burnup plan at that time, to do
           confirmatory research to verify that.  The decisions
           that have been made were valid.  The attachment to
           this Agency burnup plan also included some statements
           about how research might cooperate with the industry
           in doing the testing and gathering some data for
           burnups above 62.
                       MR. WALLIS:  Just remind me, when you say
           gigawatt days per metric ton or uranium?  That means
           all of the uranium?
                       MR. CARUSO:  Okay.  This is the value
           that's used, and this is -- you have to be careful
           about how you use it.  This is a peak rod average
                       MR. WALLIS:  This is for all the uranium?
                       MR. CARUSO:  For the peak rod average
           burnup shall not exceed 62 gigawatt days per metric
           ton.  If you look at each rod and you look at the peak
           rod average, you take the burnup over the entire rod
           and you average it so that you have an average number
           for the rod.
                       MR. WALLIS:  Yes.
                       MR. CARUSO:  The peak rod in any core
           should not exceed 62 gigawatt days per metric ton.
                       MR. WALLIS:  That's Uranium 238 is mostly
           what --
                       MR. CARUSO:  Metric ton -- MTU, metric ton
           of heavy metal.
                       MR. WALLIS:  So when you change -- there's
           nothing here which says what's the effect of changing
           in Richmond or more plutonium or anything like that at
                       MR. CARUSO:  No, no, no.
                       MR. POWERS:  How was 62 selected.
                       MR. CARUSO:  Sixty-two -- you're going to
           ask me why.  This is getting back into history before
           my time, so I'd have to reconstruct it.  I don't
           honestly know, because I wasn't involved in the
           cutoff.  It's my understanding that the industry tried
           to push beyond 62, and the Agency said, "No.  This is
           as far as we're willing to extrapolate the data at
           this point."  And a conscious decision was made
           sometime in the '90s to stop at 62 until data was
                       The RAI regulatory criteria.  They come
           from GDC.  Their origins are in GDC 28, and I've
           quoted it here.  As you see, the criteria are pretty
           general GDC 28.  They're not allowed to have a
           reactivity increase that would result in damage to the
           reactor coolant boundary greater than limited local
           yielding or sufficiently disturb the core at
           supporting structures or other reactor coolant
           pressure vessel internals to impair significantly the
           capability to cool the core.  That's the mother
           document for determining RAI criteria.
                       MR. WALLIS:  What does limited local
           yielding mean?
                       MR. CARUSO:  That's the question of that
           ages.  That's difficult to determine.  So as a result,
           there are couple of surrogate acceptance criteria that
           are used.  We have a Standard Review Plan, Section
           4.2, that talks about coolable geometry.  I want to
           get this first.  It defines coolable geometry as,
           "Retaining a rod bundle geometry with adequate coolant
           channels to permit removal of decay heat."  That
           addresses the second part of GDC 28.
                       The first part of GDC 28 is addressed by
           limiting the fragmentation and dispersal of molten
           fuel from inside the cladding into the reactor coolant
           system.  And because it's very difficult to calculate
           the damage to the reactor coolant pressure boundary
           limited to local yielding, we use this surrogate of
           making sure that you do not have a violent core
           coolant interaction event.  And the way we do that,
           the way that it has been done in the past is by
           limiting the average radial enthalpy limit of 280
           calories per gram during an RIA.  The calculation is
           done by the vendors of a hypothetical RIA, and it's
           almost always a rod ejection accident.  And they
           verify that the average enthalpy does not exceed this
           280 calorie per gram limit.
                       And this 280 calorie per gram limit was
           based on some experiments that were done in the SPIRT
           facility back in the '60s, '70s, where they observed
           that if you got enthalpies up in the 300, 325, 350
           range, you got a very violent expulsion of molten fuel
           and you got a very strong pressure pulse, and it was
           thought that 280 calories per gram would provide
           enough margin so that we didn't have to worry about
                       MR. KRESS:  Those expert tests were done
           with what burnup?
                       MR. CARUSO:  They were done with pressure
           or low burnup.  We did a relatively low burnup fuel.
                       MR. WALLIS:  Doesn't this depend on the
           fuel design?  Haven't fuels changed since that time?
                       MR. CARUSO:  The fuels have changed, but
           they're still basically uranium oxide.  And the
           concern that really arose was molten fuel.  You're
           talking about does the uranium oxide melt, and do you
           have an interaction, a steam explosion of molten UO2
           and water?  So although the fuel designs have changed,
           the fundamental phenomenon really is the same.  You're
           trying to prevent a steam explosion, and the thinking
           is that if you prevent a steam explosion, therefore
           you won't have to calculate the pressure pulse, and
           therefore you won't have to calculate the building of
           the reactor coolant pressure boundary.
                       MR. KRESS:  And the 280 calories per gram
           was sufficient -- insufficient to raise the
           temperature to melt a certain fuel?
                       MR. CARUSO:  To melt it, right.  That's
           what was thought at the time.  Since then it appears
           that the melting enthalpy may be somewhere around 260? 
           So this number may not be demonstrably not
           conservative anymore.
                       MR. WALLIS:  There's nothing here about
                       MR. CARUSO:  That's correct.
                       MR. WALLIS:  And, presumably, with a lot
           of burnup the fuel is more likely to --
                       MR. CARUSO:  I'll get to that.  Well,
           we'll talk about that.
                       So with that as a background, we look at
           what came out of the CABRI and NSRR tests.  The CABRI
           and NSRR tests showed that fuel could fail at much
           lower energies than 280 calories per gram.  The SRP
           actually contains a secondary failure criteria of 170
           calories per gram.  The 170 calorie per gram number is
           used to determine when dose calculations need to be
           done.  There's a two-step regulatory process here. 
           The licensee is required to assure that the fuel will
           not melt and be released into the reactor coolant
           system.  That's what the 280 calorie per gram number
                       And then if they calculate that some of
           the fuel exceeds 170 calories per gram, they're
           required to calculate for those pins which exceed the
           170 calorie per gram limit what the dose would be, the
           release from the fuel of the fission products and then
           the release through the reactor coolant system and out
           through any holes in the reactor coolant system and
           out through the containment to members of the public. 
           And the standard for that is that that release should
           not exceed a small fraction of the 10 CFR Part 100
           limits.  That's what the 170 calorie per gram limit
           is.  It's a no-fuel failure limit, but it's not
           actually a limit, it's just a point at which you
           decide to do a dose calculation, not a limit per se.
                       Now, we had this experience at CABRI and
           NSRR where the fuel failed at low enthalpies.  There
           are problems with those tests, though.  The NSRR tests
           were done at room temperature, low pressure.  The
           CABRI tests were done in sodium.  You can make scaling
           arguments, but there were problems with the amount of
           corrosion on some of the rods.  In some of the tests,
           there were --
                       MR. POWERS:  Can you tell what you mean by
                       MR. CARUSO:  Well, some of the rods that
           failed had much higher levels of corrosion than we
           really expect to see inside an operating PWR.  There
           were some rods that had spalled fuel.
                       MR. POWERS:  But these rods came from
           operating reactors.
                       MR. CARUSO:  They might have come from
           operating reactors, but they also might have been
           preconditioned.  There were questions about them. 
           That's not really important at this point, okay,
           because we know they --
                       MR. POWERS:  But it's important enough to
           put on the viewgraph.
                       MR. CARUSO:  Well, I wanted to make it
           clear that there were atypicalities about these tests.
                       MR. POWERS:  I guess I'm struggling to
           understand what's atypical.
                       MR. CARUSO:  Well, had to do, for one
           thing, the corrosion, the fact that they were in --
           the tests were done in sodium or at low temperatures.
                       MR. WALLIS:  Well, the obvious question
           now is --
                       MR. ELTAWILA:  Dana, this is Farouk
           Eltawila from Research.  I think the issue, and Ralph
           can correct me, is that the oxidation and spoilation
           it might be typical of what you have in nuclear power
           plant, but during the conditioning of the specimen for
           the test, they oriented all the hydride in the same
           direction.  So with that small pulse, it will fail. 
           And this preconditioning does what's typical, which is
           not defeat itself.
                       MR. MEYER:  Could I clarify this?  The
           concern about preconditioning, and you can call it
           fabrication of the specimen from a fuel rod and
           preconditioning, the concern has only been expressed
           about one test rod, the one indicated up there from
           CABRI, Rep NA1.
                       MR. POWERS:  Well, let me express a
           concern about all the others.
                       MR. MEYER:  Okay.
                       MR. POWERS:  You have a fuel rod that
           you've selected in some way to extract a specimen
           from, and all these tests are done with not full fuel
           rods but some sections, so somebody has to cut it out. 
           When you send that to a lab operator and say, "Cut me
           out a section or a particular length," that section is
           not randomly selected; in fact, the operator operates
           considerably on his own to do that.  Would an operator
           in a hot cell facility with production quotas on him
           select a section of the rod that is as pristine as
           possible to enhance his chances of getting a
           successful cut?
                       MR. CARUSO:  Yes.  Of course that could be
           done, but that's not what is done.  In fact, what we
           have found is that for the PWR fuel that there's a
           fairly monotonic increase in the corrosion from the
           bottom to the top, and the grid span next to the top
           has, if not the highest level of corrosion, almost the
           highest level of corrosion, and it also has a uniform
           burnup over that span.  And we typically will select
           that span because it represents the worst condition in
           the rod.
                       We have in three cases tested an upper
           grid span and a mid grid span with considerably less
           corrosion and done comparative tests three different
           times, once in CABRI and twice in NSRR.  And in those
           three cases -- in all three cases, the rods from the
           upper grid span experienced cladding failure, and the
           ones from the lower grid span did not.  So this is a
           way that we can study the dependence of this on the
           oxide quantity.
                       MR. WALLIS:  Then the real question for me
           is you have some tests in SPIRT, you have some of
           these tests, some of which you seem to cast doubt upon
           from CABRI and NSRR.  What is the status of knowledge
           based on factual information from tests, the tests
           achieved here?
                       MR. CARUSO:  Well, the distillation of the
           knowledge from those tests came out in RIL 174.  At
           that time, the RIL 174 made a recommendation to change
           the acceptance criteria for RIAs that were in Reg
           Guide 1.77 and in the Standard Review Plan, as
           described on this page here.  Oxide spalling would not
           be allowed.  Spallation was not good because it
           creates weak spots in the fuel.  Cladding failure
           limit, the 170 calorie per gram limit, would drop to
           100 calories per gram.  And the coolability limit
           would change from -- well, right now it's at 280
           calories per gram with no burnup limit.  It would
           change to be 280 calories per gram for burnups less
           than 30,000 megawatt days per metric ton or for
           burnups greater than 30 gigawatt days per metric ton,
           the criteria would be no cladding failure, i.e. 100
           calories per gram.  Also, is it the RIL or the -- I'm
           not sure if it was the RIL or the Agency program plan
           which noted that the 280 calories per gram number
           might be reduced to 230 because of the evidence --
                       MR. WALLIS:  I guess you're describing a
           regulatory action.  I don't know what this 100
           calories per gram is based on.  It may be based on the
           fact that you had a very poor basis for
           decisionmaking, so you did something very
           conservative.  Or it may be based on tremendously good
           experimental basis, which may have drove you to a 100
           calories per gram.
                       MR. CARUSO:  Ralph has the paintbrush
           slide here, which is -- we call it the paintbrush
                       MR. WALLIS:  My impression is there's a
           very small test basis for this decision.
                       MR. MEYER:  There is a fairly small
           database, and unfortunately when I grabbed this slide,
           I didn't get the latest version of it, so there are
           some missing points.
                       MR. ROSEN:  Slide it over a bit so we can
           see the --
                       MR. WALLIS:  At least there's a scale on
           the y-axis.
                       MR. ROSEN:  That's right.
                       MR. MEYER:  Yes, there's a scale on the
                       MR. ROSEN:  It should have a scale on the
                       MR. CARUSO:  The numbers in the circles
           correspond to tables in a publication.  And it's a
           paper that we wrote.  And the indicators outside of
           circles correspond to tests that have been done since
           that paper was published.  And there are some data
           that are not on here.  I know this will be
           unsatisfying to people who collect good data.  It is
           all we have to go on, and so we resort to drawing our
           lines with broad brushes.  We have a better
           understanding now than we had in 1977.  I can tell you
           something about the personality of each of these data
           points and the pulse with the test temperature and
           other things that we believe would make the points
           either move up or down if you were able to normalize
           this to a set of appropriate conditions.
                       The bottom line is once you get away from
           uneradiated material, a new damage mechanism comes in,
           and it is a mechanical interaction from the expansion
           of the pellet pushing against the cladding which has
           lost some of its ductility.  And we plot this
           typically -- we do, not everybody in the world does --
           but we plot it as a function of corrosion in some
           measure here, the oxide thickness, because it appears
           that the oxidation on the rod gives a stronger
           dependence than the actual burnup.
                       MR. POWERS:  Well, if we move to clads
           that are less corroded --
                       MR. MEYER:  Yes.
                       MR. POWERS:  -- in the reactor, but they
           still harden in the course of irradiation, what do you
           change that outside thickness to?
                       MR. MEYER:  The irradiation hardening,
           we've always thought that the irradiation hardening
           hits a stable point very early, about ten gigawatt
           days per ton, and you get some equilibrium where
           you're annealing it as fast as you're putting it in. 
           And it doesn't seem to be as important as the
           embrittlement that comes principally from the hydrogen
           that's absorbed when you oxidize the cladding and
           steam.  So it's really -- there are two major
           variables, burnup and -- or you could say fluency and
           oxidation.  We have simplified for this plot and may
           simplify it in application, because I don't think
           we're going to be able to resolve the dependence on
           the set of variables.
                       MR. KRESS:  If I look at that curve,
           Ralph, and look at things above 40 on the oxide
                       MR. MEYER:  Yes.
                       MR. KRESS:  -- it looks like in order to
           envelope those black dots, you need a much lower
                       MR. WALLIS:  Everything fails pretty much.
                       MR. MEYER:  That's right.  And,
           unfortunately, the points that have not been put on
           this add two more right down there in that cluster.
                       MR. KRESS:  Black dots.
                       MR. MEYER:  Black dots.  Now, here's where
           you have to start looking at the test conditions,
           because those are all tests in NSRR.  They're tests at
           room temperature, and the accident of interest is a
           hot zero power accident.  That's the worst one, the
           one we look at.  And so the temperature should be
           almost 300 degrees centigrade, 285, 300 degrees.
                       MR. KRESS:  Which makes the clad more
                       MR. MEYER:  Which makes the clad more
           ductile.  In addition to that, there are different
           pulse widths between these facilities.  The JAERI
           facility has a very narrow pulse of about four and a
           half milliseconds, and the CABRI has a normal pulse of
           about nine and a half milliseconds, but they have
           artificially broadened it to as high as 80
           milliseconds in some tests.  And this affects the
           temperature of the cladding during this rapid period,
           the temperature of the cladding at the time that the
           stress is applied.
                       MR. KRESS:  It doesn't have time to get
           the heat from inside to the clad.
                       MR. MEYER:  Right.  So if you imagine
           adjustments to all of those, you take the JAERI points
           and you push them up.  And so we intentionally drew
           our line above some of the points from NSRR.
                       MR. ROSEN:  This pulse was compared to
           what in the real case?  Between four and a half and
           nine is what your test facilities have shown.  In the
           real case, what should they be if we were actually
           trying to --
                       MR. MEYER:  That's a very interesting
           question, because for years we all thought that
           typical pulse widths that an LWR would produce in an
           accident like this was 30 to 50 milliseconds, and in
           fact last summer I asked Brookhaven, who had done an
           extensive study on calculations, to go back and plot
           this out as a function -- pulse width as a function of
           the energy and the pulse.
                       And for pulses in the neighborhood of
           cladding failure, that is anywhere close to 100
           calories per gram, 60 to 100 calories per gram, LWR
           pulses will be about ten milliseconds.  And we
           mistakenly thought they were much larger than that. 
           So at the time we drew this figure, we're thinking
           that the JAERI pulses are far too narrow and that the
           normal CABRI pulses are too narrow and the broadened
           CABRI pulses are the right ones.
                       MR. CARUSO:  There's some question about
           whether PWRs can actually get those sort of pulses,
                       MR. MEYER:  Well, let me respond to that
           by saying we all believe, all of us who are involved
           ion assessing this, believe that at the end of the day
           when we get the fuel damage criteria that we're
           looking for, whatever it happens to be, that when a
           plant accident analysis is done for real core designs
           and real conditions, that you won't get there.
                       MR. KRESS:  Is rod ejection --
                       MR. MEYER:  Rod ejection --
                       MR. ROSEN:  You won't get where?
                       MR. MEYER:  You won't get up around 100. 
           You'll get maybe 30, 40 calories per gram max.
                       MR. ROSEN:  What about the pulse width? 
           What would the pulse width be in real plants?
                       MR. MEYER:  This is for a real plant, and
           this is several sources of data, and the difference
           between them if fairly minor.  So if you have a 40
           calorie per gram pulse, this is in fuel enthalpy
           increase.  This is not actual energy of the pulse. 
           There's a small difference because of heat conduction. 
           At 40 calories per gram, the pulse width is roughly 20
                       MR. ROSEN:  You're not answering my
           question.  With all due respect, Ralph, I don't think
           you're answering my question.
                       MR. MEYER:  Okay.
                       MR. ROSEN:  It is not about experimentally
           what the pulse width is that produces a maximum delta
           H that you've shown here, but when a plant has, for
           example, if the plant had a rod ejection accident, how
           wide would the pulse be?
                       MR. MEYER:  That's what this is.  This is
           a plant calculation.  This is not a test result or a
           test calculation.
                       MR. ROSEN:  So how do I pick the pulse
           width?  Is it 100 or is it zero?
                       MR. MEYER:  It depends on how much
           reactivity is in the rod that gets ejected.
                       MR. KRESS:  And where the rod is.
                       MR. MEYER:  Yes.
                       MR. CARUSO:  Whether the rod is inserted
           or whether it's normally all the way out?
                       MR. MEYER:  I can tell you that it would
           take a reactivity of about $2 to get 100 calorie per
           gram pulse.
                       MR. KRESS:  That means the rod's all the
           way in and it's a really effective rod?
                       MR. MEYER:  I don't have a good feeling
           for it, but I'm told that's too big.  That's a big
                       MR. KRESS:  That's a big rod.
                       MR. MEYER:  And you're not going to find
           any $2 Rod Worths.
                       MR. KRESS:  Most of them are around 50
           cents, I think.
                       MR. MEYER:  Most of them are?
                       MR. KRESS:  Around 50 cents or something
           like that.
                       MR. CARUSO:  The rods tend to be much
           lower than the values that are assumed in the accident
                       MR. MEYER:  But I think that's -- this is
           the nature of the exercise.  You find out where the
           damage limit is that you can tolerate, and then you do
           the plant calculation and hopefully show that you
           don't get to that damage limit.  So we don't expect
           the plants to be able to deposit the energy in the
           vicinity of where we're doing the test, because we're
           trying to do the test to find out what the limit of
           damage is that we want to tolerate.
                       MR. KRESS:  But the point is that when a
           plant makes a calculation for its design, it's going
           to calculate a number.
                       MR. MEYER:  Yes.
                       MR. KRESS:  And you're going to say, "We
           want that number to be less than 280 or less than
           100," right?
                       MR. CARUSO:  Well, actually the way the
           vendors do it -- until now the vendors have all been
           using 1-D methodologies.  And this issue came up in
           the mid-'90s.  They were asked if they had any better
           estimates of the actual values, because they were
           using conservative 1-D methods.  Using 3-D methods,
           they estimated that the numbers would be well below
           100.  And we have this information from all of the
           vendors, and this is something that Brookhaven has
           also calculated.  For real cores using 3-D methods,
           the values will be much lower than 100.
                       And about a month ago, we received a
           topical report from I can say Westinghouse to review
           so that they could redo their calculations using a 3-D
           methodology.  And this is a comparison of two fuel
           enthalpy calculations that they did, one using a 3-D
           methodology and one using a 1-D methodology for the
           limiting pin.  And you can see -- you have to use the
           scale on the right, not the BTUs per pound, calories
           per gram.
                       And you can see that for this limiting
           fuel rod, the values are well under 100.  They're in
           the neighborhood of about 70.  This would be for a
           rod, I believe, early in life, maybe at the end of the
           first cycle, sometime in the first cycle, early in the
           second cycle.  This is typical of the results we see
           from the vendors when they use more realistic but
           still conservative analyses.
                       MR. KRESS:  So you're saying you've got
           lots of margin to this 100.
                       MR. CARUSO:  Lots of margin.
                       MR. KRESS:  But --
                       MR. CARUSO:  I'm getting way ahead of
                       MR. KRESS:  Yes, but the point is if
           somebody were to come in with a calculation that says
           it was 99, you'd still would have used up all your
           margin, but you would approve it.  You'd still meet
           your regulatory criteria.
                       MR. CARUSO:  We haven't set these new
           regulatory criteria yet.
                       MR. KRESS:  Well, whatever the criteria
                       MR. CARUSO:  And that's something that we
           do have to do.
                       MR. KRESS:  Yes.
                       MR. CARUSO:  And we're waiting for the
           results of the work that Research is doing to revise
           Reg Guide 177 and the SRPs.  When that work comes in,
           we will revise those regulatory criteria.  In the
           interim, though, we have lots of licensing actions
           that need to be done.  This morning I talked to you
           about power uprates, I've talked about PWR power
           uprates.  Work continues.  So I can't --
                       MR. KRESS:  I heard you say you're waiting
           for the results of the research.  Does that mean the
           operative words in the previous slide are no longer
                       MR. CARUSO:  No.  It says that we will use
           the results of the research work.  I mean I can't
           ignore it, I shouldn't ignore it.  I will use it.  I
           will use it to revise the regulatory guidance.  But
           until that's done I still have regulatory activities
           that I must continue to do.  I can't just stop and
                       MR. WALLIS:  Well, you can.  I want to go
           back to my first question.  You have not -- I think
           you've convinced me that you do not have a good basis
           of test data on which to base these decisions.  You've
           got points which are all over the place.  You don't
           have a very good understanding of how fuel fails, and
           this 100 calories per gram has been obtained by some
           very broad brush estimate.
                       MR. CARUSO:  Well, the 100 calorie per
           gram number is the number we were going to use for
           fuel failures.  Remember that the GDC criteria is two
           parts.  GDC criteria is no threat to the reactor
           coolant pressure boundary and no loss of coolable
                       MR. WALLIS:  I don't really care what
           you're going to do regulatory-wise.  You haven't
           convinced me you have a good basis of knowledge on
           which to base your decision.
                       MR. CARUSO:  Oh, but you see I have to
           make the decision about whether I will meet the
           general design criteria.  The general design criteria
           is the ultimate acceptance criteria, because as a
           regulator that's my criteria.
                       MR. WALLIS:  How can you do it if you
           don't have a good basis of knowledge?
                       MR. CARUSO:  Well, I do as good a job as
           I can with the information that's available to me.
                       MR. WALLIS:  Then you must have tremendous
           uncertainty in your decisionmaking.
                       MR. CARUSO:  And we do.  We do have some
           uncertainty, but I'm about to get into the reasons why
           I sleep well at night, even given that degree of
                       VICE CHAIRMAN BONACA:  One thing that you
           said, it sounds almost as if there is new information
           coming because for the first time they're doing 3-D
           methods.  That's not true.  I mean I can remember that
           combustion engineering was using a 3-D model method
           seems for years, 25 years ago, Hermit, I believe, is
           the name of it.  I think it was a credible nodal
           method.  I don't know what this is.  I don't know, for
           example, what kind of work you're ejecting here.  I
           see that this is a protracted transient and typically
           we have seen them turning faster now.  I'm trying to
           say that they've been using -- yes, Westinghouse has
           been using some kind of synthesized method, they were
           using 1-D and 2-D and tied them together, and they
           were not really a 3-D.  And so I'm trying to
           understand what we've learned in the past ten years
           that is so different from what we learned before.
                       MR. CARUSO:  Well, what we've learned from
           the research program is that the fuel failure limit is
           not correct.  It shouldn't be 170 calories per gram,
           and the 280 calorie per gram limit needs to be revised
                       VICE CHAIRMAN BONACA:  No, I was asking
           about the results that the vendors are showing now. 
           Why are they so lower?
                       MR. CARUSO:  Now, what the vendors are
           doing, and this is going to get ahead of myself here
           again, the vendors are preparing for what's called
           extended burnup fuel above 62.  And for burnups above
           62 we've said they've got to provide the criteria,
           they've got to provide the data, they've got to show
           why it's safe.  We're not going to do that.  They've
           go to do that work.  Now, they have, just last
           Thursday, sent in a topical report on this subject
           which proposes changing the limits.  And they've
           proposed changing the limits to about 230 calories per
           gram for the upper limit and about -- still leaving it
           170 for burnups below about 35 gigawatt days per
           metric ton, dropping to about 130 calories per gram at
           about 80,000.
                       MR. KRESS:  Is this based on new data?
                       MR. CARUSO:  They don't have any more data
           than Ralph has.
                       MR. KRESS:  Okay.  So it's --
                       MR. WALLIS:  How can they possibly justify
           it, except by arm waving and theory?
                       MR. CARUSO:  That's a good question.  We
           just got this report Thursday, and we have to review
                       MR. ROSEN:  I think it would be
           appropriate to read it.
                       MR. CARUSO:  Pardon?
                       MR. ROSEN:  I said it would be appropriate
           to read it.
                       MR. CARUSO:  Exactly.  But if you -- you
           were asking the question what's going on and why am I
           getting this all of a sudden if the vendors already
           have these methods.  They want to go to higher burnup,
           so they have to have better methods to go to the
           higher burnup.  So Westinghouse has got the jump on
           the other two vendors by submitting a method here.
                       VICE CHAIRMAN BONACA:  I just was taking
           exception on their statement that until recently they
           used 1-D methods and they didn't.
                       MR. CARUSO:  What I mean by use it is in
           the regulatory context, in terms of the approved
           licensing methodologies, they've been using 1-D
                       VICE CHAIRMAN BONACA:  Westinghouse has
           used, not -- so, anyway.
                       MR. CARUSO:  Okay.  Let's see, where was
           I?  I think we got sidetracked.
                       MR. POWERS:  Let me continue the
           sidetracking a little bit.
                       MR. CARUSO:  I'll put this one up.
                       MR. POWERS:  What I'm struggling with a
           little bit, Ralph Meyer, is you and your colleague
           have critiqued what data you have based on the
           experimental technique that was used.  And your
           critiques sound possible to me.  The experiments are
           not high-temperature experiments and what not.  And so
           you've thought, "Well, maybe I should move my criteria
           in just a little bit to reflect what I think the fuel
           would do if I had done the experiment correctly, I
           mean an absolutely prototypic experiment."  And it
           sounds as though you've gotten a topical report that
           comes in and says, "Okay, we can move these lines a
           little more because we think this fuel will behave
           even more differently if the experiment had been 
           absolutely prototypic."
                       Is there, within the psyche of the Agency,
           any plausible argument of moving those lines around
           where you set the criteria that could be accepted
           without at least one experimental data point to show
           that what you think the fuel would do had the
           experiment been prototypically done it would in fact
                       MR. MEYER:  Yes.  In fact, since the 1997
           information letter, we have not made any further
           statement about how we think that -- about where we
           think that line should be drawn.  We have learned
           enough from recent tests and from our kinetics
           analysis to hone in on what we think are fairly
           definitive parameters.  And the one thing that we are
           waiting for in order to make another estimate is a set
           of tests that are now scheduled for 2004 in the NSRR
           test reactor in a new high-temperature, high-pressure
           capsule.  So NSRR at that time is going to make a
           direct comparison between the room temperature test
           and a test conducted at the right temperature.
                       Now, they will not be able to vary the
           pulse width.  The pulse width will still be about five
           milliseconds, and at the energies of the test the
           correct pulse width should be about twice that.  Now,
           we do have varying pulse widths from CABRI.
                       MR. POWERS:  Could I just hone in a little
           bit on this issue of pulse width?  And just tell me if
           my understanding of the pulse width issue is correct. 
           The issue is one of how much heat do you get into the
           clad, as opposed to keeping it all in the fuel?  And
           there must surely be a pulse width that is so narrow
           that no heat goes into the clad at all.  And any pulse
           width really doesn't change phenomenology; is that
                       MR. MEYER:  Yes.
                       MR. POWERS:  And the question is can you
           give us an idea of what that pulse width is such that
           essentially no heat goes into the clad?
                       MR. MEYER:  Yes.  More or less, it's
           around 20 milliseconds.
                       MR. POWERS:  So it really doesn't matter
           whether they have a five or not.
                       MR. MEYER:  My opinion at the moment is
           that I doubt it.
                       MR. POWERS:  Okay.
                       MR. KRESS:  And not only that, the
           narrower the pulse width, the more conservative the
           result is with respect to --
                       MR. MEYER:  Certainly.  You could say
           that.  There is another -- there are two effects that
           are hypothesized.  One of them is the temperature
           effect, which we've spoken of, and it obviously
           exists.  How important it is we don't quite know yet. 
           Because in fact when you start looking at the
           mechanical properties measured separately as a
           function of temperature, in the range from room
           temperature to 300 degrees centigrade, uniform
           elongation for Zircaloy and some other alloys doesn't
           show a temperature dependence there.  But the total
           elongation that's been measured shows some.  But total
           elongation is a funny property.  It's not really a
           materials property.  It depends highly on the test
           arrangement.  So I don't know what to expect --
           something or nothing.
                       There is another effect that's
           hypothesized, and that has to do with a dynamic gas --
           fission gas expansion that might increase the loading. 
           In the picture here -- I don't have a slide to
           illustrate this -- but the picture here is grain
           boundaries, ten micron size, roughly, which are
           decorated with fission gas bubbles under high
           pressure, lots of them and they're small, and a rapid
           temperature transient that expands those bubbles,
           forcing the grains apart and sort of acting like
           levers to add to the mechanical loading on the
           cladding from the thermal expansion of the O2 itself. 
           Now, I don't know whether that's a real effect, an
           imagined effect, how important it is.
                       MR. WALLIS:  This is just part of it.  I
           mean my colleague is talking about a relaxation time
           for the fuel to share energy with the cladding, which
           we're talking about on order of ten milliseconds. 
           There are all kinds of non-homogeneities in this fuel. 
           There are spots where there's more fuel than others. 
           It's not absolutely uniform.  So at some microscopic
           level, when you zap it very quickly, there are certain
           spots that get hotter than others.  There's all kinds
           of things that happen microscopically in there.
                       MR. MEYER:  That's correct.
                       MR. KRESS:  You get more in the power
           going into the --
                       MR. WALLIS:  The little nodules of
           plutonium or whatever is in there in the MOX fuel.
                       MR. MEYER:  In high burnup UO2 fuel, I
           think it's pretty homogeneous.  The thing that --
           where we are on the lookout for such an effect is in
           the MOX fuel, which is not -- it's fabricated with
           inhomogeneities which may never disappear.  And so
           that's a separate matter.  I mean it's real.  We have
           a few tests on MOX fuel, and that's a real effect. 
           The dynamic gas expansion, I don't know if it's real
           or not real, but it's possible.
                       MR. POWERS:  I'll just sideline us just a
           little more because he provokes me all the time with
           these wonderful statements, things like that.  Ralph,
           you said that you thought in a high burnup fuel the
           power input was fairly uniform?
                       MR. MEYER:  That's what I said.  Is that
                       MR. POWERS:  It seems to me that I have
           seen plots that would suggest to the contrary, that
           it's highly peaked around the periphery.
                       MR. MEYER:  Oh, oh, okay.  Sure.  I
           thought you were talking about like little local
           islands of inhomogeneous stuff.
                       MR. POWERS:  Oh.  Okay.  What you're
           saying is --
                       MR. MEYER:  It's creamy smooth, but it's
           got a heck of heat on the end.
                       MR. POWERS:  On the perimeter.
                       MR. MEYER:  Oh, yes.
                       MR. POWERS:  But certainly uniformly
           across the pellet there.
                       MR. MEYER:  Yes.
                       MR. POWERS:  Okay.  I understand now.  I'm
                       MR. RANSOM:  I have a question.  Why is
           the 3-D and 1-D so much different?  In fact, it seems
           counterintuitive, I would think, that the 3-D might
           reveal a higher new energy locally per gram than say
           a 1-D energy.
                       MR. MEYER:  I can't answer that question. 
           Maybe somebody --
                       VICE CHAIRMAN BONACA:  The 1-D were never
           neutronics, they were just point kinetics --
                       MR. RANSOM:  Right.  But that's the entire
           core they're doing 1-D, right?
                       VICE CHAIRMAN BONACA:  That's right.  But
           I'm saying --
                       MR. RANSOM:  Versus a 1-D where you've
           actually getting variations across the cross section.
                       VICE CHAIRMAN BONACA:  Yes.  But they were
           using typically static calculations.  And so it didn't
           have all the effect of feedback that you will get in
           a neutronic calculation of 3-D.
                       MR. RANSOM:  Is that the explanation that
           the feedback is much different then?
                       VICE CHAIRMAN BONACA:  That was a key
           difference there.
                       MR. CARUSO:  Let me go on to my next
           slide, which is what I call "why I sleep well at
           night" slide.  When this issue arose from the CABRI
           and NSRR tests, we talked to the vendors and they
           performed some 1-D calculations or they showed us some
           1-D calculations that showed that the neutronics would
           be much better.  The limiting fuel, the graph I showed
           you for the Westinghouse plot, this is for fuel that's
           less than 30 gigawatt days per metric ton for which we
           think the 280 or even the 230 value is still
           reasonably a good value to use.
                       MR. POWERS:  Why do you think that?
                       MR. CARUSO:  Well, we -- I'd have to go
           back to the paintbrush plot, and if you look at the
           paintbrush plot and look at burnup against failure,
           you plot burnup against failure, you'll see that this
           fuel at less than 30 gigawatt days per metric ton
           doesn't fail.
                       MR. POWERS:  I think that I will not see
           that.  If we could put the paintbrush slide up, I will
           be stunned to see --
                       MR. CARUSO:  It's not as a function of
           burnup.  It's a function --
                       MR. POWERS:  No, I understand that, but we
           can -- I'll be willing to make a mental change and
           point to a bunch of plots at around 150 and zero and
           say, gee, those look black to me.
                       MR. CARUSO:  Do you know what those data
           points are, Ralph?
                       MR. MEYER:  Yes.  There were cladding
           failures in some PBF tests.  Where's Harold?  Help me
           -- and the other SPIRT ones?  Those were around five
           -- Harold Scott is the Harold that I'm referring to
           here, and Harold will come to a microphone and help me
           recall some of the details.
                       MR. POWERS:  Well, understand the question
           that's being posed is why anyone would think a 280 or
           a 230 calorie criterion is adequate for any fuel ever?
                       MR. CARUSO:  First of all, remember that
           that criteria is not for fuel failure.  That's a
           criteria for ejection of molten material.
                       MR. POWERS:  I will repeat my question: 
           Why would anyone think that a 230 or 280 criterion is
           appropriate for any fuel ever?
                       MR. MEYER:  Okay.  Let me tackle that.  If
           you look SPIRT and PBF data with burnups of less than
           five gigawatt days per ton, so essentially zero,
           essentially zero burnup, fresh fuel, some of them had
           very small amounts of burnup.  And there's a fairly
           sizable database.  And you line these up as a function
           of the peak fuel enthalpy.  You'll find a dividing
           line around 230 calories per gram, where below 230
           calories per gram you get no fuel dispersal, and above
           230 calories per gram you get fuel dispersal.  As soon
           as you get some burnup, some significant burnup, and
           the first time this shows up is with a PBF test with
           a burnup of about five or six gigawatt days per ton,
           you begin to see the PCI mechanism and the failure at
           the much lower energies.
                       MR. POWERS:  Okay.
                       MR. MEYER:  It's much below 30.
                       MR. POWERS:  I'm not sure I want to argue
           with you too much about this, but if indeed seven is
           your SPIRT data, I certainly see a point up there at
           zero that seems to suggest you get failure at below
           230.  So your dividing line is a peculiar dividing
                       MR. MEYER:  This is zero on an oxide
           scale, not a burnup scale.
                       MR. WALLIS:  But it goes down with more
                       MR. POWERS:  Well, would you expect the
           oxide to be different than about zero for zero burnup?
                       MR. MEYER:  No, but I expect --
                       MR. POWERS:  Well, then it's a good point.
                       MR. MEYER:  I expect at zero burnup that
           you don't have any irradiation targeting.
                       MR. POWERS:  Okay.
                       MR. MEYER:  It saturates somewhere around
           ten or at some low value.  So I do think there is
           something else that is precluding the failure from
           limited ductility with very fresh materials.  And the
           failure mechanism there is a high temperature
           oxidation and embrittlement mechanism, something like
           you have in --
                       MR. POWERS:  Okay.  Let me change my
           question:  Why would anybody accept 280 or 230 as a
           criterion for any fuel with burnups greater than five
           to eight gigawatt days per ton?
                       MR. KRESS:  If you had a different plot
           that says on the x-axis quantity of dispersed molten
           UO2 versus enthalpy increase --
                       MR. MEYER:  That's the important question.
                       MR. KRESS:  -- then you're saying that
           plot would -- a line drawn through 230 or something
           like that would show roughly very little ejected below
           it, and some above it would be ejected is what you're
           saying, that the criteria for that is just how much
           molten fuel gets ejected, not whether the --
                       MR. CARUSO:  It's the molten fuel
           criteria.  The 230 is going to be
                       MR. KRESS:  Not whether the clad fails or
                       MR. CARUSO:  Not a clad failure.
                       MR. MEYER:  It's not a clad failure, but
           the 230 in fact corresponds to, for the fresh
           materials, to no fuel dispersal.  I think there were
           probably in the whole population of tests there were
           only a couple of cracks that occurred at a lower
           energy, and they didn't disperse.  They didn't lose
           any fuel from those.
                       MR. KRESS:  Now, if you start fuel out --
           if it's running at hot shutdown, is this the test
           you're talking about?  So the fuel starts out
           something about five or 600 at hot shutdown?
                       MR. CARUSO:  Five or 600 what?
                       MR. KRESS:  Degrees F.
                       MR. CARUSO:  Hot zero power would be 500
           to 560.
                       MR. KRESS:  Okay.  And you add to that
           temperature 230 calories per gram.  Does the increase
                       MR. MEYER:  You know exactly the total --
           this is the total.  Don't add them.
                       MR. KRESS:  I can't locally put that on a
           piece of fuel and say whether it takes me to molten or
                       MR. MEYER:  Two hundred and sixty-seven
           calories per gram is the solidest for fresh UO2.
                       MR. KRESS:  It depends on what temperature
           you start from.
                       MR. MEYER:  What?
                       MR. KRESS:  It depends on what temperature
           you start from.  Or are you just giving me the delta
           H at the melting point to fully melt it?  Is that the
           delta H you're giving me?
                       MR. MEYER:  No.
                       MR. KRESS:  I've got to heat the fuel
           first, and then I've got to melt it.
                       MR. MEYER:  Two hundred and sixty-seven
           gets you up to the solidest, and I think you chemists
           do it from room temperature, don't you?
                       MR. KRESS:  Generally, but we're starting
           with 500 -- I'm trying to decide how much -- you're
           giving me a pulse.
                       MR. MEYER:  Okay.
                       MR. KRESS:  I'm trying to decide how much
           fuel I've got.
                       MR. MEYER:  At hot conditions, 285, 300
           degrees centigrade is about 18 calories per gram.
                       MR. KRESS:  Okay.  So I'm going to get
           molten fuel with these pulses, and I'm going to fail
           the clad.  I'm trying to understand the two curves
           that I see.  I've got a lot of molten fuel, and I've
           got a failed clad.
                       MR. MEYER:  No, no, no, no, no.  Something
           is not coming across right here.
                       MR. KRESS:  Okay.
                       MR. MEYER:  Because the way the SPIRT data
           were analyzed and the way the criterion is written,
           it's a total enthalpy.  You don't get to add the 18 to
           that amount.  In later test analysis, we have been
           taking it out and just looking at the delta, because
           the two main facilities --
                       MR. CARUSO:  Operate from those
                       MR. MEYER:  -- operate at different
                       MR. KRESS:  So you're saying the 280 is
           not a delta, it's an absolute --
                       MR. MEYER:  Right.
                       MR. KRESS:  -- enthalpy.
                       MR. MEYER:  Right.  Right.
                       MR. WALLIS:  Well, I guess I've got to
           drop this, but instead of talking if you'd show us a
           figure which is infinitely more convincing than this
           one, I would be very happy.
                       MR. MEYER:  Well, I hope in a couple of
           years when we get these what I view as key tests from
           Jerry to be able to show you one that's more
           convincing than this, I don't think you're going to be
           happy with it, but I think it's going to be probably
           the best we're going to be able to do maybe ever, but
           at least for a long time.
                       MR. KRESS:  The reason I was confused is
           your y-axis says enthalpy increase.  That led me into
           that line of thinking.
                       MR. MEYER:  Again, this is not the plot as
           a function of burnup.  This is --
                       MR. KRESS:  That's the problem --
                       MR. MEYER:  This doesn't have the 18
           calories in this plot.  Did I say it wrong before?
                       MR. KRESS:  No, no.  I was thinking wrong
                       MR. MEYER:  This plot doesn't have.  But
           as Dana points out, this plot doesn't extrapolate to
           zero at 230.  That comes in at 150.  The 230 probably
           has a very limited range of applicability.  I agree
           with you, Dana.
                       MR. CARUSO:  EPRI seems to think
           otherwise, but we'll get a chance to look at that.  I
           think this is a matter that we will consider as part
           of the revisions to the SRP and the Reg Guide, and we
           will ask for your help and we'll ask for the help from
           the Office of Research, and we'll ask for comments
           from the industry in order to set those limits.
                       MR. KRESS:  How far are we from being
                       MR. CARUSO:  Let me just get through this,
           because I want to make these points.
                       MR. KRESS:  Okay.  Okay.
                       MR. POWERS:  Tom, just for scheduling
           purposes, the next speaker will be very brief.
                       CHAIRMAN APOSTOLAKIS:  Have you spoken to
                       MR. POWERS:  I've had an in-depth with
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. POWERS:  And implored him to curtail
           his normal exuberance.
                       MR. MEYER:  Is that me, Dana?
                       MR. POWERS:  No.
                       MR. MEYER:  Oh.  I thought I was the next
                       MR. POWERS:  No.  The next session.
                       MR. CARUSO:  As I said, this is why I feel
           comfortable with the plants as they are right now.
                       MR. POWERS:  Your tolerance, sir, is
                       MR. CARUSO:  As I said this morning,
           someone has to make these decisions.  And if this is
           all you've got, then this is all I've got to make a
           decision.  These are expensive tests.  I can't go get
           a lot of data.  I would like to have lots of data, but
           lots of data costs a lot of money.
                       MR. KRESS:  I don't see anything on here
           that says the expected frequency of rod ejections is
           very low.
                       MR. CARUSO:  Well, actually, it's
           contained in the third big bullet, okay?
                       MR. KRESS:  Okay.
                       MR. CARUSO:  Let me just talk about the
           second bullet first.  The fact that the paintbrush
           slide, as you noticed, was plotted against corrosion. 
           Corrosion seems to be very important for these fuel
           failures.  We are going to materials -- better
           materials that don't corrode as much, that don't
           spall, hopefully don't spall.
                       But the third bullet is the important
           bullet, okay, about how the machines actually operate. 
           And it's very important to realize that PWRs are
           designed these days to operate with all rods out
           during normal operation.  Normally they pull all the
           rods out and they don't go critical because they have
           boron in them.  Gradually they dilute the boron, go
           critical and operate for a full cycle with all rods
           out.  Therefore, if you have a rod ejection accident,
           there would not be any rods to eject, because they're
           already out.  There is no reactivity to add.
                       MR. WALLIS:  As long as they stopped.  As
           long as they didn't go into like containment.
                       MR. SIEBER:  The rods are already out.
                       MR. CARUSO:  They're already out.
                       MR. WALLIS:  They're not in containment.
                       MR. CARUSO:  No.  They're out of LOCA. 
           They're out of the core.  They're sitting on --
                       MR. WALLIS:  I thought the rod ejection
           was actually a LOCA event where the rod came out and
           made a hole.
                       MR. CARUSO:  Well, it doesn't have to be,
           but that's the way we would think of them these days. 
           In order to --
                       MR. ROSEN:  The point is there's no
           reactivity addition.
                       MR. CARUSO:  There's no reactivity
                       MR. ROSEN:  The reactivity has already
           been added.  When the PWRs are in all rods out
           configuration, all the reactivity from the rods have
           already been added --
                       MR. CARUSO:  Exactly.
                       MR. ROSEN:  -- to the core.
                       MR. CARUSO:  Thank you, Dr. Rosen.
                       MR. ROSEN:  There's none left.
                       MR. CARUSO:  The analyses that have been
           done are analyses of the hot zero power configuration,
           okay?  Hot, some rods in for some reason, zero power,
           just barely critical, eject a rod, you get the highest
           pulse.  LWR Rod Worths these days are designed in to
           be small for a number of reasons -- for safety
           reasons, for economic reasons.  There's all sort of
           reasons rods are designed to have small Rod Worths. 
           And the concern here is about high burnup fuel.  Well,
           high burnup fuel, by definition, has been burned up. 
           Therefore, it has less reactivity than fresh fuel.
                       And, also, I would add if you look at the
           number of rods in a typical core that are anywhere
           near the 62 gigawatt day per ton limit, it's extremely
           small, extremely small.  Batch discharge averages I
           think in the BWRs you heard this morning are running
           about 45,000 to 50,000.  That's the batch average,
           which means that there are some rods that are up
           around 62, but the average is a 45.
                       MR. POWERS:  I hate to bring up the
           paintbrush slide again, but I did not see anything on
           that paintbrush slide that suggested there was
           something magic about 62 gigawatt days per ton; that,
           in fact, it was a fairly substantial degradation as
           soon as you crossed -- certainly crossed 40 microns. 
           That seemed to be very big threshold and that there
           are no pins that seemed to survive beyond that.  But
           even before that, it seemed to me that it was some
                       MR. CARUSO:  We are working on this.  I
           think that may be a valuable observation, but realize
           that 40 microns these days with new cladding materials
           is actually pretty high corrosion.
                       MR. POWERS:  Well, I also hasten to point
           out that that oxide thickness was selected as the
           variable on that plot because it was there, not
           because it reflects on how the clad is actually the
           embrittlement of the clad.  Now, when you change
           clads, now you've got to change whatever you're
           plotting against, which is going to be something like
           a measure of ductility or a measure in embrittlement
           or something like that.  And that when you look at
           these new clads, you're going to find that they suffer
           some degradation in strength as you go up in burnup.
                       MR. CARUSO:  Possibly, that's correct.  In
           any case, there's going to have to be a scaling
           argument made between the materials.  I believe most
           of these tests were done with Zircaloy.  We're using
           now Zirlo or using M5.  BWRs use Zirc-2 which is
           different than Zirc-4.  So a scaling argument will
           have to be made in any case.
                       MR. POWERS:  I would be more enthusiastic
           about an experimental argument.
                       MR. MEYER:  The CABRI program is test --
           its next two tests will be the Zirlo run and an M5
                       MR. POWERS:  Didn't we -- I mean I see
           papers in the literature that suggest that M5 has the
           capability of picking up more hydrogen than what you'd
           find is usual for the Zircaloy.
                       MR. CARUSO:  I don't know that's the case
           at the normal operating conditions.  We do know of
           this Russian alloy, E110 that seems to pick up a lot
           of hydrogen during a high temperature LOCA-type
           transient, where you're up above the Alpha-Beta phase
                       MR. POWERS:  I see some -- I've seen at
           least one paper concerning the can-do conditions,
           where M5 seems to be picking up -- and it wasn't ever
           specimen of M5, but some specimens of M5 seem to pick
           up like twice as much as hydrogen as is normal, as
           they oxidized.
                       MR. CARUSO:  Yes.  I'm not aware of that.
                       MR. MEYER:  I'm not aware of that either.
                       MR. POWERS:  Maybe I should share that
           paper with you.
                       MR. CARUSO:  Okay.
                       MR. MEYER:  Okay.
                       MR. POWERS:  I have to find it, but it
           just came to me.  It's a curiosity, because it's not
           every specimen of M5.
                       MR. MEYER:  I mean we did see -- Framatome
           presented last year, both here at NRC and in a public
           forum, ductility measurements, these ring compression
           tests, for specimens that had been oxidized under LOCA
           conditions.  And, in fact, the hydrogen content in
           those specimens were surprisingly low.
                       MR. CARUSO:  That's what I thought.  I
           thought they were showing --
                       MR. MEYER:  Yes.  Whereas the similar
           rings of E110, which is the same nominal alloy, sucked
           up a lot of hydrogen under very similar conditions. 
           This, by the way, is something that we don't
           understand fully.  We have -- I want to say this.  We
           have the full cooperation from Framatome on this.  We
           have signed an agreement with them to do some
           cooperative research on M5 cladding at Argon under
           these conditions to try and understand the situation.
                       MR. CARUSO:  I think that's all I've got
           to --
                       MR. WALLIS:  Ralph, did you ever mention
           ATWS?  Do you worry about fuel failure during an ATWS
                       MR. CARUSO:  Fuel failures during an ATWS
                       MR. WALLIS:  Calories per gram are used as
           a criterion for an ATWS --
                       MR. CARUSO:  ATWS criteria -- well, we
           have a rule for ATWS, and then there are several
           subsidiary criteria that are used to verify that the
           rule is still applicable to new fuel designs or
           changes in power level.  And those relate to PCT,
           containment issues, containment peak vessel pressure. 
           But for fuel it's a peak cladding temperature of 2200.
                       MR. POWERS:  There isn't a calories per
                       MR. CARUSO:  Lately, for certain ATWS
           instability events where you have an ATWS and you've
           had an instability, some calculations have been done
           because they were not able to show that they met the
           2200 degree limit for an unmitigated ATWS event,
           unmitigated ATWS instability event.  So realize the
           event you're talking about you're having an ATWS --
                       MR. POWERS:  I think when we were
           listening to these power uprates, they showed us a
           peak --
                       MR. CARUSO:  Right.
                       MR. POWERS:  -- and they talked about
           calories per gram.
                       MR. CARUSO:  Right.  That's correct.  That
           was because they did not meet the 2200 limit.
                       MR. POWERS:  What sort of calories per
           gram were we talking about?
                       MR. CARUSO:  Actually, I have a chart
           here, and I believe the numbers are on the order of 70
           or 80 calories per gram.
                       MR. POWERS:  So it is a consideration.
                       MR. CARUSO:  It is a consideration, but,
           once again, you have to consider what the event is for
           which this was calculated.  This is an unmitigated
           ATWS instability event.
                       MR. MEYER:  Are those 70 or 80 numbers
           recent numbers?
                       MR. CARUSO:  Let's see.
                       MR. MEYER:  Because in NEDO 32047, which
           was audited by NRR, I understand that the number was
           250 and said to be less than 280 and therefore okay.
                       MR. CARUSO:  This is out of any DC33006P. 
           This is actually out of a MELLA topical report. 
           Excuse me, let's see, GE14 --
                       MR. WALLIS:  I just thought that while --
                       MR. CARUSO:  -- 64.
                       MR. WALLIS:  -- you say why you slept well
           at night, you ought to cover the ATWS thing, that's
           all.  And now you're doing it.
                       MR. CARUSO:  Sixty-four calories per gram,
           excuse me.
                       MR. WALLIS:  And that's okay.
                       MR. CARUSO:  And that's okay.
                       MR. WALLIS:  By legislative --
                       MR. ROSEN:  Ralph Caruso, on your "sleep
           at night" slide, under PWR operational practices,
           something I claim to know something about, this hot
           zero power case that you say is analyzed, you say
           that's a reason you sleep at night.  Is that because
           PWRs are not at hot zero power very often?
                       MR. CARUSO:  That's correct.
                       MR. ROSEN:  Probably less than one percent
           of the time?
                       MR. CARUSO:  Probably much less than one
                       MR. ROSEN:  Probably much less.  I'll give
           you a tenth of one percent of the time, eight hours
           per year.
                       MR. CARUSO:  Yes.
                       MR. ROSEN:  Plants don't like to stay at
           a hot zero power.
                       MR. CARUSO:  That's correct.
                       MR. ROSEN:  It's not a place you want to
           stay.  You're either shutting down and going through
           it or you're going the other way as fast as you can to
           get to power.
                       MR. CARUSO:  Yes.
                       MR. ROSEN:  Okay.  So it's a probability
           argument.  While you're exposed in this position --
                       MR. CARUSO:  I hesitate to make that
           statement, because I'm not a PRA expert, and I can't
           defend the --
                       MR. ROSEN:  Well, we did do --
                       MR. CARUSO:  -- probability of that.
                       MR. ROSEN:  Well, I can make the
           statement, and I think there's hardly anybody in this
           room that would deny it, except perhaps -- well, I'll
           just say not very many people -- that plants don't
           stay at hot zero power very long.
                       MR. MEYER:  Brookhaven did do a
           probability estimate in connection with the program
           plan in 1998, and they did include that small factor
           in coming up with their estimate, which was in the
           range of around ten to the minus six.  It was at that
           time where we did a similar probability estimate for
           the rod drop in the BWR, concluded that it was
           significantly lower than the rod ejection probability
           in the PWR and at that time switched our attention
           from the BWR rod drop to the BWR power oscillations. 
           So that's how we got onto the power oscillations in
           terms of the high burnup fuels work.
                       VICE CHAIRMAN BONACA:  I think you should
           stay away from probabilities.  I mean we just had a
           recent even in a plant where we could have gone back
           to power without realizing that there was something up
           there, and you would have gone critical at zero power
                       MR. ROSEN:  I don't see that as a reason
           for not accepting the fact that plants don't stay in
           this condition.
                       VICE CHAIRMAN BONACA:  I agree with you.
                       MR. POWERS:  Let me just remind my
           probablistic colleagues that at the Chernobyl Plant
           there was a prescription of operating at low power,
           absolutely forbidden to operate at low power.  Things
           that people don't like to do they sometimes do.
                       MR. ROSEN:  What country was that in?
                       CHAIRMAN APOSTOLAKIS:  So this Slide 6 is
           going to take forever, huh?
                       MR. CARUSO:  Slide 6, no, that's done. 
           That's done.  Slide 7.
                       CHAIRMAN APOSTOLAKIS:  So, excuse me,
           Ralph, are you going to spend all this time on each
           slide from now on?
                       MR. CARUSO:  I don't need to spend any
           time on this slide if you want to --
                       CHAIRMAN APOSTOLAKIS:  Okay.  Then you go
           to eight.
                       MR. CARUSO:  Okay.  The other Ralph takes
                       CHAIRMAN APOSTOLAKIS:  The other Ralph
           takes over.  Okay.
                       MR. MEYER:  I have four slides, and I only
           plan to speak to the first two.
                       MR. POWERS:  These are the slides that
           you're going to discuss?
                       MR. MEYER:  The upper half of the first
                       MR. POWERS:  Could I ask a question,
           Ralph?  Will the slides that you provide us give us
           some understanding of why this research is irrelevant?
                       MR. MEYER:  I didn't understand you, Dana.
                       MR. POWERS:  Well, one of the questions we
           were trying to understand is why NRR considers the
           research irrelevant.
                       MR. MEYER:  Yes.
                       MR. POWERS:  And I'm wondering if your
           slides are going to tell us why it's irrelevant.
                       MR. MEYER:  My slides are going to tell
           you why I think what we're doing is important.
                       MR. CARUSO:  As I explained at the very
           beginning of my discussion, we consider the use of
           that word to be unfortunate.  And we value the work
           that is done by the Office of Research, and I don't
           think I personally would characterize the work as
                       MR. POWERS:  But the fact of the matter is
           that in the written documentation remains irrelevant;
           is that correct?
                       MR. CARUSO:  The document was signed, and
           it's in the document system, and that's correct.
                       MR. KRESS:  I guess the broader question
           is does NRR still think there is a need for a user
           need letter on this research?
                       MR. CARUSO:  Actually, then we're going to
           have to go back to the previous slide.
                       CHAIRMAN APOSTOLAKIS:  This is the
           fundamental question.
                       MR. KRESS:  Yes.  Let's go back to the
           previous slide.
                       CHAIRMAN APOSTOLAKIS:  This is the
           question that needs to be answered.
                       MR. CARUSO:  The user need process in the
           Agency right now evaluates -- user needs are evaluated
           against these four criteria.  These are the four
           Agency pillars:  Maintaining safety, improving
           efficiency, reducing unnecessary regulatory burden and
           improving public confidence.  Until last Thursday, we
           had no licensing actions under review which required
           the results of the research --
                       MR. WALLIS:  I'm sorry, Ralph.  Do you
           think your broad brush curve satisfied Criteria 4? 
           And if it doesn't, what are you going to do about it?
                       MR. CARUSO:  Well, what we do is we
           evaluate against all four of the criteria.
                       MR. POWERS:  How do you do that?  How do
           you evaluate Number 4?
                       MR. CARUSO:  We have decisionmakers who
           sit around in a room and talk about it.
                       MR. POWERS:  Maybe you should make your
           presentation to some intelligent technically
           knowledgeable members of the public, see if that
                       MR. CARUSO:  Well, all I can say is this
           is what we do.  And we rank each proposed user need
           against these criteria.
                       CHAIRMAN APOSTOLAKIS:  But the criteria
           are not equally weighted.
                       MR. CARUSO:  They are equally weighted, at
           least in NRR they are.  NMSS, I believe, has weighting
           factors for different criteria.
                       CHAIRMAN APOSTOLAKIS:  Maintaining safety
           and improving public confidence is equally weighted?
                       MR. CARUSO:  Well, in NRR right now the
           criteria are weighted equally.
                       CHAIRMAN APOSTOLAKIS:  See, now we can
           talk about it forever.  I mean which public are you
           talking about?  But, anyway, why don't we let you go
                       MR. CARUSO:  As I said, until last
           Thursday, we had no licensing actions under review
           which required the results of the research high burnup
                       MR. POWERS:  That's the one I've never
           understood on this.  It seems to me that you have all
           kinds of things here.  You've got a Regulatory Guide
           that's in desperate need of amendment.  You've got a
           topical report there that seems to have a fairly
           interesting selection of criteria.  I mean just in
           your own presentation I think I counted three or four
           different things that were on your plate that seemed
           to address them, required information from the
           Research Program.
                       MR. CARUSO:  Well, this report, as I said,
           arrived last Thursday.  I didn't expect this report to
           contain the information it does.  I expected it to
           contain information about burnup above 62, not below
           61.  And the Research Program is not aimed at burnups
           above 62, it's supposed to be confirming values for
           burnups below 62.
                       So in addition, you asked about these
           regulatory criteria that desperately needed to be
           revised, and I guess I would take issue with that
           characterization of the need to revise the Regulatory
           Guides and the SRP.  We know they need to be revised. 
           We want good data to be provided to us, but that data
           isn't going to be provided to us for at least several
           more years.  And in the interim, I have licensing
           actions that I have to make that I cannot delay until
           this information comes out, until it goes through a
           public comment period, till it comes to the ACRS,
           several times probably, goes to the CRGR and is
           debated.  I have to make a licensing decision in the
                       MR. WALLIS:  You can turn down --
                       MR. KRESS:  You're also going to have to
           make licensing decisions later on when you could
           really use that data.
                       MR. CARUSO:  And I will.  I will.  I will
           use that information when it eventually comes out. 
           I'm not saying I'm going to ignore it.
                       MR. KRESS:  Okay.  Isn't that a criteria
           for a user need letter, "I'm eventually going to need
           this to make better decisions?"
                       MR. CARUSO:  I guess I'm going to go to my
           bottom line right now, which is to say that the user
           need program, we recognize, needs some work, and we
           are in the process of revising it.  And this issue
           will be one of the things that will be considered as
           part of the revision to the user need process. 
           Agencies try to work on a prioritization scheme for
           user needs, how to do this in an integrated fashion
           between the offices, and --
                       VICE CHAIRMAN BONACA:  You know, you could
           characterize your situation as one that says, "I have
           to make decisions.  Therefore, I'll make decisions
           with whatever information I have.  And what I have I
           can use."  I can understand your position, but --
                       MR. CARUSO:  That's the position I'm in
           right now.
                       VICE CHAIRMAN BONACA:  Wait, wait.  But if
           I were in your shoes, I would say, "However, I don't
           have enough information, and therefore I'm hardly --
           I'm pressed to have this data as soon as possible." 
           I would feel that way, because what you presented to
           us wasn't very convincing.  And instead you're saying,
           "I don't have enough information to do the work, but
           I can live with that, and whenever the information
           will come, then I will do that.  And if it comes in
           several years --
                       MR. CARUSO:  I would like to have more
           information, but right now we don't have it.
                       VICE CHAIRMAN BONACA:  The reason why I'm
           making a comment is that that comment is pertinent to
           the recommendation to RES on whether the work they're
           doing is important or urgent or whatever enough to
           justify stepped up effort or slow down effort or
           whatever.  That's why I'm making an observation.  I
           mean to me, particularly on the part of the users,
           depending on how you feel pressed for that information
           to back up what you have, which is not much.  Okay? 
           Then that will give some kind of impetus to the work
           that RES is doing or slow it down.
                       MR. CARUSO:  I'm not sure how much I could
           speed it up.  I mean the CABRI program is proceeding
           at the speed it's going to proceed, and I don't think
           I have any effect on whether it proceeds quickly, more
           quickly or not.  Can we make the CABRI program go
                       MR. MEYER:  No.
                       MR. CARUSO:  No.
                       VICE CHAIRMAN BONACA:  No, but you could
           kill it.  I mean --
                       MR. ROSEN:  It's not a U.S. program.
                       MR. CARUSO:  NRR has not taken a position
           that the CABRI program should be killed.  We think
           this is valuable research.
                       CHAIRMAN APOSTOLAKIS:  What did you say,
           Ralph, I'm sorry.
                       MR. CARUSO:  It's valuable research.
                       CHAIRMAN APOSTOLAKIS:  Okay.
                       MR. CARUSO:  But then I've got to -- what
           does the word "need" mean?  My management is about to
           shoot me.  What does the word "need" mean?  We don't
           know.  This is not a well-defined term.
                       CHAIRMAN APOSTOLAKIS:  So the bottom line
           then is what?
                       MR. CARUSO:  The bottom line is that this
           is not a --
                       CHAIRMAN APOSTOLAKIS:  There is no user
                       MR. CARUSO:  Under the current definition
           of "user need," which we have in the office, this is
           not a user need.
                       CHAIRMAN APOSTOLAKIS:  Was it at any one
                       MR. CARUSO:  Yes, it was.
                       CHAIRMAN APOSTOLAKIS:  What changed since
           that time?  The definition of "user need" changed?
                       MR. CARUSO:  You're asking me a policy
           matter, which I can't address.
                       MR. HOLAHAN:  I can give it a try.  This
           is Gary Holahan at NRR.  I think the issue of user
           need is a confusion factor that we're trying to work
           into a better process.  At the moment, user need
           really means identifying who's the sponsor, who's
           responsible for saying, "I want this money spent.  I
           want this agency money spent on this subject and not
           on other subjects."  At the moment, when NRR says this
           is a user need, we're saying we're responsible.  We
           want this information, and no one else has to justify
           why this program is being done.
                       At the moment, NRR says we have, and have
           had since 1997, interim criteria which provide a 
           reasonable basis for meeting the general design
           criteria.  In fact, many people would say at least 100
           conservatism between 100 calories per gram and
           challenging vessel integrity or probability of the
           core.  And under those circumstances, we could live
           with the interim criteria.
                       I recognize that we don't  have complete
           control over these programs.  If the Japanese and the
           French decide to shut down those test facilities and
           take the interim criteria and go through the process
           of public comment and all that, those will be the new
           criteria for the Reg Guide and the Standard Review
           Plan.  We could live with that.  That doesn't say
           there's no value to the research.  It doesn't say that
           it isn't a good thing to do and that we wouldn't use
           it if the data was generated.
                       The question is who is causing the data to
           be generated.  Is it because NRR has said, "I need
           this information whether anyone else wants it or not"? 
           And until last Thursday, I don't think we could say
           that, because we had an interim position for a low
           probability event for which we have a very
           conservative criteria, no clad failure for a ten to
           the minus six event is the most conservative criteria
           among accidents.  What we've said is last week EPRI
           and NEI sent us a new report, and when we look at that
           report we'll relook at the question of what technical
           support, what research program and what assistance
           from the Office of Research we need in reviewing that
           topical report.  So each time we have a new set of
           regulatory issues before us, we go back and we ask
           that question.
                       And the question in my mind now is are we
           in a position to review this topical report and the
           issues that it puts on the table without additional
           research?  And we don't have an answer to that yet. 
           We just got the report.  We'll look at it and we'll
           reconsider.  And it may be that we decide that there's
           a real user need or it may be that we don't need that
           and we'll review the report under some other --
                       MR. POWERS:  Gary, you've indicated that
           you can live with the interim criterion.
                       MR. HOLAHAN:  Yes.  And we have been.
                       MR. POWERS:  And what I will point out
           that based on the discussion for the last 40 minutes,
           you may be very content with them, but you have a very
           hard time convincing other people that those are
           useful criteria.
                       MR. HOLAHAN:  I heard that.
                       MR. POWERS:  So I will draw your attention
           again to Mr. Wallis' point in your fourth criterion on
           whether you have a user need or not.
                       MR. WALLIS:  My impression is you have a
           tremendous user need, unless there's something I
           haven't heard today that this seems to be a problem
           that's been going on for a long time, that decisions
           have been made based on very tenuous information.  Now
           maybe I'm completely wrong.  Maybe you've given me
           completely the wrong impression, but that's the
           impression that's given.
                       MR. POWERS:  What I will point out to you,
           Graham, is that this decisionmaking that went on was
           presented to this Committee.  This Committee has
           supported it, but with the caveat that there was a
           strong Agency plan supported strongly by NRR with a
           user need to conduct the research to validate that. 
           And now that component that led to a fairly
           enthusiastic endorsement of what was going on seems to
           be missing here.
                       MR. KRESS:  I think we've discussed this
           a lot.  Can we wrap it up pretty fast, Ralph?
                       MR. MEYER:  Could I suggest that maybe you
           just view the slides, and if you don't want additional
           presentation, I'd be happy to go quickly or just not
           at all.
                       MR. POWERS:  Well, let me just ask you
           this question, Ralph.  Your slides are indeed fairly
           explicit, but at what point -- do you have any insight
           right now on what point it would be useful for a
           Reactors Fuel Subcommittee to assemble and look at
           your program again?
                       MR. MEYER:  Yes.  I think it's time very
           soon for that.  We have been doing that about once a
                       MR. POWERS:  Right.
                       MR. MEYER:  And we didn't schedule one
           this spring.  So I think we should.  There have been
           developments in the last year that are significant, 
           and it would be a good idea to do that.
                       MR. POWERS:  Yes.  I think that just
           anticipating the ACRS' obligations, we are obligated
           this year to produce a fairly comprehensive research
           report, and it would be useful to have a meeting so
           that we can prepare this section of that report.  So
           maybe if you guys can find a time that's convenient. 
           I don't want to hit you at a time when everything's
           chaos and whatnot, but some convenient time maybe we
           could find a mutually satisfactory time to do this,
           because just looking at your slides there's a lot of
           interesting stuff.
                       MR. MEYER:  I would suggest that the
           Subcommittee might also want to look at the EPRI
           topical report.
                       MR. KRESS:  That's a good idea.
                       MR. MEYER:  And I think within a few
           months the staff will have time to look at it and
           generate some positions, and in fact you might want to
           hear from them as well.
                       MR. POWERS:  Maybe some coordinated thing
           between the two of them.
                       MR. MEYER:  That would be a good idea. 
           We've had that happen before.
                       MR. POWERS:  As long as we have the
           information so that in the fall of this year we can
           prepare our research report, that would be useful.
                       MR. SIEBER:  I'd also like to ask a favor. 
           The three slides that you used that were graphics, if
           you could make us copies and provide us a copy.
                       MR. CARUSO:  I'll get them.
                       MR. SIEBER:  The other thing, I noticed
           that the one slide which you said came from
           Westinghouse, is that proprietary?
                       MR. CARUSO:  It's not proprietary.  The
           document itself is proprietary, but this page is not
                       MR. SIEBER:  Okay.
                       MR. CARUSO:  It doesn't have the brackets
           around it that indicate proprietary.  And I
           specifically asked them if I could do that.  It's not
           actually proprietary.
                       MR. KRESS:  I want to thank the speakers. 
           This was a useful exchange of views, I think.  And we
           appreciate you coming down.  With that, I'll turn it
           back to you, Mr. Chairman.
                       CHAIRMAN APOSTOLAKIS:  Thank you.  I don't
           think we will need transcription for the next session. 
           Thank you.
                       (Whereupon, at 2:26 p.m., the ACRS meeting
           was concluded.) 

Page Last Reviewed/Updated Monday, July 18, 2016