ACRS Meeting on Fire Protection - January 20, 1999

                       UNITED STATES OF AMERICA
                        U.S. Nuclear Regulatory Commission
                        11545 Rockville Pike
                        Room T-2B3
                        Rockville, Maryland
                        Wednesday, January 20, 1999
         The above-entitled meeting commenced, pursuant to notice, at
     8:33 a.m. 
         DANA POWERS, Chairperson, ACRS
         THOMAS KRESS, Member, ACRS
         DON MILLER, Member, ACRS
     .                         P R O C E E D I N G S
                                                      [8:33 a.m.]
         CHAIRMAN POWERS:  Let's bring the meeting to order.  This is
     a meeting of the ACRS Subcommittee on Fire Protection.  I am Dana
     Powers, Chairman of the Subcommittee for Fire Protection.
         ACRS members in attendance are George Apostolakis, Tom
     Kress, and we expect to be joined by Don Miller.
         The purpose of the meeting is for the subcommittee to review
     the reactor fire protection activities, the insights gained in the fire
     protection area from the view of licensee submittals of Individual Plant
     Examinations and External Event Reports, result of the Pilot Fire
     Protection Functional Inspections, Electrical Circuit Analysis, proposed
     NFPA Fire Protection Standard and related matters.
         The subcommittee will gather information, analyze relevant
     issues and facts and formulate proposed positions and actions as
     appropriate for deliberation by the full Committee.
         Amarjit Singh is the Cognizant ACRS Staff Engineer for the
         The rules for participation in today's meeting have been
     announced as part of the notice of this meeting previously published in
     the Federal Register on December 18th, 1998.
         A transcript of the meeting is being kept and will be made
     available as stated in the Federal Register notice.
         It is requested that speakers first identify themselves and
     speak with sufficient clarity and volume so that they can be readily
         We have received no written comments or requests for time to
     make oral statements from the members of the public.
         This is going to be an action-packed meeting of the Fire
     Protection Subcommittee.  It seems that both the Staff and the industry
     are hyperactive in this area in recent weeks.
         We have invited Dr. Miller, who is the Chairman of the I&C
     Committee in our answer to Reddi Kilowatt for the ACRS to assist us in
     what is rapidly becoming one of my favorite issues, both now and when I
     was 17, the issue of Hot Shorts.
         CHAIRMAN POWERS:  As this issue has unfolded, it looks like
     it may be a good deal easier to resolve than I had anticipated.  The
     industry positions include licensees have effectively implemented the
     applicable regulations and the issues raised by the Staff either do not
     exist or are outside the regulatory requirements or licensees have made
     a good faith effort to implement the applicable requirements but
     implementation may not be 100 percent for a variety of reasons including
     mixed guidance from the Staff or circuit analysis issues raised by the
     Staff are covered by existing regulatory requirements and to the extent
     they have not been implemented, additional actions by NRC is warranted,
     and my understanding of course is the Staff has divergent views on
     these.  It sounds like an easy issue.
         One of the issues that is emerging in connection with fire
     shorts is the issue of risk analysis and I will be particularly
     interested in Professor Apostolakis's views on the risk analyses,
     because to my mind a lot of the risk analyses that have been presented
     seem to be persuading me that Browns Ferry did not occur.
         The next issue we will be dealing with is the Fire
     Protection Functional Inspections.  This is an evolving issue, it seems
     to me.  It seems to be raising questions about what the Staff is
     inspecting and what it should be inspecting in our fire protection
         Of course, one of the highlights of this meeting will be the
     NFPA draft standard on fire protection.  This is the much-awaited
     performance-based fire regulation.  It is, however, a far cry from the
     one-page regulation that Professor Catton used to argue passionately
     for.  In fact, I would characterize the NFPA standard as the Prego
     Spaghetti Sauce Standard.  If you like defense-in-depth, it is in there. 
     If you like determinism, it's in there.  If you like performance, it's
     in there.  If you like risk, it's in there -- and in fact I think Dr.
     Kress will find substantial validation of some of his views on
     performance-based regulation embodied in this draft standard.
         The topic of focus in tomorrow's session will be the
     much-awaited Research Program, and it is the chore before the Committee
     to develop its input to the ACRS's report on research based in part on
     this material, and I will probably ask Dr. Kress to draw upon his wide
     breadth of experience and preside over that session.
         With that introduction, and insights on all that we have to
     accomplish, I want to turn now to Tad Marsh to give us some additional
     insights and perspective on this with his Overview of Fire Protection
     Activities within the NRC.
         MR. MARSH:  Thank you.  Good morning.  My name is Tad Marsh
     and I am Chief of the Plant Systems Branch, and I do want to say I am
     looking forward to this meeting.  I am looking forward to the
     discussions and I am looking forward to synergism and there's a lot of
     very good topics and I am looking forward to this action-packed meeting,
     I really am.
         CHAIRMAN POWERS:  Tad, let me just interrupt you.  I omitted
     discussion of some of the real groundrules for the meeting.
         Subcommittee meetings are the one opportunity the ACRS has
     to get into depth into an issue and we have an agenda and a schedule,
     but I think speakers should concentrate on getting their points across
     to us and let Mr. Singh and I worry about the schedule.  We are
     scheduled to go to 4:30.  I had promised the members 5 o'clock and I
     guarantee them 6:00, so we have got some flexibility here, and I'd
     comment that members of the audience should feel free to interject
     points that they think would help clarify our understanding here, but
     recognize, however, that I have my back to you, so that if you want an
     input, get attention, but feel free to do so because this should be a
     very collegial exchange.  I believe the Staff feels that way.  I
     certainly feel that way, so that we can get as much input as we can in
     this session.
         MR. MARSH:  Thank you.  Thank you very much.  I am glad you
     said that because I have said the same thing to our staff, especially in
     the context of the NFPA 805, which is a document that is going through
     change and is being developed and about which we have mixed views, and
     so as we present or as industry presents things, I have encouraged folks
     to go ahead and chime in.  I am looking very much forward to that
     discussion.  We were dry-running this yesterday it's going to be good.
         But I want to step back for a minute, talk about the big
     picture on fire protection and what's been going on because it's been a
     very active, very fluid situation in terms of fire protection from the
     last time that we spoke.
         There have been three forces which have been guiding us and
     changing us in fire protection within the last year.  One main force is
     of course the Agency's emphasis in becoming more risk-informed in
     everything that it does.  You will hear as we go through the
     presentations risk elements in almost each one of these presentations,
     and well it should be.
         You are also going to hear some of our frustrations and some
     of the difficulties associated with going in that direction and that
     will become clear to you.
         The next force is this new assessment process the Agency is
     working on.  That has a strong influence on where we go on the fire
     protection functional inspections, and it even plays out in some of the
     circuit analysis issues which we are going to talk about.
         The third force which has been guiding us and moving us in a
     direction this year is not a new force but it is one which has been
     emphasized by the Commission's interactions with stakeholders, et
     cetera, and that is working more closely with the industry in some of
     these endeavors, and in all of the efforts you are going to hear about
     today there's been work with the industry -- sometimes a great deal of
     interaction, sometimes less so, but there have been a lot of
     interactions with the Agency.
         I'll start by giving you an overview of the fire protection
     functional inspection, and that is going to be Pat Madden giving his
     presentation.  This is I think in my opinion one of the most important
     things we have done this year, maybe the most important thing we have
     done this year, because we have looked very hard at four plants and the
     state of their fire protection programs, and we have come with findings
     about how we think things are.
         As we expected, there are weaknesses there in programs.  Now
     the challenge is to decide where to go, what is the future of the FPFIs,
     and that is a decision that the Staff will have to make a recommendation
     to the Commission about.  That decision will be probably some time in
     the early spring.  We have a paper which is due to the Commission -- it
     was intended to be at the end of this month.  It's now been delayed
     until next month, the February timeframe.  We did that because we needed
     industry input.  We needed industry recommendations on how they see the
     FPFI program, what views they may have on how to go in the future, and
     how that should and could fit into the final assessment process which
     the Agency is working on.
         Enforcement issues in the context of FPFIs have become
     something which we have focused on.  The Agency is using risk insights
     in enforcement issues and that has become a challenge, and so as these
     FPFI findings are to be processed through the enforcement process, the
     risk associated with those findings has become something that we are
     striving to determine and it is again an area which is not easy, and you
     will hear some discussion about that as we go through the presentations.
         CHAIRMAN POWERS:  One of the things that comes clear to me,
     I think should be clear to me, maybe you can correct me if I am wrong,
     is that FPFI is really raising questions about how we organize our
     inspections and what should be inspected and what should not be
         Now you are raising a different issue -- do we have the
     tools that will allow us to actually assess risk in what happens to be a
     context of enforcement but risk in general --
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  -- here in a reliable and believable
         My sense is that we are a little inconfident in that area,
     not because we know that the tools are inadequate but because we know
     they have not received the kind of scrutiny we have applied to tools
     such as we use for normal power events and things like that.
         MR. MARSH:  Right.  I would agree.
         CHAIRMAN POWERS:  And I think that is where tomorrow
     afternoon's session, where Nathan Siu will discuss both the Research
     Program and the IPEEE, but I think we will interrogate him quite
     closely, because I think he is knowledgeable in the status of these
     tools, what we ought to be doing and where we ought to be going.
         One question to present to you, as an overall question for
     the meeting, Tad, is are there things that we should be planning to
     bring forward to the ACRS either at its February meeting or its March
     meeting.  It sounds like the March meeting is appropriate for this paper
     on the functional fire protection --
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  -- inspections, but if there are things
     that you think should be brought forward to the ACRS or the members
     identify to bring forward, let's flag those immediately.
         MR. MARSH:  Okay, fine.  Can I -- let me hold that question
     and we can think about it as the meeting goes on.
         CHAIRMAN POWERS:  Yes, that is an overall question for
     whenever it comes to mind.
         MR. MARSH:  The FPFI program is -- I don't want to overuse
     the term but is "out in front" of a lot of Agency efforts and it is
     maybe symbolic of a lot of Agency change.  It is a major inspection
     effort.  We are not doing very many of those any longer.  It came from
     concerns that were older concerns but they dealt with the adequacy of
     fire protection programs and features coming from the Thermo-lag
     experience and self-assessments.
         Now that we have done those inspections, again we are right
     on the cutting edge of how do we factor risk into whether a program
     should continue, how do we factor the future into this assessment
     process, how do we work with the industry in coming up with a viable
     program which is a better use of resources and a better, more
     coordinated effort -- and risk itself -- in this program, and
     enforcement actions.
         I led off with FPFIs as perhaps the most important thing
     that we have done this year because it is out in front so much.
         CHAIRMAN POWERS:  I think your assessment is correct, by the
     way, and I'll also point out that as we moved in this area in risk we
     were also running into the difficulty that the public has when presented
     with risk assessments.  They see things that from a lay deterministic
     viewpoint seem to be risk-significant --
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  -- but from a quantitative point of view,
     a systematic analysis, may not be, and discontinuity from perception and
     quantitative analysis seems to come forward more clearly in fire
     protection than any other area, perhaps because the lay public
     understands the threats of fire better than it understands other
         MR. MARSH:  I think that is a good insight.
         We have stylized ways of analyzing scenarios in accident
     analyses in Chapter 15 and in licensing bases.  We analyze LOCAs, we
     analyze feed line breaks and steam line breaks and we have Standard
     Review Plans that tell you how to do that, and we come up with answers
     about whether things are protected and whether the DMBRs are exceeded
     and whether the PCT limits are met, and those types of stylized,
     artificial measures of safety of plants, and they construct procedures
     and features and measures to protect against those stylized ways.
         Well, fire protection is another stylized licensing bases
     type of construct.  We have layers of defense-in-depth and we come up
     with answers about whether systems and features are adequate to protect
     against these challenges, but we lack the opposite approach that we have
     in normal accident analyses.
         We have pretty good tools to assess risk associated with
     LOCA and feed line breaks, and we don't have that counter approach in
     the fire area, and from the public's perspective fire is something that
     people understand.  Fires are things that they see, that they hear
     about, and it presents a personal challenge to them, unlike LOCA, feed
     line break, steam line -- people can't empathize with those scenarios. 
     They don't know what that means.
         CHAIRMAN POWERS:  They don't have LOCAs in their house very
         MR. MARSH:  But they understand fire.
         The second issue which we are going to talk a lot about is
     one Steve is going to present, and this circuit analysis and that has
     presented a unique challenge too, because there are disagreements with
     the industry over what the Staff now believes to be the licensing
     requirements for plants, what the regulatory requirements are, as
     opposed to what the industry has presented to us as being what they
     believe the Staff's licensing requirements were.
         Risk plays an element here too.  You will hear from Fred
     Emerson, NEI, tomorrow I believe, or perhaps later on today industry's
     approach in resolving this problem, which has embedded in it a risk
     element as well as a stylized deterministic element and which again
     encompasses risk.  There is a challenge here in understanding and trying
     to evaluate the probability and the consequences of some of these
     circuit failures, so again adequacy of tools has become an issue.
         I am looking forward maybe most to our discussion about 805
     because it is so new, and it is so novel, and it present discussions
     about how licensing requirements and fire protection requirements
     compare to this new document, and it will be a lively discussion.
         I mean I think that it is a difference construct of fire
     protection requirements that we have heard before, and so it will evoke
     all kinds of questions about circuit requirements and baseline
     requirements, and what is important, and how licensees could actually
     use this.  That will be an interesting discussion.
         Another thing that is on our plate that I want to make sure
     you know, and I think we have talked to Jit about this, is the
     Commission meeting that is coming up February 9th, okay.  We will be
     talking with them about the NFPA 805 document, the Comprehensive Reg.
     Guide, which is another important program we have ongoing, Quad Cities,
     the results of that evaluation and our assessment of that situation, and
     more discussion about the status of the research programs.
         Well, I didn't want to take much more time than that.  I
     wanted to give you an overview, and I hope I have.  And the thread that
     I would like you to see in these discussions is the three forces that
     are involved in each one of these endeavors, okay.  And the first force
     is the effort for the agency to move in a more risk-informed way in
     many, many things that we do.
         The other force that is involved is the assessment process,
     this new assessment process.  We are not going to spend a lot of time
     talking about that because we are not experts in it and because it is
     evolving, but it is pushing us in a way, especially in the FPFI program,
     cornerstones, performance indicators, things of that sort.
         And the third force is working with the industry.  In all of
     these endeavors we had been and been successfully working with the
     industry on these programs.
         Okay.  The first presentation is Ed.  He is going to be
     talking about the status and development of the proposed Reg. Guide, a
     Comprehensive Reg. Guide on fire protection.
         DR. POWERS:  Before Ed gets started, I will just comment,
     Tad.  I think that you have identified correctly the forces that are
     operating now, but I am willing to bet that as we move further in
     applications of risk, and as we move away from the traditional
     deterministic examination of fire protection, we will see an emerging
     force in the form of public dissatisfaction and legislative
     dissatisfaction with the persuasive power of risk as a metric of safety,
     and that is going to be a force, not active now, or only perceptible
     now, but one that we are going to have to confront directly as we go
     forward.  Because, as you have accurately pointed out, people do
     understand fire.
         And they are going to find surprising the kinds of
     conclusions that emerge from risk assessments, especially in situations
     where you have established an elaborate protocol of defense-in-depth so
     that you can tolerate deficiencies in one or more elements of that, or
     you can tolerate tradeoffs between the elements of defense-in-depth and
     still maintain a bottom line safety.  But it is going to be
     contra-intuitive to a lot of people, and you are going to find people
     grabbing ahold of elements of that, and castigating -- claiming to see
     how ridiculous this is.  Can't possibly be safe because, as everyone
     knows, you know.  Fill in the blank, there will be lots of things there.
         I think that is going to emerge as an issue, and it is not
     going to be one that is going to involve presentations in front of
     committees like this.  It is going to be that manifests itself within
     the legislative branch.
         MR. MARSH:  I agree.
         DR. POWERS:  Ed, welcome to the meeting, and you are going
     to discuss the Comprehensive Fire Protection Regulatory Guide.  You come
     here with some courage, because I think it is well known that this
     subcommittee was not in favor of this activity.
         MR. CONNELL:  Well, maybe I can change your mind a little
     bit.  Good morning, my name is Edward Connell, Senior Fire Protection
     Engineer in the Plant Systems Branch at NRR and I have a little
     presentation this morning on the Comprehensive Fire Protection
     Regulatory Guide.
         A little refresher background information, as most are
     aware, the existing NRC guidance on fire protection is scattered through
     many, many documents, different kinds of documents spanning many
     generations, even some of it before the Brown's Ferry fire in 1975, and
     I think --
         DR. POWERS:  None of it pre-dated Jit, right?
         MR. CONNELL:  No, no.  No.  And this is just to give you an
     idea.  We have about 17 Generic Letters, seven Bulletins, an
     Administrative Letter, 71 Information Notices, and I am not going to go
     through all them, just to kind of make my point that there is a lot of
     stuff out there.  It takes up five binders on my desk, so --
         DR. POWERS:  It takes up five binders on my floor.
         DR. APOSTOLAKIS:  Why?
         MR. CONNELL:  You are asking why does it take up five
         DR. APOSTOLAKIS:  Yes.
         MR. CONNELL:  Because there's over 125 documents.
         DR. APOSTOLAKIS:  And why are there over 105 documents?
         MR. CONNELL:  Because that's how many were issued.
         DR. APOSTOLAKIS:  And why were they issued?
         MR. CONNELL:  You are asking me why stuff was issued in 1975
     till 1998?  I don't know.  The staff saw a need to issue guidance,
     Information Notices, Generic Letters, internal memoranda, Administrative
     Letters, Bulletins, Standard Review Plans, Branch Technical Positions. 
     The staff saw a need and issued that guidance.
         DR. APOSTOLAKIS:  I mean what is so special about fire
     protection that led to all this?  I mean did this happen in other areas?
         DR. POWERS:  Well, I think what you find is that -- two
     things.  Yes, fire is special.  There is no question about it, fire is
     special.  And that you find that our learning about fire has been
     different than it has been about LOCA and nuclear incidents, that we
     thought we had a handle on fire and we have thought we had a handle on
     fire, every year we think we have a handle on fire, and we discovery new
     things, a new diversity of things.  At the same time, there have been
     imperatives, and I think one of the presentations that is in your
     briefing book accurately reflects the imperatives that come along and
     cause crunches to get things out, so it has led to an incrementalism in
     documentation and whatnot.  And this is -- Ed is discussing an effort to
     try to wrap this up into one package.
         MR. CONNELL:  Well, I think, you know, the objective is to
     simplify and consolidate the existing guidance into one place, because,
     let's face it, we have guidance that spans over 20 years.  And if you
     look at the second bullet there, you know, some of the existing
     guidance, no surprise over a period of time like that, with over 125
     documents, some of the existing guidance conflicts.  And I pulled out
     three little examples, these are simple examples of where the guidance
     conflicts and what the difference would be depending on which guidance
     document is being used by the licensee or the staff to review a
     particular program.
         So I think it is worthwhile to try to do a scrub of that
     guidance and simplify it.  My goal would be to reduce the five binders
     down to one.  About 25 percent of what we currently have, as far as
     number of pages, and I will be satisfied if we get down to about a
         DR. POWERS:  Set aggressive goals, Ed.
         MR. CONNELL:  Well, yeah, sure.  And revise them as
     necessary as you go along.
         DR. APOSTOLAKIS:  I still don't understand.  Why will you be
     able to do that now and you were not able to do it 15 years ago?
         MR. CONNELL:  Well, there was no attempt to do it.  Well,
     there was one attempt to issue a Reg. Guide many years ago in the early
     '80s.  The staff did issue a draft Reg. Guide, Reg. Guide 1.120, that
     attempted to do this, and then it fell off the table.  But that was many
     years ago, George, and not many of the people that are here today were
     involved 20 years ago in the project, so I can't tell you why a specific
     document was issued 20 years ago.  The staff felt there was a need, they
     issued the guidance.  We are trying to do a scrub of that now, we think
     it is time.
         DR. APOSTOLAKIS:  Is the state of knowledge now different,
     that it will allow us to do this?
         MR. CONNELL:  That is not the concern.  The issue is we are
     basically, with this project, we are going through the existing
     guidance, looking where there's holes, and I will give you some examples
     further along in my presentation where we think that the guidance is
     either not there or is lacking, but it is not a state of knowledge.  It
     is not something like, well, we have PRA today, we didn't have it 20
     years ago, so that impacts this guidance.  That is not the point here.
         MR. MARSH:  One of the forces that drove us to do this was
     an acknowledgement on our part, a concern on the Commission's part and
     on the public's part about the clarity of the fire protection
     requirements.  They have existed over a long span of time.  They have
     evolved.  They are reactionary.  They are many volumes, and it is not an
     easy subject to explain, okay, because there are so many documents out
     there and so many requirements out there.
         So the effort here is to try to synthesize and to be more
     cogent in what the requirements are.  I am not sure that there are other
     programs out there that could also benefit from this type of effort,
     too.  I mean I think EQ is an area that -- environmental qualification
     is an area which suffers from evolving guidance, NUREGs, Standard Review
     Plans, things that are difficult to explain.  And the effort here is to
     clarify what the licensing requirements and the agency's guidance is.
         DR. APOSTOLAKIS:  Well, in one of your earlier slides, as an
     example of conflicting or inconsistence guidance, you had the maximum
     length of hose per hose station, 75 feet versus 100 feet.
         MR. CONNELL:  Yes.
         DR. APOSTOLAKIS:  So what you are doing now is you are going
     to clean up the regulations and say the maximum length of hose is X?
         MR. CONNELL:  Well, we are going to clean up the guidance. 
     Most of this stuff is not in the regulation.  We are going to clean up
     the guidance so that we don't have three different, conflicting guidance
     for a particular topical area.
         DR. APOSTOLAKIS:  But you are not actually asking yourself
     whether giving guidance on the maximum length makes sense.
         MR. CONNELL:  Well, we are asking that, too.  Yes, we are
     asking -- if we decide that maybe we don't need to provide guidance as
     far as maximum hose length, we will take that away.  That will also
     eliminate the conflict.
         DR. APOSTOLAKIS:  And this will come from the current state
     of knowledge, I assume.
         MR. CONNELL:  Yes.
         DR. APOSTOLAKIS:  Which is risk-informed and
         MR. CONNELL:  Well, I don't you are going to come up with
     hose length out of a PRA.  I don't think that is going to give you that
     kind of information.
         DR. APOSTOLAKIS:  But the PRA perhaps will tell you whether
     you need such kind of guidance?
         MR. CONNELL:  I don't see how the PRA is going to tell you
     whether you that need that kind of guidance.  Most PRAs don't credit
     minimum suppression capability.
         DR. APOSTOLAKIS:  But will you attempt to identify the needs
     form a risk assessment perspective?
         MR. CONNELL:  We will identify the needs from the feedback
     that we get internally and externally within the agency and with the
     stakeholders, the industry and the public, identify those topical areas
     that they think need to be addressed in a fire protection guidance
         DR. APOSTOLAKIS:  Okay.
         MR. MARSH:  I don't think -- the idea, as we had envisioned
     it, was to take the existing unclarity and clarify.  Not so much to go
     forward, you know, and to superimpose or to change the guidance based on
     new tools and technology, because we don't know yet how that is going to
     play out, the 805 is going to play out, and how the -- that is kind of
     moving forward more than this effort was intended to do.
         This effort had, in my mind, a clarity, a simplicity to it,
     and it was an effort to do the job better, to take what is out there and
     to try to look at it collectively and say, gosh, look at how these
     things line up, or don't line up.  And what do you think the right
     answer is here with respect to what is out there, not with respect to
     where we need to go in the future.
         DR. APOSTOLAKIS:  Which means that you would not this
     Regulatory Guide risk-informed?
         MR. MARSH:  You know, I am not sure we have thought about
     that part of the formula here, to be truthful.
         MR. CONNELL:  Well, what we did think about was allowing
     risk-informed -- risk information to be used by licensees in the
     implementation of the guide.  We thought about that.  But we were not --
     at this stage, we were basically going to scrub existing guidance, add
     any -- add guidance for topical areas that were lacking or non-existent,
     and I have got some examples of those, and then allow licensees the
     opportunity to use risk information in the implementation of their fire
     protection program.  But the guide is not directly risk-informed, and
     the guide is not performance-based.  It is basically a scrub of the
     existing deterministic guidance.
         MR. MARSH:  Cleaning house is more or less what it is doing.
         DR. MILLER:  Is it safe to say that you are going to clean
     house, which is a challenge with 125 documents?  But if you have a
     situation where you have three hose lengths, who is going to decide
     which one is right, and what is the criteria you are going to use to
     make that decision?  Is it going to be risk-informed criteria involved
     there?  How is that going to play out?  Or do we know?
         MR. CONNELL:  Well, we are going to take feedback from this
     committee, from the public, from industry, internally in the staff, and
     whatever information we have -- I don't think you can use risk
     information to determine the appropriate hose length.  It just doesn't
     exist, it is an example.
         DR. MILLER:  Well, I am just using that as an example.
         MR. CONNELL:  So that one is going to have to be more of a
     committee type decision.  Well, what does everybody think is the best? 
     And is there a reason not to do something, or is there a better reason
     to do something else?  Or we may delete guidance altogether for hose
         DR. APOSTOLAKIS:  So what is the role then of the NFPA 805
     in this?
         MR. CONNELL:  There is not direct tie into the NFPA process,
     into this process.  What we will address is the objective -- if you
     remember option 2 in SECY-98-58, NFPA 805 was going to be an option for
     licensees to choose to change their licensing basis from their current
     prescriptive or deterministic license condition to a performance-based,
     risk-informed license condition by implementing NFPA 805.
         We anticipate that many licensees may not choose to do that. 
     If licensees choose not to select 805, this Reg. Guide would be the
     Comprehensive Fire Protection Guidance document for licensees that elect
     to maintain their existing license condition.
         DR. APOSTOLAKIS:  Okay.
         MR. WEST:  This is Stephen West.  I want to add one thing. 
     We really are trying to address some practical problems, day-to-day
     problems that exist, also through this effort, and that is that you have
     a regulation, say Appendix R, and behind that there's -- don't look at
     all 125 documents, but there are some significant guidance documents
     that back that up, some Generic Letters and Branch Technical Positions,
     Standard Review Plan, and there's people out there on both the staff and
     industry, licensees that are responsible for maintaining the programs or
     inspecting them, and they are just not familiar with this stuff.
         I mean they can look at something in Appendix R and say,
     well, the regulation says you need to do this, and the licensee may have
     done something else.  And what they are not familiar with are the
     Generic Letters, like 86-10, 81-12, 83-33, that provided guidance on
     what we meant by the regulation.  And it is a big problem, I mean it is
     a real problem out there for out inspectors, just trying to get their
     arms around this.  And thing, some things change from Generic Letter to
     Generic Letter.  And it just makes sense to try to distill all that
     information and put in one place what the actual guidance is, what the
     staff expectations are at this time.
         And we learned from the workshop we had on circuit analysis,
     I will talk a little bit about that later, that even licensees that are
     responsible for the programs are confused by some of the conflicting
     guidance, or trying to understand what guidance supersedes what
         MR. CONNELL:  Okay.  I'll go on and finish this slide up. 
     Of course, the Staff proposed this in March of last year in a paper to
     the Commission and the industry indicated last May that they supported
     this effort.  In June of last year the Commission approved the Staff's
     proposal to go forward with the development of the Guide.
         I've kind of covered some of these already.  I'll go quickly
     through it.  The Comprehensive Fire Protection Guidance Document -- this
     will be to satisfy general design criterion three of Part 50,
     Structures, Systems and Components Important to Safety -- fire
     protection for that is not solely related to safe shutdown.
         We want to replace the existing guidance documents, the
     list, the 125 plus documents, eliminate the conflicting guidance,
     simplify it, define the licensing and design basis for plants related to
     fire protection.  You're aware that plants licensed before January 1st,
     1979 had to comply with certain provisions of Appendix R.  Plants
     licensed after that date had to comply with the conditions in their fire
     protection license condition.
         There's been a lot of confusion about the plants that are
     basically evaluated against different criteria within the NRC, within
     the members of the public, Congressional inquiries, and licensees
     themselves seem to sometimes get confused about what really applies to
     them. Hopefully our goal will be to kind of clear that up and make it
     easily understood by everybody, because we get a lot of inquiries about
     how come this plant has to do this and this plant that is right next
     door is doing something else, and that doesn't make any sense, and what
     are you guys up to? -- so we want to clear that up.
         One of the areas that we think is lacking, almost
     nonexistent, Staff guidance is on compensatory measures, a very, very
     important area and if you look through that list of 125 documents that I
     provided you will find next to nothing on guidance on implementing
     compensatory measures -- fire watches, temporary protection,
     administrative controls, what have you.
         MR. MARSH:  So George, here is an area where I misspoke. 
     This is something that is filling a vacancy.  This is an area where we
     are going beyond something.  It is not just a clarifying.  This is
     providing something that we think is needed.
         MR. CONNELL:  The next bullet there, and I'll just cover
     that briefly, is circuit analysis, what our intent is.  You are aware of
     the NEI BWR Owners Group effort in this area.  Steve is going to make a
     presentation in a little while on it.  That will be inputed into the Reg
         Also the Staff believes that there is some need for
     self-induced station blackout and self-induced loss of offsite power,
     and this is where risk kind of comes into it a little bit, George.  We
     have some preliminary studies that show plants that do this, present a
     higher fire risk than plants that do not, so we want to address that
         Also, you are aware of the effort that the Commission is
     undergoing with looking at the 50.59 process and we would like to tailor
     that for fire protection as well, what changes can be made, what is a
     USQ under fire protection, what needs Staff review and approval, what
     does not -- so this is all good stuff that should be addressed.
         CHAIRMAN POWERS:  Right now though, 50.59 is the flavor of
     the day.  I mean that is an evolving target there.
         MR. CONNELL:  That's right.
         CHAIRMAN POWERS:  That may be a particular challenge, to try
     to meld yourself with something that keeps evolving.
         DR. MILLER:  Quicksand.
         CHAIRMAN POWERS:  Especially since at best you'll have one
     solution today and hopefully in two years another solution.
         MR. CONNELL:  Well, we can always revise Reg Guides.  That
     is the nice thing about them.  They are a lot easier to revise than
     issuing a whole bunch of new, conflicting generic letters or information
         Okay.  The status -- we initiated this effort following the
     Commission meeting in March.  We are getting some technical support from
     Pacific Northwest National Lab.  We started with them in June.
         In November we got a draft outline from PNNL.  I also wanted
     to mention part of this effort is the development of a database so we
     know where the source documents are for the different guidance, so if
     somebody wants to know, well, what's everything the Staff said on
     penetration steels.  Well, they can ask Pat or Steve or myself and we
     can spend an hour and pull all these things apart, but we are going to
     have a database now that says this generic letter says this, this
     information notice says this, this internal memorandum says this -- so
     we will have that available, and we think that is also a useful
     exercise, knowing where everything came from, what our history is.
         In December we made the outline and I believe the Committee
     has it, publicly available and we sent it to NEI requesting that they
     coordinate the industry review and get back to us on that.
         CHAIRMAN POWERS:  Did you expect specific feedback from ACRS
     on that outline?
         MR. CONNELL:  Sure.  That would be welcome.  We'd appreciate
         DR. APOSTOLAKIS:  Are we writing a letter any time soon?
         CHAIRMAN POWERS:  I get the feeling that there is likely to
     be a letter in connection with the paper that goes to the Commission in
     middle February, is that --
         MR. CONNELL:  Right.
         CHAIRMAN POWERS:  -- and so I would presume that the
     earliest we will be able to write a letter in connection with that will
     be at our March meeting.
         Now what we are going to remain alert for throughout this
     meeting is is there anything that we should be bringing forward to the
     February meeting, and stay tuned.  We'll find out as things go on.
         MR. MARSH:  May I make a suggestion that at the end of the
     meeting or towards the end we think about everything that has been
     talked about and what maybe you spend more time?  There's a lot of
     effort to go through this Reg Guide outline and in terms of feedback it
     may be better to look at FPFI in terms of circuit analysis than to spend
     a lot of your time looking at the outline.
         CHAIRMAN POWERS:  I think you are sensing what are some of
     the misgivings that the ACRS had about this activity and that just
     seemed premature, because there is so much else coming along.
         Now in your defense, the things I see coming along I don't
     think are going to persuade a fraction of the licensees to change their
     existing programs.
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  And so in a sense maybe this going to have
     utility no matter what all this other stuff does, but you can understand
     why the Committee might have misgivings and say, gee, it would be better
     to do this after we had all this other stuff in, and then we could make
     decisions about should there be guidance in this area or not.
         MR. MARSH:  I understand.
         MR. CONNELL:  Okay.  This is my last slide.
         What we are going to do is of course we will accept and
     review the stakeholder feedback on the draft outline.  We have a meeting
     scheduled in February, February 25th, to discuss the feedback on the
     outline.  Then of course we will take that feedback and go back and
     draft the actual Reg Guide itself and we'll issue the draft for public
     comment.  Our schedule is September of this year for that.
         MR. MARSH:  There is an important step between those two
     bullets, okay?  That is our process step, and that means go to CRGR --
         MR. CONNELL:  Right.
         MR. MARSH:  -- and discuss with CRGR about this document,
     how it should be couched, whether it should go out for public comment. 
     I mean there are major, in my mind, implementation backfit issues
     associated with a document of this sort, major issues.  Can't take
     coalescence of all of our guidance and say here it is -- this is what
     you folks should be complying with.  There are just major questions of
     that sort that will come out I'm sure in the public comment period, but
     we have to decide internally before we put it out as well.
         CHAIRMAN POWERS:  You are clearly going to run into the
     difficulty that a guy that got his plant licensed --
         MR. MARSH:  Absolutely --
         CHAIRMAN POWERS:  -- at document Number 67 and has his
     licensing basis --
         MR. MARSH:  Absolutely.
         CHAIRMAN POWERS:  -- that history is going to be in rough
     sledding relative to the plant that got licensed at document 124 --
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  -- and you are simply going to have
     accommodate that.
         MR. MARSH:  Have to face that.
         CHAIRMAN POWERS:  Where you have got a big backfit issue.
         MR. MARSH:  I think we need to face that, okay?  This is the
     first step of this process -- put it all together, find out what is all
     the guidance that is out there, and then at the implementation -- or at
     the implementation stage but in the decision-making leading up to
     implementation we have to decide what it means, what are the backfit
     implications.  Is it worth backfitting or not?
         First is to develop the guidance but there's a major -- the
     future holds major challenges in terms of where to go.
         MR. CONNELL:  And I did note the implementation and also the
     relationship with NFP 805 and different paths that would be pursued.
         That is the end of my prepared presentation.  I would be
     happy to answer any questions.
         DR. APOSTOLAKIS:  Yes, there are.
         This Guide right now doesn't really say very much, does it? 
     It just says --
         MR. CONNELL:  Which Guide is that?
         DR. APOSTOLAKIS:  Well, I mean the outline.
         MR. CONNELL:  It's an outline.  That's right -- just
     addressing the topical areas of the existing guidance plus the ones that
     the Staff believes need to be expanded upon.
         CHAIRMAN POWERS:  I think we need to at some time decide as
     a subcommittee how we want to address this outline, or do we want to
     address it?
         DR. APOSTOLAKIS:  Yes.  I was looking at the Fire Protection
     Program Goals and Objectives, which is Chapter 4, there is a lot of
     stuff there but I think at the end you will really be doing what you
     have been doing all along.
         Let me ask a couple of questions.  Maybe it is there and I
     don't see it.
         Defense-in-depth is defined here as prevention of fires,
     detecting and suppressing fires, and preservation of plant safe shutdown
     functions.  Then it goes to Fire Protection Program Performance Goals,
     and now we have safety-related structures, systems and components,
     post-fire safe shutdown, prevention of radiological release.
         Well -- these are also defense-in-depth.
         MR. CONNELL:  Well, defense-in-depth, if you look in the
     definition, Appendix R, is the way it is defined in here.
         DR. APOSTOLAKIS:  Well, we cannot have different definitions
     of defense-in-depth.  What is the difference between Appendix R?
         CHAIRMAN POWERS:  In defense of the fire protection folks,
     they are the only ones that do define defense-in-depth.
         DR. APOSTOLAKIS:  Which is?
         CHAIRMAN POWERS:  Exactly as stated.
         MR. CONNELL:  Yes, as stated in the draft outline here.
         CHAIRMAN POWERS:  Yes.  The only place in the regulations
     that the words defense-in-depth actually appears in Appendix R.
         DR. APOSTOLAKIS:  And it is defined.
         CHAIRMAN POWERS:  And it is defined that way so --
         DR. APOSTOLAKIS:  So prevention, protection, and
     preservation of safe shutdown, is that the definition?
         CHAIRMAN POWERS:  That is the definition that is used.
         DR. APOSTOLAKIS:  Well, this is defense-in-depth at a --
     well -- which brings up again the larger issue here of whether you
     should just consolidate what you have or go beyond it.  I don't think we
     should have a defense-in-depth definition in different areas.  I mean
     there has to be some line drawn someplace.
         DR. KRESS:  It would be nice to have an overriding
         DR. APOSTOLAKIS:  Yes.
         DR. KRESS:  Within -- and derive from that what it means
     with respect to specific areas.
         I think if you actually had that you might come down to this
     definition in fire protection.
         MR. CONNELL:  Yes, but we are not going to do that in the
     fire protection Reg Guide though.
         DR. KRESS:  Well, you just start where you think what it
     means for fire protection, and it may or may not be consistent with some
     overriding definition.
         DR. APOSTOLAKIS:  Well, why don't we say --
         DR. KRESS:  It would be hard to believe it's inconsistent.
         DR. APOSTOLAKIS:  When we say prevention, make sure that you
     detect them, and preservation of plant shutdown functions, does that
     apply to every single area in the plant?
         MR. CONNELL:  In areas that are important to safety.
         DR. APOSTOLAKIS:  Where does it say that?
         DR. APOSTOLAKIS:  It doesn't.
         MR. CONNELL:  It's in GDC-3.  I mean this is an outline.  We
     haven't written the guidance yet, George.  This is just an outline.
         MR. WEST:  I am not sure what your -- what is your point,
     George?  What is your question?  I mean defense-in-depth is covered by
     the existing regulation.  We are not changing any of that.  You can't
     change it through a Reg Guide.
         DR. APOSTOLAKIS:  It's not just defense-in-depth, Steve.  I
     like to see a top-down approach.  I like to see the top goals, then the
     next layer, the next layer and understand how well these things come
         MR. CONNELL:  Then you'll love NFP 805.
         DR. APOSTOLAKIS:  Pardon?
         MR. CONNELL:  You'll love NFP 805 then.
         CHAIRMAN POWERS:  Maybe -- not.
         MR. CONNELL:  That is the way this is structured.
         DR. APOSTOLAKIS:  Just by putting things down, that doesn't
     mean it is very good, but this is a necessary, not sufficient,
         What I don't like is a list of objectives that apparently do
     not relate to each other.  Now they may relate in your minds, because,
     you know, you have been living with this for a long time, but there is a
     4.1 which defense-in-depth and it is defined prevention, detection, and
     preservation.  There is a 4.3 fire protection program performance goals. 
     Now we are talking about safety-related structures, systems and
     components, post-fire safe shutdown, and prevention of radiological
     release, and in my mind again, if I prevent radiological release, am I
     not taking care of safety-related structures, systems and components?
         See, that is the top-down.  If I make sure that I don't have
     radiological release, that means I have already protected the necessary
     number of structures, systems and components that will prevent that
     release, but no, this is a separate requirement, which means all of them
     will be under this.  Now -- which comes back to the definition of
     safety-related, right?  What is safety-related?
         The point is that this is not risk-informed in my opinion,
     and I don't see why it shouldn't be or at least have some element to it. 
     Why shouldn't it have some elements of risk-informed information in it?
         It may be there but right now if I only read the document
     without talking to you, I don't get that impression.
         MR. WEST:  It wasn't a goal of this project to come up with
     a risk-informed fire protection program for nuclear power plants.  That
     is a separate effort.  This wasn't intended to cause any perturbations
     in existing programs.  This is a very simple task.
         DR. KRESS:  Yes, I think if it's going to be risk-informed,
     George, I think you have to start with the regulations.
         MR. CONNELL:  Right, and the intent of this Reg Guide was it
     was going to be used by licensees electing to maintain their existing
     license condition.
         DR. KRESS:  And you really don't have --
         DR. APOSTOLAKIS:  But it doesn't --
         DR. KRESS:  -- but you can, you can work some risk
     information into the Reg Guide.
         DR. APOSTOLAKIS:  It doesn't have to be risk-informed in the
     sense that you go to Regulatory Guide 1.174 and look at delta CDF.  I
     don't mean that.  But I mean this top-down presentation and justifying
     why you do this and why you do that, there is some element of
     risk-information there or risk approach that you are using, but it is
     not really risk-informed, but I would like to see some of that because
     are we looking at what is important and how do we define important?
         MR. MARSH:  This is not --
         DR. APOSTOLAKIS:  What is the definition of importance here?
         MR. MARSH:  This is not intended to change any regulatory
     structure, regulatory format, precept, concept.  This is supposed to be
     a reconstruction of the existing format and we have got to be careful
     not to change.
         If there are --
         DR. APOSTOLAKIS:  I understand that.
         MR. MARSH:  -- are new guidance being out there, I mean
     you're right, we would need to be considering risk information in the
     new guidance.  I agree with you there, and I certainly don't have a
     problem, George, with a format if a top-down makes the existing
     regulatory structure more understandable, if it's always been there, and
     as a way of presentation it becomes clearer what the structure is by a
     construct.  I have no problem with that at all.
         But to the extent that we are changing the regulatory
     requirements or reconstructing the regulatory guidance that has been out
     there, we shouldn't be doing that in this effort.  This is only --
         CHAIRMAN POWERS:  I think George is asking this question
     maybe -- maybe -- is that you make decisions all the time when you
     formulate guidance, even within the context of the existing regulations. 
     You make decisions of emphasis, detail, breadth of coverage -- things
     like that -- and I think George is asking the question ought not that
     decision-making process that you make, whether it is reflected in the
     guidance or not, but that the decision-making process be based on risk
     information to the extent that it is practicable, and I think we have to
     say practicable here, as opposed to practical because we again come into
     this question is the intuition we have developed from the risk
     assessment tools of any use to us or is it open to question, or do we
     have to rely on another definition of risk, which is not so much the
     quantitative but more the engineering judgment type of risk that has
     been used historically in the fire protection area to make those
     decisions, and if you do, does that change the method of presentation
     here without changing any regulations at all.
         I think that is a legitimate question to wrestle with --
         MR. MARSH:  Okay.
         CHAIRMAN POWERS:  -- in thinking about bringing this up and
     maybe a politic one as well.
         MR. MARSH:  It is simply that.
         MR. CONNELL:  And understand the timeframe that we are
     talking about here.  We are trying to get this thing out, you know, near
     the end of the year here, so if there is something that we are going to
     have to wait for development of, we won't -- I mean we'll skip it.
         CHAIRMAN POWERS:  I think the ground-rules you have set for
     yourself is development is somebody else's problem.
         MR. CONNELL:  That's right.  I'll let Nathan do that.
         CHAIRMAN POWERS:  Nice -- I'm sure he will appreciate it.
         DR. APOSTOLAKIS:  I mean that same question can be rephrased
     as follow:  To what extent have the fire risk assessments that have been
     done in the last 15-20 years influenced this and to what extent has this
     new inspection program that the Agency has been developing with their
     cornerstones that you mentioned earlier influenced this?
         MR. CONNELL:  Well, I'll give you some examples, George.  I
     gave you the SISPO and the self-induced loss of offsite power.  That is
     directly resulting from the risk assessments.  We have no guidance on
     that and partially through the risk assessments and partially through
     some Staff initiative we discovered that licensee were using this
     methodology for their post-fire safe shutdown method, so that is one way
     that the risk information is being used in it.
         Of course, I expect the circuit analysis resolution is going
     to have some risk information tied to it, as will probably the
     compensatory measure guidance that we generate, but like I said before,
     I don't think that the risk tools can tell me how long the hose needs to
         DR. APOSTOLAKIS:  My fundamental question is whether it is
     any of your business telling them how long it should be.
         MR. CONNELL:  Right now it is.  Right now it is.
         DR. APOSTOLAKIS:  I don't know.  Why?
         MR. CONNELL:  Because we have that guidance now.
         CHAIRMAN POWERS:  We have a big prescriptive regulation.
         DR. APOSTOLAKIS:  The boundary conditions here are confusing
     the hell out of me.  We have to do this because the regulation that we
     wrote says we ought to do it.
         MR. MARSH:  We are.
         DR. KRESS:  Right.  That's right.
         DR. APOSTOLAKIS:  Does that make sense?
         MR. MARSH:  We are -- we are writing a new regulation.  I
     mean we have two parallel efforts going on here.
         One is if you want to keep your existing program under the
     existing regulation, this is how you do it.  This is how you maintain
     it.  If you want to go performance-based risk-informed, there has going
     to be a vehicle to do that.  It's a parallel path.  Licensees can pick
     either way and we are going to talk more about that this afternoon.
         DR. KRESS:  This is the parallel path we talked about that
     we have to be prepared to accept -- remember in our last letter where we
     talked about risk-informed regulations.  You have to be prepared to
     accept a parallel path, and I think this a real example of it, we have
     to be able to accept it.
         MR. WEST:  There are licensees out there that say we are
     happy with our programs, we think they are safe, and we have and the NRC
     hasn't or the ACRS hasn't shown us anything that says they are unsafe,
     we are going to stick with it.
         DR. APOSTOLAKIS:  I think that parallel path is a little
     dangerous, and I will tell you why.
         DR. KRESS:  What are the choices?
         DR. APOSTOLAKIS:  I will tell you why -- because any time
     you find something from the PRAs that you haven't thought of,
     immediately you bring it into the current regulations, right?  So PRAs
     used to increase the regulations, and you don't just say, ah, this is an
     insight from the PRA, but I will only use it on this path because that
     is the risk part.  You are also affecting the deterministic part, but if
     the PRA says certain things are unimportant, then that goes to the risk
     part, not to the deterministic part.
         DR. KRESS:  You are talking --
         DR. APOSTOLAKIS:  Now that doesn't make sense to me at all.
         DR. KRESS:  -- talking here historical past practice.  I
     think we are entering a new -- I hate the word "paradigm" but we are
     entering an area where we are going to change the regulation package to
     be risk-informed.
         DR. APOSTOLAKIS:  And this is not --
         DR. KRESS:  This is not part of that.  This is the other
     package where you are --
         MR. MARSH:  This is not the Part 50 risk-informed change at
         DR. MILLER:  This challenge is just to codify basically what
     is already there.
         DR. APOSTOLAKIS:  So you promise then that if I look at it
     more carefully I will not find additional requirements coming from PRAs?
         DR. KRESS:  Oh, no.  I won't promise that.
         MR. MARSH:  I won't promise that either.
         DR. APOSTOLAKIS:  But then if you do that, you will also
     promise that I will find some relaxation of requirements because of the
         DR. KRESS:  Yes --
         DR. APOSTOLAKIS:  In here.
         DR. KRESS:  No, no.  I don't know what's in there.  I
     suspect not on either of those, right?
         MR. MARSH:  It wasn't intended to do that.
         CHAIRMAN POWERS:  You know, I think it would be unfair to
     expect these gentlemen to produce something closing their minds to what
     they see coming from other sources.  I mean they have an intuition about
     risk that is derived from a variety of different sources, each probably
     a little bit different, but to say that they are not mindful of the
     results of quantitative risk assessment when they produced this outline
     would be asking for a discipline that I think would defy anyone's
     ability to put together.
         Just as the people who wrote the guidance 20 years ago were
     mindful of a lot of things, including some element of risk assessment,
     as they saw it at that time.  But that is not the intention in this
     particular document.  I think you are just hitting upon things that we
     had misgivings about it, thinking that this was a little bit premature. 
     And it may all be fine, because it does -- some of the things that we
     wanted to mature will be maturing in parallel with this and,
     undoubtedly, will influence it somewhat.
         DR. APOSTOLAKIS:  But it seems to me, though, that we have
     been talking about a two tier system and we have sort accepted it
     uncritically that there will be a two tier system, and now I am finding
     that -- and that was one, --that it may not be practical to have a two
     tier system.
         MR. MARSH:  When you say two tier, you mean risk-informed
     technique and the classical Appendix R technique?
         DR. APOSTOLAKIS:  Right.  Because the classical Appendix R
     technique is affected by this finding.
         MR. MARSH:  Certainly.  Certainly, it is.
         DR. APOSTOLAKIS:  So now the line is beginning to be
         MR. MARSH:  You can't --
         DR. APOSTOLAKIS:  What I don't know want to see is it being
     one way.
         MR. MARSH:  There is a precept -- there is a precept that
     was associated with the formulation of the regulation in the first place
     that had a risk notion to it.  It may not have been well defined,
     certainly not quantified, but it was a precept.  I mean it was there.
         DR. APOSTOLAKIS:  In fact, one other thing, for example, in
     the fire PRA a very important first step is screening the locations
     according to certain criteria.  Right?  In such a screening allowed
     here?  Or every single location, I have to make sure I don't prevent --
         MR. CONNELL:  Well, the fire PRAs are focused on prevention
     of core damage only.  General design criterion 3 is a lot broader than
     that.  So the PRAs, implementing the PRA does not show that you are in
     compliance with general design criterion 3.  There are other issues,
     fire protection issues at a nuclear power plant other than core damage.
         DR. APOSTOLAKIS:  Like?
         MR. CONNELL:  Like radiological release.  You have a fire in
     rad waste building.
         DR. APOSTOLAKIS:  Okay.  So --
         DR. KRESS:  That's very --
         DR. APOSTOLAKIS:  Right.  Right.
         MR. CONNELL:  George, and the PRAs don't address that.
         DR. APOSTOLAKIS:  So I can have a set of criteria, including
     those --
         DR. KRESS:  That PRA could address.
         DR. APOSTOLAKIS:  Could address and it does not address to
     the pleasure of everybody present here.
         DR. POWERS:  George, let me ask you --
         DR. APOSTOLAKIS:  Wait, wait.  No, this is important.  I can
     set a number of criteria, core damage, LERF, measure of radiological
     release, anything else I want, and then screen the locations according
     to those.  And then apply the defense-in-depth idea of preventing fires
     there, rather than saying in an absolute manner, up front, I want to
     prevent fires from occurring, and so on, which implies everywhere.  Now,
     isn't that a different approach?
         DR. KRESS:  I thought that was the approach.
         DR. APOSTOLAKIS:  I didn't see screening anywhere.
         MR. CONNELL:  Licensees simply do not have different fire
     prevention programs for different areas of their plants based on their
     PRA results.  They have a site-wide administrative control that limits
     combustibles, limits hot work, controls hot work.  All those things are
     incorporated in their program and it is site-wide.  It is not -- they
     don't say, well, in this room, I have to do this, in this room I have to
     do something else.  That doesn't exist, and it is impractical to
     implement something like across a plant.
         DR. POWERS:  George, let me ask you a question about your
     concern about one-way streets from PRA.  It seems to me that there is a
     one-way street, but it is the other way.  That is I, as a licensee, do
     the fantastic, unbelievably detailed and validated PRA, and I find that,
     indeed, there is an excessive amount of conservatism within Appendix R,
     I have a mechanism for asking for relief through 1.174.
         If, on the other hand, I am NRC and I do the fantastically
     accurate, unbelievably validated and verified PRA and find that there is
     something missing from Appendix R, that should have been included in
     there, but was not, for whatever reason, that the only mechanism I have
     to add that is to go through a backfit analysis.  So it seems to me that
     the one-way street is actually the other way.
         DR. APOSTOLAKIS:  No, because even the first way it can be
     killed by saying our objective here is not just to prevent core melt and
     LERF, minimize LERF.  So 1.174 really doesn't do much for you.
         DR. KRESS:  Well, 1.174 sort of includes that, because it
     says you will also preserve the defense-in-depth philosophy, and you
     will also comply with the current regulatory requirements.  And when you
     throw those two in, it sort of -- it gets a little broader.
         DR. APOSTOLAKIS:  Yeah, but we can't say 1.174 says preserve
     the defense-in-depth philosophy and then say we, as fire protection
     engineers, define it this way.  That doesn't make sense.
         DR. KRESS:  No, you will have to -- it will have to be as
     defined as 1.174.
         DR. POWERS:  No, no, no.  In this case, what -- the
     defense-in-depth philosophy, we are much further aground here with
     respect to defense-in-depth philosophy than we are anywhere else in the
     regulations because we have -- this is the one area where we have a
     definition.  Okay.  We may not like the definition, and there are
     certainly people sitting at this table that don't even think that fire
     protection is an area where defense-in-depth should be invoked.  But it
     is, and it is there, so there's a very clear standard to compare against
         DR. APOSTOLAKIS:  See, my problem is, when I read this, and
     I will read it again, I get the impression that all these fire risk
     assessments that have been for the last 15-20 years really have had no
     impact on this.
         DR. POWERS:  I think that is a fair perception, that the
     explicit impact probably is small because they are trying to collect
     together all the guidance that has been given over the last 25 years.
         DR. APOSTOLAKIS:  So, there will be another Regulatory Guide
     in two years after Nathan finishes with this one.
         DR. POWERS:  I think that is exactly what the marching order
     is here.  Now, I agree with Tom, it is more likely five.  But I think it
     would be inevitably true --
         DR. MILLER:  Predict two, it will be five.
         DR. POWERS:  -- that -- it is clearly inevitable if the NRC
     says you can comply with Appendix R or you can comply with NFPA 805. 
     That is absolutely true that there would be two sets of guidance there,
     that is unavoidable.  It is likely to be true that in two to five years,
     the fire protection staff at NRC would say I need additional guidance
     because risk-informed regulation has progressed sufficiently that I need
     additional things to be considered that, indeed, one need not have a
     specific hose length in a fire protection area anymore because of this
     risk-informed guidance, and things like that.  I think that is pretty
         MR. WEST:  I just want to remind George of one thing.  A
     couple of years ago, in this room -- I think most of us that are here
     today were here then, two years ago -- we discussed with you a proposal
     to do exactly what you are suggesting today, get rid of Appendix R,
     delete it, eliminate it, and go with the one page, or maybe even one
     paragraph fire protection regulation.  And you thought that was a good
     idea, the ACRS thought that was a good idea, and we went to the
     Commission with that.  And the Commission agreed.  Okay, get rid of
     Appendix R and replace it.
         And largely because of subsequent protests from industry, we
     abandoned that plan and came up with this parallel path plan, and that
     is where we are today.  I mean I don't think we disagree with you, but
     circumstances overcome events and we are -- you know, we are where we
     are at today.  And I don't think we are going to really seriously
     consider going back now and starting over where we were two years ago. 
     Although, personally, I would like to.
         MR. MARSH:  It's much easier.
         DR. POWERS:  No, it wouldn't be.
         MR. WEST:  Do you remember that now?  You are being awfully
     quiet.  You may have been out for coffee that day.
         DR. POWERS:  Trust me.  They are absolutely -- Steve is
     absolutely correct.  We were in here very excited about the idea of
     creating an Appendix S prime that we thought the world was hungering
         MR. MARSH:  Right.
         DR. POWERS:  And we got our wheels realigned for us real
         DR. MILLER:  The world wasn't hungry.
         DR. POWERS:  Well, they were hungry for something else, I
         DR. MILLER:  I wasn't even here and I remember it.
         MR. WEST:  You read the letters.
         DR. POWERS:  Ed, thank you very much.  Steve, let's move on
     to an issue that has much less controversy associated with it.
         DR. MILLER:  Oh, is that right?
         DR. POWERS:  We were kidding.
         DR. MILLER:  Talking about areas where problems could be
     involved, I think it one.
         DR. POWERS:  Well, as you weren't here for my opening
     comments, the difficulty I had on the probabilistic assessments that I
     have seen in connection with this issue is that it appears to me many of
     them are directed at trying to convince me that Brown's Ferry could not
     possibly have occurred.  And I think that is something where we have got
     to really think carefully about our analytic tools and our experimental
     activities in this area.
         If they cannot demonstrate the kinds of things that were
     observed at Brown's Ferry, if they can't demonstrate the kinds of things
     that have been observed in a number of industrial fires, then I think
     those analytic tools and those experiments are simply not validated. 
     And I think we are going to have to think about that carefully when
     people make these arguments.
         And I think it is going to behoove the staff generally,
     perhaps the research program, to start rethinking the kinds of databases
     they should be collecting, and instead of focusing exclusively on fire
     incident rates, to start focusing on fire consequence events, because we
     are having people making these arguments -- I ran this test and it
     didn't show any shorts to conductors, it only shorted shorts to grounds. 
     But, unfortunately, the fire showed shorts of every conceivable variety.
         And so the question is not what is the applicable regulation
     here, the question is what is the valid text.
         DR. APOSTOLAKIS:  And why doesn't that thinking apply to the
     75 foot hose?  Why don't I have to see evidence why it has to be 75 and
     not 76?
         DR. POWERS:  I don't know.  I think --
         DR. APOSTOLAKIS:  Is it because the Committee said it is 75?
         DR. POWERS:  I think it is fair to ask people why in the
     world they came up with particular bits of guidance on 75 foot hoses,
     just as three foot telephone extensions.
         DR. APOSTOLAKIS:  That's right.
         DR. POWERS:  Both ask why the specific length and why the
     guidance.  But I also --
         DR. APOSTOLAKIS:  You know, it seems to me the principle is
     the same.
         DR. POWERS:  I also think it is possible for them to come
     back with an answer.
         DR. MILLER:  It seems like that is a totally different
     question than some of the --
         DR. APOSTOLAKIS:  Anyway, anyway --
         DR. POWERS:  Yes.
         MR. WEST:  Well, a lot of that, of course, is just based on
     -- it is classical fire protection features.
         DR. APOSTOLAKIS:  I know.  Classical, not in the way the
     Greeks use the word.
         MR. WEST:  I think in this case, yes.
         DR. APOSTOLAKIS:  You mean traditional.
         DR. MILLER:  Traditional, right.
         MR. WEST:  Traditional, classical.  But you do see a lot of
     deviations from it.  I mean it is basically guidance.  It is a starting
     point and you can deviate.  I mean some plants probably do have 76,
     maybe 78.
         DR. MILLER:  Steve, are we going to talk about issues, or
     are we going to talk about some fundamental, physical aspects of these
     issues, or just go through the issue?
         MR. WEST:  In this presentation?
         DR. MILLER:  Right.
         MR. WEST:  Basically, I think -- I think status, really,
     kind of tell you where we are at.  And I think some of the other
     presentations on the topic today from the Owners Group, from NEI, will
     get to more of the issues, although I can try and answer any question
     you have.
         DR. MILLER:  I am not -- you may know, I am not a member of
     the Fire Protection Subcommittee, but I was intrigued in looking at the
     circuit analysis issues.  I wanted to run out and start doing
     experiments right away.  Not a lot, but it seemed like --
         DR. APOSTOLAKIS:  Well, then you would have the problem Dr.
     Powers raised.
         DR. MILLER:  Dr. Powers raised a very good point.  I can do
     all the experiments in the world and somebody would question did I do
     the right ones.  I understand that.
         MR. WEST:  Right.  Well, I will be happy to try to answer
     any question I have.  If I am not covering it, and you want to discuss
     something, just ask.
         DR. POWERS:  Well, Steve, I hope that you will be around
     after we have had presentations from both Emerson and the BWR Owners
     Group, because I think we would like to discuss some of the philosophy
     of resolution here.
         MR. WEST:  Yes.
         DR. POWERS:  I have certainly articulated a concern that I
     have, a big time concern I have, but there are a lot of other issues
     here that I would like to both --with and to get a better understanding
     for.  Because every time I go through your presentations, I come away --
     your and Pat's presentation, I say I understand this issue, it is very
     simple.  Every time I go through Fred Emerson's presentations, I say I
     understand this issue, it is very simple.  Unfortunately, the two are
         MR. MARSH:  Well, those are great presentations.
         DR. MILLER:  Again, being new, I found it intriguing, when I
     read 86-10, at least the parts with circuit analysis, and I kept saying,
     where did we -- how did we reach these conclusions that we are going to
     say these circuits are always going to be failed until somebody correct
     them and so forth?  Those kinds of questions.  Probably I am not the
     first one to ask those questions, or the last.
         MR. MARSH:  Probably not.  Probably not.
         DR. POWERS:  I hope you noticed that we can blame all of
     86-10 on the Nuclear Utility Fire Protection Group.
         MR. WEST:  Well, Dr. Powers, I think you are right, it would
     be better to -- it would be good to have a discussion after you have
     heard all the presentations today on the subject.
         I am Stephen West, Chief of the Fire Protection Engineering
     Section.  When Jit asked me to come talk about this, I immediately said
     yes, because I am always anxious to come to you guys about things.  And
     it wasn't until I started late last week thinking about what I was going
     to say that I was second-guessing my decision to come here.  And after
     the last presentation, I am ready to run for the hills, to tell you the
         MR. MARSH:  But George isn't here, so go ahead.
         MR. WEST:  Yeah, I know, I am going to hurry up.
         DR. POWERS:  It won't do you any good.  Anything that he
     needs to be reminded of, I will see to it that he gets brought up to
         MR. WEST:  We came in June of 1998 and made presentation on
     this issue.  The staff did, Pat Madden made a presentation and got into
     a lot of technical detail, and we went through the issues and possible
     resolutions.  And I think we also heard from NEI at that time.  They
     gave some industry views on --
         DR. KRESS:  Too late, he is back.
         MR. WEST:  Yeah, I see that.
         DR. POWERS:  And, again, very welcome.
         MR. WEST:  And so I wasn't going to try to discuss again all
     the details of the technical issues, although we certainly can.  But,
     basically, the problem is that fire-induced circuit failures may
     adversely impact the ability of a plant to achieve and maintain safe
         DR. MILLER:  Is that -- that's nothing new?
         MR. WEST:  That's nothing new.
         DR. MILLER:  The designers 40 years talked about that.
         MR. WEST:  Well, I think that was -- no, I think 40 years
     ago, --
         DR. MILLER:  Thirty.
         MR. WEST:  -- they probably had some problems with separate
     -- you know, the kind of things we would take for granted today, some
     kind of routine separation of redundant functions and divisions.
         DR. MILLER:  They may have not sufficiently made provisions
     for it, as we proved as Brown's Ferry.
         MR. WEST:  Right.  Yeah.  Well, the Brown's Ferry fire
     definitely revealed the problem, the technical problem, the issue.  And
     we had thought that we had resolved or addressed that problem through
     Appendix R.  I mean it was basically -- one of the principle objectives
     of Appendix R was to specify fire protection features and methods to
     provide reasonable assurance that a fire in the plant would not
     adversely impact the ability to achieve and maintain shutdown.  So we
     thought we had addressed the problem.
         We found recently in the last couple of years that some
     licensees may not have fully considered the effects of fire on their
     safe shutdown capability.
         DR. MILLER:  Does that mean they didn't adhere to the
     guidance that was out there or they didn't understand the guidance?
         MR. WEST:  It could be a combination of both.  I think when
     Dr. Powers in his opening remarks on this issue, I think he was reading
     from something we wrote --
         CHAIRMAN POWERS:  Yes.
         MR. WEST:  Summary of our workshop we had on this issue, and
     it kind of characterized the different places that the Staff and the
     licensees could be, depending on your perspectives.
         My personal feeling is I think there are some licensees out
     there that made good faith efforts to comply with the regulation as they
     understood it, using the guidance that we had issued, and they may have
     failed for whatever reason, but it wasn't because they didn't try.
         You said you read the guidance in 86-10 and I have been
     living with this stuff for so long I kind of think it's easy to
     understand but I am not so sure.  I have heard convincing or compelling
     arguments that it is not that easy to understand, that it can be
     confusing, that saying something in Generic Letter 81-12 and then saying
     it again but maybe differently in 86-10 is confusing, so we do have some
     of that.
         CHAIRMAN POWERS:  What you can concede is people can
     formulate detailed technical questions whose answer is not transparent
     without assisted guidance?
         MR. WEST:  Yes, I agree.  But we do have the licensees where
     it appears that they made a good faith effort to comply and they may
     have complied in many cases but not all cases.  Then we do have others
     who I think have embraced a certain interpretation of the regulation
     that would not lead to compliance and their are sticking by their guns. 
     There are some out there, and that is the third bullet, the third
     problem -- there are some differing views between the NRC Staff and the
     industry on this issue and I am going to talk about those a little bit
     more.  This is kind of just the problem we are dealing with.
         Again, without getting into a lot of the technical
     discussion again -- we may hear more of that I think from the other
     presentations -- but there are a lot of factors or elements in a circuit
     analysis, things that need to be considered --
         MR. MARSH:  Steve, before you go into some of those details,
     I want to inject another what I think is a reality.
         I think the NRC may be bag-holders to some of these
     disagreements or the situation as well.  It may very well be that a
     technical reviewer may have approved some particular type of design
     feature or compliance method back in those licensing arenas.  It may
     very well be that there are documents out there that support some of
     these industry disagreements with the Staff.
         I don't want to color it with you as being purely black and
         MR. WEST:  Okay.
         MR. MARSH:  That is, that there are some licensees who
     misunderstood.  I think that there may be situations out there where we
     endorsed some approach which we now think is not appropriate, but to be
     honest, we haven't seen a document that supports that.  We haven't seen
     safety evaluations or letters or REIs back and forth with that that
     support that notion, but I would not be at all surprised if that is the
         DR. MILLER:  What would you think -- just take 86-10 -- ten
     people might read that in ten different days to get multiple
         MR. MARSH:  They may.  They certainly may, and what I am
     saying is that we are a Staff, we are people, we are engineers, and we
     may have had different interpretations at various points in time as
     well, and I just want to recognize a reality that I think is out there,
     that we may have endorsed this as well, so this has backfit implications
     as well is what I am saying.
         DR. MILLER:  That's your bottom line?
         MR. MARSH:  Yes, sir.
         MR. WEST:  Anyway, there's a number, there's a lot of
     factors and elements that go into a circuit analysis and just briefly we
     kind of look at these circuit analysis as the background of the whole
     fire protection program.
         I mean the circuits are vulnerable, and it's the circuits
     that you need to remain functional in the event of a fire or following a
     fire, to operate the equipment you need to shut down the plant and
     maintain it in a safe shutdown condition.
         That analysis really defines what level of fire protection
     you put in place, what kind of features you put in place, where you need
     fire barriers, where you need suppression systems, so it is really a
     critical element of the whole plant fire protection program and the
     foundation of it.  The whole thing rests on the circuit analysis.
         They need to consider both required and associated circuits. 
     Where a required circuit would be the circuit that powers the pump --
     you need that power cable to remain free of fire damage and functional
     so you need to provide some kind of protection for that to ensure that
     your pump is going to be operable when it is called upon.
         An associated circuit is a circuit that is not required but
     it may be associated with the required circuit in some way -- could be
     connected to the same boss -- but if it is damaged it could cause you to
     lose the required circuit.
         DR. MILLER:  In that first bullet it seems like that is the
     nemesis, this whole problem.  That defines the scope of what we are
     looking at --
         MR. WEST:  Right.
         DR. MILLER:  -- and required is probably fairly easy but
     associated I think has lots of ambiguity depending on the plant design.
         MR. WEST:  That's true and that is one of the specific
     issues that the BWR Owners Group for example is working on, coming up
     with definitions.
         DR. MILLER:  Because I could go in and make certain all my
     safety-related circuits are appropriately isolated and Thermo-lagged and
     buried and anything else --
         MR. WEST:  Right.
         DR. MILLER:  In the associated circuits I may still have a
         MR. WEST:  Right.  Well, even for required circuits there
     could be a problem, and I'll talk about that when I get into the issues
     we are working with industry on, but I agree with you.
         So the analyst is looking at the potential for various
     actuations, operations, fire-induced -- you know, fire could cause a
     problem like a hot short or a short to ground or an open circuit, could
     cause -- you need to look at fuse breaker coordination, circuits that
     are in common enclosures, need to look at your transfer and isolation
     capability.  For example, for a control room fire, you need to leave the
     control room.  How do you isolate the control room and transfer control
     to your alternate shutdown panel or panels?
         Look at high/low pressure interfaces.  They get kind of
     special treatment in fire protection and an issue, MOV -- motor-operated
     valve mechanical damage -- and I will talk about that in a second too,
     but that is just kind of an example of the considerations that would go
     into one of these analyses.
         DR. MILLER:  Now wouldn't your PRA be important to some of
     those analyses?
         DR. APOSTOLAKIS:  What did you say?
         DR. MILLER:  The PRA would be better today --
         DR. APOSTOLAKIS:  No.  They are not using that.  You are not
     allowed to use that.
         DR. MILLER:  I am saying as an analytical tool only.
         MR. WEST:  It could be.
         CHAIRMAN POWERS:  Steve, let's come back to your spurious
         MR. WEST:  Okay.
         CHAIRMAN POWERS:  And I think it is important to understand
     that spurious actuation or signal is in the --
         MR. WEST:  Right.
         CHAIRMAN POWERS:  -- in the requirement, and to understand
     that you have this actuation and signal, and then there is a cascade of
     things that follow from that.
         I mean a signal tells something to do something and that in
     turn tells something else, and you have to track that whole thing --
         MR. WEST:  Right.
         CHAIRMAN POWERS:  -- in doing this.  It seems to me that's a
     crucial point to understand.
         MR. WEST:  Right.  As you can imagine, there's a lot of
     things that could go wrong.
         I mean you could have valves operate that shouldn't operate,
     pumps start that shouldn't start or stop that should be running or you
     could have false indications on instrumentation -- any number of things,
     whatever a fire-induced failure could cause to a circuit, power
     instrumentation or control.
         DR. MILLER:  Well, spurious actuations for example could be
     when you have, say, shorts, hot shorts.  You get sparks.  Now in the old
     days of analog instrumentation, sparks may not be a problem, but sparks
     may be a problem with digital stuff -- I mean just like the old spark
     gap transmitter almost.
         MR. WEST:  Right.
         DR. MILLER:  I don't want to introduce new problems here.  I
     started to envision it when I started reading all this stuff.
         MR. WEST:  Okay.  Basically the regulatory considerations --
     it is an issue of high regulatory interest.  It's an issue that has the
     attention of the Commission and industry and the public.  It has the
     potential to have a significant impact on industry or at least certain
     licensees, so there is a lot of interest.  That is evidenced by the
     involvement of the Owners Group and NEI in this issue, for example.
         We believe that it has potential safety and risk
     significance --
         CHAIRMAN POWERS:  I noticed that nearly all of the speakers
     and writers on this issue used those words, "safety" and "risk
     significance" -- but they don't go on and -- I mean they are obviously
     drawing a distinction between safety and risk here, but they don't go on
     and tell me what that distinction is.  Can you tell me what that
     distinction is?
         MR. WEST:  Probably not.  I mean it is -- I was getting
     ready to say "although" when you asked your question.
         We believe that there -- I mean the safety and risk
     significance is obviously going to be configuration-dependent.  You
     could probably go into a plant and find configurations where a
     relatively small fire, for example, could cause significant problems --
     maybe a control room fire where a licensee has not done an adequate
     analysis of the MOV issue to where a relatively small fire in one or two
     cabinets could cause a lot of problems with a number of MOVs that would
     cause them to go into a configuration that you don't want and that you
     cannot recover from, at least not easily, because the valve becomes
         That could have significant adverse effects on your safe
     shutdown capability, your ability to either achieve safe shutdown or to
     maintain it, and can introduce significant challenges to the operator
     and to the plant.
         There are probably other configurations where the
     configuration may not meet the regulatory requirements -- you know, the
     regulation said you should have a one-hour barrier on this cable and
     maybe you don't -- but if you look at it, you may agree that it is not
     that significant.  Maybe it doesn't matter.  It may be a valve the
     operator would expect to be available won't be available but it is not
     going to be that big a deal.  He could easily recognize the problem and
     have another way to compensate for that valve being unavailable or going
     into an adverse position.
         We don't really have our arms around the risk significance
     of these various configurations.  I think it is the focus of the NEI
     effort that Fred is going to talk about -- in fact that is on my next
     slide -- trying to get their arms around the risk and
     safety-significance of circuit analysis problems or fire-induced faults,
     fire-induced failures.
         I think also our research program -- Nathan is doing some
     work, having contractors at Sandia National Laboratory -- try to give us
     some insights into the risk significance of these problems, and I think
     they are trying to use Brookhaven also.  Are you going to talk about
     that later, Nathan?  Nathan will talk more about the research effort.
         MR. SIU:  That will be tomorrow.
         MR. WEST:  Tomorrow, okay.
         DR. MILLER:  Is that research effort directed toward the
     second and third bullets also -- the second and third sub-bullets under
     Bullet 3?  Fire-induced faults?
         MR. WEST:  Nathan can address the question -- I think the
     second bullet.
         MR. SIU:  Sure.  My understanding, Steve, is that this slide
     talks about the rules for how you do a deterministic analysis.  The
     research program is looking at the likelihood of specific failure modes,
     what are the factors that affect the likelihood, so it would bear on
     that when it's done but right now that's not being factored.
         MR. WEST:  Okay.  We have touched on the disagreements
     between the NRC Staff and the industry on some of the issues associated
     with circuit analysis, and that is what has obviously caused the
     complication in coming to a resolution on the issue.
         But basically a few years ago the NRC issued an information
     notice that provided information to the reactor licensees on certain
     potential failure scenarios that some licensees had found, and it is the
     situation that I was just talking about for a control room fire where a
     fire that affects the control of an MOV that could cause it to open or
     close in a way where it bypasses the limit switch and becomes
     mechanically bound so the valve becomes inoperable and stuck in open or
     closed configuration.
         DR. MILLER:  That was 92-12?
         MR. SINGH:  18.
         MR. WEST:  92-18 -- Information Notice 92-18.
         The industry through NEI took a position later that
     consideration of that type of damage, fire damage, would be a new
     requirement.  It is not covered by the current regulation -- kind of
     getting back to George's thing, well, what if something new comes up?
         We have taken the position that, no, it is not a new
     requirement.  It is covered by the regulation -- because we didn't try
     to, we have never tried to define fire damage in terms anything other
     than the component that is needed being functional.  A valve that goes
     into the wrong position and can't be restored is not functional, and if
     that causes a problem with your safe shutdown capability, then it is a
     problem under the current regulation.  
         Then the other -- it's kind of related to the other two --
     and this gets back to the issue of once you identify the required
     circuits it shouldn't be a problem.  You know what they are.  You can
     protect them.
         The problem is, the disagreement is on the number of
     fire-induced faults that could occur in a circuit, and the number of
     spurious actuations that could occur during a fire.  Those are really
     the -- I think these are really the two issues that we are struggling
         DR. MILLER:  Are these disagreements based on judgment or
     are they based analysis?  I didn't find any, and I read through all the
     presentations, the workshop and so forth.  I didn't come away with the
     conclusion that anybody really knew -- could put down numbers to say
     "and here's why this faults occurred."  I saw a lot of philosophy but
     not much --
         MR. WEST:  It really -- it kind of gets back to, I guess
     back to the Browns Ferry fire, which is the real fire experience we have
     that led to these regulations in the first place, but I mean during that
     fire there were multiple spurious actuations.
         DR. MILLER:  But if a plant were designed under current
     guidance and regulations, would Browns Ferry occur in the same way?
         MR. WEST:  No.
         DR. MILLER:  Are we fighting the last war and not the
     present war?
         MR. WEST:  I would say no.  I think if Browns Ferry were
     designed in accordance with the Appendix R criteria that you shouldn't
     have had the problems they had, the multiple spurious actuations.
         MR. MARSH:  Are you saying -- I am asking if the industry
     position is correct, that there should only be -- and if the plants were
     designed and operated in accordance with Appendix R, would they have the
     same type of Browns Ferry fire?
         DR. MILLER:  And would you have the same number of
     fire-induced faults per circuit that we had in Browns Ferry?
         MR. MARSH:  I think you were saying we think plants should
     be designed to accommodate this, and if they are designed they should be
     able to accommodate that?  Are you asking if the industry position is
     correct, that there should only be one?
         DR. MILLER:  No, I wasn't asking whose position.  I was
     asking what the positions are derived on -- experiments, facts or just
     good -- or judgment?  If they are derived on what happened at Browns
     Ferry we could now maybe agree it wouldn't happen.
         MR. WEST:  Well, they were derived basically I think from
     the Browns Ferry experience.
         CHAIRMAN POWERS:  Let me contradict you on that and then you
     can correct me if I am wrong.
         MR. WEST:  Okay.
         CHAIRMAN POWERS:  I get the impression that we had the
     Browns Ferry experience.  We say, gee, lots and lots of stuff
     happened -- it's hard to sort this all out.
         Let's take a reasonably conservative position but not wildly
     conservative position and establish an analysis tool that will confront
     the kinds of things that we saw at Browns Ferry and that involved this
     thou shalt look at all the functional failure states of components in a
     system that can be affected by fire.  Let us concern one spurious
     actuation per fire area, I believe, is what the word actually is is one
     per fire area.
         MR. WEST:  That is from where?
         CHAIRMAN POWERS:  From the 86-10, isn't it?  I think it is
     86-10.  I could be wrong about that.
         It strikes me that we did not set up guidance or regulations
     that said let us make sure that we can fight Browns Ferry because I
     don't think anybody thought you could, that if you had that number of
     things go wrong in your plant in a fire you were in desperate shape and
     you set up things to avoid that ever happening, and that the analysis is
     conservative but not an attempt to fight -- not to, say, reproduce all
     the things that happened in Browns Ferry because now you had separation
     requirements and redundancy requirements that they didn't have.
         That is my perception.
         MR. MADDEN:  This is Pat Madden.  Dr. Powers, I would agree
     with you to some extent, providing that the plant was in compliance with
     Appendix R, and what I mean by that, if you had complete separation
     between these required circuits and these associated circuits -- for
     example, one train of those systems needed for safe shutdown or reactor
     protection would have been free of fire damage, throwing the one
     spurious signal on top or a spurious actuation on time of that separate
     scheme I would agree would have been a conservative approach.
         What we are getting involved here is we are looking at the
     redundancies and the lack of protection for redundancies and arguing
     over could, you know, parallel valves and injection path both go closed
     as a result of fire damage to those circuits that go through a common
     fire area.
         If you take a literal interpretation of the regulation, we
     would assume that either that A or B valve, those parallel injection
     valves, one of them would always be maintained free of fire damage and
     available to you.
         That is kind of the fundamental position that we are in as
     we are looking at to some degree some of this protection is not in
     place.  It's people pushing to say, well, now let's look at it from a
     risk perspective.  What is the probability of both those valves if they
     are injection valves and they are supposed to be open and they are open
     at the time of the fire and they are open prior to the fire, what is the
     probability of both of them going closed as one common fire event
         That is the gray area that we don't have any answers with. 
     There's no analytical tools and I am not aware of any experiments with
     configuration conditions like a single cable and conduit or there's a
     cable in multiple cable tray stack -- there's all kinds of different
     combinations that could occur that could affect the way a cable shorts.
         So to put it in perspective, if we had complete separation,
     to go back to what Dr. Powers said, if you throw on top of that a
     conservative one spurious actuation, that's probably conservative, but
     that is not the area where we're at right now.
         MR. WEST:  Well, I guess in summary for the Staff, the
     Staff's position, I think what we basically say is that regulation --
     was never intended that under the regulation we'd get into doing this
     detailed analytical analysis of the circuits and trying to decide how
     many and what types of faults need to occur before you had some adverse
     conditions, but if it was subject to an adverse condition, you would
     just provide protection, so that is where we are coming from, and then
     Pat mentioned the second thing about protection of redundancies.
         CHAIRMAN POWERS:  Steve, you are beginning to have a circuit
     failure and we are trying to compensate here.
         MR. WEST:  And this is the last slide -- again, basically on
     status.  There's a number of initiatives underway to deal with this
     issue and come up with some resolution that would be acceptable to both
     the Staff and the industry and that resolves obviously any safety
         We had, the NRC had, a while back a path that we were going
     to take where we would basically come up with a resolution and issue it
     to industry in the form of a generic letter and our approach has changed
     somewhat because of the efforts of the BWR Owners Group and the NEI.
         CHAIRMAN POWERS:  Steve, I think we will stop you and do
     some compensating rework on the circuit here.
         MR. WEST:  Okay.
         MR. MARSH:  It may already be known by the Committee but I
     want to make sure a little bit of the background on this issue comes up.
         These issues about circuits and the circuit analyses, as
     Steve said, was not a precept of the regulation.  The philosophy of the
     regulation is to protect circuits.  There's barriers and separation --
     not to have to go through a detailed circuit analysis because it is
     admittedly difficult, and these problems may not have been prevalent 10
     years ago.  Why not?  Because circuits were protected with barriers.
         What happened?  Thermo-lag and plants to resolve Thermo-lag
     may have been removing barriers, doing new circuit analysis, new safe
     shutdown analysis in order to have to remove this barrier, which was a
     question and a problem.  That is why we are seeing perhaps some of these
     issues, some of these philosophical and analytical questions come up.
         CHAIRMAN POWERS:  That is a good insight.  That's useful.
         MR. WEST:  Okay, so anyway, we had a plan that we talked to
     you about in June that would have the final regulatory action at least
     from NRR would have been a Generic Letter and then obviously I guess
     licensees would have had to react to that, and then there probably would
     have been NRC inspection follow-up, but because of a couple of industry
     initiatives, we have adjusted our plan to basically work with the Owners
     Group and the NEI Task Force -- well, not work with them but to wait for
     the results of their efforts and they are going to talk to you this
     morning about the details -- and to review those to see that they
     resolve the issue.
         We have had a number of meetings with both over the past
     year, so we are continuing our regulatory oversight through that.  We
     are still doing inspections.  The inspections we do are inspecting
     against our interpretation of the existing regulation and guidance.
         We had a workshop, an industry workshop, last summer, a
     one-day workshop, that was well attended by industry, and we went
     through in great detail a lot of these issues, tried to achieve an
     understanding of where the hard spots were, what could be done to
     resolve them, and we considered that in our decision to back off a
     little bit and wait for these industry initiatives.
         Basically the BWR Owners Group created an Appendix R
     committee, and they have identified this effort of theirs to come up
     with a resolution of the issues as one of the -- if not the most
     important thing they are working on.  They sent a letter to Commissioner
     Diaz and pointed out that -- described what they are doing and the
     emphasis they were placing on their efforts, and they are basically
     developing industry positions on a number of technical issues that are
     associated with circuit analysis.
         For example, one that was mentioned earlier about what is
     the duration of a short or how long would a fire-induced condition be in
     effect -- you know, is it 30 seconds or is it until some physical action
     is taken to correct it?
         I think they have identified 20 or so issues that they need
     to develop positions on, industry positions, and hopefully get the NRC
     Staff to agree.
         DR. MILLER:  Is some of the research going on addressing
     that particular issue, experimental research, at all?
         MR. WEST:  You mean --
         DR. MILLER:  By the Owners Group?
         MR. WEST:  Not by the Owners Group.  I don't think they have
     any experiments going on.
         DR. MILLER:  Some of the research at Sandia, for example,
     is --
         CHAIRMAN POWERS:  There is certainly a discussion at one of
     your workshops on the experiential base with short circuits of various
     types and to the extent that that is based on experiments or events, I
     guess there's some experimental work there.
         DR. MILLER:  These issues can't be unique to the nuclear
         CHAIRMAN POWERS:  No, no, I am sure they are not.
         DR. MILLER:  You may argue what the consequences may be more
     here, but the issue of shorts and how long they are going to last during
     a fire --
         MR. MARSH:  The types of impedances that are involved and
     the voltages of the circuits and how they relate to the types of
     failures that could be there -- that was an excellent presentation and
     that is being used as part of the Owners Group effort as an input into
         The only other research that I know of is the Sandia
     research that is going on.  The only other data that has been
     presented --
         CHAIRMAN POWERS:  You might want to look and see what the
     military is doing because I know on board ships that are carrying
     nuclear power generation devices that operate under extraordinarily
     short time scales that we worry about this a lot.
         MR. MARSH:  Okay.
         DR. MILLER:  I think if I were designing a big aircraft
     carrier with umpty-ump nuclear plants on it, I would be worried about
     these things --
         CHAIRMAN POWERS:  It is not the nuclear plants that we worry
     about.  It is those short operational nuclear plants.
         DR. MILLER:  The issue of fire-induced shorts and so forth
     just can't be unique to what we are dealing with.
         MR. WEST:  It's not.
         MR. MADDEN:  No, it's not unique but DOE did some testing in
     this area where they actually configured some trays and tried to monitor
     cables and look at duration of shorts and output signal, et cetera, et
     cetera, but that is very limited testing that they did because they ran
     out of funding, but we do have some limited data with respect to it, and
     what they were looking at is specifically trying to backfit Appendix R
     to their reactors and some of the considerations that they need to do,
     to implement because they didn't have the level of separation as far as
     through the power ranges that some of the nuke plants, the operating
     nuclear plants, commercial plants have.
         MR. WEST:  Okay, so anyway, the Owners Group effort is
     basically deterministic.  They are basically saying we have a regulation
     we need to implement.  We are going to develop positions that interpret
     the regulation the way we think it should be interpreted.
         We are going to develop a method using those positions that
     a licensee could apply to decide what kind of circuits require
     protection, what level of protection, et cetera, to meet the regulation,
     and they are going to package that up in a topical report that they are
     going to submit and have the Staff review through the normal review
     process, have us write an SER that hopefully we accept the method.  Then
     it would be available for any licensee to use.
         There may be a couple of -- you notice it is the BWR Owners
     Group.  There may be a couple of positions that are unique to BWRs but
     we think that most of this effort would be applicable to any reactor,
     any commercial reactor, and thee is some coordination with the other
     owners' groups.  I think maybe Fred will talk about that a little bit
     later, because the NEI after the workshop also I guess agree to quit
     arguing with us and develop, put together an issue task force.
         They have done that and we have had a couple of meetings
     with them, and they -- Fred is going to talk to you, but I think they
     have characterized their effort as the development of a
     safety-significance determination method, something like that, and we
     are not -- I don't really want to talk about it because I don't think we
     understand it well enough to do it justice.
         We did get a letter from NEI just yesterday, I haven't even
     read it yet, that describes in more detail exactly what they are doing,
     where they are going, and I am sure Fred will talk about that today,
     right, Fred?
         They are also doing some industry coordination and in the
     last one of -- a recent meeting we had, it wasn't on this subject I
     don't think -- talking about how these two efforts would work together,
     exactly how would the NEI method be used, what is it for, what does it
     do, how would it be done.
         Somebody who was at that meeting from the Owners Group said
     that he thought that they would have this deterministic method and you
     could use that probably to do a lot of your circuit analysis and decide
     what levels of fire protection you wanted, but then you would have some
     left where you weren't so sure you really needed to protect them or
     provide that level of protection, and then you would drop into -- use
     the NEI method and use risk insights and whatever else is in that method
     to maybe do a different type of analysis of those circuits and decide
     what you needed to do, so it could be some kind of risk-informed input
     into the analysis.
         We had a meeting last week with Quad Cities, Commonwealth
     Edison, to talk about Quad Cities and as you know they had a lot of fire
     protection problems there with their safe shutdown analysis and the
     various components of it, including the circuit analysis.
         We have been following their activities for a long time, a
     year or couple years.  They had problems with their risk assessment. 
     But in that meeting they were telling us kind of an approach they used
     to where they did a combination of deterministic analysis and based on
     that they made changes to a bunch of circuits, but then they did some
     kind of risk-informed, applied some kind of risk-informed method to
     other circuits and decided they didn't want to make any changes -- they
     could do something less than a physical change, maybe just a
     compensatory measure or procedure change.
         In that meeting we didn't have time to get into all the
     details of what they did, but it was intriguing.  We were very
     interested.  We got all the people, most of the people who were in this
     room, all the engineering folks and the risk folks, and we are going to
     have a follow-up meeting with Commonwealth Edison, working level
     meeting, where we get into really the details of what they have done, so
     I found that extremely interesting.
         It may be the first real case of a licensee risk-informing
     their fire protection -- so that's where we're at.
         CHAIRMAN POWERS:  If NEI formulates a quantitative risk
     assessment method, methodology for screening circuits -- I mean
     essentially maybe that is an inverse screening of circuits -- and
     presented it to you in some forum -- format that calls upon the
     preparation of an SER, are you in a position where you think you could
     evaluate a quantitative risk analysis?
         MR. WEST:  Well, with all of the resources of the NRC, I
     guess I would have to say yes.
         I think we would be obligated to do whatever it took to
     review that.  I mean after all we are expecting industry to develop
     something and I think we wouldn't be asking them to go forward with that
     if we didn't think we were going to be in a position to review it and
     either accept it or comment on it or reject it.
         We are having periodic public meetings with both of these
     groups and where they have an opportunity to tell us what they are
     doing.  We have obviously an opportunity to react to it, so I think if
     there was anything, if they were going down some path that we knew was
     going to be unacceptable at the end we would take those opportunities to
     suggest course corrections.
         We will have to see what we get, but I think through the
     Staff and Research and our contractors, we would review it.
         CHAIRMAN POWERS:  Can I turn to you?  What Steve has given
     us, I think, is a status report here.
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  There are some nitty-gritty issues of
     lines of language and their interpretation that arise here.  I am sure
     you saw it in the reading here that we may get into as we go further in
     this discussion.
         Is this an area you want to chase down, or you think it will
     arise naturally or --
         DR. MILLER:  I assume that -- I am anxious to see the NEI
         CHAIRMAN POWERS:  Steve, I hope you'll stay around for
     continued discussions.
         MR. WEST:  Yes -- I have got a -- we'll work something out.
         MR. MARSH:  This is this afternoon.  We should be here this
     afternoon -- we'll be here.
         This is another major effort where there's risk information
     that is at issue that is trying to be used to resolve an issue.  It's
     another one of these issues where it is important to work with the
     industry to come up with a resolution pathway.  It is to our benefit we
     believe and the industry's benefit to work in that manner.
         I guess my read on this so far, it's a little hesitant, I am
     not sure how this thing fits together yet.  I am not sure.
         We have had a number of meetings with the industry on this
     thing, and we need clarity because as an Agency we are holding back
     regulatory action because of what the industry is doing and I need
     clarity and understanding of what I am relying on the industry to do so
     that we don't take regulatory action.
         CHAIRMAN POWERS:  What I see is the opportunity for getting
     a cascading analysis that has no end in this.
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  And I take comfort from some of the
     presentations that call attention to the fact that what you want to
     analyze is not necessarily how you would like to run the plant but how
     you may be forced to run it under the circumstance that you judge to be
         Now it seems to me what I judge to be bounding is the area
     where risk might well be capable of telling us how bounding we need to
     be, and I am heartened when I see pronouncements that this is the
     highest priority for our risk assessment research programs and things
     like that.
         MR. MARSH:  Right, and it is the BWR Owners Group that has
     written the Agency and said this is one of the most important things
     they have got on their plate to resolve -- they wrote Commissioner Diaz
     and said that, but I share your concern that this could be kind of an
     endless loop, an endless circle, and we need to be mindful of that in
     our responsibilities to not let that happen.
         CHAIRMAN POWERS:  That's right.
         MR. MARSH:  Come to a resolution pathway that is not
     risk-based either.  It just needs to have a risk implication in it, a
     risk-informed approach in it, but not as a "dispense with this because
     it has no risk implications" -- they need to be careful of that.
         CHAIRMAN POWERS:  But again I think that risk does not
     provide a vehicle for dispensing with this.
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  Simply because circuit problems do arise
     in fires.
         I am going to declare a break until -- I have been advised
     or dictated -- until 11 o'clock.
         CHAIRMAN POWERS:  Let's come back into session.  We have Pat
     Madden to talk about the fire protection functional inspection pilot
         Pat, I understand you are going to focus in your discussion
     on a summary of the inspection findings?
         MR. MADDEN:  That's correct, Dr. Powers.
         CHAIRMAN POWERS:  I hope that we will have time at the end
     to discuss implications of those findings.
         MR. MADDEN:  Well, the ending is going to be kind of crazy
     and bizarre and I have a lot of questions for you, George, and you can
     help me out here.  There's a lot of questions on the table and I am
     going to pose those questions in a broad perspective.
         CHAIRMAN POWERS:  Good.
         MR. MADDEN:  What I would like to do is go over the program
     objectives.  Some of what we call the defense-in-depth principles -- you
     have seen this before.  Ed Connell talked about them a little bit this
         I am going to talk about the scope of the FPFI Program.  The
     NRC's memo talked a little bit on a broader sense on the current NRC
     inspections program versus what we did in the FPFI and where we found
     some holes in the current program versus the FPFI.
         We're going to look at the actual pilot inspection effort
     and what we considered, what plants were part of the pilot program.
         I am going to give you a little bit of a summary of what I
     want to call the -- a summary of the findings and to some degree the
     insights that we got looking at the program as a whole and looking at
     the way NRC does inspection business as a whole.
         Then the last two bullets of my presentation, assessing risk
     and safety significance of the findings and future plans, is where I
     have a lot of questions, and we'll pose some of those questions and
     where we are going to go with them and what we are trying to answer and
     what we are trying to achieve.
         The objectives of the FPFI program was to revalidate or
     reevaluate I should say the scope of the inspection program or the fire
     protection inspection program, as we know it today, i.e. for example the
     core program, take a look at that, take a look at the initial Appendix R
     inspections and were they good enough and broad enough, and then there
     was a triannual module that was supposed to go back in and revalidate
     Appendix R compliance which was not used very much by either the
     industry or the NRC Staff.  It really wasn't implemented.
         The FPFI program was to try to develop a coordinated
     approach towards doing comprehensive and complex fire protection
     inspections, and by that we kind of used integration of people with
     varying knowledge including a risk analyst, a systems analyst,
     electrical and I&C type specialist, and a fire protection engineer.
         The other aspect was to provide a strong and broad-based and
     coherent inspection program, and what we were trying to do is trying to
     standardize and trying to come up with a methodology that an inspector
     in the field if he wanted to use certain aspects of the FPFI module, he
     would have all or a good deal of the guidance in front of him that would
     guide him on how to do an assessment of a certain program area in fire
         CHAIRMAN POWERS:  Is what you are saying that you tried to
     design an inspection program for fire protection here?
         MR. MADDEN:  Well, it is a little bit more than fire
         CHAIRMAN POWERS:  Yes.
         MR. MADDEN:  Post-fire safe shutdown, circuit analysis.  We
     also looked at what I want to call auxiliary issues that aren't covered
     by the regulations -- for example, event-based fires -- for example, a
     turbine fire results in a fire and what impact it would have in a plant,
     and also try to look at what we want to say are phenomena that we are
     just kind of probing in but it's called a fire-induced transient where
     you would actually have a transient caused or impact on a plant, i.e.,
     what comes to my mind is spurious opening of SRVs, for example, and what
     impact that may have on a plant and how a plant would react. --
         CHAIRMAN POWERS:  I guess you triggered two questions there.
         The first question is where did our core inspection program
     for fire come from, and the second one is what caused you to grab hold
     of this fire-induced transient?
         MR. MADDEN:  What caused us to grab a hold of it, you know,
     logically speaking we went back a little bit in history, of course we
     always revert back to Browns Ferry, but we asked ourselves the
     question -- you know, we looked at it classically from an exposure
     perspective of fire in a room creating a condition that could impact
     your ability to safety shut down, but we don't -- at one point in time
     we were trying to look at it from a broader sense to say, well, what
     could a fire do to a plant and how could it change its configuration and
     could those changes in configuration be managed and identified by plant
     operators, and even though it may not affect your "ability to safely
     shut down" in a classical sense with respect to Appendix R, could it
     affect your ability to safely shut down or cause you to use drastic
     measures to shut the plant down as a result of a fire in a space that
     you would have not analyzed with respect to post-fire safe shutdown in a
     classical way.
         CHAIRMAN POWERS:  Are you -- see, what you did not say was
     you did not say gee, I looked at an awful lot of PRAs and what-not and I
     found these transients were frequency dominant or risk dominant or
     something like that.
         Is what you are saying that you find these risk assessments
     to be deficient in that they don't cover that sort of thing?
         MR. MADDEN:  Looking at the IPEEEs, we couldn't find any
     indication where they covered any of that.  They only covered it or
     looked at it in a classical sense with respect to 100 percent power
     operations and shutting the reactor down without any perturbations or
     external perturbations that may be caused by fire.
         CHAIRMAN POWERS:  Okay, so what you are doing is you are
     really raising a question that the risk analysts ought to pay some
     attention to, whether they are being complete or not.
         MR. MADDEN:  That's correct, that's correct.
         CHAIRMAN POWERS:  I think that is very, very important.  I
     think that it is an issue that comes up all the time, this completeness,
     and I suspect if I were going to look for incompleteness it is going to
     be at the interfaces between disciplines and here you have the
     discipline of fire protection versus PRA during operations.
         I think that is an interface that is fraught with a
     potential for incompleteness.
         DR. APOSTOLAKIS:  Of course the issue exists also in the
     current regulations.
         CHAIRMAN POWERS:  Oh, absolutely.
         MR. MADDEN:  That's correct, and that is why we probed in
     that area.
         CHAIRMAN POWERS:  What I see emerging, and do correct me if
     I'm wrong, is coming out of this pilot program a suggestion that perhaps
     our core fire protection inspection is looking at certainly an
     incomplete set of things, but perhaps an inadequate set of things as
     well, and so the question that comes to my mind is where did that core
     inspection program come from?
         MR. MADDEN:  Well, I'll get there.
         CHAIRMAN POWERS:  Okay.
         MR. MADDEN:  In this presentation we'll go through --
         CHAIRMAN POWERS:  Good, good -- I didn't -- I can wait.
         MR. MADDEN:  -- a little bit of the insights that I brought
         To get back a little bit on track, like I said, we wanted to
     provide some clear guidance regarding oversight not only to the NRC but
     also to industry if they wanted to use the FPFI module for
     self-assessment.  We wanted to make sure that they had a good clean set
     of rules to do that self-assessment by.
         The final aspect that we thought would be of benefit to this
     program was to refocus everybody's attention on fire protection and
     compliance with not only their licensing basis but design basis in
     current regulations.
         CHAIRMAN POWERS:  But that -- go ahead, George.
         DR. APOSTOLAKIS:  The most important item or bullet in my
     mind is Number 4, focus on the fire protection issues of most
     importance.  The issue there is of course how do we define importance
     and then are we really doing this, are we really focusing the NRC
     resources on the most important issues.
         MR. MADDEN:  Well, we tried to augment this program a little
     bit.  We used what information we could get out of the IPEEE.
         DR. APOSTOLAKIS:  So we will get to this?
         MR. MADDEN:  Yes.  I'll just give you an oversight here --
     that's where we started the inspection, you know, as far as looking and
     scrubbing and looking at areas.  That is where we started, okay, but in
     the other aspect we looked at we concentrated our focus not only on
     those areas but if you had a fire in those areas, how are you going to
     shut down those areas and what could be affected?
         That is where we focused primarily when we started the
     inspection and we might have branched out as a result of us looking at
     those primary plant areas.
         CHAIRMAN POWERS:  Let me comment just a little bit about the
     last item on this -- "provide an immediate safety benefit arising from
     new industry attention to nuclear power plant fire safety."
         I think that if my reading of the comments and presentations
     made at the workshops that you have had is that the FPFI Program did
     this and that it was universally applauded by both the regulators and
     the regulatees -- maybe "applauded" is a bit of a strong term but
     recognized that that happened, and I came away saying, gee, that's
     distressing, that I would have been much more comfortable had the
     industry said this program was unnecessary -- gee, we're very focused as
     it is on fire protection issues.
         MR. MARSH:  I don't think they said that.  I think what you
     read is -- there is another flavor that goes on with it too.  I think
     they said there were issues in fire protection that need to be addressed
     and you helped us address those issues.  I am not sure they used the
     word "safety" but they talked about fire protection issues.
         They went on to say, and Fred I'm sure is going to talk
     about this some more, that they believe that the overall effort was way
     too intensive, that it caused a lot of industry resources and too short
     a period of time to be focused on these things, and their belief, if I
     can speak for a minute, in a disproportionate way -- that is, a lot of
     attention on things that may not have been significant and so they are
     proposing something different and a different allocation and a different
     timeframe for looking at fire protection issues in the future.
         But you didn't hear, I didn't hear, nobody heard "you guys
     are off-base."  There weren't any issues out there -- inappropriate
     expenditure of Agency and also industry resources -- because everything
     was fine.  You didn't hear that.  You're right.
         I would have felt -- I think we constructed this program
     thinking that was the problem that was there.  There needed to be some
     refocusing of industry attention towards fire protection programs, and
     that is what we found, and that was an end-result as well, and not just
     in the four plants either, I think in other plants as well.
         CHAIRMAN POWERS:  I think you are having an impact, a ripple
     effect --
         MR. MARSH:  Right.
         CHAIRMAN POWERS:  -- beyond the four or six plants,
     depending on how you care to count here.
         MR. MARSH:  In the opening comments this morning I said that
     this is perhaps the most important thing that we have done this year --
     these FPFI programs -- not just because they examined four but because
     of what -- the ripple effect that they have done, the ratcheting, the
     leveraging effect.
         MR. MADDEN:  Trying to get back on track, when we modelled
     this or developed this procedure, we looked at basically assuring
     ourselves that we still had what we want to call the principles of
     defense-in-depth fire protection still being applied at plants, and that
     there wasn't any findings or weaknesses.  That was our goal, that as we
     did these pilots that we would not have any finding of weaknesses and
     find strong programs in those programmatic areas.
         The areas again are preventing fires, detecting, suppressing
     and putting them out quickly would be the second element, and then the
     third element of course is designing plant safety systems so that if you
     did have a fire that wasn't prevented and of course wasn't detected or
     suppressed properly that you would still have the ability to maintain
     those essential plant safety functions that you would need to either
     shut down or compensate for whatever else was going on in the plant as a
     result of the fire and potential perturbations caused by the fire.
         Another aspect is that, you know, I hear from time and time
     again that Appendix R is not performance-oriented, but it is.  There is
     one specific goal that we did carry through in this theme of the FPFI
     and it is a performance goal and it is almost directly out of Appendix
     R.  It provides some level of safety margin.
         I guess you can call it an interpretation of mine or
     whatever but it basically says a fire event should not cause the reactor
     coolant process variables to deviate from that which would be predicted
     by a Chapter 15 accident analysis for a loss of offsite power.
         That is a pretty fine point in the regulation with respect
     to what kind of safety margin was being anticipated at that time when
     the regulation was being promulgated -- so that was part of the theme of
     the FPFI.
         CHAIRMAN POWERS:  I guess I don't understand quite -- at
     first it sounds, gee, that's kind of logical -- let's make sure that a
     fire doesn't make things any worse than the loss of onsite power, but I
     think that a fire does make things worse because with a loss of onsite
     power, I know what things fail and I know the direction they fail in,
     but it seems to me that with a fire the problem we are running into is
     there are many, many different ways things can fail and some of those
     failures because they are at once variable and time-dependent make it a
     much more complicated system than a loss of onsite power.
         MR. MADDEN:  I won't disagree with you, but I think what the
     message there was was to try as much as possible to protect normal
     systems or systems that you would know that could bound or maintain you
     within those predicted levels.
         If that statement wasn't in there for example on a PWR, you
     could go to a bleed-and-feed type operation and reduce the number or the
     scope of equipment that you would have to actually protect.  Now is that
     safer?  Now in some risk circles people can draw a parallel that it is
     no riskier to do that type of operation than it is to shut down
         Now do I have a comfort with that?  I think I would much
     prefer having the operator staying within normal bounds of predicted
     systems to shut the plant down than having to jump in deeply into an
         Okay.  Let's talk a little bit about the scope of the
     inspection procedure and what we call the primary focus and the
     secondary focus.  And, like I said before, you know, I kind of alluded
     to you that we did use risk-informed, or we tried to use a risk-informed
     approach, or gather data from the IPEEE, and we did that a risk analyst
     that accompanied on most of the inspections.
         We started out by assessing the implementation of the fire
     protection program in the risk-sensitive areas of the plant.
         And then the other primary focus was to look at
     configuration management.  You know, how well are these plants
     maintaining their license and design basis in the configuration that the
     NRC perceived as -- you know, that they have implemented?  So that was
     the primary focus of the FPFI.
         The secondary focus was to look at what I want to call these
     fire-induced vulnerabilities and try to come up with a handle on, you
     know, what we should do about those, gather information about those and
     try to look at those findings in the future to determine if there are
     some risk implications associated with those findings.  But, as you will
     see, we had our hands full with just the what I want to call classical
     compliance issues, and we had a very limited opportunity to look at the
     secondary --
         DR. APOSTOLAKIS:  Don't take that away.  Why can't we take
     the thought in your first bullet and apply it to the Regulatory Guide
     whose outline we saw earlier today?  In other words, I can have a graded
     approach and say that, yes, the idea of defense-in-depth, as it has been
     defined in the fire area, preventing fires and so on, will be applied to
     the areas that are fire-risk-sensitive, and in other areas, I will do
     something less, I will not apply the same criteria.  Now, that would
     immediately start making the Regulatory Guide risk-informed.
         MR. MARSH:  That may be how this Reg. Guide gets
     implemented, but not in its development.  The development of the Reg.
     Guide is supposed to just pull together existing regulatory guidance,
     regulatory requirements, what is the existing verbiage that is out
     there.  Now, that how that gets implemented -- if there are issues at
     plants where they may not be in compliance.
         DR. APOSTOLAKIS:  But if the Regulatory Guide says that you
     have implement defense-in-depth as defined here, the licensee cannot
     come back and say we are doing only in the fire -- in the sensitive
         MR. MARSH:  Yes.
         DR. APOSTOLAKIS:  Can they?  They can not.  They can?  I
     thought the language of the guide should allow that, the language is not
     there.  It very clearly states this is 4.1 objectives.
         MR. WEST:  No, the guide -- the guide will say that the
     methods that are specified in the guide are one acceptable way of
     meeting the fire protection regulation.  It doesn't mean it is the only
     way, and it doesn't mean you have to do everything it says in every
     area.  Licensees --
         DR. APOSTOLAKIS:  But I mean since we have it here, Steve,
     why don't we say it ourselves?
         MR. WEST:  It does say that.
         DR. APOSTOLAKIS:  It does say that?
         MR. WEST:  Well, you have an outline, you don't have the
     full guide.  Go, for example, to the -- one of the existing guidance
     documents, the Standard Review Plan.  It says that the guidance in the
     Standard Review Plan is one acceptable means of meeting the regulation.
         DR. APOSTOLAKIS:  I understand that, it is one acceptable
     means, but finding another sometimes is not easy.  And if it is already
     acceptable to the staff, --
         MR. WEST:  Well, we have 900 exemptions from the regulation,
     for example, out there, other acceptable means of meeting the underlying
     purpose of the regulation.
         DR. APOSTOLAKIS:  And I thought the idea of this Regulatory
     Guide was to get away from this huge number of exemptions.
         MR. WEST:  No.  No, you are -- remember, parallel efforts. 
     Think of the parallel efforts.  The 805 will do that.
         MR. MADDEN:  George, my view of the Reg. Guide and, you
     know, my bosses can correct me, but it is a vehicle.  You have got to
     start out with the deterministic space and then you can branch out as
     you gain knowledge or look at certain aspects of fire protection that
     lends itself to risk-informed approaches.  You can automatically
     incorporate those into the Reg. Guide in saying that this is an
     acceptable alternative.  But you can amend the Reg. Guide, and it is a
     lot easier to amend the Reg. Guide than it is to try to change a
     regulation or to go out with a Generic Letter, for example.  So it
     becomes a tool or a vehicle to where we can springboard into some kind
     of approach like that.
         DR. APOSTOLAKIS:  Yeah, but if -- I mean there are methods
     and there are objectives.  And I see how a licensee can come back and
     say, well, we have an alternate method that is not in your Regulatory
     Guide and you guys will review it.
         MR. MADDEN:  That's correct.
         DR. APOSTOLAKIS:  But they cannot come back and say we have
     alternate objectives.  And if you state them as objectives and you say
     that this section describes the basic objectives of the fire protection
     program, and the very first subsection is defense-in-depth --
         MR. CONNELL:  Yeah, those objectives, George, -- this is Ed
     Connell again -- are out of the regulation, so they can't be changed by
     the Reg. Guide.
         DR. APOSTOLAKIS:  In other words, we cannot implement this
     then.  The licensee cannot go back --
         MR. CONNELL:  We would have to change the regulation to
     change those objectives.  Those objectives that you see in that outline
     are directly out of the regulation.  In order for us to -- a Reg. Guide
     cannot change the regulation, we would have to change the Regulatory
     Guide in order to do what you are suggesting.  And industry has
     indicated that they do not want to unilaterally change the regulation to
     make everybody go into a risk-informed, performance-based fire
     protection environment.
         DR. APOSTOLAKIS:  Well, first of all, that is not what I am
     saying.  I don't think that it is all or nothing, you know,
     risk-informed, performance-based or what we have now, but I mean some
     insights, some flexibility would be warranted.  So how is this program
     then, that you are describing to us, going to affect the Regulatory
     Guide?  It will not?  That is for later.
         MR. MADDEN:  Yeah.  This program wouldn't -- if the
     Regulatory Guide was risk-informed, had risk-informed methods in it, we
     would translate the Regulatory Guide or the regulation into an
     inspection procedure.  And, you know, based on the licensing basis, the
     safety evaluation which approved their program and their approach, that
     is what we would -- we would amend our inspection procedures to
     implement a methodology to go out and inspect that.
         DR. APOSTOLAKIS:  So back to the FPFI program objectives, to
     provide clear guidance to the staff and industry regarding oversight of
     reactor fire protection programs.
         MR. MADDEN:  As we know it today.  It is not as we know it
     in the future, it is as we know it today.
         DR. APOSTOLAKIS:  So this is in the future, the words "in
     the future" are missing here.
         MR. MADDEN:  No, it is not.  The module is already drafted,
     it is already in place.  I mean it is as we know the licensing basis of
     these plants today.  Now, if we go to an 805 approach or some other
     approach, we are going to have to make adjustments to our inspection
     program appropriately in order to inspect and enforce those new fire
     protection requirements.
         DR. APOSTOLAKIS:  So the picture is this, that we have the
     Regulatory Guide which consolidates the regulations, I mean the guidance
     of today.
         MR. MADDEN:  As we know it today.
         DR. APOSTOLAKIS:  As we know it today.  And then we have the
     inspection program.  And the inspection program is allowed to look at
     the risk-significant areas.
         MR. MADDEN:  We start out with risk-significant, but we use
     the deterministic tools to judge compliance in those risk-significant
     areas.  We focus our resources on those risk-significant areas.  We
     can't look at the whole plant, we can only take a sample, so we sample
     the risk-significant areas.
         DR. APOSTOLAKIS:  But the licensee is supposed to implement
     this Regulatory Guide to all areas.
         MR. MARSH:  No, not the Reg. Guide.  The Reg. --
         MR. MADDEN:  He implements the regulation.  Okay.  And the
     Reg. Guide is one tool or way he can implement that.
         DR. APOSTOLAKIS:  But the Regulatory Guide reflects the
         DR. POWERS:  Is it fair to say that no plant will be found
     to follow the Reg. Guide absolutely?
         MR. MADDEN:  That's correct.
         DR. POWERS:  That all of them will take some exception --
         MR. MADDEN:  Some exception, right.
         DR. POWERS:  -- or some shade of meaning or something.
         MR. MADDEN:  Yes.  As a part of their licensing basis
     review, those exceptions are identified and the staff will make a
     judgment against the Reg. Guide under alternative approach and if -- you
     know, the alternative approach, based on their situation, and this is
     what I want to call the engineering judgment type performance look on
     their situation meets the underlying intent, the staff will find it
         DR. POWERS:  It's not -- my point is, this is not unusual.
         MR. MADDEN:  No, it is not unusual.
         DR. POWERS:  In every single plant, you will find some
     difference between the template established by the Reg. Guide and what
     is actually done, but in no plant should you find a difference between
     what is done and what the regulations say.
         MR. MADDEN:  Right.  Generally --
         DR. POWERS:  Without an exemption.
         MR. CONNELL:  Right.  This is Ed Connell again.  I don't
     think that we are smart enough to write a perfect Reg. Guide that can be
     applied 100 percent at 103 plants.
         MR. MADDEN:  I think that's true.
         DR. POWERS:  So, judicious humility there.
         DR. APOSTOLAKIS:  So just so I understand what is going on,
     we are risk-informing the inspection process, but not the regulations?
         MR. MADDEN:  No, that is not true.  We are using the
         DR. KRESS:  They are risk-informing this particular
         DR. APOSTOLAKIS:  Just fire protection.
         DR. KRESS:  It is a one time thing.
         MR. MADDEN:  Well, we are hoping it is not a one time thing.
         DR. APOSTOLAKIS:  He is gaining insights.
         MR. MADDEN:  We are using the insights from the IPEEE, yes. 
     And I think if we did a review today, we still use the insights as a
     part of the review process for any kind of license amendment, from the
     IPEEE.  It is just one --
         DR. APOSTOLAKIS:  So if you do an inspection a year from
     now, it will be influenced by this, right, the FPFI?
         MR. MARSH:  FPFI modules.
         MR. MADDEN:  That's correct.
         MR. MARSH:  Sure, you would.
         DR. APOSTOLAKIS:  So the inspection is risk-informed.
         MR. MARSH:  Sure.
         DR. APOSTOLAKIS:  It could be risk-informed, but the
     regulation is not.
         DR. MILLER:  The regulation is not, no.
         DR. POWERS:  The regulation is what it is right now.
         DR. APOSTOLAKIS:  Which is not risk-informed.
         DR. POWERS:  I think that is wrong.
         DR. APOSTOLAKIS:  What is wrong?
         DR. POWERS:  To say that the regulations are not
         DR. APOSTOLAKIS:  They don't use PRA.
         DR. POWERS:  What we now have are tools to do more
     quantitative, more systematic assessments of risk than we had in the
     past, but I think that every one of the authors of every one of the
     regulations, save perhaps for a few of the legal ones, felt that they
     were operating from a risk-informed perspective.
         DR. APOSTOLAKIS:  I understand that point, but what I am
     saying is that we use the word risk-informed the way we have been using
     the last two years, namely, using the quantitative results of what is
     known as PRA, so let's not argue that point.  Of course, there was
     risk-information embedded in the regulations before.  So what Pat is
     describing to us here is an inspection program that will use these
     results.  In that sense, it is risk-informed.  But the basic regulation
     does not.
         DR. POWERS:  Yeah, it didn't exist at the time they were
         DR. APOSTOLAKIS:  That is correct.
         MR. MARSH:  Just a point of clarification --
         DR. APOSTOLAKIS:  Does that make sense?  Okay.  Okay for
         MR. MARSH:  Pat is telling you how we have done four FPFIs. 
     Okay.  Pat is not telling you where we are going to go.  Okay.
         DR. APOSTOLAKIS:  I understand.  I understand.  But I
     suspect there is a strong correlation with where we are going to go and
     the findings here.
         DR. POWERS:  I think, in fairness -- it is my perception --
         DR. APOSTOLAKIS:  I am not trying to be unfair.  To
     understand --
         DR. POWERS:  Let me say it is my perception that the FPI
     pilot findings in the conclusions of that are opening up the debate on
         MR. MARSH:  Absolutely.
         DR. POWERS:  That is my impression.
         MR. MARSH:  Absolutely.
         DR. APOSTOLAKIS:  Opening up which debate?
         DR. POWERS:  Debate on the inspection program.
         DR. KRESS:  It may need to be more --
         MR. MADDEN:  Yeah, it is opening up a unique debate and we
     will get some of those questions on the table here.
         This is to go back to your question, Dr. Powers, on the
     baseline of the core, and I don't know what it is going to be called in
     the new context of the cornerstone.  It may be called complementary
     inspection, or I don't know exactly what the new buzz phrase term is. 
     But we do have a module, it is called 64704, which is predominantly done
     routinely by the regions at all the plants.
         And in that center section you can see, these are the items
     that are looked at repetitively.  And when I show you the results of the
     FPFI, you will see that to some degree there is either weaknesses in
     here with respect to the core, that we weren't looking at the right
     thing, or we weren't being critical enough, or the items, like
     administrative controls, for the most part.  We did find some findings
     in the administrative control section, but you could probably say that
     everybody looks at that, everybody looks at how you control transients,
     so, therefore, plants do it quite well.
         I looked at the quality assurance program the core did, but
     it only looked at in only looked at it in the sense of auditing fire
     brigades and some what I want to call routine programs and never really
     evaluated the engineering or the design issues.
         Generally speaking, for, I think it is an 18 month period,
     fire protection is either under the baseline or core, is focussed on
     either a resident or a regional inspector and about 32 hours of
     inspection effort.
         In the initial phases of the late '80s -- or early '80s, I
     should say, we conducted a one time inspection, it was Appendix R
     implementation.  It was done under 64100, and that was a headquarters
     regional initiative, one time inspection, one week, basically, five
     people, I believe, so five people for basically three days on-site
     inspection time, equating to about 128 hours to inspect the actual
     implementation, safe shutdown analysis, et cetera, et cetera, associated
     with Appendix R.
         There is another inspection procedure that is on the books
     that could be used as a regional initiative but has sparsely been
     implemented, and that was intended to look at long-term compliance of
     Appendix R.  So, to my knowledge, I think Region IV is the only one that
     did any of those type of inspections, and they were done quite some time
         Understanding this, understanding the thermo-lag dilemma,
     understanding the self-assessment report that was one on the staff,
     there is a lot of issues in fire protection, so that raised -- or that
     is why we developed the FPFI program.  Like I said, the principal focus
     of the FPFI was to look at fire protection features, post-fire safe
     shutdown design and compliance, the fire protection licensing basis and
     look at the program elements, you know, of the defense-in-depth and how
     they integrated and how they were actually implemented in an integrated
     fashion at a plant.
         What was being done in the past, everything was being looked
     at fragmented and, you know, the core looked at administrative controls
     and fire brigade, for example, and that was its primary focus.  You had
     a one time look at Appendix R and its implementation.  Nowhere in
     between was anybody really looking at how adequate 5059s are, how
     adequate configuration management was, how adequate the actual
     robustness of the Appendix R safe shutdown analysis was.
         So the FPI program basically equated to 400 hours on-site
     and there is -- and the initial inspections, I believe, three of were
     led by headquarters with a fire protection engineer, like I said, an EE
     with INC and electrical engineering background, a reactor system
     engineer or analyst, a PRA specialist and a regional fire inspector.
         We did -- I showed -- I had that last bullet on the bottom
     of that slide, but I want to couch it with the actual pilot program. 
     The last concept, we did try a different concept, and that was looking
     at some self-assessments where we cut the scope back to look at how well
     the licensee performed its own self-assessment using the FPFI
     techniques, and, so, therefore, we cut back on the scope of our
     inspection and pushed it back to the 128 hour concept similarly used
     under the 64100 module.
         The FPFI pilot program, we looked at -- we did three full
     scope inspections, two BWRs and one PWR, and then we did two reviews of
     self-assessments, one BWR and one PWR, and then we used the FPFI
     techniques on a confirmatory action validation inspection, which was a
     BWR, and I think can guess to some degree which plant that was.
         And I'll have to show -- yeah, that shows up pretty good. 
     This is kind of like what I want to call the scattering of the findings. 
     We had approximately 140 findings out of the inspection and, you know,
     if you want to equate it into -- we had -- if you start around the
     circle, we had 10 percent -- 10 percent of the findings were associated
     with implementation procedures for safe shutdown; 6 percent of the
     findings were dealing with what we want to call alternative shutdown
     implementation; 6 percent -- or 5 percent, I mean, 5 percent of the ASD
     implementation; 5 percent in emergency lighting; 2 percent in
     communications; and those -- those four chunks right there go all hand
     in hand.
         I mean you have to good communications in order to do the
     implementation.  You have to have adequate emergency lighting to do
     shutdowns and move through the plant.  And you have to have adequate
     procedures in order to do the proper implementation.  And what we mean
     by ASD implementation, some pieces of equipment or steps in the
     procedure didn't match the safe shutdown analysis and, therefore, were
     not picked up in the field as a required action, so there were some left
     out actions from the procedures.
         Then we get into some of the classical fire protection where
     we had 5 percent in fire prevention, and here are some surprising
     things.  Twelve percent in fixed suppression, and that's -- what we did
     there is looked at the design basis and how the suppressions systems, as
     installed in the plant, actually met the code or record with respect to
     like the NFPA codes and the sprinkler code for installation, sprinklers,
     halon code for the installation of the halon system.  So we did find
     some surprising findings in the way these systems were installed in
         DR. POWERS:  My experience with those kinds of findings is
     colored heavily by experience within DOE facilities, where in some cases
     the discrepancies were catastrophic.  Detection systems that simply
     didn't detect, and couldn't possibly have ever detected even if they
     were fully operational.  Suppression systems that had been -- that are
     on the drawings that are in the safety analysis report, but, in fact,
     had been blanked off.
         What -- can you give us some feeling for the -- you know,
     well, it said put a suppression sprinkler nozzle every 12 feet and they
     were 11.6 feet or something like that?
         MR. MADDEN:  Well, not to that extreme, but what I would --
     how I would couch it is that, you know, we use a reliability factor, a
     factor that these things are 98 percent effective against -- you know,
     we use industry, nationwide industry data, and I don't think that is a
     fair portrayal in the nuclear industry, because, you know, if I were to
     argue on one side, I could say, well, you know, the general industry is
     probably more conservative than the nuclear industry.  You know, the
     nuclear industry took liberties with the rules.  For example, they put
     in the sprinklers, but then they went and ran things underneath the
     sprinklers such as duct work, et cetera, et cetera, but they never went
     back and looked at the sprinklers, or they misapplied head.
         You know, for example, the UL listing and the way they were
     tested for a certain head, it had to be installed in a certain
     configuration, and this and that, you know, and they had specific
     criteria based on the testing in order to get optimum performance in
     order to meet the minimum code requirements.  Well, they misapplied that
     type of -- they never looked at that data, but they misapplied the head. 
     You know, they installed it and they used a configuration that should
     have been installed.
         So, you know, with that aspect, you know, that is what I
     talk about a little bit about configuration management, making sure that
     your system keeps abreast of plant changes, et cetera, et cetera.
         And the same thing would hold true for the detection
     systems.  You know, there is a fundamental argument about high ceilings
     beam pockets the way detectors are tested.  Detectors are usually tested
     on -- for optimum performance, and that would be for general industry,
     it would be on 15 foot high ceilings with no beam pockets.  So now we
     have 30 foot or 40 foot ceilings beam pockets and we expect the detector
     to respond in the same manner it would have been when it was tested by
     UL and it is -- you know, to meet the standard.
         DR. POWERS:  Well, they just can't possibly do it.
         MR. MADDEN:  Right.  So, you know, but yet, you know, this
     goes back to risk.  You know, what data do we use to -- and what kind of
     judgments do we make to say that we have optimum detection in these
     plants and optimum suppression?
         DR. POWERS:  That particular kind of thing is one that is
     going to very, very difficult for the risk assessment analyst to come up
     with, because --
         MR. MADDEN:  That's correct.
         DR. POWERS:  -- he is going to sit down and say, okay, you
     have got a detector here, and he says, well, how good is that?  And he
     is going to go look at the UL test data, because there is not going to
     be any test data for --
         MR. MADDEN:  I guess the point I am making is that making
     the nuclear industry, to some degree, has to take a conservative
     approach to install additional detectors in lieu of trying to stick with
     what I want to call the traditional methods of the NFPA standards, for
     example, or the traditional methods of -- you know, with respect to
     sprinklers, when in doubt, install a sprinkler head under an
     obstruction, you know, because plants change and configurations change,
     et cetera, et cetera.
         So, to go on, we had 10 percent of the findings were in
     passive barrier design.  Some of that dealt with penetration seals. 
     Some of it dealt with thermo-lag barriers and the implementation of
     upgrades of the thermo-lag barriers.  We had 8 percent of findings dealt
     -- or were associated with the IPEEE and some of the assumptions that
     were done with the IPEEE.  Five percent was in that area that I said we
     didn't spend a lot of time, the evaluation of plant transients and -- or
     4 percent, excuse me.  And 22 percent of the findings were associated
     with SSA, safe shutdown analysis and its implementation.
         MR. MARSH:  Pat, can you take a minute and talk about, or
     maybe you are going to talk about it a little later on, some of these
     fire brigade issues that were so surprising to us?
         MR. MADDEN:  Yeah, I can when I get to the slide.  I mean
     the next few slides are real quick overviews as far as where we found
     them and how many plants they were associated with.
         DR. POWERS:  Now, the trouble with those slides is, again,
     they don't communicate to me what in your written words you have said
     you need to do there.  They don't communicate to me the significance of
     the findings.
         MR. MARSH:  Right.  Right.
         DR. POWERS:  And when you get to the bottom, to the last of
     those slides, when I have seen them before, I don't know and I haven't
     looked ahead yet in your package, your written word, you say I can't
     understand this until I get a plant-wide view.
         MR. MADDEN:  That's right.
         DR. POWERS:  And I don't have that yet.
         MR. MADDEN:  And you won't have it until I tie it all up at
     the end.  I mean it's -- you have got to -- and that's why I kind of
     stress, you have got to keep in mind what I want to call
     defense-in-depth, you know, and where we are going to draw the line here
     is you are going to see that by doing the FPFIs, we identified
     weaknesses, or I should say findings in all the levels of
     defense-in-depth with respect to fire protection, George, only that. 
         So -- and to say, you know, what is the punch line, is this
     -- how risk-significant is this, how gross is this, how -- I guess what
     I want to say is, in a classical sense, it didn't meet the expectations
     of current guidance and regulations.
         So in the administrative end point of it, we had three out
     of six plants where they had control combustible problems, or
     weaknesses, and they may have been isolated.  But the point I guess I am
     making here is that they did have a process, a program and yet that
     program has -- or you can circumvent the program, and it can go on for
     some period of time.  In one plant, the uncontrolled combustibles had
     been there for some period of time.
         DR. POWERS:  And that is simply one of those issues that
     seems to have a life of its own.  I am certainly familiar with a DOE
     plant where we cited them for transient, uncontrolled transient
     combustibles every single inspection.  They were removed and replaced
     every single inspection, and our inspections were substantially more
     frequent, they were every three months.  It was always a different set
     of combustibles, but it was always there.
         DR. MILLER:  Absolutely.
         MR. MADDEN:  Compensatory measures, two out of the six
     plants, we had some views or findings associated with how they implement
     compensatory measures.  And by that, I mean when they do an operability
     assessment, do they look at the whole problem, or do they just go for
     the quick fix compensatory measure?  But if it is like a safe shutdown
     function that is out of service, do they only put a fire watch, an
     hourly fire watch in the area, or do they take the step further to say,
     well, if this safe shutdown train is out of service, what kind of things
     could we do to get around this problem, operationally-wise, and alert
     the operators?
         The other one out of two, and there was only two PWRs we
     looked at, but one of them had problems with their oil collection
         The next area, the second element of defense-in-depth and
     that is detection and suppression.  I think over on the lefthand side of
     the slide it kind of couches it right -- Designer installation did not
     meet industry standard, or code or record.  In absence of an engineering
     evaluation to evaluate those deviations, some of them you can simply
     dismiss, but some of them, you know, would have warranted either
     additional detectors or additional sprinklers.
         So we had one area, or one -- five out of six plants had
     problems with detection.  Five out of six had sprinkler concerns.  We
     had a gaseous suppression system and we looked at the acceptance, the
     initial acceptance tests of the gaseous suppression.  There were two out
     of six plants that we looked at, two of them had -- we had concerns over
     the initial acceptance of the test -- testing.  It actually had failures
     and lack of ability to hold a concentration, but they did an engineering
     evaluation to determine that that was acceptable.
         One plant out of the six we had questions about the
     suitability of the agent for the hazard and the design concentrations of
     the gaseous suppression.  For example, cables can be considered if -- if
     a cable fire progresses to a deep-seated fire, the agent was not applied
     for that concentration to control a deep-seated fire.
         MR. MARSH:  Let me interject a thought here as we go through
     these slides.  These slides could also be read as not giving any sense
     of significance, okay, any either risk significance or of any safety
     significance, or compliance significance or anything, these are just a
     frequency charts.  These -- it says, on how many plants did we have
     findings of this sort?
         DR. POWERS:  The trouble with that I have is that some
     people will take it as an indicator of significance.
         MR. MARSH:  We need to be careful about how these -- what
     these connote.
         DR. POWERS:  Yeah, I think that -- I think it is a real
     problem because there are people that will leap upon this as proof --
         MR. MADDEN:  Right.
         MR. MARSH:  Right.
         DR. POWERS:  -- of this or that contention.
         MR. MADDEN:  Right.  You know, and I -- yeah, I do want to
     caution.  I mean these are findings -- I mean, you can go back to the
     details of the report and look at the findings.  Now, would I classify
     any singular finding as being drastically risk-significant?  Probably
     not, because I have all these other layers of defense-in-depth that I
     would rely on.  But if you start, you know, looking at the whole picture
     and why we are having so many findings, and where we are -- why we are
     where we are today, then that raises other questions.
         MR. MARSH:  It raises questions in my mind about -- how come
     five out of the six plants that we looked have detection issues?
         MR. MADDEN:  Right.
         MR. MARSH:  Is it something that we haven't said clearly, or
     that the guides aren't clear, or is there -- what is the synthesis of
     this information?  Not significance yet, just the synthesis of it.  If
     you see a large fraction, it should raise questions in your mind, but
     that is the only thing that it should do, is just raise a question in
     your mind.
         DR. POWERS:  Well, with respect to detection, it is my
     experience that actually what I find surprising is it is not six out of
     six, because, quite frankly, you have an awful lot of detectors in a
     plant, and to say that every single one of them is located in exactly
     the optimal position and is at any time absolutely functional is asking
     a bit much.
         MR. MARSH:  Yeah, see, there is a lot of talking that needs
     to go along with this.
         MR. MADDEN:  That's right.
         MR. MARSH:  Because we didn't inspect in that vein.  We
     didn't go look for a 100 percent.
         MR. MADDEN:  So, like if you said detection, you know, my
     response would be, well, what is the significance of that?  Well, the
     detector may not react for 10 minutes, okay, when, you know, it should
     probably react in a minute.  But it will react sooner or later, I mean
     it will react.  I mean it is just that you don't know -- does it meet
     the criteria of prompt detection?  Is 10 minutes prompt?  You know, it
     depends on who defines it.
         MR. MARSH:  But there's another dimension.
         DR. POWERS:  Those were even subtle issues.
         MR. MADDEN:  Right.
         MR. MARSH:  There's another dimension that goes -- must
     accompany this chart.  That's, you know, a vertical dimension.  How
     significant are these five out of the six?  It needs discussion, and I
     worry sometimes about these things being misused.
         DR. POWERS:  Well, I think this discussion of significance
     is a point raise by some of the findees.
         MR. MARSH:  Sure.
         DR. POWERS:  And at some point we are going to have to put
     that third dimension on this.
         MR. MARSH:  Absolutely.  In a lot of ways.  You need to --
     in terms of a recommendation to the Commission about whether this
     program, what did it find and is it safety worth -- what is its safety
     worth, you have to do it in that context.  You have to do in the
     enforcement context.  You evaluate these findings and what to do about
     them in enforcement space.  There has got to be a significance element
     associated with that.  So there is that synthesis going on.
         DR. POWERS:  We have a comment.
         MR. WARREN:  Yeah.  Glen Warren of the BWR Owners Group. 
     And Pat, just for clarification of me, too, and understanding the chart
     that you have here, when you are talking frequency, and in the example
     of hose stations, a plant could have hundreds of hose stations in the
     plant, and a finding of one hose station in that plant would make this
     show up as one of the six, that this is not four of 6, like at six hose
     stations, we looked at four of them and had a problem?
         MR. MADDEN:  No, no.  No, no, no.  It's plants, we are
     talking plants.  Frequency of plants.
         MR. WARREN:  Thank you.
         MR. MADDEN:  For example, one plant had an exemption which
     required, as part of the basis of the exemption, that it would have hose
     stations available to suppress a fire in the control room.  Well, when
     we went out and measured the actual -- or the distance, and they
     committed to meet the NFPA standard, when we went out and started taking
     a look at -- I shouldn't say we, the licensee started to take a look at
     it because they knew the FPFI was coming along, they determined that
     those hose stations would not have reached, or the hose wasn't long
     enough to reach the control room, or weren't strategically placed to
     accomplish what they stated in their exemption request and stated in
     their licensing basis.  So that's the type of examples that, you know,
     we were finding.
         Now, why?  I don't know.  That should have been something
     that should have been evaluated back in the early '80s.
         MR. MARSH:  See, now, you can -- you misled by a comment
     like, gosh, there's 300 hose stations, they only found one problem, so,
     therefore, it adds up to be four rather than three.  That finding has
     some significance, whereas, a finding someplace out in the turbine
     building where there's many hose stations may not.
         MR. MADDEN:  Right.
         MR. MARSH:  So there is a synthesis that is going on about
     these numbers that is important.
         DR. POWERS:  Yeah.  If the hose won't reach the place it is
     going to and there is no other hose to do that, you have got a problem.
         MR. MARSH:  Right.
         DR. POWERS:  The fact that the hose has a prescribed length,
     but that --
         MR. MARSH:  It didn't quite make it.
         DR. POWERS:  Make it.  But it is still adequate to meet its
     function, then --
         MR. MARSH:  Then it is nickel, dime.
         MR. MADDEN:  That is a different story.  But, you know, some
     of the arguments that you will hear on the other side -- Well, that
     would have been no big deal.  I mean if we had an actual fire, we would
     have just sent somebody to go get another piece of hose.
         DR. POWERS:  Well, I think I would be less susceptible to
     that kind of an argument.
         MR. MADDEN:  Yeah.  I mean I was.  I wasn't very sympathetic
     to that argument, you know, but that's --
         DR. POWERS:  Yes.  It is very easy to claim that somebody
     will take a remedial action when you do not recognize that when one of
     these events occurs, there are a few distractions.
         MR. MADDEN:  Yes.  Well, the other aspect is, you know, I am
     a firm believer that the design of the plant ought to take care of
     itself and you shouldn't have to rely on all these remedial actions to
     place the plant in a safe condition.
         Meaning of suppression.  We looked at the fire brigade, and
     I am not going to say we looked at them very hard, I mean I don't think
     we were that critical on them, but we had findings with respect to
     equipment and the adequacy of equipment for the hazards that are on the
     plant, you know, on the plant site at three out of the four plants.
         Drill performance.  We don't -- we didn't feel that the
     utilities were, you know, putting enough emphasis on what I want to call
     realism of the drill scenarios and expectations of what they wanted to
     accomplish through these drills.  For example, we had people using --
     during the drill, they didn't use their breathing apparatus, okay.  We
     had other examples where they didn't put on their turn-out pants and
     boots.  We had other examples where they pulled the hose off the hose
     rack and they left it all in a heap and they didn't unfeather it or,
     otherwise, if they have been charged, it would have been kinked and the
     nozzlemen wouldn't have been able to use it right.
         We had another technique that was -- we had a situation
     where the hose flat-out didn't reach the seat of the fire whatsoever.  I
     mean that was in the drill.  We had another situation where they used
     cellular phones for communications, and the cellular phones went belly
     up.  I mean it just -- you know, there was all kinds of things that went
     on and, you know.
         You know, the expectations and being critical of, you know,
     a defense -- what I want to call layer of defense-in-depth was not -- we
     didn't see it, the criticality.
         Qualifications of fire brigade members.  We think
     fire-fighting is pretty stressful, and we found at one plant -- our
     guidance documents require medical examinations.  We saw at one plant
     where they decided that annual medical examinations were too frequent
     and they decided to extend that.
         Pre-plans and strategies.  Three out of four plants we had
     some questions about their pre-plans and strategies.  A lot of these
     plants are older plants and they don't have smoke removal capability
     and, you know, any type of lubricating or hydrocarbon fire, oil, puts
     off a significant amount of smoke -- or any type of cable fire, the
     cable jackets put off a significant amount of smoke.  And we really had
     some questions about how do you manage smoke in a plant, and they all
     pointed to the pre-plans.  And when you went to the pre-plans, there
     would be just a one line statement, you know, vent smoke as needed, or,
     you know, use your portable fans.
         So our questions were, portable fans, you know, what is your
     smoke management plan?  Do you put the smoke in an area where the
     redundant train isn't?  Do you put the smoke in an areas where sensitive
     electrical equipment that you may be relying on isn't?  How do you
     protect your operators from carrying out the manual actions that they
     may need -- that may be associated with that fire in that fire area?
         So we asked all, you know, all those questions.  And so we
     looked at, you know, the in-depth look at -- you know, if you needed a
     fire brigade and it was a serious fire, how you would cope with some of
     the what I want to call the real situations that they may be faced with.
         MR. MARSH:  I think this was a surprise, right, Pat?  The
     breadth and depth of the findings in the fire brigade?
         MR. MADDEN:  Yeah.  For a long period of time, and even in
     the IPEEEs, there's, you know, always a reliance on we have a plant fire
     brigade.  They will always say -- you know, and they are well qualified
     and well trained.  And it was kind of a surprise.  And maybe our
     expectations are being held a little higher than theirs, but we think
     that if they are one of those barriers of defense, they ought to be
     pretty good.
         DR. POWERS:  I think I agree with you that we have always
     presumed that fire brigades were supermen, quite frankly, supermen.
         MR. MARSH:  Especially at a nuclear plant.  We thought,
     gosh, they have got to have good training, good equipment.
         DR. POWERS:  And I don't know that we have, or would ever
     have anything that said, okay, if your fire brigade is deficient,
     medical examinations, training, whatnot, equipment, that how does it
     function in the bounding fires that we know, that we anticipate?  It
     seems like a very difficult area.
         MR. MARSH:  We haven't focused on it either.
         MR. MADDEN:  Yeah, I mean if you were to, quote-unquote, use
     the term realistic or credible fire that they all been called out on, to
     function, you know, and I can only think of a couple of cases where I
     would say that the fire brigade has been absolutely unsuccessful, and
     those, you know.  But, generally speaking, you know, most fires are
     handled with a fire extinguisher.
         DR. POWERS:  Yes.
         MR. MADDEN:  Granted.  Okay.  And I guess if this was a true
     performance-based world, that is all we would be training on.
         MR. MARSH:  Dr. Powers, I have a question for you, sir.
         DR. POWERS:  I didn't have sex with the woman, if that's
     what --
         MR. MARSH:  I didn't ask that question.
         DR. KRESS:  The question is why didn't you?
         MR. MARSH:  We have a group of slides -- I don't know where
     to go with that.
         DR. POWERS:  Don't go anywhere with that.
         MR. MARSH:  State of the Union.
         DR. POWERS:  The President suggests it is a lot more trouble
     than it is worth.
         MR. MARSH:  We have a group of slides following this one
     which give you a frequency connotation, and the discussion that Pat is
     going through is important because it gives you the breadth and depth of
     the inspection that went behind these frequencies.  It gives you some
     sense of what was found, not just a number, but a sense of what was
     found.  Okay.
         Would you like us to continue this way, to go through these
     and give you the discussion or --
         DR. POWERS:  I think it is fair to say that the members have
     these slides already.
         MR. MARSH:  Okay.
         DR. POWERS:  And have probably looked at them, and they
     probably have just exactly the same -- all the same questions that we
     have been dancing around.
         MR. MARSH:  Okay.
         DR. POWERS:  And so --
         MR. MARSH:  And so where do you go?  Okay.
         MR. MADDEN:  Well, I would to jump to 17.
         DR. POWERS:  Right.
         MR. MADDEN:  Okay.  The first bullet is that we have had a
     real fragmented approach as far as looking at fire protection as a
     whole.  In the implementation of the fire protection plan, every plant
     has a plan.  And what we found during the FPFI, that Appendix R is
     generally not considered a part of that plan, and that plan generally
     focuses on administrative controls, fire brigade, surveillance of
     testing -- surveillance and testing of detection and suppression.  But
     when you get into actual engineering evaluation or the analysis
     associated with safe shutdown, that is always outside or very rarely
     integrated into the plant.
         So, the integration, we couldn't really draw a conclusion
     that the site plan actually ever integrated or validated the SSA.  The
     safe shutdown has always been viewed as engineering and not an integral
     part of operations.  So that was one insight we got out of the program.
         The other insight was what I call internal self-assessment. 
     And, true, the NRC has put out guidance on QA audits for fire
     protection.  And some of that guidance is relatively old.  And that
     guidance never really asks the licensee to assess or evaluate its
     compliance or long-term compliance with Appendix R.  So out of the
     audits that we looked at, there wasn't an application of QA or a
     principle focus on QA audits on compliance with Appendix R, the analysis
     of Appendix R, and the implementation of Appendix R.
         Pre-FPFI inspection procedures, they never verified -- and
     this goes hand in hand with the one above, that safe shutdown was
     actually being thoroughly audited by any implementation, was thoroughly
     audited by licensee's programs and, therefore, some of the issues that
     were identified were only identified as a result of reanalysis done by
     the licensee, not based on audit.  And some plants started to go that
     way as they got closer to being chosen for an FPFI.
         Another thing that we noticed, that the administrative
     controls or the fire prevention aspects are overly emphasized by core
     inspections.  Basically, the core inspections done by the NRC are
     primarily focused on the administrative or the operations side of the
     plant and not so much on engineering and design, and maintenance of
     engineering and design.
         The next bullet is -- basically what I said is that the
     design basis of suppression systems, detection systems, components used
     to protect your safe shutdown features was never really evaluated,
     reviewed or inspected in-depth with respect to its design basis prior to
     the FPFI program.
         MR. MARSH:  These are weaknesses that Pat and the teams
     discovered through doing the FPFIs, and in looking retrospectively at
     the core and other past inspection efforts, okay, because that was part
     of the charter.  Part of the charter was, hey, how -- what is our
     inspection core?  What are these procedures, are they any good?  Okay. 
     So that is part of what we are finding here, that there were weaknesses
     in past inspection efforts.
         DR. POWERS:  And I think this is really the key insight
     here.  And it raises the key question, okay, now what?
         MR. MARSH:  Right.
         DR. POWERS:  And this is where I think the risk insights
     come in.  One can now conceive of going through and taking these things
     and doing a top-down -- what should I be inspecting?  What really is
     important to do?
         MR. MARSH:  Right.
         DR. POWERS:  Are the administrative controls so important to
     my fire prevention activities, one leg of the defense-in-depth that they
     have to receive some emphasis, or should there be a more uniform
     emphasis to achieve the risk reduction that I am really looking for
     here?  I think that is what Professor Apostolakis would argue for in
     bringing insight to this.
         MR. MARSH:  Right.
         DR. POWERS:  This slide is the stuff that I really got
     excited about when I saw it in a previous presentation.  It continues
     on, though, you have got lots of insights.
         MR. MARSH:  It does.
         MR. MADDEN:  Yeah, it does continue, but they are all kind
     of interconnected.  I mean they really are interconnected to some
         DR. POWERS:  But they all ask the same question -- what
     should the inspection program really be?  And I think Professor
     Apostolakis would argue passionately for a top-down risk-informed
     adjudication on that.
         DR. APOSTOLAKIS:  I don't know about passionately.
         DR. POWERS:  I have never seen you dispassionate, George.
         MR. MADDEN:  Some of the other aspects were actually
     weaknesses in the program with respect to procedures and how to inspect
     some of these deterministic analyses.  And that could hold true if we
     were to look at risk-informed analyses, you know, we would still have to
     have the same procedures or aspects incorporated in the inspection
         One thing that we did notice, that the core procedure does
     not -- and I have said this before, does not look at any of the Appendix
     R program elements.  So the NRC really does not visit Appendix R in any
     type of depth, other than specific issues coming up here and there.
         Another thing that we had problems wrestling with is 5059s,
     adequacy of 5059s and what is considered a USQ, et cetera, et cetera, in
     fire protection space.
         Post-fire safe shutdown operability.  How do plants control
     operability?  Could an element in the system that is required for
     post-fire safe shutdown only go out of service and, you know, is a
     compensatory measure adequate for that?
         Configuration management and reportability.  When is a plant
     outside its design basis with respect to fire protection?  Those are
     issues that were not fully addressed but were looked at and inspected
     under the FPFI.
         Now, to say do we have any answers, we have some views, but
     I don't think we have any answers.
         Another thing that we did find, and we did, even in the FPFI
     program, to some degree, we took a stab at this, but we believe that
     additional inspection guidance is needed to fully address the adequacy
     of risk analyses.  And by that, I mean the IPEEEs.  I mean one plant has
     a pilot fire -- which may be no better than this piece of paper, and
     another one does a bounding fire modeling technique, which, you know,
     looks at creating a challenge or finding out when the challenge would
     occur to their plant.
         DR. POWERS:  You said that you needed examine the IPEEEs. 
     In the IPE space, we really don't do that.  The IPEs exist, there is an
     underlying PRA for most of them.  People have reviewed the IPEs against
     a set of criteria that are pertinent to the original request, but not
     pertinent to the question of, can I use the IPE for analysis of a
     regulatory question?  They just haven't looked at them for that purpose.
         MR. MADDEN:  Well, the thing that I guess I am driving at
     with this statement is that when we go to looking at risk with respect
     to these findings, let's say all these were compliance issues, and I
     know how to deal with those compliance issues, and we are going to get
     to this in the next slide, but when I go to deal with risk, if I only
     have a snapshot in time -- first of all, I have got to have some kind of
     IPEEE that I have confidence in, to start evaluating each individual
     finding or findings grouped together -- I need to know what impact that
     has on that IPEEE.  And right now, you know, with, you know, divergence
     and assumptions methodology, and what our perception is about the
     results, I mean the only thing that we really use them for is relative
     ranking of sensitivity of rooms, and understanding what that relative
     ranking is.
         Now, to judge the findings, you know, is it only those rooms
     that we do enforcement against?  Or is it -- you know, are there other
     elements outside those boxes that we do enforcement against?
         DR. POWERS:  I guess my point is that I would not expect the
     IPEEE to be a very reliable source for risk information, ipso facto.
         DR. MILLER:  Right.
         DR. POWERS:  That -- it was done under a set of ground rules
     that exist, they are fixed.  They probably didn't recognize this
     potential use of it, and so don't ask it to do that.  Now, you still
     have this problem.  How do I risk rank my findings?  Because people tell
     you you have got to have some risk ranking here -- how do we go about
     doing it?  That really is the problem.
         MR. MARSH:  And it is something we are struggling with
         MR. MADDEN:  Right.
         MR. MARSH:  It's very true, very relevant.
         MR. MADDEN:  Some of the point is that when we ask the
     utilities to do it, they revert back to the IPEEE.
         DR. POWERS:  And that -- if they did, then I think it is
     fair game to go look at their IPEEE at that point.  But I don't think it
     is fair to go until they say, yeah, verily, you can use this.
         MR. MARSH:  We clearly need some method to come up with some
     judgments, qualitative, quantitative, some tool to assess the risk
     significance of some of these findings, some type of rack up, some type
     of ranking, and we are struggling with that.
         Now, as part of the assessment process, there is efforts to
     build a new baseline inspection program, baseline inspection across the
     regulatory board, in all programmatic areas, looking at performance
     indicators and things of that sort.  There is a group of individuals
     that are involved in that that are trying to do the same thing, assess
     the risk significance of inspection findings, and there are some tools
     that are being developed, not mature yet, but there's thinking along
     this way, because that is an element which must exist in this inspection
         We have not asked ourselves this question before, that I
     know of in other -- any inspection effort.  What is the rack up of
     findings in risk space of relative -- these relative findings?  We
     assess like a point estimate of a finding, which is a dangerous thing to
     do, to just come up with a point.
         DR. POWERS:  Well, it is an unfair thing to do.
         MR. MARSH:  It is an unfair thing to do.
         DR. POWERS:  Because you have deliberately set out to have a
     fire protection structure that is tolerant of failures.
         MR. MARSH:  Right.
         DR. POWERS:  And I think you have laid down an interesting
     challenge to the risk community here with your question, and I realize
     that you are in the hot spot, you have got to have an answer
     immediately.  I would really enjoy hearing what you think you need to
     have, not maybe perhaps this year, but let's say what you would like
     your son, when he takes your job, to have for doing that question.
         MR. MARSH:  Well, he is in computer information systems, so
     he is --
         DR. POWERS:  Much smarter than you, I understand.  But I
     think that's the question we have got to ask.  As we go to look for the
     right tools, we also have to address your immediate question.  And I --
     you know, I am sitting here saying, gee, how do they -- how do you do
     that?  How do you get the risk analysis on this from the staff's point
     of view when you don't have something like a NUREG-1150 for a
     representative cross section of plants dealing with fire protection
     issues?  I mean you have one or two that came out of NUREG-1150, but it
     is not this robust, --
         MR. MARSH:  No.
         DR. POWERS:  -- analyzed device and subdevice that gives you
     some insights on the risk significance of these items.
         MR. MARSH:  Yes.
         DR. POWERS:  You have this IPEEE per plant that is
     presumably a good shot at things, but an unreviewed good shot.
         MR. MARSH:  Right.
         DR. POWERS:  And you have got a tough one here.
         MR. MARSH:  And there is danger because we are making
     decisions about futures of programs which may hinge on this, this part
     of the assessment, and all the frustrations that you are recognizing, we
     are there as well.
         MR. MADDEN:  One other aspect of the IPEEE, you know, its
     foundation was compliance with the regulation.
         Anyway, to go on to trying to assess risk and safety
     significance of the findings, this is where I told you I was going to
     ask you questions.  I am turning the table now.
         DR. POWERS:  Ah, but, see, we don't have to answer.
         MR. MADDEN:  I know, I know.  I know, that's the bad part
     about it.
         Purely from the inspection findings now, you know, I am not
     going to say that the findings identified gross values of any one of
     these elements, but it did indicate that there are program concerns that
     could, you know, be involved with one element or multiple elements of
     defense-in-depth, and that is an indication which was, to some degree,
     somewhat surprising.
         The safety significance of individual findings is kind of
     dependent on the overall program effectiveness and should be judged in a
     plant-wide context.  And I guess what I mean by that is that, you know,
     if they had a single finding and one area or one element of
     defense-in-depth showed an inherent weakness, but the other elements
     were very strong and robust, then, of course, the safety significance of
     that finding would probably be relatively insignificant.
         But when you start to look at I have a few findings here in
     this area, a few findings in this area, and few findings in this area,
     now, in a plant-wide context, what does that mean?  And it starts to get
     a little grayer.
         DR. POWERS:  What we know is that risk assessment portrays
     itself as a particularly suitable vehicle for making judgments of
     exactly that kind.
         MR. MADDEN:  That's correct.
         DR. POWERS:  That's what it portrays itself.  Now, the
     question is, is it now adequate to do that kind of fine judgment?  We
     frequently find in operational PRAs that we ask regulatory questions
     that are too microscopic to be explicitly addressed by the PRA.  Now,
     does that mean those questions are not risk-significant?  I think not. 
     But -- and so how do we interface them?  I mean that we had that
     particular problem in 5059, that the questions being asked are below the
     resolution of the PRA and it is -- how do you make a risk-informed
     judgment on a question that the PRA can't see?
         MR. MADDEN:  That, you know, that may fall in suit here
     also.  I mean --
         DR. POWERS:  There's a real potential here.
         MR. MADDEN:  Yeah, there is a potential here.  And it
     depends on, you know, where that threshold bar is, you want to place.  I
     mean if you want to place it fairly hard -- or high, I mean you can
     probably filter a significant number of findings.
         DR. POWERS:  One of the problems I could foresee in using
     PRA in this area has to do with the objective function.  You have -- a
     PRA will give you information on CDF and a PRA will give you information
     on LERF.  That is only half of the objectives of your fire protection
         DR. APOSTOLAKIS:  What is the other half again?
         DR. POWERS:  The other half is going to be life safety for
     occupants, whatnot, and plant damage control.
         DR. APOSTOLAKIS:  You can do a PRA for those.
         DR. POWERS:  I think you can, but you are going to have to
     -- I think you can do a PRA for any objective function you would care to
     define, but the objective function is going to be different than the
     ones that get used for -- the operational guys have a different set. 
     They only have to go against CDF and LERF.  You have got an extra one. 
     If you choose to preserve that extra one, and I think right now there is
     no evidence we shouldn't, then you have got to add it in.
         MR. MADDEN:  My reaction to this is that I could look at
     these findings and I could probably judge these findings on the merit if
     I was just looking at what I want to call a fire protection, risk
     assessment mitigation model.  You know, if I could just -- you know, if
     I could evaluate against the change of my success, you know, just a
     delta in the success of -- with this element out of the picture, what is
     the delta in my success in the mitigation model?  That, I could probably
     understand, you know.  And that, I could probably make relatively fast
     judgments about the potential safety significance of these findings.
         DR. KRESS:  The importance function.
         MR. MADDEN:  Right, exactly.
         DR. KRESS:  I think there is a lot to be said about that.
         DR. POWERS:  I think it is fair to say that when you read
     the reports on Prairie Island and St. Lucie and things like that, that
     an experienced fire protection engineer can go through and say this one
     is important, this is one is -- this one is a gotcha, but I don't care,
     and things like that.  Literally, that fast.  I think that is fair to
         MR. MADDEN:  Yeah, it is fair to say.  But I think what you
     need to do is also step back.  Like if you looked at the St. Lucie
     report, I mean there was such a divergence in all the findings, to come
     out to the conclusion that none of it, from a programmatic standpoint,
     was safety significant, I don't know how we get there from there.  I
     mean if you look at the whole big picture.  And that is why I have that
     second kind of sub-bullet there, that you have got to look at it from
     the big picture, also, you just can't focus on the individual findings.
         DR. APOSTOLAKIS:  The fire community out there has done some
     work that uses PRA kind of methods to find the egress time.  Is there
     another area where the word egress is used or is it just in the fire
     protection?  I mean is that used anywhere else?
         DR. KRESS:  Lots of places.
         DR. APOSTOLAKIS:  I have never seen it, only in the fire. 
     It is like the urn, it is in probability --
         MR. MADDEN:  If your ship is sinking, I think you would want
     to know the egress to the lifeboats.
         DR. APOSTOLAKIS:  Yeah, that's right.  Where they estimate
     the time that it would take for people to get out, and that's meaning
     PRA really, although not as sophisticated in the other PRAs, in other
     words, the tools for these kinds of things, for these analyses, exist to
     some extent, not -- they are not really advanced.  But now, you know,
     they are talking about -- I am sure you know that -- performance-based
     fire regulations in Australia and in other places, where this is the
     main theme, actually, estimating the time it takes people to get out,
     and then the time, you know, to kill them, and whichever is greater.  So
     we will not be starting from scratch.  I mean this is just a comment.  I
     mean if we want to address the other half.
         DR. POWERS:  Well, I think we have a confidence that focus
     on any of these tasks could lead to resolution.  The question is -- what
     focus, when and how much?
         MR. MADDEN:  See, I think if you -- you know, this -- if you
     take it all the way to core damage, you know, in an analyst's space, it
     takes away a lot of flexibility that an inspector has in the field to
     make rapid judgments.  And that's why I said if you -- and George is
     touching on this -- is that if you say in the mitigation aspect, or
     trying to figure out just what my probability or likelihood of success
     is with all these different elements out of this little model out of the
     picture, that can give, you know, relatively quick, you know, how these
     items interact and what their importance are, too, if you decide to go
     that next step.  You may not.
         I mean you may say that that is good enough for fire
     protection.  You know, that we have got to protect the plant personnel,
     we have got to protect life safety.  We have got to, you know, preserve
     the shutdown ability and the operator's ability to move through the
     plant.  We have got to have the ability of the fire brigade to take
     prompt action.  We have got to have smoke control measures.  You know,
     if that was all integrated into a mitigation model, it would give you
     probably a better picture of how success we are really going to be.
         DR. POWERS:  Okay.  You are saying a little different kind
     of analysis than classic CDF analysis.
         MR. MADDEN:  Right.  Exactly.  It is a little bit more
     simplistic.  I mean --
         DR. POWERS:  I think it is -- I think it would end up being
     just every bit as sophisticated.
         MR. MADDEN:  Well, maybe you are right.
         DR. POWERS:  But I think it is an intriguing idea because it
     avoids you going to the step that I think just leads to defocusing.
         MR. MADDEN:  Right.  Exactly.
         DR. POWERS:  And that might be very advantageous to do.
         DR. KRESS:  The problem I have with it is the same problem I
     have with performance-based regulations in general, is how do you know
     when you have done enough?  What acceptance criteria are you going to
     use to say this is good enough here?  And that is always a problem with
         DR. POWERS:  Could you imagine doing it, Tom, where you make
     occasion tie points to the CDF analysis?
         DR. KRESS:  Or to other measures.
         DR. POWERS:  Other -- something else.
         DR. KRESS:  I don't like -- you know, I don't like sticking
     CDF.  But if you had occasional tie points, enough that it made it
     relatively coherent, I think --
         MR. MARSH:  So that you could interpolate.
         DR. KRESS:  -- the more you go, the better off you are. 
     But, you know, I don't even think it has to be -- I think performance
     type of regulations can stand on their own as long as you put together a
     set of acceptance criteria for them.  Now, they don't have to be PRA
     based, or they don't have to be CDF based.  They could be like any other
     acceptance criteria, it is what people are willing to accept.
         DR. APOSTOLAKIS:  But they would be rational.
         DR. KRESS:  They would be rational.  And they would be
     arrived at by a process that incorporates things like decision criteria,
     loss functions and stuff like that.  But it is how you arrive at these
     acceptance criteria that has always bothered me in the performance.
         DR. APOSTOLAKIS:  I want to ask a question.  If you had gone
     -- if one of your plants in this program had been Quad Cities, --
         MR. MADDEN:  It was.
         DR. APOSTOLAKIS:  Did you find that thing yourself?
         MR. MADDEN:  Yeah.
         DR. APOSTOLAKIS:  That the IPEEE found?  Did you know about
     it before?
         MR. MADDEN:  Well, what the IPEEE found, I think we found a
     little bit beyond the IPEEE.  Let me kind of explain.
         DR. APOSTOLAKIS:  When did you go, though?  When did you do
     this, before or after the IPEEE?
         MR. MADDEN:  After the IPEEE.  Yes.  But I mean we found
     things that were not even considered by the IPEEE.
         DR. POWERS:  I understand that the IPEEE finding is
     relatively narrow considering --
         MR. MADDEN:  Were they important?  Yes.
         DR. POWERS:  In comparison to the raft of things that have
     been found at Quad Cities now.
         MR. MADDEN:  Were they important?  Yes.  We found conditions
     where a diesel generator could have been loaded on faulted buses.  I
     mean that wasn't picked up by the IPEEE.  We found conditions where
     smoke management was never even considered and operators would have had
     to go through rooms full of smoke.  That wasn't picked up by the IPEEE. 
     I mean there was all kinds of conditions that we picked up.
         I mean I am sure you read that report and that's pretty --
         DR. APOSTOLAKIS:  So where do we go from here?
         MR. MADDEN:  Okay.  I guess what I am talking here is what I
     think -- if I -- you said something about if I wanted a tool, what kind
     of tool would I need?  And it is basically the methodology that I kind
     of regurgitated to you, but I mean it would have to be a tool that would
     not only, number one, assess compliance, but look at the risk in the
     changes, basically, on what I want to say in the safety margins of the
     individual findings, and that is what I mean by -- you know, our rule is
     written around mitigation of consequence, you know, starting out with,
     you know, the event is one.  And I had a tool that could just tell me
     the change in the mitigation of success, that would give me a good
     indicator of what worth that individual item or individual finding had.
         DR. APOSTOLAKIS:  So you are talking about compliance now
     with the existing regulations?
         MR. MADDEN:  Absolutely.  Right.  I mean I have to, I mean I
     can't talk about future because I don't know where it is going to be.
         DR. APOSTOLAKIS:  So why do you care about risk?
         MR. MADDEN:  Why do I care about risk?  Because it would
     come into play on how strong of a viewpoint I take with respect to
     getting it fixed, enforcing it, and what kind of generic implications it
     may have.  I mean if I am going to push -- if it is low risk, I am not
     certainly not going to push the licensee to immediately take action, to
     shut his plant down to do this, to do that, you know, so I am not going
     to do that.  I mean if it is dealing with improper fire-fighting gear or
     whatever and it is low risk, sure, it is a finding, it may be a
     non-cited violation, it may be he agrees to fix the problem and I go
     away happy as can be.
         But if it is high risk, I may have to get other individuals
     involved such as management, et cetera, et cetera, and we may have to
     start another dialogue with that utility and ask them why they think
     they are justified to continue to operate.
         So I think risk has to play a little bit of a picture in
     here.  But I think the real thing is that we really need to understand
     what the change in the safety margin is over the perceived regulation to
     where they are at that given point.
         And then I think another thing that we need to do is have a
     methodology for assessing what I want to call the big picture, the
     programmatic aspects of what we perceive as a weak program, and that
     means across the board, and what impact that may have on the plant as an
         DR. POWERS:  I guess I don't see the distinction between the
     two methodologies.
         MR. MADDEN:  Well, there maybe isn't.  And my mindset
     up-front was looking at individuals, but if you had a robust enough
     tool, you could look at the whole big picture with one tool.
         DR. POWERS:  What you want to do is look and say I have got
     a bunch of individual findings, they are not in each -- they are not in
     just one leg of the defense-in-depth.
         MR. MADDEN:  Right.
         DR. POWERS:  I have findings in every one of the legs of
         DR. MADDEN:  Right.
         DR. POWERS:  I am confident that if I have all three legs of
     defense-in-depth operational, I am in good shape.  If I have two out of
     three, I think I am still in good shape.  If I have one out of three, I
     am maybe a little less confident.  But the question is, when I have
     findings in all three --
         MR. MADDEN:  Weaknesses in all three.
         DR. POWERS:  Weakness.  Do I ever get the combination of
     events that just follows that weak link all the way through?
         MR. MADDEN:  That's correct.
         DR. POWERS:  That's what you want to have.
         MR. MADDEN:  That's correct.
         DR. POWERS:  And that seems to me tells you about the entire
         MR. MADDEN:  That's correct.
         DR. POWERS:  And I think you have certainly raised an
     interesting approach to that that looks a lot more tractable to me than
     the conventional PRA type of approach.
         DR. APOSTOLAKIS:  Well, actually, what I find very
     interesting is that we are willing to make the inspection process
     risk-informed, but not the regulations.
         MR. MADDEN:  Well, let me do this first, George, and then we
     will work on the regulations.
         DR. APOSTOLAKIS:  I'm sorry.  Go ahead.
         MR. MADDEN:  I said let me do this first and maybe we will
     work backwards and do the regulations.
         DR. APOSTOLAKIS:  This is kind of selfish, Pat.  You are
     trying to save the agency money but not industry.
         DR. POWERS:  I don't understand, George, I thought with
     1.174 --
         DR. APOSTOLAKIS:  I'm sorry.
         DR. POWERS:  I thought with 1.174 we announced that they
     could make these regulations risk-informed.
         DR. APOSTOLAKIS:  Well, up until this morning, I was under
     the impression we are talking about risk-informed, performance-based
     regulation.  Now, we are talking about traditional regulation,
     risk-informed inspections.
         Now, Pat may be right, maybe you want to understand this
     first before you go to the first one, which is what -- which is not what
     we did with 1.174.
         DR. POWERS:  To the detriment of 1.174.
         DR. APOSTOLAKIS:  This is a revolutionary change in my
         DR. POWERS:  Well, understand that I think --
         DR. APOSTOLAKIS:  No, the change has not happened yet, but
     something I had to --
         DR. POWERS:  Understand that --
         MR. MARSH:  I am going to -- I have a challenge.  My
     challenge is for myself, to understand the depth of your concern about
     this Reg. Guide.
         DR. APOSTOLAKIS:  I didn't say it was a concern.  Oh, this
         MR. MARSH:  The Reg. Guide, yeah.
         DR. APOSTOLAKIS:  Yeah, I don't like the way it is put
         MR. MARSH:  Yeah, because I am not understanding.  And let's
     not do it -- but my -- the Reg. Guide started, and its intent was to
     address an existing, real life problem out there now, to put into one
     place all this stuff.  Okay.  I think that is a great thing to do.  I
     mean I think that is a wonderful, noble and necessary thing to do.
         Now, what you do with that, where you go with that is the
     next more difficult step.  And if this becomes a parallel track to go
     with 805, whether this becomes backfit to operating plants, that is
     where you may inject risk information into that, that type of the
     process, but --
         DR. APOSTOLAKIS:  But there are elements of the thinking
     that has evolved over the years from PRA without necessarily being
     strictly PRA that, like this top-down approach and stating your
     objectives.  Pretty much what the inspection program does, the other
     inspection program with the cornerstones.  That could have been used
         All right.  I realize that there is a need for consolidating
     the existing regulations, but you can inject a little bit of your
     thinking in there without really going all the way to PRA.  It is not
     all or nothing.
         The other thing that worries me -- see, I am not raising one
     of my concerns, because I haven't really studied it.  I suspect that
     when the PRA tells you to do more, you are very happy to embrace it.
         MR. MADDEN:  It's backfit.
         DR. APOSTOLAKIS:  But when the PRA says relax on all the
     requirements, you are not too willing to do that, not just you.
         MR. MARSH:  Why do you say that?
         DR. APOSTOLAKIS:  Why do I say that?  Because all the
     evidence points that way, and I use Bates theorem every day.
         DR. POWERS:  I am going to interrupt this discussion.
         DR. APOSTOLAKIS:  We have a major problem identifying
     regulations that were eliminated because of a PRA.
         DR. POWERS:  I am going to --
         DR. APOSTOLAKIS:  It is very easy to create long list of
     things that were added to the regulations because of the PRA.  And then,
     of course, you go to the industry and they say, PRA, what's that?  I
     don't want to know about it.
         DR. POWERS:  I am going to --
         DR. APOSTOLAKIS:  I'm sorry.  Okay.
         DR. POWERS:  -- interrupt this discussion, not because I
     disagree --
         DR. APOSTOLAKIS:  Or agree.
         DR. POWERS:  -- or am fascinated with it, but because I have
     to be fair to the subsequent speakers this afternoon.  But we have -- we
     do have time on our agenda to pursue exactly this issue, and I think the
     Committee needs to wrestle with how it is going to respond to your
     Regulatory Guide.  I mean we responded at one time and said we didn't
     think it was a useful expenditure of resources.
         MR. MADDEN:  Right.
         DR. POWERS:  But, obviously, we were in gross error over
     that judgment.
         MR. MARSH:  The Commission thought it was a really good
     thing to do.
         DR. POWERS:  So now we have had our wheels realigned, I
     think we would like to get -- we need to decide how we want to pour oil
     in the water, and we need to answer your question -- what is our depth
     of feeling?  But, on the other hand, I want to be fair to the other
     speakers, so I am going to defer it till a little later this afternoon
     and whatnot.
         MR. MADDEN:  Okay.  Just the line and final slide here, and
     the big question is, where do we go from here?  You know, how does the
     FPFI program fit into the NRC cornerstone inspection process, or
     philosophy?  Big picture. Do we rely on audits, audits of licensees'
     self-assessment, for example?  You know, do we turn the FPFI program
     over to the licensees and say, hey, do them?  Come up with a plan,
     blah-blah-blah, and we will come in and audit them.
         Do we do a mixture of both?  You know, is it just a FPFI
     audit, you know, at a certain set of plants -- you know, maybe one or
     two a year, maybe three a year -- and, also, do audits of licensees'
         One thing I think we do have to do, and this is not really a
     question, but I think we have to revisit what is going to be in the
     complementary inspection program with respect to the cornerstone effort? 
     I mean there are -- I have seen elements in there, but I don't believe
     they are the right elements.
         And then how do we monitor licensees' fire protection
     programs with respect to the effectiveness of their programs in the
     cornerstone program?  By that, I mean what do we gauge it against?  What
     is the benchmark?  Who monitors it?  How do we get the information and
     how do we know that the information is reliable with respect to
         So, with that, I close.  I thank you for your attention.
         DR. APOSTOLAKIS:  By the way, I can see the need for
     consolidating certain things.  I don't necessarily have to like it.  I
     mean there are certain things that need to be done that could have been
     done a different way, and I am not --
         DR. MILLER:  Isn't the real question the drafting?  In the
     process of consolidating, you are recommending they build in risk
         MR. MARSH:  That's right.  That's what I hear.
         DR. MILLER:  The danger of doing that is you fail in doing
     both very effectively.  The other way is consolidating, then building
     the risk insights later.  That's --
         DR. APOSTOLAKIS:  See, I wouldn't mind that, if it weren't
     1999, and the reactor safety study was published in 1975.  To hear that
     Nathan will give me research results five years from now to start doing
     -- using PRA, depresses me, because that will be 2004.  Okay.  That will
     be 30 years after the draft WASH-1400 was published.  Thirty full years.
         DR. POWERS:  The proof that the PRA analysts had been very
     effective -- ineffective in communicating their message.
         I am going to recess until 1:30.  If any of the subsequent
     speakers are going to have difficulty, please bring it to my attention.
         [Whereupon, at 12:50 p.m., the meeting was recessed, to
     reconvene at 1:35 p.m., this same day.].                   A F T E R N O O N  S E S S I O N
                                                      [1:35 p.m.]
         DR. POWERS:  Let's come to order.  I have already come to
     order.  Fred, you are going to discuss with us two topics, I guess.  You
     are going to talk on my favorite, hot shorts -- boy, that is good for
     after lunch -- and the FPFI. So, I guess, the floor is yours.
         MR. EMERSON:  Actually, four topics.
         DR. POWERS:  Four.  Oh, sorry, Fred.
         MR. EMERSON:  It remains to be seen whether I get through
     them all in 60 minutes, but I will give it a shot.  The four topics that
     I wanted to cover today, first of all, I will try to address some of the
     issues that the staff addressed this morning and then some that they
     haven't addressed yet.  I would like to start with discussing the fire
     protection inspections and assessments, which is what Pat wound up with
     this morning, then standards and guidance development, including NFPA
     805, fire-induced circuit failures and a new area for us, risk-informed
     fire protection applications.  I am going to move fairly fast because of
     the quantity of information.
         First, in the area of fire protection inspections and
     assessments.  I am not sure to what extent your Committee has been
     exposed to SECY-99-007.  I am not going to try to go through it in any
     detail, but I would like to provide some background information for what
     we are proposing as a follow-on to the FPFI program.
         In the overall proposals in the SECY that is currently out,
     there is both industry roles and NRC roles, industry and assessment, and
     NRC and baseline inspections and other activities.  The new assessment
     process, as I said, is embodied right now in the SECY-99-007, and it
     integrates licensee audits and self-assessments into regulatory
     oversight.  Just as quick sketch of the process, I am not going to try
     to again go through this except to indicate that it shows both the NRC
     and the licensees -- I'm sorry -- the NRC and the licensees as having
     distinct, but complementary roles in this new assessment process.
         I have labeled this an NEI approach.  Actually, it is not,
     it is what is currently embodied in the SECY document.  It involves
     several performance levels, which I will put up in just a minute.  It
     involves thresholds for increased NRC attention, a threshold for overt
     regulatory action to assure public health and safety, and these
     thresholds are intended to be a blend of regulatory requirements and
     risk insights.
         There are -- if you look on the subsequent pages, these next
     two slides are shown in full sizes, so you don't have to get our your
     magnifying glass to read the type.  As I say, there are four performance
     bands, and I am just going to cover this again very quickly as a
     backdrop to the recommendations which we have very recently made to the
         The first area is a Licensee Response Band, which will
     involve licensees monitoring performance indicators where they exist,
     and NRC engaging in a core baseline inspection program where the
     performance indicators do not exist.  Below the top band is called the
     Increased Regulatory Response Band, and that is an area where the NRC,
     when performance begins to drop off, either as measured by performance
     indicators or as core inspection results, NRC and licensee become more
     active and increased attention is needed for those performance
         The third area is the Regulatory Response Band.  That is
     where some significant action is needed.  That is a yellow color.  And
     then the bottom one is Unacceptable Performance where plants won't
     normally be allowed to operate.  This slide represents the performance
     for any specific performance indicator or core inspection module.  There
     are those at NEI who are much more conversant with this than I am, so I
     am not going to try to address the process in more detail than this.
         DR. KRESS:  There would be a number of these for each
     performance indicator.  Supposedly, each performance indicator has some
     way to quantity so that you can have these --
         MR. EMERSON:  Yes.  As I understand it, performance
     indicators either have been or are being developed, and in areas where
     performance indicators do not exist, there is a core baseline inspection
     module that the NRC would use to evaluate performance.
         DR. APOSTOLAKIS:  So what is the difference again between
     increased regulatory response and required regulatory response?
         MR. EMERSON:  Increased regulatory response means the
     performance indicators or the core inspection results are dropping off a
     little bit.  It is time to take a closer look at that indicator and the
     reasons why it is not going the way it should.  As you drop lower in
     performance, either you have more indicators going south, or you have
     one going south repeatedly and still more increased attention is devoted
     to it.
         If I can put up the next slide, it might make things a
     little clearer.
         DR. KRESS:  Let me ask you a question on this slide.
         MR. EMERSON:  Sure.
         DR. KRESS:  The slide implies to me that the measurement of
     these performance indicators is continuous, because there is a
     continuous line.  Would they be, in fact, though, continuous, or would
     they be something that would the result of an inspection or
     self-assessment that would be at specific points in time, specific
         MR. EMERSON:  I think to the extent that the licensees
     monitor their own programs, there would be a continuous level by the
     licensees of monitoring performance against these indicators.  I don't
     know that they would do it on an everyday basis, but they would do it
     frequently enough to keep in tune with --
         DR. KRESS:  Continuous doesn't have to mean that.
         MR. EMERSON:  Right.  I am not familiar enough with the core
     baseline inspection programs to know how the NRC, how frequent those
     would be.
         Okay.  This is what is intended, and, again, this is out --
     almost entirely out of SECY-99-007.  This involves actions by the NRC
     and licensees with respect to what do you do when either one performance
     indicator moves into a certain band or more than one moves into a
     certain band, and it reflects increasing levels of attention by both the
     licensee and the NRC as the performance indicators decline, or as core
     inspection results indicate a declining performance.
         Now, the way fire protection is currently wrapped into this
     -- and, staff, feel free to correct me if I misstate this -- as I
     understand it, right now, it is intended to be a complementary baseline
     inspection program because no performance indicators have been worked
     out for fire protection.  It is intended to address the two cornerstones
     of initiating events and mitigating systems.  The types of things that
     the baseline inspections are intended by -- as written in the SECY
     document currently, to address are review of ignition sources, control
     of combustibles, fire protection system and equipment, licensee controls
     to minimize the probability of a fire, and the availability and
     reliability of equipment to mitigate the effects.  That is, as I
     understand it, how it is stated in the current SECY, current version of
     the SECY document.
         What I would like to get into next is what we propose to
     augment this, if you will, to replace the fire protection functional
     inspection program.  In the broadest sense, our view of the future of
     the FPFI is that all assessment and inspection guidance for fire
     protection ought to be consistent with and integrated into the changes
     in NRC oversight and assessment that are included in the SECY document.
         We believe that performance indicators should be used
     wherever possible to monitor and assess fire protection and safe
     shutdown programs.  And in cases where performance indicators cannot be
     developed that are satisfactory, or readily acceptable, then the core
     inspection would be -- modules would be developed to carry on core
     inspections to be able to identify and trend licensee performance in
     those areas.
         In general, the licensee would have the principal
     responsibility as long as his performance stayed in the highest
     performance band, the green band.  NRC would continue to conduct
     baseline inspection, but no significant amounts of activity would be
     needed.  And, as we pointed out earlier, there would be increasing
     licensee and NRC activity as performance declined into the lower
     performance bands, that is in the broadest sense.
         What I would like to cover are our recommendations for
     short-term activities and long-term activities for fire protection to be
     integrated better into this process.  I have separate recommendations
     for NRC actions, NEI actions and individual licensee actions.
         In the short-term, we had understood from conversations with
     the staff that they were developing the current FPFI inspection guidance
     into discrete inspection modules, and we encourage that process to
     continue, with the addition of developing performance indicators
     wherever that is possible for each of those inspection modules, and I
     will indicate what we would like to see done with those modules shortly. 
     That is in the short-term, and by short-term, I mean in the next six to
     12 months.  The letter that we just sent to the NRC, and advised ACRS
     and provided copies of, provides a more detailed schedule for these
         What we propose as short-term activities for NEI, the first
     activity would be to form an issue task force, which is a group of
     working level experts in a given area who can pool their knowledge and
     expertise for whatever specific task NEI needs to have done.  This task
     force's responsibilities would be, first, to develop some near-term
     inspection guidance, or assessment guidance for licensees.
         Now, this short-term activity is intended, while we are in
     the process of implementing the long-term activity, to see whether there
     are any short-term needs, or any holes that licensees need to fill while
     we are getting the long-term process rolling.  It is intended to address
     an NRC concern that we might not want to wait, if findings in the FPFIs
     had proved significant, to -- for all licensees to address it, and to
     address the question of consistency and comprehensiveness of licensee
     self-assessments.  So we would be developing guidance and requesting
     licensees to look at their own programs if they had not performed recent
     inspection or -- I'm sorry -- assessment activities.
         Then we would ask the task force, and this would be one of
     the important roles, is to put their minds to drafting risk-informed,
     performance indicators to provide input to the staff.  This -- if the
     staff is developing inspection modules with performance indicators, we
     feel that industry expertise should be factored into the staff's
     preparation of these modules, and we would devote some significant
     efforts to suggesting performance indicators for staff consideration.
         DR. POWERS:  When you say risk-informed -- sorry.
         DR. APOSTOLAKIS:  The risk-informed indicators, I think we
     are going to have a problem defining those for an event like a fire.  I
     can see an indicator dealing with perhaps the frequency of minor fires,
     but anything beyond that, I don't know what performance means anymore. 
     I mean I have difficulty seeing the performance indicators that will be
     a good set that will cover a lot of things.  I mean you necessarily, you
     have to rely on programmatic requirements.  It is not like trains of
     safety systems that are being tested frequently and you can produce an
     unavailability figure and so on.
         With fires, I mean it is such -- especially the fires of
     interest are such rare events that I don't know how many indicators we
     can have.
         MR. EMERSON:  I am not going to try to pre-judge what the
     indicators would look like, but I would agree that they would probably
     need to address perhaps at least the elements of defense-in-depth.  You
     might want to measure your ability to prevent fires from starting,
     control of combustibles, your ability to detect and suppress, fire
     brigade performance perhaps.  Those might be areas where performance
     indicators -- no single indicator is going to do the job for the whole
     program, but, taken collectively, I believe that we can come up with
     enough to make the effort worthwhile.
         Now, as I said, I can't pre-judge what they will look like,
     and, as you pointed out, this probably is not going to be an easy
     process, but we definitely think it is worthwhile trying it.
         DR. KRESS:  It looks particularly difficult to put that on
     the four region map you have, because, you know, like in detection, that
     is can you or can't you, it is not four regions there.
         DR. APOSTOLAKIS:  And I don't know to what extent the
     detectors are tested.  Maybe Pat can enlighten us in a little bit.
         MR. EMERSON:  Well, there is in some test frequency, but,
     recently, there has been trends to extent that testing frequency by the
     utilities.  I think it was on a once per like every refueling cycle,
     they would go and then actually do some testing of the circuitry, maybe
     not specifically the detectors.
         DR. KRESS:  Those, in that sense -- or maybe the frequency
     at which it doesn't work.
         DR. APOSTOLAKIS:  Yeah, but when it comes, for example,
     suppression systems.
         MR. EMERSON:  You don't touch, generally touch those, no.
         DR. APOSTOLAKIS:  The ability to shut down.
         MR. EMERSON:  Safe shutdown systems, you mean.
         DR. KRESS:  Check and see if the water available and there's
     valves that are reliable.
         DR. APOSTOLAKIS:  But that is not performance.
         DR. KRESS:  Oh, performance is anything you want it to
         DR. APOSTOLAKIS:  Oh, I don't know.
         DR. KRESS:  That's another problem I have.
         DR. APOSTOLAKIS:  See, that's the problem I have, and, in
     fact, I copied the definition.  It says the extent to which something
     meets its intended purpose.  Now, I don't know that if you have water
     that is a performance by an objective criterion.
         DR. KRESS:  It's the extent to which it could meet it, and
     then you back off of that when you can --
         MR. EMERSON:  George, I would share your view that it will
     be a challenging exercise.  But, given the level of expertise in this
     area both within the staff and the industry, I think that if these
     people can't come up with useful performance indicators, the inspectors
     and the users of them, then I will agree then that it is not a possible
         DR. APOSTOLAKIS:  And this is in the short-term, so that
     makes it even more challenging.  But, anyway, I am just expressing a
     thought here.
         MR. EMERSON:  I understand.  And those opinions have been
     expressed by the staff and by my own peers in the industry, too.
         DR. POWERS:  When you say risk-informed on your performance
     indicators, you are using that in the sense of engineering judgment of
         MR. EMERSON:  I don't know that I would even try to
     characterize how risk information would be factored into them just yet. 
     I just -- we just haven't thought about them enough.
         The next task would be to recommend steps for integration
     fire protection into the overall assessment process.  Those are the
     questions that Pat asked on his last slide this morning.  How are we
     going to factor all of this into the new process?  And those questions
     have yet to answered and we would, hopefully, have the opportunity to
     work with the staff and make recommendations on how that could be done.
         Our task force would also request plants with no recent
     self-assessments, and by recent, I mean pretty much since the inception
     of the FPFI program in the last year-and-a-half, to take a look at
     themselves critically and see whether an assessment is needed in the
     short-term to address holes.  The main thing is for them to be aware,
     thoroughly aware of the health of their own program.
         DR. POWERS:  As I understand the status of self-assessments,
     and my understanding is imperfect at best, only just barely half the
     plants have done a self-assessment on both the fire protection and the
     safe shutdown programs.
         MR. EMERSON:  That's what our survey showed, it was
     approximately that.  Now, more had done one and more had done the other. 
     And, certainly, other plants that have not done what I would call formal
     self-assessments have had other types of either inspections or
     assessments that they might credit at least partially for that.
         DR. POWERS:  So it is a situation of you would ask people
     that had done self-assessment of their fire program, surely, but had not
     done the safe shutdown, now to go ahead and do the safe shutdown?
         MR. EMERSON:  I am not necessarily asking to go out and do a
     full blown self-assessment.  What I first would be asking them to do is
     to take a look and see whether, based on their -- based on what is going
     on in the industry, based on the FPFI results, based on their own
     knowledge of their own programs, whether it is time to take a look, and
     we would provide them some guidelines for how to do that.
         The whole idea of this is to get people to be looking at
     their own programs in the short-term, not asking them to go out and do
     expensive and time-consuming self-assessments unless they see a need for
     that.  You know, they need to be the masters of their own destinies.
         DR. POWERS:  Sure.  And a guy that has spent a lot of money
     keeping his program up to date doesn't need to do a self-assessment.
         MR. EMERSON:  Right.  That is also true.  We would ask the
     licensees to use the NEI guidelines to determine whether a
     self-assessment is needed in the short-term, and, although it is not
     reflected in there, if they do determine that one is needed, we would
     ask them to complete it probably by the end of the first quarter of the
     year 2000.  As I understand it, formal self-assessments are not easily
     scheduled and accommodated within a plant's cycle, so expecting them to
     do within a space of three months might be very unrealistic.
         Moving into the area of long-term recommendations, for NRC
     and the industry both, they would be basically implementing the
     performance indicators and the core inspection programs that were
     developed in the short term.  We would suggest that the core inspections
     use the modules that staff was intending to develop from the FPFI
     guidance, and we would suggest to the licensees that they use these
     modules for regulatory -- with those addressing regulatory requirements
     for their self-assessments when they determine that a formal
     self-assessment is needed.
         Some of the feedback that I've gotten from licensees, I
     won't call this a universal reaction, but a number of them have said
     well, you know, the FPFI was a good, thorough approach to reviewing a
     program, and it would make sense to use the guidance in a
     self-assessment as long as we didn't have to do it in the space of a
     month, either as part of an FPFI or as part of a self-assessment
     preparing for an FPFI.
         Now we would -- the licensees would conduct routine
     performance monitoring and/or NRC would conduct baseline inspections in
     the green band depending on the existence or lack of performance
     indicators.  We would propose that licensees conduct what I would call a
     focused self-assessment if a single indicator starts going south into
     the white band.  By focused I mean you focus on the area where the
     indicator is going south.
         If performance declines on a broader scale, we would propose
     a general self-assessment using more than one NRC module for -- with NRC
     oversight in the yellow band.  And this in general is consistent with
     the -- we believe with the guidance in the SECY-99-007.  Where FPFI, a
     large team inspection such as the FPFIs would play a role is if
     performance continued to decline further into the red band, obviously
     there are some major breakdowns in the licensee's fire-protection
     program, and an FPFI or an inspection similar to the FPFI pilots might
     be warranted because something more drastic is needed to turn things
         Continuing, NRC and licensees would continue other
     inspections and assessments that were not superseded by the new process,
     and I can't sit down and give you a full list of what those other
     inspections might be, but we're not precluding other appropriate
     activities.  We would expect appropriate credit for results of those
     other inspections or assessments against the self-assessments and core
     inspections that the NRC would be doing on an ongoing basis.
         I'd like to spend a couple of slides addressing some
     questions that the NRC has asked us in previous meetings or concerns
     that I've heard expressed privately as to why don't we just maintain the
     FPFI program in parallel with this new process.  So I'd like to address
     four specific concerns that I've heard.
         First of all, the first concern would be the FPFI is needed
     to adequately evaluate fire protection programs.  Pat explained very
     well this morning what some of the deficiencies in earlier inspection
     programs were, and the reasons why FPFI had beefed up the quality of
     inspections.  Now we believe that integration of fire protection into
     the proposed assessment process improvements will achieve that same goal
     with greater cost benefit, especially if we continue to use the FPFI
     guidance in discrete inspection modules by both the NRC and licensees.
         A second concern was what assurance do we have the licensees
     will conduct adequate self-assessments, and I think we heard some
     references this morning and some concerns that licensee self-assessments
     may not have been adequate.  We believe that this proposal provides for
     more timely and comprehensive assessments and inspections than
     continuing routine functional inspections, because the licensee is
     looking at himself with a set of known criteria, and the NRC is using a
     set of core inspection criteria that are based on the FPFIs.  I really
     believe that dual look by the licensee and the NRC would fill the same
     need without the need for the full-team inspections unless again as I
     pointed out earlier performance really declines in a drastic way.
         The third concern has to do with the significance of the
     FPFI findings.  You know, Pat again talked eloquently this morning about
     the measurement of significance for the FPFIs, and pointed out clearly
     what the status of the staff efforts are to assess significance.  Really
     the purpose of this overall program is to focus on safety-significant
     issues, and if we construct the fire-protection elements of that
     properly, we I think will meet a great many of the needs for focusing
     inspections in the right area.  I think if we set it up properly and
     implement it properly, the goal is certainly to identify
     safety-significant areas, and the program should accomplish that goal.
         Lastly, it was the question just raised by George about
     performance indicators, and as I said before, it'll be challenging, but
     we think the expertise is there to maximize chances of success, and we
     think that the effort is needed.  We at least need to give it a try.
         Now that concludes my discussion of the assessment and the
     FPFI follow-on program.
         DR. POWERS:  Fred, one of the original objectives of the
     FPFI program, one that probably has been subverted -- or subordinated,
     not subverted -- was reviewing the status of Thermo-Lag, and that has a
     certain political visibility that the NRC has to respond to.  In your
     view, does this combination of licensee self-assessments and NRC
     auditing or oversight, are these self-assessments going to give them the
     ability to respond to political interest in the Thermo-Lag issue?
         MR. EMERSON:  Well, the political --
         DR. POWERS:  The slow pace which is being resolved at some
         MR. EMERSON:  Well, the political discussion is basically
     over one element of defense in depth, and that's the adequacy of fire
     barriers.  And if we have constructed the inspection modules properly,
     we'll be in an objective way continually reviewing on a frequent basis
     the viability of the fire barriers you have at your site, whether it's
     Thermo-Lag or some other material.
         As far as addressing the political aspects, I can't speak to
     that, but I think it should be adequate to determine any
     safety-significance aspects of the fire-barrier issues.
         DR. POWERS:  As you probably understand, the question they
     have to answer every once in a while, episodically, it seems, is why is
     it taking the NRC so long to get the plants to resolve this barrier
     Thermo-Lag issue.
         MR. EMERSON:  Um-hum.
         DR. POWERS:  And I'm wondering if a response that went to
     the effect that we know we have multiple lines of defense here in
     degradation and one of those is not deemed risk-significant to some
     level that's going to be an effective response to that particular
         A rhetorical question.
         MR. EMERSON:  I understand the question.  I don't have an
     answer for it.
         DR. POWERS:  No one else does, either.  So let's move on.
         MR. MADDEN:  Dr. Powers, just one thing.  I mean, the
     Thermo-Lag question is just a little bit more complex than just
     responding to looking at the adequacy of a barrier, for example.  I
     mean, there have been changes in shutdown methodology and approaches as
     a result of Thermo-Lag and rerouting of cables, et cetera, et cetera. 
     So it's a little bit more complex than just that.
         MR. EMERSON:  I didn't mean to oversimplify it, Pat.
         Okay.  If there are no other questions, I'll move on to the
     area of fire-protection standards and guidance development.
         I think everyone's familiar with the provisions of the
     Commission decision directing the staff to work closely with the NFPA to
     develop Standard 805 on an expedited basis and to ensure a proper
     risk-informed performance-based approach, that that type of approach is
         The NFPA Technical Committee of Nuclear Facilities, and I'm
     not going to try to get too much into that, because you'll hear a
     separate talk from the NFPA representative later, released a draft for
     proposals or, in layman's terms, comments.  The distinction was lost to
     me until fairly recently.  These proposals or comments are due February
     19, and there are several cycles of comment still ahead of us which I
     think Mr. Bielen will elaborate on further, perhaps.
         DR. APOSTOLAKIS:  Are we going to comment, Dana, on 805?
         DR. POWERS:  That's one of the questions the committee has
     to address.  If we choose to comment, we'll have to bring it forward in
     front of the full committee, unless we choose to comment separately and
         MR. EMERSON:  I'd like to offer our current views on the
     NFPA 805, and these are understandably at a fairly high level.  Just
     based on my personal observations of the committee's activities over the
     last six months to a year, there has been a great deal of effort, and I
     can't stress that strongly enough, a great deal of effort by the
     committee members -- Ed Connell is one of them -- to develop a
     high-quality draft.  Recognizing that this foray into performance-based
     risk-informed standards is a fairly new area, there have been some
     extremely -- extreme amount of work has gone into developing this
     product to the extent that you see it so far.  In our view it is a
     high-quality draft, but it is still a draft, and it needs to go through
     the rest of the process to achieve its full potential as a useful
     standard for possible adoption in the regulatory arena.
         So we would urge that the process continue using the NFPA's
     approach --
         DR. APOSTOLAKIS:  Let me understand something you just said. 
     It's not clear to me what the role of the standard is in the whole
     structure of things.  We are publishing the regulatory guide, right?
         MR. MARSH:  Yes, sir.
         DR. APOSTOLAKIS:  And I have perhaps the --
         MR. MARSH:  FPFI.
         DR. APOSTOLAKIS:  And then the standard gets published.  How
     does that change the way we do business?
         MR. MARSH:  Well, this is all part of a Commission-approved
         DR. APOSTOLAKIS:  I understand that.
         MR. MARSH:  We asked the Commission, we recommended to the
     Commission option 2, which option 2 said let's not go forward with our
     own rulemaking to develop our own risk-informed performance-based
     fire-protection reg guide.  Wait for the NFPA.  And if that standard
     meets our -- we would recommend approval, then we'll come back to the
     Commission and recommend approval of that standard.
         DR. APOSTOLAKIS:  So that would be the risk-informed here.
         MR. MARSH:  Yes, sir; that's the risk-informed avenue.
         DR. APOSTOLAKIS:  And you will stay during the discussion
     with the NFPA?
         MR. EMERSON:  No, I'll let the NFPA representative, Mr.
     Bielen, address --
         DR. APOSTOLAKIS:  But you will be in the room?
         MR. EMERSON:  Yes, I'll be here.
         DR. MILLER:  So the plan is to, if it meets the needs, to
     endorse this standard as a reg guide down the line.
         MR. MARSH:  It would be endorsed through a rulemaking
     effort, okay?  You'd have to modify the rules, the regulation that would
     be either 50.48 or Appendix R, however it gets constructed, as an
     alternative to the existing regulatory structure.  The option was to the
     Commission we would allow -- this is a voluntary standard.  If it's
     endorsed, it would be a voluntary way of meeting 50.48.  It would not be
     a requirement for all licensees to comply with the NFPA standard.  It
     would be voluntary.  And it would have to be done through a rulemaking
     effort, changing the regulations to endorse the standard.
         DR. MILLER:  And this standard is being developed by --
         MR. MARSH:  NFPA.
         DR. MILLER:  And that -- the standards development group
     comprises a selected group.  Does that include staff --
         MR. MARSH:  I'd like them to tell you all about that group.
         DR. MILLER:  Okay.
         MR. MARSH:  There's a lot of important insights that people
     have brought to that committee.
         DR. MILLER:  We'll hear more about it later.
         MR. MARSH:  Yes, sir.
         DR. APOSTOLAKIS:  You will hear a lot.
         MR. EMERSON:  We expect because of the effort that's going
     in to risk-inform the standard that it could be an important factor in
     improving the use of risk information for fire protection.  I expect
     there will be a number of insights captured and ways to use risk that
     will end up benefiting the industry.
         DR. APOSTOLAKIS:  So these are your personal views.  NEI has
     not reviewed it.
         Does NEI participate in the development of the standard?
         MR. EMERSON:  NEI has a representative on the committee, as
     do other industry organizations.
         DR. POWERS:  Do you have any sense of the enthusiasm that
     there might exist within the industry for this guide?
         MR. EMERSON:  I think there is a lot of interest, and I
     think there are concerns.  And that's the reason why I'm recommending
     that we allow the process to continue to completion, because those
     concerns need to be addressed in making sure we have the best possible
         DR. APOSTOLAKIS:  I'll bet you the concerns have to do with
     the word "voluntary."
         DR. POWERS:  No, I suspect the concerns have to do with the
     word "burden."
         DR. APOSTOLAKIS:  What?
         DR. POWERS:  "Burden."
         DR. APOSTOLAKIS:  Well, that goes together with --
         DR. POWERS:  Go ahead, Fred.
         DR. APOSTOLAKIS:  It will be as voluntary as 1.174 is, don't
     you think?
         DR. POWERS:  No, I think this will be a completely voluntary
     thing.  I think this is just an alternative to using Appendix R.
         MR. MARSH:  1.174 is a technique one can use, right?  This
     would not be a -- this is a regulatory requirement.  NFPA 805, if it's
     endorsed, and if a licensee chooses to go that route, forms the
     regulatory oversight, it's a new licensing basis, you know.
         MR. EMERSON:  One of our beliefs on maximizing the
     usefulness of the standard to the industry would be to assure as much
     flexibility in its application as possible.  We think that we should be
     allowed to use it not just in an -- say an all-or-nothing proposition,
     you either choose it as an alternative to the existing standard or you
     can't use any portion of it at all for any reason, and we believe that
     flexibility in its use, to take some of the insights that have gone in
     through the efforts of the committee should be made available to
     licensees, even those licensees, even those who choose to remain within
     the existing licensing basis to improve the application of risk insights
     to their compliance with that licensing basis.
         DR. POWERS:  Well, you're raising a big issue here, which
     has been a concern to some members of the committee.  Of course, if the
     industry can use this standard flexibly, then the staff should be able
     to do the same thing.  So using PRA insights, for example, to increase
     regulatory requirements in the deterministic side should be as
     acceptable to the industry as it would be to use this guide to support
     exemption requests.
         And then the big question is do you really have two tiers? 
     Can you really pick and choose if you have two tiers and say well, gee,
     you know, tier 1, this looks good to me, I'm going to do it, but the
     other part I don't like, I'll switch to the other tier.  Then we are
     creating an even bigger mess than we have now.
         So -- and that's something that's bigger than fire
     protection, in my opinion.  We wrote in one of our letters that there
     will be two tiers of regulation, and in the stakeholders' meeting they
     picked it up and said yes, yes, we'll have two tiers.  But I'm not sure
     that everybody understands what having two tiers means, and I don't
     think it means that you will pick and choose and create your own tier. 
     You know, either you follow tier 1 or you follow tier 2, because there
     may be other requirements that are in tier 1 that are related to the one
     that you like, or you don't like.  So that is something that perhaps NEI
     also wants to think about.
         MR. EMERSON:  We certainly have thought about it.
         DR. POWERS:  I think when you look at 805 the thing that
     comes through almost immediately is gee, can a guy come pick and choose
     in here?  I mean, it just struck -- by page 3 I was asking that
     question.  And I think it's one that we ought to pose to the committee,
     have they thought about it.  Because I think they have thought about an
     integrated structure which doesn't lend itself well to picking and
     choosing, and then what Fred's saying is gee, for maximum flexibility,
     there are -- I believe your words were ideas and thinking that went
     behind some of these things that could be applicable.  And that's
     interesting.  That may be the grist for reg guides, and that may be
     grist for regulations.  And it would be interesting to interrogate on
     that point.
         DR. APOSTOLAKIS:  Well, I really think our committee should
     look at this issue of the two tiers, you know, at a higher level, not
     just in the context of fire protection and maybe say something.  Because
     evidently now it's acquiring momentum, we're going to have two tiers,
     and I'm not sure if people have really digested the implications or
     possible problems.
         DR. POWERS:  When the ACRS as a whole has addressed that
     issue, I guess right now they have a mixed record.  In one case they
     recommended picking and choosing, and in one case they rejected picking
     and choosing, and in both cases they were overridden.
         DR. KRESS:  In the source term reassessment as a committee
     we recommended picking and choosing.
         DR. POWERS:  I guess we were endorsed in that.
         MR. MARSH:  Right.  That approach is being endorsed.  That
     is allowed.
         DR. APOSTOLAKIS:  But in the last letter I think we just
         DR. POWERS:  Yes.  What we wanted the Commission to be aware
     of is that they were going to proliferate regulations and proliferate
     difficulty in having a trained work force to inspect and enforce those. 
     And it's very difficult --
         MR. MARSH:  Assessing compliance with the structure,
     whatever that structure may be.  And even in proposing changes to the
     structure in an amendment space, what is being deviated from.
         DR. POWERS:  We have enough difficulties with the
     pre-'79-post-'79 split, the BTA and Appendix R split, and all the
     exemptions.  This is a group of people that may not be wild about
     picking and choosing.
         MR. EMERSON:  I would agree that the picking and choosing
     process is not on the surface something that you would want to sign up
     for, but I guess where I'm going is that a licensee who has a great deal
     invested in his current licensing basis and doesn't want to make the
     extreme effort to transfer to an entirely new, different licensing basis
     should nonetheless be able to reap the benefits of risk information in
     his compliance with the current licensing basis, and if there are
     insights that the NFPA process has offered that would be useful in that
     area, if there are places where it would make sense to apply those
     insights, then I think we should explore ways to do that.
         DR. APOSTOLAKIS:  Now wouldn't or shouldn't the regulatory
     guide in preparation now have words to that effect?  I mean, I
     understand its main purpose is to consolidate the existing regulations,
     but since we are going through the process, there should be some
     allowance for risk information along the lines you just set.
         MR. EMERSON:  Well, the staff this morning talked about the
     extent to which you put risk information into the reg guide versus
     whether you use risk information to implement the reg guide, and I think
     that's going to have to come out as the reg guide advances farther from
     its current outline form.
         DR. POWERS:  It seems to me that just Reg Guide 1.174
     provides the adequate opportunity for the occasional use of risk
     information to modify your licensing basis in light of risk information. 
     You know, if you're not going to switch completely over but you find one
     element of your program under Appendix R or the BTA, that would benefit
     from risk information; 1.174 looks like it's a perfectly legitimate way
     to go about taking advantage of it.
         DR. KRESS:  I thought that too, Dana.  Then I got to
     thinking that 1.174 in total requires a section that says you will meet
     the deterministic requirements of the rules.  And then when you come up
     against here you've got one set of rules versus another set.  What does
     that particular provision 1.174 mean, and how do you decide whether or
     not you've met that stricture?  I'm not sure how you --
         DR. POWERS:  Well, it seems to me that that stricture exists
     that you will meet the requirements of the rules except the rule that
     you're trying to get changed.  I mean, it's not a catch-22.
         DR. KRESS:  Well, that is catch-22 I think.
         DR. POWERS:  Well, it could be, but we were told explicitly
     that it is not.
         DR. KRESS:  It meets all the rules except the one you're
     trying to change.
         DR. POWERS:  Yes, I mean --
         DR. KRESS:  So we'll just systematically change all the
     rules -- I think that is a catch-22 at 1.174.  When you're dealing with
     rule changes --
         DR. POWERS:  We worried very much about that when we
     discussed 1.174 when it was being produced, and it became -- not that we
     thought it was the intent.  We were just worried about the explicit
     language.  And I think there's clarification in that, that it's meeting
     all the other rules, not the one that you're actually addressing.
         DR. KRESS:  1.174 is generally related to plant changes
     themselves, specific changes to the procedures or the plant
     configuration or something, and the question is does the resulting new
     configuration meet all the rules.  It normally doesn't talk about
     changing rules because licensees don't change the rules.  They get
     exemptions from them or something.  So that's why I think it tends to be
     a catch-22.
         DR. POWERS:  I mean, here you would not really be changing
     rules either.  You'd be implementing in a different fashion.
         MR. WEST:  This is Steve West.  This is a question I think
     we're going to have to deal with later.  I'm not sure what it has to do
     specifically with the development of NFPA 805 at this stage.  I mean, I
     think the objective of the committee is to develop a standard for a
     performance-based, risk-informed fire protection program at nuclear
     powerplants, and I trust that the committee members aren't doing that
     with also the -- in the back of their minds trying to work out how they
     could fit this piece or that piece into an existing program without
     adopting the standard in whole.
         You know, right now under 5012, which governs the exemption
     process, a licensee can request an exemption and it's basically up to
     them to submit a technical basis that supports the exemption.  And I
     guess if they were to say the standard is in place, if they could use
     techniques that are specified in the standard or other information in
     the standard, we'd have to decide at that point if it was technically
         Now if all of a sudden the standard's out and some licensee
     comes in with 100 exemptions, but they're not going to adopt the
     standard, I mean, that raises a question, right?  Because you haven't
     heard much about the standard yet, but to implement the standard is
     going to require some effort on the part of the licensees.
         DR. POWERS:  No kidding.
         MR. WEST:  For example, there's a sitewide risk assessment,
     and that's one of the bases that gives us comfort in having this
     performance-based risk-informed standard in the first place.  There's
     this overlay of the sitewide risk assessment, which we'll hear more
     about.  I don't want to get into that.  But if all of a sudden licensees
     see this great -- a lot of flexibility and they can come in with a lot
     of exemptions, you'd have to wonder if they're trying to come up with a
     cute way or having a risk-informed, performance-based, fire protection
     program without the sitewide risk assessment, for example.
         DR. POWERS:  I'm pretty sure I know which one of those is
     the least pained route, and it is not the exemption route.
         MR. WEST:  Yes.
         DR. POWERS:  I think we're going to have to move on.
         MR. EMERSON:  Last in this topic, there was a good
     discussion this morning of the comprehensive reg guide, and my only
     comment here is that we are looking at it very carefully, and will
     provide comments at the time that Ed Connell indicated this morning.
         DR. MILLER:  Do you have a comment on the objective?
         MR. EMERSON:  I'm sorry, on the --
         DR. MILLER:  This reg guide.  Do you have a comment on the
     objective of the reg guide?
         MR. EMERSON:  As far as consolidating guidance?  I think Ed
     characterized it correctly this morning, that industry supports the
     consolidation of guidance.
         Okay.  Next is another area that we spent some time talking
     about before, and that's the area of fire-induced circuit failure
     resolution.  And what I propose to talk about here is basically work in
     progress by the NEI task force as to what our currently envisioned
     approach looks like, and certainly we would be receptive to feedback
     from your committee, as well as from anyone else.
         The approach that we're looking at at this point and working
     to put more meat on involves three basic elements.  One is looking at
     the cable failure modes and mechanisms if you get a fire large enough to
     cause cable damage, how will it fail, to try to hopefully add some
     knowledge to what currently exists as to how cables will fail in the
     event of fires of certain sizes.
         DR. MILLER:  Is there an expectation for a data base out
     there on that, or are you going to generate one in that area?
         MR. EMERSON:  Well, we're certainly looking at the existing
     information that's out there, and we would consider augmenting that with
     more research if the need arises.  I'm not going to try to address what
     the Office of Research is doing in that area right now, and we haven't
     made any decisions on what more research might be necessary, but
     hopefully we could compile some additional data from existing literature
     to the extent that it applies to this area.
         Again, the first area involves cable failure modes and
     mechanisms.  The second area involves risk information.  And when I say
     risk information, I'm not talking about the likelihood of cable failure
     given a damaging fire, it's the likelihood that you will either get a
     fire large enough to cause cable damage, the likelihood that you can
     recover from the damage that's involved in a fire, or the availability
     of alternate systems to help you in the event that your systems are
         And the third area of course is other considerations.  Since
     this is a risk-informed method and not a risk-based method, we would
     have to consider the usual deterministic considerations.  We would have
     to consider defense in depth.  We would have to consider safety margins
     and other things that were touched on by the staff this morning.
         I think I just talked about this slide without putting it
         DR. MILLER:  As I look at that process, it sounds quite
     good, except I expressed a concern, is there a data base that will
     provide you to get off bullet 1, so if you don't get off bullet 1, you
     won't go to bullet 2, right?
         MR. EMERSON:  Well, I expect we will be able to apply bullet
     2 insights.  I think the best possible method would address all three
     areas.  If I can get into subsequent slides, I want to get into each of
     these areas in a little more detail.
         Our intent first would be to try to look at the data base or
     the information we can accumulate and the types of failure mechanisms we
     can postulate as a result of our review to screen out potential failures
     involving our initial goal interactions between two different cables in
     the same tray.  Then next we would consider what we could do with
     interactions between conductors within the same cable.
         This would be again based on an improved understanding of
     cable failure modes based on review of test results, new testing if that
     was appropriate, some sort of analysis.  We haven't pinned down exactly
     what is going to serve as the basis for this yet.  We are developing
     what needs to be done to make this method workable within our committee.
         DR. POWERS:  It seems to me that there is a real challenge
     in knowing whether the test that you identify or what analyses that you
     have on cable failure modes have really improved the understanding.  I
     have certainly seen presentations in which individuals have done a test,
     and they have said see, this particular kind of failure is very
     unlikely, 12 out of 12 times I tried it, I didn't get this particular
     kind of failure.  That kind of failure was precisely the kind of failure
     that has been observed in accidents, Browns Ferry not being the only
         This whole area of what is an improvement in understanding
     and what is an inapplicable data point seems to be a challenge to me.  I
     certainly don't know the answer of what is an adequately appropriate
     test.  Is there someone trying to figure that out, what is a good data
     base on cable failure modes and what goes into it and what is excluded
     because it's just not applicable?
         MR. EMERSON:  I think Nathan would like to say something.
         DR. POWERS:  He gets his opportunity tomorrow morning.
         MR. SIU:  I was waiting to hear what Fred was going to say.
         Again, tomorrow I think we'll talk about at least how we're
     approaching the problem, and I think you're right, if you try to do this
     in a purely statistical fashion saying gee, I've got zero failures out
     of 12 or I got one failure out of 12, you're really susceptible to this
     issue of the applicability of that kind of test to the situation you've
     got at hand, and what you really need is some sort of model-based
     approach where you understand what are the parameters that affect that
     likelihood and then use the test results to quantify the model
         We are right at the beginning of that stage trying to
     identify what are those parameters and what are the sources of data that
     we might be able to use to quantify those parameters.  I don't know what
     industry is doing along these lines.
         MR. EMERSON:  I would say that's a pretty good
     characterization of what we're doing too.  We've been reviewing the test
     reports that we can find that have results applicable to this activity. 
     We've been talking to individuals who are knowledgeable in cable failure
     modes and mechanisms, and given fires, given their experience in the
     industry, both the nuclear industry and outside the industry, we're just
     at the stage now where we're trying to pull some of those insights
     together and decide what else we need to do to improve the knowledge
     base to the point where we can make some statements that we the industry
     can accept and the staff can accept as a screening criterion for this,
     and I wouldn't pretend that we could come up with this lightly or in the
     near future.
         You know, this is where we intend to go, but the process of
     fleshing out our intent with solid information that the staff and
     industry can accept is going to take a little longer.
         DR. POWERS:  You and I both attended an international
     conference in which we saw lots of people standing up and saying we're
     going to create a new fire-incident data base.
         MR. EMERSON:  Um-hum.
         DR. POWERS:  It's going to be international in scope.  And
     we did not hear a lot of people standing up saying we're going to create
     data bases on effects of fire like cable failure modes and things like
     that.  It is my suspicion that fire incident data is not transferable
     from one country to another, but fire effects, like cable failure modes,
     is transferable from country to country.  Should we be pressing these
     various people creating data bases to, if not abandon their incident
     data base, at least augment it with failure mode data bases?
         MR. EMERSON:  Well, I wouldn't try to say whether we should
     scrap the efforts to improve the incident data bases internationally,
     but certainly we should make the effort to broaden the data bases to
     individuals in other countries, and as an example of that, we heard at
     our last information forum a presentation from a senior engineer at
     Electricite De France about cable testing that they have done.  It
     wasn't with this in mind, but the fact is that other countries are
     interested in cable failure modes, and there may be some ways that we
     can take advantage of work that they're doing and vice versa.
         As far as developing a data base, certainly the process of
     compiling information and test results, it would have to go into some
     sort of a data base.  I just don't know what that would look like.
         Certainly you could not make a decision on screening out
     something based on a cable failure mechanism in isolation from
     consideration of things like defense in depth and safety margins when we
     would propose that any decision based on this tool to screen out
     potential interactions at this step would be done through consideration
     of defense in depth, so that you didn't just say well, we think it's
     unlikely, boom, it's gone.  We'd have to think about it as to what the
     consequences of screening that out were.
         Okay, the second method has to do with -- the first was
     intended to be a generic method.  The second step is intended to be a
     plant-specific method.  One member of the staff pointed out at one of
     our meetings, and rightly so, that it's difficult to create a generic
     criterion for screening based on risk, because plants have
     plant-specific risk elements.  So we would propose that the second
     element, the application of risk, be done on a plant-specific basis to
     address failures or potential failures that had not been screened out
     with the first one.
         We would -- the types of analysis that would be necessary to
     apply this, first we would ask the proposed user to determine either the
     frequency of a damaging fire or the probability of conditions supporting
     a damaging fire, determine whether that reached some threshold value. 
     We would ask them to determine the probability of recovery of equipment
     if it were damaged through either operator action or some other type of
     recovery, and determine the availability of redundant equipment if it
     could not be recovered.
         We would look at the PSA elements that went into each of
     those three determinations and develop an appropriate criterion with
     which to compare that, and again in parallel consider the impact on
     defense in depth and safety margins.
         As a result of this second step, should it come about as we
     foresee, you would have screened out more potential failures based on
     plant-specific determinations.
         The rest of the method has to do with, you know, if you were
     unsuccessful in screening out potential interactions at this stage, you
     probably have a pretty good idea that they were safety-significant
     enough that you should do something about it.  Before you do that, you
     might want to analyze it using more traditional analysis methods, the
     kind that are used currently by licensees.  And then lastly, once you'd
     finished that step, to take appropriate action to address any remaining
     potential failures that you could not write off as being nonsignificant. 
     And obviously you need to document what you've done for future
         I don't want to spend a lot of time on this.  This covers
     some of the elements that you would consider in the --
         DR. MILLER:  Do you have a kind of expectation for a time
     frame in --
         MR. EMERSON:  In the development of this method?
         DR. MILLER:  For developing this method and knowing that the
     data base is certainly a sizable unknown in this whole issue.
         MR. EMERSON:  Yes.  I have some slides at the end which kind
     of explain what our time frame is for developing the pieces which
     support this, if you can wait.
         As I said before, our primary goal is to -- we feel we
     can -- if we could address interactions between cables, that would help
     us rule out a lot of interactions.  If the likelihood of interactions
     between cables is low, we could screen out a large fraction of potential
         DR. MILLER:  That would go a long way in answering a lot of
     problems we have right now independent of the rest of your process,
     wouldn't it?
         MR. EMERSON:  Those on our committee who do this sort of
     analysis say that would help a lot.  We always face the likelihood that
     perhaps this is an unrealistic goal, but this is where we're going at
     this point.
         Obviously we'd like to consider failures within single
     multiconductor cables, that that would be a second-order goal.
         In the area of the risk information, I'm not going to try to
     go through this in any detail.  In looking at the frequency of fires or
     the probability of conditions supporting damaging fires, these are the
     types of parameters, PSA parameters that we would consider --
     initiation, exposure, growth, detection and manual suppression, and
     automatic suppression are the principal parameters that would allow you
     to calculate a probability of achieving a damaging fire.
         The other two elements involve the probability of recovery
     of equipment, as I said, and the availability of redundant equipment,
     and these are the parameters that you would be able to calculate those
     values from.
         With respect to the timetable, our current timetable is to
     in the area of the generic circuit failure mechanistic method we're
     developing a method of -- a draft, a matrix of failure combinations by
     the end of this month, and by the end of February we're going to have
     drafted a program plan for achieving our goals.  It will reflect the
     information we've gathered to date, the test results and so forth.  It
     will address what further work we need to do to gather more information
     or conduct testing or address further analysis requirements, and it
     would factor in the work that the Office of Research is doing to make
     sure that we're not doing things that are entirely redundant to their
     activities.  So this program plan is intended to say how we are going to
     get this tool developed and what we have to do to get there and lay out
     in more detail how we will get there.
         In the area of the plant-specific risk tool, we have drafted
     an outline for the three specific risk methods and their use, and we
     intend to turn that into the program plan that I mentioned for the
     earlier tool, again by the end of February.
         Factoring in the deterministic methods including the defense
     in depth, safety margin, and traditional deterministic methods, we are
     going to put that piece of it into the overall program plan, again by
     the end of February.  So our initial timetable for developing how we are
     going to turn this plan into something of a reality is due by the end of
     next month.
         We expect to run some sort of a proof of concept or a pilot,
     and we currently envision that this would take place during the March
     and April time frame.
         As Steve has pointed out this morning, we have been
     interacting with the staff on at least a monthly basis, I think, since
     we actually started our work, and we've briefed the staff within very
     short periods of time after our committee meetings.  And so they are
     pretty much in tune with what we are doing and where we plan to go.
         DR. MILLER:  What will be the purpose of the pilot?
         MR. EMERSON:  The purpose of the pilot would be to see
     whether this method could work at an actual site, whether a plant could
     take this method and see does it work or not, given how we expect it to
         DR. POWERS:  Fred, we were anticipating having another
     subcommittee meeting in Region I in June.  I wonder, would that be an
     appropriate time to come discuss what you've done here?
         MR. EMERSON:  We'd always be available to share with you our
         DR. POWERS:  It would be in Region I offices.
         MR. EMERSON:  Should be no problem.
         DR. POWERS:  Okay.  We might just stay in touch as you
     progress along.  Sometimes schedules slip.  Not NEIs, but sometimes our
     schedule slips.  And if it's convenient and what not, that might be a
     good time to do it.
         MR. EMERSON:  That's fine.
         To wrap this up, I have no illusions that this plan is the
     same thing as an actual method.  You know, what we intend to do is all
     well and good, but it's what we end up with that will be whether we have
     achieved our goals or not, and we're going to be exerting some
     significant efforts to try to get this to be a workable method.  And we
     look forward to further discussions with the staff on making this a
     method the staff can embrace as well as the industry.
         The last area has to do with -- the last area I want to
     cover, and I only have one slide for this, is the area of risk-informed
     fire applications.  We were asked to review draft NUREG-1521, which
     covered a number of such potential applications for risk information and
     performance bases to the fire-protection area, and we think it's
     important, as I indicated earlier when we were talking about the draft
     standard, to be able to apply risk information to existing
     fire-protection programs under current licensing bases to gain the
     advantages of that information as perhaps a more objective way for
     addressing either plant-specific or generic issues.
         And what we propose here is that we agree with the staff
     that this is a worthwhile goal to promote the increased use of risk
     information and to work out agreed-upon actual applications that staff
     can have some confidence that the industry knows how to use properly and
     the industry can have some confidence that the staff will accept them if
     they are properly done.  But anyway, predeveloped applications, if you
     will.  And we would propose to start that.
         DR. POWERS:  We had discussions earlier this morning on what
     it meant to do fire-risk assessments and the quality of our tools, and I
     would hope that that would be an area of a great deal of cooperative
     agreement, because it's clear that we're all suffering from a lack of
     tools, the industry and the staff, for exactly the same reason, where we
     can find nonconformances and noncompliances, but it's very difficult
     right now to do anything that looks like a justifiable or well-supported
     assessment of the risk-significance of those.  And as we move our
     inspection and enforcement policy more toward risk-informed, it's in
     everyone's best interest to have acceptable tools that are broadly
     supported within the technical community to make these judgments about
     risk and what the significance of these findings are.
         MR. EMERSON:  I would agree that having those tools is
     needed, and having ways to use those tools in agreed-upon ways is also
         DR. POWERS:  That's right.
         Do the Members have any additional questions?
         Fred, always useful to get your insights, and we'll stay in
     contact perhaps for our June fire-protection meeting, what not.
         I have made an adjustment to the schedule to accommodate
     some travel plans, and we propose now to move on to the presentation on
         MR. MARSH:  From the industry?  From the --
         DR. POWERS:  From the group.
         MR. MARSH:  NFPA?
         DR. POWERS:  Yes.
         MR. BIELEN:  Good afternoon.
         DR. POWERS:  As you progress through your presentation, if
     there is a point at about midway that it would be appropriate to take a
     break, you might indicate.
         MR. BIELEN:  Okay.  Will do.
         I just wanted to give you a little bit of a brief overview
     of where we are with the development of NFPA 805, just go over the
         The purpose of this presentation really is to give really a
     progress report, and I would want to differentiate that between a
     progress report versus a defense.  We're not going to really be
     defending the document as far as what we did or some of the details. 
     Some of the details actually I'm not going to be able to answer, because
     some of the experts that we have, for instance, on PRA are not here
     today.  I have some committee members here in the audience to help
     support the presentation if we need, but as far as some of the details
     go of the report, we may not be able to answer as we're going through. 
     So this is really to be just a progress report on where we are with the
     document, where we are in the cycle, and how much further along we have
     to go.
         I think it would be useful to also review the NFPA
     standards-making process.  I've done this before on some other
     presentations previously, but I think it would be worthwhile to go over
     again a little bit about the NFPA process and how that works so that you
     get a better feel for what a consensus-base document actually is, the
     way we present it.
         Also I'd like to go over where we are in the cycle, again to
     show you how far along we are, where we are at this point, and what the
     steps are in the future that we have to still go through.  And then I do
     want to go over a brief overview of NFPA 805 and I call it Draft 6.3,
     which was released to the public back at the end of November -- so we've
     gone through quite a few number of drafts -- and then finish up with the
         The NFPA standards-making process -- and again this is just
     a real brief overview, and I left out a lot of the details and some of
     the minor points in between -- but essentially the NFPA Standards
     Council, which is a 12-member committee that oversees all the standards
     activity, approves a new project, as in this case with NFPA 805.  An
     NFPA technical committee is then formed.  In this particular case the
     Technical Committee on Nuclear Facilities was an existing committee with
     some other documents, NFPA 801, 802, 803, and 804.  So in this
     particular case, an existing technical committee took on the
     responsibility of developing this new project, NFPA 805.
         The Technical Committee would then have to on new projects
     develop a draft document to be released to the public.  And the reason
     why we have to have the draft document released to the public is because
     we have a proposal closing date or a call for proposals, and we have to
     have a document that the public has to see in order to submit proposals
         So this is a consensus-based or a consensus process, so we
     have several different steps as far as proposals and comments, and I
     heard earlier how there was some confusion and differences as to what
     they are, but again I won't get bogged down with the details of the
     differences between it.  But basically it's a two-step process where
     there's a proposal period and a comment period.  So there's a deadline
     for call for proposals on the draft document.  The committee --
         DR. MILLER:  Excuse me.  What's the draft document?
         MR. BIELEN:  The draft document is NFPA 805, and I --
         DR. MILLER:  The draft document you're talking about in
     bullet 3 is what we have in our hand right now.
         MR. BIELEN:  Right, Draft 6.3?
         DR. MILLER:  Right.
         MR. BIELEN:  Yes, I believe the committee has that.  Okay.
         DR. MILLER:  I don't know if it's 6.3; we have a draft.
         MR. BIELEN:  Right, a draft of NFPA 805.  Yes, it would be
     6.3, which is one that was released to the public.
         There's a deadline on proposals, and I'll go over the cycle
     on the next series of overheads that I have.  But essentially then the
     committee would have to meet and review all the proposals that we have
     both from the public and any ones that are generated by the committee
     and take an action on them.  And there's --
         DR. MILLER:  Proposals meaning in this case comments?
         MR. BIELEN:  We can call them comments, yes.  In the NFPA
     process we call them proposals, but they're essentially comments on the
         DR. MILLER:  So the Technical Committee basically as a
     consensus committee spent the better part of a year, I suppose, coming
     up with that.
         MR. BIELEN:  About two years, yes.
         DR. MILLER:  Or two years.  How large a committee was that? 
     I could count the members, but --
         MR. BIELEN:  Yes, there's -- let me just see here.  I do
     have something here.  Actually not for the committee.  This is just some
     information as far as the number of people.  We have about 51 people
     altogether, including technical committee members, both principals and
     alternates, and then there's several volunteer people.  And just to give
     you a feel for the types of people that we have, I could just go over
     some of the different areas and the names and the industries.
         As far as the industry users or the user groups we have Stan
     Davis from Pennsylvania Power & Light, Frank Garrett from Arizona Public
     Service, who represents NEI on the committee, Dennis Henneke from
     Southern California Edison, Chris Ksobiech from Wisconsin Electric,
     Cliff Sinopoli, who is with us today, from Baltimore Gas & Electric,
     representing EEI.  Ray Tell from Los Alamos National Laboratories.  Mike
     Vitacco from Westinghouse Savannah River.  Lee Warnick, who is with us
     today from Virginia Power.  Then we have a series of special experts. 
     Rick Alpert from Triad Fire Protection Engineering, Mario Antonetti from
     Gage-Babcock, Tom O'Connor from EPM, Arie Go from Bechtel Corporation,
     Liz Kleinsorg from Duke Engineering.  Don Kohn, Dave Notley, Dan
     Sheridan, Black & Veatch; Bill Sullivan, Contingency Management.
         And I guess maybe it will take a little bit longer --
         DR. MILLER:  I didn't really want you to read all the
     members.  I was just trying to -- I meant through the process.  I'm
     trying to relate it to the process I've been through, so --
         MR. BIELEN:  Okay.  You've been on the NFPA process before?
         DR. MILLER:  No, I've been through a different --
         MR. BIELEN:  Different process.
         DR. MILLER:  Standard process where we start out with a
     reasonably small committee that develops a draft, and that goes to a
     larger committee.
         MR. BIELEN:  Yes, we've had task groups that went over
     different chapters, and then the task groups would get together with the
     main committee and go over the whole document.
         DR. MILLER:  Page 50, I assume that was the one that went
     over the overall document, and then different groups developed different
         MR. BIELEN:  Right.  Correct.
         DR. POWERS:  In light of the public interest that
     fire-protection issues have generated, I'm surprised that there isn't a
     member that would -- what we refer to as the public when we talk about
     nuclear regulations.
         MR. BIELEN:  Yes, we have a category for consumer, but very
     few consumers or the general public join into the technical committees,
     whether it's this Nuclear Facilities Committee or any of the other ones. 
     It is a category that we have in the process, and unfortunately the
     consumers don't have a lot of funding I think it is to attend a lot of
     the committee meetings, so they don't apply and don't attend.  But also
     the meetings are open committee meetings, so any member of the public
     can attend any of the committee meetings.
         DR. POWERS:  Okay.
         MR. BIELEN:  So they don't have to formally be a member of
     the committee, they can attend.  And actually we do get several guests,
     but they're usually from the industry or insurance or something along
     those lines.
         DR. MILLER:  Did you invite specific people from the public
     to participate from the very beginning or just let it know it's open?
         MR. BIELEN:  The latter.  We pretty much publish when we're
     having our meetings and where they're going to be, and it's open for
     anyone to attend.  So we didn't specifically invite members from
         DR. POWERS:  Yes, I think that is one of my inherent
     objections to the entire consensus process --
         DR. MILLER:  Well, the process I was involved in -- in fact
     I represented the public for four or five years on it -- they also
     invited somebody specifically who participated from a quote "antinuclear
     group," who did participate, as well as I did.  We too represented the
     public.  Of course we had to pay our own way, so that's a big issue. 
     This is not an inexpensive process.
         MR. BIELEN:  Correct, and all the members of the committees
     are volunteers, and they pay their own way.  So this isn't funded
     through NFPA in any way.
         DR. MILLER:  So at this point the document we have has been
     through the consensus process to the point where all issues, all
     objections or issues brought up by every member of the committee have
     been addressed independently?
         MR. BIELEN:  No, actually --
         DR. MILLER:  That process at that point now?
         MR. BIELEN:  We're still in the process right here where
     it's call for proposals.  The proposal closing date in some of the other
     overheads I have is February 19 of this year, '99.
         DR. MILLER:  My question was, have all the issues brought up
     by the Technical Committee been addressed at this point or not?
         MR. BIELEN:  Well, the committee is addressing the issues as
     we go along and always making modifications to it, so we're not done
     with addressing technical issues yet.
         DR. MILLER:  So internally the consensus process is not
     done, as well as externally.
         MR. BIELEN:  Correct.  Yes, internally we've still got a
     ways to go, and I'll show you when I go through the cycle, and actually
     we're still -- we haven't even reached this point yet where -- well,
     we're in the call for proposals.  We haven't reached the deadline yet. 
     The committee's gone through several editions of drafts, but we still
     have the proposal, the ROP meeting, and what we call the ROC meeting to
     finalize it.  So we still have several steps left in the process to go.
         Once the committee has acted on the proposals, it's
     published in a report called "The Report on Proposals."  At that point
     the public again gets a chance to look at the proposals and how the
     committee acted on it, and then they get a chance to submit public
     comments on the Report on Proposals or the ROP, and the process more or
     less repeats itself where the committee has to act on the comments.  The
     comments get published in a report called "The Report on Comments" or
     the ROC --
         DR. MILLER:  That basically addresses in some way every
     comment, right?
         MR. BIELEN:  Correct.  I think what is important to remember
     also is the official actions are taken by the committee on the proposals
     and then the comments, so if there are concerns or issues that are
     raised by either committee members, the public or anybody where it says
     you didn't address this issue and you ought to look at that issue,
     unfortunately because of the way our process is set up that doesn't mean
     that that issue is necessarily going to be addressed.
         The way it is going to get addressed is if that person or
     organization of someone submits a public proposal or a public comment. 
     Then it has to be reviewed by the committee.  So in the consensus
     process there is a formalized process of submitting proposals and
     comments and the committee has to address those, and that is really the
     direction that we have to go as far as making any modifications to this
     draft or after the ROP period.
         In the consensus process the NFPA membership then gets a
     chance to vote on the document as with all documents.
         DR. MILLER:  That is assuming they have already commented,
     they just vote on it yea or nay --
         MR. BIELEN:  The membership?  No.  That is not until, and
     you will see in the next couple of overheads, until May of 2000.  That
     is at the end of the process.
         DR. MILLER:  At that step in the process you say the
     membership.  Is that a consensus process or do they just vote yes or no?
         MR. BIELEN:  Oh, okay, yes.  At that time it is a go/no go
     or yes/no, as to whether or not the document should go forward or get
     released.  The final step is the Standards Council actually issues a
     document based on the Report on Proposals and the balloting results,
     based on the balloting results of the Report on Comments, and then based
     on any floor action at the fall meeting.
         They take all that into consideration and then they either
     issue or don't issue the new document.
         DR. MILLER:  So this doesn't go to ANSI though?
         MR. BIELEN:  It then goes to ANSI -- right, and then it
     becomes ANSI-approved.
         DR. MILLER:  I should have looked one ahead -- you probably
     had that on your next overhead.
         MR. BIELEN:  I didn't about ANSI but I do about some of the
     other questions.
         The cycle, just to give you an idea of how long it takes for
     a document to get released and some of the steps that are involved and
     where we are, we are what we call an annual 2000 cycle right now, and
     you will see later on that that means the document gets published in the
     Year 2000.
         Let me jump to Bullet Number 3 here first, and let me just
     back up.  As I mentioned before, February 19th of this year, the public
     proposal closing date, that is the deadline for the proposals, to back
     up -- and this is actually a mistake -- it should be November 25th,
     1998 -- a draft document that you have in front of you has been released
     to the public for review with a call for proposals with that February
     19th deadline for proposals, so we are still in the proposal stage, any
     submissions from the public.
         The committee is going to be meeting next week down in
     Orlando, the 26th through the 28th, to act on any internal committee
     proposals that we generated, which is kind of an extra step that we
     added into the process.  We didn't want to wait just for the public
     proposals.  The committee also wanted to continually work on the
     document and we wanted to formalize that a little bit so we developed an
     internal committee proposal process.
         DR. MILLER:  So by that time all of the committee members
     should have submitted all their proposals?
         MR. BIELEN:  For the internal deadline that is correct and
     then if they miss the internal deadline, they still have until February
     14th for the formal submission of proposals.  Actually to this point
     right now we have 50 public proposals, all from Ed Connell, out of
     150 -- actually, we have 100 internal committee ones and 50 public and
     the 50 public are Ed Connell's so at this meeting next week we will be
     acting on all 150 of those proposals.
         DR. MILLER:  So you have none outside of the committee or
         MR. BIELEN:  That's correct for public proposals.  The
     internal ones are all committee members, but as far as the external
     proposals from the public right now they are all from a committee
     member, correct.
         DR. MILLER:  But you would expect, I assume, by February
     19th that you would have some from industry and others outside of --
         MR. BIELEN:  Right, I would assume that we would be getting
     some from industry and outside groups.
         Historically what's happened is people don't submit
     proposals until the last week, and then they realize there is a deadline
     and you get 50 or 75 percent of them in the last couple days of the
     closing date.  I can tell you from experience that is what happens all
     the time, so, yes, I expect to have some from industry and whoever else.
         DR. APOSTOLAKIS:  So if we write a letter, then, Dana, that
     would be a proposal?
         CHAIRMAN POWERS:  They might well treat it as a proposal.
         DR. MILLER:  Yes --
         MR. BIELEN:  There is actually a formal proposal form to be
     filled out, but if you were to submit a letter I think we would probably
     accept it as a proposal.
         One thing we do want in the proposal form is we require
     specific wording for what you want changed and substantiation for why
     you want to change it.
         For instance, we get bogged down with proposals or comments
     that say you didn't address this issue -- you should address it.  Okay. 
     But how do you want us to address it is the question.
         DR. APOSTOLAKIS:  I don't think that the ACRS can write a
     letter to you.  If we write a letter we do it with the EDO.  I don't
     know of any instance where we wrote a letter to somebody other than the
     EDO or the Chairman of the Commission.
         CHAIRMAN POWERS:  I don't know of any reason why we
         DR. APOSTOLAKIS:  Or the Staff can forward our letter to the
     EDO --
         CHAIRMAN POWERS:  They could do that too.
         MR. BIELEN:  Yes, you can have all your correspondence -- we
     don't care how it comes through us, whether directly from you or from
     the NRC Staff, and in this situation we are blessed with NRC Staff
     members.  We have got Nathan, Pat and Ed, so any one of those people can
     deliver your concerns to us through a proposal.
         DR. APOSTOLAKIS:  Because I think we have to write to the
     EDO.  I don't know of any case where we wrote to anybody else except
         CHAIRMAN POWERS:  I known of no restriction on who we write
     to.  I know it is usually to write to the Staff or the Commission.
         DR. MILLER:  It might be -- well --
         DR. APOSTOLAKIS:  It might be what?
         DR. MILLER:  I was thinking since we are going to be dealing
     more with the standard, we might develop a policy on how we deal with
     issues of this type, but I think that is an issue we should discuss
         I agree with you, George, that based on past practice we
     have never written a letter to somebody besides the EDO or the Vice
     President --
         DR. APOSTOLAKIS:  -- the Vice President --
         DR. MILLER:  -- or the Chairman of the Commission.
         MR. BIELEN:  And I would strongly recommend if you have
     comments, concerns, issues, whatever, that you do provide us with input.
         DR. APOSTOLAKIS:  So at this February meeting it would be
     very timely if we wanted to write something?
         MR. BIELEN:  Yes.  There is a meeting we are having next
     week, but then we are also having another one in March -- March 16th
     through the 18th -- to complete the ROP meeting, so we have until that
     meeting actually if you wanted to submit anything.
         MR. MARSH:  George, it is also timely in the sense of the
     Commission meeting on February 9th where we are going to talk about the
     NFPA standard.
         DR. APOSTOLAKIS:  The letter though will probably not be
     ready.  I mean the committee will write it if it decides to write it
     during the meeting, but then it takes awhile for the Staff to process
         MR. MARSH:  I am just thinking if the Commission would want
     to know what your views would be on the standard thus far, that would be
     helpful.  I understand your time constraints though.
         DR. APOSTOLAKIS:  No, I think the Staff can read the draft
     after the committee has approved it.  It's just that it takes some
     editing after that and so on.  Anyway, that is something that is not
     relevant at this point.
         CHAIRMAN POWERS:  We have an opportunity to resolve that.  I
     think it is more important that we get to the point that we can
     formulate a position the full Committee can adopt, and I am hoping that
     we do so.  The mechanics of it I think we can sort out.
         DR. APOSTOLAKIS:  Well, Mr. Connell will talk about the
     contents of it tomorrow, right?
         MR. BIELEN:  Right.
         DR. APOSTOLAKIS:  So he will get the subcommittee's views --
     individual members' views, I'm sorry.
         CHAIRMAN POWERS:  That's okay -- the subcommittee's views
     are fine.
         I mean this subcommittee does not operate on a basis of the
     full Committee.
         MR. BIELEN:  Okay, so as I mentioned, February 19th for the
     public proposal closing date, and then the committee is going to have a
     second ROP meeting, the final one, March 16th through the 18th, in
     Albuquerque to review the remaining public comment -- proposals and take
     action on those.
         The report then gets published and there is a public comment
     closing date of October 8th, 1999, so there's your second shot at it
     once we submit proposal, the committee takes action on it.  You are able
     to see what the actions are, hence to submit another round of comments
     by the October 8th deadline.
         DR. APOSTOLAKIS:  And then there will be a third chance?
         MR. BIELEN:  Nope.
         DR. APOSTOLAKIS:  Oh, no, no, no -- for the NRC Staff has to
     accept it.
         MR. BIELEN:  Okay.
         CHAIRMAN POWERS:  Lots of opportunities here.
         MR. BIELEN:  The committee would have to meet by December
     27th of 1999 to have their ROC, Report on Comment, meeting to take
     action on any of those public comments.
         DR. APOSTOLAKIS:  Do you plan to meet the last couple days
     there --
         MR. BIELEN:  I'm not -- around Christmas?  No.  I think we
     will probably meet somewhere closer to the end of October into the
     beginning of November and stay away from the holidays.
         It then goes to the NFPA Annual Meeting of May 14th through
     the 18th in the Year 2000 where the NFPA membership votes on it and that
     will be in Denver, Colorado.
         DR. APOSTOLAKIS:  So the whole membership votes on the
         MR. BIELEN:  Yes.  The NFPA -- when I say the NFPA
     membership, it is whoever shows up at the Annual Meeting.
         DR. APOSTOLAKIS:  Usually how many show up?
         MR. BIELEN:  In the Annual Meetings they are typically a
     little bit bigger -- I would say between 3,000 to 5,000 people show up. 
     Not all of them ar NFPA members.  There might be 1500 to 2,000 people --
     1,500, around there, that will be actually in the hall that are voting
     members that will vote on the document.
         DR. MILLER:  What is the size of the NFPA as an association? 
     How many members total?
         MR. BIELEN:  We have got approximately 70,000 members --
     just under, like 68,000 -- somewheres around there. Cliff?
         MR. SINOPOLI:  I am Cliff Sinopoli, Baltimore Gas &
     Electric.  I think one important thing too from a public standpoint,
     also from the subcommittee's standpoint is once you put in a proposal or
     a comment, you may not be satisfied with the response that you get from
     the committee, you have the opportunity actually two more spots -- you
     have the opportunity to get up in front of the entire membership to make
     your case and you also have the opportunity, if I am not mistaken, Rich,
     to go in front of the Standards Council -- say you lose on the floor of
     the Annual Meeting, you can still go to the Standards Council provided
     you have made these comments at each of the proper closing period, so
     the public as well as this committee -- anyone has an opportunity to get
     satisfaction up to the level of the Standards Council.
         MR. BIELEN:  Right.  There's a whole number of steps
     involved.  If you submitted a proposal and if you submitted a comment,
     and you didn't like the action that the committee took on either one,
     you then have that option to get up in front of the membership at the
     Annual Meeting and to try to get a floor amendment and convince them
     that they should accept your proposal or accept your comment if the
     committee rejected it, for instance, and then if you are still not
     satisfied with the action there, you can then take your issue to the
     NFPA Standards Council and file an appeal and argue your case with the
     Standards Council, so there are several steps involved.
         DR. MILLER:  How often does that happen on an NFPA standard,
     that somebody comes to the membership and makes an appeal?
         MR. BIELEN:  All the time.
         DR. MILLER:  All the time?  How often does the membership
     agree with the person making the appeal?
         MR. BIELEN:  I'd say it's about 50/50, depending on how
     strong of an argument and they'll argue issues for hours on the floor
     and at that point it is kind of a 50/50.  It is a tossup as to which way
     it is going to go.
         When it then gets to the Council, that is where the odds
     start to go against you.  The Council doesn't generally like to go
     against what the committee and what the membership does on the floor,
     although they will if they have to in certain cases.
         DR. MILLER:  So at the membership meeting, of course
     obviously that includes a lot of people who hardly know what a nuclear
     plant is.
         MR. BIELEN:  Right, but they are --
         DR. MILLER:  They know the issue of --
         MR. BIELEN:  -- are fire protection people.
         DR. MILLER:  You get the input of fire protection
     independent of a nuclear plant.
         MR. BIELEN:  Right -- and then at some point, at the July
     Standards Council Meeting, if everything has gone well with the ROP, the
     ROC and the floor action and any appeals, they then issue the document
     in July and it gets published around the September-October 2000
     timeframe and it is then available to the public at that point.
         Kind of a brief overview of the document and actually there
     is a flow chart that I will be going over at the end here, but the
     document is comprised of several chapters -- Chapter One being the
     introduction; Two is methodology -- telling you how to apply the
     standard; Chapter Three is fire protection elements of defense-in-depth;
     Chapter Four is performance requirements; Chapter 5 is fire protection
     during decommissioning and permanent shutdown; Appendix A is just
     explanatory material that goes along with the requirements in the
     document; Appendix B is still being worked on by a task group --
         DR. APOSTOLAKIS:  So you don't have it?
         MR. BIELEN:  You have some material in Appendix B right now,
     but it is very general, very brief.
         DR. APOSTOLAKIS:  Definitions?
         MR. BIELEN:  As a matter of fact, we put that in just as a
     place-holder in order for the committee to do something.  If we didn't
     have anything in the draft, the public doesn't have a chance to submit
     any proposals on that so what is in Appendix B right now more or less is
     just a place-holder.
         The task group met January 8th and I believe they are
     meeting this Friday or beginning of next week before the main meeting,
     but they are meeting again very shortly to still go over some of that
     material, so by the time we meet next week or in March, we should have
     something that is a little bit more detailed, but right now, correct,
     what we have is probably not what you are looking for.  It is very brief
     and very general.
         Then Appendix C is just references.
         CHAIRMAN POWERS:  I guess you are not here to defend so
     much, but some of your committee members are here, so I'll let them
     interject if they choose to.
         In the course of this morning's discussion, questions were
     raised and critiques given of the existing tools for doing risk analyses
     in connection with fires, and concerns were expressed that those tools
     may not be adequate to the tasks presented to them.
         Those tasks are not wildly different at all from the kinds
     of tasks NFPA 805 would have risk analyses do.  Why aren't those tools
     then inadequate and incomplete for doing the NFPA?  In other words, why
     is Appendix B ever going to be an inadequate document?
         MR. BIELEN:  I saw Nathan out of the corner of my eye going
     up there.  Do you have any comments?
         MR. SIU:  Yes.  I guess Rich hasn't had a chance yet to walk
     you through the flow diagram.  I assume you saw it.
         The concept is that risk will come in in a couple of
     different ways.  One is more or less as a vulnerability search.  At the
     end of going through all the plant fire areas, all the fire protection
     features, and having complied with the performance requirements, you are
     still taking a risk shot at the end or taking the risk picture to see
     where you are and to identify if there are any additional things that
     need to be taken care of.
         That kind of use of the risk assessment is very much like an
     IPEEE vulnerability search and I guess the feeling is based on the
     experiences from the IPEEE reviews we certainly know a number of areas
     where we can say what appears to be the best way to approach an issue,
     even if it is not necessarily truth.  It is our best shot at identifying
         The second use of the risk assessment tools is actually at
     the performance level -- let's say in lieu of doing some fire modelling,
     one chooses to use a fire risk assessment to show that a particular
     feature is not needed above and beyond what is required in the base fire
     protection program.  Again, that is something that I think Rich will
     walk the whole committee through.
         In that situation I think that the burden on the fire risk
     assessment is greater.  We probably at this moment can't specify what
     are the precise tools that we should be using to address some of the
     issues there, but we can certainly say what are some of the concerns and
     things that have to be addressed, and again the document I believe makes
     numerous references to this phrase of how the analysis has to be
     acceptable to the authority having jurisdiction, so there is going to be
     some give-and-take in the context of how a standard has been written for
     that particular issue.
         So the bottom line is we probably won't be able to specify
     in great detail how the analysis should be performed just as ASME is not
     specifying in great detail how, let's say, each RA should be performed
     and internal, that's PRA standard, but at least we can provide some of
     the functional requirements that we think need to be addressed in a
     better assessment.
         CHAIRMAN POWERS:  The document makes reference to something
     called qualitative PSA.  Would you tell me what that is?
         MR. SIU:  As Rich said, there are discussions ongoing within
     committee.  Honestly, there are some differences of opinion right now as
     to how we should be using risk in this.
         DR. APOSTOLAKIS:  We will discuss in more detail the
     standard I think when Ed comes to the floor, right?
         MR. SIU:  Yes, although that particular --
         DR. APOSTOLAKIS:  I would like to pursue Dana's comment and
     paraphrase it a little bit.
         CHAIRMAN POWERS:  I was being gentle, George.
         DR. APOSTOLAKIS:  No, the previous comment.
         CHAIRMAN POWERS:  I was being gentle then, too.
         DR. APOSTOLAKIS:  Dana said that questions have been raised
     about the tools of PRA and so on, and you gave an answer.  Questions
     have also been raised, and if they have not I will be very happy to
     raise them, regarding the completeness of the deterministic methods.
         I would like to see a discussion in the standard, the same
     number of lines as the lines you will use to discuss the incompleteness
     of the PRA, discussing the incompleteness of the deterministic methods.
         MR. SIU:  Well, I think the standard is going to make -- is
     going to describe how the analysis should be done.  I don't know the
     extent to which it is going to talk about the limitations in any of
     these methods.
         DR. APOSTOLAKIS:  Well, I can assure you that there will be
     something from the ACRS that will raise the issue.  If not from the
     whole Committee, there will be definitely individual members' comments.
         DR. APOSTOLAKIS:  I want to see exactly the same number of
     lines devoted to the incompleteness issue of PRA and I will count them,
     yes, because I don't think deterministic methods are complete and the
     false assumption that this is perfection, that the new kid on the block
     has to prove herself I don't buy -- that PRA has to be complete and has
     to have nearly perfect methods, so I would like to see the same
     criticism and evaluation raised against the so-called traditional
         MR. SIU:  Which you will see, I suspect, and I don't know
     how far the fire modelling part of Appendix B has gone -- by the way,
     Appendix B covers fire modelling as well as the fire risk assessment.
         I think you will see some fairly high level requirements for
     the analysis that don't get into what are the specific limitations of a
     particular approach.  It will say that the approach must be -- and then
     name a quality -- like it must be --
         MR. SIU:  No, but I suspect even as we get further along, we
     are not going to be specifying, for example, you must use CFAST in this
     situation.  It is not to that level of specificity, nor will it talk
     about if you use CFAST in this situation be careful for this because
     this is a problem.  It just doesn't get to that level of detail.
         DR. APOSTOLAKIS:  Right.  Right, but --
         MR. SIU:  So what it does say is that you may choose to
     employ various methods to show that your functional requirements have
     been met -- your fire protection requirements, and these are the ways
     you can show that.
         DR. APOSTOLAKIS:  I understand that.  All I am saying is you
     should give equal time to traditional methods and -- for example, there
     is some discussion on completeness someplace, which I can't find it now
     and maybe it is inappropriate to raise it right now, but uncertainty
     analysis --
         CHAIRMAN POWERS:  But the issue of completeness or
     uncertainty certainly arises and is cited explicitly in the discussion
     of uncertainties, but though people cite uncertainties in the document,
     which is a very good feature of the document, one of its few good
     features, that it doesn't tell me what to do.  It doesn't tell me
     whether I am to use the mean of my estimates to compare against the
     standard mode, the median --
         MR. SIU:  What you are seeing -- there was actually material
     that was in an earlier draft that covered exactly that --
         CHAIRMAN POWERS:  Well, we didn't see another draft.
         MR. SIU:  I understand.  I am just explaining how I think
     you got where you are.  I understand that that material was supposed to
     have been moved to an appendix, and I don't remember if it is Appendix A
     or Appendix B and it might have gotten left out.
         MR. MARSH:  B.
         MR. SIU:  B -- it was supposed to be in there and if it
     isn't in there, there is every intent to make sure that it is in there.
         DR. APOSTOLAKIS:  Are we -- okay.  When are we going to
     discuss the details?  Not now, right?
         CHAIRMAN POWERS:  What is the course of presentation now?
         MR. BIELEN:  Just to go over a general approach on now the
     standard is to be used, go over the flow chart, and then to wrap it up,
     but our intention at this particular meetings wasn't, as I said, to
     defend the document, to get into details.
         If we need to have a more detailed presentation on the
     specifics of the document in the future we can do that, and get the
     right people here -- not that we don't have the right people here now,
     but we can get the people who are PRA experts, for instance, here if we
     need to have those questions answered, but the thing to remember is it
     is still in a state of flux because this is only a draft.
         We still have the proposals to go through.  We still have
     the comments to go through and it probably wouldn't be appropriate to --
     well -- I guess you could, at some point you might want to have a
     detailed discussion so you can maybe want to submit comments or
     something during the appropriate time.
         But I was going to say that since it's still in a state of
     flux, I'm not sure what the right time is, because it's always going to
     be changing.
         DR. POWERS:  It's always in a state of flux.
         MR. MARSH:  But it exists now, and it's out for some
     comment, and I think the staff has comments about it.  You're going to
     hear some details tomorrow.  I want to be cautious that we are not in
     the position of defending it either.  We're going to be explaining it to
     you as we understand it with its -- and our concerns too.
         DR. APOSTOLAKIS:  Okay.  So Ed then will be speaking as an
     NRC staff member, not as a member of the committee.
         MR. MARSH:  As a member -- that's right.  He's not going to
     be --
         DR. APOSTOLAKIS:  Okay.
         MR. MARSH:  Defending it; he's explaining it to you.
         DR. POWERS:  Sometime I have to understand why this becomes
     what I've characterized as the Prego spaghetti sauce of all standards. 
     This has something for everybody in it, and as a result, it's not clear
     to me that it takes a direction that the NRC wants to go or that it
     could ever be approved as a regulation.  Built this way, it's just not
     clear to me that it ever makes the grade as a regulation.
         MR. BIELEN:  Do you have specific recommendations on how you
     might improve the document so that it might, which is what we'd be
     looking for in the proposal period and the comment period, so we
     could -- you know, if we know what your concerns are, you know,
     specifics, let us know so that the committees can address it.
         DR. APOSTOLAKIS:  So maybe tomorrow we can hear some of
     our --
         DR. POWERS:  Yes.
         MR. MARSH:  We have concerns about it too.  And I want to
     say something that Fred said earlier, there's a laudable effort that's
     gone into this standard.  It isn't perfect.  It's got concerns that we
     have too, but there's been a great deal of work that's gone into it,
     great number of hours, very diligent folks who have been working hard at
     it --
         DR. POWERS:  I think the people who have worked on NRC's
     core capabilities will attest to you that the number of hours spent on a
     document carries little weight with this committee.
         MR. MARSH:  Okay.
         DR. APOSTOLAKIS:  It's a performance-based --
         DR. POWERS:  I'm going to declare a recess for 15 minutes at
     this point.
         DR. POWERS:  I'd like to resume the meeting, and we are now
     on to the NFPA overview.
         I don't know why I have a mental block about sticking the
     805 in there.  It's not like the only thing that NFPA is doing.
         MR. BIELEN:  I think I'm going to skip over to the flow
     chart, because a lot of the other overheads I have with the general
     approach basically say the same thing except in words, and we maybe
     follow it a little bit better, maybe not, in the flow chart.  But the --
     look at the flow chart.  This is -- it's supposed to tell us basically
     how the NFPA 805 is to be used, and I think this might generate a few
     questions here.
         DR. POWERS:  Well, it does, and it does just from the very
     top.  As I have read and understood the document, which I'll be the
     first to admit I have not pored over it in critical detail, but there is
     what you call on the slide the minimum fire protection program, and then
     one comes down and there are choices in what additional requirements you
     choose to impose upon yourself.  And those are what you call either the
     deterministic or the performance.  And then wrapped around this whole
     thing is a risk evaluation, okay, which will allow you to go through and
     reassess a deterministic versus performance additional requirements, but
     does not include this first initial very deterministic what you call up
     here the minimum fire protection.
         Why was this particular structure selected?
         MR. BIELEN:  I don't have an answer for why it was selected. 
     It was kind of a structure that was generated by committee, so I don't
     know if there's one person who can have a real good answer as far as why
     this particular structure was --
         DR. POWERS:  Well, see, my question about is the risk -- you
     asked the question is risk acceptable, and the answer is no, but the
     only things I can change are in here.  The problem may be up in my
     minimum acceptable program.  Or I can come down and say is risk
     acceptable?  I may find myself down in the minuscule noise of risk, and
     the reason I'm there is because of this minimum program may be far more
     than what I need.
         I mean, it seems to me that if I'm going to use risk to
     adjudicate on what I need to do, I cannot box myself into the one-way
     street Professor Apostolakis frequently mentions, which is I can -- I
     only use risk here to augment the requirements that I choose to impose
     on myself.
         MR. WARNICK:  I'm Lee Warnick with Virginia Power.  I'll
     make a feeble attempt at answering that question, but as far as the
     establishment of the minimum fire protection program, the intent there
     is that there are certain things, certain elements of a fire protection
     program which are going to be basic to every nuclear plant regardless of
     the risk or the degree of risk in any specific area.
         The best example is the fire brigade.  Every plant has to
     have a fire brigade.  It's the committee's opinion that every plant has
     to have a fire brigade regardless of your calculation of risk in any
     specific area of the plant.  And so it was intended to establish those
     type of requirements that fell into that box as a separate category of
     the standard.  And then you move on beyond that to establishing specific
     requirements based on the hazard in any particular area of the plant,
     based either deterministically or risk-based.
         DR. POWERS:  I think you've chosen a particularly
     appropriate example in the fire brigade.  Your minimum program said you
     all have things that deal with prevention of fire, suppression and
     detection of fires, and mitigation of damage from fires.  Had that made
     up the elements of your minimum program, I think I probably wouldn't
     have objected.  I can probably find people that would object, but I
         When you come to the fire brigade, that is a means to
     achieve an end.  It is not the end in itself.  I mean, the objective of
     a fire-protection program is not to assure employment of
     fire-suppression personnel.  I can perfectly well imagine a plant who
     says my costs come from people, and having five fire-protection people
     on each one of my shifts, what, a typical plant has five shifts, is a
     big expense to me.  I can get rid of that expense by enhancing my
     automatic suppression systems.  I can have a super whammy dammy
     fire-suppression systems that are just the cat's meow, and I don't have
     to have all those people.  That should be an option open to him.
         MR. WARNICK:  One other comment as far as the administrative
     controls are another category within that base program, certainly that
     would be common.  As far as the fire brigade, all I can say is again
     it's the sense of the committee that the brigade should fall under that
     minimum requirement.
         DR. APOSTOLAKIS:  Now -- are you done, Dana?
         DR. POWERS:  No, but I will pause to take a breath.
         DR. APOSTOLAKIS:  Is the committee that's putting this
     together familiar with the work that the NRC is doing on inspections,
     the cornerstones and all that data that has been developed?  You
     probably cannot get the document itself, but the viewgraphs at least for
     the presentations that show the objectives, the goals of the inspection
     program.  These are very good, in fact, and as I started reading this
     document, chapter 1, page 3, it has a statement of the goals.  And these
     are not quite consistent with the cornerstones that that document has.
         So the first question is whether this agency -- I mean, this
     is NFPA, but eventually we want to adopt this, we can have different
     goals in different documents.
         Second, it talks about radioactive release goal and talks
     about a release that will result in adverse effects to the public, plant
     personnel, or the environment.  Now is protecting the environment part
     of the regulations?
         DR. POWERS:  Yes, it is.
         DR. APOSTOLAKIS:  Where?
         DR. KRESS:  It's down in the regulations --
         DR. POWERS:  GDC 4?
         DR. KRESS:  That have dose acceptance requirements in them.
         DR. POWERS:  Well, I'm --
         DR. APOSTOLAKIS:  That's the environment?  I thought it was
     for people?
         DR. KRESS:  It's the same.  You can view that as protecting
     the environment, because the doses are so low that they have no adverse
         DR. POWERS:  I am informed that appeal to GDC 4 is
     appropriate for the environment.
         DR. APOSTOLAKIS:  Which says?
         DR. SINGH:  That's a general area.
         DR. POWERS:  I can look up what the general design criterion
     is for you.
         It's Appendix A.
         DR. APOSTOLAKIS:  But anyway the goals are -- and then the
     objectives -- I think they should be consistent with the other
     activities in the Agency, but also within the document there are
     inconsistencies.  For example, it's not clear to me how one decides
     which equipment to protect from the goals.  We really need a top-down
     approach that goes from the top goals that are stated here, protect the
     environment, to show schematically how you decide which equipment to
         The way it is now, and maybe I'm wrong, the way I read it is
     that the determination of which equipment to protect is something else
     that somebody else decides again as an additional requirement, and that
     goes back now to the current deterministic approach where, you know,
     safety-related equipment are supposed to be protected.  But how these
     equipment relate to the nuclear safety goal of providing reasonable
     assurance that the fire will not result in nuclear fuel damage or will
     prevent radioactive releases is not clear.
         I think the top-down approach, the power of the top-down
     approach has been underestimated by a lot of people, and this program
     that the NRC has to put together an inspection program does a very good
     job using the top-down approach, starts with the top goals, goes down to
     the cornerstones, and then goes all the way down using fault-tree type
     logic to what they want to inspect, what the performance indicators will
     be, what is it that's not covered by the performance indicators,
     therefore there has to be a programmatic inspection and so on.  And I
     think that's great, and I think we should try -- now I don't know to
     what extent your committee can become familiar with that before the
     staff publishes that report, but since you have NRC staff on your
     committee, they can certainly read it.
         But that's something that struck me as needing help here, to
     structure this whole thing so we start with top-level goals, and then
     when I go to page 35 I will be able to understand why there is an
     attempt to protect a certain area or piece of equipment.  That's missing
         MR. SINOPOLI:  This is Cliff Sinopoli with Baltimore Gas &
     Electric.  I think we've tried to do that, and apparently
     unsuccessfully.  I know the format that we've used, the NFPA has come up
     with a primer.  I think there's a number 3 now.  And that's what we
     tried to follow.  And I think -- I mean, I don't think the committee
     would have any objection to trying to make it as consistent with the NRC
     approach as possible.  Again, though, provided that we can try to
     maintain the NFPA framework to the best, we need to marry those two.
         DR. APOSTOLAKIS:  Okay.  Now the other thing that really
     confused me is the distinction between deterministic requirements and
     performance-based requirements.  So if I go to page 29 that talks about
     water supplies, part of the deterministic requirements is the
     fire-protection water supply shall not be less than two separate
     300,000-gallon supplies.
         Okay, makes sense, deterministic.
         Then I go to performance-based.  An adequate fire protection
     water supply shall be provided in all areas of the plant as determined
     to be necessary by the FAHA.  So that's performance?  Having an adequate
     fire-protection water supply is a performance-based requirement?  I'm
     utterly confused.  It sounds to me like a deterministic requirement.
         And then the second performance-based requirement, an
     untreated raw water source may be used as a fire-protection water supply
     when both quantity and quality can be shown to be acceptable.  Is that
     what we mean by performance, Dr. Kress?
         DR. KRESS:  You certainly don't want to ask Dr. Kress what
     he --
         Can't we do this in private?
         DR. POWERS:  I would say -- I'm surprised, Tom, because I
     would have thought you would have said yes, that's exactly what a
     performance-based requirement is --
         DR. KRESS:  Yes, yes, among other things.
         DR. POWERS:  Performance-based rules either lead you to
     determinism or risk --
         DR. KRESS:  You said it very well.
         DR. POWERS:  And there is no middle ground for you.  Except
     here's proof that a middle ground exists.  It's both.
         DR. APOSTOLAKIS:  Another performance-based requirement.  If
     fire pumps are powered by electric motors, the electrical supply shall
     be independent such that a fire involving one electrical supply and a
     simultaneous failure of any one fire pump shall not prevent delivery of
     the required fire flow.
         I would not call that a performance-based requirement. 
     Where is the performance?  That's a design requirement.
         MR. SIU:  Yes.  Without commenting on the last one, George,
     I think there is a difference -- I think there's a difference in
     interpretation of what performance-based means between how NFPA
     approaches it and how that term has been used here.
         DR. APOSTOLAKIS:  And I looked it up.
         MR. SIU:  Yes.
         DR. APOSTOLAKIS:  The Random House dictionary.
         MR. SIU:  Now wait, wait, wait, wait, wait.
         DR. KRESS:  That doesn't work.
         DR. APOSTOLAKIS:  That doesn't work?
         MR. SIU:  This is the NFPA --
         DR. APOSTOLAKIS:  It worked beautifully.
         DR. KRESS:  I don't think the words mean anything.
         DR. APOSTOLAKIS:  They have --
         DR. KRESS:  They define words.  They don't define the fine
         DR. APOSTOLAKIS:  A lot of them refer to the dramatic arts. 
     We understand that.  Then they have one that comes the closest to what I
     think performance is.  The manner in which or the efficiency with which
     something reacts or fulfills its intended purpose.
         That's actually pretty good.  That's a performance.  But to
     say that an adequate fire-protection water supply shall be provided,
     that's not performance, it's design.
         MR. SIU:  Rich, correct me if I'm wrong, but my
     understanding of how performance-based requirements are being developed
     for nonnuclear applications in the fire-protection industry is basically
     they're talking about the use of codes or models to predict something
     like temperature, like smoke, and so forth.  It's not a measurement of
     something that you will observe down the road.  Hopefully you'll never
     have that fire that leads obviously to that.
         DR. APOSTOLAKIS:  And I agree with that.
         MR. SIU:  Okay.
         DR. APOSTOLAKIS:  If you predict the behavior of smoke --
         MR. SIU:  Um-hum.
         DR. APOSTOLAKIS:  And you show, for example, that it remains
     under certain conditions below a value, a pressure --
         MR. SIU:  Yes.
         DR. APOSTOLAKIS:  That's performance, yes, because you're
     dealing with the manner in which the smoke fulfills its intended
     purpose.  In other words, being below -- but if you say I want a water
     supply, I don't see any performance.  I mean, you design it and you have
     it, you build it.
         MR. SIU:  Well, but you have to have an adequate supply.
         DR. APOSTOLAKIS:  So when you inspect it then you make sure
     that the water level is --
         MR. SIU:  Or your model, whatever -- the design calculations
     that you use to show that it's adequate.
         MR. SINOPOLI:  I think in the past we've always been told
     you're going to have 300,000 gallons.  That's what you've always been
     told in nuclear energy.  What we're saying here is we're not telling you
     anymore how much you have to have.  What we're saying is your fire
     hazards analysis finds those areas where you see that you need to have
     some pressure or whatever, you're going to fight a fire that occurs,
     whether it's manual fire suppression, what your flow to the hoses are
     going to be, to the sprinkler system, whatever.  And you design your
     supply based on that requirement for the water, as opposed to the past
     where it said here's -- you have to have 500,000 gallons or 300,000
     gallons or whatever it was.
         DR. APOSTOLAKIS:  So performance then means that you don't
     specify numbers.
         DR. POWERS:  Well, what it is is, I think the question is
     not whether they specify numbers but whether they specify function. 
     That is, why would not one write a performance-based regulation that
     says you can put out a fire before it does any damage.  I mean, maybe
     you'd write it somewhat differently.
         MR. SINOPOLI:  I think that's the intent of the --
         DR. POWERS:  And why would you care whether the guy put out
     the fire with water or with CO2, with appeals to the Great Water Demons? 
     I mean, you really wouldn't care, as long as he can do that and show
     that he can do that.
         DR. APOSTOLAKIS:  Well, that would be performance.
         DR. POWERS:  That would be performance.
         DR. APOSTOLAKIS:  Putting it out before it does damage is
     performance.  In other words, in my mind, performance has an element of
     time in it.  Something is happening in time and stays below or above a
     certain level.  Then I say yes, it performed well.  But to say that the
     electrical supplies of the pumps must be independent of the fire is not
     performance.  It's design, isn't it?
         DR. POWERS:  I mean, it seems to me that that's part of --
     that particular requirement sounds like it's straight out of a standard
     review plan.
         DR. APOSTOLAKIS:  It's design, though.
         DR. POWERS:  Yes.  I mean, it's not performance.
         DR. KRESS:  If one uses the top-down approach, say the
     top-down performance objective is to be able to put out the fire before
     it does any damage, one has a lot of trouble figuring out what that
     actually means.  One can say well, in a performance world, we know if we
     can do this, this, this, and this, like supply enough water, like have
     enough detection, have enough sprays and so forth, we know that if we
     have enough of these, we have satisfied this objective.  So let's put
     our performance measures down here on things we can look at.  In that
     sense it is performance.
         DR. APOSTOLAKIS:  That's a prescriptive approach.
         DR. KRESS:  Not necessarily.
         DR. APOSTOLAKIS:  So the current regulations are
         DR. KRESS:  Not necessarily.
         DR. APOSTOLAKIS:  Well, that's what they tell you to do.
         DR. KRESS:  No, I maintain that they know --
         DR. APOSTOLAKIS:  Twenty field separation --
         DR. KRESS:  That if you look at performance-based
     regulations in the current ones that they're almost --
         DR. APOSTOLAKIS:  Isn't Appendix R performance based?
         DR. KRESS:  Based on different forms, though.
         DR. APOSTOLAKIS:  Appendix R is performance-based.  It says
     that you have to have a minimum of 20 feet empty space separation,
     right?  How is that different from saying that the electrical supplies
     to the pumps must be independent of the fire or that you have to have an
     adequate fire-protection water supply?  I go there and I measure it.  I
     go there and I look at the water.
         Now, if I had a model that would predict the time to
     suppress the fire, then that would be my performance measure, and the
     other stuff down here I wouldn't care about.  But I don't have that. 
     Therefore, I abandon the performance-based approach and I go to the
     prescriptive approach, which says what you said.  I suspect that if I
     have enough water and trained people, they're going to put it out in
     time.  But that's not performance, that's prescriptive, because of lack
     of model to calculate that time, to estimate that time.
         DR. KRESS:  Well, it gets to be performance if you don't
     actually start describing distances and length of hoses and say you must
     have enough separation or you must have enough water to let the
     conditions determine how much that is or let the licensee's calculations
     and plant configuration determine --
         DR. APOSTOLAKIS:  I think if I compare the similar
     requirements that run the deterministic and performance-based, there is
     a requirement that's called deterministic that says each pump and its
     driver and control shall be located in a room separated from the
     remaining fire pumps and from the rest of the plant by fire barriers
     with a minimum rating of three hours.  So they specify the rating.
         In the performance-based part, it just says they should be
     independent from the fire and the simultaneous failure of any other fire
     pump.  In other words, what is not specified is that there should be
     fire barriers with a minimum rating of three hours.
         Now is that the distinction between deterministic and
     performance-based, simply that you don't specify the fire rating of the
     barrier?  That's news to me.
         DR. KRESS:  I don't -- you know, I once made the comment
     that there's very little difference, and that in fact, when you go to
     performance-based regulation, all you're doing is proliferating all the
     bad things that you already have, and just relax --
         DR. APOSTOLAKIS:  Well, yes.  Yes.
         DR. KRESS:  And that's a prime example of it.  You're just
     doing the same thing over again in a different way.
         DR. APOSTOLAKIS:  Well, if you stretch the definition of
         DR. KRESS:  Yes, which you almost have to, because the only
     reason you have that kind of performance-based rule is because you can't
     do a risk-based one.  If you could do a risk-based one, it would all
     make sense.
         DR. POWERS:  I'm going to ask that we let the speaker move
     on.  I think the point, if not elaborated upon, has been made.
         DR. KRESS:  Let me ask another question about his viewgraph. 
     The triangle where it says is risk acceptable, is that fire risk or is
     that plant risk?
         DR. APOSTOLAKIS:  Yes, that's what I mean, fire.
         DR. KRESS:  Fire risk?
         DR. APOSTOLAKIS:  It says somewhere in the standard, that
     the licensee should specify the fraction of the total risk --
         DR. KRESS:  Due to fire.
         DR. APOSTOLAKIS:  Due to fire.
         DR. KRESS:  And that's what was in --
         DR. APOSTOLAKIS:  Which I don't understand how they're going
     to do and why they should --
         DR. KRESS:  That's why I asked --
         DR. POWERS:  And why they should have to.
         DR. APOSTOLAKIS:  Huh?
         DR. POWERS:  And why they should have to.
         DR. APOSTOLAKIS:  And why they should have to.
         DR. KRESS:  That's why I asked.
         MR. BIELEN:  Well, I don't know if I have the expert -- I
     don't have the expertise to debate why we did things, why we didn't, and
     all the details of how we did it, except I can try to explain what's in
     there, which you can see already, and probably have gone through it
         But again I do encourage you to submit proposals so that the
     committee can hear your concerns.
         DR. APOSTOLAKIS:  And in terms of communicating to the
     public -- and I'm a member of the public -- when I see deterministic
     approach, no further analysis required, a performance-based-approach
     engineer, I'm turned off.  Because that again shows deterministic
     approach is nice and good and no further analysis required.  The other
     stuff requires additional work.  I don't know whose idea it was to put
     it up there, but it seems to me when you take the deterministic
     approach, don't you have to do any engineering analysis someplace? 
         MR. BIELEN:  Well, the NFPA process is a dual-track
     approach -- I don't know if you remember that terminology that we used
     before -- where you can go down a what we normally call prescriptive,
     but I guess in this industry we call it deterministic, versus
     performance-based.  So that's why there's kind of that split there with
     deterministic and performance-based.  And I hear you as far as your
     concerns go that -- about the engineering analysis for deterministic.
         DR. APOSTOLAKIS:  Yes, I mean, this no further analysis
     required, I mean, there's a flag out there that says hey, do it this
         MR. BIELEN:  Well, there is further analysis, because you've
     got to go down to doing a sitewide risk evaluation.
         DR. APOSTOLAKIS:  In either way, though.  I mean, whether
     you do it deterministically or performance-based in that box you still
     have to do the sitewide risk evaluation, which is a good thing.
         And I noticed, by the way, that the title of this does not
     have the words "risk informed."
         MR. BIELEN:  Right.
         DR. APOSTOLAKIS:  It's only performance-based.
         MR. BIELEN:  Right.  But the risk is kind of built in there
     when you look at if the performance-based approach, risk-based methods
     are encompassed in there, and then also in the sitewide risk evaluation
     and is risk acceptable, that's where we use risk methods.
         DR. APOSTOLAKIS:  So why not then put it in the title,
     performance-based, comma -- no, is it comma?  Risk-informed.
         MR. BIELEN:  Yes.
         DR. APOSTOLAKIS:  Yes, is an official position on that.
         DR. KRESS:  Comma, yes.
         DR. APOSTOLAKIS:  Comma, yes.
         MR. BIELEN:  I hope to see a proposal from you stating that.
         If we kind of move down through here, as Dana started with
     the first box with the minimum fire-protection program, that's correct,
     chapter 3 kind of is your base fire-protection program, here's what you
     have to have as far as a minimum goes.  And then there's some additional
         DR. APOSTOLAKIS:  Now, the minimum, is there a rational way
     of determining the minimum?  You mentioned, for example, the fire
     brigade, and I would say yes, that makes perfect sense to me.  Is the
     requirement that the hose be 75 feet part of the minimum?
         MR. SINOPOLI:  No, that's -- what we considered the minimum
     was primarily those things such as your fire prevention.  For example,
     combustible control, hot work permits, things that we've learned over
     the years every construction site should have if you're doing hot work. 
     The basic sort of what I call the first leg of the defense in depth. 
     And, I mean, that's just something that we've learned over the years.
         DR. APOSTOLAKIS:  So it's a fairly high level.
         DR. MILLER:  That's just independent of whether it's a
     nuclear plant or just any facility.
         DR. APOSTOLAKIS:  Well, is that true?
         DR. MILLER:  Well, yes, I suppose it --
         DR. APOSTOLAKIS:  You don't have a fire brigade in a
     building, do you, an office building?
         DR. MILLER:  Any industrial facility where fire may be an
         MR. WARNICK:  Well, and in fact I think the fire brigade is
     actually in the next --
         DR. APOSTOLAKIS:  Do all chemical process facilities have
     fire brigades?  Probably not.
         MR. WEST:  No, they probably do.
         DR. APOSTOLAKIS:  They do?
         MR. SINOPOLI:  Some level of trained people.  Even the
     fossil plants typically have some level of trained people.  They may not
     be under the fire brigade.  There's different categories -- or like we
     use interior structural fire fighters, you know, the fire extinguisher
         DR. APOSTOLAKIS:  So the minimum program then is the
     accepted collective wisdom of the fire protection brigade.
         MR. SINOPOLI:  Remember, this is a committee, because you
     have insurance people on there who have certain aspects, because they
     want the warehouse protected, you know, they see valuable assets there
     as well, you know, the staff we knew.
         And the other problem with the five-man fire brigade, for
     example, why did you pick five?  And we struggled with that a little bit
     too.  But right now with OSHA is you're going to have a fire brigade of
     the type we have, you have to have two in, two out, which means if two
     guys go in with a hose, you have to have two guys back out to back them
     up, with one person left for a brigade leader.  So unfortunately that
     number is going to be pretty much automatic.  We picked out a minimum of
     five just because of other requirements.  You can't get away from OSHA
     requirements, for example.
         DR. APOSTOLAKIS:  So is it fair to assume then that you're
     selecting performance goals and objectives because this is a nuclear
     plant?  That's where the fact that it's a nuclear plant --
         MR. SINOPOLI:  I'm still up in the first box.
         DR. APOSTOLAKIS:  No, but the first box, as Professor Miller
     said, would apply to any industrial facility.  This is the minimum
     requirements for any industrial facility.  Then the additional
     requirements and goals and so on in the second box come because this is
     a nuclear plant, so you want to protect the fuel and so on.
         MR. SINOPOLI:  In most cases I think there's probably a
     couple exceptions.  First of all, life safety.  Any facility is going to
     have to have certain life safety requirements.
         DR. APOSTOLAKIS:  Right.
         MR. SINOPOLI:  Okay.  And the only thing we did a little bit
     differently here is that typically, you know, life safety requirement
     situation, you want people to get out.  Here we recognize there's going
     to be some individuals who may have to maintain their positions or make
     entries into certain areas, so we adopted that in here.  And also,
     business interruption.  Most facilities have some sort of, whether it's
     a fossil plant, nuclear plant, chemical plant, they have some sort of
     contingency plans or some sort of level of risk they're willing to
     accept, you know, a million dollars', two million dollars' worth of loss
     or a certain amount of downtime.  And that was put in here as well,
     which I don't think is strictly nuclear.  But obviously the first --
         DR. POWERS:  At the risk of provoking my colleague even
     further, or maybe the hope, hydrants with individual hose gate valves
     shall be installed approximately every 250 feet apart on the yard main
         Provided at intervals of no more than 350 meters along the
     yard line mainstream.  These are among those minimal requirements. 
     These are very prescriptive things where, another one, weekly valve
     inspections, why one week?
         DR. APOSTOLAKIS:  Exactly.
         DR. POWERS:  Eight days is unacceptable, six is too often. 
     I mean --
         DR. APOSTOLAKIS:  And that is something that really can be
     analyzed using risk analysis.
         DR. POWERS:  Yes.  Yes.  Yes, these are ones that can be
         DR. APOSTOLAKIS:  We have a whole risk-informed standard now
     -- I mean Regulatory Guide.
         DR. MILLER:  Weekly was probably established years ago by
     the --
         DR. APOSTOLAKIS:  Yeah, that's what --
         DR. POWERS:  Yes, but that is not an excuse for including it
         DR. APOSTOLAKIS:  See, that is the whole point with the
     redundant trains of safety systems, that years ago somebody said once a
     month, it became the Bible.
         DR. POWERS:  That's fine.
         DR. APOSTOLAKIS:  And now with risk-informed, one expects
     one can change that, like some of the diesels have gone up from seven
     days to 21 and so on.  So even the minimum requirements then can be
     questioned, that is what you are --
         DR. POWERS:  No, I think they can't.  I do think we need to
     move along, though.
         DR. APOSTOLAKIS:  Sure.
         MR. BIELEN:  Okay.  Moving off of box one.
         DR. APOSTOLAKIS:  I think we covered that.  We really don't
     want to be discuss that anymore.
         MR. BIELEN:  Does everyone have a general feel for how the
     standard is working better now?
         DR. APOSTOLAKIS:  Is there anything else you would like to
     tell us?
         MR. BIELEN:  We can probably move on to the next one.
         DR. POWERS:  You can be secure that the Subcommittee members
     have read the document.
         MR. BIELEN:  Okay.  A lot of the other overheads I have are
     kind of just word explanations for the flow chart, which I think we have
     gone over, and I will just go up to the conclusions.
         I would like to state that the project is on schedule. 
     Remember, it is the annual 2000 cycle.  We have a public proposal
     closing date of February 19th.  We are going to be meeting -- have to
     ROP meetings, so the project is going on schedule according to the NFPA
         The Committee still has to review the ROP and ROC, or still
     has an ROP and ROC period to make changes to address concerns.  I just
     want to emphasize that we are still at the very beginning stages of the
     process.  We just have the draft out.  We still have the ROP and the ROC
     period to go through.
         So, again, I know there seemed to be a lot of questions and
     concerns, and, like I said, we are still early on in the process, and I
     would like to get, as specific as we can, some input from the Committee
     as far as what we need to address and how to address it, which really
     addresses point number 3, is all public input proposals and comments
     must be addressed by the Committee.
         So just by saying I have got a problem here, I have got a
     problem there, you should address this, it doesn't mean it is going to
     get done.  What we really need to do is put this in as a formal process,
     a formal proposal or a formal comment if we are that stage, and then the
     Committee has to address in some way.  So that is what I would like to
     finish up is, any input we do have, do try to get it in on a public
     proposal by the February 19th deadline for the Committee to review.
         DR. POWERS:  I will comment that there has been information
     discussions among members of the Subcommittee where we would like to put
     together a set of comments.  We are struggling now as to how to bring it
     -- to follow our own process, which means we have to -- we can propose
     this to the full Committee and they are the ones that actually write the
     ACRS positions.  And we have to figure out a mechanism for doing that. 
     We think we have hit upon one.  And we will be -- we find ourselves in
     camera for the next two-and-a-half weeks or something like that, so
     there should be adequate time for us to work out the details of that.
         DR. APOSTOLAKIS:  By the way, what is A 2000?
         MR. BIELEN:  Annual 2000.
         DR. APOSTOLAKIS:  What does that mean?
         MR. BIELEN:  The NFPA has two cycles, an annual meeting and
     a fall meeting.  So this document is up for the annual meeting of 2000,
     which is May of 2000.
         DR. APOSTOLAKIS:  Okay.
         DR. POWERS:  Let me ask you a question about the
     philosophies behind these consensus standards a little bit.  No, it is
     not -- I am not going to go into that.  I promised you I wouldn't go
     into that.  I see we have your -- among the people developing these
     standards, those involved in the regulatory process that are
     knowledgeable about regulatory law, we have those who the licensees and
     are the victims of regulatory law, and we have another class of people
     who are the insurers who have a knowledge about standards and
     qualitative perceptions of risk.
         DR. MILLER:  And they also vendors of equipment.
         DR. POWERS:  And vendors perhaps.
         DR. MILLER:  I don't know if this one has it.
         DR. POWERS:  But it seems to me that, in looking to take a
     standard into the de jour, that you have a problem, that you are
     carrying along baggage that is imposed -- you have the possibility to
     carry along baggage that is imposed for financial rather than safety
     reasons.  Is that a concern we should have here in looking to some day
     take this standard and endorse it as a part of -- as an option within
     the NRC regulations?
         MR. BIELEN:  Yeah, that concern comes up with actually any
     standard because of the make-up of the Committee.
         DR. POWERS:  It is not yours in particular, it is anybody's,
         MR. BIELEN:  Or any of the NFPA ones.  But because of the
     way we are set up, we have to have two-thirds agreement by the Committee
     in order for it to go forward.  So we try to have balanced Committees by
     having no more than one-third of any particular interest group on the
     Committee, so the Committees basically can't be dominated by just the
     users, or just the enforcers, or just the manufacturers, or just the
     whoevers.  So you really have to have two-thirds agreement by the
     Committee in order for it to go forward, so that is how we have
     addressed that concern, by limiting the membership, balancing the
     Committee, and then having the two-thirds agreement.
         DR. POWERS:  My concern is not balance, I mean I, as an
     insurer, said, gee, I want a standard out there that I know if the guys
     comply with that, that I -- they have minimal risk of fire damage that I
     have to pay for, and there are a lot of things I want to have.  And so I
     work very hard and persuasively and get those in there.  But when we
     come from a legal basis that says, no, we don't worry about that sort of
     thing, what we worry about is protecting the public health and safety,
     we are imposing things, especially when we have prescriptive elements.
         We are imposing things upon the licensees that are none of
     our business to be imposing.  We have no legal basis to impose those, if
     one were to look at it in microscopic detail, and that is what concerns
     me a little bit about taking this and moving it into -- as an
     alternative to the regulations.  It is less concern to me if we say this
     is a Reg. Guide, this is a way to meet the regulations, but to say it is
     an alternative to the existing regulations, I think you run into a
     problem there.  It is an expression that has no answer, it is just a
         DR. MILLER:  Well, there is certainly precedence for that
     happening, though.
         DR. POWERS:  Steve has a question.
         MR. WEST:  I have a question?  I have an answer.
         MR. BIELEN:  Steve has an answer.
         DR. POWERS:  Good.
         MR. WEST:  Well, I think that is really a question that is
     more appropriate to ask the staff, that we will need to address through
     the rulemaking process.  I think, generally, the NFPA as an
     organization, in their charter mission, they are concerned about
     property, protection of property damage.
         DR. POWERS:  Oh, yes.
         MR. WEST:  I don't think not considering that in the
     standard is really an option for them.  Life safety, too, it is kind of
     part of their foundation, is to --
         DR. POWERS:  It was not meant as a criticism, it was meant
     as a question.
         MR. WEST:  Right.  I think through the -- if the staff finds
     -- and this is a question that has been raised by people in industry
     also.  We were at an NEI forum earlier, or late last year, and a lot of
     the participants there were questioning having property protection
     criteria and life safety criteria in the standard and what it meant in
     the regulatory space.
         But I think through the rulemaking process, we don't have to
     necessarily endorse the standard, the entire standard, we can endorse
     parts of it, or endorse it in part, or only those parts that we care
     about for regulatory purposes.  But there may be other authorities
     having jurisdiction out there that may be interested in the property
     protection or the life safety aspects and they may impose them through
     their own regulatory vehicles.
         DR. POWERS:  Good.  Sounds points all.
         DR. APOSTOLAKIS:  Why is the NFPA doing this?  Who started
     the process?  The industry or --
         MR. BIELEN:  Well, the NFPA has been involved with fire
     protection in nuclear facilities, I am trying to think of -- I think in
     the early '70s when we first started developing standards for the
     nuclear facilities.  805 kind of developed as a need, from what we have
     been hearing, through Committee members, through industry, but,
     basically, it was NRC, I think, from what I remember from the early
     discussion, was looking for a rulemaking and performance-based,
     risk-informed and the Committee said we can do that.
         MR. MARSH:  I think we wrote you a letter saying we needed
     this to be a component in the NFPA 805 in order to gain Commission
         DR. APOSTOLAKIS:  But I remember a letter to the Commission
     from the NFPA saying that we hear that you guys are about to do
     something and we are already doing this so why don't you join forces. 
     So that sounds like --
         MR. WEST:  You need to get to a microphone.
         George, there was also, there was a public law that said
     that federal agencies should, to the extent they could, rely on the
     consensus standard process instead of rulemaking and we did --
         DR. APOSTOLAKIS:  I understand.  But there was this letter,
     though, from the NFPA to the Chairman --
         MR. WEST:  Right.  When we --
         DR. APOSTOLAKIS:  -- saying that we are already doing this
     and why don't you guys join.  So it doesn't sound like the NRC was the
     one that initiated it.
         MR. WEST:  Well, there was a negotiation.  There was the NRC
     was looking at options for creating a performance-based, risk-informed
     rule or Reg. Guide for use by the industry.  And in parallel with that,
     the NFPA was thinking of creating NFPA 805.  But my sense, my memory is
     that they had not specifically -- and they came and talked to you --
         MR. MARSH:  Right.
         MR. WEST:  -- and you guys raised this question, too.  They
     did not specifically plan to include risk in the standard.  So the
     letter, the letter from NRR back to NFPA was, yes, we are interested in
     utilizing the NFPA consensus standard process for this new regulation,
     but if we are going to -- if you are going to do that, you have to
     understand what we need, and you are going to have to agree to include
     in your process our needs.
         DR. APOSTOLAKIS:  Okay.
         MR. WEST:  And then that's when we introduced the risk
     aspects to the standard.
         DR. POWERS:  I think we have -- have we covered your
         MR. BIELEN:  Believe me, I am done.
         MR. BIELEN:  Well done.
         DR. APOSTOLAKIS:  Very good.
         DR. POWERS:  Well, let me assure you that we very much
     appreciate your coming here.  You may not -- you may never come back
     again, but I hope you do.
         DR. MILLER:  Every year, we want you to come back.
         DR. POWERS:  Thank you very much.
         MR. BIELEN:  Okay.  Thank you.
         MR. WEST:  Dr. Powers, what is going to be fun is that Ed
     Connell has missed a lot of this, and he is going to be giving his
     presentation tomorrow, so.
         DR. APOSTOLAKIS:  Yes, I am not really sure, though, there
     is any purpose to that presentation.  Oh, no, he is presenting us --
         MR. WEST:  He is going to make a --
         DR. APOSTOLAKIS:  Your use of the 805.
         MR. WEST:  Right.
         DR. APOSTOLAKIS:  That should be interesting.  That should
     be interesting.
         MR. WEST:  Without the benefit of these comments, though.
         DR. APOSTOLAKIS:  Well, that is his problem.  The room was
     open to all.
         MR. WEST:  I said it should be fun.
         DR. POWERS:  It will not be the first time we have set Ed
         DR. APOSTOLAKIS:  So is this the end of the day, Dr. Powers?
         DR. POWERS:  No.  We are going to go back to my favorite
     subject, which is hot shorts.
         DR. APOSTOLAKIS:  And why are we going back, did I miss
         DR. POWERS:  Yes.  You have missed, or not had the privilege
     of a hearing from the BWR Owners Group, who is a major player in this
     whole area of the hot shorts and the hot shorts resolution effort.
         And I will have to say that, to introduce this, that I am
     gratified to see the spirit of resolution that so permeates some of
     these activities now in this area, rather than arguing simply over
     language and the like.  With that, the floor is yours.
         MR. BACANSKAS:  Good afternoon, my name is Vince Bacanskas. 
     I am not Greek, I am Lithuanian.
         DR. POWERS:  Well, you are very foolish, you should have to
     claimed to be Greek to begin.
         MR. BACANSKAS:  And there are two words missing from my
     presentation, one is "risk" and the other is "performance", and that is
     by intent.  I am the Appendix R Committee Co-Chairman.  We have two
     utility chairmen on this group and let me get right into it.
         To give you a little background, we formed this Subcommittee
     in 1997 in response to, first, some issues that came out of the early
     FPFIs, which the first two were BWRs, and some issues specific to BWRs
     came out.  I also wanted to mention to you that this was charted as a
     generic committee within the Owners Group.  What that means is that all
     BWRs are full participants and have full voting rights within this
     Committee.  You have had other groups speak to you who are cafeteria
     committees, or special interest committees such as the Mark I Owners, or
     some of the smaller groups.  This is all BWRs involved.
         What we are trying to do is -- and you heard earlier this
     morning from Ed, we have, I think, seven volumes of documents, guidance
     documents, on implementation of safe shutdown analysis.  We are trying
     to gather all of that, read through it, understand it, and put it into a
     format where it can be used as more or less a cookbook approach, a
     generic approach, for performing a safe shutdown analysis.
         So you are aware, we have a very explicit charter from our
     executives that we will not do this in a vacuum.  We have participants
     on both our Steering Committee and our Subcommittee who are active
     members of the Fire Protection Working Group at NEI, who are members of
     the NEI Circuit Failures Issues Task Force.  As Fred generates his, I
     believe two new tasks forces, we will probably have membership there as
     well, or members of our Committee, who are also serving on his.
         And we speak frequently with some of the industry
     representatives of the NFPA 805 Committee.  And I want to state that
     very clearly, we have been discussing a directed vote member for the
     Owners Group on the 805 Committee.  We are supposed to be in final
     discussions on that, but at this point we are coordinating and
     discussing issues with members from utilities of the Committee.  So we
     have no direct relationship with the NFPA 805 Committee.
         We have had three outstanding meetings with the NRC staff,
     which I would like to thank them publicly for today.  At each of these
     meetings we have had open discussion.  We have brought items to the
     table that we felt were our understandings of issues.  The staff went
     through in detail with us their history on that specific issue.  We have
     looked at solutions to provide a high level of safety, and have taken
     the NRC's input and gone back and looked at our work again.  And I think
     we have opened their eyes to some things that -- or perspectives that
     they did not see, and how we arrived at those perspectives.
         As Steve said earlier this morning, what we are attempting
     to do is to provide a licensing topical report, a GE -- I guess it would
     be a NEDO document, or an NEDC document, to the staff with the explicit
     methodology and positions for review by the staff, and request of a
     safety evaluation report and approval of our methodology.
         DR. APOSTOLAKIS:  So, your methodology -- I mean let's say
     that 805 is cleaned up and it is accepted.  Your methodology will go
     beyond that and adapt it to BWRs, or you might end up saying, gee, we
     like 805, so this is it.
         MR. BACANSKAS:  I think that as we get into it a little
     further along, you will see that what the Owners Group is doing at this
     point would parallel more the Reg. Guide effort than anything else.  We
     all have different licensing bases, different SERs, different
     idiosyncracies in our plant design, and we are trying to establish a
     common methodology that envelopes as much of the existing, as it is
     today, with the appropriate basis stated, and the source documentation
     from the regulations, so that we can walk through and understand how did
     we determine that this is adequate and safe.
         DR. APOSTOLAKIS:  Okay.
         MR. BACANSKAS:  We have developed an outline of the
     document, which I will run through quickly for you, and identify those
     areas where we will take what we call positions.  And I guess to explain
     a position, it is more or less an interpretation of the existing
     guidance and how it would be applied.
         We have gone through, as I said, seven volumes of regulatory
     information, SECY letters, Commission briefs, Information Notices,
     Generic Letters, the entire gamut, and have reviewed SERs, reviewed and
     catalogued all of this information, and we are trying to put it together
     in a cohesive story so that someone ten years from now can understand
     how we got where we are, which seems to be one of the biggest problems
     that exist today, that if we look back -- how did they do it ten years
     ago? -- we are not sure how we got where we are today.
         DR. POWERS:  Since that kind of objective seems to parallel
     very closely one of the objectives the staff has, is there a point where
     you think you -- you anticipate cross-checking your two conclusions?  I
     would not say reconciling your conclusions, because it would not
     surprise me at all if you were at odds here and there.  But will there
     be a cross-checking?
         MR. BACANSKAS:  We are doing through our meetings.  I don't
     know that they are holding up the draft Reg. Guide and saying this is
     what we have written.  But we are bringing forth, as we meet with them,
     the detailed written positions, making presentations to the staff, and
     then discussing them.  And it is nice to know they haven't thrown us out
         DR. POWERS:  I think they probably salivate every time you
     come because you probably make their job a little easier.
         MR. BACANSKAS:  Well, I think it is -- as I said earlier, it
     has been a very, very informative process, and I think a very positive
     process for both industry and the staff, because we are free to discuss
     these things in a non- -- even though it is a regulatory environment, it
     is a non-regulatory environment because there is no specific license
     action on the table.
         DR. POWERS:  I notice that the workshop in July, at least
     associated with the BWR Owners Group, there were a set of very specific
     questions on spurious operations.  Some interesting questions,
     situations, that asked for what the NRC position was.  Did you get an
     answer to those questions?
         MR. BACANSKAS:  On the July workshop?  From the Owners
     Group, --
         DR. POWERS:  I just assumed it was from the Owners Group.
         MR. BACANSKAS:  No, we did discuss some of this in detail at
     our December 2nd and 3rd meeting.  We are -- I believe Steve left with
     an action that he was going to give us certain bounds on what they have
     seen, and that we would continue to develop our position and discuss it
     with them further.
         MR. WEST:  Does that answer your question?  I mean during
     the workshop, we had question and answer sessions set up and we did take
     questions from the floor, and we responded to them.
         DR. POWERS:  Well, I will just --
         MR. WEST:  I don't know, I don't remember anything from the
         DR. POWERS:  I will read the start of a question, maybe it
     will trigger somebody's memory on that.  Assume that the spurious start
     of an ECS -- ECCS pump, such as the RHR pump A and a boiling water
     reactor is a concern.  Further assume the spurious start of the pump
     requires three short circuits to occur on separate conductors.  The
     separation analysis show the control cables associated with these
     conductors may be affected due to a common fire.  Is the starting the
     pump considered to be a valid spurious operation that needs to be
         There is a lot more to the question, but it ends up -- What
     is the NRC position on this?
         MR. WEST:  Yeah, we answered that one.
         DR. POWERS:  Okay.  What was the answer?
         MR. WEST:  Yes.
         DR. POWERS:  Okay.
         MR. WEST:  And I mean that is kind of also an example of the
     level -- some of the level of discussion we were having in the meetings
     with the Owners Group.  We get into some specific examples like that,
     looking at wiring diagrams and schematics, and postulating different
     events and what could happen.  It is the same type of -- parts of those
     meetings are the same type of discussion.
         MR. BACANSKAS:  And Steve reminded me to mention that.  I
     didn't put a specific note.  But one of the things we are including in
     the document, and have brought to our discussion are schematics, so that
     we can sit down and talk in detail, this circuit with this
     configuration, and these cables in this area, because sometimes, to get
     a clear path to resolution, you have to go to that level of detail.
         DR. POWERS:  Especially in this area, I don't see how you
     can avoid it.
         MR. BACANSKAS:  Correct.
         DR. POWERS:  Because the way the concern and the resolution
     comes clear to you is by looking at what the circuit actually does and
     where it is.
         MR. BACANSKAS:  Absolutely.
         DR. MILLER:  Are you starting with some of the assumptions
     that are in the Generic Letter 86-10, I think it is?  Are those the
     starting point for some of this?
         MR. BACANSKAS:  I think that is an accurate statement.
         DR. MILLER:  In other words, you are not looking at physical
     mechanisms of board circuits and stuff like that?
         MR. BACANSKAS:  No, we -- for instance, in question, I
     guess, question and answer 531 talks about hot shorts, shorts to ground
     and open circuits.  We are looking at those types of faults occur.  Now,
     we are trying -- they occur as a result of the fire.
         DR. MILLER:  Okay.
         MR. BACANSKAS:  What we are trying to do is look at, is
     there a means to bounds for a specific event and configuration?  How
     many of those would be credible?  That also walks into position on the
     hot short duration that you mentioned earlier, and then there's other
     sideline issues such as, if I have a fire of significant magnitude that
     it would burn up all of the cable in the tray, or burn up the insulation
     on the cable in the tray such that these faults could occur, is it
     credible then to assume that it would also damage the circuits such that
     they could not continue to carry the type of current that would be
     necessary to energize a pump motor, a valve, you know?  And we are also
     looking at, how far does that go.
         DR. MILLER:  So you are in a sense trying to bound, you
     point out the --
         MR. BACANSKAS:  We are trying to bound the deterministic
         DR. MILLER:  The answer in that particular Generic Letter.
         MR. BACANSKAS:  Yes.  Also, I wanted to mention that we have
     obtained abstracts and full reports on approximately, I guess it is
     around 95 NUREG contractor reports on testing of cable related to fire. 
     Steve Knowlen from Sandia assisted us in that area.  We have reviewed
     all of that for pertinent data with respect to the electrical fault
     conditions.  And, unfortunately, what we have found to date is there is
     not the database that you were alluding to earlier out there and
         DR. MILLER:  Which is not a surprise.
         MR. BACANSKAS:  No, it is not.
         DR. POWERS:  Well, you know --
         MR. BACANSKAS:  There is a lot of information with respect
     to how does the insulation system respond, but not to the electrical
     performance characteristics.  There's a fairly detailed report on the
     effect of aging and the loss of antioxidants in the insulation system
     and the impact on its propagation of flame with an ignition source.  But
     the cable was not energized during the testing, it is not in the
     standard configurations, and so there is no real value from the
     electrical circuit analysis standpoint.
         DR. POWERS:  Are you looking -- is anyone looking to see
     what other people have?  Certainly, you would think that maybe other
     industries have it, or the insurance industry has, or perhaps the
     military has it, especially, the Navy.
         MR. BACANSKAS:  I think I heard the same presentations you
     did from the one individual.  NEI is investigating that and speaking
     with that individual, and we are trying not to do the same thing in five
     different places.  So we are looking to NEI to lead that effort.
         DR. POWERS:  Okay.  Good.
         MR. BECANSKAS:  I think I've already stated this.  Steve
     mentioned earlier this morning that there were 20-odd positions that
     we're looking at developing and after additional committee meetings and
     discussions we found that, well, some of these really aren't position
     statements.  They are definitions and they are terms that are generally
     undefined in the existing guidance documents and also in the
     regulations, so we would like to attach a very specific definition so
     that wherever that word appears you get the same meaning from the word.
         We felt that we had to start with definitions so we are all
     starting on a level playing field, as far as understanding.
         We have reviewed several of these position statements with
     the Staff, as I said, and our basis for them, and they have provided
     feedback.  We are discussing them and we continue to discuss them and we
     have an Owners Group meeting planned the first quarter to work on more
     of our positions and hopefully not long after to meet again with the
     Staff to go through those.
         The schedule -- we provided a full schedule for submittal of
     our document to the Staff and originally we had looked at either late
     first quarter or early second quarter of this year for completion of our
     document with some of the input we are looking for from NEI we are
     probably going to submit later in the second quarter of this year.
         However, we still see this as a very high priority issue. 
     We have a lot of resources applied and we want to continue to move and
     complete the activity in a reasonable timeframe.
         The rest of my presentation I think is just a breakdown of
     the document and the sections, and again our entire purpose with this
     activity is to take all the existing guidance and put together a
     methodology that can be used for support of the existing information
     that we have and should design modifications be done in a plant to
     factor in those changes through use of this methodology so that we are
     all working to the same way of doing business.
         We have had discussions with the other owners groups about
     their participation in this activity and we have received interest from
     them.  I think that the BWR Owners Group is set up a little differently
     as far as how they function and start committees and issues, which has
     brought us to the front end of this issue and through NEI, through many
     of our own utilities -- mine, for instance, we have Combustion
     Engineering units, B&W units, and GE units -- we also have a fire
     protection peer group that is supporting this activity internally, so we
     are disseminating this information.
         Unless somebody wants me to go through the specific details
     of any of these sections, I can stop right here and hopefully answer any
     questions you might have.
         CHAIRMAN POWERS:  I guess the first question that comes to
     mind flows immediately from what you have just said -- disseminating the
         Do you anticipate that there are going to be wild
     differences between what you -- this cookbook that you have come up with
     at least with respect to approach on circuit analysis for a BWR or any
     other plant?  I admit the specific circuits are going to be a bit
     different, the acronyms for the equipment are a bit different, the
     functions of the equipment tend to be about the same?
         MR. BECANSKAS:  I think the simple answer to that is no. 
     There are some unique functions in a BWR that will be addressed, however
     we expect that 80 to 90 percent of the overall document could be applied
     to any operating reactor.
         CHAIRMAN POWERS:  And the next question that comes to mind
     is that if indeed late in the second quarter you are able to submit a
     document, I hope you would have a chance to come by and talk to us about
     what you came up with in that document?
         MR. BECANSKAS:  We have anticipated all along that when we
     had the details of the document or had a draft document that had been
     approved through our executives, far enough along through our process we
     would bring it here as well as the Staff.
         CHAIRMAN POWERS:  I think that would be very edifying for
     us.  We will promise that the words "risk" and "performance" will not be
     allowed in the discussions.
         MR. BECANSKAS:  It seems to go quicker if you leave those
     words out.
         DR. MILLER:  It would be interesting when you feel it's
     available for the public to share your definitions and your positions. 
     I realize you wouldn't want to do that now because they're certainly in
     flux, but that would be very illuminating right at this point.
         MR. BECANSKAS:  I don't think there would be any
     disagreement with that, and we are still fighting with one or two of the
     definitions because of all the various documents and how it is couched,
     and you end up with a definition that is eight pages long.  That doesn't
     buy you a whole lot.
         DR. MILLER:  You need to shorten that a page or two.
         MR. BECANSKAS:  A little bit -- get it down to 10 and we'll
     say we'll use Number 6.  Thank you, gentlemen.
         CHAIRMAN POWERS:  Thank you very much.
         This was -- I guess that I am enthused about this activity
     just because it seems like it's a damn good QA check for reactivity that
     you are taking under with the Reg Guide activity.
         MR. MARSH:  Well, I am enthused in that we have moved off of
     this --
         CHAIRMAN POWERS:  Oh, yes.  Yes.  This is going to get us to
         MR. MARSH:  We may not agree 100 percent with how this thing
     ends up, but it is a lot better process to get to that point than
     arguing over "this document is wrong" --
         CHAIRMAN POWERS:  These particular set of words and --
         MR. MARSH:  By using deterministic, risk insights and test
     information, I think there's hope to end up at really the right place.
         CHAIRMAN POWERS:  Yes.  I agree with you 100 percent on
     that.  This is going to take us to some sort of a resolution --
         MR. MARSH:  Absolutely.
         CHAIRMAN POWERS:  -- that everybody can live with.
         MR. MARSH:  Absolutely.
         CHAIRMAN POWERS:  That brings us to the close of the formal
     presentations for the day.  We will have a presentation tomorrow and --
     quit chuckling -- Ed's got a hard job.
         MR. MARSH:  I am not going to tell him anything that was
         CHAIRMAN POWERS:  Oh, you are a dirty dog.
         MR. MARSH:  He missed the day.  That's his problem.
         DR. MILLER:  You are going to make him clueless?
         MR. MARSH:  That's right.
         CHAIRMAN POWERS:  I think it will be an important
     presentation but I think it is more important for the subcommittee to
     get its act together and figure out how we can comment effectively on
     what we have heard, and we will do so.
         We are also going to discuss the Research Program and the
     IPEEE and that of course is a much-anticipated discussion by an erudite
     and authoritative figure in the field --
         DR. APOSTOLAKIS:  You are not speaking for the subcommittee,
     are you?
         CHAIRMAN POWERS:  You will quickly find that I will be
     recusing myself and turning the chairmanship over to Mr. Kress.
         So now let me close this session by asking if there are any
     comments that the members would like to make at this point, recognizing
     that we will have comments again at the end of tomorrow's session, but
     George, aside from the fact that I think we all agree that we do have a
     problem of PRA being one-way street to enhanced regulation that has to
     be guarded against, anything else you would like to say?
         DR. APOSTOLAKIS:  Well, I think I have said enough.  I'll
     summarize tomorrow, I suppose.
         CHAIRMAN POWERS:  Dr. Kress?
         DR. KRESS:  I think I have said it.
         CHAIRMAN POWERS:  Your definition of performance-based
     regulation still rings true in my mind.
         Our distinguished guest from the I&C Committee?
         DR. MILLER:  Well, I find that this was a very illuminating
     day and I am anxious to get more involved in the circuits aspect of
     this.  I learned a lot today and what I learned most is there's a lot
     more to go here with this.  The circuits aspects are kind of challenging
     and kind of interesting.
         DR. KRESS:  We realize you I&C guys are the whole trouble.
         DR. MILLER:  Yes?  I thought we were the solution.
         CHAIRMAN POWERS:  If the I&C guys would just use cables
     about this big around, a lot of our problems would go away.
         DR. MILLER:  Fire resistant cable -- that's what you need.
         What if we have to use all fiber optics cables and replace
     all the electrical cables?
         DR. APOSTOLAKIS:  Who else is a member of this subcommittee?
         CHAIRMAN POWERS:  Frequently Mr. Barton attends -- because
     we frequently find ourselves involved with plant operations and so often
     he attends.
         DR. APOSTOLAKIS:  I think one of the utility people should
     be a member, a standing member.  Mario?
         CHAIRMAN POWERS:  Barton just frequently attends and I will
     remind the members also that we are still anticipating a subcommittee
     meeting in June in Region I.
         DR. MILLER:  On this particular issue or just --
         DR. APOSTOLAKIS:  You can change the dates -- June -- seven
         CHAIRMAN POWERS:  It is a much more wide-ranging issue than
         With that I will recess the meeting until tomorrow after
     thanking all the speakers and participants.  I found it fun today.
         [Whereupon, at 5:00 p.m., the meeing was recessed, to
     reconvene at 8:30 a.m., Thursday, January 21, 1999.]

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