Safety Research Program - December 01, 1999
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS *** MEETING: SAFETY RESEARCH PROGRAM *** Room T-2B3 Two White Flint North 11545 Rockville Pike Rockville, Maryland Wednesday, December 1, 1999 The committee met, pursuant to notice, at 1:20 p.m. MEMBERS PRESENT: GRAHAM WALLIS, Chairman, ACRS WILLIAM SHACK, Member, ACRS DANA POWERS, Member, ACRS GEORGE APOSTOLAKIS, Member, ACRS ROBERT SEALE, Member, ACRS ROBERT UHRIG, Member, ACRS JOHN SIEBER, Member, ACRS JOHN BARTON, Member, ACRS. P R O C E E D I N G S [1:20 p.m.] CHAIRMAN WALLIS: The meeting will now come to order. This is a meeting of the ACRS Subcommittee on the Safety Research Program. I am Graham Wallis, chairman of the subcommittee. ACRS members in attendance are Dr. William Shack, Mario Bonaca, Dr. Thomas Kress, Dr. Dana Powers, Dr. George Apostolakis, Dr. Robert Seale, Dr. Robert Uhrig, Mr. John Sieber, Mr. John Barton. The purpose of this meeting is for the ACRS members to discuss the final draft of the Year 2000 ACRS Report to the Commission on the NRC Safety Research Program. The NRC staff will participate in the discussion as appropriate. We are hoping to go as far as we can toward drafting a final version of this report. Mr. El-Zeftawy is the cognizant ACRS staff engineer for this meeting. 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 November 16, 1999. A transcript of this 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 heard. We have received no written comments or requests for time to make oral statements from members of the public, but I expect that we will call upon at least one member of the staff. Now, we are on the record at the moment, and my hope for this meeting is that while we're on the record, we can talk generalities; we can talk about what should be in the report; what is in the -- it's a broad-brush treatment in the report. We can go through section-by-section with comments, and if we get far enough, which hopefully we will do, I would like to look forward to a time when we can go off the record, and we can proceed paragraph-by-paragraph and hopefully line-by-line with the report. I read yesterday some remarks by Rolls Royce chairman Manuel Bartu, and he said there were three ways to lose money. The most fun was on women. The most foolish was to gamble. But the most certain way was to sponsor research. [Laughter.] DR. KRESS: I'd like to do some research on those first two items. [Laughter.] CHAIRMAN WALLIS: So, all levity aside, what I would like to do is proceed with our business. And what's going to happen in this meeting is that the report which was drafted mostly by one person with help from individuals will become a report representing the consensus of all of us. And the way I think we could do that is to start off with an overview of what it tries to say and see if there are major issues involved in what is said now; if there are better ways to say it or alternative things that should be said. So unless there are objections or other proposals, I would like to go through section-by-section and invite constructive comments and criticisms, suggestions. The first section is called introduction. It's very brief. What it tries to do is say that we've already written two reports, and one of them is hot off the press, and in those, we looked at the details of what research is going on and commented on it, and our comments are still valid, so what we have tried to do in this report is to take a broader view. Is this -- DR. POWERS: I took exception to this. CHAIRMAN WALLIS: Okay. DR. POWERS: That I thought -- it begins by saying this is the third in a series. It's all on the same intense topic, and I said no, this is just our annual report on the research, and people know that things have gone before, and it didn't make any difference. CHAIRMAN WALLIS: Could that be fixed by simply changing the wording of the first paragraph? DR. POWERS: I'm sure that we can change it. CHAIRMAN WALLIS: This is the third report, and if the word series disappears, that's fine. DR. POWERS: I would just say that it's our 2000 -- DR. SEALE: 2000 report. DR. POWERS: It's the Year 2000 report on research. CHAIRMAN WALLIS: So this could be fixed by wordsmithing. DR. POWERS: And I would not say that what we said before remains valid. It says some of our comments remain valid, and most of our -- DR. BARTON: My problem was with the word most, not the other ones. DR. POWERS: So now, we force them to say ah, which one of these is valid, and which one has expired. CHAIRMAN WALLIS: Let's say our previous comments remain valid. DR. POWERS: No, I would just say if our previous comments remain valid, it's time to remake them, and I think we do, but it's important to say it. DR. APOSTOLAKIS: Yes; I was bothered by that, too. CHAIRMAN WALLIS: You're bothered by them being still valid? DR. APOSTOLAKIS: No, I think that phrase is too vague. DR. POWERS: The word, yes. CHAIRMAN WALLIS: Well, the idea is we don't want to go over old ground. DR. POWERS: And that's fine; we don't have to, and we don't need to apologize for it. We're going to get into it right down here. I would say this is our report; we examine in a broader context than we have before. CHAIRMAN WALLIS: I think that's fine. I think this could be fixed at the -- DR. POWERS: Yes. CHAIRMAN WALLIS: -- point where we edit. DR. APOSTOLAKIS: My recommendation was to take our 1998 and so on; make it part of the first paragraph and delete the sentence many of these programs. CHAIRMAN WALLIS: Again, if this can be fixed by editing, then, we'll do it. DR. APOSTOLAKIS: It's a little more than editing. That's why we raise it now. CHAIRMAN WALLIS: Yes; the thing that concerned me was whether we said the right thing and whether we didn't say enough, perhaps. DR. APOSTOLAKIS: But I have one more comment on the general structure. CHAIRMAN WALLIS: Yes, sir. DR. APOSTOLAKIS: There is a memo here that says that we decided to go with option four, which is a much shorter high level report; make recommendations and more like an extended ACRS letter. If it's more like an extended ACRS letter, should there be a section up front with major conclusions and recommendations? DR. POWERS: I think I would be enthusiastically opposed to doing that. DR. APOSTOLAKIS: The problem that I have is that I have to read a lot of this stuff without knowing where I'm going: external context, internal context, and then, I have to stop and think so what is the ACRS proposing here? I think it will help having up front a series of -- okay, you discuss external context. What is the message you're sending? Can that be stated in two or three lines and put it up front? Why do I have to stop and think what the committee is trying to say? DR. POWERS: It's usually useful to stop and think first. Most people, you know, support that kind of -- DR. KRESS: I think it would sort of really hurt the flow of this letter if you did what you say, George. DR. SEALE: You're almost inviting somebody to quit. DR. APOSTOLAKIS: No; then, another way of doing it is maybe to indent a critical paragraph at the end of each section. DR. KRESS: Well, that might be all right. DR. APOSTOLAKIS: And say -- yes, in order not to interrupt the flow. You know, you have read all of this; now, this is the essence of it; this is what we're telling you. And for example, for the external context, it seems to me that the last paragraph, maybe with a little bit of wordsmithing, is really what you're trying to say: hey, industry, change your attitude. I mean, that's what I got from all this. DR. SIEBER: Would you consider writing an executive summary? DR. APOSTOLAKIS: It's a short report. DR. POWERS: It's a short report. DR. KRESS: It's short enough. CHAIRMAN WALLIS: I suggest that we think about this, and we come back to it. DR. APOSTOLAKIS: But I must say that I had to stop after the first two or three sections and really reflect on what the committee is trying to say. CHAIRMAN WALLIS: I moved away from it personally, that originally, we had some bold things in the recommendations; remember the very early draft and others; I didn't like that. This really is more -- it's to be read more as an article, and every paragraph should count. It's not as if there are recommendations that stand out. DR. APOSTOLAKIS: Of course, they count, but still, you know, once you whet my appetite that you're telling me to do something, I will go back and read your paragraphs to understand better where you're coming from, but all I'm saying is that certain paragraphs and sentences here deserve to be indented to bring attention, you know, to the conclusion, to something. We have done this before. DR. BONACA: The other possibility, you know, if you go at the end of the introduction, and then, you look at what comes after that, the external contents, the internal contents and so on, it looks exactly like what you do when you're looking at a strategic plan. That's really what the NRC is not doing when they're looking at research. They're looking at external contexts; they're looking at internal contexts; they're looking at the horizon they're looking at, which for research, I think, is fundamental. They do research for 20 years; 30 years; they use it for research for now. We never addressed that issue there. The bottom line is that at the end of the introduction, one could present a brief summary statement of what is coming. DR. APOSTOLAKIS: That would help a lot. DR. BONACA: Just a little section that says here, we are portraying some perspective on a research program that includes a description of the external context, you know, and go on in some summary or thought process that takes you there. The other thing you're doing or that you're trying to do is take all of their analysis, and for example, later on, on the PRA issue, I find that I believe that the NRC has never addressed the issue of stakeholders. I believe that the industry and the NRC right now on development of user PRA, they have somewhat different ideas. There isn't a full understanding of the stakeholders, what they want. I'm just making that as an example there why we have to maybe make a description there and then tie together these other issues. DR. KRESS: I personally have never liked reports that say here's what we're going to say in this section and then say it and then at the end say this is what we said. It sure wastes a heck of a lot of time in my mind. So it sort of ruins the whole flavor of the thing for me. DR. POWERS: I'd like to, quite frankly, enjoy being seduced. DR. KRESS: Yes. DR. POWERS: Both intellectually and physically, by the way. DR. KRESS: Yes. [Laughter.] DR. KRESS: I agree on both of those accounts. CHAIRMAN WALLIS: There's no connection. DR. APOSTOLAKIS: The intellectual seduction here is very low. DR. POWERS: To my mind, I want to understand -- I like to know what the title of the issue is; then, I like to know something about its history; something about its, you know, what's happening; what the issue is, and then, hit me with a conclusion. CHAIRMAN WALLIS: When you go to a play, it usually doesn't help to have the plot -- DR. POWERS: It usually does. CHAIRMAN WALLIS: -- told ahead of time. Well, they set the stage, but if the plot is revealed, that spoils the fun. Anyway, I suggest that we read through it, and then, we bear this in mind: we say is there some way this could be summarized? And then, if there is, we may want to come back to this issue -- DR. POWERS: Okay. CHAIRMAN WALLIS: -- and respond to George. Is there anything else on the introduction? [No response.] CHAIRMAN WALLIS: Can we move on to the first -- DR. POWERS: The section? CHAIRMAN WALLIS: The section, yes; I was going to say the first thing that was substance. MS. FEDERLINE: Can I offer just one point on the introduction? CHAIRMAN WALLIS: Yes, please. MS. FEDERLINE: My name is Margaret Federline. One concern that we had on the introduction was the indication that most of your comments from previous reports are still valid. A number of areas we feel we've tried to respond to your comments, and this sort of leaves the question open of is staff just ignoring the ACRS, and we hope that you don't feel that way. DR. POWERS: I thought we'd convinced him to just delete those words altogether. MS. FEDERLINE: I apologize. DR. APOSTOLAKIS: The sentence is out. You agreed, right? DR. BARTON: No, he agreed to change i. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: It was supposed to be supportive. I mean, I'm thinking about thermohydraulics. I mean, the last report, we had two pages on thermohydraulics, explaining why there was a need for research in this area, and the intent of saying still valid was to say that, you know, there was still a need for research in this area for the same reason. It wasn't to say that you hadn't responded; it was to supply the support that you needed. DR. POWERS: You have to understand the practicalities. Our compliments don't help them a bit. Our criticisms are used against them. DR. APOSTOLAKIS: And I think it's too vague a sentence. That's why I wanted it -- CHAIRMAN WALLIS: Well, let's look at it when we look at the detail. MS. FEDERLINE: I think it would be helpful to say the needs are still valid that we described. That would be very helpful. DR. APOSTOLAKIS: But then, I'm having a problem with that, because I have to know what needs they are. I think the sentence should be deleted. CHAIRMAN WALLIS: If in doubt, leave out. But then, we're down to editing. DR. POWERS: And again, if there's something that's important that remains true today, be it needs or be it criticism, we state it. DR. APOSTOLAKIS: We state it. CHAIRMAN WALLIS: The reason it was put there was to respond to people who say why didn't you say something about X? Well, last year, we said a lot about X, so we didn't do it this year. DR. APOSTOLAKIS: Well, why don't we do that as we go along and then say, you know, for this X, go to last year's report. CHAIRMAN WALLIS: Maybe; okay, perhaps. The purpose of the external context was -- I think everyone has a different view of what's been happening, but my view is that the NRC has responded to budgetary pressures and pressures from political sources saying it's taking too long to make decisions; it's not effective; it needs to streamline its regulations; it's done a good job there, and research hasn't had the same sort of external stimulus because there haven't been great events at nuclear plants which had to be investigated technically and our research and so on. In the license renewal, which some people thought was going to be a big technical issues turned out to be well-managed, and ongoing programs can handle that. There haven't been big challenges from the public and so on. So there has been perhaps a feeling that research wasn't needed, but, in fact, we don't think that's the case, and here are the reasons why. That was the purpose. DR. UHRIG: You've got one sentence in here that will raise a red flag with a lot of people: there have been no major events at nuclear power plants that have received widespread publicity. DR. POWERS: Yes. CHAIRMAN WALLIS: The meaning there was technical, though. DR. UHRIG: Millstone is on the front of Time Magazine -- DR. APOSTOLAKIS: Was it this year? DR. POWERS: Well, the trouble was that in reading this, it's very unclear what time context. DR. UHRIG: Yes. DR. POWERS: And, in fact, it turns out that as you read through this and go further into the document, the time period issue is varied according to the need. CHAIRMAN WALLIS: It's supposed to be a year. It's the first line. DR. UHRIG: If you say that in the last year, then I don't have any quarrel with that. DR. APOSTOLAKIS: Well, that's the first sentence, isn't it? DR. POWERS: The first sentence says. Well, I think I still have troubles even if it says the past year. CHAIRMAN WALLIS: Millstone was more, if I may dare to say so, a political event than a technical event requiring research, so maybe the words need to be changed, but I don't think Millstone was what I call an event at a plant. An event at a plant to me is a broken pipe or a near disaster. DR. POWERS: Or something. DR. UHRIG: A major event at a utility. DR. POWERS: In that context, you've had WPN II, and somehow, having a pipe break by water hammer that floods things up 10 feet deep strikes me as modestly interesting. I mean, it got my attention. CHAIRMAN WALLIS: It didn't receive widespread publicity. DR. POWERS: If you were in Washington State, it did. CHAIRMAN WALLIS: Well, let's see: can the thrust of this be fixed, or do you want to delete the idea? DR. POWERS: I think first of all, I had difficulties with the word context. I mean, it just grated. I just don't know what it was. You needed to explain to me what you were trying to do in the context, and maybe you need to do that up in the introduction. CHAIRMAN WALLIS: I thought Mario did a good job of that already. DR. POWERS: I guess I haven't read what he has written. CHAIRMAN WALLIS: It's sort of standard when making a plan for anything to look at the external and internal context. It's almost standard jargon. DR. POWERS: Not in my world. I probably haven't used the word context six times this year. CHAIRMAN WALLIS: I've heard George use it a lot. DR. APOSTOLAKIS: And it will be used again. You don't mean the external error-forcing context. CHAIRMAN WALLIS: Is there a better word? Is there a better word for context? DR. SIEBER: Situation? DR. POWERS: Well, maybe if we understood better what it was being tried to accomplish here. DR. APOSTOLAKIS: Environment? DR. POWERS: Because we begin with this that there have been no events, but gee, I've got a lot of LERs; I've got a lot of events. It struck me as kind of interesting. CHAIRMAN WALLIS: Well, research doesn't exist in a vacuum. It exists in response to the external world, which is the context in which it exists. DR. POWERS: Okay; well, this agency has been responding pretty heavily to our political context. CHAIRMAN WALLIS: Yes. DR. POWERS: That is not mentioned in here and probably shouldn't be mentioned in here, okay? CHAIRMAN WALLIS: That's been the first paragraph, really. The technical issues have taken a back burner because political issues have received over much publicity and attention. DR. KRESS: I think it's an ultimate -- second from the bottom paragraph is probably true, and I think he's trying to set up the context by which that statement can be put as being a true statement. DR. POWERS: Because I didn't hear what sentence it was that you were -- CHAIRMAN WALLIS: A climate has grown up. DR. KRESS: Starting with a climate. DR. APOSTOLAKIS: Second paragraph from the bottom. DR. POWERS: I guess I still don't understand. CHAIRMAN WALLIS: I think that's the message we want to get across. It's the message I want to get across that you guys have got the wrong idea. DR. POWERS: I still don't understand which sentence you're talking about. DR. BARTON: The second. DR. KRESS: It's actually two sentences. DR. POWERS: Okay; you're well along here. Look: I have troubles with this whole second paragraph. I just didn't agree with a single word that was said in here. It says acquired absolute margins that have required a resolute defense. Gee, there have been all kinds of things there: the maintenance rule; 50.59; cornerstones of safety; all of those dealt with margins. It comes along here predictions. I'm confused. I doubt any licensees would be willing to claim a DBA analysis he has done as a prediction of a plant response, realistic or otherwise. I'm just not going to agree with those things. CHAIRMAN WALLIS: I disagree, but my view is these are preliminary skirmishes. They could be resolved without having to do hard work. The really tough ones haven't really come up yet. That's my view. DR. POWERS: Okay; it's a definition of effort, then. 50.59 to you was a walk in the park; maintenance rule was a -- CHAIRMAN WALLIS: I better not say anything about it. DR. SIEBER: From the point of view of research. CHAIRMAN WALLIS: The intellectual effort put forward was zilch. The amount of maneuvering and doubletalk, that is not -- DR. APOSTOLAKIS: Wait a minute. CHAIRMAN WALLIS: Okay. DR. APOSTOLAKIS: If you try to risk-inform 50.59, I think there are intellectual challenges. CHAIRMAN WALLIS: Absolutely. DR. APOSTOLAKIS: If you are trying to have a stable rule the way the commission wanted it, then, I think it's a matter of English. CHAIRMAN WALLIS: Then, you probably don't need research. DR. APOSTOLAKIS: English literature. DR. POWERS: It does not say there has not been anything here in terms of research. If there is an absolute sense the agency has not had to deal with margins, and I've heard more of a discussion of margins this year than I have in the five previous years I was on the committee. Now, if it's in a context of research, you've got to say that. CHAIRMAN WALLIS: You have to read what it says. It says requiring clearer definition of adequate safety. We have not yet had the clear -- DR. POWERS: You're going to have to tell me where you are, because somehow, my -- CHAIRMAN WALLIS: I'm talking about margins. DR. POWERS: -- version here is not correct. CHAIRMAN WALLIS: So I was addressing the sentence with margins. It says significant challenges requiring clearer definition. DR. POWERS: 5.1, I don't have. CHAIRMAN WALLIS: The point is that in the future, we are going to have to be much more hard-nosed about some of these decisions. We can't just talk our way through them. Again, that's my view. DR. POWERS: So I marked up the wrong one? MR. EL-ZEFTAWY: No, it's the same one, the same one that he's -- DR. APOSTOLAKIS: Just a different font. MR. EL-ZEFTAWY: A different font. CHAIRMAN WALLIS: You have a different document? DR. POWERS: Okay; how do I know where I am on this thing? CHAIRMAN WALLIS: You should have this document. DR. POWERS: Well, I don't have that document. CHAIRMAN WALLIS: We all have it. DR. SHACK: Second paragraph, external context. DR. POWERS: It would really help if these paragraphs were numbered, and the lines were numbered, if we're going to discuss this, because I don't think this second paragraph is a fair statement of what's going on in the agency. It may be a fair statement of what's going on in the agency with respect to research, but it does not say that, and if you tell me I have to read this like a Talmudic scholar and understand this is only about research, I object. DR. APOSTOLAKIS: I guess the first sentence of the second paragraph is the thought behind the rest of it, but there are important ongoing technical issues that are addressed by the research programs. The external context really has not affected those. And then, you go on to give examples. So the word research is there. Now, he's referring to research programs in the rest of the paragraph. DR. POWERS: Again, George, if I have to pore over this -- DR. APOSTOLAKIS: Well -- DR. POWERS: -- and spend time debating -- DR. APOSTOLAKIS: Might as well make it clear. DR. POWERS: Yes, because some of these things are fairly bold statements, categorical in nature, that I think would lead most people to say my God, one or two things are wrong: either the ACRS has no idea what's going on in the agency, or I don't know what's going on in the agency. DR. APOSTOLAKIS: Let me propose that we delete from the third line "there have been no major events" all the way down to "realistic." I think the rest of it is not so -- such a time bomb. The NRC is still gaining experience; the need for reliable and comprehensive PRAs is correct; kind of neutral. I think it's those four lines between there have been no major events through prediction methods more realistic that are creating this problem. DR. KRESS: I wouldn't want to lose the sentence that starts out with nor have there been significant challenges to the research. DR. APOSTOLAKIS: Well, see, that's what, I think, bothers Dana, though. DR. KRESS: I know, but I wouldn't want to lose it. DR. APOSTOLAKIS: It depends on how you interpret the significant challenge. There were significant challenges, but I think Graham's point is that they were not research challenges. I mean, the issue of margins certainly was a major challenge, and who owns the margin but NEI and so on? But it isn't really a research question. It's more of a policy question. DR. KRESS: In the broader sense of research, yes, it is. DR. APOSTOLAKIS: I think it's more of a policy issue. Maybe we can start by saying while there have been significant challenges in the policy arena, the corresponding research needs, you know, have been minimal. DR. POWERS: Okay; and I'm going to come along and say gee, the Frenchmen get a bunch of experiments in Katarache and upset the whole basis that the fuel licensing program is going on, and we had to institute a major confirmatory research program in order to assure that what we had done in the past hadn't jeopardized the plant. You know, that was at least modestly entertaining to me. DR. APOSTOLAKIS: Well, would you agree with my recommendation, delete those five lines? DR. POWERS: Well, I'm going to keep going, because the next one, I have objections to the next sentence as well. DR. APOSTOLAKIS: The industry are still gaining experience with risk-informed regulations? That's a true statement. DR. POWERS: It's that there may be significant rewards from taking changes in the regulations by truly risk-informing Part 50. DR. APOSTOLAKIS: Yes. DR. POWERS: And I object -- DR. APOSTOLAKIS: That's pushing it. DR. POWERS: -- to arguing that the reason we're going -- intimating that the reason we're going to risk-informed regulations to ensure that the industry gains rewards. I think the reason we're going to risk-informed regulation is that we believe that it will focus more clearly on the parts of safety that are really important, and what is there to be gained -- CHAIRMAN WALLIS: That's a reward. DR. POWERS: If rewards are to be gained by the industry, so be it. DR. APOSTOLAKIS: But I don't think that's his point there. I didn't read it that way. It was more of a statement of fact that the industry is finding out that this is true. Graham is not saying that we are pushing it because of that. That's how I read it. In fact, that ties very well with your last paragraph, when you are asking them to be less hostile. CHAIRMAN WALLIS: I'm surprised at that, because the whole thrust of this paragraph is to say look: you guys have had difficulty justifying research based on external events or external justifications. If you had had major events; if you had had industry saying gee, whiz, we can gain all this stuff if we risk-inform, then, you would have to respond. And in fact, we are implying that these things could happen in the future. DR. POWERS: My fuel example comes right back to me. Here is an external challenge that arose; NRC responded, and they funded Ralph rather well and vigorously. CHAIRMAN WALLIS: Which one is this? DR. POWERS: High burnup fuel. They suddenly realized that their regulations were based on an extrapolation of the database that might not be defensible. They looked at it; they said, well, it doesn't look so bad that we're clearly in trouble. Let's institute a research program to see to it that we confirm that we are okay where we are, and they did, and they're pursuing it. It seems to belie the point that you're making. CHAIRMAN WALLIS: So this would be one of the few immediate crises which it has faced. DR. POWERS: Similarly, it seems to me that we raise some issues with them on whether steam generator tube ruptures were going to be induced in plants, and they went through a rather elaborate research program to come to the analytic conclusion in all probability not. I'm looking to my research organization friends to confirm that that was the case. MS. FEDERLINE: Sorry; I -- DR. POWERS: A steam generator tube rupture -- MS. FEDERLINE: Yes. DR. POWERS: -- effort that Charlie Tinkler undertook -- MS. FEDERLINE: Yes. DR. POWERS: It was a challenge; the question was are the degraded tubes such that all accidents become bypass accidents, and Charlie Tinkler launched an effort that seemed to involve many laboratories; I can't remember all of the details of it, but he had everybody and his dog working on it at one time, I think, in which they went through it, and they said based on what their codes did, based on calibrating their codes to Westinghouse flow data that no, it probably wouldn't turn all reactor accidents into bypass accidents. MS. FEDERLINE: Yes. DR. POWERS: I believe that's the conclusion. CHAIRMAN WALLIS: Does anybody else have an opinion on this paragraph? DR. KRESS: Well, I think Dana has brought up a couple of examples that are contrary to the -- what you say here, but I still believe that in general, as an overall integral assessment that what you say is basically right, and there are a few things that we can bring up that are contrary to it, but that's always the case, and I would -- my opinion is that the paragraph basically characterizes a situation with a few exceptions and that it's well worth keeping in there, because it leads you into your external context that you want to make your main point about the climate. CHAIRMAN WALLIS: The first sentence is it has faced few major crises; we could insert some of these examples of -- DR. KRESS: You might want to do that to soften it. DR. APOSTOLAKIS: No, no. DR. KRESS: But I think -- DR. APOSTOLAKIS: No. DR. KRESS: -- in terms of general external contexts, while there might be some few exceptions, it's still a pretty good characterization. DR. APOSTOLAKIS: I agree with Tom, and I would keep it general. So I repeat: I propose we delete there have been through realistic; I propose we delete and are just beginning to learn through Part 50. CHAIRMAN WALLIS: I'd like to hear -- DR. APOSTOLAKIS: That makes it neutral, and it achieves the purpose that Tom mentioned. CHAIRMAN WALLIS: I'd like to hear what the rest of the committee has to say. I mean, we can have the paragraph which has the intent that I think Tom recognizes, which would be fixed in detail. How does the committee feel about -- DR. SEALE: I think the situation that Graham is addressing has to do more with the more usual case where the utilities are looking for reduction in regulatory burden, and that's where we're getting the pressure from that side. There is relatively modest pressure from the other side, and I think that's due to the fact that this first round of regulations that we are currently largely following generally have had large margins on the safe side, and so, there is lots of room for the utilities to push and actually get relief without a hell of a lot of relevant research being required, because the experience base that we've gained over the last 25 or 30 years of operation almost without exception support those reliefs. On the other hand, we haven't had a lot of pushing, because to date, anyway, there is not a large perception of an increased risk from the other stakeholders as a result of those changes, and I think maybe the point that it is relative to the existing regulatory situation that we have this pushing going on back and forth, but there is nothing going on yet except for the kinds of things that Dana's talking about which really are going to hit a reef of research need before you can budge one way or the other, but I think his comment about the general situation with regard to regulatory relief is right on. DR. APOSTOLAKIS: I think that the general comment is right on myself, and I think Dana's objection, the way I see it, is that there are inaccuracies the way it's stated. So with the deletion of a few lines and maybe modifying a couple words, I think you can still preserve the spirit of it without getting into trouble with details. CHAIRMAN WALLIS: This is where I wanted to turn, is whether the overall message is -- DR. APOSTOLAKIS: Yes, right. CHAIRMAN WALLIS: And if the details are to be fixed, we'll do that later, and it may be that those who didn't speak up, I want to give you an incentive to speak up, maybe given the job of fixing it. [Laughter.] DR. POWERS: I already fixed it, actually. CHAIRMAN WALLIS: If I were to give those who speak up the job of fixing, they might have -- DR. KRESS: Shack's already fixed it. DR. APOSTOLAKIS: Shack already fixed it. CHAIRMAN WALLIS: Okay; so, Shack has already fixed it. That's great. DR. SHACK: Well, you have my fix somewhere. CHAIRMAN WALLIS: Right. So enough people feel that the general idea is worthwhile, though. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Then I think we should move on. DR. APOSTOLAKIS: I would also delete the word quick on the line before last. CHAIRMAN WALLIS: We can easily delete things like that. MS. FEDERLINE: Could I offer -- I'm sorry. DR. APOSTOLAKIS: Go ahead. DR. KRESS: Yes. CHAIRMAN WALLIS: Please. MS. FEDERLINE: Could I offer a perspective? DR. KRESS: Yes, ma'am. MS. FEDERLINE: One sort of issue that we've had is in our minds trying to balance the role of research in probing for vulnerabilities; in other words, we're talking about, when we talk about there have been no significant events, a more reactive role for research; that once something happens, we are going to look at it. You know, if we look back through history, research had anticipated ATWS before it occurred. Is that the kind of role that you think research should have in looking ahead towards aging plants and risk-significance? This came across to us a little bit as a little reactive. It didn't emphasize the role that, you know, research is our protector; it sort of needs to be out there not only looking at new technologies but anticipating safety issues that haven't happened before. DR. POWERS: It writes a pain to that at the end. CHAIRMAN WALLIS: That happens, Margaret, later on when we're talking about the role of research, and if the external world is not sensitive to what you are sensitive to, maybe it doesn't fit in. MS. FEDERLINE: But I think it is. I think a big piece that's missing here is the international. You probably saw in the Inside NRC the Eurosafe conference, where the European regulators got together and were very concerned about the loss of leadership in the NRC research program and, you know, more or less saying, you know, it's a big concern that that's happening, and I think that's an external factor that, you know, the bigger world is saying why is NRC going this way? DR. POWERS: The last part of this document is going to complain about just that lack of leadership, and I'm going to complain that it's not necessarily bad. DR. APOSTOLAKIS: Well, let's wait until it comes up. DR. POWERS: In the past, NRC has been the leader on nearly everything; at one time on everything. And over the time, we've started seeing leadership exerted by other countries; first, the European Communities; now, we're seeing the Koreans, and I think we'll see the Japanese before very long asserting themselves more, and Graham worries about that in this document. I said gee, I'm not sure that's bad. MS. FEDERLINE: Well, I think if we look back, we did away with our thermohydraulics capability, and we did away with our fuels capability in the eighties, and it showed that we needed those capabilities, and we had to restore them. I mean, if we could predict what problems are going to come about, you know, we would be in good shape, but I was just suggesting that for the external context, you may want to introduce just a sentence or two of balance here to say, you know, others in the world feel differently. DR. APOSTOLAKIS: I think that's an excellent idea. Part of the external context is the international community. DR. POWERS: Sure. CHAIRMAN WALLIS: We'll think about that. DR. APOSTOLAKIS: Yes. MS. FEDERLINE: Thank you. CHAIRMAN WALLIS: Now, license renewal; is this paragraph okay in general intent and thrust? DR. APOSTOLAKIS: So when are these changes going to take place? CHAIRMAN WALLIS: Well, George, I don't know if you were here earlier. What we would like to do is go by this section-by-section -- DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: -- see if the overall thrust is right of the research programs -- DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: -- which the members would like to insert to make a point -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- or to take out because a point is not valid in general. DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: But not wordsmith it. Then, we'll go off the record later, maybe in a couple of hours, and we'll work through -- DR. APOSTOLAKIS: There is a fuzzy line there somewhere where something sounds like a wordsmithing effort but really isn't. So when I say delete the word quick, it's more than wordsmithing. CHAIRMAN WALLIS: I've already deleted it. DR. APOSTOLAKIS: But you are agreeable to receive comments -- CHAIRMAN WALLIS: I'm very agreeable. DR. APOSTOLAKIS: -- of this type, okay. CHAIRMAN WALLIS: It was put in to be removed. DR. APOSTOLAKIS: It's not just to make it read better; okay. CHAIRMAN WALLIS: No, that's right. DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: It's just better to remove it; I agree. How about license renewal? Is this a fair statement? DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Can we move on? Are you willing to have a statement about the interested public? DR. POWERS: Here, again, you are saying something has not happened. Yet, when I talk to Hub Miller, about the first thing he discusses with me is the help that he gets from interested communities throughout the Northeast on his regulatory work and the fact that he has a full-time publicist and that the major portion of their activities are in fact dealing with the media, so much so that they were going to have a news conference just as soon as we left to talk about what came up. He feels that he is getting a tremendous amount of media attention for his activities in the Northeast. CHAIRMAN WALLIS: Yes; again, it depends on what your evidence is. My evidence comes from reading transcripts of public meetings, and they are absolutely dominated by representatives from the industry. DR. APOSTOLAKIS: I agree with Graham, and, in fact, I'm disturbed when I see that the NRC staff held a public workshop with stakeholders, and this is what they told them, because the stakeholders are primarily industry. DR. POWERS: You're dealing with the first sentence, and I'm dealing with the second sentence in here. DR. APOSTOLAKIS: Ah. DR. POWERS: Nor has it been the focus of media attention, and I think there has been a lot of media attention focused on the NRC in the Northeast. I agree with Hub. I think it's been an area where he gets big strokes for having a program that can deal effectively with that much media attention, and I know it must be true, because I've been having phone calls from people up in Connecticut working for newspapers wanting to know about subjects. CHAIRMAN WALLIS: I think we could give up the media attention part, but don't you agree that it has not had to face legal challenges or serious critiques? One purpose of doing research is to be ready when someone challenges you with good arguments. DR. POWERS: I guess there is a legal challenge right now going on in connection with the license renewal activity. CHAIRMAN WALLIS: So maybe we could wordsmith, and perhaps media is -- leave the media out. We can leave the media out. MS. FEDERLINE: I think it's a procedural issue. DR. POWERS: It is. CHAIRMAN WALLIS: Generally, is the idea okay, though? DR. POWERS: Well, I was going to say legal challenges are also unlikely to be solved by research. CHAIRMAN WALLIS: Yes, but if you're in front of a judge, you'd better get your arguments right and don't get through with a judgment, engineering judgment. DR. POWERS: The next question is I think it is true that in any public forum or request for public comments that the predominant responders are those with a financial interest in responding, but I think it's also true that the previous chairman made major strides, steps, to facilitate the involvement of people that might -- you might say represented the public interest. So I wonder if there is a possibility of a veiled criticism of what I thought was a pretty good effort. I mean, she did come to this very room and hold a stakeholders meeting and certainly did Lochbaum was a major participant in those things. We've certainly had Lochbaum and other people attending here. CHAIRMAN WALLIS: I put this in because in discussing with one of the managers in research, he made this point about legal challenges, and I've been in a courtroom; you really have to get your arguments clear in a courtroom, yes. DR. APOSTOLAKIS: Graham, the reporter has a -- CHAIRMAN WALLIS: I'll move forward. I'm sorry; I sat back. And it's very different from being in front of your colleagues or even ACRS so -- let me finish editing this. The next paragraph is part of the message -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- that we're putting across. It's been discussed already. Is it okay? DR. APOSTOLAKIS: See, that's the point now. I think all of these paragraph lead to the sentence this technically undemanding environment has led to a decline. This is really where you're going with this. And at a certain level, you're right. I think what Dana is doing is really, he's scrutinizing every sentence you have in here, and, I mean, it should be accurate, of course, but I think by and large, you're right. The last year has not seen major technical demands. I mean, it depends what major is. Like after Three Mile Island, for example, that was a major thing. Now, that a newspaper in Connecticut is interested in something is not really a major issue, but somehow, this sentence ought to stand out somewhere. I'm coming back to my earlier comment about conclusions. Because this is really the essence of what you tried to say in the previous four paragraphs, that the technically undemanding environment has led to the decline in appreciation of the products of research. DR. KRESS: I think the -- sorry; I think the thing stands out myself. DR. POWERS: It's a question whether -- I mean, I can take a different view. I can take the view -- the alternative view is the NRC is correctly moving resources away from research so it can better reap the harvest from research it has sponsored in the past; the compelling issues have been resolved well enough to do that. That's an alternative view on the world. CHAIRMAN WALLIS: Is that the view of the committee? DR. POWERS: Well, the question is how do you prevent somebody from advancing that point of view? Because if he advances that point of view, he's not going to read any further. CHAIRMAN WALLIS: Well, you're describing the climate in a different way. DR. POWERS: And why is it not accurate? I think it's not accurate because the industry is continuing to change. CHAIRMAN WALLIS: The industry is far from static. DR. POWERS: That view is not reflected in this report. CHAIRMAN WALLIS: The next line says the nuclear industry is far from static. This is a lead-in to the next part. Here's the situation, and here's what we think about it, and is it going to stay this way? No, it's not. Is this -- this is act one, scene one. You build up a climate this is the way we are, and gee, whiz, it's not going to last; something is going to happen. DR. POWERS: That interpretation you give is not in the reading. If I don't have you here, I don't get that interpretation. DR. KRESS: That's certainly the way I interpreted it when I read it. CHAIRMAN WALLIS: I would think anyone who read a climate has grown up, like that stands out, that gee whiz, why does he say that? DR. POWERS: And that's what I said, and I think it's wrong. CHAIRMAN WALLIS: It's the shortest paragraph; it's the one that skipping through, you might read. DR. POWERS: Yes; and I read it as saying it's undemanding, and it should be; that they've done a whole lot of research in the past, and now, they've got to take advantage of it, and all of the compelling issues have been solved well enough for them to do this. DR. APOSTOLAKIS: But even if you interpret it that way, it doesn't matter, because the next paragraph says things are going to change. DR. BONACA: Well, why don't we take this technically undemanding environment as led? There is no need for that statement, because that brings in the judgmental that puts into question whether or not -- DR. APOSTOLAKIS: But it's true. DR. BONACA: I understand that, but I'm saying that you could go with the climate has grown up of confidence, blah, blah, blah; the situation is likely to persist for long, okay? The case for research is being made after that statement. CHAIRMAN WALLIS: I have a critique by Dana which says in the margin I think this is true. So at least, you must be ambivalent or maybe just arguing to make sure the arguments are robust. DR. POWERS: I'm not above doing that. [Laughter.] CHAIRMAN WALLIS: I think it's very appropriate that you do. I've heard enough to say we should move on. We can always edit that. But enough people felt this was the sort of statement that at least should be taken seriously and maybe is appropriate. Can we move on to the situation is unlikely to persist? Is this -- the overall intent of this paragraph sensible? DR. POWERS: The interesting thing that struck me about this paragraph is that it is a statement -- it contains a statement that the industry faces severe economic challenges, and I think just recently, I read an article in Business Week, it said that they are in fact making more money now than ever; and though they anticipated some severe challenges, they're really not coming to the -- things are moving much slower than people anticipated, and it's not going to disappear. From my own experience, I think across the board, I've seen that, that it is not the kind of make or break environment that other kinds of industries sometimes face. CHAIRMAN WALLIS: But Dana, when a billion dollar plant is sold for $100 million or $10 million -- DR. POWERS: Yes, that is happening. CHAIRMAN WALLIS: Is that a good situation for the industry? DR. POWERS: It may be the best situation that -- DR. SHACK: For the guy who bought it, it still is. DR. POWERS: It could be an excellent situation for them. CHAIRMAN WALLIS: But it must be desperation for the people who wanted to sell it. DR. POWERS: It may be down to the point that it's essentially zero worth on their books. DR. BONACA: The public should be alarmed about the situation. DR. POWERS: So $10 million is $10 million all to the good. CHAIRMAN WALLIS: And who's paying the bill? DR. SEALE: It's actually pocketed money. DR. BONACA: But now, they're paying -- DR. POWERS: It's a few of the bonuses for the year. DR. BONACA: Well, but -- CHAIRMAN WALLIS: Well, I read what people like Bob Uhrig report when they go to meetings, that the industry doesn't see an easy road ahead financially. Maybe we can change the wording a bit, but that -- DR. SEALE: Well, there's a little bit of -- DR. SHACK: Whether or not they need to, there are certainly pressures to reduce costs, if not for the challenge, for the fact that they like the profits that come from it. DR. POWERS: I wonder if there was ever a time in the nuclear industry that there wasn't pressures to reduce costs. DR. UHRIG: I think there was earlier on. DR. BARTON: For 10 years after TMI, it was spend, spend, spend, keep the regulator happy; keep the plant safer. DR. UHRIG: Just keep it operating. DR. BARTON: Yes, keep it operating. DR. KRESS: I think deregulation does put it in a new environment. I don't know how severe the challenge is. DR. POWERS: I think that kind of a statement, you can go along with; it is a new environment, and we really don't know how severe the challenges are going to be on that. CHAIRMAN WALLIS: Well, we could say faces challenges and remove things like severe economic; deregulation, don't we recognize there are some challenges in the future? DR. POWERS: Yes; I think we are assured that there will be challenges in the future. I don't think there's any future in which that's not been the case. DR. BONACA: That statement is true in the context of the nuclear industry within the electric utility industry. That means that still, nuclear has to demonstrate that it is competitive with respect to other means of generating electricity, and that's still a challenge, okay? So to some degree, that statement is true. DR. APOSTOLAKIS: That's true. DR. SEALE: Well, you've got the perception of the consequences of deregulation to help justify any decision you want to make. DR. UHRIG: The situation is that the structure of the industry is changing drastically. A lot of the utilities that have to be competitive are divesting themselves of their generating facilities, and those facilities will only operate as long as they can produce electricity that's competitive. Otherwise, it's just going to sit still there. DR. POWERS: I think if you can get across the idea that there is, seeing some changes, then, quite frankly, you're seeing groups of people saying that yes, they can operate plants effectively and are going out of their way to try to do that and other groups saying if I put the plants up as an income source, and we'll support that income source as long as it's competitive with other income sources. I mean, there are two different views. My own view is that the era of the one-plant utility is history. DR. UHRIG: I agree with that. CHAIRMAN WALLIS: True. DR. POWERS: And that actually is producing a less-aggressive industry, because as the utility becomes larger, it accommodates the regulations and engineers its way out of it, because it can; it has the resources that it can do so, because you amortize that over many plants. And you don't see the kinds of objections coming from Duke that you do from the one-plant utilities. DR. APOSTOLAKIS: They can afford to develop expertise; that's what you're saying. DR. UHRIG: But on the other hand, the percentage of cutback is not significantly different. Florida Power and Light went from 17,000 down to under 10,000 people as a utility; TVA went from, what, 45,000 to about 15,000. Those are big utilities. DR. BONACA: But the bottom line is that there is no bottom price for the cost of electricity when there are companies that just distribute. They would be on the open market, and on that basis, they can buy it so cheap that that puts this continuous pressure on any generating facility. DR. APOSTOLAKIS: Sure. DR. BONACA: That is really the environment that you have -- DR. APOSTOLAKIS: It's true. DR. BONACA: -- companies with a sizable number of customers that have no facilities. They will buy whatever at as cheap as it can be. In that environment, they're going to have -- DR. UHRIG: There are actually times of the day that utilities put electricity out there for nothing just to keep their plants operating at a minimum level so they have them when they need it. DR. POWERS: They almost never sell for nothing. They bid nothing. DR. APOSTOLAKIS: They bid nothing. DR. POWERS: But they almost never sell for nothing. DR. UHRIG: Okay. DR. POWERS: Yes. CHAIRMAN WALLIS: But do you think the industry is not static is a fair statement? And if so -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- is it going to lead to some needs for research? And is it going to be driven by licensees coming in with requests for things which have to be responded to? DR. KRESS: I think those are all true. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: So something like this paragraph would be okay to leave in? DR. SIEBER: Yes. CHAIRMAN WALLIS: It may be some fixing -- DR. APOSTOLAKIS: The whole paragraph is fine. CHAIRMAN WALLIS: -- and will be fixed. Now, the next one came from a different context. Originally, I was quoting from an NRC statement. DR. KRESS: I found that one of the most interesting paragraphs, by the way. CHAIRMAN WALLIS: And then, it got moved to here because it seemed to fit better at the suggestion of one of the members. DR. APOSTOLAKIS: I have a request: the first line, delete by no means mature they are. CHAIRMAN WALLIS: Yes; this was because we were talking about maturity in another context. DR. APOSTOLAKIS: Take that out: the regulations that govern this industry are essentially first generation. CHAIRMAN WALLIS: That's fine. DR. APOSTOLAKIS: That's pretty good. CHAIRMAN WALLIS: The mature came from a different -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: It will be removed. DR. POWERS: I am having difficulty following you. I do have questions about the last sentence in the previous paragraph on mixed oxide fuels. You're making some sort of a point, but it seems out of place to me: the public monies that will pay for anything needed by the regulators or by the licensees for the work for mixed oxide fuel; that's a DOE initiative. CHAIRMAN WALLIS: There is a need for research. Essentially, things are changing; fuels are changing, so they need to have a knowledge base. That's why that is in there. DR. POWERS: But there is no issue that I can think of that the NRC will not be in a better position to look at the licensee or the applicant and simply say they will get the information and share it with me. DR. APOSTOLAKIS: You mean the NRC knows enough already? CHAIRMAN WALLIS: Well, when we get to the other thing, we could, if you wish, argue about removing that sentence. DR. APOSTOLAKIS: No, I'm trying to understand, though, what Dana's point is. When does the NRC know enough on mixed-oxide fuels to ask the basic questions and have them go -- DR. POWERS: Sure; all you have to do is go over and ask the French what questions they're asking. DR. UHRIG: You think you're going to get an answer? DR. APOSTOLAKIS: What? DR. UHRIG: Are you likely to get an answer? DR. APOSTOLAKIS: These days, you would. DR. POWERS: See, the French have imposed a 30 gigawatt day-per-ton limit on mixed oxide fuel because of their technical questions. Now, later on in here, you're going to raise the questions about the grade of the plutonium, whether it's reactor grade or weapons grade and the big difference that makes. The fact is it's in the noise compared to the real questions you have about fuel. DR. APOSTOLAKIS: Well, wait a minute now. Haven't we argued in the past that we should have independent capability wherever it's needed? And now, you are telling me go ask the French. DR. POWERS: No, I'm telling them to go ask DOE. DR. SHACK: No, what he's arguing is that the DOE is one customer who says, you know, when you tell them he needs to bring information, we'll go get it. DR. POWERS: Yes. DR. SHACK: And they will be less likely to say, well, you know, I can't afford to do this. DR. APOSTOLAKIS: No, but still, don't we need independent capability? DR. POWERS: I think that's as we get in later into this document, I think that's really the fundamental issue. It's maybe more in the internal context section, but that's really the question right now. You have lots and lots of areas where the NRC gets something in from an applicant, and they review what he has, and they draw a judgment. We have a few areas where the NRC gets something in from an applicant, and they go out, and they independently evaluate the issues. Research is one of those areas where they spend a lot of time. CHAIRMAN WALLIS: But the context -- DR. POWERS: Mechanical behavior is another area where there has been a lot of independent evaluation. I have never understood how the agency decides when it will do one and when it will do the other one. If all you have to do is just read and evaluate what somebody sends to you, your knowledge level is probably at one. If you have to go out and independently evaluate something, then, your technical capabilities have to be quite different, and, in fact, there is more room for research in that second area. So it seems to me it's very important to understand why some areas get this independent evaluation and some areas don't, and I think that you're going to find that it has to do with personalities. Somewhere, somebody was aggressive and said I want to independently evaluate this, and in other areas, somebody somewhere was not. DR. SEALE: The likelihood of having more and more of those fairly complete scenarios is going to grow as we have more and more of these generating goliaths, because they'll have the structure to prepare those cases. DR. POWERS: I think that's a good chance. CHAIRMAN WALLIS: I'd like to get back to why this is in here. The purpose here was to identify some things going on in the world outside which will require that technical knowledge be generated somewhere in response, and this was why this was put in there, because there is a vertical move. We don't have a good technical basis. That was why it was put in there, without getting into all of the other details. But I think we are going to talk about fuels later in more detail. Now, this rather strange paragraph about regulations, do you think that belongs in here? DR. POWERS: I certainly will take off my clothes and paint myself blue on this one. CHAIRMAN WALLIS: And what does that mean? [Laughter.] DR. KRESS: I want to see it. CHAIRMAN WALLIS: Does that mean yes or no? DR. POWERS: It's sitting here, and it says they have never been redesigned but have been built over the years with some of the original rationale either forgotten or no longer consistent with new information and insight. I defy you to find somebody that does not feel that he understands the rationales in the regulations here, and if, in fact, we can see anything that's inconsistent with new information and insights, we are obligated under law to inform the commission immediately. CHAIRMAN WALLIS: Oh, dear; I see a real hodgepodge of stuff thrown together in a deterministic world guessing and trying and seeing what worked with no real basis logically whatsoever except that it worked, and risk-informing is supposed to clarify all this stuff. That's the great white hope. DR. POWERS: I think that's a nice position to take, a useful position to take, but I don't think you need to come in and say that NRC has forgotten -- CHAIRMAN WALLIS: Oh. DR. POWERS: -- what the rationale for its regulations are and that it is inconsistent with information that's now available. DR. APOSTOLAKIS: Put the period after over the years. You'll make your point. DR. KRESS: It just says some of the original rationale is forgotten. DR. APOSTOLAKIS: Huh? CHAIRMAN WALLIS: That's fine; that's fine. We'll moderate the language. DR. APOSTOLAKIS: Yes, yes. CHAIRMAN WALLIS: If the message is necessary. Is the message -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- worthwhile? DR. APOSTOLAKIS: I like it. CHAIRMAN WALLIS: So we'll remove some things which needn't be said at all, but they may be true. I was really impressed that no one could discover why it was there. DR. SEALE: 102 percent is -- DR. POWERS: That was the ECCS number. DR. KRESS: That's a new number. DR. SEALE: They were going to get as close as they could. DR. APOSTOLAKIS: Yes; the other -- okay, the other sentence on the easy parts, such as focusing inspections on the most risk-significant components have been done. That really goes against some of the positions we have taken regarding the maintenance rule and the validity of the importance measures. I'd be happier if you deleted it. DR. POWERS: Which one, George? DR. APOSTOLAKIS: The easy parts, such as focusing inspections on the most risk-significant components. I mean, if you know what the most risk-significant components are, why the hell did the ACRS raise hell with the maintenance rule paragraph A4 or 4A, and why did it bother the commission with all of these problems with the inappropriate measures if you already know what the risk-significant components are? I think it's too strong of a statement. DR. UHRIG: But it's still the low-hanging fruit, so to speak, to have a success. DR. APOSTOLAKIS: Yes, but maybe this is not the best example of that. I agree with the general statement that at the beginning, you can do a lot of things with immediate return without necessarily using sophisticated methods, but I think this particular example may create a problem for us. CHAIRMAN WALLIS: So we need a better example, but the overall message is okay, is it? DR. APOSTOLAKIS: The overall message, I like, yes. DR. KRESS: You could just say the easy parts have been done. DR. APOSTOLAKIS: Yes. DR. KRESS: Leave the example out. DR. APOSTOLAKIS: Yes; I mean, whenever you start something new, you always have immediate return very quickly. CHAIRMAN WALLIS: It's good to have examples, though. Otherwise, it's just an assertion. DR. KRESS: I know it. CHAIRMAN WALLIS: Well, probably, I've already put Kress and Apostolakis in the margin to fix this paragraph. DR. APOSTOLAKIS: Oh, is that what you're doing all this time? CHAIRMAN WALLIS: Yes, I'm writing down who's going to fix all the paragraphs. DR. APOSTOLAKIS: The purpose here is to critique. [Laughter.] CHAIRMAN WALLIS: You're doing a very good job, a very helpful job. Keep doing it. How about the consolidation part here? DR. APOSTOLAKIS: I think that is valuable. CHAIRMAN WALLIS: Consolidation -- DR. BONACA: Before you leave that, you have to say the NRC must be ready with sound technical arguments -- CHAIRMAN WALLIS: Well, yes. DR. BONACA: -- to counter possible legal challenges. It gives a sense of adversarial relations that shouldn't be there, in my mind. I think that you can phrase it by saying the NRC must be ready with sound technical arguments to justify those reductions on a technical basis, I mean. CHAIRMAN WALLIS: We're talking about external context. Who is the threat? Who might actually force the NRC to really get things straight? It could be a court. DR. BONACA: I understand that, but if I read these two paragraphs, these two phrases, if large changes are made, they may appear to certain public interest groups to permit successful regulation. And second, it brings it down only to a level of legalistic confrontation, and it seems to me the issue is a bigger one of saying that it would have to be a convincing technical basis and then -- CHAIRMAN WALLIS: Right. DR. SIEBER: I mean, they have to sustain a legal challenge if necessary. DR. SHACK: NRC has to convince itself -- DR. BONACA: Itself first and then -- DR. SHACK: To hell with the public there. DR. BONACA: -- and then, you know -- DR. APOSTOLAKIS: To hell with the public? DR. SIEBER: So it can sustain a legal challenge and forget about the last groups. DR. BONACA: And maybe that's exactly the words that Jack provided, okay? CHAIRMAN WALLIS: But the rumblings from the intervenors are that this risk-informing is just playing into the hands of some industry; it's going to make things easier, and they're throwing away safety. DR. KRESS: I think you leave that sentence in there, if large changes are made. Change the second sentence. CHAIRMAN WALLIS: Okay; so, we're going to be wordsmithing; this paragraph should survive, but it may be just a couple of sentences? DR. APOSTOLAKIS: Exactly. CHAIRMAN WALLIS: That's okay? DR. POWERS: I think you will find interest -- CHAIRMAN WALLIS: It may disappear even. DR. POWERS: -- interest groups being progressively isolated or moved out of the ability to contest. CHAIRMAN WALLIS: Or we could leave out the certain public interest groups completely; it may appear that there is a bit excessive -- there are ways to fix this. DR. SIEBER: I don't like that. CHAIRMAN WALLIS: Yes; right, so you get to do that as long as you -- DR. BONACA: The bottom line is that the NRC needs to have sound technical -- CHAIRMAN WALLIS: -- as long as you think something should be -- DR. BONACA: -- basis. DR. POWERS: What I think is going to happen is there are going to be changes in the rule, some of which will be reductions, many of which will be reductions, based on things that you cannot evaluate without having access to a technical capability that most people don't have. That will be a very, very intimidating sort of thing or a terrifying thing, because people will say gee, you know, there is just no way I can verify this person's statement that he has found out that this is unimportant to risk. It looks like it's important to me. We run into this problem in the fire area already, where everybody knows that the fire barrier penetration seals are important, and you come along and say yes, but from a risk perspective, it's not really necessary to go inspect every damn one of them. And yet, he says, you know, there's no way an individual can come in and say that penetration seal is risk-significant, and this other one over here is not. It's just not possible for him to do that. So you can't judge the wisdom of the actions, and I think that is going to become more and more of a problem is, you know, somebody that lives next door to a plant sees people doing things that he cannot evaluate; using some mysterious jargon that he has no link to, no availability to whatsoever and doing things that on the face of it look like they increase his level of risk. CHAIRMAN WALLIS: Can we move to the consolidation paragraph? Do you think that -- so, instead of dozens of utilities are going to end up with two or three major conglomerates? DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Is it not likely that they will be able to fund their own research more; they'll have more forceful presentations? DR. APOSTOLAKIS: The only sentence that perhaps does not belong there is the last one. I think you've made your point with the first two. CHAIRMAN WALLIS: I think I'll put that in as an afterthought to sort of say -- DR. APOSTOLAKIS: I know. CHAIRMAN WALLIS: -- why this is related to research. DR. APOSTOLAKIS: Well, I mean, you have said that the NRC must ensure that there is a knowledge and base and tools for technical evaluation keep ahead of the sophistication, because the last sentence -- CHAIRMAN WALLIS: It's redundant. DR. APOSTOLAKIS: -- to respond to proposals; oh, I don't know about that. CHAIRMAN WALLIS: If it's redundant, we can cut it out. DR. APOSTOLAKIS: You made your point. CHAIRMAN WALLIS: If you think the point is worth making. DR. APOSTOLAKIS: I think it is worth making, yes. CHAIRMAN WALLIS: Can we move to the next one here? DR. APOSTOLAKIS: Yes; I'm not sure what you mean by more enlightened regulation. [Laughter.] CHAIRMAN WALLIS: George, it's yours -- risk-informed -- DR. APOSTOLAKIS: Well, either you put i.e., risk-informed or just drop it, because enlightened may be offensive to people. CHAIRMAN WALLIS: How can it be offensive? DR. APOSTOLAKIS: To the unenlightened, yes. DR. KRESS: I would say the rewards from risk-informed regulatory -- CHAIRMAN WALLIS: Should we take it out? DR. APOSTOLAKIS: From risk-informed. CHAIRMAN WALLIS: Okay; we'll avoid -- DR. APOSTOLAKIS: And maybe put a few -- DR. POWERS: Let me ask you -- CHAIRMAN WALLIS: We know it's more enlightened, but we'll just call it what it is. DR. POWERS: Let me ask you about the word almost hostile. CHAIRMAN WALLIS: It's gone. DR. POWERS: It's gone? DR. APOSTOLAKIS: Why? I agree; it should be there. CHAIRMAN WALLIS: I thought it was something which would raise too many hackles. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: We should just leave it out. DR. POWERS: Sure because -- CHAIRMAN WALLIS: I think it's true. DR. POWERS: I mean, I can't go -- if I go and write down here your attitude, industry, is almost hostile, not one of them will say yes, you're right, it is almost hostile. They'll all say no, no, no; everybody is in favor of research. Now, we're not in favor of research that's not well-directed and well-focused, but we're not hostile to research in general. DR. APOSTOLAKIS: But on the other hand, we will try to shut down the San Antonio Research Center; we're going to give the Office of Research $3.50 for next year; other than that, we think research is great. Oh, come on. DR. POWERS: They don't have well-designed programs. DR. APOSTOLAKIS: Huh? DR. POWERS: They don't have well-designed and focused programs, but if they did, I would give them all the money they needed. DR. APOSTOLAKIS: There are all of these guidelines in the book; raise the son of a -- and then kill him. DR. POWERS: Of course. DR. APOSTOLAKIS: You're doing a great job, but I don't need you anymore. CHAIRMAN WALLIS: If necessary when it comes to edit -- George, if necessary, when it comes to editing, we will vote on hostile. DR. APOSTOLAKIS: I think hostile belongs there. There is a clear evidence that the industry would like the office to disappear tomorrow. DR. UHRIG: Because it's costing them money. DR. APOSTOLAKIS: I mean, let's not kid ourselves, and I think it's our chairman who keeps telling us we have to face the problems head on, as you plan to do on another issue at this meeting. So the major problem we're having with the Office of Research is that the industry, which is very influential these days, doesn't think it's worth a damn. DR. POWERS: I don't think that's -- DR. APOSTOLAKIS: And that's the truth. DR. POWERS: I don't think that's affected a dime going to the research organization one way or the other. DR. APOSTOLAKIS: But this is the problem here. CHAIRMAN WALLIS: So we're not arguing -- DR. APOSTOLAKIS: It's a hostile industry. CHAIRMAN WALLIS: We're not disagreeing about the truth of the word hostile; but we're arguing about the effectiveness of putting it in a report. DR. BONACA: Yes, hostile. DR. APOSTOLAKIS: This independent committee expresses its view in this last paragraph, which I think the commissioners should read. This goes only to the commissioners this time, right? Not to the Congress? Just the commission. CHAIRMAN WALLIS: But it's a public -- DR. APOSTOLAKIS: I think the commissioners should read this. CHAIRMAN WALLIS: But it's a public document. DR. SIEBER: Yes, but it's a public document. DR. APOSTOLAKIS: Well, we are writing, though, to the addressees. DR. POWERS: George, I don't think we have the capability to defend the word almost hostile. DR. APOSTOLAKIS: Well, if the rest of the sentence conveys that message, I'm willing to -- CHAIRMAN WALLIS: If you can think of a better word which conveys the meaning but is not such a hostile word -- [Laughter.] CHAIRMAN WALLIS: -- we'll try to use that. DR. APOSTOLAKIS: Does apprehensive fill the spirit of what we just said? CHAIRMAN WALLIS: I take it, George, you're in favor of saying something about industry in this -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- paragraph. DR. APOSTOLAKIS: Because it's the truth. I mean, they're trying to shut down -- DR. POWERS: Let me illustrate a contrary view to you, George. A couple of years ago, a young lady from EPRI had an idea on how she could do some research and help the industry out. EPRI didn't have any money in their budget, but they said sounds like a good idea; why don't you go approach the utilities about it? She was able to raise $10 million a year for 5 years in research monies. It's on top of what they gave to EPRI ordinarily; new money. So to say that the utilities are hostile to research is just wrong. I mean, they'll say -- DR. APOSTOLAKIS: No, but it says hostile view of NRC research. DR. POWERS: I think we will have a hard time justifying that, because they will simply come around and say look, how can you say we're hostile when, in fact, we have these cooperative programs? They just signed a memo of understanding with EPRI, between the Office of Research, and they say how can you say we're hostile? DR. APOSTOLAKIS: Well is there another word that's stronger than apprehensive and less strong than hostile? CHAIRMAN WALLIS: We'll look for something between insignificant and -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: We'll look for some word. DR. APOSTOLAKIS: Is there another word in there that -- apprehensive is too weak. DR. KRESS: Negative? Negative view? DR. APOSTOLAKIS: Negative might do it. DR. POWERS: I would -- whatever word you pick, I encourage you to make sure that when I get interviewed on this, I have some support for the word. DR. APOSTOLAKIS: I'm telling you: they tried to shut down a whole center. DR. POWERS: That's fine. DR. APOSTOLAKIS: Fine? DR. POWERS: Sure. DR. APOSTOLAKIS: One of the major issues this industry is facing is disposal of spent fuel, and the only research organization that's supporting the NRC to understand the phenomena there, and here is the industry trying to shut them down. I mean, don't tell me that's a friendly gesture. CHAIRMAN WALLIS: Anyone else have any opinion on this paragraph? DR. POWERS: Well, in the end, the paragraph comes along, and I interpret it as saying this seems to say the industry should do the research; isn't this what the commission is also saying? DR. UHRIG: No, it's not. CHAIRMAN WALLIS: I didn't intend to say that the commission -- DR. POWERS: The cost of failure to anticipate these issues and prepare for this resolution on a sound technical basis could be an extensive base while the requisite knowledge is acquired. CHAIRMAN WALLIS: Research by the NRC. DR. POWERS: So I said gee, if we don't have the knowledge necessary to pass this thing, it's going to be big delays, so I'd better invest in doing the research so I can present the knowledge along with my application. CHAIRMAN WALLIS: You better be done that NRC's done some research, because if you come up with something, and NRC isn't ready, then, they may have to do some research, and then, you have to wait. That's what it's supposed to say. DR. APOSTOLAKIS: In other words, you're paying the price later. That's what you're trying to say. DR. POWERS: I mean, somehow, that's a nice way of saying it, except I didn't read it that way. CHAIRMAN WALLIS: Well, we can wordsmith that. DR. POWERS: Is there some way to get that point across? CHAIRMAN WALLIS: Is there any argument that no such paragraph should exist? DR. POWERS: No. DR. APOSTOLAKIS: No. CHAIRMAN WALLIS: Okay; then, let's move on. DR. APOSTOLAKIS: Well, you have a break here scheduled. CHAIRMAN WALLIS: I was going to remind the committee that it's a long way to go, and we're not going fast enough. DR. BARTON: 7:00 is four hours away too. CHAIRMAN WALLIS: No, this is just the beginning. We go through it like this, and then, we come back, and we go through it -- DR. APOSTOLAKIS: Oh, my God. CHAIRMAN WALLIS: We are going to come up with a document, because we have half an hour tomorrow. DR. APOSTOLAKIS: Yes, but John pointed out that it's four hours to 7:00. CHAIRMAN WALLIS: Yes; in the ideal world, one does not work until 7:00. One works efficiently and effectively. DR. KRESS: Just let people take breaks when they want. DR. APOSTOLAKIS: If you ever run for chairman, I'm never voting for you. DR. KRESS: Let individuals take breaks. [Laughter.] DR. APOSTOLAKIS: I just made up my mind. [Laughter.] CHAIRMAN WALLIS: Well, I think you may have done some of the easier part. DR. APOSTOLAKIS: I think the most difficult part is the first two sections. CHAIRMAN WALLIS: The next part, internal context. DR. APOSTOLAKIS: That's difficult, too, but after that, it should go faster. DR. SHACK: Famous last words. CHAIRMAN WALLIS: The internal context; I've been made very aware that RES works in an internal context in the NRC and that there are pressures from all sides of all sorts and that we have to say something about that. I've been trying to find out for myself how the NRC as a body did research; and I was astonished to read things like annual reports; there was almost no mention of research whatsoever, and there was no mention of the need to do research or what research was for. So I felt I had to say something about it; it may not be appropriate. I felt less comfortable with this section. DR. APOSTOLAKIS: I understand what you're trying to do here. You're saying there is little acknowledgement that the significant output of a major part of the NRC has improved knowledge, and then, you complain that the researcher's role is not appreciated. What would you like them to do, though? When they draft a regulatory guide, to have a footnote that says boy, our office did this? CHAIRMAN WALLIS: In saying what they do, they should not only say we made all of these regulations; we've enforced all this stuff. We've also identified areas where we need to know more, and we are -- DR. APOSTOLAKIS: Now, where would they put this? CHAIRMAN WALLIS: In the report, because it's part of their job. DR. APOSTOLAKIS: Which documents are you referring to? Regulatory guides can't say that. CHAIRMAN WALLIS: No, no, no, the annual report which says what we did this year. It's their statement; their raison d'etre. DR. APOSTOLAKIS: The annual report from where? CHAIRMAN WALLIS: The NRC. DR. POWERS: NRC's annual report, the report, and there's a whole section in it that's titled research. DR. UHRIG: All of two pages. DR. POWERS: The particular one he looked at, it's a little less than one page. [Laughter.] DR. APOSTOLAKIS: No, that report, I agree with; it's the rest of it that there is no appreciation from other offices and all that, the question is what do you want them to do? DR. POWERS: And since it contradicts what he says earlier in the document, that, too is a problem. And similarly, in the annual report, I think the agency is under some pressure to claim it's got its act together, and say and here is this long inventory of things that we don't know about is probably difficult for them to say. Even if they would admit it in private to you, I think they would probably not like to write it down. CHAIRMAN WALLIS: I don't think it's -- as I say, to give assurance that they're on top of things, they would say we've made all of these decisions; we're going to have these decisions to make in the future; in order to make those decisions, we're doing this research because we need to get this, this and this done before we can make those decisions. DR. APOSTOLAKIS: It's a subtle way of promoting the Office of Research, and I agree with it. I agree. CHAIRMAN WALLIS: Well, I don't know it's promoting. I think -- I'm not sure it is promoting. If there is no reason for doing research, it shouldn't be done, but at least it should realize why it's doing research, not sort of be dragged into it by some other forces. The management of the agency should realize that there is an appropriate role for research. Now, maybe it's 1 percent of the budget; maybe it's 50 percent, but there is an appropriate role, and it needs to be on top of what that role is. That's what I'm trying to say, and I probably don't say it right but -- DR. POWERS: Well, I mean, part of the -- the difficulty I have in the first paragraph is again, I can come to another conclusion; I can argue that the NRC spent a lot of money in the past to build this knowledge base that you speak of, and it succeeded. Now, it can scale back since it only needs to maintain; it doesn't have to build anymore, and if licensees wanted to move beyond this plant base, they are the ones who have to provide the information. [Pause.] CHAIRMAN WALLIS: Well, I was really struck by what I call absolute naivete, that all you have to do is set some goals and some general terms and everything would take care of itself, and if you look at the annual report, it says reduce unnecessary -- but they're going to do that by meeting with the stakeholders and making decisions. Well, that's just sitting around discussing. You've got to have a good technical reason for saying why this burden is necessary and why you can relax it, and that's what I'm trying to say: you can't just debate with the stakeholders. DR. APOSTOLAKIS: You're right; you're right. That's why I think we need the short paragraph with the conclusion, but it's too long. CHAIRMAN WALLIS: I think you could cut this section down, but I'd like to know what is worth saying here. DR. APOSTOLAKIS: I like that point; I don't like the repetition of the observations from the 1998 report with the implication that the staff hasn't done much; I mean, they are trying to develop a systematic process for designing and engineering the research program. You may have objections to some of the details, but they are trying, so to repeat these, there is an implication that they are not doing everything. CHAIRMAN WALLIS: Trying is not good enough. DR. APOSTOLAKIS: Well, look: you have to start with something. Now, with the ACRS agrees with 100 percent of what you're doing is a separate issue. But the implication here is that these three bullets still apply, and I don't agree with that. CHAIRMAN WALLIS: I think my view -- we'll try to hear from more people -- is that if we could make the agency do this, if we could make, say, the new chair say we are going to make sure that these bullets actually are implemented -- DR. APOSTOLAKIS: Yes, but again, you don't want to -- CHAIRMAN WALLIS: -- it would be a wonderful thing. DR. APOSTOLAKIS: But Margaret, I think correctly, pointed out earlier that the staff has been responsive to our comments. So you don't want to create the impression that we wrote something in 1998, and we have seen the need to repeat it verbatim without any comment. That implies that they have completely ignored us, and that's not true. That doesn't mean you agree with everything they're doing, but that's not true. From the management point of view, I think this is not right. CHAIRMAN WALLIS: Should I ask for volunteers to suggest which parts of this section are worthy of inclusion in the report? DR. POWERS: Well, I certainly sent you the note on -- oh, God, this is going to be near impossible -- on my page 8, where you start saying however, there is no way to assess the value or prioritize them in the absence of connections; the front of the document answers the question such as, et cetera; that's where I would start, and I would eliminate all of the diatribe. DR. APOSTOLAKIS: Now, which paragraph is that? DR. POWERS: I don't have numbers on my paragraphs. DR. SHACK: It's the middle of page 4, from page 59; then, the second sentence is -- DR. APOSTOLAKIS: Oh, okay, okay. DR. POWERS: It's where you guys -- is this issue delaying or otherwise restricting the meeting of performance goals; what specific results will improve definite measures by which performance goals are met and those things. CHAIRMAN WALLIS: Don't you see any need to say things about reducing burden isn't just a matter of discussion; you've got to explain why it can now be reduced? DR. POWERS: Sure. CHAIRMAN WALLIS: I thought those were important points. DR. APOSTOLAKIS: It is an important point. CHAIRMAN WALLIS: Diatribe is a hostile word. I mean, this was supposed to be -- DR. POWERS: I mean, when you come in here and say look: I read their 1999 performance plan, and it sucked, but they fixed it all in 2000 and 2001 plans, but I'm going to still beat them up on their 1999 plans, that strikes me as really looking for something to beat on people with. CHAIRMAN WALLIS: I don't know about this beating up. That's sort of in the wrong language. All of this criticism is supposed to be helpful to the agency: say look here; you may not realize it, but when you write your annual report, you really don't say anything about why you do research, and that seems to me is important. I would love to find a couple of people who would rewrite this section without having to -- and I would like some guidance from the members about which parts have some value. CHAIRMAN WALLIS: Dana likes the part about the three bullets, the three closely -- DR. APOSTOLAKIS: I don't like the other three. CHAIRMAN WALLIS: And George doesn't like repeating 1998. How about some of these things about you can't just say we're going to meet with the stakeholders and figure out how -- DR. APOSTOLAKIS: That is correct. CHAIRMAN WALLIS: I mean, we've got to do some real work. DR. APOSTOLAKIS: I'm with you. CHAIRMAN WALLIS: I would fight for that to be in there. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: But maybe we don't need say that much now up front. How about the first paragraph? Is that a reasonable statement of why they do research? DR. KRESS: Yes. DR. APOSTOLAKIS: Yes; I have no problem with that. CHAIRMAN WALLIS: So the first one, maybe, is okay. And then, maybe we can cross the next two to small or zero. DR. KRESS: But you all want to make this -- DR. UHRIG: I think it's pertinent. I think that -- CHAIRMAN WALLIS: Have crossed? I think we need two people. DR. KRESS: I'll help with that. CHAIRMAN WALLIS: Will someone help Tom do this? Or do you want to do the whole thing? DR. KRESS: I don't care. DR. UHRIG: I'll work with him. DR. POWERS: You don't have -- CHAIRMAN WALLIS: I think you need guidance from the members, though, Bob. DR. POWERS: I have these comments -- DR. KRESS: I would like to have -- CHAIRMAN WALLIS: I'll give you that. DR. APOSTOLAKIS: Dr. Uhrig just volunteered. There is one word I would like to delete, though. In the first full paragraph on page 4, 2, 4, 5 lines down, clearly, a great deal of hard work and analysis; do you see that? CHAIRMAN WALLIS: Yes. DR. APOSTOLAKIS: Delete hard. CHAIRMAN WALLIS: Ah. [Laughter.] DR. POWERS: I've finally figured out where on the document -- all you need to do is sit down and talk about things with stakeholders is. I'm just having a hard time following this. And in there, I commented. On the other hand, we do have 3,000 reactor-years of experience, and we really haven't killed anybody in that period of time. All we've done is melt a little fuel in one plant. DR. APOSTOLAKIS: Yes but -- DR. POWERS: That's not a bad basis -- DR. APOSTOLAKIS: No. DR. POWERS: To say yes, let's sit down and talk about what kinds of things have contributed to that good track record and what kinds of things haven't without doing any more research. DR. APOSTOLAKIS: On page 5, we attack this. DR. POWERS: Page 5, it's hopeless for me on page 5. I'm on page 8 right here. DR. APOSTOLAKIS: Oh; on page 8? DR. POWERS: My page numbering and yours aren't the same. DR. APOSTOLAKIS: On the evolving role of research; that section. There is a paragraph that attacks this idea. DR. POWERS: Well, and my point is I think you've got to be careful about attacking this, because -- DR. APOSTOLAKIS: But I think, though -- DR. POWERS: -- you do have a long, 3,000 yesterday of operating experience is a non-trivial track record. DR. APOSTOLAKIS: It's non-trivial, but on the other hand, I object to calling it long. When somebody tells me that his core damage frequency, 5 x 10-5, 3,000 years, I'm sorry, doesn't do that. First of all, I will also question whether it's 3,000, because our plants here are unique. CHAIRMAN WALLIS: It's a non-static industry. DR. APOSTOLAKIS: Can you really take everybody's experience? Can you take the reactors and everything else? DR. POWERS: And my argument is it's long enough -- DR. APOSTOLAKIS: I don't know that. DR. POWERS: Even on an individual plant, it's long enough to say yes, some of the things that we worry about in risk assessments really are rare events, and it really is important that we not think that these plants are right on the verge of melting down when you look at them cross-wise. DR. APOSTOLAKIS: They are not on the verge of melting down. On the other hand, the evidence is not just what he mentioned, the partial core melt. The evidence is that you also had Wolf Creek; you had -- DR. POWERS: And everything recovered. CHAIRMAN WALLIS: Excuse me; you're on page -- DR. POWERS: The system responded the way it was supposed to. It worked. CHAIRMAN WALLIS: You're on page 5? DR. SIEBER: The two instances where you get into these unknowns is when you try to do something different or the plants get older. DR. APOSTOLAKIS: I just don't think you have strong enough effort to get in a room and just decide what to do. CHAIRMAN WALLIS: Gentlemen, you're on page 5; I want to finish up page 3 and 4, and where I think we have agreed is -- DR. SHACK: Yes, but, I mean my objection is nobody does that. I mean, that is part of my problem with something, you know, Graham talks about, you know, you do -- you do regulation by judgment calls. CHAIRMAN WALLIS: Are you on pages 3 and 4? DR. POWERS: Yes, you do. DR. SHACK: You use judgment, but, you know, I don't -- you know -- DR. APOSTOLAKIS: It's not the seat of judgment. DR. SHACK: And, you know, it's not as though you're just -- DR. SIEBER: Extractions. DR. SHACK: -- winging it here, you know; yes, all the decisions involve engineering judgment, and they will, you know, for the foreseeable future involve engineering judgment. DR. APOSTOLAKIS: I think, though, that maybe he overstated that point, but his argument that there is a need for work and analysis -- DR. SHACK: I think there is an overuse of the word rational. DR. APOSTOLAKIS: -- I think is a valid -- DR. SHACK: You know, as though all of the other decisions are made irrationally. DR. APOSTOLAKIS: No, but I think -- I get the impression that a lot of the times, the industry and the staff get together to resolve an issue, and they start with the assumption that the issue can be resolved with the existing methods, and I think that's where he's attacking. DR. SHACK: Yes. DR. APOSTOLAKIS: You're wanting for risk importance? Sure; we'll use these, I think. Use the PRA; use this. Well, the PRA is not very good in certain things. You have done your transition risk; you have done your low-power shutdown. And somehow, these issues do not seem to be significant when there is a negotiation as to what to do. DR. SHACK: Well, I mean, there are two ways to do that. One, you work on the tools; the other one, you pick the problems you can solve. DR. APOSTOLAKIS: That is correct; but we have a maintenance rule where we don't have the tools. DR. KRESS: I think the reason where -- DR. APOSTOLAKIS: I cannot figure out the risk-significance under some weird configuration that Mario and John can come up with. DR. BARTON: That's what it's for. DR. POWERS: Yes, we do. [Laughter.] DR. POWERS: But if it's something that you've done 600 times, and it's probably not something that you need to have verbatim procedures for. DR. SHACK: It's also a question of if you know what the risk-significance is; if you realize that you have to calculate the risk-significance of that, you may well be able to do it; you just don't happen to have done it yet. I mean, I would think they would argue that, you know, there are tools for doing this; you know, we didn't ask them to do the impossible; we only asked them to evaluate the risk in these configurations. DR. APOSTOLAKIS: That's right. DR. KRESS: Except in ISI and IST, we ask them to do the impossible. You can't calculate the risk of those things. DR. SHACK: Well, we didn't ask them to. We asked them to do relative rankings. DR. POWERS: We can't even calculate the risk of our QA programs. DR. SHACK: That's right; that's for sure. DR. POWERS: Which probably are risky. CHAIRMAN WALLIS: I'm going to bang my gavel in a minute. Where I understand we are on the internal context is that something like the first paragraph can remain and that something about the work -- there needs to be some work; you can't just wave your wand and reduce burdens. You need to say something about the research being tied into goals, and then, we can shorten this whole thing by about half. Yes? MS. MITCHELL: I just wanted to say that you have three questions on what is my page 4, Margaret's page 4. It says is this issue delaying or otherwise restricting the meeting of the performance goals? That's the first one. The first two questions were probably answered fairly specifically for the 2001 budget and will be answered more specifically for the 2002. I don't think that anybody is really looking at what is the cost of not having the knowledge, but there may be other questions that are somewhat related to that in a strained way, but I don't think they're going to get a cost number at all, but the document that you referenced, the performance plan, is a much higher level, and you would never see in the performance plan enough information to allow you to know that the staff really did make a big attempt to answer at least two of those questions and others. It's much too high level a document. That document, the performance plan, goes to the Congress. CHAIRMAN WALLIS: That's where you need justification, first of all. MS. MITCHELL: It would be a document that would be many inches thick instead of a document that is only a quarter of an inch thick. DR. KRESS: I think what she's saying is basing an opinion and judgment based on just the performance plan may be a mistake. MS. MITCHELL: If you want to see the justification for why are you doing a specific piece of research -- CHAIRMAN WALLIS: The problem I see just in the agency is research being justified among the major management of the agency and then externally justifying it to Congress. You're never going to get that by saying you've got to look at the details. You've got to say come up front with some very good arguments. You can't just say wait until you see the details. MS. MITCHELL: But the document, the pieces of individual research that are discussed in the 2001 performance plan are just sort of listed. If you wanted to justify each and every one of them, it would be a huge task. If you wanted to show the answers to the six or seven questions that they really did try to answer for each one in order to establish that we should work on techniques for underwater welding, it would be just a lot of detail in there, too much, probably for justification to Congress. DR. BONACA: Although, I mean, I must say that, you know, I made some comments before regarding strategy plan, and that's exactly what will take you from high level goals. That's what corporations do; down to what you're going to do today and tomorrow, and I don't see that the research has ever done that, in part I mean -- MS. MITCHELL: Well, they tried -- the research tried to do that for the 2001 performance plan. They had the first attempt to answer questions like one and two; I said they're not going to get costs. They didn't get anything to do with costs. But questions like one and two and others -- DR. BONACA: Yes, but for example, I would have liked to see for research and maybe it's already written but an evaluation of the external context they're living with; the evaluation of the internal context they're living with. MS. MITCHELL: The internal what? DR. BONACA: Context. Again, and issues of that type and then a stakeholder evaluation that includes all the other parts of the NRC in which the NRC has direct input as well as the public; the industry; and then, from that analysis, you really come down to the link between your goals there and specific activities. I haven't seen that. To some degree in this discussion and the other reports put together, it is attempting to almost put a structure to the thought process that should go behind that plan, and the NRC hasn't done that. MS. MITCHELL: Well, they didn't do it for 2001. The 2001 budget went to the Congress a year ago. They're attempting to do that for the 2002 budget, which is due in like February, and they're working on it in a way that is more nearly what you want in that instead of saying here's research, research attempted to do this for 2001; nobody else did. They've changed it to the 2002 budget to arenas, so we have the reactor arena; we have the waste decommissioning and transportation, I think it is; we have materials, and we have international programs, and they are looking at them all together. So there are strategic goals; there are performance goals; there are strategies, and supposedly, each individual work item like underwater welding or reactor inspection will have a tie and answer questions such as one and two. DR. BONACA: Yes; I understand that. I just want to make the point about that, because there are two things that I have not seen ever discussed in the NRC plan. One is coordination before the horizon for research; now, we may all assume that we understand it. A fundamental element of research is horizon. What are you looking for? What are you trying to do? If you're making just reactive research that addresses the problem of the moment, you're going to say that, and for that, you set your goal in a way and explain why you don't go beyond a certain horizon. That's one issue that I haven't seen, and I'm not sure they're doing it. But the other one is stakeholders, because on some issues, for example the use of this information or how do you modify regulation, how do we risk-inform information, I think that right now, the commission and NEI have different objectives. I really am convinced of that. While the commission wants to risk-inform the regulations, NEI says, well, do what you want; then, I'll tell you what I am going to pick and choose from it, and if I don't like it, if it costs me money, I'm not going to go along. So to me, that's another example where the stakeholders have not been pulled together in recognition of the industry as a stakeholder clearly, and certainly, the public hasn't been pulled in; so, just two examples of where I don't think they're going to do that, but at least some comment, Graham, in your report that goes about what it should be doing; for example, when you're saying that the leadership of the committee should be outside of research, which goes right to this point of putting the stakeholders in some role of leadership, and I was supportive of that, by the way. CHAIRMAN WALLIS: I want to move on to the next section. I think what we've agreed, and Tom Kress has volunteered to try to rewrite this section, consulting with other members, particularly Uhrig, Bonaca, Powers, those who have had opinions; okay, can we move on? The evolving world of research: comments on the first paragraph, history? DR. POWERS: The only comment I make is that Chernobyl just really didn't have any impact here. CHAIRMAN WALLIS: I didn't hear. DR. POWERS: Chernobyl didn't have any impact on the programs here. CHAIRMAN WALLIS: Had no impact on the programs? DR. UHRIG: On the research programs. DR. KRESS: Not any that I can see. DR. POWERS: Absolutely none. DR. UHRIG: It had a lot of impact on other things but not the research. DR. POWERS: I don't think it had impact on much. DR. UHRIG: Well, there's been a rather comprehensive review of any graphite-based reactors. DR. KRESS: Oh, yes but -- DR. POWERS: Since there was a total of one in the entire country -- [Laughter.] DR. KRESS: They also went, you know, to look at the research and activities -- DR. SEALE: It screwed up DOE pretty good. DR. KRESS: -- and research into accidents and -- CHAIRMAN WALLIS: So we could remove Chernobyl. DR. POWERS: Yes. CHAIRMAN WALLIS: That's an editorial thing, remove Chernobyl, but it's okay to say something like paragraph one. Is it okay to say today, the situation is different, paragraph two? There's a mature industry in place; this is an NRC statement. I felt a need to challenge the statement. DR. POWERS: Yes; I think that's an incorrect statement. I mean, they say that, and it's just wrong. CHAIRMAN WALLIS: Okay so -- DR. POWERS: It's not wrong; it's just not useful. DR. UHRIG: Yes. DR. POWERS: It is a mature industry, but it's one that's continually changing, and it's very much alive. DR. KRESS: Every time I listen to NEI, I think it's an immature industry. CHAIRMAN WALLIS: Well, I'm very nervous about relying on industry to do the research. DR. KRESS: I'm quite nervous about that, too. DR. BONACA: In fact, you know, I don't agree with the statement that says research in the public interest, because they're not doing it in the public interest at all. I mean, indirectly, but, for example, research on fuel they're making is mostly because they want to be able to run the fuel reliably, and so, therefore, the goal may coincide with the one of protection of the public, but in reality, the whole goal is you want to run the fuel so you don't have to open up your reactor in the middle of a cycle, and you can run a long cycle. I'm not sure that's in the public interest. DR. POWERS: It's the next paragraph. CHAIRMAN WALLIS: Next paragraph. DR. POWERS: Is where I think -- CHAIRMAN WALLIS: Is worth talking about. DR. POWERS: Yes, because I think this gets to the heart of the issue here. I mean, this is where this interesting issue of whether the NRC should independently investigate something or passively read something comes to the fore. And I think it's a question we need to address explicitly, because I don't know why; I mean, it says NRC cannot be passive and merely scan the supplied documentation to see if there are any obvious mistakes. Why not? Why is it that they can't do that? And then, it goes on: in many cases, a proper view can only be done by professionals who are actively engaged in using tools that are equally or more sophisticated than those developed in the industry, and I come along, and I see -- I don't know why that is. CHAIRMAN WALLIS: Well, this is true in spades in thermohydraulics. Unless you have developed these tools, unless you know the weaknesses, unless you know how you can cheat, you can't tell when someone else is doing it. DR. POWERS: But that doesn't mean that you need to be working with tools that are equally or more sophisticated. You just have to understand the tools that they're using. DR. BONACA: In some cases; for example, in PRA, some of the assumptions that undermine the value of the PRAs today. CHAIRMAN WALLIS: Well, maybe they don't have to be more sophisticated. I would like them to be. DR. POWERS: It seems to me -- CHAIRMAN WALLIS: In the way the professor grades the student; the professor usually claims to be a little more sophisticated. DR. POWERS: Yes, but the fact of the matter is that this is not a grading exercise; this is an adult exercise. It's not a parent or a student-teacher exercise. I think I'm willing to agree that there are two categories of issues: those where the NRC merely has to review and those where it has to independently review. They exist. I don't know how to separate between them, and I think sooner or later, we're going to have to figure out how to separate between them. I'm willing to agree that those two exist. DR. KRESS: Yes, but if they do exist, then, the need for the sophistication and the tools exists. DR. POWERS: Yes. DR. KRESS: So it doesn't -- DR. POWERS: No, it doesn't -- DR. KRESS: Yes. DR. POWERS: I'm willing to say that the two exist, and I'm willing to say I don't understand when one and not the other. DR. KRESS: I don't either. DR. POWERS: But clearly, it has an enormous impact on your research program, because when you had the independent, then, I think you do want tools that are equally or more sophisticated. You want to have them on a very firm foundation and well-validated. And I'm willing to go further and say and until research answers this question, they're going to have troubles justifying the research budget, because everyone is going to want to move the ones that are expensive and require independent validation into the review category. In other words, this paragraph is very seminal, and I think it's where we make our first hard impact on telling them here is, research, something that you need to do that you haven't done up to now. CHAIRMAN WALLIS: I thought it was wonderful when we got NRR to say we will actually get in the thermohydraulic code; some will exercise them ourselves and find out how they work. I thought that was a wonderful development, long overdue. Otherwise, they just present the results, and they want to show you. DR. POWERS: And in some places, that's fine. There's nothing wrong with that. There are lots of things that I think the NRC gets in, looks at, reads the words that the applicant has written down, thinks about them a little bit -- CHAIRMAN WALLIS: You think, Dana, this is not generally true but true in some areas? DR. SHACK: You know, you don't redo the piping analysis, for example. CHAIRMAN WALLIS: Because it's a really mature -- DR. SHACK: You tend to believe the stress analysis; you know, you're much more skeptical about the thermohydraulics analysis. CHAIRMAN WALLIS: So we need to say something perhaps about what these many cases may be. DR. KRESS: The trouble is the stress analysis, they're all done basically the same way. It's a couple of codes. Thermohydraulics analysis, there is a code for every plan out there. DR. POWERS: And maybe you have found the criterion of how we decide when one and the other, but it's clear to me that until we understand when one and when the other that the one that's taking all of the resources right now is going to be continuously under pressure to become like the one that doesn't take much resources, okay? So if you want to avoid research coming in here with long faces about how their budget has been killed and once and again, you've got to have this decision made, this criterion that everybody agrees to where an independent confirmatory analysis will be done as opposed to a review and approval type analysis. CHAIRMAN WALLIS: So could we fix this up? It says here in many cases, a proper review can't even be done. Maybe rather than think so vague, we should talk about what those cases are, when it's -- the technology that's peculiar to the nuclear industry, and it doesn't have a broad base or when it's something that is an immature technology. DR. POWERS: I'm reluctant to define them, because I think somebody has to think more about it, but I would say look: we've looked at this thing, and we know that there are things that the NRC reviews just to assess what the licensee has done, and we know that there are things that they have -- they look at and independently confirm, and you can give examples of each and say what we have never seen is a criterion for why you pick one and not the other. CHAIRMAN WALLIS: Well, maybe we can say a criterion needs to be developed. We do say in many cases, which is a nice, vague statement. Maybe we need to add something about the need to develop a criterion for when this needs to be done. DR. POWERS: I mean, there's got to be an explicit criterion that everybody agrees to. CHAIRMAN WALLIS: Can you draft one? DR. POWERS: I can certainly try, because I think that -- CHAIRMAN WALLIS: A couple of sentences there? DR. POWERS: I think this speaks to this issue where the research struggled for a couple of years on core capabilities, because I think it's the core capabilities are going to be those areas where you say I am going to do an independent analysis, using my own tools, my own techniques, to verify what the applicant has said, and those are going to be core capabilities, and when the funding falls to hurt those, you're hurting a principle that presumably, everybody has agreed to. CHAIRMAN WALLIS: Let me suggest a criterion is uncertainty. DR. POWERS: Yes; we don't know what it is. CHAIRMAN WALLIS: Thermohydraulics has uncertainties in it; then, you need to be technically competent to evaluate. If it's something which is stresses in steel, it's probably standard. DR. UHRIG: The only difference in a stress analysis is the length of the stick. [Laughter.] DR. UHRIG: Everybody uses the same basic analysis. DR. POWERS: In thermohydraulics? DR. UHRIG: No, in stress analysis. DR. POWERS: Oh, in stress analysis. CHAIRMAN WALLIS: Okay; so, Dana is going to draft a couple of really cogent sentences about criteria for when they need this. We would retain some statement in this paragraph like what's there; is that okay? DR. KRESS: Good. DR. APOSTOLAKIS: Yes; I agree with that. CHAIRMAN WALLIS: Do you agree with this really patsy statement about questioning if it's wise to rely over much on industry and conduct research in the public interest? DR. POWERS: Do I have that sentences someplace? CHAIRMAN WALLIS: Yes, you do. DR. SHACK: It's the next paragraph. CHAIRMAN WALLIS: It's in the middle of page 5. DR. POWERS: The next paragraph. DR. BONACA: Yes; I just object to the words in the public interest. DR. POWERS: Well, I guess I -- CHAIRMAN WALLIS: Okay. DR. POWERS: -- don't understand where industry is doing research in the public interest. DR. BONACA: Right. DR. UHRIG: Then take that out. DR. BONACA: For example, they have two major programs right now: a robust fuel and the equivalent of, you know, the BWR VIP. DR. APOSTOLAKIS: Those two programs, yes, they have certainly public interest ultimately. CHAIRMAN WALLIS: So would you put say conduct the definitive research or something and leave out in the public industry? DR. BONACA: Industry research. DR. POWERS: And I don't -- DR. UHRIG: Their own research. CHAIRMAN WALLIS: They've got to do some research. DR. POWERS: It's just wise to rely over much on industry research, period. DR. UHRIG: Period. DR. SEALE: Results of industry. DR. POWERS: The question is -- okay, I think everybody will agree it is not wise to rely over much on anything; by definition, you would think it's not wise to do that. I would not be very anxious -- CHAIRMAN WALLIS: As the sole source of research? DR. POWERS: -- to question the integrity of industry research in any broad fashion. Specific items, I'm willing to question, but as a general class, no; I think that their results are as good as the results are, and there's no need to say anything about that. The question is this criteria, and it comes up again here in this paragraph: the criteria of when the NRC thinks that in the name of adequate assurance of public health and safety, it must do an independent analysis as opposed to just reviewing the analysis done by the applicant. CHAIRMAN WALLIS: Well maybe, Dana, you should work on these two paragraphs. DR. BONACA: But what I want to say is that it is not wholly an issue of research, however. There is a bigger issue; for example -- I'll give you an example. RELAP 5 was developed, and many of the staff believe that they were the only one to use RELAP 5 because it was supposed to be a verification tool of analysis. Then, licensees began to use it, and the NRC allowed it to happen. There were submittals made with RELAP 5 and modified RELAP 5, which has really eliminated the ability of the staff to perform independent verification with the only tool they had, which was RELAP 5. In part, I think COBATRAK became something of that type, too; not as much. So in part, I think it's also, you know, the strategy of the staff. DR. POWERS: Well, I think you touch upon another issue, and it's one we need to get into as well, that okay, if the tool I have for doing an analysis, and let's just take ABACUS, because that's kind of a universal code used by everybody, if I have ABACUS as a regulator, and you have ABACUS as a licensee, and we do the analyses, is that independent verification or confirmation of the analyses or not? And I certainly tend to be of the opinion, yes, it is, but I know that there are other people who take the other view, that using -- essentially, both used ABACUS; we didn't really weave. We proved that you didn't make a mistake. We didn't prove that your conclusion was true. And it's a tough issue, because smart licensees will know that any code developed for the NRC is public property, and they can get it, and what better code to use for the analysis than what the regulator is going to use? CHAIRMAN WALLIS: Dana, could you fix those two paragraphs? DR. POWERS: I could. I do want to leave out this indeed, it would be desirable for an essential core of this work to be supported by public funds not because I disagree, because I think I do agree, but because I think that's an argument that deserves a separate report. CHAIRMAN WALLIS: That came up in my discussion with one of the commissioners, being something desirable to say but not to say it too much; just slip it in somewhere, so I slipped it in here. DR. POWERS: I don't think I would object if a cogent argument were advanced for saying that, and I think the cogent argument exists, but it has to be a cogent and careful argument. CHAIRMAN WALLIS: You don't think this would help? DR. POWERS: I think all it will succeed in doing is pissing off somebody who has gain turned up high on this issue. CHAIRMAN WALLIS: But it may also please someone whose gain is turned up. DR. POWERS: I don't think so. I don't think it's enough to please those who believe this, but it is enough -- DR. SHACK: Preaching to the choir never gets you anywhere. DR. POWERS: But it's enough to offend those that -- CHAIRMAN WALLIS: Well, it does if they want to quote you somewhere. And ACRS is not an authoritative quote. So that's probably -- unless anyone wishes to leave it in, we'll excise it. The next statement responds to the idea of the industry being mature, and George persuaded me that 3,000 years isn't very much compared with 1E-5 or 1E-4. I think he's right. DR. POWERS: Yes, but what it shows you is that those numbers probably are true. It probably is not 1E-3, okay? And that's the concern. That's the concern I've expressed repeatedly in connection with 1.174, that I believe all of the plants are above 1 x 10-4, but I don't believe they're above 1 x 10-3. DR. BONACA: The other thing that's important is that you don't have to wait until you get to measure the number before you assess your improvement, and what we have seen, for example, is an extreme reduction in number of SCRAMS per year. We have seen all of these kinds of improvements in pieces that make up ultimately your 10 to the minus whatever core damage frequency, and you have an indirect measurement that you derive from that, and I think that to me, that supports some level of maturity in the industry. I mean, we have experience; we have learned what triggers what, and we have improved things. Now, I still can't support the statement you made here, that they have been operating successfully. CHAIRMAN WALLIS: The idea is to counter the argument that because the industry is mature, no more work needs to be done. I think that's the purpose. DR. BONACA: It's just the second statement, where it says when compared with the probabilities of events and the importance of the assessment, it implies only CDF and LERF. CHAIRMAN WALLIS: This is -- George isn't here, but that's George's. DR. BONACA: But for me, there are other events other than core damage and LERF that will give me an 1 indirect measure and, in fact, will make up -- CHAIRMAN WALLIS: Then, do we need this paragraph? Is it useful? DR. POWERS: I think it's a useful paragraph. CHAIRMAN WALLIS: So we'll leave it in. DR. POWERS: In that I think -- I think it is very important to address the issue of maturation of the industry in a balanced sense, and is it -- that balance comes from, yes, we've had a long history of fairly successful performance. That success came because literally, we regulated the hell out of the industry. Every single thing we could think of that could possibly go wrong about regulated and double-whammied and what not. And now, it is possible, because of improvements in technology and because of experience, to see how to make things better, and it's possible for the industry to make things different, and we want to make sure that they also make them -- keep them safe. DR. BONACA: It still makes me uncomfortable for two reasons. One is you don't have to measure only respect to core damage frequency to get an assessment of maturity. I mean, there are other measurements that this neglects to identify; and second, it gives me discomfort in that we will never be a mature industry, because if we are going to look for 10-4 -- DR. POWERS: Yes, you'll never get it. DR. BONACA: You'll never get there. So that's the only reason why I have the -- CHAIRMAN WALLIS: We'll get to it but not in your lifetime. DR. BONACA: Maybe we could -- DR. SHACK: Quite a few lifetimes. DR. BONACA: -- we could word-inform the statement here to make it more, you know -- I think there are two sides to this. Granted, we haven't measured to those kinds of levels, but there are indicators -- well -- CHAIRMAN WALLIS: Maybe you and Dana can work on this. DR. BONACA: I guess that line is true in the context of what it says; I mean, either it's more right because -- CHAIRMAN WALLIS: I might welcome your thoughts about how to improve this paragraph. DR. BONACA: Okay. CHAIRMAN WALLIS: Next paragraph really takes a different tack, talking about the future role of research or the present role of research. Comments on this paragraph? DR. POWERS: The thing that bothered me a little bit about this paragraph is you come down here, and you discuss the foresight issue, foresight to ask appropriate questions before the agency is under pressure to supply the answers. That's what they say in GSI 22 that research is supposed to be. So it's not like you're revealing truth to the research organization; they already know this. They've been told that that's their mission; in fact, the author of that quote, of DSI, I believe, is here with us, and they know that, and don't we want to acknowledge that they know that? CHAIRMAN WALLIS: Well, it doesn't hurt for us to say so if we think independently it's important. DR. POWERS: Yes; that's true. DR. SEALE: What about if you say it this way, that they have also been charged in GSI 22 to act in a proactive way, so on, so on? And then, to do this, it will be necessary to retain independence? CHAIRMAN WALLIS: I'm not sure we have to -- DSI 22? This is our independent opinion; it happens to agree. DR. SEALE: Okay. DR. SHACK: The question is whether you should reflect whether other people have this opinion or this is -- DR. SEALE: Yes. DR. SHACK: -- a new thing. CHAIRMAN WALLIS: The rest of this paragraph, yes, came from our discussions with the staff, actually; that's where it came from. DR. POWERS: Well, I hope your discussions revealed to you what a regulatory cul de sac is. [Laughter.] DR. SEALE: It ends. CHAIRMAN WALLIS: You get in; you can't get out. [Laughter.] DR. POWERS: And that's the whole point is the NRC never gets into such a thing. CHAIRMAN WALLIS: Well that's why -- DR. POWERS: NRC always -- CHAIRMAN WALLIS: -- what the senior manager of NRR said. He didn't want to get stuck taking some approach that didn't work out. DR. POWERS: He should feel happy, because he will never get into one, because there's always a conservative answer to any question that comes along. CHAIRMAN WALLIS: There is at least one answer is worried about getting stuck. He wants to know what to turn to when some approach he's taking doesn't work out. Now, you don't have to use the word cul de sac. DR. POWERS: I'm just fascinated as to what a regulatory cul de sac is. CHAIRMAN WALLIS: Well, I don't want to get into the French. I could explain to you each word. DR. POWERS: The one thing I know is you probably do not want to be in a cul de sac, now, regulatory or otherwise. CHAIRMAN WALLIS: Well, then, we could just stop. We don't need to say being prepared; you could say something much simpler about it, but there was a real concern about what do we do if the line we're taking with some regulation doesn't seem to be working out? We need to have someone thought about the alternative approaches. That's why we need research, to have thought these things out ahead of time. That was the line this manager in NRR was taking with me, and maybe we need to say it differently. DR. POWERS: Well, I think there's nothing wrong with the idea that yes, you have a plan, and then, you have a plan B. CHAIRMAN WALLIS: And you flex them. DR. POWERS: And if things don't work out, you can move between them and things like that; you have contingency plans. In fact, you know, that's one of the reasons that you have managers in the research organization is to make decisions on when it's time to fall back to plan B because plan A is taking too much time; doesn't show promise, things like that. CHAIRMAN WALLIS: So are we in the wordsmithing mode here? We change the words, but the idea is not too bad? DR. POWERS: Yes; I think if we can get rid of regulatory cul de sac -- CHAIRMAN WALLIS: Are we all right with that paragraph, then? We move on? [No response.] CHAIRMAN WALLIS: What about the statement about line organizations? DR. POWERS: Well, here, I had confusion here, because in the introductory part, and I'm not sure I can find where you say that, but somewhere up here, it says while the agency itself is generally aware that important ongoing technical issues are being addressed by its research programs, and then, here, you say something about at the same time, the line organizations of NRC must have more ownership of stake and appreciation for and confidence in the research effort. The two sound contradictory, but then, I thought about it a little bit, and I said, well, you know, it's very desirable that the line organizations had all of these things, but do they have to? No; they can survive perfectly well without it. Research might be able to survive perfectly well without it. CHAIRMAN WALLIS: Well, my sense is that the line organizations need certain information which they don't have, and they rely on research to provide it. They are the customers for research. DR. POWERS: And I think what you -- CHAIRMAN WALLIS: And if they don't ask for the right things, they won't get them, and they have a real stake in research. For that reason, it meets their needs. DR. POWERS: And that's a point that you're make in here or you have been trying to make in this is saying that gee, the line organizations have to go out and ask for tools and technologies that get them ahead of where they are, and that would be nice, but I'm not sure that line organizations anywhere in this world are very good at doing that. I think that it is far more likely that if you gave the imperative and the funds to do that, the research -- they would hire these young guys to come in and say now, what kinds of things can you do better for the line organizations, and they would come up with great ideas if they had the money and resources and mostly time and personnel to actually go look at the line organizations and see how they could help. I think that's the direction you're more likely to get that kind of thinking. I think line organizations have a particular mentality and job set that always leads to them saying yes, I want things that solve today's crisis today, and I'm not interested in having a tool that means I'll never get into that crisis ever again. It's the alligators here right now that I worry about. You know, I think it's wishful thinking to say that I would have this enlightened group of people, and there are enlightened people over in line organizations that can come in and say here's what I need for 10 years down the line here, but I think that you're asking too much for that to happen. I think it does happen in this agency, particularly in Bill Shack's area. I think there is a good cooperation between the line organization and the research organization to get a very forward looking research program. I think that's not the case in most of the research programs where there is a community of interest that's looking forward from the line and then transmitting that vision to the research organization to carry it out. DR. SEALE: Where the problem is particularly destructive is where you vest an unaware line organization with control over the budget of the research organization. DR. POWERS: Well, I think that's -- DR. SEALE: And that's exactly where we are right now. DR. POWERS: I think we have gone way overboard in the user need request as a way of giving a badge of credibility to the research program -- DR. SEALE: Yes. DR. POWERS: -- instead of saying, you know, the research program should have a substantial portion of its resource base toward meeting goals that it identifies. It's got this management structure that's, you know, bright guys; experienced guys; guys from across the agencies that can conceive of research programs and not have to wait for the line organizations to come up with research programs. I think we are wasting that talent right now fighting budget games. CHAIRMAN WALLIS: Well, the big picture I see is there is too much conflict between research and line organizations over budget and turf and self-interest, and it's really the fault of both sides. DR. POWERS: Yes. CHAIRMAN WALLIS: They're not doing their job. And it's mostly the fault of the management, because the management, which is above both of these parts -- DR. SEALE: That's right. CHAIRMAN WALLIS: -- is the responsible party, and this is trying to say look, you guys, you've got to work together better and solve the problem right; make sure the research does what's appropriate, and the users use it and so on. But really, it's the job of management to make sure this happened. That's what I'm trying to say. That's the bottom line, and somewhere, the EDO is involved later on here. DR. POWERS: I think it's a truism. I think it's also a truism, but I can't think of any counterexamples to that existing. I think certainly, I've sent you some notes on a report about the National Academy of Sciences workshop, and they had a very nice talk from DuPont saying how they had these problems of when do you fund a research program and how much do you put into it; what kinds of areas should it be; something directly from the user organization, or should it be something innovative and things like that? I think all people have difficulty; not surprising the NRC, I think, that research has gone way too heavily into this I've got to have a user need request in order to carry out a program. DR. SEALE: That was sort of rammed down their neck by -- what was it? -- the inspector general. DR. POWERS: If you don't mind, use your mike. DR. SEALE: That was sort of rammed down their neck by the report back about 5 years ago, 4 years ago. They just got beat over the head by these inspector generals on this. DR. POWERS: Bob, it's gone through cycles. DR. SEALE: I know. DR. POWERS: And I've seen for 20 years of where they go from research being self-motivated to no, no, everything's got to be tied to a user request to creeping in and things like that. I think we've just gone too far. CHAIRMAN WALLIS: Well, Dana, in order to get things going here, I wonder if any of these things could be resolved at the editorial stage, or is there some major -- DR. POWERS: No, I think it's -- CHAIRMAN WALLIS: -- major point which needs discussion in the entire forum? And if it is going to be -- if this section is going to be rewritten, who do I ask to do it? Or can we actually sort it out later on when we go line by line? I mean, I'm suggesting that we might be able to sort this section out line-by-line. Is that acceptable to the committee? [No response.] CHAIRMAN WALLIS: Are you nodding or -- DR. SHACK: Yes, probably; falling asleep. CHAIRMAN WALLIS: If the committee will accept that, I will propose a break. DR. UHRIG: That's a fine motivation. DR. SEALE: I think you just jammed it down their throat. [Laughter.] CHAIRMAN WALLIS: The next part is the evaluation of research needs and results. Margaret Federline wanted to tell us something about that. Is she going to come back? DR. POWERS: Before you get there, a couple of other questions I just had here. You say in here that just in time research would be nice, but it's often more cost-effective to obtain results 3 years before they're needed rather than one year too late, and I struggled to understand that; could think of no examples of where that was true, so I wondered whether you shouldn't -- CHAIRMAN WALLIS: We could throw that out. DR. POWERS: -- provide a reference on that. CHAIRMAN WALLIS: That's a sort of parenthetical thing, and we can throw it out. If there's any doubt about the statement, we can throw it out, and we can always edit that sort of thing away. It was an idea, and it got amplified with suggestions from individuals, but I don't feel it says very much. DR. POWERS: Yes; I think we need to guard against catty comments: though we marvel that such a special effort would be necessary -- CHAIRMAN WALLIS: It's gone; it's gone. That was only put in so you could get excited. DR. POWERS: Well I -- CHAIRMAN WALLIS: I do marvel that it's gone, and that's not the sort of thing you put in the report. Yes; so, we are going to -- are we ready to break -- DR. SEALE: Yes. CHAIRMAN WALLIS: -- until -- is quarter to -- no, it's not enough, is it? Ten to? Ten of? Ten of 4:00? And we'll come back ready to start off with the section evaluation of research needs and results. [Recess.] CHAIRMAN WALLIS: So if anybody else comes in, they will join us and not go away. Dana, we are back in session. We have another section of the front part of the report before it gets into the details of research requirements, and I think it's the front part of the report that's just going to take the time. And what I'm hoping is that we can look at this next section, and then, we can move pretty rapidly through the last part of the report, because it's been gone over by quite a few of my colleagues already, and various pieces have been gone over by various individuals. And then, we may take, if all goes well, a break around 5:00 where those who are drafting revisions to pieces can do some work and give it to them, and we can come up with something which we can then go through line-by-line around 5:30 until the end of the day, and at that time, we won't need a recorder. Does that seem a feasible plan? Or do you think we're going to get hung up? I do think -- I would really like to get to the point of going line-by-line over something today, but the hope is that we could go -- DR. POWERS: Sounds like a fighting chance. DR. SEALE: Charge. DR. POWERS: Okay. CHAIRMAN WALLIS: We do intend to finish this document this session, by December 4. All the work we can do today -- DR. APOSTOLAKIS: Are we on the evaluation of research yet? CHAIRMAN WALLIS: So we're going to move along with evaluation of research needs and results. Comments upon this section, please? [No response.] CHAIRMAN WALLIS: Do we need reiterate the 9/98 report? DR. APOSTOLAKIS: I'm sorry? CHAIRMAN WALLIS: Do we need the first three bullets of this section? Do we need to reiterate them? DR. APOSTOLAKIS: Well, the context here is different, so I can live with it. CHAIRMAN WALLIS: Okay; any other comments on the first three bullets? DR. APOSTOLAKIS: I have a comment on the whole section. CHAIRMAN WALLIS: Yes. DR. APOSTOLAKIS: I believe that it is very important for the EDO to play a more active role in achieving all of these things we are recommending; maybe part of the reason why the Office of Research is not appreciated; doesn't play the role it should is that management at that level has not gotten involved. Now, in the last paragraph, we do mention the EDO, but I'm thinking that maybe we should emphasize it in stronger terms that the EDO should take an interest in this and let him decide whether he wants to have an RERB reporting to him and doing things, because the problem -- I mean, up until now, all of the comments have been directed to the director of the Office of Research, and the poor fellow is trying his best to do -- well, I know, and the commission, but I think you need an executive with real power to take an interest in these issues, and I think an explicit recommendation that the EDO should do something would go a long way towards achieving this. And he can have his own advisors. DR. POWERS: I mean, what is that something supposed to be? Is he supposed to come in and tell them here is the approved criteria for doing research programs? DR. APOSTOLAKIS: No, that's too low a level for him. DR. POWERS: What are you asking him to do? DR. APOSTOLAKIS: Well, essentially the role that Graham is describing for this research effectiveness review board. I want the EDO to be responsible for this and let him delegate. DR. POWERS: So we can just get rid of the RERB. I'd go along with that. DR. APOSTOLAKIS: I hadn't thought about that, but he might. DR. POWERS: Well, I mean, if you're going to have an executive make the decision, you damn well do not want a committee to second-guess the executive. DR. APOSTOLAKIS: I'll leave it up to him to decide that if he wants to have a board or not. CHAIRMAN WALLIS: George, do you think that looking ahead at the middle of page 7, it says the first and last of these tasks are and should be more appropriately shared by the entire agency; we should bring the EDO into that? DR. APOSTOLAKIS: Is this the page 7 now? CHAIRMAN WALLIS: Middle of page 7. DR. APOSTOLAKIS: The title? CHAIRMAN WALLIS: The middle of the -- DR. APOSTOLAKIS: Oh, this is a different 7. CHAIRMAN WALLIS: The one we're working from, the middle of page 7. DR. APOSTOLAKIS: Where? Yes? CHAIRMAN WALLIS: Do you have the same document I have? DR. APOSTOLAKIS: Which paragraph? CHAIRMAN WALLIS: Middle of page 7; the middle of page 7. DR. POWERS: RES presently bears an inordinate share. DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: Right when it says the first and last. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Do you think we should bring the EDO into the discussion at that point, where it says shared by the entire agency? DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: It's basically the responsibility of the EDO. DR. APOSTOLAKIS: Of the EDO. CHAIRMAN WALLIS: Or something like that. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Would you bring the EDO in there -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Maybe? DR. APOSTOLAKIS: Yes, yes, yes, yes. CHAIRMAN WALLIS: Now, I disagree with what you said earlier, that the intent of the report is to revert before the commission. DR. APOSTOLAKIS: I understand that. CHAIRMAN WALLIS: Under research. DR. APOSTOLAKIS: That's fine; that's fine, but in terms of operations -- CHAIRMAN WALLIS: Yes, it's operations. DR. APOSTOLAKIS: -- in terms of day-to-day activities, I think it's the proper role of the EDO to -- and he can delegate; again, he doesn't have to do it himself, but the weight of his office will go a long way towards remedying some of that. DR. UHRIG: Think we ought to take it out from the last paragraph? DR. APOSTOLAKIS: No, I think it should be combined, okay? CHAIRMAN WALLIS: So the upper management is mentioned in -- let's start with broad results, below the bullets, George, that paragraph; upper management is brought in at that point, too? DR. APOSTOLAKIS: I'm sorry again. Which paragraph? CHAIRMAN WALLIS: Broad results. DR. APOSTOLAKIS: Broad results. CHAIRMAN WALLIS: One third of the way down. DR. APOSTOLAKIS: Yes, yes. CHAIRMAN WALLIS: Upper management is brought in there? DR. APOSTOLAKIS: You can say to the office of the executive director. CHAIRMAN WALLIS: Or bring the EDO in there. DR. APOSTOLAKIS: I think you need the sentence before, though, stating that we do want the EDO to take charge of this. [Pause.] CHAIRMAN WALLIS: So you agree with the intent of the paragraph that -- DR. APOSTOLAKIS: Oh, yes. CHAIRMAN WALLIS: -- upper management should be involved? DR. APOSTOLAKIS: Yes, yes. DR. BONACA: Plus, I mean, he is the person who is going to ask the money for research, so you would want him to be -- CHAIRMAN WALLIS: Do you want to state that the ACRS should be involved too? DR. APOSTOLAKIS: No, no. CHAIRMAN WALLIS: There's no such thing. DR. APOSTOLAKIS: No, we are not in the -- no. Now, let me understand this research effectiveness review board. To who are they reporting? Is it -- CHAIRMAN WALLIS: RES, Thadani. DR. APOSTOLAKIS: Oh, no, no. CHAIRMAN WALLIS: Makes no sense. DR. APOSTOLAKIS: That's not what I have in mind. DR. UHRIG: Well we do have the responsibility taken over from the Nuclear Safety Research Review Board, and that -- I assume that's what you were addressing here when you put ACRS in this, or is that something else? CHAIRMAN WALLIS: Yes. DR. UHRIG: Is that what you had in mind? CHAIRMAN WALLIS: I think it's part of our job to sort of advise on research, and we need reports from them, so I don't know why we would want to cut out a reference to that. DR. UHRIG: That's my objection, is we need to leave it in. DR. APOSTOLAKIS: Yes, we should leave it in. CHAIRMAN WALLIS: So that sentence, the wordsmithing may survive? Leave it in -- DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: -- and move on? Are you comfortable -- I'm not sure I am entirely -- with the next one about an inordinate share of the burden? I'm not sure I like the word clairvoyant. DR. APOSTOLAKIS: That's why the EDO should be involved. DR. POWERS: Is he clairvoyant? [Laughter.] DR. POWERS: Is that a criterion for being the EDO is you have to be clairvoyant? It would probably be very useful. DR. APOSTOLAKIS: I think the other officers, certainly NMSS and NRR, should participate with research in addressing these bullets at a very high level, and the only way to do that is to have the EDO bring them together. I think you're right that their research presently bears an inordinate share of the burden. CHAIRMAN WALLIS: So apart from wordsmithing, these two paragraphs should survive? DR. APOSTOLAKIS: I'm happy; yes. CHAIRMAN WALLIS: Maybe be combined or something. DR. APOSTOLAKIS: Yes, but make it clear that the EDO will have to do this. CHAIRMAN WALLIS: Now, the RERB does exist. DR. APOSTOLAKIS: Well, I mean, if Thadani wants a board to advise him, I don't think that's my problem here. CHAIRMAN WALLIS: I don't think that was the original intent. DR. APOSTOLAKIS: Hmm? DR. UHRIG: They were established by a SECY. The commission established them. CHAIRMAN WALLIS: It says or some similar body. DR. APOSTOLAKIS: The way I see it is if we recommend that the EDO take charge, I think we should leave it up to him to structure the management of the whole activity. If the EDO's office feels that they should have an advisory board to the director of research, I mean, that's their prerogative. I don't think we should get involved in that. CHAIRMAN WALLIS: I think we should acknowledge that the RERB does exist. It's their response to the situation is to have created this board. DR. APOSTOLAKIS: And I guess we are disagreeing now that that's not the proper response. CHAIRMAN WALLIS: Well, don't you want the EDO to either strengthen the RERB so it does the job right or to create some other mechanisms? Isn't that what you're asking? DR. APOSTOLAKIS: No, I want another mechanism. CHAIRMAN WALLIS: You don't want the RERB? DR. APOSTOLAKIS: No, not in its present form. DR. SIEBER: It seems to me that if this were a utility that had a research arm, which we did, the chief nuclear officer was the one who allocated resources, and the way that that was done was to look at what tasks and what projects needed research input. And then, they would decide with the budget in front of them how much can they afford; what will they accomplish; and how will they do it. And they would use a committee to monitor the progress of that job and whether or not the department head was being satisfied with the research effort that was going on and whether it was getting out of hand or not. DR. BONACA: Because it is not the EDO's position, also, to determine what needs each one of these functions has to achieve certain goals and therefore to rely on research, and he really ultimately makes the determination of how much money goes to -- DR. SIEBER: Right, that's right. DR. BONACA: But the planning of research at that level involved officers other than the research. DR. SIEBER: That's right; it involved the chief nuclear officer -- DR. BONACA: Right. DR. SIEBER: -- and it involved the department heads -- DR. BONACA: Good. DR. SIEBER: -- along with the -- whoever was in charge of research to decide whether he could do it or not and how much it would cost. That was a big deal. CHAIRMAN WALLIS: Let me ask, George, if the issues to be addressed in those bulleted items are okay, but we may say that they need to be addressed in some suitable way by the EDO but without highlighting the way to do it. DR. APOSTOLAKIS: That's all right. CHAIRMAN WALLIS: Is that what you'd like to see? DR. APOSTOLAKIS: Yes. DR. SIEBER: That's right. MR. EL-ZEFTAWY: But that means the last paragraph has to -- CHAIRMAN WALLIS: Well, it means we have to rewrite it so the RERB doesn't play such a prominent role. DR. APOSTOLAKIS: Exactly. CHAIRMAN WALLIS: But the EDO must address these needs, and maybe the RERB is the way to do it. DR. APOSTOLAKIS: Yes. DR. SIEBER: Yes. CHAIRMAN WALLIS: Okay. DR. UHRIG: You do want to address the effectiveness of the RERB. I think you have to say something. DR. BARTON: The effectiveness of RES. DR. UHRIG: Yes; it didn't do much. CHAIRMAN WALLIS: That's okay. DR. UHRIG: I thought you were going to cut it out. CHAIRMAN WALLIS: No, no, I was going to start with this business about recommend that the RERB do all these other things to say these other things need to be done; the EDO needs to get a mechanism for doing it. DR. APOSTOLAKIS: The bottom one -- CHAIRMAN WALLIS: It may not be the RERB. DR. APOSTOLAKIS: The bottom three bullets. DR. SIEBER: Right; should be him. CHAIRMAN WALLIS: So I think we can rewrite that. DR. SIEBER: Yes. CHAIRMAN WALLIS: Any other comments on this section? [No response.] CHAIRMAN WALLIS: Are there any comments from research about this? MS. MITCHELL: Yes; this is one of the places where both Ashook and Margaret left notes on this, and I will attempt to translate their notes and tell you what I think they would say if either one of them could be here. They're both very concerned about this specific section. It's the one section that comes up. Ashook was very concerned about the scope and responsibility of what you had the RERB doing here and said that what they intend to do with the currently-envisioned RERB process was to define both user needs and how the research products would be used. Now, Charlie Aider expressed this as a vertical slice look at it, so the whole process from conception up here through production of some product and then down to use at the bottom would really all be looked at. Ashook really feels that this -- if this is what they're doing, he really needs to have it reporting to him rather -- you know, with copies to Travers or so -- and that Margaret's comments were basically, she didn't think it was realistic for the task to be shared by the entire agency. I think for the reasons that I heard Dana express earlier, that line organizations are not usually very good at looking several years into the future as research hopes that it will be doing that to ask to put them in a position where they have a huge input into this process is only to make it more difficult to justify anything that is really far forward looking. DR. POWERS: I think we've had a history of panels not refining the research program but simply making it more difficult to carry it out. I think we can go back -- I bet you Jocelyn could go back into early history and give you more detail than I can. MS. MITCHELL: Yes. DR. POWERS: But I think that you have to be very careful about panels, and you have to say, now, what's the legitimate role of high-paid people like Charlie here who -- you didn't know you were high-paid? [Laughter.] DR. POWERS: You have this research management structure, and you say, now, why do I have those guys and panels? You know, I mean, they get the medium-sized bucks to make these hard decisions on what should be done and what should not be done and where to put resources and where not to put resources. And now, what are you asking a panel to do that's different from that? And do you want to give that panel dictatorial control? Okay; you know, what does a guy like -- hi, Charlie, since you're here -- have to do? He comes up with a good idea; maybe actually your staff comes up with good ideas, and they feed them up to you, and half of them, you say yes, well, you thought it was a good idea, but it really wasn't, and the other half now go up to your boss, and he takes another half of those and throws them out and what not. So he's got lots of people second-guessing him: do you really need another panel to keep second-guessing everybody? DR. APOSTOLAKIS: The only value of a panel is if they're outside people to express an opinion, bringing the outsider's perspective, but they should never have the dictatorial powers you mentioned. CHAIRMAN WALLIS: Well, I'm willing to rewrite this saying the EDO needs to get involved; make sure that these things happen and not making the RERB mechanism. DR. APOSTOLAKIS: I think that would take care of it. CHAIRMAN WALLIS: I don't think of it as the mechanism, but I do think we need to say something about the RERB in passing about it has been formed; it isn't really doing very much; just something about it. DR. APOSTOLAKIS: Just facts. CHAIRMAN WALLIS: Because it was responding to one of the things we raised for and we talked about. DR. APOSTOLAKIS: I think if you write it that way, you are responsive to the concerns from -- DR. SEALE: Don't you want to be just a little bit more aggressive than that? What we're dancing around, it seems to me, is the fact that the money is now controlled and comes through other line organizations, and these line organizations have no real responsibility for the research, and all they -- you know, the thing they can say, the thing they guard the most is the right to say no, and as long as they have that right, the panel or no one else is going to be effective in modifying the resources that are available to the research program, and the only place this is going to happen is if you have someone who is above the people who are currently allocating the money in the present process, and that's the EDO's office. CHAIRMAN WALLIS: Yes. MS. MITCHELL: Well, there is something called the Executive Committee, which is where the ultimate budget that goes to the commission for the commission's consideration comes through the EC, which Bill Travers is only one member. Now, he may be first among equals, but there are other members on that committee, so -- and do you really want Bill himself to do some of these things that you're talking about here: identifying, formulating and expressing needs for additional information, methods and decision making; planning research activities in response to these needs; and evaluating the effectiveness of research? You want Bill, himself, to do this? DR. APOSTOLAKIS: No, that was not the intent. The intent is for him to create a structure that will report to him that will do these things. DR. SIEBER: For him to approve the allocations. DR. APOSTOLAKIS: And for him to approve. MS. MITCHELL: But that -- if you want to hook at it, that structure exists. It's called the Office of Research. DR. APOSTOLAKIS: Well, then, I guess the committee is saying that that's not a good structure. We would like other offices to have a say in these things. Now, the EDO can decide how to do that. He, himself doesn't have to do it, but eventually, it will come to him. And again, you know, you mentioned that line organizations are not very good at thinking ahead. Still, they can participate in the planning, but how much their opinion will count, again, will depend on the EDO's views. CHAIRMAN WALLIS: If they can't think ahead, someone else is going to do it. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: The EDO has to make sure somebody does it. DR. APOSTOLAKIS: Right, right. CHAIRMAN WALLIS: I will take responsibility for this piece if you're happy with that. DR. APOSTOLAKIS: Yes, I'm happy. CHAIRMAN WALLIS: So, I will delegate other parts. DR. BONACA: The one thing that I want to point out is that there are structured approaches to do this. I mentioned a number of times that there is a -- that we pull out, even from organizations that normally cannot reasonably contribute parts; that we pull out their needs as part of a structured process, and that doesn't mean it's going to be easy. CHAIRMAN WALLIS: Can we move on from this? We will come back to it in the editing process. Now, the research requirements. Many of you have had inputs to these, some of which were contradictory. I put things in, took them out, juggled them. DR. APOSTOLAKIS: I have a comment. CHAIRMAN WALLIS: I've been soliciting advice. How would you like to proceed? DR. APOSTOLAKIS: I don't know; paragraph by paragraph? CHAIRMAN WALLIS: Go section-by-section; say risk-informed regulation, comments on that one? DR. APOSTOLAKIS: Yes, I have comments. CHAIRMAN WALLIS: Okay. DR. APOSTOLAKIS: At the bottom of the page -- well, let me make sure we're talking about the same page. CHAIRMAN WALLIS: Eight. DR. APOSTOLAKIS: Yes; after the quotation from Ahern, and by the way, his name has an A there, after the quotation from Ahern, I propose that we insert the following: we encountered an example of weak foundation recently when we identified the inadequacies of importance measures. Given the major role importance measures play in risk-informing the regulations, this is a major problem indeed. CHAIRMAN WALLIS: So you will give that to him, and he will insert that? DR. APOSTOLAKIS: Yes, I will write it. CHAIRMAN WALLIS: Will you go along with that? DR. APOSTOLAKIS: In clear English. CHAIRMAN WALLIS: Any problem with that? DR. POWERS: And if we can come up to the paragraph before then, it says we believe that the NRC should be able to explain to the public in meaningful terms either related to everyday experience or readily explainable in common language what the level of protection is. You might believe that, but I don't believe that. DR. KRESS: I think this relates to the question of they always say, well, we provide adequate protection to health and safety of the public, but nobody ever says what that is, that it's -- DR. APOSTOLAKIS: I have an objection to that. DR. POWERS: It is not connected with the research program. I mean, yes, it would be really nice if everybody could do this, and everybody could understand it and things like that, but I don't think that's how I'm going to judge my research program, on the ability to do that. And I don't even think I want to divert the activities to do that. I think there is a problem with risk communication, but I don't think it's resolved by developing the ability to explain in common language what the level of protection is. DR. KRESS: I thought that was -- DR. APOSTOLAKIS: I was going to suggest that the last sentence of the preceding paragraph, it can also provide, be deleted, and if you delete that, then, you delete the paragraph that offends Dana for the reasons he stated. I think this committee -- we've heard that CSIS and Ahern especially asked for a quantitative definition of adequate protection. I don't think this committee has discussed it enough to form an opinion of its own. I'm not sure that the quantitative definition is possible, and where do you put it? So to put it in the research report in passing doesn't serve any purpose. So that last sentence plus the whole paragraph that follows really don't serve any purpose in this report. DR. POWERS: My personal feeling is that adequate protection is a concept that would atrophy if we're successful in risk-informing regulations. CHAIRMAN WALLIS: Well, no, you still have to say what it is. DR. POWERS: No, I don't think you have to. DR. APOSTOLAKIS: I don't think you have to say what it is. DR. POWERS: What I think is how it's described now is plenty good enough. CHAIRMAN WALLIS: I think it's scandalous the way the agency goes around and says if you meet our regulations, that's adequate protection. DR. APOSTOLAKIS: But on the other hand -- DR. POWERS: No, they don't say that. They don't say that. They say if you meet our regulations, it is presumed that there is adequate protection. But they go on to say if you don't meet our regulations, it does not mean that you're no longer providing adequate protection. And I think there is a genius to that that can be underappreciated until you have to -- CHAIRMAN WALLIS: I guess I was saying that there is a role for research here, to actually come up with -- DR. SEALE: Can't. DR. POWERS: I think it's a waste of their time. CHAIRMAN WALLIS: -- proper measures of safety. DR. POWERS: I think it's a waste of their time. DR. APOSTOLAKIS: I think proper measures of safety is different from defining adequate protection. DR. POWERS: Yes. DR. APOSTOLAKIS: I really think it's different, and I had a couple of lawyers explain to me that you really don't want to get into the numbers game with adequate protection. It's part of the Atomic Energy Act, and you will create all sorts of problems if you start quantifying it. But I think your point, Graham, about the communication is a valued one but not in the context of adequate protection. CHAIRMAN WALLIS: Well, you need a measure of safety. What's adequate is political. DR. APOSTOLAKIS: I understand that. CHAIRMAN WALLIS: I put that in here and they -- DR. APOSTOLAKIS: But I think Dana's point is well-taken, too; I mean, if you're not recommending any research to be done, then, why mention that we have to -- leave alone the fact that it's -- DR. KRESS: The research is the new NRC policy statement. DR. APOSTOLAKIS: What? DR. KRESS: The research effort is the new NRC policy statement. DR. APOSTOLAKIS: Well, that's a policy statement. DR. KRESS: I know that, but it's being put together by research. DR. POWERS: I mean, that's fine if they want to do that. I just don't think this is a -- I think this is a nicety that I can live without. I've got bigger issues, fish to fry. CHAIRMAN WALLIS: What's a bigger fish? I think this one is a whale here. DR. KRESS: Well, my feeling is that without adequate definitions of what is the level of safety that is acceptable in terms of things like risk metrics other than CDF and LERF and such things as uncertainty, how you deal with it, how you deal with defense-in-depth, I think those are needed to be more precisely defined in order to do a risk-informed regulatory system properly, and I think that's the role of research to define those and then to tie them together and say what are our acceptance limits? And how do we deal with them? DR. APOSTOLAKIS: But the motivation for that, Tom, is not to explain it to the public. DR. KRESS: No, no, I'm not arguing that. DR. APOSTOLAKIS: That's the objection to this paragraph. DR. KRESS: Okay; well, I don't care whether it's to the public or not. I agree with that. DR. SEALE: Yes; and as a matter of fact, CDF and LERF aren't -- CHAIRMAN WALLIS: Let's cut out these, and if we can think of a message which needs to be inserted in some other way, we'll insert it. DR. BONACA: I'd like to say one thing: as we move into this section, again, I pointed out before I don't think -- I think one of the major impediments to move to risk-informed regulation is the fact that you have different stakeholders with different objectives there. You have a commission that wants to move to risk-informed regulation; you have the industry that really, it's the best caging about it. Think about it. I mean, they are likely to have a standard developed; in fact, they want to have several standards so that you have the standards. They would like to perform decent PRAs, because really, that's what we have on record. They're saying well, it has to be optional, so if it is advantageous to me, I'll use it; if it is not, I'm not going to use it. And I think this dichotomy in the stakeholders, because they have not done a full stakeholder analysis, is the point of their research program, it's a major undermining of anything they try to do, because ultimately, it seems to me the commission says we want to go risk-informed. But they also, the commission says don't make PRA mandatory. And those two statements are totally inconsistent, it seems to me, and I think we have to say something about the fact that ultimately, these efforts for research are the focus or the success of what is going to be undermined by the lack of bringing together stakeholders, because ultimately, you know, if the licensees don't want to have PRA, they have the plants, and they have the PRAs right now. So we can do anything we want to try to accommodate insights from that, but nothing is going to happen. DR. KRESS: That's a huge problem; I agree. DR. BONACA: I think that -- but it should come; I mean, if they did the planning for research, you would look at those stakeholders, and you would put them together, but we haven't done that. CHAIRMAN WALLIS: Do you want to draft something to insert it here? DR. BONACA: What do you think will be appropriate to put something here? DR. KRESS: I'm not a great believer in getting stakeholders together, frankly. I think NRC ought to decide what their needs are and -- DR. SEALE: Tell them what the requirements are. DR. BONACA: But, you know, they can be, you know, walk into Oz, you know. They are going to -- for the great future of risk information, but nothing is going to move, because the standard is going to stay what it is; the PRAs are going to be what they're going to be. You cannot make judgment. And so, you have this, you know, they are developing regulation. CHAIRMAN WALLIS: Does this point to some research that needs to be done, or is this -- DR. BONACA: Well, it points to the -- I believe ultimately, research may fail to succeed, okay, because it doesn't get really the amount of resources risk information and the commissioners say they'll get. I mean, the commission is still saying don't force the utilities to have PRAs. DR. APOSTOLAKIS: But we have a whole discussion in the retreat on the impediments. DR. BONACA: Do we? DR. APOSTOLAKIS: So we will bring that -- is that appropriate for that? CHAIRMAN WALLIS: This is a broader topic than this context here. DR. POWERS: It may be. DR. APOSTOLAKIS: Yes, and Mario, you will have a chance to raise it -- DR. BONACA: Okay. DR. APOSTOLAKIS: -- in January. CHAIRMAN WALLIS: It's important but maybe not in this report. DR. BONACA: Okay. CHAIRMAN WALLIS: How about the next page? Can we move on to the next page, page 9? We've inserted something from George, and we've excised some lines. DR. APOSTOLAKIS: You want to say that the release of RG174 was a significant step rather than giant? CHAIRMAN WALLIS: Whatever. MR. EL-ZEFTAWY: Can you say that again, George, please? DR. APOSTOLAKIS: I'm sorry; what? MR. EL-ZEFTAWY: Can you say that again? DR. SHACK: A small step for science. DR. SEALE: Neil Armstrong, huh? DR. APOSTOLAKIS: The first line: the release of RG -- significant, yes. DR. KRESS: Okay. DR. BONACA: It was a step. CHAIRMAN WALLIS: Is that bigger than minimal? [Laughter.] DR. APOSTOLAKIS: Now, you are really attacking here the qualitative part, and I have mixed feelings about this. CHAIRMAN WALLIS: I read that. DR. APOSTOLAKIS: If you want to make that a little more quantitative. CHAIRMAN WALLIS: I was astounded of how waffly and qualitative it all was. You read that guide; you like it, but I -- DR. APOSTOLAKIS: No, I didn't say I like it, but the question is -- I didn't say no, I may like it, but I didn't say that. CHAIRMAN WALLIS: You love it. DR. APOSTOLAKIS: But the question -- CHAIRMAN WALLIS: Maybe no one doubted it. DR. POWERS: It was equivocal on 1.174. [Laughter.] DR. APOSTOLAKIS: Given what they had to work with, given the situation; I think they did a good job, and as I keep saying, he was consistent with approaches in other fields, where they talk about analytical and deliberative processes and so on. I mean, our staff reinvented the wheel because they had to, and they did a good job. Now, I think what you're saying here -- that's why I'm not objecting to it -- is because okay, you did that then, but try to take away a lot of the deliberative process by quantifying it, and I think that's a valid point. CHAIRMAN WALLIS: So maybe we could wordsmith this? DR. POWERS: Well, no, I don't think so. I think it's out of whack, because I think what's missing is a palpable strategy for getting to risk-informed regulatory practices. Yes, you have 1.174, and yes, you're going to have to do some things in the future to make it better as your capabilities get better. But it isn't the top on my hunting list by any means. And I think what happens is the next paragraph says everything is hunky dorey, and I just think -- I just disagree totally with the next paragraph, and if you rework that, then 1.174 gets put in the proper context as something that we'll have to get around to fixing one of these days but not now; we've got bigger fish to fry. DR. APOSTOLAKIS: Which is the Part 50? DR. POWERS: No; I think we are in no position to do risk-informed regulation. We cannot calculate risk; we cannot even calculate core damage frequency. DR. APOSTOLAKIS: Right. DR. KRESS: But we have the regulations, though. DR. APOSTOLAKIS: Wait a minute now -- DR. KRESS: In the absence of those, I think. DR. APOSTOLAKIS: I think these are too strong statements. They're way too strong. There may be instances where you're right, but there are other instances where you're not right. DR. POWERS: Where am I not right? DR. APOSTOLAKIS: I mean, to make a blanket statement that we cannot calculate risk -- DR. POWERS: You cannot calculate risk. DR. APOSTOLAKIS: I don't think that's the -- DR. POWERS: Okay; show me an example. DR. APOSTOLAKIS: I think you can make changes to power operations. DR. POWERS: Oh. DR. APOSTOLAKIS: And I don't mean the low-power shutdown. DR. POWERS: Oh, power operations. DR. APOSTOLAKIS: Yes. DR. POWERS: Yes; maybe we can calculate risk there. DR. APOSTOLAKIS: Yes. DR. POWERS: That's not risk for the plant. CHAIRMAN WALLIS: The commission said go ahead and try to risk-inform Part 50. It can't be built entirely on an illusion. They have said go do it. DR. POWERS: Want to bet? They're operating on an illusion. They think they can calculate risk, and they can't. CHAIRMAN WALLIS: Well, I don't think it's an illusion. I think it's a very desirable thing to do, and they've got to figure out how to do it. It may turn out to be difficult. DR. POWERS: One of the ways to figure out how to do it is to get the capability to calculate what you say you're going to calculate. DR. SEALE: Precisely. DR. KRESS: I thought the concept was if you could calculate risk, what would the regulation look like? DR. APOSTOLAKIS: I don't think that's the right question, Tom. You should ask the question what should the regulations look like given your capability to estimate risk this way. DR. KRESS: Okay; that's another way to -- that's another way to put it. DR. APOSTOLAKIS: But it's a more practical way, is it not? DR. KRESS: That's the more practical way. Given the incompleteness and the uncertainties -- DR. APOSTOLAKIS: Sure. DR. KRESS: -- in risk analysis -- DR. APOSTOLAKIS: Sure. DR. KRESS: -- I mean, how do you write the regulations? DR. APOSTOLAKIS: Right. DR. KRESS: That's probably a better sentence. DR. APOSTOLAKIS: And where can I go and do more research -- DR. POWERS: But why would you do that? Why wouldn't you get your capabilities up to the minimal level that you know you need for this? DR. KRESS: I prefer your approach. DR. POWERS: Yes. DR. KRESS: I mean, before you go off and do it, let's -- DR. POWERS: You're right. DR. KRESS: -- look at the capabilities. DR. POWERS: I'll never have a perfect -- DR. KRESS: Yes. DR. POWERS: -- capability to do it. DR. KRESS: Somewhere, you have to stop. DR. POWERS: Right. DR. KRESS: Yes. DR. POWERS: I'm so imperfect now and so limited in my capability to launch off and address the regulations right now is just fooling yourself. DR. KRESS: I think that's true. DR. POWERS: If you said it. DR. KRESS: I do it based on the fact that I don't think you handle uncertainties well enough, not the incompleteness. I think the incompleteness -- DR. POWERS: It would have been the next sentence out of my mouth. DR. KRESS: Yes, okay. DR. POWERS: We can't calculate the uncertainties on these things: we don't have risk acceptance criteria that are meaningful and useful. DR. KRESS: Yes, exactly; that's my feeling. CHAIRMAN WALLIS: Can we address this later down when we talk about PRAs and their inadequacies? Doesn't that address some of your concerns? DR. POWERS: It may well, but this paragraph that precedes probabilistic risk assessment I think is a pollyannish view of what reality is. DR. APOSTOLAKIS: So what is the offending sentence? DR. POWERS: It begins with SECY and ends with -- DR. APOSTOLAKIS: Yes. DR. POWERS: -- resources. DR. APOSTOLAKIS: Yes, but what is it that makes it -- [Laughter.] DR. APOSTOLAKIS: That's not a sentence. I want the words that make you upset. What is it that you don't like? DR. POWERS: Developing intellectual leadership on the part of the research staff. DR. APOSTOLAKIS: Where is that now? Let me find it. DR. POWERS: Real work is being an issue with -- it's like candidate regulations to be revised. DR. APOSTOLAKIS: The real work is being initiated with efforts to select -- sorry; so, you don't think that's something -- DR. POWERS: I think we're just taking -- we're presenting way too rosy of a picture here, that without some real capability development on the part of the staff, what they will do is they will take the existing regulations and put a risk shine on the outside. DR. APOSTOLAKIS: Right. DR. POWERS: And I think that's wrong. I think what we really need to do is say if you wanted to create a new regulatory structure based on risk, what would it look like? And I think for instance, the existing regulations presume a shutdown plant is a safe plant, and we certainly haven't demonstrated that. It may be true, because I don't believe our shutdown risk assessments are sophisticated enough. I think you have to go to something like the Kressian Monte Carlo method to get something realistic. DR. APOSTOLAKIS: Objection, objection, I'm not sure. DR. POWERS: It's a much better job handling -- DR. KRESS: George, you of all people should appreciate the genius in that method. DR. POWERS: Well, I think you have to do a much, much better job addressing the issue of intervention, because I think the problem that the risk assessments we're doing now have had is they overestimate the risk because they can't account for imaginative interventions, because it is not proceduralized. There's no way to handle it. DR. APOSTOLAKIS: Are you objecting to that? DR. POWERS: Yes, I think it's premature. CHAIRMAN WALLIS: Well, I think given the job by the commission, and they're trying to do it, and we're commenting on what they're doing. DR. APOSTOLAKIS: Yes, but I can see the staff doing what you've just said; you know, reevaluating the major assumptions of the regulations as part of their attempt to risk-inform Part 50. Risk-informing Part 50 does not mean look at this little rule and put a risk shine to it. DR. POWERS: That sure looks like what option two is. DR. APOSTOLAKIS: That is correct. [Laughter.] DR. APOSTOLAKIS: That is correct, but I don't think you should say you are objecting to risk-informing Part 50. Risk-informing Part 50 make take certain -- some fundamental work first: rethinking the whole philosophy of the existing system and see whether, in a risk-informed environment, the basic assumptions we've been making for 40 years are still valid. Is a shut down plant a safer plant? But that's part of risk-informing Part 50, in other words, as part of the mechanics of doing it, not the philosophy of whether to do it at all. CHAIRMAN WALLIS: What I intended to say was that they've been given this job by the commission. How well are they doing? Well, a year ago, they didn't know what they were doing. They'd just begun. Now, they've been -- this is very faint praise. There have been signs of a developing intellectual leadership; they're just beginning to realize what they really need to do. DR. APOSTOLAKIS: How about if you say that the real work really should be doing some of the stuff that Dana mentioned? CHAIRMAN WALLIS: I think these guys need some encouragement. DR. APOSTOLAKIS: Yes, but I mean -- CHAIRMAN WALLIS: And they also need to know that it's a very difficult job. DR. APOSTOLAKIS: Oh, I don't think the staff needs a lesson there. DR. POWERS: I think they've probably got a clue. [Laughter.] DR. APOSTOLAKIS: It's not a walk in the park. I have no clue that they're -- I said gee, we hadn't realized it. CHAIRMAN WALLIS: I'd like someone else to have a comment. DR. POWERS: What I will say, Graham and George, in response to both of you is yes, I don't have any objections to the commission saying go see what it takes to risk-inform Part 50 and make sure you do a real good job on there, as long as we come back and eventually say look: I think you're going to have to take a much broader view of what risk assessment tools you have to have. DR. APOSTOLAKIS: Absolutely. DR. POWERS: I am firmly of the belief that they've got to completely rework the PRA implementation plan. CHAIRMAN WALLIS: Well, that's the -- DR. APOSTOLAKIS: I agree with you. I think you're taking your position in stronger terms than is justified. But your basic premise of reeevaluating the foundations of what we've been doing and whether we want to proceed that way is very valuable. CHAIRMAN WALLIS: Could you two gentlemen come to an agreement elsewhere about this paragraph and let us know the result? DR. APOSTOLAKIS: I would be willing to comment on a paragraph drafted by my colleague. CHAIRMAN WALLIS: Thank you. DR. APOSTOLAKIS: Since he feels so strongly. [Laughter.] DR. POWERS: The paragraph that I want to draft is devoid of sentences. [Laughter.] DR. APOSTOLAKIS: No, no, I object to that. CHAIRMAN WALLIS: We'll include that one. DR. APOSTOLAKIS: No, how about if you say SECY such-and-such defined options and so on. We believe that the effort should be broader; you know, that kind of stuff and drop the rest of the paragraph? I will go along with that, because I think it's a valid -- CHAIRMAN WALLIS: I'm sorry; I did a lot of research. I said what steps have they done? They must realize that they've got to define certain things and so on, so I spent a lot of time looking at the presentations and -- DR. POWERS: We also wrote a letter saying it was a good idea. DR. APOSTOLAKIS: As a side remark. CHAIRMAN WALLIS: Well, George, can you work out something that Dana will accept or that even if he won't accept, he'll at least present it to -- DR. APOSTOLAKIS: No. DR. POWERS: You should write another letter saying the -- DR. APOSTOLAKIS: I think Dana should write it, because he's the -- DR. SEALE: All right; this is the back door into doing the shutdown risk thing. DR. APOSTOLAKIS: I'm working on a letter right now. CHAIRMAN WALLIS: I know. DR. SEALE: You can't do 50 unless you do the shutdown risk, and you ought to say so. DR. SHACK: If we don't think you should even start thinking about risk-informing Part 50 until you have the tools, we also should have said that. CHAIRMAN WALLIS: You should have said -- that's right. DR. APOSTOLAKIS: I think it's an extreme position to say we don't have the tools to risk-inform the regulations, and it's not true. I think Dana is making a point, you know, the point -- CHAIRMAN WALLIS: The thing I made later when we talk about PRAs? DR. APOSTOLAKIS: Huh? CHAIRMAN WALLIS: Doesn't that point get made later when we talk about -- DR. APOSTOLAKIS: Sure. CHAIRMAN WALLIS: -- PRAs? DR. APOSTOLAKIS: Sure, sure. CHAIRMAN WALLIS: So I'm not convinced with this debate that I hear that we know what to do with this paragraph. We don't -- DR. APOSTOLAKIS: Well, Dana is redrafting it. Let's move on. CHAIRMAN WALLIS: I'm not sure that a redraft which is zero is acceptable. DR. APOSTOLAKIS: No, he's going to put some words down. Don't worry about it. Move on. CHAIRMAN WALLIS: And we'll have a slug fest between this paragraph -- DR. APOSTOLAKIS: Move on. CHAIRMAN WALLIS: -- and his paragraph. DR. POWERS: We'll move on. CHAIRMAN WALLIS: Sounds good. But you all help me move on, please. PRAs. DR. SHACK: This was the easy part, remember? [Laughter.] CHAIRMAN WALLIS: Everything always takes at least twice as long as you think. DR. KRESS: Well, I think there is some doubt about this second sentence. [Laughter.] CHAIRMAN WALLIS: Which is that? DR. SIEBER: Well, it's not clear that the ASME is going to produce the kind of standard that we might find acceptable. DR. APOSTOLAKIS: Yes; I thought about that, but Graham does not say -- CHAIRMAN WALLIS: It should would help to make the -- DR. APOSTOLAKIS: -- the standard itself will do that. It says the development. DR. SIEBER: I worry about that. DR. POWERS: Well, I think the problem is it's too prominent here. I think this is one of the things that has to be wrestled with: how do you have a PRA that you have some confidence in? How do you review them when they're intractable to review; they're very difficult to review? And the standards debate is a good one. I think that's an item in there. I think we need to begin the discussion by saying look: we have a PRA capability that has proven its worth in one small area. DR. SIEBER: Right. DR. POWERS: We have seen how industry can apply that in that area and learn useful things about plants, okay? We've gone on, and we've learned some disquieting things about plants contrary to what we had thought in the past. The shutdown, fire and external events are all very important contributors to the risk, and our tools aren't up to snuff in those areas, and we need to do the following things, in addition to which we need to have some sort of standards, because it is impossible -- DR. SIEBER: Right. DR. POWERS: -- for the NRC staff to review all these PRAs, even in their limited form now, to the depth of detail that it would be essential to assure that they're adequate. CHAIRMAN WALLIS: Can we leave in the reference to ASME standards, then? DR. POWERS: Yes; it just becomes an item. CHAIRMAN WALLIS: It's not a big deal. DR. POWERS: It's a useful thing. CHAIRMAN WALLIS: Not a big deal. DR. POWERS: Yes; it's a useful thing but it's not -- DR. SIEBER: But it should just really say that a satisfactory standard, a satisfactory, high-quality standard is necessary as the underpinning for all the PRA work and forget about however they arrive at it. DR. APOSTOLAKIS: I agree that a standard will contribute to the wide acceptance of PRA. There is no question about it. DR. SIEBER: Yes, but it's not clear that the current ASME standard does that. DR. APOSTOLAKIS: But if it doesn't say -- DR. SIEBER: I know, but it almost looks to me like an endorsement. DR. APOSTOLAKIS: Not at all. CHAIRMAN WALLIS: Do you want to say of a standard such as the ASME standard? DR. SIEBER: No. DR. APOSTOLAKIS: No; either you say ASME and ANS, because ANS now is involved -- CHAIRMAN WALLIS: Right. DR. APOSTOLAKIS: -- or simply the ongoing development of standards. CHAIRMAN WALLIS: Right. DR. SIEBER: Right. CHAIRMAN WALLIS: Okay; this is wordsmithing. We can sort that out. DR. APOSTOLAKIS: Right; it's difficult. CHAIRMAN WALLIS: You want to say ASME, ANS or -- DR. APOSTOLAKIS: No, it's critical. DR. SIEBER: Okay. CHAIRMAN WALLIS: Okay; well, it's a sentence, though, and when we get to editing, we can say did we want this sentence or not? DR. SIEBER: And just get rid of the -- CHAIRMAN WALLIS: So that's not -- right. DR. SIEBER: -- ASME. DR. POWERS: It seems to me that in this bulleted list, you have to come and wrestle with the issue of core damage frequency versus low risk. If you work in a core damage frequency space, really, the phenomenological models aren't important in that area. We just really don't have many phenomenological models in that area. Things like common mode failure and human error are very important in that area. DR. APOSTOLAKIS: But where does he refer to phenomenological -- DR. POWERS: If you get down to the reexamination of all supporting phenomenological models -- DR. APOSTOLAKIS: Oh, down there, okay. DR. SIEBER: Last paragraph. DR. APOSTOLAKIS: Yes. DR. POWERS: Okay; I think you have to draw a distinction. DR. APOSTOLAKIS: How about LERF? They don't affect LERF? DR. POWERS: LERF is such a stylized thing that, I mean, LERF is, as defined in the appendix to 1.174; it's not something real. DR. APOSTOLAKIS: But if I want to calculate LERF, don't I have to worry about the phenomena -- CHAIRMAN WALLIS: Yes. DR. APOSTOLAKIS: -- in the containment? CHAIRMAN WALLIS: Very much so. DR. POWERS: But only to the extent that it's outlined in Mark's appendix. If you did, the phenomenologists would tell you most of that is wishful thinking. DR. SIEBER: But that's only two mechanisms for external damage, and risk may consist of more than two. DR. APOSTOLAKIS: I don't understand what you're -- DR. SIEBER: CDF and LERF isn't -- what if you think that societal damage consists of -- DR. APOSTOLAKIS: But that's a safety goal issue. We asked them to revisit the thing. DR. SIEBER: Okay; but that's part of this to me. DR. APOSTOLAKIS: Well, maybe you want to say somewhere here that the improvements on PRA should be made, you know, after the goals are defined. DR. SIEBER: Well, perhaps you ought to be able to calculate what happens to the early fatalities and -- DR. POWERS: It seems to me at some point you have to come along and say look -- DR. SIEBER: This is it. DR. POWERS: -- how much capability do I want to have available to me at NRC to calculate the progression of accidents and the dispersal of radioactivity from the plant? Do I want capabilities that are equivalent in the accuracy to what I have for estimating core damage frequency? DR. SIEBER: Probably not. DR. POWERS: That's way more sophisticated than what we have now. Do I want to know some of the general broad features much like what we have right now? DR. SIEBER: Yes. DR. POWERS: That's something. Do I want to just dispense with it all? You have to make those kinds of decisions, because the question that research has to wrestle with is how much money to invest in severe accident research, and right now, they're kind of handicapped. DR. SIEBER: I'm suggesting that they need to ask those questions of themselves -- DR. POWERS: Then? DR. SIEBER: -- and answer them. DR. APOSTOLAKIS: Yes. DR. SIEBER: And that becomes an element in the research program. DR. POWERS: And I think that's the way to handle it. CHAIRMAN WALLIS: Well, how do we fit this in with our draft report? DR. APOSTOLAKIS: I think we need a few lines up front stating that risk-informing the regulations will require certain metrics to be defined such as CDF, LERF and possibly others, that will depend on the commission's safety goal policy statement, which we understand is under revision. Then, I would go on and say that some nicer words, but no matter what, CDF is expected to be there, so the ability to calculate CDF is a given, is a need that is a given, and I think the first five bullets refer to the ability to calculate CDF. So they must do those. Then, you go on and say now, depending on what metrics you want to use to go beyond CDF, you may have to spend significant resources on reexamination of phenomenological models and so on. In other words, you prioritize in some way. CHAIRMAN WALLIS: I don't understand what you're saying. I mean, if you don't understand the phenomena, how can you evaluate CDF? DR. APOSTOLAKIS: But I don't understand -- I don't need to understand the fuel coolant interactions to do CDF, do I? DR. POWERS: No. CHAIRMAN WALLIS: No, but you need to understand whatever these phenomenological models are. DR. APOSTOLAKIS: But you already have it. DR. POWERS: It's a question of depth of understanding: what people understand is that if you uncover the fuel, it will melt on you, and if it melts, you're in a world of hurt. That is not a situation you want to get into. CDF is calculated based on what are success states that will avoid having me getting in to a core damage? And everything else is an unsuccess statement. DR. KRESS: That's right. DR. POWERS: They don't need to understand phenomenology. DR. APOSTOLAKIS: Yes; that's my point. Now, when you define another metric that goes to releases, then, of course, the phenomenon -- CHAIRMAN WALLIS: I don't see how you can evaluate the probability of reaching a success state unless you understand the -- DR. APOSTOLAKIS: What phenomena are you referring to? CHAIRMAN WALLIS: -- phenomena. Any phenomena; whatever happens. DR. POWERS: It's too large of this thing being understood by phenomenological -- DR. APOSTOLAKIS: Yes; that's right. DR. SIEBER: Right. DR. APOSTOLAKIS: I mean, I'm leaving there the thermohydraulic codes. DR. KRESS: That's why we need it -- CHAIRMAN WALLIS: That's why we need a phenomenological model, isn't it? DR. APOSTOLAKIS: Fine. And there, it belongs. But the last bullet of the page is not something that I need to do a CDF. CHAIRMAN WALLIS: You don't need phenomenological models to do CDF? I mean, if you have an absolute -- DR. APOSTOLAKIS: See, most people understand by phenomenological, you know, severe accident kind of -- DR. POWERS: Thermohydraulic is a physical model; it's up in a higher bullet. The thermohydraulic models that you understand is is the core covered, or is it not? DR. KRESS: That's right. DR. POWERS: It's not a very difficult question. DR. KRESS: And that's not very much phenomena in there. DR. POWERS: Right; that's a heat balance. DR. KRESS: And will one pump or two pumps keep you covered? DR. POWERS: Yes. DR. KRESS: I mean, it's not real -- CHAIRMAN WALLIS: Those are phenomena. DR. KRESS: Yes, I know, but they're not -- DR. APOSTOLAKIS: But they're not CDF -- DR. KRESS: It doesn't take much understanding. DR. SIEBER: CDF is not phenomenological, because it -- you need containment leakage or failure to really affect public safety. DR. POWERS: Yes; I mean it's just -- DR. SIEBER: So you need to go up to the next -- DR. APOSTOLAKIS: I think we can talk about the world differently. DR. SIEBER: Yes, right. DR. APOSTOLAKIS: I think Graham comes from the point of view that no matter what you calculate, you have to understand the underlying phenomena. DR. SIEBER: Yes. DR. SHACK: He realizes that thermohydraulics is a phenomenological -- DR. APOSTOLAKIS: But in the jargon, I think the way the rest of us are using it, phenomenological really means the severe accident space, where you get into -- CHAIRMAN WALLIS: You're way beyond me here. Can you fix this up, George? I don't understand what you're talking about, so can you fix it up? This section has been gone around by a lot of people, you know. DR. BONACA: Success criteria, I mean, are based on specific thermohydraulic calculations, and typically, you want to stay away from the FSAR ones, which are coarse, and so, they may be abbreviated or simplified, but you do, if you have a good PRA, you are going to do best estimate calculations. Do we want to have a best estimate -- DR. APOSTOLAKIS: Give me some success criteria. DR. BONACA: Success criteria? DR. APOSTOLAKIS: Yes. DR. BONACA: For example, how many auxiliary pumps I need to remove decay heat with. DR. POWERS: Yes but -- DR. APOSTOLAKIS: I mean, what are the phenomena here? CHAIRMAN WALLIS: Heat transfer; fluid mechanics. DR. APOSTOLAKIS: Sure, but that's not what we mean by phenomenological uncertainties. I don't think we mean that. DR. BONACA: Would one charging pump be adequate, one charging pump rather than low pressure injection, be adequate to maintain -- DR. APOSTOLAKIS: But is that what you understand by phenomenological uncertainties, Mario? CHAIRMAN WALLIS: If you calculate the heat transfer coefficient from this fluid, and you are uncertain about the heat transfer coefficient, you're not in a very good position to evaluate whether or not the core is cool. DR. BONACA: I understand what you're saying. DR. POWERS: Trust me; these calculations are based on energy in, energy out. CHAIRMAN WALLIS: They're based on -- DR. SIEBER: The mass and energy balance. CHAIRMAN WALLIS: Now, wait a minute. DR. SIEBER: Period. DR. POWERS: That's it. DR. APOSTOLAKIS: You say that you want to understand uncertainties in the supporting physical models. Doesn't that cover your concern, Graham? Do you really have to bring the word phenomenological there? CHAIRMAN WALLIS: Sure, you can change the words. DR. APOSTOLAKIS: No, the word is fine as it is. I think the first bullets are fine as they are for CDF. CHAIRMAN WALLIS: So what's the problem? Just change -- DR. APOSTOLAKIS: The problem is the very last bullet at the bottom of the page. CHAIRMAN WALLIS: You don't like the word phenomenological, we'll change it, but I don't know why we're talking so much about this section. Is the section in reasonable shape, or do we have to rewrite it or what? DR. APOSTOLAKIS: No, the section should have some of the flavor that Dana mentioned, that a lot of it depends on what metrics you plan to use. DR. SIEBER: Right. CHAIRMAN WALLIS: We're talking about PRA. DR. APOSTOLAKIS: Yes. DR. SIEBER: Right. DR. APOSTOLAKIS: If somebody told me that risk-informed regulation means core damage frequency based regulation, then I don't need to understand -- do I need to understand reflood? Do I need a reflood research program at Penn State? DR. KRESS: Yes; it's part of the success criteria. What reflood rates you need -- DR. POWERS: It's not built into the PRA CDF codes. DR. APOSTOLAKIS: Yes; not CDF. DR. POWERS: To make it more sophisticated, but right now, the codes go in and say -- CHAIRMAN WALLIS: But that's ridiculous. That's ridiculous. DR. KRESS: It's built into the question of how much -- CHAIRMAN WALLIS: There is no way you can evaluate the likelihood of the core being damaged if you don't understand how it gets cooled when you put water in it. I mean, it's preposterous to make any assessment of probability if you don't understand what happens. DR. POWERS: Well, on a different basis. You're saying you want to understand absolutely, guaranteed, if this happens, will that core become uncovered? And what the regulator has done is he says I don't have that information. I'm not going to have that information in that detail. What I know is that if I do not have this, I am not assured of cooling this, and those are strictly energy and mass balance that are fairly conservatively done. And so, the PRA guy comes along and says okay, those are the criteria; if you're on one side of the line, it's success, and if you're on the other side of the line, it's failure. DR. SIEBER: Yes, red or green. DR. KRESS: Those are things like if I lose this pump and don't gain it back within a certain amount of time -- DR. SIEBER: That's it. DR. POWERS: Then I'm dead. DR. BONACA: If you want to really know, for example, if you -- if you can do bleeder feed in a PWR, that's not an easy thing to do. DR. POWERS: Yes. DR. BONACA: Some plants are so marginal, you get to do really some -- DR. POWERS: Some plants, you can't do it at all. DR. BONACA: No, if you have to do a really detailed calculation with good thermohydraulics because otherwise, you're going to hang your hat on the availability of bleeder feed, and probably, that's going to reduce significantly CDF while you can do it. DR. APOSTOLAKIS: But that's what the second bullet says: uncertainties in the supporting physical models. DR. BONACA: Okay. DR. APOSTOLAKIS: I'm with Graham now. I don't understand what this is all about. CHAIRMAN WALLIS: I don't understand this; there is a proposal by George that we need some lines up front. DR. APOSTOLAKIS: Let me take a crack at it. CHAIRMAN WALLIS: Can you do some lines up front? DR. APOSTOLAKIS: By when? By when? CHAIRMAN WALLIS: By 5:00. DR. APOSTOLAKIS: What? DR. KRESS: That's 10 minutes, Graham. DR. APOSTOLAKIS: No. DR. BONACA: You have 9 minutes. DR. UHRIG: Quit talking, George. CHAIRMAN WALLIS: Otherwise, can we move to the next page? DR. APOSTOLAKIS: License renewal, I don't participate, so I will go and wordsmith. CHAIRMAN WALLIS: Maybe we'll wordsmith words like phenomenological. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Can we move to the next page? I'm not sure that we need the -- should we cut out that whole bullet? DR. KRESS: The whole thing? DR. POWERS: The trouble is I didn't understand what they were. DR. APOSTOLAKIS: Laguna was a movie with what's her name. DR. POWERS: No, no. DR. SHACK: Yes, Brooke Shields. DR. APOSTOLAKIS: That was a lagoon. DR. SEALE: Boy, that's modern. It's a hole, yes; I love it. I think that's a real great way -- DR. POWERS: I mean, the trouble is it refers to this Laguna and didn't tell me which ones they were. CHAIRMAN WALLIS: Let's leave some mystery in this report. DR. POWERS: No, let's not leave any mystery in this report. [Laughter.] DR. APOSTOLAKIS: Let's what? CHAIRMAN WALLIS: Leave some mystery in this report. [Laughter.] DR. SIEBER: We have. DR. APOSTOLAKIS: After all, we are operating -- DR. SEALE: The risk-significant ones may not. DR. KRESS: They're low power and shutdown risks. DR. POWERS: Right, Bob. DR. KRESS: Higher or -- CHAIRMAN WALLIS: I think we can wordsmith that. Any comments on the last paragraph? DR. POWERS: That's what it says. CHAIRMAN WALLIS: The last paragraph? DR. POWERS: Please don't say last paragraph; give me something -- CHAIRMAN WALLIS: Last paragraph of PRA, this one we're so sure about. DR. BONACA: That is a pretty significant statement; I mean, today, if you ask the utilities, they would be horrified to believe that -- CHAIRMAN WALLIS: Well, do we want to leave it in for the sake of wordsmithing it? Do you want to leave it out? What's the overview? DR. BONACA: The task of the regulator. CHAIRMAN WALLIS: I've got some people who loved it; some people who hated this paragraph. Should I just leave it in? DR. BONACA: I'm not saying there's a problem with it; I'm only trying to envision this world where you have a PRA model of the plant and a PRA model here, and people are agreeing on every assumption -- CHAIRMAN WALLIS: I think we leave the paragraph in; then, we debate it when we are wordsmithing. DR. SHACK: My comment was that I thought it was a wet dream. [Laughter.] CHAIRMAN WALLIS: I remove it. DR. POWERS: From the important questions. [Laughter.] DR. KRESS: Teenagers have wet dreams. CHAIRMAN WALLIS: I would remind my colleagues that the court reporter is still here. [Laughter.] DR. POWERS: I guess that I didn't take it as such a pipe dream. DR. KRESS: I agree. DR. POWERS: That, in fact, I think it's entirely feasible even today. DR. KRESS: And I think it would be a very desirable goal. CHAIRMAN WALLIS: Okay; let's leave it in. DR. POWERS: To get that far. DR. SIEBER: Maybe Commonwealth Edison might get there. CHAIRMAN WALLIS: Leave it in for now. Can we move to license renewal? DR. APOSTOLAKIS: There is a comment. CHAIRMAN WALLIS: Yes? MS. MITCHELL: Margaret had a comment that she wrote on this personal computer that everybody can run in a few minutes that most NRC managers are afraid of this; they don't have sufficient understanding to manage such a regulatory regime. I think I agree with her. DR. POWERS: Well, Jocelyn, I think I have a certain sympathy for that comment, but what I know is those managers that have that difficulty now are a dying breed. [Laughter.] DR. POWERS: And they will be replaced by people who look to the computer -- DR. SHACK: What comes out of the computer. DR. POWERS: Yes, that there are so much more computer attuned than people of my age and older are just not prepared for that. It's much like the difference between electrical circuit designers who were trained with tubes and then got transistors versus those who were born with transistors and only got more transistors. DR. BONACA: But I believe that the concern is more about the regulatory regime in which the NRC has access and decision on every single individual element or assumption of that PRA. That's very significant, because there will be continuous interaction and debate at a level that is well below 50.59. I mean -- DR. POWERS: What day? I mean, because we'll have 50.59; why would there? DR. BONACA: Well, because I'm saying that every assumption you have in your model of the plant -- DR. POWERS: I mean, presumably, the NRC will have said yes, this PRA meets the standards, okay? And if it's a very substantive decision, they will have said it's blessed and change it now. I will understand the objection that okay, the plant is always going to have a model that's a little different than the one at the NRC, but it's how you use it there, and I don't see the NRC moving into where they're arguing over valve cracks and things like that or small things. I think it's going to be more a tool for them to evaluate big issues. DR. UHRIG: I think it's more likely that they will have risk meter type systems -- DR. POWERS: Yes. DR. UHRIG: -- as opposed to just the PRA itself. DR. APOSTOLAKIS: In an ideal world, though. DR. POWERS: I suspect they will not look exactly the way the PRA -- DR. APOSTOLAKIS: Well, wait a minute; in an ideal world, the risk meter is based on the PRA. DR. POWERS: Oh, yes, oh, yes, absolutely. DR. UHRIG: That's the point of this. But the point is that the operation of that is totally different than having to deal with the details of a PRA. DR. APOSTOLAKIS: The only thing that worries me about this computerization is that there are so many assumptions that go into these models that I would hate to have people who don't have an appreciation for these assumptions use them. DR. POWERS: Get used to it. DR. APOSTOLAKIS: Well -- DR. POWERS: Get used to it, sir, because that's going to happen. DR. APOSTOLAKIS: I'm going to fight. DR. POWERS: You can resist all you want to. It's going to happen. It's no different than anything else. There are huge numbers of technical details. DR. APOSTOLAKIS: No but -- DR. POWERS: And I haven't got a clue about what's going on in -- DR. APOSTOLAKIS: It is different. DR. POWERS: It is not, George; it's going to happen. DR. APOSTOLAKIS: This is an integrated view of the plant. So if you have people now using computerized models for pieces of it that have certain assumptions, now, all of these assumptions are coming together; plus many other assumptions that are -- DR. KRESS: You're objecting to the risk meter as a -- DR. APOSTOLAKIS: The way things are now, yes. I would like to put a line there somewhere that this capability combined with some knowledge of what the hell is going on -- DR. POWERS: George, what's going to happen is there are going to be people that understand the details, and there are going to be people who are just going to use the product, and there are going to be much more people just using the product than there are those who are understanding the details, and you might just as well get used to it, because that's going to happen. CHAIRMAN WALLIS: That's inevitable. DR. UHRIG: Yes, but 15 years ago, NRC put about something approaching $1 million into development of this type of system to be put out in the field for the resident inspectors in order to give them an independent assessment of judging what was happening in the plant as to whether the sequencing of maintenance was proper or not. JBF Associates was the group that did that. DR. POWERS: I know the guy that did that. DR. APOSTOLAKIS: Yes but -- CHAIRMAN WALLIS: We're very close to the time when I was hoping to take a break to fix up sections we'd discussed, but we haven't finished the report yet. DR. UHRIG: Not good. CHAIRMAN WALLIS: So we move on. DR. POWERS: What you're telling me is that you failed to control the meeting properly. DR. APOSTOLAKIS: To meet your goals? [Laughter.] DR. APOSTOLAKIS: Did you use a top-down approach to define -- DR. POWERS: Yes. DR. KRESS: The PRA -- CHAIRMAN WALLIS: I decline to comment. Let's move on to the license renewal. Comments on the license renewal section? DR. POWERS: Well, this paragraph that begins in some cases I've said gives mixed messages, and do we really know what points we're making? In the next one, I simply say I would argue that this area is in good shape; it's a success story, and we can relax. DR. BONACA: Yes; I provided this. Well, when deciding what kind of research you have to do, you may decide in certain cases that you're better off that you do inspections rather than do research that may not lead you to information only enough to make calls on the issue. That was the intent of that. The other cases, in other instances, it depends on the issue itself. In other instances, you may want to do some research. CHAIRMAN WALLIS: Can we fix this by -- DR. BONACA: Yes, we can. CHAIRMAN WALLIS: -- the editorial process, or is this a major issue we need to debate? Can we fix it later on? Only to reword -- DR. BONACA: I think so; I think so. CHAIRMAN WALLIS: We fix it later on? Anything that we need to restructure at this time about license renewal? [No response.] CHAIRMAN WALLIS: Hearing nothing, I propose we move on to licensee initiatives. DR. POWERS: Well, under license renewal, do we really need to get into the area of irradiation assisted stress corrosion cracking; environmental assisted corrosion? I mean these -- there are programs going on in these areas. CHAIRMAN WALLIS: The bullet at the top of page 11, second bullet. DR. POWERS: Are we going to say anything about them? And are these things important, not important? I mean it looks to me like it's -- I think it is not a major source of core damage. DR. BONACA: Just these areas where we have provided a recommendation in the very recent time by them -- the report went out just a few months ago. DR. KRESS: Well, I envision license renewal to be an over and over and over process, ad infinitum, and somewhere, these issues are going to come out to be important. Maybe it's premature to talk about the research needs now for the current license renewal but maybe for the next time. CHAIRMAN WALLIS: Yes. DR. KRESS: When they do it again. DR. SEALE: Yes, and Murphy's Law says if you shut down these efforts and you get rid of those staff people, you're going to need them in 5 years. DR. POWERS: Well, I mean especially in these areas, with the exception of irradiation-assisted stress corrosion cracking, which has a certain reactor-specific nature to it, so I can believe you might want to have -- but general corrosion, gee, corrosion chemists are a dime a dozen. CHAIRMAN WALLIS: Can we attack this at the editorial stage? DR. SEALE: Yes. CHAIRMAN WALLIS: We may want to change the words or cut it out. DR. BONACA: Or cut it out; sure. DR. POWERS: Well, I'm wondering -- right now, we come down here, and it says -- DR. SHACK: It's supposed to be environmentally-assisted cracking of nickel based alloys, not corrosion. DR. BONACA: That's right. DR. POWERS: We come through here, and we've listed things. DR. BONACA: This is one of the recommendations. DR. POWERS: I mean, the staff has said specifically, we recommend and support include -- I mean, the staff has come in and said they have a nice PTS program that we hailed to all that would listen. I mean, are we just reiterating that? DR. BONACA: This actually, at the end, these four bullets were straight out of the report that we issued 6 months ago. CHAIRMAN WALLIS: Is the debate about whether we need to have bullets at all? DR. POWERS: Yes. CHAIRMAN WALLIS: Is that the real issue here, whether we need to actually highlight certain search areas or not? Is that the issue? DR. POWERS: I guess there is nothing wrong with just citing -- reiterating what we said. DR. SEALE: I guess the comment I would make is we've already independently made the observation, some of us earlier, that this is the one area where it seems that the relationship between NRR and research is collegial and flourishing in terms of intellectual content, and it's also a place where they've got a worthwhile cooperative program with industry, and what we'd really like is to be able to have bullets like these in some of these other areas where it looks like right now, there is just nothing but dead silence. DR. BONACA: I think that something that Sandia would facility here would be I think originally, what I provided was a reference to the fact at the beginning of the bullets that we continue this report, specific research in these topics, as we mentioned in the 1998 report, so that there is nothing new here in any case that makes it clear. But also, it doesn't say that what we told you 6 months ago is not good anymore. DR. SHACK: Since we do change our minds with a great deal of frequency -- DR. BONACA: I thought 6 months was a little bit too fast for changing our minds on all these issues, but I would propose we leave it in. CHAIRMAN WALLIS: Leave it in for now. DR. BONACA: So that the specific -- DR. SEALE: Consistent with our recommendations. DR. BONACA: Consistent with recommendations. CHAIRMAN WALLIS: Okay; it's not a major -- let's move on. Licensee initiatives? DR. BONACA: Under power-up rates, third line down, it says smaller crates have been already approved on the basis of arguments; then, no significant changes in DBAs with a -- I get a sense from the way it's written that it would be a minor effort. Actually, it is not a minor effort. Typically, it is a major effort to upgrade by 5 percent a power plant. DR. SEALE: Yes, it is. DR. BONACA: Major undertaking; many plants have not gone to it because of the cost involved in it; many, many millions of dollars. CHAIRMAN WALLIS: Well, there's a balance of plant; all kinds of -- you've got to change the turbine very often. DR. BONACA: No, no, not physical changes; just simply -- CHAIRMAN WALLIS: The regulatory -- DR. SEALE: The analysis? DR. BONACA: Absolutely; enormous cost because of the ramification of, you know, into everything; it's extreme. You have to go through so many different things. DR. SIEBER: Let me ask a question. It seems to me back in the 1974 time frame, when they had the FAC hearings, that there was litigation that specified exactly how peak clad temperature would be calculated and set out in the settlement of that court case what that temperature would be, and moving from a conservative code to a best estimate code would be contrary to the outcome of that hearing. Is that true or not true? That's my understanding of it, and all those things like 102 percent -- DR. KRESS: They have since passed a new version of Appendix K that sort of does away with that. DR. SIEBER: Well, it does, and it doesn't. The Appendix K is still not a best estimate code, right? DR. KRESS: Well, it gives you the option. DR. SHACK: It gives you the option. DR. KRESS: It gives you the option. DR. SHACK: But it did take a rule change to do that. DR. KRESS: It took a rule change to do it, though. The rule specifies how you use -- how you can use properly the best estimate. DR. SEALE: Yes. DR. SIEBER: I think that there is as much legal research that has to be done as there is thermohydraulic research. DR. SEALE: Well, apparently, it has been done, because they've already approved some. DR. SIEBER: To a certain extent that we're suggesting they do even more. CHAIRMAN WALLIS: Do you agree with the general idea that if you want significant upgrades above a few percent, then it has to be much more research done about what's a real margin of safety, and what's the uncertainty, and how close are you getting to it? DR. POWERS: It struck me that that was really a non-issue, because most of these plants can only upgrade so far, and then, they run into really expensive limits. DR. SIEBER: That's right; equipment. DR. POWERS: And everything that I have seen on these plants says they can go at least that far and not get into any real risk space. DR. SIEBER: Yes. DR. POWERS: So it struck me that this was just -- DR. SIEBER: For us, it was like 4 percent, and then, it got -- DR. UHRIG: Vendors are now, at least on paper, justifying significant major expenses, including high pressure turbine replacement, with increased capacity. DR. POWERS: That's what I call a really expensive complement. DR. UHRIG: Yes; but I don't know of anybody who -- yes, I think there is one utility who has committed to do that, to replace their high-pressure turbine. DR. POWERS: Fermi's doing it at the next outage. DR. UHRIG: What? DR. POWERS: Fermi's changing their high-pressure turbine next outage. DR. SIEBER: But they screwed up their turbine and have to do something. DR. BARTON: Not the high-pressure turbine. DR. POWERS: You have to go forward; you can't go back. DR. SIEBER: Now they wiped out their low pressure blades. CHAIRMAN WALLIS: So where are we on this? DR. POWERS: It looked to me like it was just not very important compared to other issues because -- DR. SIEBER: Right. DR. POWERS: -- before anybody got into big-time risk space, they're going to have to make real big changes in the plans. Now, highlighting that, because certainly, Farouk brought forward to us a research program where he's looking at his higher heat transfer rate cores, I thought that was just a heck of a good, forward-looking program, because I can fully imagine, you know, once you're going to bite the bullet and do those things, then, you're going to need fuel that gets you more heat, because you can't make the core any bigger. So I thought that was an excellent, forward-looking thing. So if we could transfer it and bring in these thoughts like Bob just brought up on these high-pressure turbines and things like that and say the issue is not these things that we're proving kind of routinely with the existing structures; it's really the issues that research ought to be looking at is what are the possibilities of much bigger changes, more than a few percent? Because I see the little ones that they can do with existing structures just don't seem to get into risk space at all. DR. BONACA: Really, are we envisioning a lot of power upgrades? Because I really don't envision almost any. CHAIRMAN WALLIS: I thought that was the drive behind these best estimate codes; instead of all of these conservative assumptions, we're going to do best estimate, and that's going to show that really, it's far saver than you thought; therefore, up goes the power. DR. BONACA: For certain plants, they're running at 100 percent because of what's happening to fuel. I mean, there is really an issue with flow or mixing and a lot of other -- particularly the Westinghouse plants have had failures, and people are backing off from aggressive loading patterns at full licensed power. CHAIRMAN WALLIS: Do you think that power upgrades don't require research; that the is sis not an important one? DR. BONACA: Well, if, in fact, there would be a number of applicants, then, it is an issue. I'm only saying that I don't foresee that there will be a lot of people taking advantage of this; maybe 1 percent, 2 percent because of that -- DR. SIEBER: So that's one or two plants is what you're saying? DR. POWERS: I think it's the things like Bob's talking about or these things that Farouk is researching; those are the ones they upped -- the research has got to be on its toes looking ahead for, because if those things happen, then, you're really changing the structure of the plant, you know, and we really don't know how to handle it. That's what the issues are right now. DR. UHRIG: Specifically, ABB combustion. DR. POWERS: No. DR. UHRIG: They're the one who is promoting this. DR. POWERS: Sure. CHAIRMAN WALLIS: You don't think that with the existing plant, there are so many margins in there that really upgrade quite a lot? DR. POWERS: Well, what I think is that the existing regulations cover it well enough. CHAIRMAN WALLIS: You think they do? DR. POWERS: Yes; I just haven't seen any real big problems. Tom, you've looked at it closer than I have. CHAIRMAN WALLIS: I can see them coming in with a new code which says our new code which is not conservative; it's much more realistic; and it predicts that these temperatures, instead of being up at 2,000, are 1,000. DR. POWERS: Yes, I know. CHAIRMAN WALLIS: Tremendous margin of -- DR. POWERS: But the thermohydraulics committee will look at that and say they can't document it; it's user-unfriendly. DR. SEALE: The code don't work. DR. POWERS: They've screwed up their equations, and it will never happen. DR. BONACA: The ramification that you have is that what you have to do is so enormous, that's what the biggest issue that there is is that you have to change so many things in the plant because you're upgrading. CHAIRMAN WALLIS: Do you want to leave in anything about power upgrades in this report? DR. KRESS: I think the research that's needed there does have to do with just what is the definition of a good best estimate code -- DR. SEALE: Yes. DR. KRESS: -- and what is the acceptability of it. I think that will be an issue. CHAIRMAN WALLIS: It could be an issue. DR. KRESS: Even though they can do them all. DR. POWERS: I guess I agree with you. DR. KRESS: But the best estimate codes is how they will show that they meet the regulations currently, and I think there is an issue there. DR. SEALE: The people at Palo Verde, when they had to derate their reactor exit temperature to suppress that corrosion mechanism they had in Unit II -- DR. SIEBER: Right. DR. SEALE: -- by about 15 or 20 degrees got the power back, but they did it with the other two units, too. They got the power back by opening up the steam inlet valves on the turbines. DR. SIEBER: Right. DR. SEALE: And they said at the time that the potential was there to get a little bit more by opening them full but that the next big step for them was to redo the first two stages on the high-pressure turbine. DR. SIEBER: Right. DR. SEALE: And that would let them talk about 15 percent or something like that. DR. SIEBER: Reblade and nozzle blocks, yes. DR. KRESS: And I think some of them are going to find that well worthwhile. DR. SEALE: Yes, yes. DR. KRESS: And it is those big changes that are going to -- DR. SEALE: Yes; if you drop off 20 degrees and get it back and then get some more; that's -- DR. KRESS: Those, I think, may start becoming risk-significant. I think Dana is right about -- you know, there is a need for some research on what a best estimate code is and how acceptable it is, but I don't see that as a big deal. CHAIRMAN WALLIS: Let me ask the committee: I've been asked if we're likely to go through this line-by-line. I think not. So I think that the folks who would help us go through it line-by-line can be sent home; is that okay? DR. APOSTOLAKIS: I revised the probabilistic risk assessment. It will take me a minute to tell you what I did. CHAIRMAN WALLIS: Well, no, what I would like to do is at least today, I would hope that those of you who are going to help rewrite the document would do that today. DR. APOSTOLAKIS: I just did it. CHAIRMAN WALLIS: And that that would go to Med, and whenever we pick this up again, we go line-by-line; we have a new document that -- DR. APOSTOLAKIS: Right. CHAIRMAN WALLIS: -- addresses the major concerns raised today. DR. APOSTOLAKIS: But my point is I changed it significantly. So maybe -- DR. POWERS: Well, George -- [Laughter.] DR. POWERS: -- the tradeoff you've got is this: yes, we can go back and go over yours; that will only delay us from getting through the rest of it. CHAIRMAN WALLIS: I don't think we should go back and go over it. DR. POWERS: Right. CHAIRMAN WALLIS: I think you should give it to Med; you've listened presumably to what your colleagues said as well as what you thought; you've come up with a synthesis. Let's debate that next time around. DR. KRESS: It's non-synthesis, he says. CHAIRMAN WALLIS: What? DR. KRESS: It's a non-synthesis, right? CHAIRMAN WALLIS: I think that's what we have to do. Otherwise, we'll take forever with every -- DR. APOSTOLAKIS: Yes, but, I mean, I'm making changes of the nature that we have been discussing all afternoon, and now, we're saying no, we're not going to discuss those changes; that's fine. CHAIRMAN WALLIS: We'll have another opportunity. DR. SEALE: We ought to go ahead and finish up the first cut on all of it, though. CHAIRMAN WALLIS: All right; I still want to find out what to do with power upgrades. So do you think there should be something about -- DR. SEALE: Leave it like it is. CHAIRMAN WALLIS: Leave it like it is, after all that discussion? DR. POWERS: I am opposed to the way it is. CHAIRMAN WALLIS: Can we have someone who will work on reviewing it? DR. POWERS: I will work on it; I will not give you anything today. CHAIRMAN WALLIS: So Dana is going to improve the power uprates. DR. BONACA: I'll give you some changes. DR. POWERS: And I'll feed things to you, Bob. CHAIRMAN WALLIS: So Bob Uhrig? DR. UHRIG: All right. CHAIRMAN WALLIS: And Uhrig will be responsible for -- DR. UHRIG: I'll take a crack at that. CHAIRMAN WALLIS: Okay. DR. APOSTOLAKIS: So we're going to see a new document? CHAIRMAN WALLIS: I don't know what to do personally. DR. UHRIG: Tomorrow or whenever. CHAIRMAN WALLIS: Do you want to say something about synergistic safety issues? That's the second paragraph on the power upgrades. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Okay. DR. APOSTOLAKIS: That is good. CHAIRMAN WALLIS: Fuels; Dana has offered to rewrite the fuels part. [No response.] CHAIRMAN WALLIS: Is that okay? Reduction of margins. Any comments on page 12? DR. POWERS: Well, it seemed -- it seemed to be a hobby horse area where you dumped a bunch of things in there, and I'm wondering if that's the right title for it. DR. UHRIG: Right. DR. POWERS: I mean, you're getting in here; you've got PTS and other things all kind of mixed together, and I'm wondering if you really want to do that. DR. UHRIG: What would you do? Put a PTS for the first two paragraphs and then put reduction of margins? DR. SIEBER: Reduction in margins is a better word. DR. POWERS: Well, in this paragraph that says when the staff speaks of margin, I just really didn't understand. CHAIRMAN WALLIS: That's being rewritten. You don't have the new version? DR. POWERS: What is that? I'm sorry? CHAIRMAN WALLIS: You don't have the new version? DR. POWERS: Apparently not. CHAIRMAN WALLIS: I don't know why you -- DR. POWERS: I have the version you sent me. CHAIRMAN WALLIS: No, but we've got a new version since then which we are all looking at, I think. DR. POWERS: All my comments are on a version. [Laughter.] CHAIRMAN WALLIS: The version that we're looking at, particularly that part that you mention is being completely rewritten. DR. APOSTOLAKIS: I'm looking at the version dated November 17 from Med El-Zeftawy. MR. EL-ZEFTAWY: Right; that's the one. DR. APOSTOLAKIS: Okay. CHAIRMAN WALLIS: It's a rather -- DR. POWERS: Okay; I don't know how to handle that. I mean, you've got a version written in a type that's too fine for me to read, and I've got comments on another version. DR. SHACK: That particular one is so different that -- DR. KRESS: I'd just throw away the other version. DR. POWERS: It's so different that I don't even see where I am here. CHAIRMAN WALLIS: Well, I suggest that you give your comments to Dr. Kress, who is really the main author of this part. I've already rewritten according to Dr. Shack. DR. POWERS: Okay; well, I guess in looking at it, my question is and? What is the point being made here? CHAIRMAN WALLIS: Well, we have to come up with an improved version, and if there are some debateable items we all need to discuss, then, we should address it today. DR. POWERS: This paragraph beginning safety margins, the deterministic regulations are provided by choice of acceptance values that -- acceptance values of these metrics. I'm not sure I understand the sentences, but I'm wondering where are we going with this? What are we telling them to do? CHAIRMAN WALLIS: We're saying that the bottom line is, as the agency moves more into risk-informed -- bottom paragraph -- the need for more clearly defined margins of safety will become acute. As the licensees start pushing the envelope, the NRC has got to be clearer in just where it needs to take a stand; what sort of margins it's going to give up for what reason. DR. SHACK: I couldn't understand it either, because you can change those acceptance values over dead bodies sort of thing. DR. POWERS: Yes; I'm aware of that. 2,200 degrees; that's there forever. This, I thought, was wrong. This may not say anything right. That was sort of where I come. CHAIRMAN WALLIS: Let me go back to something more fundamental. Is it not an important issue for the agency to know what margins of safety are and under what circumstances there can be changes in those margins and be clear about this? Isn't this something that we have come up against many times in our decisions? There needs to be proper measures of these margins and awareness of how big they are and how small they can be and not just a kind of negotiation with words? DR. POWERS: If there is no negotiation with words, there will be no acceptance of that. 2,200 degrees F is there by -- CHAIRMAN WALLIS: It may well be that 2,200 degrees is not a very good measure of public safety. DR. POWERS: 2,200 degrees F is not 2,201 degrees F. I mean, it's as precise and as quantitative as you can get. DR. SHACK: Mark, as your notion that these are vague, waffling things. CHAIRMAN WALLIS: No, I said risk-informed regulatory system may come back and say it's not cast in granite; you know, it could be 2,250 for good reason. DR. POWERS: Or it might ought to be 1,500. CHAIRMAN WALLIS: Yes; maybe it ought to be set at less. DR. POWERS: Yes; but you're talking -- DR. KRESS: And the tools you use to calculate it with. DR. POWERS: You're talking a long ways down the pike here, aren't you? DR. KRESS: I guess. DR. SIEBER: Based on the valuation of the tools, it has gone up and down and up and down four or five times this year; not the 2,200 but what is extrapolated from your plan. DR. POWERS: Yes; I mean, you can waffle around and go up and down in there all you want to. DR. SHACK: Changing 2,200 -- DR. POWERS: Ain't going to happen. [Laughter.] DR. SIEBER: No, that's -- DR. POWERS: But, I mean, Graham is similarly right. If I went to a risk-informed area, that 2,200 would probably not even be the regulation, unless all you're doing is putting a risk-informed patina over the existing rules. CHAIRMAN WALLIS: This is what is stopping risk-informed regulation DR. POWERS: Stopping it? CHAIRMAN WALLIS: It's clinging to these numbers whose rationale has been forgotten. DR. APOSTOLAKIS: Which one is the offending sentence again? I'm lost. CHAIRMAN WALLIS: I don't know. DR. APOSTOLAKIS: Oh, you don't know? [Laughter.] CHAIRMAN WALLIS: I'm tempted to move on, but I don't know where we will be next time we visit this. MR. EL-ZEFTAWY: Well, I think we still have tomorrow. DR. APOSTOLAKIS: We don't have tomorrow. How can we have tomorrow? CHAIRMAN WALLIS: There seems to be an issue here about the whole idea. DR. APOSTOLAKIS: Tomorrow night? DR. SHACK: Well, I think in the long-term, it's right. I mean, there is nothing that says that those acceptance values are written in concrete; it's just that, you know, it's not just a matter of calculational tools. I mean, it would take, I think, a great deal of research to justify change. Maybe some of them could be, and some of them couldn't be, but it's a large -- it's a large thing to bear off. DR. KRESS: Well, there is another issue, and that is when they just completely void a risk-informed regulations, the license is granted on the basis of the calculations of the design basis accidents; it's granted on the basis of the code calculations made by the licensee applicant, and they calculate a value for some metric that is different and lower generally than the acceptance value. And the question is is that number sacrosanct? And can they increase that all the way up to the 2,200, say, by better tools or better calculation or a change in input values or some change to code? And I don't think we're in good shape to decide on those issues. DR. POWERS: As long as they don't introduce a new accident type or create additional risk. DR. BONACA: 50.46 has very, very prescriptive requirements. What I mean is that you cannot change the model without informing the NRC. DR. SIEBER: That's right. DR. BONACA: Using the same model, you cannot increase temperature by more than 50 degrees without informing the NRC. DR. SIEBER: Right. DR. BONACA: So you have very, very controlling -- DR. KRESS: I know but suppose I say I want to do something, upgrade my power, until my new calculations -- I didn't change my code at all; it says now, I'm only 20 degrees below my 2,200, whereas before, I was 150 degrees. DR. BONACA: As I mentioned, if you went up to 50 degrees, you have to report it to the NRC. DR. KRESS: Okay; I'm reporting it. DR. BONACA: You're telling them -- DR. SEALE: Or suppose they say okay? DR. BONACA: And they are going to come in and review it. DR. SEALE: Or suppose they said my best estimate calculation is the same, but I haven't done it the same way; I've done it this different way because I know better how to calculate what my margin is? CHAIRMAN WALLIS: Reduction in uncertainty is the main message at the beginning. DR. SIEBER: But the real question is whose job is it to do the research to develop the new code or look at the margins? And it's the applicant as opposed to the NRC. The NRC would be doing it on spec. CHAIRMAN WALLIS: What does the NRC do when an applicant comes in and says we've done all this risk-informed work, and we've now shown that you don't need this 2,200 degrees; it should really be 2,250? DR. SIEBER: 2.206 and ask for a rule change. CHAIRMAN WALLIS: Then, what is the NRC going to do? DR. SIEBER: And be prepared that they would process it according to that, but you would be prepared for potential litigation. CHAIRMAN WALLIS: They may need to do some research. DR. SHACK: I mean, the more likely circumstance is the one that Tom posed, is that you redid the calculation in some way that, you know -- DR. SIEBER: That's right. DR. SHACK: That you really didn't come in to change the 2,200. DR. SIEBER: No; that would be the last thing that you would do. CHAIRMAN WALLIS: But you're not so conservative in your calculation, right? DR. SHACK: Right, and then, the question is how does the NRC evaluate that? DR. KRESS: Whether it's acceptable or not. DR. SIEBER: Yes; they would go and inspect the model and look at the benchmarks and -- DR. BONACA: The model is untouchable for the moment in which you get the license, and if you want to have a change in the model, you have to go for a license amendment. DR. SEALE: That's right. DR. BONACA: So, first of all, that's why you rely on a vendor, because the vendor has to work for years to have a special effects analysis and comparison and benchmarks determined by the model. So once that is in place, all you can change is that input. DR. SEALE: That's right. DR. BONACA: So your input may be a change in temperature; may be a change in pressure; may be a change in power level. DR. SHACK: But just to address Tom's question, if you do have a validated model that's acceptable, you can move up if you meet the regulations. DR. SIEBER: Right up to 2,199. CHAIRMAN WALLIS: The NRC decided they should validate the model. DR. KRESS: Well, I don't know that you can, because the value that was calculated by the original model was, according to Jocelyn, based on judgment that that model has certain uncertainties in it, and therefore, we like this margin, and we approve this design and this acceptance value based on that margin, and just because you're going to do something different is no reason to say you can eat up that margin all the way to the thing. DR. BONACA: That's why there is the 50 degrees. CHAIRMAN WALLIS: Well, I go back to George's question: where are the offending words here? We're writing a document. We can still call NIDA about these things, but are there some offending words or ideas in this section that need to be fixed? Can we put it through the line-by-line, everything? DR. APOSTOLAKIS: Now, I have another thought that I don't know whether it belongs here or not. I get the impression that these safety margins are set in isolation of each other, perhaps. I mean, when you set a margin on the temperature, for example, the fuel, then, aren't there many other safety margins that are set at lower levels that are not necessarily consistent with that top margin? I mean, they are on top of everything else, aren't they? When you calculate success criteria and all that for systems. No? That's not true? DR. SIEBER: The 2,200 degrees has a regulatory margin built into it. In other words, the real temperature is higher. And then, the model has conservatisms also, which you can justify removing to some extent. The number is fixed. Now, the question -- you end up with about 20 different parameters to define the space that you're in; people usually trade one for the other. DR. BONACA: But you're conservative at that level as well. DR. SIEBER: And every one of them has a regulatory margin -- DR. BONACA: That's what I'm saying. DR. SIEBER: -- associated with it. DR. BONACA: Yes. DR. SIEBER: And you're in a box. DR. BONACA: Right. DR. SIEBER: In a multidimensional box. DR. APOSTOLAKIS: I mean, is that the self-coherent system there? The margins? Probably not. Now, is there any connection, any connection between defense-in-depth and safety margins? Should the fact, for example, that in some instances, I require a one out of three system, should that affect the margins at all? Right now, I'm under the impression it does not; that there are two different principles that are implemented independently, and my question is whether that is wise. DR. BONACA: People are overlapping, you know, the process has been so incoherent. There's an overlapping of margin here, margin there. DR. APOSTOLAKIS: I understand the incoherence, but I'm trying to understand whether you agree that it is incoherent. DR. SIEBER: Oh, I do. DR. APOSTOLAKIS: Should there be a connection between defense-in-depth and safety margins? DR. BONACA: The only way you could do it was to use PRA. DR. APOSTOLAKIS: But there should be a connection. DR. BONACA: Because you have a coherent process there that -- DR. APOSTOLAKIS: Yes, but you agree that there should be a relationship. DR. SIEBER: Or could be. DR. APOSTOLAKIS: I mean, depending on the level of redundancy I'm using, I should be able to reduce individual margins. DR. BONACA: Yes, it would be better, in fact. DR. APOSTOLAKIS: Sure. DR. BONACA: And then, you could then reduce them more coherently, because you would have an understanding of the relationship. DR. APOSTOLAKIS: Yes. DR. BONACA: Right now, I think the reason why there is caginess about reducing margin of this is that you don't see, in fact, those kinds of correlations. DR. APOSTOLAKIS: That is correct. DR. BONACA: And you are concerned that if you reduce the margin here, you may affect something where you don't have as much -- that's our issue. DR. SIEBER: Yes; I always sort of looked at the regulatory margin as reducing the uncertainty as opposed to changing the probabilistics of it. DR. APOSTOLAKIS: Let me give you an example. What if somebody said I am willing to design a reactor where the limit for the temperature is not 2,200 degrees; it will be 1,100, not 1,200. And I will demonstrate to you that I have done that, but then, I want you to allow me to remove the containment. So I'm putting a bigger margin in the fuel temperature, but in return, I don't want the containment. Would that fly? Can I trade off margins versus defense-in-depth? DR. BONACA: In the current system, no. DR. SIEBER: No. DR. BONACA: Never. DR. APOSTOLAKIS: Would it make sense ideally, though, to do this, to do such kinds of tradeoffs? Put more defense-in-depth and reduce the margins or vice-versa? MS. MITCHELL: I think that the 2,200 degrees is a very bad example for you to use in that particular case. DR. APOSTOLAKIS: Okay; let's find another one. MS. MITCHELL: The way the 2,200 degrees came about was sort of I have 95 percent confidence that 99 percent of the time, I will not embrittle the cladding. DR. APOSTOLAKIS: Okay. MS. MITCHELL: So that when it refloods, I have a high probability of losing the coolable geometry, okay? If it's embrittled clad when I reflood it, it will shatter and end up in a non-coolable geometry and therefore go to core melt. So that is a -- for the first few seconds of a large break loca where the core will -- the level will go down and then will reflood, I don't want to have any possibility of oxidizing enough of the cladding that it becomes embrittled. DR. APOSTOLAKIS: Now, if I reduce that -- MS. MITCHELL: But there are an awful lot of other accidents where I ain't ever going to reflood the core, so 2,200 degrees doesn't mean anything. So therefore, I can't assure 1,100 degrees because I have all of these other accidents for which I need the containment where I didn't reflood it. DR. KRESS: The 2,200 is -- DR. APOSTOLAKIS: Let's not -- CHAIRMAN WALLIS: We're going to have to come back to this topic. I think we're roaming around all over the place, and I still don't hear anything specific about this section. DR. APOSTOLAKIS: Well, I am asking them to quantify safety margins, and I'm saying is there a broader issue here in a risk-informed environment of looking at all of these tradeoffs that involve defense-in-depth? CHAIRMAN WALLIS: More clearly define the margins of safety, yes; we're asking for it here. I think it's covered here. We're saying a need for more clearly defined margins of safety. DR. APOSTOLAKIS: If the committee agrees that such tradeoffs can take place, I would like to see the words defense-in-depth explicitly given there. DR. BONACA: Are you asking if the committee agrees that we should have the ability of changing -- DR. APOSTOLAKIS: First of all whether it's a reasonable point. I don't know. Maybe you guys say no, they are two entirely different spaces. DR. BONACA: No, no, I'm only asking you. Are you asking if we should be able -- DR. APOSTOLAKIS: Yes. DR. BONACA: -- if we would like to see an environment where we can -- DR. APOSTOLAKIS: Yes. DR. BONACA: -- make tradeoffs or what is possible today? DR. APOSTOLAKIS: No, no. DR. BONACA: Today, it is not possible to trade off. DR. APOSTOLAKIS: Whether we should get in the environment where tradeoffs of this kind should be possible. DR. BONACA: Unfortunately, the containment example gives me trouble. CHAIRMAN WALLIS: I think it's covered by the -- DR. SHACK: We've already written the letter, George, that says we should do that. We've written a letter that says we should do that. CHAIRMAN WALLIS: I want to move on, really. This is getting out of hand. DR. APOSTOLAKIS: The tradeoff is important. CHAIRMAN WALLIS: I don't think we're getting anywhere with this. DR. APOSTOLAKIS: Okay; fine. CHAIRMAN WALLIS: Are there specific things, you have to tell Tom that they should be included; they can be debated. The main issue about being more specific about margins and evaluating margins I think covers a lot of what we're talking about here. So not seeing that we're converging on changes in the document, I'd like to move on. DR. APOSTOLAKIS: All right. CHAIRMAN WALLIS: New technology. DR. APOSTOLAKIS: I think it's fine. DR. UHRIG: Good. DR. APOSTOLAKIS: Good. CHAIRMAN WALLIS: GSIs; do we need to say anything about GSIs? DR. APOSTOLAKIS: What is this now? CHAIRMAN WALLIS: Top of page -- DR. APOSTOLAKIS: Generic safety issues? CHAIRMAN WALLIS: Okay; leave it in. Effects in the field? DR. APOSTOLAKIS: Now, again, I thought the idea was not to put statements like we are pleased that the staff is making progress. If you don't have anything to say on generic safety issues, just leave it out. Isn't that the idea of the whole document? DR. POWERS: I really honestly think that the GSI can be left out, because they really have gone to a new system. I know -- there are only what? Seven GSIs left on the books? CHAIRMAN WALLIS: There's a proposal to remove this altogether. Is that -- DR. POWERS: It's a small number. CHAIRMAN WALLIS: Does anyone wish to debate this proposal? DR. SEALE: Well, on the other hand, 5 years ago, there were 12. CHAIRMAN WALLIS: Would anyone regret it if we left out this -- [No response.] CHAIRMAN WALLIS: Okay; take it out. Effects in the field? Do you want to say more, or is this adequate? DR. APOSTOLAKIS: I think this is a good thing, because I think this is one of the best things the agency is doing. CHAIRMAN WALLIS: There might be a move to kill it; so we want to support it. Maybe think about whether we need another sentence or two. International programs? DR. POWERS: Let's see; you cite the ARTIS program. That's not an NRC program. CHAIRMAN WALLIS: ARTIS is out. ARTIS is out. DR. APOSTOLAKIS: What is out? CHAIRMAN WALLIS: ARTIS, Swiss ARTIS experiment is out. DR. APOSTOLAKIS: Why is it? CHAIRMAN WALLIS: Because it hasn't really happened. DR. APOSTOLAKIS: There is nothing on the Halden reactor. CHAIRMAN WALLIS: I noticed that, yes, but I asked Gus, and he said, well, it's not really that important. DR. APOSTOLAKIS: Halden is not important? DR. POWERS: Well, it's one that -- if we've got something to say, we ought to say it on that, because historically, the NRC has participated in the Halden effort. They have contributed a share of the funding that they are now, by dint of outrageous fortune, being forced to drop, and, of course, the question comes up: is it a good idea to do that or not? Halden addresses four topical areas that are pertinent to the research program, and I'm not sure I can do them off the top of my head accurately, and maybe Bob can help me. They do fuel work; they do man-machine interface work; they do -- CHAIRMAN WALLIS: I&C. DR. UHRIG: I&C. DR. POWERS: Materials irradiation and digital systems. Is that -- DR. UHRIG: Basically; they also do a lot of work -- I guess it's really the human factors. DR. POWERS: Or at least man-machine interface. DR. UHRIG: Interface. DR. POWERS: Interface, I guess they would call it. They call -- they say they're getting into more human factors type of stuff, but the stuff we saw at our last meeting was pretty primitive stuff. It was much more sophisticated in the man-machine interface area. Now the question is -- DR. UHRIG: They're also into virtual reality. DR. POWERS: Yes; they've got this virtual reality sort of thing that's kind of neat. CHAIRMAN WALLIS: So do we need a paragraph on the Halden work? DR. APOSTOLAKIS: I don't know. DR. POWERS: I think it would be very useful for them, because Don and Bob went over to a previous meeting, and they came back and said they're going to take a look at this, and Don Noor had four or five questions that he thought ought to be addressed. And so, this last time, I went and I tried to address these questions. What I saw and heard, I discussed with various people and what they were using it for is some research on fuels that Ralph told me was generating absolutely crucial data for their FRAPCON code, that they, you know, this was normal operational data for fuel, to be sure, but it was very crucial as input. They're doing -- they provide neutrons for some programs that Argonne comes up; they're just a neutron source. DR. SHACK: Well, but they also get access to the research that they're doing under a cooperative effort. That's an unfair characterization, that Halden itself does IASCC research. You know, they do Craccode and -- DR. POWERS: Yes; and NRC treats them as a neutron source but also as a source of whatever the results of their information. I saw the stuff on the man-machine interface, they really do quite a lot of stuff that I would have thought the nuclear industry would be very interested in. I didn't see much pertinence to the regulatory mission; in fact, very little at all. I chatted with a couple of people, and I came away with the distinct impression that these kinds of investigations were of great interest to countries that had small nuclear programs; that countries like Germany and France did their own thing and really didn't care what Halden was doing. I don't know that that's accurate, but it's the impression I got. And as I say, the human factors stuff left me very cold otherwise; the classic human factors stuff. I mean, it just didn't seem -- they did a big study and came up and found out that people working on graveyard shift aren't as effective as people working on the daytime shift, and I said -- DR. APOSTOLAKIS: Is the length of the telephone cords there 27 inches also? DR. POWERS: No, I don't think so. That's not the kind of thing that -- CHAIRMAN WALLIS: I'm going to propose that Professor Uhrig, who I think has already written about the Halden, draft a paragraph for us on Halden. DR. UHRIG: All right. CHAIRMAN WALLIS: I just still wonder if it's appropriate to give that much visibility to Halden compared with other work. DR. POWERS: In the spirit of being useful to the NRC management, because they're going to have to make decisions that are undoubtedly not going to be pleasant for one side or the other, I think they would appreciate anything we may make things at least easier. CHAIRMAN WALLIS: So, Bob, can you supply a paragraph to fit in here and gather information? DR. UHRIG: Well, I guess I have my prejudices here. CHAIRMAN WALLIS: I have no idea, so I can't do anything. DR. UHRIG: I put this down on paper a couple of months ago, but basically, we are approaching the limit of what we can do with training people, and the big jump is to automation, and we're not going to make that, so the intermediate jump, which is the area that they're working on, is computerized procedures; computerized systems that assist the operators, and the question is is this useful? The point Dana makes is this is of great use to the utilities, but it's not a regulatory issue. Am I stating your position fairly? DR. POWERS: Yes. DR. UHRIG: And I don't know if we want to get into that or not. CHAIRMAN WALLIS: Well, if you can't write it, who can? If we're going to say something about Halden -- DR. UHRIG: Well, let me take a crack at it. CHAIRMAN WALLIS: Okay; so, you will write it. The issue that was raised earlier was about the leadership taken by NRC, which was a subject that we address here. Do you think we need to talk about the leadership role, or should we avoid the issue altogether? DR. POWERS: I just didn't see it being an issue. CHAIRMAN WALLIS: It was suggested by some committee members. That's why it's there. DR. POWERS: And yes, the U.S. is not the leader in every field nowadays, but is that bad? DR. APOSTOLAKIS: Is that a research issue though? I don't think so. That's a policy issue that somebody has to -- I mean, the White House is getting involved in this and, yes, the President's Committee of Advisers, they made a big deal about that. CHAIRMAN WALLIS: Would you be happy to cut out the paragraph? DR. APOSTOLAKIS: So it's at that level. CHAIRMAN WALLIS: Would you be happy to cut out the paragraph? DR. APOSTOLAKIS: I don't know what paragraph that is, because I don't see it. CHAIRMAN WALLIS: The second paragraph. MR. EL-ZEFTAWY: The second paragraph. CHAIRMAN WALLIS: In the current budget, reactive mode to programs and -- MR. EL-ZEFTAWY: International programs. DR. APOSTOLAKIS: Oh, yes, yes. CHAIRMAN WALLIS: Do you want to cut that out, the consideration of leadership? DR. UHRIG: I think it contributes something. DR. APOSTOLAKIS: Yes; it's different. CHAIRMAN WALLIS: Do you want to leave it in just to debate? [Chorus of yeses.] CHAIRMAN WALLIS: Anything else about international programs? DR. SHACK: This is just a question of whether you get the information that you need. CHAIRMAN WALLIS: That's right; right. DR. SHACK: It's not leadership for the sake of leadership. CHAIRMAN WALLIS: I think that we should just -- if it's the right way to get the information we need, that's the thing to do. That's the main message. The summary at the end here. DR. APOSTOLAKIS: Leadership, leadership. CHAIRMAN WALLIS: Summary at the end? DR. APOSTOLAKIS: I don't think it's a summary. CHAIRMAN WALLIS: It's not a summary. DR. APOSTOLAKIS: You might say concluding remarks. It's not a summary of the report. Concluding remarks is different. We have noble intentions, and we've done these things. CHAIRMAN WALLIS: We change the title here to be -- DR. APOSTOLAKIS: Concluding remarks. DR. SIEBER: Postscript. CHAIRMAN WALLIS: Epilogue or something? DR. POWERS: Epilogue, yes. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: A good play needs no epilogue, said Shakespeare, right? Now, let's go to the ending. We haven't got where I wanted to be today, but we've got somewhere. DR. APOSTOLAKIS: I think we've got a hell of a lot. CHAIRMAN WALLIS: Well, we've had a lot of talk, but now, we have to actually get some words down. DR. POWERS: I was distressed to see nothing on the fire program. CHAIRMAN WALLIS: Well, there's nothing specific on many things. Does it fit in one of the categories here? DR. KRESS: PRA. CHAIRMAN WALLIS: PRA or -- DR. APOSTOLAKIS: Well, fires are mentioned under inadequacies of some of the probabilistic models. DR. POWERS: Yes, but we had a fellow go through and take a fairly exhaustive effort to prepare a research program in fire risk assessment, and we really haven't had a subcommittee meeting to look at it, but I certainly looked at it and critiqued it, and I think given the level of effort that they expended on it, it was certainly an effort, a program worth commenting on. CHAIRMAN WALLIS: There were some other programs too like -- DR. APOSTOLAKIS: Yes but -- DR. POWERS: And the other thing is that the OMB has been regularly communicating with us on this particular area. Our previous research report criticized the fire protection research area, and they're calling to ask if it's okay now. CHAIRMAN WALLIS: Well, this goes back to the beginning of the report here. We said that we reviewed these areas in the previous reports, and then, we had this business about the programs were ongoing and the comments being valid, and folks wanted to rewrite that; there was some suggestion that we should revisit some of these areas, which would cover your fire. Do we want to revisit some of these areas in the previous reports? That means digging them out and deciding what to do. It's a whole new task. DR. APOSTOLAKIS: Oh, yes. Are we going to write any letter on this fire program anytime soon? DR. POWERS: No; right now, our intention is that it will come up in our fire subcommittee meeting to be held in February. DR. APOSTOLAKIS: And then, there will be a full committee briefing and a letter or -- DR. POWERS: That will be up to the fire protection subcommittee to decide. DR. APOSTOLAKIS: But it may be wise if outside stakeholders are interested to pursue that and actually write a letter and say that this is now what we think rather than addressing the issue in the research report. I mean, you have a subcommittee meeting in February. We either write our letter in March or in April. DR. POWERS: The subcommittee will decide whether a letter is to be written. DR. APOSTOLAKIS: I realize that, but in the decision making process, perhaps the need to respond or to say something about the criticisms we raised a year ago will play a role in deciding whether to write a letter. DR. POWERS: I'm sure it would. DR. APOSTOLAKIS: Yes. DR. POWERS: I'm sure it would. DR. APOSTOLAKIS: So that may be a better mechanism to respond. DR. POWERS: I mean, I know the critique that I wrote on it is kind of critical. DR. APOSTOLAKIS: Of the program? Then, I would avoid writing anything here. DR. POWERS: Why is that? DR. APOSTOLAKIS: You want to be critical in here, in this report? Yes, but then, the rest of the committee will have to debate the points you're making; I mean, this will never finish. I mean, you want the other members to be aware of what's going on. CHAIRMAN WALLIS: It will be covered in another way. DR. APOSTOLAKIS: I think it can be covered in the March or April meeting. CHAIRMAN WALLIS: Can I go back to where we are on this? I don't have the warmest feeling that I'd like to have, but I think we've made some progress. DR. APOSTOLAKIS: We've made a hell of a lot of progress. CHAIRMAN WALLIS: No, because we have to specifically rewrite the things we want to rewrite. DR. APOSTOLAKIS: A lot of them have been rewritten. CHAIRMAN WALLIS: No, no, no, no; that's not the case. We go to the initial part; I think I have to say something about what we just were talking about, how the previous reports and how they fit in with the present one. In the external context, we had a lot of comments about the external context, particularly the second paragraph on page 2, while the agency itself is generally aware. I got the impression that this needed to be -- DR. APOSTOLAKIS: The solution. DR. BARTON: Take out the whole middle of that paragraph. CHAIRMAN WALLIS: So you think that can be sorted out when we actually put it on the screen, and we simply say take out the middle of the paragraph? It doesn't require someone to go away and rework it? DR. APOSTOLAKIS: I don't think so. I haven't heard anybody -- CHAIRMAN WALLIS: Dana, you had a lot of ideas about this paragraph. Do you think we can handle it that way? DR. POWERS: I'm not sure what paragraph you're on. CHAIRMAN WALLIS: You've got the same document I've got. [Laughter.] CHAIRMAN WALLIS: Page 2 of the most recent document. DR. SEALE: Under the heading external context; it's the second paragraph. CHAIRMAN WALLIS: Second paragraph, external context. While the agency itself is generally aware. DR. POWERS: Well, I mean, that paragraph -- I don't think there was a sentence in there that I didn't have something to say about. CHAIRMAN WALLIS: Can it be handled by the line-by-line process, or do we need to delegate a group of people to go away and rework it? Several people have ideas about it. Can we handle it in a group here with the normal editing process, or do we need a complete -- DR. POWERS: It really has to be rewritten, because, I mean, it says while the agency itself is generally aware of the important ongoing technical issues. And then, later on, when you say well, the problem in this agency is that the line organizations don't appreciate what research is doing. CHAIRMAN WALLIS: This is to put the external world in context with -- DR. POWERS: That dichotomy confuses me. Then, on each one of the things that you go through here, it says gee, you haven't looked at margins. I thought gee, I've spent more time thinking about margins this year than any other year in my life. CHAIRMAN WALLIS: Well, the -- my view is that it's been just the beginning. Anyway, how do we handle it? DR. POWERS: I think you have to decide what point you're trying to make; agree that it is a legitimate point and then write it to make that point. Now, a lot of this -- a lot of what you were trying to say here, I think, is you wanted to get the idea that there's not a whole lot of people clamoring for some big change that requires a massive research effort. CHAIRMAN WALLIS: Research has not been driven by external events. DR. POWERS: Okay. CHAIRMAN WALLIS: In a very sort of big picture; there haven't been big things coming in where the political process on the Hill, they've realized they have to do research, because there's this big thing; or the commissioners haven't said we've got this tremendous issue; we've got to do research on it. That's the sort of -- DR. POWERS: The commission hasn't picked an issue where there has to be a huge amount of research effort is what you're saying, and I say gee, I think they have. I mean, the commission has come along and said why don't you guys go out and risk-inform Part 50? That seems like a pretty demanding role for research to take up. CHAIRMAN WALLIS: That's not an external event. That's something internal for the agency. DR. POWERS: Okay. CHAIRMAN WALLIS: It's not an external driving force. DR. APOSTOLAKIS: I really don't think it's worth debating this. I mean, if it bothers Dana that much, drop the damn thing. CHAIRMAN WALLIS: So can we handle it? Can we handle it line-by-line? Or is someone going to rewrite it? I'm not going to rewrite it, because I don't know what to say. DR. APOSTOLAKIS: I propose we drop it completely. DR. POWERS: I mean, if you want to say the sentence that there have been no external bodies demanding a lot of research by NRC, you know, that's true. CHAIRMAN WALLIS: I would be tempted to ask Bill Shack to rewrite this paragraph. DR. SHACK: Let me -- I think I probably have already rewritten it. [Laughter.] CHAIRMAN WALLIS: With that, can we now move on. DR. SHACK: Somewhere in the email system. [Laughter.] DR. SEALE: A comment or two -- CHAIRMAN WALLIS: Oh, so -- DR. SEALE: -- about the -- CHAIRMAN WALLIS: Ace; our ace has been played with Bill Shack. MR. EL-ZEFTAWY: Is that for the whole section or just that paragraph? CHAIRMAN WALLIS: Well, particularly that offending paragraph, the second paragraph. Most of the rest of it, there are some things that can be cut out and so on. I think we can handle that, okay? So Bill Shack has a job. Next page. MR. EL-ZEFTAWY: I got a lot from Dr. Kress on page 3. CHAIRMAN WALLIS: A lot from Dr. Kress on the regulations you've got in this industry are essentially first generation? That part? MR. EL-ZEFTAWY: Yes; except I think after this one, we asked Dr. Apostolakis to look at it and -- DR. KRESS: My intent was to rewrite that the way I wanted it and let Dr. Apostolakis look at that particular one and then -- CHAIRMAN WALLIS: Can I look at it, too? DR. APOSTOLAKIS: No, no. [Laughter.] CHAIRMAN WALLIS: So Kress and Apostolakis are working on -- DR. APOSTOLAKIS: Kress, Kress, I'm just commenting. DR. KRESS: Well, I mean, it's going to be for you to look at it seriously and make substantial -- CHAIRMAN WALLIS: What we're speaking of is page 3, second paragraph. DR. BARTON: Okay. CHAIRMAN WALLIS: So I've got Kress and Apostolakis in my margin, and it's all under control, because they're working on it. MR. EL-ZEFTAWY: Page 3, second paragraph. DR. APOSTOLAKIS: Oh, okay. CHAIRMAN WALLIS: So that's under control because you're working on it. DR. APOSTOLAKIS: Yes. MR. EL-ZEFTAWY: Also, I have something from Dr. Kress on internal context. He wants Dr. Uhrig to look at it. DR. KRESS: The committee was to be Uhrig and Bonaca and Powers on that. CHAIRMAN WALLIS: Yes, I have Uhrig and Bonaca as well. DR. KRESS: I rewrote that part, and the intent was to have these other guys look at it and see if I did a good job and rewrite my rewrite. CHAIRMAN WALLIS: How are we going to do that? Can you do that today? MR. EL-ZEFTAWY: I was going to type all of the changes, and tomorrow, I was going to give it to all of the other people -- CHAIRMAN WALLIS: Give it to the other folks? MR. EL-ZEFTAWY: The other folks. CHAIRMAN WALLIS: Okay. Dana, when are we going to take this up again? DR. POWERS: I don't know; I'm going to have to look at the agenda, but I think we probably can afford some time in both the next two evenings. CHAIRMAN WALLIS: Next two evenings? DR. POWERS: Yes. CHAIRMAN WALLIS: So if we get input this evening or by noon tomorrow, we can have a new document tomorrow night, tomorrow afternoon? MR. EL-ZEFTAWY: I think I should have something by tomorrow night. CHAIRMAN WALLIS: Okay. DR. POWERS: Tomorrow night, we're going to, I believe, you'll have to handle letters regarding 50.55(a) and license renewal for Calvert Cliffs. I think those are pretty straightforward letters. But does anybody differ with me on that? DR. BARTON: License renewal is pretty straightforward. I don't know about 50.55(a). DR. SHACK: I'll write a letter; we'll see how straightforward it is. DR. POWERS: I look forward to your letter. DR. KRESS: Yes, I do, too. DR. POWERS: I think we are probably not going to write a letter on low power and shutdown risk insights, because we haven't seen a report. MR. EL-ZEFTAWY: Right; I was going to say -- DR. POWERS: It's not really possible to write a letter on that. Okay; so that means that with a little bit of diligence on our part, we can probably -- DR. KRESS: How would you like to rephrase that? DR. POWERS: Looking at the research report that evening. CHAIRMAN WALLIS: I hope we get to the point where we can go line-by-line through at least some of it. The internal context, I think we agreed that about half of that could go. And I've got names like Kress, Uhrig, Bonaca in my margin. Who is actually going to do this? MR. EL-ZEFTAWY: Well, I think Dr. Kress took it place. CHAIRMAN WALLIS: Dr. Kress has it. And he's going to consult with Bonaca maybe? DR. KRESS: Well, which one are you talking about? CHAIRMAN WALLIS: The internal context. DR. KRESS: Well, I would hope I've already done it. CHAIRMAN WALLIS: Already done it? So that's in the works? DR. KRESS: Yes. CHAIRMAN WALLIS: Okay; and the evolving role of research, page 5. Dana had, I think, agreed to rework the second and third paragraphs -- third and fourth paragraphs. We only agree partially with the assessment down to -- DR. POWERS: Public funds. CHAIRMAN WALLIS: -- public funds. We agreed to cut out the -- MR. EL-ZEFTAWY: Yes, that's the last sentence cut out. CHAIRMAN WALLIS: And the specific thing was to try to figure out what the criterion is for when the agency really needs to dig into these things and when it can review, because everyone understands the basis for the review. DR. SHACK: Hey, if we can come up with that criteria, we will have earned our money. CHAIRMAN WALLIS: Dana, are you going to do that? DR. POWERS: Yes; but we don't have to come up with the criteria; we just have to pose the questions. DR. SHACK: You said we were going to solve the problem. CHAIRMAN WALLIS: And the industry is mature in the sense that -- you weren't here, George. MR. EL-ZEFTAWY: I thought Dr. Bonaca was going to -- CHAIRMAN WALLIS: Bonaca was going to look at this. There was some argument about we've had 3,000 years of experience, so that's good enough. DR. POWERS: Let me ask a question just on the mechanics. How do we designate what goes where? CHAIRMAN WALLIS: That is going to get retyped. MR. EL-ZEFTAWY: All of the changes, I'm going to type in italics. DR. POWERS: I mean, I hand you something and say this goes here in the report; how do you know where here is? CHAIRMAN WALLIS: You will say. You will give him enough information. DR. APOSTOLAKIS: An appropriate page, I guess. MR. EL-ZEFTAWY: Tell me what section. DR. POWERS: My page numbers are okay? MR. EL-ZEFTAWY: No, tell me what section and what paragraph in that section that could -- DR. APOSTOLAKIS: I think we should give a Xerox copy of the page and -- CHAIRMAN WALLIS: I hope it will look pretty obvious. DR. APOSTOLAKIS: All you have to know is the section. CHAIRMAN WALLIS: You'll give him enough information. DR. POWERS: I think it really would have been very, very helpful to have done page numbering on this or -- DR. APOSTOLAKIS: Can we, the next version that we will be handed tomorrow, should we have the lines numbered? MR. EL-ZEFTAWY: Yes, right, I think -- DR. APOSTOLAKIS: Space and a half, perhaps. MR. EL-ZEFTAWY: I think the reason we have it -- DR. APOSTOLAKIS: And the paragraphs numbered, please? MR. EL-ZEFTAWY: Okay; the reason we have it this way is because Dr. Wallis thought it was a lot easier to read in a smaller version than just the -- DR. POWERS: Let me be the first to assure Dr. Wallis that 10-point type is illegible to me. DR. APOSTOLAKIS: Dr. Wallis -- CHAIRMAN WALLIS: This is big type. [Laughter.] MR. EL-ZEFTAWY: Last month came like 26 pages. Last month, when we had the double space and line number, it came to like 26 pages on the report. DR. POWERS: Trees died everywhere. DR. APOSTOLAKIS: 6:00, and you're arguing about 26 pages. [Laughter.] DR. SHACK: No, we're arguing about the postage. Got to wait until 7:00. DR. APOSTOLAKIS: So you will not eliminate anything from what's there now. You will just indicate the new changes. MR. EL-ZEFTAWY: Right. DR. APOSTOLAKIS: And maybe, you know, if I recommend a paragraph to go out, then, you will highlight it or something. MR. EL-ZEFTAWY: Yes. DR. APOSTOLAKIS: Or cross it out. MR. EL-ZEFTAWY: Right. DR. APOSTOLAKIS: Okay. MR. EL-ZEFTAWY: So you know what originally was there and what the new changes are. DR. APOSTOLAKIS: It's too bad the agency is using WordPerfect. It's not very good on this. CHAIRMAN WALLIS: Now, on the evaluation of research needs, I undertook to rewrite that. I undertook page 7 and evaluation of research needs, the RERB business. We agreed to bring the EDO in to -- DR. POWERS: Yes. CHAIRMAN WALLIS: Say much less about the RERB. DR. APOSTOLAKIS: You agreed to write that, right? CHAIRMAN WALLIS: Right. Research requirements -- DR. APOSTOLAKIS: Comment, Graham? CHAIRMAN WALLIS: Yes. MS. FEDERLINE: I'm sorry; I know it's late; and I apologize; we were briefing Dr. Meserve. That's why I had to leave. Ashook had a particular concern in the area of -- the problem we are having right now in sort of coordinating with the program offices is that the program offices have a very short term need. And the agency, at the very top levels, is also driven by schedules and very short-term needs. So the concern is that how do we balance these short-term and long-term needs? And if we're driven by a customer assessment, we're going to be driven by short-term needs. I mean, we agree totally that our products have to be relevant to the needs of the agency; there's no question about that. But the concern is that if we're driven by a customer assessment, they need to have the longer-term perspective to say that yes, high burnup fuel, utilities are going to be coming in 3 years from now. It's not as critical for them as perhaps the schedule for license renewal. And so, you know, as long as you have one box of resources, and everybody is competing for the same resources, it's going to be very difficult for a customer assessment to drive both the short-term and a long-term balance. DR. APOSTOLAKIS: Yes; the intent was not to have the customer, so to speak, drive this effort. All we're wanting to say here is that this thing of planning research and identifying issues and so on will not work until the EDO gets involved, and the EDO should establish a mechanism -- it will be up to him how to do it, but what we have in mind is that he should establish a mechanism that will get all of the offices involved. That does not mean that there is a vote, for example. That does not mean that NRR assesses what you do, but there should be high level interaction under the auspices of the EDO to do these things. Now, it may very well be that research will have the lead, and the issues you just mentioned very appropriately should be taken care of by the EDO. So we're talking about an assessment by the customers. MS. FEDERLINE: Right; this thing that we see, I guess, as missing is the criteria to balance between long-term and short-term needs. DR. APOSTOLAKIS: That's the EDO's prerogative. MS. FEDERLINE: And those need to be set at the higher -- DR. APOSTOLAKIS: Yes. MS. FEDERLINE: And that would be most useful to us is a recommendation that they set criteria which the offices can then go away and implement. DR. APOSTOLAKIS: But the offices also should interact at a very high level, not just go away and implement the criteria. MS. FEDERLINE: Right, right. DR. APOSTOLAKIS: No; I think the idea of saying something to that effect is a good one. CHAIRMAN WALLIS: While you're here, Margaret, we do talk about your vision statement. If we don't have the final version, then, we may be speaking about something which we don't really know about. MS. FEDERLINE: We don't have the final version either. CHAIRMAN WALLIS: We would like to support it, but if we don't know what it is, how can we do that? MS. FEDERLINE: I can provide you a copy of the latest -- CHAIRMAN WALLIS: We have the draft, but we don't have the final -- MS. FEDERLINE: It's still under consideration in the EDO's office. CHAIRMAN WALLIS: Can you give us -- we didn't see, I think, the final thing that went to the EDO. We saw an earlier draft. MS. FEDERLINE: Oh, absolutely; we can get you -- there have been -- CHAIRMAN WALLIS: Would it be appropriate for us to comment on that? DR. APOSTOLAKIS: I don't think so. CHAIRMAN WALLIS: No? DR. APOSTOLAKIS: Why are we getting involved in this? CHAIRMAN WALLIS: We just leave it out? DR. APOSTOLAKIS: Yes; this is something the agency is working on, and it's none of our business. MS. FEDERLINE: Well, I think your input as to what you view the role of research would be very helpful. I would think that the EDO would want that advice in making his decision on the vision. CHAIRMAN WALLIS: Well, we may -- DR. APOSTOLAKIS: Yes, but -- CHAIRMAN WALLIS: I'll leave it in, but we may, when we get to it, cut out all reference to this vision statement. DR. APOSTOLAKIS: It would be nice for us to see the draft, but I'm not sure we want to comment. CHAIRMAN WALLIS: Well, we saw a draft earlier on; we talked about it when they presented it to us, remember? DR. SHACK: We want to see the most recent. DR. APOSTOLAKIS: The most recent. MS. FEDERLINE: Yes; we would be happy to. DR. APOSTOLAKIS: Version N. CHAIRMAN WALLIS: You'll get us that tomorrow? MS. FEDERLINE: Yes. CHAIRMAN WALLIS: So we'll cross that bridge when we -- DR. SEALE: We're going to cross a lot of bridges tomorrow. DR. APOSTOLAKIS: We'll probably have dinner brought in. CHAIRMAN WALLIS: Okay; so, we're sensitive to your concerns. MS. FEDERLINE: Okay; thanks. CHAIRMAN WALLIS: I'm not sure that we can satisfy everybody. MS. FEDERLINE: Well, our desires are the same as the agency's desires. We just want to make sure that there is a long-term and short-term balance that's achieved. CHAIRMAN WALLIS: But if there's a problem with the real top management of the agency appreciating the need for research, I'm not sure we can do much about that. We'll just have to tell them that they've got to do their job. They've got to make a decision. DR. APOSTOLAKIS: Yes. CHAIRMAN WALLIS: Now, research requirements, we have some suggestions about cutting out a piece of risk-informed regulation that we've got this insert from George. George and Dana, here, we're going to sort out this offending paragraph about SECY 98-300. This is on page 9 of my document, risk-informing Part 50. I don't know what else to do about that, but Dana had some -- we had a sort of debate going on here. DR. APOSTOLAKIS: I thought he was going to write something, aren't you? DR. POWERS: Yes. CHAIRMAN WALLIS: I think he represents a view which is -- can you represent George's view as well? DR. APOSTOLAKIS: No, he will show it to me, and George will represent his own view. CHAIRMAN WALLIS: Okay; okay. So he will write it, and you will present it. DR. APOSTOLAKIS: Don't worry about it, Graham. [Laughter.] CHAIRMAN WALLIS: I'm worried about with both of you getting an extreme view of what we need a consensus on. DR. APOSTOLAKIS: What do you mean both of you? I never take extreme views. CHAIRMAN WALLIS: Then either of you. Okay. DR. POWERS: I always take extreme views. DR. APOSTOLAKIS: I know that. So we'll take care of it. MR. EL-ZEFTAWY: On the PRA, I got another writeup from Dr. Apostolakis. CHAIRMAN WALLIS: Okay. DR. APOSTOLAKIS: A drastic change. MR. EL-ZEFTAWY: A drastic one. CHAIRMAN WALLIS: Okay; so, George has written -- rewritten that. DR. APOSTOLAKIS: Yes. MR. EL-ZEFTAWY: He took a lot of stuff out. CHAIRMAN WALLIS: All right. [Laughter.] CHAIRMAN WALLIS: License renewal, we talked about a lot, and then, we left it alone. Power uprates, I noticed here that Uhrig is going to be responsible. DR. UHRIG: With some input from Dana. You're going to give me what you want. CHAIRMAN WALLIS: I'm a little concerned. DR. POWERS: Let me try to draft two or three sentences that essentially say what I said; basically, I agree with you. It's the big-time changes in the future that research needs to be -- DR. UHRIG: Yes. DR. POWERS: -- paying attention to, and I think they are doing that in the thermohydraulics program, at least in one area, and it's a good example of the kind of issues that they're -- they should be looking at, and from all indications, there are others, and down here, I think they need to -- research does not need to worry about these little upgrades; they need to worry about the things that may come down the pike that represent big changes in the plant. DR. UHRIG: This will be in the morning? DR. POWERS: Yes. CHAIRMAN WALLIS: Okay. MR. EL-ZEFTAWY: Sorry; before you leave this, on the license renewal, are we going to leave the last four bullets on the research topics? CHAIRMAN WALLIS: We will leave them for now. MR. EL-ZEFTAWY: Going to leave them in? DR. POWERS: Yes. CHAIRMAN WALLIS: Leave them for now, right. Fuels, Dana, you promised me -- DR. POWERS: Yes, I'll do that. CHAIRMAN WALLIS: -- a new section on fuels. I think it's an important area. DR. POWERS: Yes; I believe that you will -- that it is something NRC should have some prolonged expertise in. I think in the end, we'll find that it doesn't make that much difference; that they can really -- it really doesn't matter what happens to fuel. CHAIRMAN WALLIS: There must be some limit to reasonable burnup before you get to the point where safety gets impacted. DR. POWERS: It's really an issue on the clad, and the new clad is looking pretty darn good. There are a lot of ancillary issues. I think it probably seems like a bigger issue to people than it really is. It's actually pretty good, and fuel technologies are pretty -- DR. SEALE: If you've got a problem, I'll help you. DR. POWERS: Yes; get the tin out and putting Iobium in seems to be the answer, surprising as it may be, contrary to the conventional wisdom, but I think fire is more of an area -- CHAIRMAN WALLIS: So you don't see economics of the stations are being bought by the fuel manufacturers? The stations are being bought by the people who make fuel. DR. POWERS: Yes. CHAIRMAN WALLIS: The fuels, the economics, it concentrates on the fuel now. DR. POWERS: Yes. CHAIRMAN WALLIS: There is going to be a push to make more and more money out of your fuel. DR. POWERS: Sure; people will -- CHAIRMAN WALLIS: Getting closer to some safety limit, maybe? DR. POWERS: People want to burn those fuels up higher. It's not an economic issue. It's a societal issue. You want to store less fuel onsite. And quite frankly, it looks like the fuel is going to be able to take it. CHAIRMAN WALLIS: We don't need to do research? DR. POWERS: I think a lot of the research is -- I mean, there is the confirmatory research that's going on. The real question boils down to if you go from where we limit it now to where the industry wants to go, how much independent capability does the NRC have to have? If you're telling the licensee that you want to go beyond 62 gigawatt days, you come in with a story. The trouble is we run into the Wallis convention, which is if you're going to evaluate that story, you've got to work on that story with a tool of equal or superior sophistication, and I think that's the step which has a problem for the NRC. DR. BONACA: The other thing, there are two different issues. I mean, the NRC really has focused on performance during -- will the cladding extend? Will the lattice -- all of those issues, especially for high fuel burnup. The industry is concerned about operating with clean plants, and their goal is zero defects, and they have really improve tremendously. I mean, just 20 years ago, they used to run with 10, 20 -- and theoretically in the title. Then, they shut down for two or three. So did BWRs. DR. POWERS: It's very unusual to have two or three. DR. BONACA: So they really have different goals. Now, the industry really is interested in making sure that the NRC will approve the 60 megawatt day per megaton, so they will support the research, but really, the goals are very different in that sense, and they're looking at a different end of research. CHAIRMAN WALLIS: Well, we will have a new section on fuels, which you will give to Med, and he will prepare it for us. Reduction of margins; we had a lot of discussion, and I concluded it wasn't going anywhere. If you have some serious suggestions about the wording, please go to Dr. Kress. DR. KRESS: I reread that section, and there was absolutely no resemblance to anything I recognize as having come from me. [Laughter.] DR. KRESS: At all; so I undertook the task of rewriting it so it's coherent and makes some sense. [Laughter.] DR. KRESS: So I will be happy to provide you with that. DR. POWERS: Otherwise, there were no problems with it. [Laughter.] DR. KRESS: I will be happy to provide you with that rewrite. DR. SEALE: You better check to see -- CHAIRMAN WALLIS: Your memory must be somewhere faulty. DR. KRESS: No, this got altered. CHAIRMAN WALLIS: Well, it got altered, yes. DR. KRESS: In such a manner that it lost all coherence and meaning and things of that nature. DR. SEALE: Somebody has been using your -- CHAIRMAN WALLIS: Well, okay, you will do it. DR. SEALE: Your email address. DR. SHACK: Now, now, now; he knows who the guilty party is. DR. KRESS: Or parties; I don't know. CHAIRMAN WALLIS: We obviously have a difference of opinion, which will be sorted out here. [Laughter.] CHAIRMAN WALLIS: New technology; okay. Generic safety issues is out; effects in the field is in; international programs we have Uhrig preparing a Halden piece. DR. POWERS: Good. CHAIRMAN WALLIS: And we probably will cut out the business about NRC leading, but we don't know yet; we're going to talk about that. We may want to talk about the epilogue. We have made some progress. DR. APOSTOLAKIS: Oh, you finally permit yourself. It's a lot of progress, yes, a lot of progress. CHAIRMAN WALLIS: Okay; are we ready to -- DR. APOSTOLAKIS: Do we really want seriously to go over it line-by-line tomorrow? CHAIRMAN WALLIS: That's -- well, we have to sometime during this meeting. DR. APOSTOLAKIS: I would suggest you go paragraph-by-paragraph. CHAIRMAN WALLIS: George, sometime during this meeting, we intend to come up with a final document. DR. APOSTOLAKIS: I understand that, but line-by-line is too much. CHAIRMAN WALLIS: I don't think it's good to put it off to the end. If we get squeezed, it won't get done right. The proper word is research. DR. APOSTOLAKIS: Adjourn. This is a subcommittee meeting. You're adjourning. CHAIRMAN WALLIS: We will adjourn. [Whereupon, at 6:18 p.m., the meeting was adjourned.]
Page Last Reviewed/Updated Tuesday, July 12, 2016
Page Last Reviewed/Updated Tuesday, July 12, 2016