ACRS Meeting on the Ad Hoc Subcommittee on Differing Professional Opinion Issues - October 12, 2000

                             UNITED STATES
                              Thursday, October 12, 2000
                              U.S. NRC
                              11545 Rockville Pike, Room T2-B3
                              Rockville, Maryland
               The above-entitled meeting commenced, pursuant to
     notice, at 8:30 a.m..     PARTICIPANTS:
     Dana Powers, Chairman, ACRS
     Mario Bonaca, ACRS Member
     John (Jack) Sieber, ACRS Member
     Thomas Kress, ACRS Member
     Ivan Catton, Consultant
     James Higgins, Consultant
     Ronald Ballinger, Consultant
     Jack Strosnider, Division of Engineering, NRR
     Jack Hayes, Probabilistic Safety and Assessment Branch, NRR.                         P R O C E E D I N G S
                                                      [8:30 a.m.]
               DR. POWERS:  The meeting will now come to order. 
     This is the third day of the meeting of the Ad Hoc ACRS
     Subcommittee on Differing Professional Opinion Issues.
               The purpose of this meeting is this subcommittee
     will review the technical issues contained in the differing
     professional opinion on steam generator tube integrity.
               The subcommittee will be hearing from the NRC
     staff today.
               The meeting is being conducted in accordance with
     the provisions of the Federal Advisory Committee Act.  Mr.
     Sam Duraiswamy is the designated Federal official for the
     meeting.  Ms. Undine Shoop, a staff member who is assisting
     the panel, is also present.
               We have received no written comments or requests
     for time to make oral statements from the members of the
               A transcript of this meeting is being kept and it
     is requested that speakers use one of the microphones,
     identify themselves, and speak with sufficient clarity and
     volume so they can be readily heard.
               Do any members of the panel have any opening
     statements they would like to make before we get started on
     today's proceedings?
               [No response.]
               DR. POWERS:  Seeing none, I will turn the floor
     over to Mr. Jack Strosnider, Director, Division of
     Engineering, NRR.  Welcome, Jack.
               MR. STROSNIDER:  Thank you.  Thank you, Dr.
     Powers, and I want to thank the subcommittee here and
     consultants for your time and effort that you're putting
     into reviewing the steam generator issues.  I wanted to
     started off with that acknowledgment.
               As Dr. Powers indicated, I'm Director of the
     Division of Engineering in the Office of Nuclear Reactor
     Regulation.  Historically, the Division of Engineering has
     had the lead responsibility for steam generator integrity
     issues, specifically related to inspection and maintenance
     sort of activities.
               But I think as everyone is aware, steam generator
     issues are really a much more multi-disciplined effort and
     if you look at my second slide, which is an abbreviated
     version of the agenda, as you can see, in the next few days,
     we're going to be talking about a lot of different technical
     issues, ranging from iodine spiking and metallurgy and NDE
     to probabilistic risk assessment, thermal hydraulics, and,
     ultimately, integrated decision-making.
               So you'll be hearing from staff both from the
     Office of Research and from NRR and from a wide variety of
     different branches and disciplines.
               If you look at the more detailed agenda that you
     have, the names that are listed there are the principal
     speakers.  I would just point out that they may be relying
     on other staff members to help supplement some of their
     discussions, and I would remind the staff that when they're
     asked to do that, to use the microphone and identify
               We've tried to arrange these issues in some sort
     of logical order.  Basically, these various technical issues
     are all issues that feed into a more integrated assessment
     and culminating tomorrow afternoon, we're going to talk
     about the integrated decision-making process, which is what
     I described in Reg Guide 1.174 on how to do risk-informed
     license amendment reviews.
               And we're going to talk about two specific
     examples, one which was mentioned yesterday.  That was the
     Farley review, in which the NRC found the risk-informed
     amendment request acceptable, extended the operating cycle.
               We're also going to talk about review earlier this
     year on Arkansas Unit 2 regarding a risk-informed amendment,
     which the staff followed this process and we found that
     amendment unacceptable.  The plant subsequently shut down to
     perform steam generator inspections.
               The presentations that we're going to make will
     cover the DPO issues.  However, they go beyond that.  In
     response to the agenda that we were provided, we are going
     to talk about additional issues.
               I think that's an appropriate thing to do, because
     I think it will help to provide some additional context for
     the issues and really bring you up-to-date on the whole area
     of steam generator regulation.
               With regard to NDE and cracking phenomena, I think
     there's going to be a little bit of rearrangement in the way
     we present some of that.  Based on the discussions yesterday
     with regard to Generic Letter 95-05, I think it's very
     important that we spend a little more time on that than we
     might have originally planned.
               Frankly, I don't think the committee was left with
     the clear understanding of exactly what's in that letter or
     the basis for it or our experience with its implementation.
               So when Ken Karwoski talks about these issues,
     he's, first, I think, going to talk about the regulatory
     framework in general, but then I think he's going to talk to
     Generic Letter 95-05.  We want to take that as sort of a
     unit before we move into other NDE and cracking phenomena
     issues, because I think we need to be careful.  There is a
     potential to mix different issues.
               And Generic Letter 95-05 is a very specific --
     deals with a very specific mode of degradation and there are
     some very specific requirements, and we want to make sure
     that's clear for everyone.
               The final thing I would mention with regard to the
     agenda, I've put some hours in here which I hope roughly
     correspond to what's in the more detailed agenda you have.
               The main reason I did that is just to point out
     that I think it's important that we do try to stick to the
     time schedule.  Obviously, the staff is here, it's your
     meeting, and we're going to respond to what you want us to
     respond to.
               But as I indicated earlier, all these things, we
     want to try to show how they fit together and add up to this
     overall process.  So I would just encourage that we do watch
     the clock.
               I would also point out that there has been an
     extensive amount of background information provided.  My
     understanding is you've got about a foot-and-a-half of
     paper, literally.
               DR. POWERS:  It's about twice that.
               MR. BALLINGER:  Eighty-nine pounds.
               MR. STROSNIDER:  Eighty-nine pounds?  Okay.  But
     it goes to a point.  There is an extensive amount of
     documentation on these issues.  However, I'm somewhat
     sympathetic in that I suspect you might suffer from some
     information overload there.  So as we go through these
     issues, if there are specific questions that come up, I
     would offer that we could help point to the right reference
     and maybe the right location of that reference that you
     could study later to help address some of your concerns.
               DR. POWERS:  Understand the weight is not usually
     an indicator of content.
               MR. STROSNIDER:  Okay.  If I could move on to the
     next viewgraph, Dr. Hopenfeld presented, yesterday morning,
     a very detailed timeline that he went through.  This is my
     abbreviated version.
               I was hoping to make perhaps a few bigger picture
     observations.  If I start with the lower line on here, it
     talks about the DPO activities and you're familiar with when
     the DPV and the DPO were submitted.
               I did indicate in here one ACRS meeting that was
     held in October of '97 on the DPO consideration document.  I
     went back and I'm not sure I've got an accurate count, but I
     think I'd just mention, for the record, perhaps, that there
     have been 11 ACRS meetings from 1994 to the year 2000 on
     steam generator issues.
               Seven of those dealt explicitly with the DPO
     issues and it's several of those Dr. Hopenfeld did make
               Having said that, I recognize, in Dr. Powers'
     memorandum, I think it was September 11th, to the EDO, that
     the intent is to take a fresh look at these issues,
     notwithstanding that there have been prior meetings.  And I
     think there is merit to that, also, because things have
     evolved.  We have information today that we'll be presenting
     that wasn't available in prior meetings.  So I think that's
     a worthwhile thing to do.
               But I did want to point out for the record that
     these issues have been discussed publicly in the past.
               If we could look then at the upper timeline for a
     minute, I wanted to focus for just a second on what went on
     here with steam generator rulemaking, Generic Letter
     NEI-9706, and there's -- I guess the best way I can say it
     is that there is some frustration for everybody perhaps in
     how long it takes to see things happen.
               But I did want to point out there are some
     processes that the staff follows in these sort of
     activities.  The processes were established to provide
     appropriate checks and balances, opportunity for public
     participation, opportunities for presentations to ACRS,
     CRGR, those sort of activities.
               So it does take time.  I continue to read and hear
     about the failed steam generator rulemaking.  I just wanted
     to comment on that, because I guess I can understand the
     perspective that, yes, the staff said they were going to
     embark on generating a new rule, and that in the end, we
     didn't do that.
               But what I wanted to point out is that part of the
     rulemaking process is to go through a regulatory impact
     analysis to determine whether the rule is justified, and
     there are several different ways it can be justified, but
     nonetheless, we went through that.
               It involved a lot of work.  It involved some
     groundbreaking risk assessment to support the evaluation,
     which subsequently was published in NUREG-1570.  It took
     time to do that.
               In the end, when we look at the criteria, it
     didn't support the idea of a rulemaking.  I don't look at
     that, personally, as a failure.  I look at that as we
     followed the process, we looked at the results, and that was
     the outcome.   We also recognized when we finished that,
     though, that there were some improvements that needed to be
     made within the existing regulations and regulatory
     framework, and, of course, that led us to the generic
               There was some suggestion yesterday that
     abandoning the rule had something to do with the fact that
     the industry might not like a steam generator rule.  That
     was not why the rule didn't happen.  It was because of the
     reg impact analysis.
               When we started looking at the generic letter, and
     we did have a lot of interaction with the industry, and I
     think the staff had some influence on them.  I'd like to
     think they saw the technical and safety merits of some of
     our issues, and they developed this industry initiative
               This is a good thing.  I think we need to credit
     the industry for taking that initiative, and I'll just give
     you a few examples on that.
               The existing steam generator tech specs basically
     say plug at 40 percent, except for where some alternate
     repair criteria would ever have been added, but for most
     plants, it's shut down, do the inspection, plug at 40
     percent and you can restart.  There are no explicit
     requirements to do a condition monitoring of the steam
     generator, to understand exactly what the condition was at
     the end of the cycle, or to forecast or do this operational
               By 9706, all licensees, all PWR licensees have
     committed to do those and they started performing those.  So
     that's a good thing.  Those two things alone make this a
     very important initiative.
               MR. HIGGINS:  Jack, you said all licensees have
     committed to 9706.  Is that a formal commitment or informal?
               MR. STROSNIDER:  We have a written commitment and
     I don't remember if it's on each docket or if it's through
     NEI.  I think it may be through NEI.  But we have a
     commitment that all the PWR licensees will follow the
     guidelines in 9706.
               I would also point out that doing that did not
     relieve licensees from meeting any of the existing
     regulatory requirements.  In fact, we sent a letter to NEI,
     which was distributed to the licensees to make that clear to
               So this has been a good initiative and if you
     follow this timeline, it didn't put on here
     direction-setting initiative 13, the Commission guidance to
     interact with the industry to look for voluntary
     initiatives, and it made sense, when we started looking at
     what was happening in 9706 and in the generic letter, that
     we should work on that approach, and that's what has been
               I would indicate that -- and I'll talk a little
     bit more about this in the summary tomorrow, but we have put
     this effort on hold following the Indian Point 2 steam
     generator tube rupture, so that we can factor lessons
     learned from that event into our review of this steam
     generator licensing change package, which is 9706 and more. 
     This actually involves some new and improved tech specs.
               But we haven't gotten to approving that yet and
     we're going to factor in lessons learned from the most
     recent tube failure event.
               So that's what we'll talk about, how things have
     evolved.  The other thing I wanted to point out here is a
     lot of the discussions that we had yesterday and that we'll
     have in the next two days deal with the risk-informed
     approach to addressing steam generator tube integrity
               I put a couple things on here.  If you look at
     NUREG-1477, there was some risk analysis in there.  It
     didn't deal supplementary with the area of severe accidents;
     that is, core damage events leading to tube rupture, except
     in a qualitative way.
               I would remind people that back in the early '90s,
     when we first reviewed some of these proposals by the
     licensee for voltage-based approaches, that we were still
     doing a very much deterministic licensing basis sort of
     review.  When we got to this point, we tried to factor in
     some of the risk perspectives.
               As you move off in time, as I indicated, one of
     the major things that happened with the steam generator
     rulemaking was the development of NUREG-1570 and the work
     that was in there.
               It was very important work, because it dealt,
     again, with some sequences that weren't specifically
     addressed before.
               Finally, I put a milestone on here of the issuance
     of Reg Guide 1.174.  That's the first time that the staff
     actually had Commission-approved and formal guidance on how
     to apply risk-informed regulation in reviewing license
               So you have to keep in perspective that this has
     been an evolving process.  As such, some of the information
     that you're going to hear has evolved with time.  And,
     again, I'd mention I think it's worth going back and
     reviewing today's state-of-the-art as opposed to some of
     what we can talk about historically.
               So those are a couple of the major points I wanted
     to make with regard to the timeline.  But one other thing I
     wanted to come back to, when we talk about this process and
     the time it's taking to work toward this improved framework,
     we're often questioned, well, what about safety.
               I would point out that during that timeframe, and
     I counted them up last night, the staff issued seven generic
     communications on steam generators, ranging from subjects
     like the importance of optimizing the inspection methods
     you're using to how you deal with circumferential cracking,
     to dealing with U-bend cracking, externals, degradation of
     steam generator secondary side components.
               So we have been dealing with the issues as they
     come up, interacting with the industry through generic
     communications and through our other processes for dealing
     with the licensees.
               Finally, I'd like to talk just briefly on, I
     guess, maybe I suggestion on what I think you need to be
     looking for in terms of resolution of some of the DPO
     issues.  You're going to hear, in some of the areas we
     talked about, some specific technical answers, if I can
     characterize it that way, and one example might be the first
     presentation we had this morning on iodine spiking.
               You're going to see where work was done,
     parametric studies were performed, and we concluded that
     certain assumptions are valid for performing these analyses.
               But there are other issues where you're going to
     hear that it's more of a process resolution and I'm not
     talking about the same -- well, in some cases, it might be
     the process I talked about earlier.  Some of the recent
     issues with regard to vibration and dynamic loads during
               We put in the GSI process and it's working through
     and you'll hear something about that.   
               But there's another aspect of this.  Some of the
     issues that come up, particularly from a risk-informed
     perspective, when we start talking about probability or
     frequency of bypass events and that sort of thing, what we
     concluded from some of the work was that various alternate
     repair criteria for steam generator tubes or ultimate repair
     methods can, in fact, influence those frequencies.
               Now, we don't know, the NRC staff doesn't know
     what the next alternate repair criteria is that the industry
     is going to send in to us for review.
               So we can't, ahead of time, come up with here's a
     specific solution.  But what we have said is that we will
     review those things considering the risk-informed aspects. 
     In fact, with regard to 9706, as an example, the industry
     guideline document, and the tech specs that have been
     developed, the industry very much would have liked to have
     had freedom to define their own alternate repair criteria,
     to define their own alternate repair methods.
               We have, in working on those tech specs, indicated
     that, no, whenever you come up with a new alternate repair
     criteria or a new repair method, you need to come to the NRC
     staff for approval, and the reason we did that is so that we
     can look at it from a risk perspective and determine what
     the impact will be with regard to some of these
     risk-informed aspects of the issue that we've been studying.
               Unfortunately, we don't have guidelines out there
     at this point where the industry could pick it up and do it
     themselves.  That's what I mean by a process resolution.
               We committed to look at some of these things as
     part of our reviews.  I think when you hear the discussions
     on Farley and Arkansas, you'll see that we're doing that.
               There may be discussions about assumptions that
     are made, how we do those analyses, and I don't think that
     that should be a surprise, given that, again, these are some
     of the first ones that we've done and those discussions are
               But the point I want to make is that where we said
     we were going to include these things in our evaluations,
     that we did that, and that's the way some of these issues
     have to be addressed.
               So that's basically the opening comments I wanted
     to make.  I'd just ask if you've got any questions for me.
               If not, again, we appreciate your time, and I will
     turn it over to Jack Hayes.  I think he's our first speaker
     on iodine spiking.
               MR. HAYES:  Good morning.  I'm Jack Hayes, and I'm
     with the Probabilistic Safety and Assessment Branch, and I
     will be discussing that aspect of the differing professional
     opinion which deals with iodine spiking this morning.
               This morning, I'm going to be discussing the DPO
     author's concern.  I'm going to be discussing the staff's
     assessment of that concern, but I think it's really
     important to understand that it was not the DPO's concern
     that had us address iodine and spiking.
               That was part of an overall reassessment we were
     doing with respect to accident analysis.  So to understand
     how we arrived at our assessment of the DPO concern, I think
     it's important to understand the staff's reassessment of
     iodine spiking as a whole and the conclusions which we drew
     with respect to iodine spiking.
               Now, the DPO author's premise is the following. 
     If you have a reduction in the tech spec value of primary
     coolant activity level of dose equivalent iodine-131, which
     is typically one microcurie per gram, to low activity
     levels, that that may result in a spiking factor which is
     greater than 500.
               Now, if you had that situation where you reduced
     activity levels and you have a spiking factor greater than
     500, then the premise is that the consequences you'll have
     if you have a main steam line break accident, that Part 100
     dose limits will be exceeded.  That's the premise.
               DR. KRESS:  A question.
               MR. HAYES:  Yes, sir.
               DR. KRESS:  Have these tech spec changes been
               MR. HAYES:  Yes.  It's tech spec values lower than
     one microcurie have been approved.
               DR. KRESS:  What levels have they been taken down
               MR. HAYES:  I think down to probably the lowest
     has been about ten-to-the-minus-two, about
     one-times-ten-to-the-minus-two, that ballpark.
               DR. KRESS:  Okay.  Thank you.
               MR. HAYES:  Now, in order to understand this
     further, there's some background areas we believe you need
     to discuss.  One is iodine spiking, what is it.  We think
     you need to understand that how do you incorporate iodine
     spiking in the calculations of releases associated for a
     main steam line break, and then how does this figure in with
     the voltage-based criteria that licensees implement.
               Now, what is iodine spiking?  Well, it's an
     increase in release rate from fuel to primary coolant
     resulting from a transient.  Most of us like to deal with
     mathematical expressions.  In essence, it's a release rate
     from post-trip over the release rate at steady-state or
     release, if you will, pre-trip.  That's a way to define it.
               Now, the question is how does it occur.  Well, in
     order for iodine spiking to occur, you have to have a fuel
     defect.  If you have a fuel defect, you will get water into
     the gap associated with the fuel pellet.
               When that water enters, because of the large delta
     T between the fuel pellets and primary coolant, some of that
     water is going to vaporize.  Now, at the beginning of a
     transient, the fuel pellet temperature decreases.  This
     causes the steam which is in that fuel rod gap to condense.
               Once it condenses, it causes an imbalance between
     the reactor coolant and between the fuel.  You get
     additional water which enters.  Now, because the fuel pellet
     is still at a much higher temperature than the reactor
     coolant, it causes some of the entering water to vaporize
     and sets up a local delta P, such that as you reduce
     temperature in the fuel, you're going to get water which
     will enter back into reactor coolant.
               That's what the spike is.  Now, as the fuel
     temperature decreases, eventually you will shut off the
               Spikes occur, power transients, startup, shutdown,
     typical occurrences.  These are included in the analysis
     which we perform for steam generator tube rupture analysis
     and main steam line break accidents.
               DR. CATTON:  This kind of says that the post-trip
     release is somewhat independent of the steady-state release
     rate, because you're really sort of clearing out the iodine
     from the fuel itself.
               MR. HAYES:  Yes.
               DR. CATTON:  It's kind of separate.
               MR. HAYES:  Yes.
               DR. CATTON:  That would be why the ratio would
     increase when you reduced.
               MR. HAYES:  That's correct.
               DR. CATTON:  Do you account for this?
               MR. HAYES:  Yes, we do, and we'll be going right
     through it right now.  It's a good lead into how we do these
               When we do a main steam line break accident or a
     steam generator tube accident, we usually presume that the
     calculations are done at tech spec values.  For example,
     normal operating primary to secondary leak rate, this value
     is typically one gallon per minute.
               The primary coolant activity level is also a tech
     spec value.  This is typically one microcurie per gram of
     dose equivalent iodine-131.  And then the spiking factor
     which we assume in these calculations is a factor of 500. 
     Now, for this particular scenario, the dose acceptance
     criteria is 30 rem thyroid for the exclusionary boundary,
     EAB, the low population zone, LPZ, and for the control room.
               Now, one thing I would like to point out is that
     when we do these calculations, typically we don't approach
     this value of 30.  In other words, in essence, most of the
     PWRs, they're probably anywhere from a factor of three to
     ten below these values.  That's where you typically are in
     terms of the evaluations in normal situations such as this.
               Now, in order to perform these calculations, it's
     necessary to determine the equilibrium release rate
     associated with the fuel.  For example, it might be that
     four microcuries per gram of dose equivalent iodine-131,
     that the release of iodine-131 is five curies per hour.
               When you factor that into a main steam line break
     or steam generator tube rupture accident analysis, since the
     spiking factor is a factor of 500 larger, this goes into the
     release rate.
               So in other words, when you start this accident,
     you have your primary coolant activity level and then you
     start releasing from the fuel into primary coolant.  In this
     case, it would be 2,500 curies per hour of iodine-131.
               DR. KRESS:  A question.  To get that five curies
     per hour out of the .4, which is what's measured, you have
     to favor in the cleanup system.
               MR. HAYES:  Yes.
               DR. KRESS:  And the decay constant for iodine.
               MR. HAYES:  Right.  The terms, if you will, you
     have a release into the fuel, but you have a removal, and
     the removal consists of decay, let-down flow, and also
     primary to secondary leakage.
               So all three of those factors are utilized to
     arrive at the five curies per hour.
               DR. KRESS:  The major one being the cleanup
               MR. HAYES:  Yes.  And depending upon the isotope,
     also, decay.  Primary to secondary leakage --
               DR. KRESS:  You deal with more than just I-131.
               MR. HAYES:  Yes.
               DR. KRESS:  You use the other isotopes.
               MR. HAYES:  Yes.  All five isotopes of iodine are
               DR. KRESS:  All five isotopes.
               DR. POWERS:  A couple of questions.  On the
     previous slide, you indicated most calculations were done
     with the tech spec limit, which you cited as one microcurie
     per gram.
               MR. HAYES:  Yes.
               DR. POWERS:  And now you've switched to .4
     microcuries per gram.  Was there a reason for that?
               MR. HAYES:  The only reason I did that is because
     in doing the slides and the preparations, one of the
     examples I had was that .4.  Let me give you what an actual
     number is.  I've looked up an actual number.  I'm just doing
     an amendment associated with Watts-Barr.  And this number,
     one microcurie is, for Watts-Barr, corresponds to like 13.8
     curies per hour release rate and the 500 times that value is
     like around 6,900 curies per hour.
               So that was just chosen.  I probably should have
     put an example of one, but that's what the number is.  Also,
     if you like numbers, the typical primary coolant activity
     level at one microcurie for Watts-Barr, that's 161 curies of
     iodine-131 starting out.  So that gives you some numbers.
               DR. KRESS:  Is there a wide variation in the tech
               MR. HAYES:  No.
               DR. KRESS:  It's generally around one.
               MR. HAYES:  Yes.  In essence, for all plants which
     do not have the alternate repair criteria, the value is, in
     essence, one.
               DR. POWERS:  There is a peculiar habit of iodine,
     it usually gets called hideout.  Did you attempt to account
     for hideout?
               MR. HAYES:  No.  We don't have any special
     function that includes hideout.
               DR. POWERS:  What does DE stand for?
               MR. HAYES:  Dose equivalent.  I'm sorry.
               MR. SIEBER:  Could you tell us again what the
     basis for the 500 spiking factor is and is it the same for
     every plant under every condition, with any amount or no
     fuel leaks?
               MR. HAYES:  Right.  Okay.  The value of 500 is the
     same for all plants which was utilized.  I cannot tell you
     the basis, other than to say it's in the standard review
     plan.  I can't tell you how it was arrived at back probably
     in the '70s.
               I presume that someone did an enveloping estimate,
     but I don't know what the basis for it is.
               MR. SIEBER:  Would that not be the most important
     factor to consider in trying to figure out what the dose
     equivalent at the exclusionary boundary and the control room
     would be?  It would seem to me to be the most important
               MR. HAYES:  No, it isn't.  The most important
     thing is your primary coolant activity level and also the
     primary to secondary leak rate, because -- let me go back to
     a slide.
               MR. SIEBER:  The primary coolant activity level,
     the spike actually is where the dose comes from and if it's
     500 times greater than what you would ordinarily have as a
     dose commitment from primary coolant, that's a substantial
               DR. POWERS:  We're talking about a release rate
     and not -- he's not multiplying his primary coolant
     concentration by 500.  He's multiplying his release rate by
               MR. HAYES:  The other thing I think is important,
     this is the definition of a spiking factor.  We have two
     terms. We have one as the numerator and one as the
     denominator.  For example, if the denominator is extremely
     small, this spiking factor will be very large.
               So the absolute value of the spiking factor isn't
     as important as is really the primary coolant activity that
     you have and the primary to secondary leak rate.
               In further discussions, when we go into the
     parametric analysis that we did, we hope that we will be
     able to show you that that is indeed the case.
               MR. BALLINGER:  A question.  You say that you
     don't really consider hideout, as it were.
               MR. HAYES:  Yes.
               MR. BALLINGER:  But do you look at the sort of
     steady-state, if you want to call it steady-state, iodine
     concentration in the system as a function of time versus how
     the plants operate, to try to get an idea of whether you're
     using an average which has a lot of uncertainty in it or
               I mean, how do you arrive at the .4, for example?
               MR. HAYES:  The value of one is a tech spec value
     and plants do not operate even close to that.  The reality
     of the situation is this.  When plants start to get at
     around ten-to-the-minus-two, they get real, real antsy and
     they start to take action.
               And, see, the presumption that we have with this
     particular analysis is that you are already at one
               MR. BALLINGER:  But the proposal is to reduce that
     in some cases.
               MR. HAYES:  Yes.
               MR. BALLINGER:  So a value that's supplied to you,
     that comes in at some number less than one.
               MR. HAYES:  Right.
               MR. BALLINGER:  But how do you evaluate whether or
     not that's a number which you believe?
               MR. HAYES:  You mean whether they're going to get
     to that number?
               MR. BALLINGER:  No.  Whether the -- oh, even the
     lower one is a tech spec number?
               MR. HAYES:  Yes.
               MR. BALLINGER:  Okay.
               DR. KRESS:  The assumption seems to be that if you
     have a number in the tech specs that is an allowed number,
     that there is a potential then for when the accident occurs,
     the steam generator tube rupture, that you may be at that
     tech spec number, since it's allowed.
               MR. HAYES:  That's an assumption made in the
               DR. KRESS:  So when you do the design basis
     accident calculation, that's why you use the one or whatever
     the tech spec number is and not the actual, because the
     actual is not really of interest.
               MR. HAYES:  That's correct.  That's very good.
               Voltage-based criteria.  As Jack Strosnider --
               DR. CATTON:  Excuse me.  I kind of got lost in a
     little bit of this.  You use the number one when you do your
               DR. KRESS:  Or whatever is in the tech spec.
               MR. HAYES:  Or whatever the tech spec value is.
               DR. CATTON:  Right.  So if somebody comes in and
     says, gee, I want you to relax a little bit, I'm going to
     reduce my tech spec value to .1 or .5, in reality, nothing
     has changed because they're already operating at a much
     lower number.
               DR. KRESS:  Something would have changed, because
     if they --
               DR. CATTON:  If they operated at one, it would
     change, but if they operated at .1, then nothing really
     changes, except the fact that they've reduced the --
               DR. KRESS:  There is a virtual change, and that is
     that if they did approach this new number, they would have
     to shut down and do something.
               DR. CATTON:  We heard that they don't.
               DR. KRESS:  I know, but that's -- but it's a
     virtual change.  They would have to if they did.
               DR. POWERS:  A virtual change is no change at all.
               DR. KRESS:  That is a change.
               MR. HAYES:  I understand some of your quandary. 
     Let me share some experience with respect to generation of
     the steam generator rule.
               The value of one is not a value that is frequently
     met.  People maintain their concentrations much lower than
     that.  So, if you will, it's not in a usual operating area.
               In the discussions with some of the utilities, as
     part of the steam generator rule, they had mentioned to the
     staff, they said, hey, we think your evaluations are too
     conservative, and what the staff -- we went back and
     reassessed that.    
               Well, what we found is when you reassessed it,
     hey, one of the things you licensees and we can do is let's
     change the tech spec value, and the operators said, no, we
     don't want to change the values.  We want that margin.
               So what you actually find out is plants don't want
     to change that value of one unless they have to and what
     happens is with the ARC amendments, in essence, they're
     forced to change it, but they don't want to do that.  They
     want to keep that value of one.    
               As another example, there's another tech spec
     value which is a maximum instantaneous value, that we're not
     talking about today, which is a value of 60.  That value, no
     one has come close to it.
               We've had three values above 15 in the whole
     operating time period.  The highest value is 18.  They don't
     want to change the value of 60.  The value of 18 was in
     1972, in Ginna.
               DR. KRESS:  In essence, then, what I read into
     that statement is that by changing the tech spec value, you
     have eroded the margins.  You have to have.  The question
     that comes to mind when you make that statement is how much
     margin do you need in design basis space.
               MR. HAYES:  You've eroded the operating margin. 
     Dose margin, you're still at the same number.
               DR. KRESS:  Well, you've eroded the margin to how
     well you've protected against receiving a particular dose at
     the site boundary or the control room, which is what you're
     interested in, how well you control the potential for having
     that dose.
               So you've definitely eroded that margin when you
     lower the tech spec value, there's no doubt, in my mind,
     because in essence, you allow more leakage to meet the
               DR. CATTON:  You're swapping real safety for
     virtual safety.
               DR. KRESS:  Yes, exactly.
               DR. POWERS:  You can do that on virtual changes,
     you can do that on margins, too.  He has enormous capacity
     for --
               DR. KRESS:  So this all gets embroiled in how much
     margin do you need in design basis space and why did you
     have the margin you had in the first place and those types
     of questions.
               DR. BONACA:  It seems the issue is with the
     leakage rate, right?
               MR. HAYES:  That's correct.  That's correct.
               DR. BONACA:  The accident analysis is used on GPM
     and that's why the number is in tech specs, but some plants
     operate with less than that.
               MR. HAYES:  That's right.
               DR. BONACA:  And if they have problems, in fact,
     meeting those limits, especially control room issues, leads
     you at times to the need to tighten up that leakage rate,
     which means you have to perform your analysis with a lower
     leakage rate.
               But I'm trying to understand how that affects the
     margin issue and the tradeoff.
               MR. HAYES:  And I think you all are doing very
     good, well, leading right into the succeeding slides,
     because in this voltage-based criteria, that's the tradeoffs
     we're getting into.
               As Jack Strosnider mentioned, he said that the
     tech specs, as they're written, at 40 percent through wall,
     you have to start plugging tubes.
               What the voltage-based criteria does, it allows
     tubes that you would normally be plugging to remain in
     service, but there's a tradeoff with that.  That is, it's
     postulated that if you have a high pressure transient, such
     as a main steam line break accident, you're going to cause,
     because of the high differential pressure across those
     tubes, you're going to cause those tubes to open up and
     they're going to leak at a certain level.
               For example, let's say that you have a main steam
     line break associated with a given steam generator and let's
     say in that steam generator, you have 100 tubes which have
     this voltage-based criteria.
               If it is postulated that each of those tubes which
     has that criteria would leak at half a gallon per minute
     when exposed to that pressure, then for those 100 tubes, you
     would have a 50-gallon per minute leak.
               Now, that's a new source.  We hadn't had that
     before.  The source we had was normal operating primary to
     secondary leakage, but now we've got what we refer to as the
     accident-induced leakage, and that value is like, for
     example, in the case I used, 50 GPM.  So that has to be
     added into your source.
               DR. KRESS:  If I view this from the perspective of
     Reg Guide 1.174, this is sort of a change to the licensing
     basis that increases risk a little, it's a question of how
     much.  The Reg Guide 1.174 calls for maintaining the
     defense-in-depth philosophy and it also calls for preserving
               I'm not sure I quoted it correctly with those and
     that's why I'm looking behind me.  It seems to me like this
     increase in risk, it's bound to reduce your defense-in-depth
     a little bit.  I don't know how much.  I don't know how
     that, quote, preserves the defense-in-depth philosophy and
     it also erodes the margins, so I don't see how it preserves
     the margins, which are sort of part of the whole integrated
               Maybe someone back here could speak to those
               MR. HOLAHAN:  This is Gary Holahan, from the
     staff.  I think in Reg Guide 1.174, the principals are laid
     out to keep any risk changes small and to preserve
     defense-in-depth philosophy and to preserve sufficient
     margin, but the discussion of defense-in-depth and margin
     wasn't meant and doesn't mean that we're not prepared to
     make any changes.
               So there's a judgment involved and there's some
     guidelines involved as to how much margin ought to be
     preserved and what does it mean to be preserving
               I think what you really need to do is to look not
     only at this design basis case, but look at the implications
     of any of these changes from a severe accident risk point of
               I think Jack isn't going to cover all of it, but
     when Steve Long speaks later, you'll see the whole picture
     of how we consider these issues and I think by the time we
     get to tomorrow's examples that Jack mentioned this morning,
     the Farley and the Arkansas amendments, you'll see, in fact,
     that there is an explicit discussion by the licensee and by
     the staff on safety margins and defense-in-depth and risk
     implications of these sort of changes.
               DR. KRESS:  Thank you.
               MR. STROSNIDER:  I'd like to provide one other
     perspective, too, which is with regard to the type of
     degradation that's being dealt with here, which is outside
     -- stress corrosion cracking at tube support plates, again,
     a very specific form of degradation.
               There was some discussion yesterday and there will
     be some additional discussion today about the difficulty in
     using eddy current methods to size racks and that sort of
               Before the voltage-based criteria went in, what
     licensees were doing was they were attempting to size these
     indications and they were leaving them in service.  So when
     you look at the delta between what the practice was and
     what's coming here, you need to ask yourself the question
     which of these is really providing a more reliable approach.
               Now, I will acknowledge there is another approach,
     which would be plug every tube that has an indication, which
     is what they typically do with stress corrosion cracking.
               But if sufficient margins can be demonstrated by
     the industry, then that's not necessarily the way you have
     to go.  So you need to look at this in terms of the
     perspective, you know, do you have greater uncertainty
     trying to size these cracks in terms of their actual
     physical dimensions, which is what people were doing and
     there was large uncertainty in that, and, to a certain
     extent, dealing with accident-induced leakage was, to some
     extent, probably just acknowledging reality and specifically
     dealing with it.
               So that's a different perspective.  Steve, have
     you got something you wanted to add?
               MR. LONG:  This is Steve Long, with the staff. 
     Just a couple of things to make sure we're clear on.  When
     Jack does this calculation in design basis type analysis,
     he's assuming that leak rates that are measured as if
     they're in the free span are going to occur.
               So he essentially has data from tubes that they
     tried to figure out what the leakage would be if the area
     that's normally captured by the tube support plates is
     exposed in the free span and then given the delta P change
     from the steam line break.
               This is not something you just throw into a risk
     assessment in that manner.  So you need to think of this
     somewhat differently than the way you would do a
     risk-informed application.  These are not risk-informed
     applications under Reg Guide 1.174 and the leakage that he's
     using assumes that every flaw that's under a support plate
     is instead in the free span.
               So it's sort of a virtual leakage calculation.
               MR. STROSNIDER:  A conservative one.
               MR. BALLINGER:  But the vendors, their correlation
     assumes no restraint by the support plate anyway.
               MR. LONG:  That's correct.  But you would have to
     have what fraction would be --
               MR. HAYES:  The question becomes, well, what is
     the impact of this voltage-based criteria.  Well, the goal
     is to minimize the number of plugged tubes.
               DR. POWERS:  Whose goal is that?
               MR. HAYES:  That's the licensees' goal.  That's
     the licensees' goal.  And because what happens, if you
     continually plug tubes, it's obvious that you have to
     de-rate your unit, and that's what they don't want.
               Now, as we mentioned at the start, we had two
     criteria.  You had the one gallon per minute primary to
     secondary leak rate and you had the one microcurie per gram
     of dose equivalent iodine-131.  Those are an equilibrium
               If, all of a sudden, you've raised that primary to
     secondary leak rate, then you have to lower the allowable
     primary coolant activity level if you're going to have this
     larger leak rate and still maintain your doses.
               So that's what they do and that's what they're
     trying to achieve.
               DR. POWERS:  Is there a hazard, safety hazard
     associated with plugging tubes?
               MR. HAYES:  If you plug tubes, you remove the
     capability of the steam generator to remove heat from the
     core and you reach a point where you have too many tubes
     plugged, you have to de-rate your unit.  Now, if the
     question is deeper than that, I'm going to have to refer to
     someone may be from the Division of Engineering to answer
     that question.
               MR. HOLAHAN:  Let me try.  It seems to me that
     when tubes get plugged, the plant meets the same
     deterministic safety criteria in terms of mechanical
     requirements, in terms of thermal hydraulic analysis, in
     cases, they have to redo the LOCA analysis.  In effect, they
     meet all the same requirements.
               I'm not aware of any risk assessments that
     indicate that taking tubes out of service by plugging them
     introduce any risk changes.
     DR. POWERS:  No accident initiators associated with plugging
               DR. BONACA:  The only sensitivity I think I could
     think of would be if you had very uneven plugging in
     different steam generators.  That, you would have to --
     those kinds of issues are considered, have to be considered.
               DR. POWERS:  So if I plug all the tubes on one
     quadrant of the steam generator, I get some sort of problem.
               MR. SIEBER:  You'd get an offset in the core,
     because --
               DR. BONACA:  You would get --
               MR. BALLINGER:  Between one steam generator in one
     loop and another steam generator in another loop where you
     have a very odd -- a very large difference in number of
     tubes plugged, then you alter that.
               MR. HOLAHAN:  Those are the kinds of issues that
     are dealt with in the analysis.
               DR. CATTON:  So, in essence, what you're doing is
     you're just making sure the iodine that's sitting around
     ready to get out is the same.
               MR. HAYES:  Right.
               DR. CATTON:  You reduce the level in the primary
     system.  You allow a little bit more to be dumped in.  The
     more that's dumped in relates to the leakers.  The leakers
     is tied to voltage.
               DR. HOPENFELD:  Right.
               DR. CATTON:  It sounds like a rather simplistic
     calculation.  Do you put any uncertainty on the steps in
     this in order to --
               DR. HOPENFELD:  No.  It's done in a deterministic
     manner.  There's no uncertainties put on it.  Now, realize
     that the criteria here is 30 rem thyroid, which is ten
     percent of Part 100 limits.
               DR. POWERS:  That's the final.
               MR. HAYES:  That's the final, yes.
               DR. POWERS:  You're playing around with some game
     in the middle somewhere.
               MR. HAYES:  The only uncertainty to that, I think,
     is utilized with respect to leakage associated with the
               DR. POWERS:  There is no consideration in the
     analysis that the events that lead or are associated with
     either a steam generator tube rupture or main steam line
     break could, in fact, cause a rupture to the cladding on
     some --
               MR. HAYES:  That's correct.  There is no
     consideration for that.
               DR. CATTON:  When you do that --
               MR. HOLAHAN:  Excuse me.  I know why.  It's
     because there is a requirement that for those events, the
     fuel continues to meet specified acceptable fuel design
     limits, which are intended to not induce additional fuel
               Of course, the fuel failures that preexisted are
     covered in the analysis and the spiking.  But you would
     expect no additional fuel failures because fuel is analyzed
     under those thermal hydraulic conditions to meet its design
               MR. BALLINGER:  Is there any data on spiking for
     actual delta P's which would exist during the main steam
     line break?
               MR. HAYES:  No.
               MR. BALLINGER:  As opposed to operational delta
     P's, which is all the stuff that I've been reading.
               MR. HAYES:  No, there is not.
               MR. BALLINGER:  So what is your judgment with
     respect to the spiking factor when you make the jump between
     what's been measured and what actually might occur?
               MR. HAYES:  We're going to discuss that and if we
     don't answer your question when we get to that point,
     please, bring it again.
               DR. CATTON:  So under this new approach, how do
     you calculate the spiking factor?  Is it this 500 times the
     new lower primary system value?
               MR. HAYES:  That's correct.  That's correct.
               DR. POWERS:  I guess I don't understand that.
               DR. CATTON:  So it goes way down.
               MR. HAYES:  That's correct.
               DR. CATTON:  And what happens to what leaked into
     the primary system?  I don't quite follow -- I'm having a
     little bit of a problem with iodine conservation.
               MR. HAYES:  The iodine is not at the one anymore. 
     It is at some lower value.
               DR. CATTON:  Reduce the level.
               MR. HAYES:  Reduce the level.
               DR. CATTON:  Now I dump some in from the fuel
     because I've got leakers.
               MR. HAYES:  That's correct.
               DR. CATTON:  I now multiply that new value by 500.
               MR. HAYES:  That's correct.
               DR. CATTON:  Or do I multiply the 500 times the
     steady-state value before it leaked?
               MR. HAYES:  Before it leaked, because, for
     example, I think the question that you're getting to is
     saying, hey, can I have this massive amount of iodine into
     the gap that's just ready in there to break loose and it
     hasn't, because it hasn't been exposed to this differential
     pressure or this transient, whatever it is.
               And the question is, if you had that activity
     available for release, it would already be showing up into
     the primary coolant, if it's through the defects.
               DR. CATTON:  What it really gets down to is you're
     reducing -- if it's 500 times a lower number, where does the
     other go?
               DR. BONACA:  If I understand it, it reflects the
     conditions of the core.  If you have a very clean core where
     you have no leakage, because assume, for example, you have a
     brand new core coming in, where every defect has been
     replaced with a new fuel rod, so there are no defects.
               DR. CATTON:  So you wouldn't have much iodine.
               DR. BONACA:  You would have not much iodine.  Then
     if you have the accident, unless you postulate it, the
     accident causes the cracks in the cladding, which we don't
     believe that is the case.
               DR. KRESS:  It commits you to better fuel,
               DR. POWERS:  I don't think so.  It doesn't seem to
     me it does that at all; that there are multiple ways that I
     can get my primary coolant concentration down.  One of them
     is I can buy a better cleanup system.
               DR. KRESS:  Yes, but he said you account for that.
               DR. POWERS:  He accounts for that.
               DR. KRESS:  You go to the rate and you account for
               DR. POWERS:  I'm accounting -- I want to get my
     steady-state concentration, normal operation.
               DR. KRESS:  You increase the cleanup rate.  That
     doesn't help you any.  It doesn't help you any in here at
     all if you do it that way, because --
               DR. POWERS:  That's right, that's my point is it
     doesn't help you at all.
               DR. KRESS:  No, but they account for that, he
               MR. HAYES:  We have factored that removal rate
     into the production rate.
               DR. KRESS:  Yes.  They work on production.
               DR. POWERS:  I understand this all.  My point is
     that it does not commit you to better fuel.  There's another
     way around the barn here.  So you don't end up multiplying
               DR. KRESS:  You're basically right, but you still
     have to meet the dose limits.
               MR. BALLINGER:  But by having better fuel and by
     having, for a given cleanup system, a lower iodine
     concentration, you have a lower release rate, as well.
               MR. HAYES:  That's correct.  And I think it's
     important to realize that you cannot commit to these lower
     levels, like ten-to-the-minus-two or so, because as I
     mentioned, they're not comfortable at those levels, unless
     you have good fuel.
               Because what you see typical plants operating at
     now is like ten-to-the-minus-three, ten-to-the-minus-four. 
     That's typically what they're operating at.  And if they
     start to approach ten-to-the-minus-two, they get antsy.
               MR. BALLINGER:  It's about ten-to-the-minus-four,
     roughly, per failed fuel element.  So it takes about one
     failed fuel element for them to exceed their -- to make them
     get antsy.
               MR. SIEBER:  One rod.
               MR. BALLINGER:  One rod, yes.
               DR. BONACA:  I think, historically, we have to
     look at -- I mean, plants used to run with several defects
     years ago.  Today, I mean, since then, there has been the
     goal of INPO of zero defects, and I think the utilities have
     been very committed to it and it's very unlikely that you
     find plants --
               I mean, today, if you find a situation like a
     Seabrook, where they had eight fuel failures, they had
     measure inspection and evaluation of why you get those kind
     of issues, and repair it.  So I'm saying that reflects, in
     part, the way that the fuel is being treated today.
               MR. HAYES:  I think if you look at the spiking
     data, you can even see that.  You can see that the levels at
     which the spikes have occurred and the values of the spike
     have really changed with time.  You just don't see them
               DR. KRESS:  Could you address the 30 rems as
     opposed to the 300?  Was that just chosen for margin or was
     there another reason?
               MR. HAYES:  You know, this is my own
     interpretation.  There is no basis of fact.  My
     interpretation is there is a calculation which is done at
     the 60 and that has the full Part 100 value.  As I mentioned
     earlier, no one has ever come close to the 60.
               I believe that the reason that you have the value
     of 30 is to account for uncertainty both with the spiking
     factor and the fact that people have been at one and higher
     than one.
               So I think that was probably what was done,
     because at that time, in terms of accident analysis, a lot
     of thought was given to the more that you have the potential
     for a release, the lower you put the limit.  For example,
     that's why a fuel handling accident has a lower one.
               MR. HOLAHAN:  I think there's also another factor,
     because the approach of using some fraction of Part 100 is
     used in some other cases, as well, and I think Part 100, the
     guideline is set up for really a maximum hypothetical
     accident, which is considered to be extremely unlikely.
               And recognizing that some events, like tube
     ruptures are much more likely --
               DR. KRESS:  They're much more likely to happen, so
     you factor that in.
               MR. HOLAHAN:  You'd factor that in.
               DR. KRESS:  Makes sense.
               MR. HAYES:  It's important to understand that the
     staff's reassessment of iodine spiking was just one part of
     a total reassessment in terms of the way we did main steam
     line break accidents and steam generator tube ruptures as
     part of the rule, steam generator rule initiative, because
     we had a situation where industry is saying we're too
               We have the DPO, which says we're not conservative
     enough.  So we had the great opportunity to make no one
     happy.  So what we wanted to do, you know, we were really
     truly interested in the 1996-1998 timeframe, really
     reassessing how we do the accident evaluation.
               So one part of this was with respect to iodine
     spiking.  Now, the industry was proposing some iodine
     spiking models.  One was in a report by Postma, which was an
     empirical model. Another was a first principle model by
     Lewis and Iglesias, which the staff reviewed, but the staff
     determined was insufficiently mature, didn't have adequate
     V&V, and did not predict a priori what the spike would be.
               So then we went to look at a couple articles by
     Adams, articles he did with Sattison and Atwood, and the
     data that Adams generated was really also included in both
     the Postma and Lewis and Iglesias reports.
               Now, the Adams and Sattison article looked at 58
     events.  The spiking factors ranged approximately two to
     slightly over 900.  Issue activity levels ranged from
     roughly ten-to-the-minus-three to about one microcurie per
     gram.  The spiking factors in three cases were greater than
     500.  Two of those were in the range of about 900.  The
     activity levels associated with those spikes were roughly
     two-times-ten-to-the-minus-two or less, and the maximum
     activity in any case was 3.5 microcuries per gram.
               DR. POWERS:  I'm going to have to ask you what you
     mean by maximum activity.
               MR. HAYES:  That the activity, at the end of the
     spike, the maximum activity which was obtained in reactor
     coolant, measured in reactor coolant, was 3.5.
               These were Adams' and Sattison's conclusions. 
     They concluded that, first of all, large spiking factors
     tend to be associated with small coolant activity levels and
     small iodine release rates and that to assume that you have
     a spiking factor of 500 in association with a dose
     equivalent iodine value of one microcurie per gram is overly
               They recommended to expand the database to
     determine and reduce uncertainties.
               DR. POWERS:  It seems to me the codicil that the
     spiking factor of 500 in association with one microcurie per
     gram is very important.  That's a non-negligible statement
     there.  That doesn't seem to be in my viewgraph.
               MR. HAYES:  The viewgraph, I think it stopped --
     this --
               DR. POWERS:  That's the one I wouldn't leave out.
               MR. HAYES:  Right.  Well, in proofreading --
     you're correct.  In proofreading, that thought was missing
     and that was a very important thought.
               DR. KRESS:  That doesn't address the question of
     how conservative, if at all, the 500 is at some other --
               MR. HAYES:  That's correct.  At this stage, it
     does not address that.
               DR. KRESS:  Okay.
               MR. HAYES:  And Adams --
               DR. KRESS:  We always thought it was conservative
     at one microcurie per gram.  I don't think that was ever a
               MR. HAYES:  And you're correct.  The issue which
     Dr. Hopenfeld has raised is a new issue and wasn't really
     considered at the time that Adams was doing this work, per
               DR. KRESS:  I see.  Okay.  That helps.
               MR. HAYES:  Because I believe, and Dr. Hopenfeld
     can correct this, but I believe that this is work that Adams
     was doing for you in the Office of Research at the time.
               DR. HOPENFELD:  He was doing this for me and I
     just thought there was something missing there.  Yes.  He
     was doing this thing for me and we went through all the data
     that was the conclusion of, and I'm glad you caught that one
     microcurie, because that was really the key thing.
               But we didn't carry that beyond that point, for
     one reason or another, and that's what -- but I thought, at
     the time, they should have been carried, but we didn't.  So
     we stopped right here.
               MR. HAYES:  The next report by Adams was --
               DR. HOPENFELD:  Excuse me just one minute, if I
     may.  You left the impression that I'm trying to be more
     conservative, that I'm saying that the utilities are not
     conservative enough.  That's not really my point.  I don't
     know, they may be still very conservative.
               My point is that what you are doing is not
     justified, just arbitrarily taking that 500 and leaving it
     there while you're doing something else.  That's my point,
     my main point.  There's no technical justification to it.
               I don't know whether you're conservative or not.
               MR. HAYES:  The next report by Adams and Atwood
     looked at spiking and the information associated with LERs. 
     What they decided to do is they decided that they would
     bound each spiking event.  They decided that the -- they
     postulated that the maximum dose equivalent iodine-131,
     which is typically measured between two and six hours after
     the event, could be no greater than a factor of three higher
     than the measured value.
               So they decided that they would bound those
     values.  Let me show you --
               DR. KRESS:  Where did the factor of three come
     from?  Because that certainly is not decay.
               MR. HAYES:  I believe that the value, that they
     came up with a value of three was probably associated with
     the pressure differential associated with the vent.
               So they said, hey, we're going to presume that
     there is a linear relationship between the pressure
     associated with that particular --
               DR. POWERS:  Didn't they raise questions about
     exactly when the sampling was done in the solution and there
     may have been some decay?
               MR. HAYES:  There were three graphs that they
     presented, one of which did not include -- well, excuse me
     -- included the factors of three, but also corrected
     presumed -- I think that it was six hours and moved it back
     to two hours.
               MR. BALLINGER:  I don't think it says anywhere in
     what I've read that that factor of three is related to an
     increase in delta P.  That's why I asked the earlier
               DR. POWERS:  I think it's a sample in their
     analysis, a question that they had about the data that were
     available to them.  They came up and said, well, it can't be
     any worse than a factor of three.
               DR. KRESS:  It's uncertainty in the way you
     determine iodine-131 in a sample, I think.
               DR. POWERS:  That's my impression.
               DR. KRESS:  Plus, you might add a little decay if
     it's seven hours.
               MR. HAYES:  This is a curve of the Adams and
     Atwood data, which is without the factor of three.  You can
     see that the highest spike that they had was approximately a
     value of 4,000 and it occurred at around
     ten-to-the-minus-three microcuries per gram.
               You can look and you can see this is a spiking
     factor one and you see that there are data points which show
     a spiking factor of less than one.
               If you look at the data from about
     ten-to-the-minus-two, you can see that most of the points
     are a value below, roughly, I'd say, 700.
               DR. KRESS:  The points below the line imply that
     when you undergo this event, that the rate of release of
     iodine from the pins decrease over what it was normally.
               MR. HAYES:  And you're going to ask me why that's
     the case, and I don't know have an explanation, whether
     that's just the data.
               DR. KRESS:  It could be data uncertainty, you're
               DR. POWERS:  When I look at this plot, it seems to
     me my first reaction is, gee, I believe I could run a
     straight line through these data on a log-log plot, and when
     I think about doing that, coming up and then using that
     straight line to make estimates on the spiking factor as a
     function of the RCS initial activity, I put error bounds
     around it for what the error in the estimate would be.
               Because I run out of data at the one microcurie
     per gram, I would think that those error bounds would turn
     up pretty dramatically.
               Have you made such a plot?
               MR. HAYES:  We did.  What we did is when we got
     done with the industry data, Adams and Atwood, we thought,
     well, we think that probably the spiking factor is a
     function of reactor coolant activity level and we can have
     -- we'll have our contractor analyze this data and hopefully
     we'll come up with a plot of spiking factor as a function of
     primary coolant activity level.
               And we couldn't get a good correlation and we
     really thought that we were going to be able to do that. 
     When we went into it, we thought we would be able to do it.
               DR. CATTON:  But you could easily get a bounding
     curve for this.
               MR. HAYES:  And we did and the bounding value that
     we got, the 95th percentile value we got was 335.
               DR. CATTON:  That's a single number.
               MR. HAYES:  That's a single number.
               DR. CATTON:  335 times --
               MR. HAYES:  Times whatever the release rate would
     be at equilibrium.
               DR. CATTON:  How is that bounding?  I can see one
     here that's more than 1,000.
               MR. HAYES:  We didn't take the highest value.  We
     took a 95th percentile value.
               DR. CATTON:  So that means you weighted a lot of
     these negative ones down here.
               MR. HAYES:  That's correct.  That's correct.
               DR. POWERS:  When I look at these data and I stand
     far enough back from the plot, I say, gee, it looks to me
     like there are two populations of data here.  There is a
     population that comes along and includes these low ones and
     there's a population above.
     Did you look at the data set to see if there was any
     indication there were two populations?
               MR. HAYES:  We asked Adams about that to see if he
     had an explanation and he didn't have an explanation.
               MR. HIGGINS:  That's a different question.  What
     Dr. Powers asked is if you did it.
               MR. HAYES:  No, we did not.
               MR. HIGGINS:  Is there at least some consistency
     at a given plant?  This is across many plants.  Do you have
     multiple data points at a given plant?
               MR. HAYES:  We have multiple data points, but I
     don't think we would have a sufficient amount to really say
     that this would be reflective of a plant.
               See, I think one of the problems you would have
     with such an evaluation is because of fuel changes.  A lot
     of the spiking data that we have is pre-1980 data, in the
     '70s, because that's when you had a lot of these events. 
     And it's really not reflective of the conditions that you
     have now.
               It will give you data, but it's not really
     reflective of what we have today.
               MR. BALLINGER:  Has it been plotted as a function
     of the delta P?
               MR. HAYES:  No, it has not.
               DR. CATTON:  The points that are below that line
     are really kind of perplexing.  I don't know how you can use
     them if you can't explain them.  Maybe it's an error in your
     data processing.  Maybe it's an error in your readings.
               So how can you use it when you attempt to
     calculate some kind of a factor?
               MR. HOLAHAN:  I would suggest it's not really
     reflective of what we have today.  If you think about what
     it means to go to the left on that chart, you're dealing
     with very small numbers and you're dealing with the ratio of
     small numbers, and I would expect the uncertainties to get
               There are two things going on.  I think Dr. Powers
     suggested that there is less data as you go to the higher
     numbers, clearly, but the numbers are harder to calculate as
     you go to the left, so the uncertainties get larger.
               DR. CATTON:  I understand that, but normally when
     you look at a plot like this and you're trying to figure out
     what's going on and you want to come down on the safe side,
     if the bottom data points which pull the number down can't
     be explained, it seems to me they should be eliminated until
     they can and not be a part of the process that leads to the
               MR. HIGGINS:  Or call them, call them spiking
     factor of one.
               DR. CATTON:  You can weight them.  I mean, there's
     all kinds of techniques for dealing with these things.
               MR. HOLAHAN:  But recognize that this is a log
     plot and they don't change the answers by all that much.
               DR. CATTON:  I see that, I see that.
               MR. HOLAHAN:  I think you should have the same --
               DR. CATTON:  I have a straight line that
     beautifully --
               MR. HOLAHAN:  You should have the same question
     about the value of 4,000, which has a large uncertainty on
               DR. CATTON:  It depends what you're trying to do. 
     You would ask the same question about the points that sit
     way up by themselves, except that they're more important.
               MR. BALLINGER:  But there's very few instances
     where you would just arbitrarily eliminate data points, but
     one of them would be if it's simply non-physical, it can't
     happen.  Now, is that the case here with the ones that are
     less than one?  Is that a non-physical situation?  That is
     to say, it just can't happen.
               MR. HAYES:  I think Gary Holahan's point is a good
     point.  Remember that the spiking factor has a numerator and
     a denominator and the values associated here are very low.
               MR. HOLAHAN:  It may be non-physical, but it's
     giving you some insights as to the measurement of
               DR. POWERS:  If we were to put error bars on these
     data points, about how big would they be?
               MR. HAYES:  Since I didn't take the measurements,
     I really couldn't answer that.  I'm sorry.
               DR. BONACA:  It could be, in effect, related to
     the type of transient that is taking place.  For example, in
     a steam line break, you have a depressurization in a system,
     where probably, in the short term, you have almost
     equalization, you could have, between system pressure and
     internal pressure of the fuel rod.
               MR. HAYES:  It's important to understand that each
     of the -- none of these events involve a main steam line
               DR. BONACA:  But you have a scram.  All right.
               DR. KRESS:  These are all team generator tube
               MR. HAYES:  Well, there are a couple of steam
     generator tube ruptures, but most of them are transients. 
     They do not involve a steam generator tube rupture. 
     Fortunately, we have not had that many steam generators, or
     we might be dealing with a different issue.
               MR. BALLINGER:  Which points on here deal with the
     steam generator tube ruptures?
               MR. HAYES:  I would have to go back to the
     original Adams and Atwood.  I couldn't tell you at this
               DR. POWERS:  It would be a substantial chore, even
     if you went back to it, sorting through his table to figure
     out which points are which.
               MR. BALLINGER:  But valuable.
               MR. HAYES:  I think you have the Adams and Atwood
     and Adams and Sattison articles from Nucleonics Week, I
     think, or some --
               DR. POWERS:  Nuclear Technology.
               MR. HAYES:  Nuclear Technology.  And I think he
     does list in those documents which ones are steam generator
     tube rupture events.
               DR. POWERS:  Then when you find them and you go in
     and try to find the point on the plot, it's a chore.
               MR. HAYES:  This is the same data multiplied by a
     factor of three and that value, you can see, takes you
     around 10,000.
               Okay.  The conclusions by Adams and Atwood, you
     know, in many respects, similar to the conclusions of his
     previous article.  In other words, a spiking factor could be
     reduced substantially, he believes, by a factor of 15 and
     still be conservative.
               Again, it's important to point out that we're
     talking at the one microcurie per gram area.  That's what he
     was addressing.  I don't want to give you a misleading
     impression.  That's what he was focusing on.
               And the large spikes occur not because the
     post-trip release is large -- in other words, the numerator
     is large -- but, rather, because the steady-state release is
     low -- in other words, the denominator is small.
               And that the spiking data that he had was really
     representative of a steam generator tube rupture rather than
     a main steam line break.
               When we did our reassessment of the spiking
     factor, we reviewed the data without the factor of three
     and, as I mentioned previously, we thought we could assess
     it and come up with a relation as a function of reactor
     activity level.
               DR. POWERS:  Let me understand a little better. 
     Adams had a reason for the reactor of three.  He did it not
     out of any capriciousness.  He did it because he --
               MR. HAYES:  He wanted the bounds.
               DR. POWERS:  But he had a rationale for choosing
     three.  I mean, it wasn't a number that he plucked out of
     the air, I don't think.  I think he made arguments about
     sampling and stuff like that, as Dr. Kress pointed out.
               Have you rejected all those arguments?
               MR. HAYES:  No, we didn't reject -- in reality, it
     probably doesn't make a difference, because we -- his
     argument was at the value of one, the value of 500 was
               DR. CATTON:  Well, it is, but from that chart you
     put up there, it looked to me like it's only maybe a factor
     of five.  Put that chart back up, the first one you had up
               I think that's one that's on the right-hand side,
     isn't it?
               MR. HAYES:  Right.
               DR. CATTON:  How can you get a factor of 15?  Do
     you take the mean through all those points?  Is that what
     you're doing?  The 95 percent level, just looking at the
     graph, looks to me like it's about 90.  Maybe I'm not
     eyeballing that quite right.
               MR. HAYES:  You're asking me to justify his
     conclusion and I'm not going to --
               DR. CATTON:  That's fine.  But you're asking me to
     accept 335 based on him saying that it was 15.  I'm just
     turning that around.  I think it's fair.  Don't you?
               MR. HAYES:  That's fair.
               MR. HOLAHAN:  Well, wait a minute.  I don't want
     to be too fair.  I think the 335 is an analysis of the data,
     independent of whether someone else concluded that 15 could
     be drawn out of that data, and we've shown you the data.
               DR. CATTON:  Well, I'm still bothered by the fact
     that you can't explain the data points, yet you want to
     treat them all as equal, and it seems to me that if you
     can't explain the low ones, which weight the number, then
     you ought not weight the final result by those points.
               DR. POWERS:  On the other hand, if I look at the
     data and I said, gee, I was going to take a 95 percentile
     and I threw away everything that I call on my second
     category, 335 isn't going to be far away from what the one
     microcurie per gram.
               I mean, it's not going to be far away and I'm not
     going to be -- if I'm in a bounding sense, for that one
     point, I'm not going to feel bad.  In fact, I'd probably
     feel guilty about picking a number that high.
               DR. KRESS:  If you did multiply the number by
     three, however, you would multiply that 300-and-something by
     three, basically.
               DR. CATTON:  But, Dana, they're going to run out
     at .001.  Now, we haven't gotten to a number for .001 yet. 
     Well, it's 335 times .001 as the spiking factor.  Where are
     you going to fall on this graph when you do that?
               MR. HOLAHAN:  The .001 never shows up in a
     regulatory analysis, because there are not and there will
     never be any tech specs as low as .001.
               We're only talking about the portion, that curve
     between one and a few tenths.
               DR. CATTON:  I take .1 and multiply it by 335,
     what do I get?  33.5.  I'm down to the middle of all those
     data points.  That doesn't look very conservative to me.
               DR. BONACA:  To the right.
               MR. HAYES:  At .1, you're right here.
               DR. CATTON:  But if I multiply .1 by 335, I'm
     going to be just a little bit above that ten over there. 
     That's a log scale.
               DR. POWERS:  Why would you want to do that
     multiplication?  Well, they're going to use the tech spec of
     .1.  They still won't be multiplying the spiking factor.
               DR. KRESS:  They won't be multiplying this number. 
     They're multiplying some other number.
               DR. CATTON:  What number do you multiply 335
               MR. HAYES:  You multiply by the release rate
     associated with this particular activity level in the
     coolant.  In other words, for example, we don't presume that
     the activity level is now 33.5 because we multiply 335 by
     this value.  No.
               What it is is release rate and you build up in the
     activity in the primary coolant.
               DR. POWERS:  He's going to take a removal rate and
     a release rate and find a steady -- choose that release rate
     such that it matches the steady-state value of .1.
               DR. KRESS:  That's what they're going to do.
               DR. POWERS:  And he's going to multiply that
     release rate by a number.
               Now, if the steady-state value were one microcurie
     per gram, we know it's 335 he's going to multiply it by.
               MR. HAYES:  For a steam generator tube rupture.
               DR. POWERS:  For a steam generator tube rupture.
               MR. HAYES:  Not for a main steam line break.
               DR. POWERS:  Exactly.
               MR. HAYES:  I think it's important, with respect
     to the point that you raise, is that since we did not take
     the data, it's inappropriate, I think, for us to throw any
     of these points out, because we have -- what is the basis?
               I mean, you can go argue from either stage.
               DR. CATTON:  It depends what you're doing.  If
     what I'm looking for is just a mean curve through the data
     of some kind, fine, but this is the safety business.  If you
     don't understand it, how can you use it to bring the number
               MR. HAYES:  But it's a safety business, but at the
     same token, we have to be somewhat realistic.
               DR. CATTON:  There's nothing wrong with being
     realistic if you understand it.  If you don't understand it,
     it seems to me it's inappropriate.
               MR. HAYES:  But it is also inappropriate to throw
     it out because you don't understand these points, as you
     don't understand these points.
               DR. CATTON:  Depends whose side you're on.  If
     you're putting a barrier between me and the plant, I don't
     want you reducing anything that you don't understand.
               DR. POWERS:  That's one of the reasons we wanted
     to explore the phenomenology a little bit is that the lower
     points do seem to be physical, whereas the upper points,
     high though they may be, at least are not inconsistent with
     the argument on why there is a spiking factor all together.
               MR. BALLINGER:  But the physics, the description
     of the phenomena that you gave right off the bat matches
     what you would see, but the low points, the ones that are
     less than one, don't match it at all.
               MR. HAYES:  I don't disagree.
               MR. HOLAHAN:  I think if you were to put error
     bounds on the measurements, real error bounds on the
     measurements, they would, by definition, on the lower end,
     be large enough to be above one, and then you ought to put
     those error bounds on all the data and you'll see, as you
     move to the left, the error bounds get very, very large.
               DR. POWERS:  If that's true, the error bounds
     would cross multiple decades.  I think if you were doing a
     regression of the data, that you would take that into
               Those data points, they are high and low, would
     count very little, which is fine because as you said, the
     only part of the curve that you're really interested in is
     one, maybe .05, at most.
               MR. HOLAHAN:  Right.  Personally, I see the data
     in different ways.  In my mind, the data between .1 and one
     is reflective of what we might possibly use in the
     regulatory process.
               By the way, all of those data points are above
     one.  The rest of the data, in my mind, is sort of a
     demonstration that, in fact, iodine spiking is a real
     phenomenon, that it is seen, and you have a lot more data
               But I don't think it tells you a lot about the
     range and the statistical analysis on the right-hand curve.
               DR. POWERS:  I think that's the point that's going
     to be -- we're going to discuss a lot of things here, but I
     think that's the most distressing thing; that let's confine
     ourselves one to .1, because that's all we're going to use,
     and say -- I'm looking at a log-log plot here and there is
     scatter on a log-log plot.
               That suggests to me that we do not have the really
     operative physical variable being plotted.  Much of these
     data, similar to a steam generator tube rupture, are not
     steam generator tube ruptures.  There's some other accident.
               There is something affecting those data over a
     decade in value other than just the activity in the coolant. 
     In fact, we think the activity in the coolant can't possibly
     have any relationship to the mechanism giving us a spiking
     factor, second order, maybe.
               How then can we be confident that a bounding that
     he does even at 335 really represents a bound on what
     happens in the steam generator tube rupture, if there is
     some other variable that is really controlling that spiking
               Otherwise, you've got a Poisson problem here. 
     These happen to be the 25 data points that you've actually
     measured, which may accidentally not hit the particular
     value of the controlling variable that gives you high value.
               DR. CATTON:  I think if you cut the data off where
     you suggest and you were to redo it, you'd get a bigger
     number than 335.
               DR. POWERS:  You may be right.
               MR. HAYES:  Everything high seems to be at about
     .05 on down.
               DR. CATTON:  Any time you have two decades of
     spread, you really ought to go back and replot it, and if
     you can't go back and replot it, you put a curve over the
     top of it.  You can't explain it and to do anything else, I
     think, is an in-road on the margin of the plant, because you
     don't know what point is there for what reason.
               MR. BALLINGER:  I think the idea -- the contention
     that you may not have the right variable is probably the one
     that's closer to the mark, that you just don't have a handle
     on the phenomena.
               MR. HAYES:  There is no question that the iodine
     spiking has not been pinned down specifically.
               MR. HIGGINS:  Isn't it really a plant-specific
     thing?  A fuel, actually a fuel and a core load specific
     thing.  It seemed like the amount of iodine that leaks out
     is very much related to the type of defect you have in the
     fuel and the specific type of fuel.
               So what you're seeing here is a demonstration over
     many cores, over many years at many different plants.
               MR. HAYES:  Exactly.  And I think I made reference
     to the fact that most of this data comes in pre-1980.
               DR. CATTON:  It sort of presents an option,
     doesn't it?  You either accept it or you go back and do it
     again and do it right.
               DR. POWERS:  I think there's another alternative
     here that I'd like to understand a little better.  You
     mentioned the Iglesias-Lewis report and I think there's also
     an EPRI empirical report and in both of those reports, they
     look at some notable events and they plot predicted curves
     versus the iodine concentration, I believe, and they're
     remarkable, actually.
               I mean, the closeness with which they get just
     really amazes me.  And there's a substantial time variation
     in what they're comparing against.  Can you tell me why
     those empirical and mechanistic models were just cast out in
     favor of this data?
               MR. HAYES:  They weren't cast out.  What we did is
     we had a contractor, INEL, evaluate those models and they
     thought that the -- after looking at the empirical model,
     they thought that probably the model to really look into and
     expend their resources on was the Lewis and Iglesias.
               And what happened was they evaluated the Lewis and
     Iglesias model and what they did is, for example, if the
     event was at Prairie Island, they tried to take that model
     and utilize the predictiveness to determine what the spike
     would be for Prairie Island.  
     And when they did that work, you couldn't take it and
     predict it for Prairie Island, San Onofre, Watts-Barr or
     whatever.  They couldn't come up with it.
               So I think the way I related to it is similar to
     when you're in a lab and you're trying to come up with a
     relationship.  You do it after you have the data versus
               So a priori, they couldn't come up with a
     predictive tool using the Lewis-Iglesias.  Adams, when we
     discussed this with him, he says he recommended, if we could
     modify the Lewis and Iglesias model, that that would be an
     approach to go and, therefore, maybe we could come up with a
     predictive tool, and that was one of the things we raised
     with industry, but industry did not choose to pursue it.
               DR. CATTON:  If you did fit -- if you fit a curve
     over just the two top data points, I bet you'll get a factor
     that is much less than the 300 when you're operating greater
     than .1.  You're going to get about 120.
               MR. HOLAHAN:  Log scale, I think you get about
               DR. CATTON:  Just by bounding the data.  It's a
     nice logarithmic curve.
               MR. HOLAHAN:  But let me suggest that this is one
     piece of a design basis dose calculation which has lots of
     other conservatisms in it, like 95th percentile meteorology
     and lots of stuff.
               And if we're not careful, we'll end up making
     every step in every calculation so conservative that the
     answers are meaningless and we're in danger of convincing
     ourselves to do things which risk-informed regulation, in my
     mind, is trying to get us away from, which is to put lots of
     attention on things that aren't necessarily important.
               So when you say we could be more conservative by
     drawing the lines differently, that can be true, but that's
     not always the best regulatory approach.
               DR. CATTON:  You could include uncertainty in
     whatever fit you put on this, too.
               DR. POWERS:  Fortunately, our concern right now is
     really going contention by contention and not designing a
     regulatory process.
               MR. HOLAHAN:  I've tried to preserve a concern
     that we ought to have an overall safety perspective and the
     regulatory approach in mind when we deal with each of these
               MR. HAYES:  Okay.  What did we conclude with
     respect to iodine spiking?  Well, we concluded that it was
     not a function of the reactor coolant activity level.  We
     did envelope the value, as we mentioned, and we came up with
     a value of 335 and, again, that is what we considered to be
     representative of a steam generator tube rupture and not
     representative of a main steam line break.  I think that's
     important to understand.
               What are our conclusions with respect to the
     spiking associated with the main steam line break?  Well, we
     concluded that you cannot extrapolate the spiking data from
     the data we have to a main steam line break, but we can do
     some sort of an assessment.  We believe that there is a
     linear relationship between the differential pressure rate
     and the resultant iodine activity or release rate.
               Now, because of the pressure, differential
     pressure associated with the main steam line break being
     maybe a factor of two or three greater than for a steam
     generator tube rupture, if you consider that to be two or
     three times the factor for a steam generator tube rupture,
     you also can say, well, maybe the expression is a
     quadriture.  So instead of a factor of two or three, the
     value is four to nine.
               I think we feel confident and we've had some
     discussions with Adams that it's reasonable to assume that
     the expression is no higher than a quadriture.
               DR. POWERS:  I guess I would understand that
     better if I understood the first line.  You said there was a
     linear relationship between the delta P and the resultant
     iodine activity level or release rate.
               Why do you have that confidence?
               MR. HAYES:  I think because, you know, it is the
     delta P that causes the spike, it forces the fuel out of the
     gap into the reactor coolant.
               DR. POWERS:  That delta P arises because of the
     vaporization of water on the hot fuel.
               MR. HAYES:  The delta P originates from the change
     in the fuel temperature and pressure and the primary coolant
     temperature and pressure.  Then when you get to the main
     steam line break, the presumption is that you have it with a
     loss of off-site power.  So you're going from the primary
     side to the secondary side and you have a direct release
     associated with the main steam line break.
               You don't have the cover associated with it like
     you do with a steam generator tube rupture.
               DR. KRESS:  The delta P rate you're talking about
     here is the rate of change of pressure on the primary system
     in the vicinity of the core.  I don't know what delta P
     you're talking about here.
               DR. BONACA:  I had the same question.
               DR. KRESS:  It's a del P, so it's a rate of change
     with time.
               MR. HAYES:  It's a change with -- it's not a rate. 
     It's a delta P, period.
               DR. KRESS:  But what delta P is it?
               DR. BONACA:  But is it a delta P between the
     primary system pressure and the pressure inside the fuel
     rod, or is it the pressure --
               MR. HAYES:  It's the pressure between the primary
     side to the secondary side.
               DR. BONACA:  Explain to me what effects that has
     on the fuel cracks opening and accepting more water inside
     and vaporizing and then exiting from the fuel rod.  I don't
     understand how the delta P between primary and secondary
     side is affecting that.  I'm trying to understand it.
               MR. HAYES:  For the main steam line break, the
     faulted steam generator, that which experiences the break,
     is considered to be at atmosphere.
               The leak which we have is then from the primary
     side to the secondary side.  We get a rather rapid
     depressurization on the secondary side.  So you set up
     between the primary and secondary a higher differential
               Then the primary pressure goes down faster than it
     would for a steam generator tube rupture.  So the pressure
     between the fuel and the primary side is a larger -- is a
     quicker and a larger delta P.
               DR. BONACA:  Between the fuel and the primary
               MR. HAYES:  Between the fuel and the primary side.
               DR. BONACA:  Okay.  I understand.
               DR. HOPENFELD:  Part of the study came out of the
     Adams study that we were going to look -- take one step
     further, and that is, if you have to look at that data in
     relation to the depressurization, what happened during this
     transient and if you look at some of the data or some of the
     reports on that subject, it shows that you can very, very
     low release rate; in other words, you have very, very few
               Then you find in those cases, all the activity
     comes out at the end of the transient, where you really have
     to depressurize is very, very high, and that suggests that
     when you have a steam line break, you have much more release
     because of the high depressurization.
               In other words, there is a relation between the
     number of defects you have and how fast you depressurize the
     system.  But nobody really has taken the time to look into
     that beyond that point.
               I can provide you the conclusion of a very lengthy
     report that was generated at Westinghouse.
               DR. KRESS:  I'm still confused by that first line. 
     Tell me again what the delta P is.  Is it between the
     primary and the secondary?
               MR. HAYES:  Okay.  It starts out between the
     primary and the secondary and the secondary -- okay.  With
     the main steam line break.
               DR. KRESS:  Yes, and it has a fixed value at
     normal operation.
               MR. HAYES:  Normal operating.  Then with the steam
     line break, you go to atmosphere.
               DR. KRESS:  That's right.  So that --
               MR. HAYES:  That reduces it down --
               DR. KRESS:  That reduces it.  It increases the
     delta P.
               MR. HAYES:  It increases the delta P, and then you
     have --
               DR. KRESS:  Are you talking about the rate of that
               MR. HAYES:  It increases both the rate and the
               DR. KRESS:  The net and the rate.
               MR. HAYES:  Right.  Because you're going -- like,
     you're comparing it to a steam generator tube rupture.
               DR. KRESS:  What in the world should that have to
     do with the rate at which you extract iodine from the fuel?
               DR. BONACA:  The only way I would see it would be
     that the primary system pressure is also dropping fast.
               DR. KRESS:  That doesn't say that, though.
               DR. BONACA:  That's right.  So that's why I was
     confused.  I mean, I believe that -- I believe that the
     difference in pressure between internal pressure of the rod
     and the primary system, it's varying rapidly.
               DR. KRESS:  Then I could see it would have a
     marked effect on it, but this difference between primary and
               MR. HAYES:  But why is the primary varying?  The
     reason the primary is varying is because you have a change
     on the secondary side, also.
               DR. BONACA:  Sure, but --
               MR. HAYES:  So you can't separate one from the
               DR. BONACA:  I understand that, but that's a
     driving force by which you are having a changing
     relationship between primary system pressure and internal
     pressure in the fuel rod, and that's the mechanism by which
     you would expect to have release of iodine activity to the
     higher level.
               DR. KRESS:  Let's say, for example, that you had
     no leaking steam generator tubes at all and you had this
     break in the secondary side, you get a marked change in this
     delta P and the rate may even vary with time, does nothing
     at all to the primary system because it's just sitting
               There's no leak coming out.  It's all driven by
     the secondary change and should have no effect on the iodine
     spiking at all or the iodine levels.  That's why I don't
     understand the statement.
               DR. BONACA:  The only thing you have is scram and
     that will have some changes in system pressure.
               DR. KRESS:  If you scram, yes, but that's --
               DR. BONACA:  That doesn't have the same effect. 
     So the driving force, seems to me, it would be on the effect
     that we're looking for would be the difference between
     primary system pressure, driven by --
               DR. KRESS:  Driven by that, yes.
               DR. BONACA:  -- the steam generator break.  I
     understand that.  And the internal pressure of the fuel rod.
               MR. HAYES:  But it will change your cool-down
     rate, though.  You say it will not an effect, but it will
     have, because it will change your cool-down rate, because
     you're using the intact steam generators to cool down the
     primary side.
               DR. KRESS:  It might have some effect, you're
     right.  That's pretty --
               DR. BONACA:  What is the average internal pressure
     of the fuel rod?
               DR. POWERS:  During operation?
               MR. BALLINGER:  What's the internal pressure?
               DR. BONACA:  Yes.
               DR. POWERS:  An intact one?
               DR. BONACA:  The fuel rod in a -- well, I'm
     talking about an intact one.
               DR. POWERS:  It would run about 100 atmosphere.
               DR. BONACA:  That's right.
               DR. KRESS:  So you look at that delta P that you
     normally get with the steam generator tube rupture and then
     you look at it, once you get to the main steam line break,
     and that's where you get this factor of two to three.
               MR. HAYES:  Right.
               DR. KRESS:  If you square that, you get four to
               MR. HAYES:  That's correct.  So what we concluded
     with respect to the main steam line break, and, again, this
     was in conjunction with the steam generator rule and
     addressing the issue of conservatisms in our evaluation, was
     that for a main steam line break, we thought that there was
     probably an uncertainty factor of ten.
               Adams indicated, for a steam generator tube
     rupture, there is a conservatism, he believed, was a factor
     of 15.
               DR. CATTON:  This is the 15 I don't like to use.
               MR. HAYES:  This is the 15 you don't like to use,
               DR. POWERS:  But what I don't understand is that
     you went through and you looked at the data and you said,
     okay, I'm not buying this factor of three bounding and you
     looked at it and you came up and you said 335 versus 500,
     which is not a factor of 15.
               How come now, all of a sudden, you grab a hold of
     Adams' factor, which nobody understands?
               MR. HAYES:  Because we incorporated more than just
     that particular factor.
               DR. POWERS:  I kind of wish you would tell us what
     those things were, because otherwise, this third statement
     down here is just going to cause me to --
               DR. KRESS:  To go ballistic.
               DR. POWERS:  Yes, ballistic, because that is
     definitely not the way you handle combined uncertainty.
               MR. HAYES:  The imaginary axis.
               DR. POWERS:  I mean, this is not even -- would not
     be acceptable in anything that I can think of, where you
     take two things that you don't understand at all and say
     they offset each other.
               MR. HAYES:  We concluded that the doses associated
     with a main steam line break are typically on the order of
     one to three rem, the ABLPZ, control room.
               There is also a parametric analysis which we have
     done to demonstrate what the spiking factors would have to
     be in order to get a dose which would exceed Part 100.  The
     criteria -- remember, the criteria associated with this is
     for a dose of 30 rem, not 300, but for 30.
               Even if you took the factor of 335, which is a
     value, what, of 1.5, roughly, 1.6, 7, and take this factor
     of ten, in our opinion, you are still within the uncertainty
     that we had and still within the margin.
               DR. POWERS:  I can buy arguments that go that
     direction.  I just can't buy this slide.  I find no
     technical justification for the third sentence.  That's the
     problem.  A bounding operation that came in and said, look,
     the sensitivity to my dose calculation or the spiking factor
     is smallish.  I have to get a very big value that seems to
     strain quadrulity to approach the limit, so I'm going to
     leave it at 500.  I'd say, okay, fair enough, that's a
     decent argument, and go on.
               Something that's just orthogonal to the treatment
     of uncertainties, this gets me excited.  You're more relaxed
     than I am.
               DR. KRESS:  I just don't show it.
               DR. CATTON:  This last statement about should
     remain 500, that sounds like you completely -- you have
     either written off or ignore or don't believe that the main
     steam line break can have some impact on the internals of
     the steam generator, because it's certainly -- at least from
     what we heard yesterday, it's most likely going to cause
     more leakers.  
               Shouldn't that be factored in somehow?
               MR. HAYES:  It's already included when we
     postulate that those tubes which have voltage-based
               DR. CATTON:  But that's before.  If that's what
     you're doing, what you're saying is that the main steam line
     break does not cause any disturbance inside the steam
     generator.  The tubes are going to stay exactly the same.
               MR. HAYES:  No.  What we have presumed is that we
     have presumed that those tubes which have voltage-based
     criteria, those cracks are going to open up and they're
     going to leak at a defined rate.
               In other words, every tube to which that criteria
     has been applied is assumed to leak.
               DR. CATTON:  But that leakage correlation was
     derived from tested tubes that have not been subjected to
     the main steam line break.  Am I missing something?
               MR. STROSNIDER:  This is Jack Strosnider.  I'm not
     sure that Jack Hayes heard the discussion yesterday on
     dynamic effects and some of the Surry and other experience. 
     We're going to talk about that later today.
               DR. CATTON:  But it impacts this.
               MR. STROSNIDER:  Well, it may or may not.  I think
     apparently you've reached a conclusion that those events
     are, in fact, going to cause additional damage to the tubes
     and we heard the discussion yesterday.
               We've put this into the GSI process and we're
     going to hear about how that's being looked at.  If, in
     fact, we conclude that those dynamic effects are going to
     have that sort of effect on the tubes, then we'll have to
     deal with it, but I don't think we've seen that concrete
     evidence to this point.
               There's certainly, in my mind, some things that
     ought to be followed up on with regard to was there a
     post-event inspection of the steam generators, what did they
     actually find, the tubes that were indicated as having
     degradation in yesterday's presentation, it wasn't totally
     clear that that was a result of the event.
               So I think it's an issue that needs to be looked
     at and when we determine whether it really has an impact on
     the tubes or not, then we need to come back and deal with
     it.  But at this point, you're right, the model does deal
     with pressure-induced leakage, and we'll talk about that
     later today, too.
               DR. CATTON:  Just if you had another line down
     there that said that this is an assumption.  See, you're
     basing this on the assumption that the main steam line break
     does nothing to the internals of the steam generator and at
     this point, that's your assumption.  I can read it, I
     understand it, we can go on.
               MR. STROSNIDER:  Right.  And we've got some new
     information here that needs to be assessed and we're going
     to do that.
               DR. CATTON:  That's right.  But that isn't what he
     was telling me.
               MR. STROSNIDER:  And like I said, coming back to
     my some of my introduction this morning, we need to go
     through and hear all the issues and look at how they all fit
     together, and that's a fair comment.
               DR. CATTON:  That's fair enough.  That's fair
     enough, but I would liked to have seen another line on that
               MR. HOLAHAN:  Remember, it's more than assumption. 
     It's a requirement.  Plants are licensed and that licensing
     basis includes looking at main steam line breaks and tube
     ruptures, but it doesn't include main steam line breaks
     damaging tubes.
               And if we find some basis for thinking that that's
     true, we'll have to deal with it, but the licensees will
     have to deal with it because that will be inconsistent with
     the current requirements.
               MR. HAYES:  Now, getting to the assessment of the
     DPO concern, we did a parametric analysis and we presumed --
     we used, as the base case, a three-loop Westinghouse plant
     and we did the analysis consistent with a standard review
     plan 15.1.5, which is the main steam line break.
               And we presumed tech spec value one microcurie per
     gram.  The primary to secondary leak rate was 150 gallons. 
     This should be corrected on your slide to per steam
     generator.  And this value is, instead of 1290, should be 11
     -- I think it's 1140.
               I didn't conclude the two steam generators, just
     the one.  It really doesn't have an effect -- it was
     included in the analysis, but not in the slide.
               Spiking factor was 500 and what we did is we
     calculated the releases for zero to two hour and zero to
     eight hour time period.
               Some other critical assumptions that we had, we
     assumed that it was eight hours for the faulted steam
     generator to be isolated.  All primary and secondary leakage
     was assumed to be released directly to the environment.  We
     did not presume, for example, for the intact steam
     generators, any partition factor.
               It really doesn't have a whole big effect on it,
     an assumption, it's probably in the third decimal place or
     third significant number.
               Spiking was assumed to occur for the duration of
     the accident and --
               DR. KRESS:  What does that mean?  Does that mean
     that you kept the rate that you calculated constant over the
     whole eight hours?
               MR. HAYES:  Yes, for the whole eight hours.  You
     think that's conservative?
               DR. KRESS:  I think that is.
               MR. HAYES:  And here is another big assumption. 
     We assume that the releases associated with zero to two
     hours and zero to eight hours equated to a 30 rem thyroid
     dose.  Now, as I've mentioned before, the typical values we
     see are somewhere between probably one to five or six rem.
               Then we did a parametric analysis.  We assumed
     three different primary to secondary leak rates, ten, 35 and
     100 GPM.  We assumed five different primary coolant activity
     levels.  I think your slide has an error, a typo.  This
     should be ten-to-the-minus-two.  I think in your slide it
     has ten-to-the-minus-three.  But these are the numbers we've
               DR. POWERS:  Gary tells us that .005 is not and
     will never -- ever going to occur.
               MR. HOLAHAN:  That's right, and the reason is not
     because I'm against low primary coolant activity.  It's
     because I'm against allowing leakage rates higher than 100-
     GPM, which is what the implication is.  And the point is the
     design basis calculations may come out with a reasonable
     dose, but the severe accident implications I think we would
     find unacceptable.
               I think we will cover those sort of issues later.
               MR. HAYES:  I may need to go put in some
     clarifying information with respect to that.  I think we
     need to probably check what the value was associated with
     Byron and Braidwood, because I think Byron and Braidwood had
     a number which was either at 100 or slightly greater and the
     value may have been down below .05.
               But that's something we need to check on, because
     they have subsequently -- I think that was for one cycle and
     they subsequently replaced their steam generators.  That
     would have been Byron Units 1 and 2 -- excuse me -- Byron
     and Braidwood Units 1.  Unit 2 did not change steam
               MR. BALLINGER:  These leak rates are prior to the
     event or during the event?
               MR. HAYES:  This is during the event.
               MR. BALLINGER:  During the event.
               MR. HAYES:  During the event.  What you can
     consider this to be is your accident-induced leakage.
               DR. KRESS:  You're calculating the spiking factor
     you would have to get to get a 30 rem dose here.
               MR. HAYES:  Well, it was presumed that the release
     that we calculated for zero and two hours gave you a 30 rem
     dose.  It did not.  It did not, but we presumed that.
               DR. KRESS:  Okay.  And you back-calculate those to
     find out what the spiking factor would --
               MR. HAYES:  Right, exactly.
               DR. KRESS:  -- would give you that.
               MR. HAYES:  Right.  Here is what we did, for
     example.  Let me walk you through a couple cases.  We
     presumed RCS activity was .5.  We took a ten GPM leak rate. 
     In order to come up with the same release rate, we would
     have to have gotten a spiking factor of 86.3.
               So for example, if you wanted to operate with the
     ten GPM leak rate, based upon our criteria, you would have
     to go down to a spiking factor of 500 before it would be
     acceptable to the staff.
               So you would go down to the -- the reactor coolant
     activity level would have to be reduced from .5 to .1.
               DR. KRESS:  I understand what you're doing now.
               MR. HAYES:  That's what we were doing.  Okay. 
     Now, the premise is at low rates of reactor coolant activity
     level, that the values would exceed Part 100 doses, that the
     spiking factor would be greater than at 5,000, and you would
     have to exceed Part 100 doses at those levels.
               If you go down to ten-to-the-minus-two, you can
     see that even at a release rate of 100 gallons per minute,
     the spiking factor is at least 500 or greater.  If you went
     down to ten GPM, you're at 5,000.  That's for a dose of --
     that's presuming that your dose was 30 rem.
               So to exceed Part 100, it would be ten times this
     value.  You'd have to have a spiking factor ten times this
     value.  It would be 5,000, 6,000, 51,000, that would have to
     be the number.
               DR. POWERS:  In order to do these calculations,
     you had to calculate what the steady-state release rates
               MR. HAYES:  That's correct.
               DR. POWERS:  Do you know what those numbers were?
               MR. HAYES:  I would have -- I could provide them
     to you.  I'd have to look at what they were.
               DR. POWERS:  I think I'd be interested in seeing
     an example calculation.
               DR. KRESS:  In order to do that, you would have
     had to assume something about that the size of the primary
     system and the capacity of the cleanup system, did you use
     some sort of generic numbers for those?
               MR. HAYES:  I did a specific plant example.  I
     took --
               DR. KRESS:  This was a specific plant.
               MR. HAYES:  Yes.  What I did, if you go back to
     the base case, I took a particular plant, a three-loop
     Westinghouse, took the numbers I had for that and then I
     adjusted it to these situations.  So it was an actual
               MR. BALLINGER:  What happens if you try 1,000
     gallons a minute?
               MR. HAYES:  I think the point -- first of all --
               MR. HOLAHAN:  Your division director goes
               MR. HAYES:  You have a LOCA, you don't have
     sufficient makeup.  You start to get above now.  I think
     some of the people from the staff can answer that, but I
     think if you get much above 100 GPM, you have a problem with
               MR. BALLINGER:  Well, previous tube rupture events
     have resulted in three, 400, 500 gallons a minute.
               MR. HOLAHAN:  Yes, but that's not what we're
     talking about here.  We're not talking about tube ruptures. 
     We're talking about acceptable post-accident leakage.
               MR. HAYES:  Because this is going directly to the
     environment.  You have no water level above your release
               I think this goes to your argument in considering
     safety and Gary said that, hey, if we start to go to 100
     GPM, he starts to get going off-scale.
               I think realistically, what do we have to be
     concerned about from an accident standpoint?  Isn't our weak
     link the steam generator?  So that when you start getting
     into these areas, you have a concern.
               Most of the people we're dealing with are in the
     ten to 35 GPM range.  That's where the numbers are at.  Now,
     we did have one case, yes, where Byron and I think
     Braidwood, or maybe just one of them, was in that ballpark
     for either a portion of a cycle or one cycle before they
     replaced their steam generators.
               MR. HIGGINS:  And those numbers in the second
     column are the ones you're going to talk to us later, about
     how those post-accident numbers are derived for the main
     steam line break.
               MR. STROSNIDER:  You're referring to the leakage
               MR. HIGGINS:  The second column there.
               MR. STROSNIDER:  Yes, and we'll explain how that's
     derived as part of the generic letter process.
               DR. BONACA:  The DPO makes the contention that the
     ultimate repair criteria results in a change to the design
     basis event that will cause to have a steam line break with
     leakage rate exceeding this number, right?
               MR. BALLINGER:  That was the point I was going to
     get at.
               DR. BONACA:  Right.
               DR. KRESS:  You said later on you were going to
     discuss that point.
               MR. STROSNIDER:  Right.  As part of our
     description of Generic Letter 95-05, we'll explain how those
     leakage rates are calculated, if you will, design basis
     leakage rate.
               MR. HAYES:  Again, reiterating, at .01, we're
     talking about a spiking factor of 5,000 to 51,000 in order
     to exceed Part 100 doses and for lower reactor coolant
     activity levels, you can see the number gets even larger.
               Again, this is the Adams data that we spent a lot
     of time looking at and discussing and the maximum value is a
     value of 10,0000.
               And, again, we presume that the releases
     associated with those two time periods were at the 30 rem
     limit, which they're not.  They're another factor at least
     three to ten lower.
               The conclusions from the table; obviously, for
     some combinations of leak rate and primary coolant activity
     levels, it would require a spiking factor of less than 500. 
     However, for ARC amendments, this would necessitate reducing
     the primary coolant activity levels and that's what they do.
               The spiking factor, because we use 500 in our
     calculations, the actual spiking factor would have to be at
     least 5,000 for Part 100 limits to be exceeded, and that's
     based upon the 500 times the 300 rem Part 100 limit divided
     by the 30, which is our use.
               And then for primary coolant activity levels of
     .01 or ten-to-the-minus-two microcurie per gram, the spiking
     factor would be 5,000 to 51,000.
               DR. POWERS:  Let me ask a question on this. 
     Suppose in my criterion, I did not take the Part 100 limits,
     but I took GDC-19.
               MR. HAYES:  Which is the third.
               DR. POWERS:  Control room habitability effect.
               MR. HAYES:  You want the -- the answer to your
     question is this.  It's what it already is right here,
     because that's what it's been based upon, 30 rem thyroid,
     same as GDC-19.  So at the ten-to-the-minus-two, we'd be at
     the 500.
               DR. POWERS:  But if I look at the Adams data or
     ten-to-the-minus-two, I can find numbers that exceed 500.
               MR. HAYES:  Yes, you can.  Yes, you can.  But you
     don't -- you see them exceeding -- this is at three times. 
     You don't see them -- let's see.  Well, these are the ones
     over 1,000 right here.  That's with the multiplier of three. 
     There's not a whole lot of points.
               And, again, look at where we're at for 1,000. 
     Even at .05, we're at ten GPM.  We're at 35 point for
               MR. HIGGINS:  So was the intent of this to justify
     the 500 spiking factor for main steam line break?  Is that
     the intent of this example?
               MR. HAYES:  No.  The intent of the example was to
     address the DPO and to say that, hey, at these particular
     low reactor coolant activity levels, the source of iodine
     that you have in coolant, both in terms of the initial
     coolant and then the release rate, is not significant enough
     to put you over Part 100 limits, and that even if you did,
     for example -- let's say our factor of 500 is wrong.
               I think you can see from the numbers here, at
     these various leak rates, you would have to have a
     significant spiking factor in order to exceed just the 30
               DR. POWERS:  I think we have a significant spiking
     factor.  Suppose that I go to the Adams data.  Suppose that
     I, say, factor of three that he multiplies things at, but
     suppose that I do buy the linear hypothesis presented
     earlier on the delta P.
               I don't even ask for the quadriture process.  I
     just use the linear.  Then I'm back onto this slide here.
               MR. HAYES:  Yes.
               DR. POWERS:  But I'm interested in complying with
     GDC-19, which has just as much effect on me as Part 100.  I
     have to take that into account just as much.
               DR. KRESS:  And I see no reason not to accept the
     factor of three.  So if you use that and the other factor of
     three --
               DR. POWERS:  Then you're in serious trouble.
               MR. HAYES:  I don't think you are in serious
     problem.  Look at this again.  This is at the GDC-19 value. 
     This is at 30. You have presumed that these releases are at
     the 30 rem, and they're not.  These releases are not at the
     30 rem.  If you take a base case and some of you that come
     from plants, you take the base case for these plants for
     main steam line break, the value is probably no more than
     one to two, three rem.
     For example, we just did an ARC amendment, we're doing an
     ARC amendment for Watts-Barr and it's a ten GPM leak.  This
     is instead of one.  And the doses, the maximum dose is two
     and that's at the LPZ.  Control room is one.
               Now, for a regular accident, the main steam line
     break isn't your limiting primary to secondary accident. 
     You're steam generator tube rupture is.
               So this number probably, if you actually went to
     one, it would probably be even lower.  But we have presumed
     that.  If you want to take -- okay.  We're going to say we
     have an uncertainty of ten.  So what, you say the spiking
     factor has to be 5,000 then.  Spiking factor of 5,000. 
               At ten-to-the-minus-two, you're still at ten GPM,
     and look what happens when you go here.
               DR. POWERS:  Look, I'm not interested in looking
     at it, because Gary has assured me I'll never go there.
               DR. KRESS:  I'm only interested up here at the .1,
     the point level.  And even at ten GPM --
               DR. POWERS:  I think you're in a world of hurt at
     ten GPM.  Now, if we factor in this additional thing that,
     in reality, the doses for this particular event at this
     particular plant at the control room is, as you say, three
     to five rem thyroid.
               MR. HAYES:  Probably the maximum, yes.
               DR. POWERS:  It's not obvious to me we're out of
     the woods either.  That doesn't get you quite there either.
               DR. KRESS:  That I presume is taking account for
               DR. POWERS:  I think the reality is that when they
     do this exact calculation for a particular plant as part of
     the FSAR --
               DR. KRESS:  The atmospheric transport.
               DR. POWERS:  Nobody comes back and says I'm at 30
     rem, they always come back and say I'm five or six and less,
               MR. HAYES:  Sometimes, in reality, with respect to
     the ARC amendments, the limiting is the control room and
     sometimes those values are high.
               One of the reasons why we stuck to releases versus
     calculating doses is because we threw out the atmospheric
     dispersion and threw out, if you will, the control room
     removal mechanisms.  We thought that was a less biased type
     of approach.
               DR. KRESS:  That's a good thing to do if it gets
     you out of the woods, because you're all right, but we're
     not so sure that gets you out of the woods yet, because
     we're not sure the spiking factor might not be 5,000, for
               MR. HAYES:  At this particular point in time, the
     staff has accepted the spiking factor of 500.  So, for
     example, if we were at this level, at
     five-times-ten-to-the-minus-two, and found at 35 we were not
     at the spiking factor, we would have to go somewhere between
     .05 and .01 and at 35 GPM, you'd be going from 283 to 1490. 
     So you're probably talking about .4, in that vicinity.  That
     would have to be our acceptance criteria and that would be
     for 30 rem.
               DR. POWERS:  I think it may be safe to say we
     understand what was done.
               MR. HAYES:  Okay.  Our conclusions with respect to
     the DPO concern, yes, we agree that spiking factors greater
     than 500 can occur, but they are low dose equivalent
     iodine-131 activity levels.
               We don't believe in any case that the spiking
     factor would be less -- would be greater than 5,000 and
     based upon the parametric analysis we did, we believe that
     if you were at an activity level of less than
     ten-to-the-minus-two microcurie per gram, that a spiking
     factor would have to be at least between 500 to 5,000 for
     the base case releases.
               If you look at the amount to exceed Part 100, it
     would have to be ten times that or 5,000 to 50,000.  At
     primary coolant activity rates of ten-to-the-minus-two, the
     primary coolant content is small and the equilibrium release
     rate is small.
               And as we mentioned, we don't believe the spiking
     factors are greater than 5,000.
               Are there any other questions?  That concludes our
               DR. POWERS:  Seeing no questions, I think I will
     declare a recess until five after the hour.
               DR. KRESS:  I have just one question.
               DR. POWERS:  I think I'm going to recess.  When he
     gets like this, I get very nervous.
               DR. KRESS:  If I want to know what the spiking
     factor is under a main steam line break accident, where I've
     got leaky steam generator tubes, I have no idea what it is,
     from what I heard.  I have no idea, because we do not have
     any data at all related to that subject.
               I don't know whether it's 500 or 5,000 or five. 
     That's not a question.  It's just a comment.
               DR. POWERS:  We'll take it at that and we can
     puzzle it over the recess.
               DR. POWERS:  Since you're not Joe Muscara, I
     assume you must be Ken Karwoski.  He doesn't look like Joe
     Muscara.  The floor is yours, sir.
               MR. KARWOSKI:  Thank you.  Good morning.  My name
     is Ken Karwoski.  Today, with the assistance of Joe Muscara,
     I'd like to discuss our three issues with respect to steam
     generator tube integrity.
               The order in the package is a little different, as
     Jack Strosnider indicated.  The first issue I would like to
     discuss is the regulatory framework and operating experience
     to date.  The second issue I would like to discuss is the
     technical basis for Generic Letter 95-05, the voltage-based
     repair criteria, including a discussion of the leak and
     burst correlations.
               And then the third issue I would like to discuss
     are the capabilities and limitations of NDE with respect to
     detection and sizing of flaws.
               The guidance with respect to steam generator tube
     integrity is located in various places.  The general design
     criteria, 10 CFR 50, Appendix A has general requirements
     with respect to the integrity of the reactor coolant
     pressure boundary.  Appendix B deals with quality assurance
     requirements.  Part 100, which you've heard about this
     morning from Jack Hayes, and dose limits.
               Regulatory Guide 1.121 contains guidance with
     respect to the loadings that the tubes should be able to
     withstand.  Regulatory Guide 1.83 discusses in-service
     inspection guidance.
               The standard review plan addresses various things,
     such as in-service inspection; also, the design of the steam
     generators and water chemistry, to some extent.  The ASME
     code has various repair criteria and the technical
               The plant technical specifications, as you heard
     this morning, were developed about 25 years ago, when the
     prevalent forms of degradation were general wall thinning. 
     The degradation that we're observing today was not
     anticipated or tech specs typically specify a depth-based
     tube repair criteria based on that general wall thinning
     type of phenomenon.
               The requirements for the inspection, repair, and
     for normal operating primary to secondary leakage are
     contained within the technical specifications.
               The typical technical specifications in plants
     today, plants that have not implemented an alternate repair
     criteria, are listed on this slide.  The first thing in the
     technical specifications is the sampling program.
               The basic sampling program involves a three
     percent initial sampling of the steam generator tubes.  That
     sample is expanded based on the categorization of C-1, C-2
     and C-3.
               Basically, what those categories are, it says if I
     have so many tubes or a certain percentage of tubes that are
     either degraded or defective, I need to inspect more tubes. 
     A C-3 classification can result in 100 percent inspection. 
     Most of the plants with extensive degradation would end up a
     C-3 classification.
               The sampling program in the technical
     specifications also require a reexamination of all
     previously degraded tubes.  With respect to the frequency of
     inspection, the technical specifications simply say that
     once every 12 to 24 calendar months, you should do an
     inspection.  That can be lengthened to 40 months based on
     the categorization of C-1, C-2 or C-3, and it can be
     shortened to 20 months.
               It also requires inspections after certain events,
     such as tube leaks in excess of the normal operating limit,
     seismic occurrence, LOCA, and the steam line break.
               With respect to the extent of the inspection, it
     basically says that you are required to inspect the hot leg
     of the tube around the U-bend to the top support plate on
     the cold leg side.
               The technique for inspection is not specified, and
     I already mentioned that the repair criteria is typically 40
     percent of the through-wall and it's applicable to all forms
     of degradation.
               So that's what you will find in most technical
     specifications today for plants that haven't implemented an
     alternate repair criteria.
               The 40 percent depth-based limit was based on
     guidance in Regulatory Guide 1.121.  There are several
     structural criteria that the tube is required to meet. 
     Typically, the most limiting is that the tube should be able
     to withstand a pressure differential of three times the
     normal operating pressure or 1.4 times an accident
     differential pressure, and, typically, the most limiting is
     the steam line break.
               In addition, Regulatory Guide 1.121 indicates that
     the normal operating primary to secondary leakage limit
     should be based on a limiting crack length, that length that
     would be limiting in terms of the structural criteria of
     three delta P or 1.4 times steam line break.
               Down here, basically what I have is a simple
     derivation of the 40 percent plugging criteria.  Basically,
     assuming a general wall thinning, you need 40 percent of the
     tube wall in order to withstand the three delta P or 1.4
     times steam line break, and if you include an allowance of
     ten percent for growth and ten percent for NDE uncertainty,
     you would arrive at 40 percent repair criteria.
               DR. POWERS:  Let me understand this.  The 40
     percent is the result of considering NDE error and
               MR. KARWOSKI:  Regulatory Guide 1.121 indicates
     that both NDE uncertainty and crack growth need to be
     accounted for in the plugging limit.
               DR. POWERS:  Right.
               MR. KARWOSKI:  Given that there is a -- the repair
     limit is 40 percent, there is roughly a 20 percent margin
     for both.  Whether or not it was explicitly called out, the
     ten percent, each one.
               DR. POWERS:  But the bottom line is you're saying
     with 20 percent of the wall, you can meet the three times
     normal operating or 1.4 times maximum allowable.
               MR. KARWOSKI:  With 40 percent of the wall.  With
     40 percent of the wall, you would be able to withstand
     roughly three times --
               DR. POWERS:  I guess what I'm asking is if I had a
     tube --
               MR. KARWOSKI:  It's 60 percent.
               DR. POWERS:  If I had a tube that I absolutely
     knew had 20 percent of the wall there, an NBS standard tube,
     if you will, had 20 percent of the wall left, would I be
     able to meet -- now, I think we've had tests that said you
     do with 20 percent.
               MR. KARWOSKI:  I don't believe so.  It's roughly
               MR. STROSNIDER:  I'd suggest it depends on the
     type of degradation.  For the analysis Ken's talking about,
     where the tube was assumed to be uniformly thinned, you
     would still meet ASME code, if you were uniformly thinned
     and the amount of material missing was 60 percent.
               So if you had 40 percent remaining, you'd still
     meet the code allowables.
               When you start looking at cracks and other types
     of defects, you may be able to withstand something deeper
     and still meet the code factors of safety.
               DR. POWERS:  Okay.  I think I understand.  Thank
               MR. STROSNIDER:  It depends on the length of the
               MR. KARWOSKI:  So what are some of the issues? 
     Over the last few days, you've probably identified a lot of
     issues with the current regulatory framework.  The major
     goal of the steam generator tube inspections is to ensure
     the structural and leakage integrity for the operating
     interval between inspections.
               Structural integrity per Reg Guide 1.121 and the
     ASME code, and leakage integrity per Part 100 and GDC-19, as
     was pointed out this morning.
               As you know, the technical specifications do not
     reflect either the current degradation modes or the
     inspection technology that we have today.  The repair
     criteria of 40 percent tends to be conservative for cracks.
               The inspection sample size, the expansion criteria
     and frequency do not explicitly take into consideration the
     severity of the degradation.
               It is based on that classification of C-1, C-2 and
     C-3, which more is a function of the number of tubes that
     either exceed the repair limit or are degraded.
               And as we know, the leakage limits don't prevent
     tube burst.
               As a result of these shortcomings, the NRC and the
     industry have been taking action over the last several
     years, for quite a long time.  I've listed here various
     efforts that have been underway.  Some of the industry
     efforts are that they have improved their examination
     guidelines.  I think the original version came out sometime
     in the early to mid 1980s.
               They have subsequently revised those several times
     based on lessons learned and based on the changing forms of
     degradation and the technology.
               The industry has a steam generator management
     program which actively participates with the NRC on various
     steam generator issues.
               In addition, the industry, as Jack Strosnider
     pointed out this morning, in NEI-97-06, they've adopted a
     condition monitoring and operational assessment philosophy. 
     I'll discuss those a little later, but basically what that
     involves is condition monitoring.  It is a backwards look to
     make sure that you operated safely during a cycle. 
     Operational assessment is a forward look to make sure that
     you can safely operate during the period of time before your
     next inspection.
               With respect to some of the NRC efforts, the NRC
     has issued, over the last ten years, several generic
     letters, Generic Letter 9503 on circumferential cracking of
     steam generator tubes, Generic Letter 9705 on steam
     generator tube inspection techniques, and Generic Letter
     9706 on the degradation of steam generator internals.
               We've also issued numerous information notices on
     various topics, including sleeves, plugs, U-bend degradation
     and other inspection related issues.
               In addition, the NRC has an extensive research
     program with respect to steam generator inspection and
     repair criteria.
               As I previously mentioned, NEI has their
     guidelines, NEI-97-06.  The staff has also developed draft
     regulatory guide DG-1074, both of which address tube
     integrity.  Those are now being rolled up into an industry
     initiative to address some of the issues with respect to
     steam generators.
               With respect to what we've observed to date, this
     picture just shows some of the -- shows a lot of the
     degradation mechanisms affecting steam generator tubes.
               Just to go over some of the more prevalent ones,
     in the tube sheet region, which is depicted in these
     pictures, you have a variety of degradation mechanisms,
     including the buildup of sludge on top of the tube sheet. 
     You have axial outside diameter stress corrosion cracking,
     pitting and wastage can occur in the sludge pile.
               At the expansion transition, the region of the
     tube where it goes from expanded to unexpanded, you have
     both circumferential and axial primary water stress
     corrosion cracking and outside diameter stress corrosion
               At the tube support plate elevations, you can have
     fretting, wear and corrosion thinning, the dominant
     degradation mechanism back in the '70s.  You can have axial
     oriented outside diameter stress corrosion cracking and
     intergranular attack.
               At dented intersections, we've observed axial
     primary water stress corrosion cracking.  We have also
     observed circumferential outside diameter stress corrosion
     cracking and primary water stress corrosion cracking.
               We've also observed fatigue at the upper most tube
     support plates and also in the wedge reason of B&W plants,
     although that picture won't show that.  They have
     once-through steam generators rather than U-tube steam
               We've also observed free span cracking, free span
     outside diameter stress corrosion cracking, and we've also
     observed cracks in the U-bend.
               DR. POWERS:  In the U-bends, do you have -- I
     don't know how to describe it well -- a bend is made and
     it's too much and so they bend it back, so you get kind of
     reverse bends on things.
               MR. KARWOSKI:  Sometimes that occurs, but --
               DR. POWERS:  And is that a site of --
               MR. KARWOSKI:  That has been a site of corrosion. 
     So what are some of the factors affecting tube degradation? 
     I think Dr. Hopenfeld yesterday touched on many of these. 
     Tube material, including the heat treatment.  The
     degradation mechanisms that I just had up there are
     primarily observed in alloy-600 mill annealed steam
     generator tubing.  That's basically most of your older
     plants, with their original steam generators.     
               There has been relatively little degradation in
     alloy-600 thermally treated steam generators, which are the
     later vintage of steam generators and some of the initial
     replacement steam generators.
               The tube material of choice these days for the
     replacement steam generators are alloy-690 thermally
               DR. POWERS:  Now, I understand that in Europe,
     they use something else, 800 alloy maybe.
               MR. KARWOSKI:  In Germany, they have used
               DR. POWERS:  And is there anything substantially
     superior or inferior to 800 relative to 690 and 600?
               MR. KARWOSKI:  I don't think I can --
               MR. BALLINGER:  The 800 works a little bit better
     if you're in phosphate chemistry and the like.  It doesn't
     waste, doesn't get wastage like 600 did, does.  So
     replacement steam generators in Europe are all going to be
     pretty much 690.  I don't think there's any 800 that's going
     to be used for replacement generators.
               MR. KARWOSKI:  Other factors affecting tube
     degradation, grain size, carbide distribution, the
     fabrication of the tubes and stresses.  For example, the
     expansion joints at the -- where the tube goes from the
     expanded to unexpanded region, there's been various means
     for expanding those.
               Initially, utilities would role expand those. 
     They tried to lessen the stresses at the transition.  They
     then went to an explosive transition and currently most
     people now do a full depth hydraulic expansion.
               DR. POWERS:  Let me ask a question about carbide
     distribution.  I see in the many documents we've been
     provided three types of carbide distribution, called,
     imaginatively, one, two and three.
               I think I understand one.  I don't understand the
     distinctions between two and three.
               MR. KARWOSKI:  I'm not sure of the reports you're
     referring to.  Other people may be more qualified to address
     that later, too.
               DR. POWERS:  Okay.
               MR. KARWOSKI:  Tube support plate design and
     material effects, tube degradation, operating temperature
     and stresses, the water chemistry, operating time and the
     presence or absence or crevices.
               There have been a number of tube ruptures.  I've
     listed ten tube ruptures here.  Some people call an event or
     a leak at Fort Calhoun a rupture, I did not include that.
               The definition of rupture I used here is leakage
     in excess of the normal makeup capacity of the plant.
               Just going over each one of these ruptures, as you
     can see, there's ten listed.  Of these ten, eight have
     occurred in the U.S., two in foreign PWRs.
               The first rupture occurred in 1975 at Point Beach. 
     The rupture was primarily attributed to wastage.  The tube
     wasn't pulled for destructive examination, but they think
     stress corrosion cracking may have also played a role.
               The next steam generator occurred at Surry-2 in
     1976.  That was axial primary water stress corrosion
     cracking up in the U-bend of the steam generator.
               The Surry rupture was attributed primarily to
     denting at the uppermost -- at the tube support plates
     forcing the tight radius U-bend tubes closer together and
     parting a stress up in the apex of the U-bend.
               The Doel rupture occurred in 1979.  It was also
     axial primary water stress corrosion cracking in the U-bend.
     However, in that case, they attributed the rupture to the
     bending process and the fact that there was ovalization of
     the tube that wasn't in accordance with specifications.
               In 1979, there was a rupture at Prairie Island due
     to a foreign object.  In Ginna, in '82, another foreign
     object.  There was some discussion on the magnitude of the
     leak rates from a rupture.  This rupture was on the order of
     760 gallons per minute.
               In 1987, there was a rupture at North Anna which
     was attributed to fatigue at the upper most tube support
     plate.  Some of the factors affecting that was denting and
     improper or inadequate ABB support up in the U-bend region.
               In McGuire, in '89, there was a free span rupture
     was a result of axial outside diameter stress corrosion
     cracking.  That was on the cold leg side.  The crack was
     associated with a manufacturing scratch.
               In 1991, there was a rupture at Mihama, which was
     very similar to the event at North Anna-1.
               In 1993, at Palo Verde-2, there was a rupture as a
     result of free-span cracking.  This was on the hot leg side. 
     The utility attributed that, in part, to a dryout region,
     which they refer to as an arc, which is present in the outer
     periphery of the bundle up in the top.  Then Indian Point-2
     in February of this year, which was a result of primary
     water stress corrosion cracking in the U-bend.
               In addition to ruptures, there have been a number
     of leaks that have resulted in forced outages.  Basically,
     what I show here is the number of forced outages as a
     function of year.
               As you can see, back in the '70s and early '80s,
     there is a number of forced outages for a variety of
     reasons.  Here in the '90s, there have been -- if you look
     at this literally, you could say that there has been a
     decreasing trend in the number of forced outages as a result
     of leakage.
               Some of the shutdowns that are on that graph were
     initiated because the plant exceeded the primary to
     secondary leakage limit in the technical specification.  In
     the standard technical specification, that limit is
     typically around 500 gallons per day through any one steam
               Some of these plants shut down voluntarily before
     the leakage exceeded those limits.  In addition, I wanted to
     point out that some plants have operated with leakage over
     the course of a cycle and then shut down at the standard
     refueling outage.
               Some of the causes of shutdowns as a result of
     leakage in the 1990s include sleeves, primarily the B&W
     kinetically expanded sleeves.  That was the result -- that
     was the cause of the Trojan leak back in the '92 timeframe.
               MR. HIGGINS:  The typical tech spec limit that you
     mentioned of 500 gallons per day, the new NEI document that
     Jack had mentioned that the plants had all committed to has
     got a number of 150 GPD.  Does that mean that the plants are
     now all observing that versus the 500?
               MR. STROSNIDER:  The plants have implemented
     administrative limits reflecting the 97-06 guidelines.
               MR. HIGGINS:  Thank you.
               MR. KARWOSKI:  So that the B&W kinetically
     expanded sleeves resulted in a number of leakers back in the
     early '90s.  The last steam generator that has these sleeves
     installed is being replaced now at ANO-2.
               There's been leaker outages in the '90s as a
     result of plug leakage, loose parts, fatigue primarily in
     the B&W once-through steam generators, in the lane wedge
     region or in the area bordering the lane wedge region, and
     leakage has been observed as a result or forced shutdowns
     have resulted as a result of leakage due to stress corrosion
     cracking at expansion transition, tube supports and free
               A number of plants have replaced their steam
     generators.  I believe there's 25 plants that either have
     replaced or are replacing.  Replacements started in the
     1980s.  Cook finished in July of 2000.  ANO-2 and Indian
     Point-2 are currently replacing right now.
               With respect to the tube materials, I'll just
     point out that these early replacements were all alloy-600
     thermally treated.  When you got to Cook-2, most of the ones
     after this are alloy-690 thermally treated, with some
               Palisades used steam generators available at
     another plant, so I believe these are 600 mill annealed. 
     Salem also used previously available steam generators at a
     cancelled plant, so these are 600 thermally treated.  And
     the Indian Point-2 steam generators, I believe, are 600
     thermally treated.  The rest are 690.
               A number of plants also have indicated that they
     plan on replacing steam generators.  Some of these
     replacements are a result of tube degradation or as a -- or
     in combination with license renewal, they believe that they
     will need new steam generators in order to operate 60 years.
               To date, only steam generators from Westinghouse
     and CE have been replaced.  Some of the replacements in the
     next ten years will probably be in B&W units, as well.
               As a result of all the tube degradation, a number
     of utilities have proposed various alternate repair
     criteria.  One of the first alternate repair criterias was
     for degradation within the tube sheet region.
               When you have a tube fully expanded against the
     tube sheet, you only need a certain length of engagement in
     order to ensure that the tube does not pull out during
     accidents.  The remainder of the tube can be degraded
     without any significant effect on the structural or leakage
     integrity, and that's what these repair criteria are
     basically for, degradation in the tube sheet area.
               Of more interest are the alternate tube repair
     criteria that has been implemented at the tube support plate
     elevation with respect to predominantly axially oriented
     outside diameter stress corrosion cracking.
               I've listed the plants that currently have this
     implemented.  There have been other plants, but they have
     either subsequently replaced their steam generators or
     ceased operation.
     Beaver Valley, Comanche Peak, Diablo, Farley, Kuwanee,
     Prairie Island, Sequoyah and South Texas currently have
     repair criteria and, I believe, as Jack Hayes indicated,
     there's others that are being reviewed now.
               There's also been an alternate tube repair
     criteria for axially oriented primary water stress corrosion
     cracking at or near dented tube support plates.  That's been
     approved on an interim basis at Sequoyah.
               That concludes the first part of the presentation
     with respect to the regulatory framework and operating
     experience.  I'd be happy to answer any questions on that.
               The next part of the presentation deals with
     Generic Letter 95-05.  This will tend to be lengthy.  I'm
     not sure if you -- do you want to start this at this point?
               DR. POWERS:  Why don't we go ahead and start it.
               MR. KARWOSKI:  Okay.
               DR. POWERS:  And I presume that there will be some
     point in there that it's logical to take a break.  Or is it
               MR. KARWOSKI:  I think this one might be
               DR. POWERS:  Okay.  I run into problems starting
     early and starting late is okay, starting early is a
     problem.  So I think what we will do is just interrupt you
     at 12:00.
               MR. KARWOSKI:  Okay.  Generic Letter 95-05
     addresses one form of degradation, axially -- predominantly
     axially oriented outside diameter stress corrosion cracking
     at the tube support plate elevations.
               There's two fundamental goals of the repair
     criteria in this generic letter, to ensure adequate
     structural and leakage integrity.
               The evaluation of structural and leakage integrity
     require periodic inspections.  It requires correlating those
     inspection parameters with the tube structural and leakage
     integrity and evaluation of the tubes accepted for continued
               And I apologize, this is where I've jumped ahead
     in the presentation.  It's page 10-27.  And I also
     apologize, as a result of some of the presentations
     yesterday, there are some additional slides that I have
     prepared to address some specific comments.
               DR. POWERS:  Thank you.
               MR. STROSNIDER:  Ken, I think we might also
     mention, I think we provided -- there was discussion
     yesterday of some of the proprietary data and I think we
     provided copies of that information for the panel, or we
               MR. KARWOSKI:  Yes.  This is the proprietary
     information containing the data in the database.
               MR. STROSNIDER:  And I would just point that
     because of it's proprietary nature, we won't be presenting
     it on the screen, but the members of the panel will have it
     so they can look at it, and, of course, need to treat it as
               MR. KARWOSKI:  Okay.  So just so that everybody
     understands what degradation mechanism we're talking about,
     Generic Letter 95-05 primarily addresses axially oriented
     outside diameter stress corrosion cracking at the tube
     support plate elevations.
               It does not permit -- or it does not apply to
     circumferential cracks, primary water stress corrosion
     cracks or cracks that go outside the tube support plate, and
     it does not apply to general wastage or thinning.
               As I mentioned, in order to ensure the structural
     and leakage integrity of the tubes, you need to do
     inspections.  The generic letter specifies specific
     inspections that must be performed.  Take this into context
     of the current regulatory framework, which says three
     percent initial inspection and expand based on the results.
               GL-95-05 requires the licensees to perform 100
     percent bobbin coil inspection; basically, all the way
     around to the cold leg, to the point where they've observed
     degradation, and a 20 percent sample at the next tube
     support plate elevation.
               I say that because that's what is in the generic
     letter, practically speaking, everyone does 100 percent tube
     end to tube end.
               The bobbin coil allows for a rapid screening of
     the tubes for defects.  The extent of the degradation is
     measured in terms of the voltage response for the defects at
     the tube support plates. 
               There are detailed procedures to ensure that the
     voltage response of the degradations being measured in the
     field is comparable to those in the structural and leakage
     integrity databases.
               So basically it tells the analyst what size probe
     to use, what frequency mix to use to size the degradation. 
     It instructs them to record the maximum voltage response at
     that location, as the voltage.
               So there are detailed procedures with respect to
     the data analysis.
               MR. HIGGINS:  Can you say what that database is?
               MR. KARWOSKI:  I'll get into the database in a few
     slides.  In addition to the bobbin coil examinations,
     rotating pancake coil examinations are performed.  This
     permits a better characterization of the defects to ensure
     that degradation is confined within the tube support plate
     and is predominantly axial.
               Make sure that you're not applying this to
     circumferential degradation or other forms of degradation;
     that you can get some idea of the morphology as a result of
     the rotating pancake coil.
               DR. POWERS:  You tend to speak of cracks as axial
     or circumferential.  Is there a case where things are at an
               MR. KARWOSKI:  Absolutely.
               DR. POWERS:  And how do you make a distinction
     between axial and circumferential when you're at an angle?
               MR. KARWOSKI:  There is some analyst judgment
     involved.  With respect to that specific issue, if you look
     at the database, clearly, from the metalography, you can
     tell -- you will see that the degradation at the support
     plates occurs in networks or is a cellular type of
               So there are oblique angles.  There may be short
     segments that are circumferential in extent.  With respect
     to the eddy current data evaluation, though, those
     typically, what you will see is you will see a pattern.
               Usually those short circumferential extents will
     not be discerned in the NDE examination.
     MR. SIEBER:  So the NDE doesn't tell us about
     circumferential cracks.
               MR. KARWOSKI:  It cannot readily detect the short
     segments.  It will find, and that will be this afternoon, it
     will find distinct circumferential cracks or large
     circumferential components.  It can do that, and I will
     present some data to show that.
               MR. STROSNIDER:  Ken, and you may get to this
     later, it might also be a time to interject that there is a
     tube pull requirement associated with it.  Are you going to
     talk about that?
               MR. KARWOSKI:  Yes.
               MR. STROSNIDER:  Okay.  But I would just interject
     that plants are required to periodically pull tubes to
     verify that the degradation mechanism is consistent with
     what's in the database and what they've seen in the past,
     but Ken will talk about that.
               MR. KARWOSKI:  These rotating pancake coil
     examinations are performed at intersections with degradation
     exceeding specific voltage limits and I will discuss the
     limits, but basically it's one volt for three-quarter inch
     tubing and two volts for seven-eighths inch tubing.  There
     are two correlations, depending on the size of the tubing.
               The plants -- the Westinghouse plants that this
     affects are either three-quarter or seven-eighths inch
               DR. CATTON:  And you find these with the bobbin
               MR. KARWOSKI:  You find these indications with the
     bobbin coil.
               DR. CATTON:  Then you do a detailed evaluation
     with the rotating pancake coil.
               MR. KARWOSKI:  That's correct, and I will discuss
     a little more on what you do with the rotating pancake coil
     examination results.     
               You also perform these rotating pancake coil
     examinations at tube support plate elevations, where the
     dents exceed five volts.  Part of the reason for doing that
     is because in highly dented intersections, the bobbin coil
     is relatively ineffective.  The rotating pancake coil gives
     you a better inspection.
               You also perform these examinations at tube
     support plate elevations with copper deposits.  The reason
     for that is because the pancake coil will give you a better
     inspection.  And also at locations with large mixed
     residuals, for the same reason.
               DR. POWERS:  Maybe you should explain what you
     mean by mixed residuals.
               MR. KARWOSKI:  What mixed residuals are are when
     you do these inspections at the tube support plate,
     depending on the frequency, you will get a response not only
     from the tube, but also from the support plate.
               So what you do, you're using a multiple frequency
     probe, you will -- you take one frequency that is more
     sensitive to the tube and another frequency that is more
     sensitive to further out or the tube support plate and you
     essentially mix out the signals.  That's not a 100 percent
     perfect.  There are some what's called residuals and so if
     you have large mixed residuals, you will inspect those with
     the rotating pancake coil to give you a better examination.
               MR. STROSNIDER:  Ken, I guess that large mixed
     residual, it basically looks like distortion of the eddy
     current signal.
               MR. KARWOSKI:  Yes.
               MR. STROSNIDER:  When the analyst looks at it,
     it's an amount of distortion that's in the signal, because
     the mixing isn't perfect.
               MR. KARWOSKI:  So I've discussed the inspections
     and I've tried to give you an idea that there are detailed
     procedures in order to interpret the voltage and to
     characterize the defects, but that's only one part of the
               You also have to have correlations correlating
     that inspection parameter to the structural and leakage
     integrity of the tubing.
               The correlations come from two primary sources,
     tubes removed from operating steam generators and specimens
     produced in model boiler facilities.  The specimens produced
     in model boiler facilities span a larger range than the data
     from tubes removed from operating steam generators, because,
     in general, the voltages observed in the field typically
     aren't as great as you can produce in a model boiler.
               And as Jack Strosnider pointed out, there is a
     periodic tube pull program for confirming the degradation
     mode at the plant.  There's an initial tube pull that
     involves a couple tubes and, I believe, four intersections.
               After that initial tube pull, there is a periodic
     tube pull requirement, which involves pulling additional
     intersections at a frequency of about every two or three
               The examinations performed on these tubes, I'll
     start down here.  You perform a metallurgical examination to
     make sure that the degradation mechanism is consistent with
     that observed at other plants and for -- and is consistent
     with the other data in the database.
               You also do leak testing, what's involved here is
     the tube is pressurized internally and on the outside.  It
     is taken up to steam line break pressure at temperature of
     around 600, 650 degrees Fahrenheit.
               The first thing that they do is determine whether
     or not it leaks or not.  If the tube leaks, then they go on
     to measure the leakage.  If the tube doesn't leak, then they
     just use the data in the probability of leakage correlation,
     which I will be discussing later.
               DR. POWERS:  In all cases, the testing is done at
               MR. KARWOSKI:  I don't know if I can say all
     cases, because I don't recall from that --
               DR. POWERS:  We'll accept 90 percent.
               MR. KARWOSKI:  The vast majority, and I would also
     like to point out, but I need to point out, it may not be
     the exact temperature and there may need to be some
     adjustments to the data.  It may be taken at 2,603 PSI
     instead of 2,650 and maybe taken at 580 degrees F instead of
     620.  So there are adjustments that need to be made to the
               The burst testing is performed at room
     temperature.  Typically, after the leak testing, they will
     take that specimen, they will insert a bladder.  The reason
     for the bladder is to prevent excessive leakage from
     preventing them to achieving burst.
     They will burst test the tube at room temperature and they
     use that burst pressure in the correlations.  When I get to
     the slides on the burst pressure correlation, all the data
     is normalized to a specific burst pressure and they use
     lower tolerance.  Then they scale it up to operating
     temperature and take a lower bound, and I'll point that out
     on the correlations.
               So that's the testing that is performed.  Earlier,
     I discussed the regulatory criteria.  Typically, the most
     limiting is that the tubes must withstand a pressure
     differential of three times the normal operating or 1.4
     times the maximum postulated accident or steam line break.
               This roughly turns out to be around 3,660 PSI. 
     For degradation at the support plate, during normal
     operation, the plate is present.  I should point to this one
     because this is the degradation mode.  That plate is
               As a result, the criteria for three times the
     normal operating pressure is met during normal operation. 
     The degradation is confined to within the tube support plate
               Given the clearances between the tube and the tube
     support plate, that tube will not burst.  So the three delta
               DR. POWERS:  I guess the question comes up, when
     you say it's combined within the support plate, what exactly
     does confined mean?
               MR. KARWOSKI:  The degradation, in general, does
     not exceed -- does not extend above or below the tube
     support plate.
               DR. POWERS:  At all.
               MR. KARWOSKI:  There have been pulled tube data
     where there has been some minor extension of the outside
     diameter stress corrosion cracking beyond the plate.  To my
     knowledge, that has only been discovered as a result of
     destructive examination in the cases I'm familiar with and
     it's only on the order of .02, .03 inches beyond the plate,
     and it's typically attributed to some slight deposits which
     basically come up along the side of the tube.
               DR. KRESS:  If that is found by the NDE techniques
     to extend beyond, then that's excluded from this being
               MR. KARWOSKI:  There is a reporting requirement in
     the tech specs that if they find that degradation, they have
     to let us know because it will draw on the question, the
     validity of all the arguments.
               If you look at our understanding of this
     phenomenon, it's basically crevice corrosion in this
     location, all the pulled tube data has suggested that
     degradation is confined within that support plate region. 
     If they find it by NDE, there is a reporting requirement to
     address that.
               DR. KRESS:  Then it's treated like a crack that's
     outside the confined area.
               MR. KARWOSKI:  Yes.  We would have to question
     whether or not they should even implement the repair
     criteria not only at that location, but at other locations
     in the plant.  That's the purpose of the reporting
               DR. BONACA:  But can you detect it if you have
     just a fraction of an inch?
               MR. KARWOSKI:  That pulled tube data that I was
     referring to where there was a minor extension, that was not
     detected in the field.  A .02, .03 inches will not be
     detected in the field.
               On the other hand, it probably will not have a
     significant effect on the burst pressure of that tube.
               MR. BALLINGER:  A question.  Circ cracks are
     plugged on detection, right?
               MR. KARWOSKI:  Yes.
               MR. BALLINGER:  Getting back to this degree of
     circumferentiality issue, when you have a network of cracks
     in the TSP, in the support plate region, is there some kind
     of judgment that has to be applied to -- since you can't see
     that with a bobbin coil and the rotating pancake doesn't
     work too well either for that kind of situation, what
     happens if there is a likelihood that you've gotten an
     equivalent circumferential crack there?
               How do you deal with that?    
               MR. KARWOSKI:  That will show up in the burst
     pressure database.  The correlations are all empirical.  So
     you've pulled a variety of tubes with given voltages.  You
     also have a number of tubes produced in model boiler
               Those tubes are somewhat representative of what's
     out in the field or they are representative of what's out in
     the field.  During those tests, if you were to have a,
     quote-unquote, limiting circumferential crack, you would
     have observed a circumferential failure.
               That's not what we've been observing today. 
     That's part of the reasons for the periodic tube pull
     examinations to confirm that that is not occurring.
               MR. BALLINGER:  So that would be picked up in the
     tube pull.
               MR. KARWOSKI:  Tube pull and if you do a -- when
     you do your rotating pancake coil examinations, which are
     basically of most indications above one or two volts, if you
     had a large circumferential extent, you would notice.
               DR. CATTON:  When you do a tube pull, do you
     literally snake that entire tube out of there?
               MR. KARWOSKI:  Basically, what's done is they will
     cut the tube at a specific location.
               DR. CATTON:  And pull.
               MR. KARWOSKI:  And pull it through the tube sheet.
               DR. CATTON:  What do they do with the rest of the
     tube, it just stays there?
               MR. KARWOSKI:  It just stays there.  They
     frequently stabilize it, depending on what they believe the
     tube will whip around, if they believe there's going to be
     some damage, but they'll stabilize that tube.
               MR. STROSNIDER:  Ken, we might mention, too, I
     think there was a little discussion yesterday.  During the
     tube pulling process, and it's not always easy to pull these
     tubes out.  There can be some --
               DR. POWERS:  Is it ever easy to pull these tubes
               MR. STROSNIDER:  There's a possibility of some
     change in terms of the defect that you're trying to get at
     and, again, I don't want to get ahead of you, Ken, but I
     think when you look at what's plotted in the database, it's
     the in situ voltage versus what was tested after you pulled
     it.  And during the pulling it, it's possible that ligaments
     might tear or whatever, but in general, the pulling is not
     going to make the burst pressures or leakage characteristics
     better.  It's going to make it worse.
               So there is some conservatism in that.
               MR. KARWOSKI:  Right.  And if you did have a large
     circumferential network which was limiting, when you're
     pulling that tube, there's some extreme forces, it would
               And that has occurred for some circumferential
     cracking at the top of the tube sheet where the licensees
     have attempted to get those specimens out.  They go to the
     tube pull, they pull it and basically it rips.  But that has
     not been observed at the support plate elevations for which
     this generic letter is applied.
               As I discussed, there are two correlations.  This
     doesn't have any data, it's old, so it won't match the data
     that I've presented or that I've provided to you, the
     proprietary information, but it will help me illustrate the
               This correlation is for seven-eighths inch
     diameter tubing.  We have the burst pressure over here and
     we have the bobbin voltage on a log scale over here.
               If you look in your package, you will see the data
     point scattered throughout.  You will see a mean regression
     curve, a lower 95 -- a mean regression curve where the data
     has been normalized to specific material properties, a lower
     95 percent prediction interval.
               DR. POWERS:  It's the 95 percent confidence level
     for a prediction drawn from the correlation?
               MR. KARWOSKI:  This is the 95 percent prediction
     interval associated with this mean regression curve.
               DR. POWERS:  What I find remarkable about that
     curve is that as you move away from the mean of the data,
     those curves typically expand out a lot.  In principal, they
     go to infinity at -- well, they go to zero and on the other
     side they go to infinity, if you get far enough away from
     the mean of the data, and this curve does not seem to do
               MR. KARWOSKI:  You asked me that question a number
     of years ago and I did research after.  If you were to blow
     this up and expand the scales, you would see the exact
     effect that you're talking about.
               You just don't notice it on the scales here, but
     you are absolutely correct.  When you blow that up, you see
     that -- see the curves with that trend, the blow-up way down
               DR. POWERS:  I'm confident that -- I mean, I'm
     encouraged that my intuition is good.  I'm surprised I don't
     see it, because it did look awfully scattered.
               MR. KARWOSKI:  Yes.  But you do observe it when
     you blow this up.
               As I mentioned, this is the mean curve adjusted to
     a specific set of material properties.  The lower 95 percent
     prediction interval.  Because material properties in the
     steam generator tubes vary, they adjust that for the lower
     95 percent material properties and they get this dotted
     curve down here.
               In order to determine the repair limit, basically,
     you take the intersection of this curve with your limiting
     regulatory guide pressure, which is around the 3660 PSI, you
     come down, you get a limit of 8.8 volts.
               That is then consistent with Regulatory Guide
     1.121.  You take off allowances for growth and NDE
     uncertainty, and I'll discuss this in a little bit, and you
     get a repair limit at which tubes would need to be plugged,
     and I will discuss that because this is not what we've
     accepted as a result of some of the assumptions made in the
     growth and NDE uncertainty.
               This next viewgraph here, I'll just discuss it
     from this.  The industry's original proposal said basically
     we would like to implement a five and a half volts. 
     Anything above five and a half volts we'll leave in service. 
     I'm sorry.  Anything less than five and a half volts we'll
     leave in service, anything greater than, we would plug.
               The values have changed and it's evolved over
     time, but basically the staff was concerned with this
     approach given that back in the '95 timeframe, most of the
     data out here was from model boiler specimens.  The pulled
     tube data was relatively scarce and it was all centered in
     the lower voltage regions.
               Because of that, because you can have higher than
     average growth rates which are used in the calculations and
     your NDE uncertainties aren't limited and a variety of other
     reasons, the staff chose to use lower voltage limits.
               In the case of seven-eighths inch diameter tubing,
     we chose two volts, and, for three-quarter inch tubing, one
     volt because of differences in the correlation.
               MR. SIEBER:  Just a quick question.  The 1.4 times
     the steam line break differential, the other requirement is
     three times the normal operating differential, which I
     presume, for Westinghouse steam generators, is either 1550
     or 1600, depending on the model.
               So that would come out to be 4800 on that chart.
               MR. KARWOSKI:  That's right.  But if you remember
     from this plot here, during normal operation, this plate
     will be in place.
               MR. SIEBER:  Okay.  
               MR. KARWOSKI:  That plate is in place.  That three
     delta P, that tube is not going to --
               MR. SIEBER:  So you don't consider it.
               MR. KARWOSKI:  Right.
               MR. SIEBER:  You don't consider that, okay.
               MR. KARWOSKI:  We don't consider it.  So how are
     these repair limits implemented?  This is not in your
     handout, I don't believe.  This is a subsequent -- I didn't
     plan on getting into all of this.
               Below the lower bobbin voltage repair limit, and
     what I mean by that is if you go in and inspect and find
     something less than one or two volts, you can allow those
     tubes to remain in service.
               Those are tubes that can be left in service.
               DR. POWERS:  Yesterday we had several mentions of
     three volts.
               MR. KARWOSKI:  I will get into that at the very
     end, but I want to point out that that three volt criteria,
     although it is a modification of this approach, it is not
     the same.  It is not the same as what's in Generic Letter
               There are similarities and some of the data is the
     same, but there are differences.
               MR. HIGGINS:  On the last slide, you said that you
     had implemented a lower repair limit as opposed to the five
     and a half.
               MR. KARWOSKI:  Right.
               MR. HIGGINS:  And you're saying now that it's one
     or two.
               MR. KARWOSKI:  It's one volt for three-quarter
     inch diameter tubing and two volts for seven-eighths inch
     diameter tubing.
               Between the lower voltage repair limit, this one
     and two volts, and the upper bobbin voltage repair limit,
     which would be the equivalent of the 8.8 volts that I showed
     you -- I'm sorry -- the 5.5 volts, you need to do RPC
     inspections for all those indications.  That confirms your
     degradation morphology and will give you added confidence
     that the degradation is within the support plate.
               Any indications that are not confirmed by RPC can
     remain in-service.  What I mean by not confirmed is the
     bottom coil has a certain detection threshold.  The RPC has
     a certain detection threshold.  The bobbin tends to be more
     influenced by noise and other masking features.  You might
     call something that is not a flaw a flaw, or the RPC's
     threshold of detection is different.
               If you don't confirm it by RPC, then you can leave
     that tube in service, and the reason is that the RPC is
     typically less sensitive to interfering signals.  So things
     that you might have caught with the bobbin may not actually
     be flaws.
               However, they may be flaws, but RPC is less
     sensitive to shallow crack networks, but it's at least
     equally sensitive to deep cracks.
               So what that means is even though that the RPC
     isn't seeing it, it's probably not significant.
               DR. POWERS:  Now, that presumes that shallow crack
     networks are not going to coalesce and make a deep crack.
               MR. KARWOSKI:  That will be handled in the growth
     rate analysis that I'll get into in a minute, but yes and
     no.  I will point out that even though these tubes are
     allowed to remain in service, the industry, I believe,
     originally argued that they should not include them in the
     probabilistic calculations that I'll be discussing.
               The staff said yes, you need to include those,
     even though you don't believe there is degradation there.
               DR. POWERS:  Okay.
               MR. KARWOSKI:  You need to address them.
               DR. POWERS:  You're setting the stage for that
     part of your talk that will take place after the lunch
               MR. KARWOSKI:  Actually, this might be a very good
     ending point.  Above the upper bobbin voltage repair limit,
     the indication must be repaired regardless of RPC results. 
     Licensees are required to RPC even those tubes that they are 
     going to need a plug, for the obvious reason.  Those are the
     ones that will start probably showing circumferential
     extent, extending outside the support plate.
               We wanted to make sure that there is nothing going
     on there that we need to be aware of before the repair
     criteria is implemented.
               DR. CATTON:  And repair means plug.
               MR. KARWOSKI:  Plug or sleeve.  If the plant is
     licensed to sleeve.
               DR. POWERS:  And the extent of Ken's talk here is
     a prologue for all this in-depth analysis he's going to do
     for us.  Are there any questions you want to pose to him
               MR. STROSNIDER:  If I could interrupt for just a
     second, Ken.  I don't know if this is the best time or not,
     I'm going to put him on the spot here.  With regard to the
     correlation in the database for burst pressure, I just
     wanted to point out that, I think you've got it in front of
     you, there's a substantial number of data points and part of
     the discussion about whether there -- first of all, it is an
     empirical model.  So some of the things you need to look at
     are what sort of correlation coefficients, how much data,
     can you do reasonable statistics with this.
               And I would suggest, if you look at the amount of
     data and the care that's been taken to make sure that it's
     the right population to compare to the steam generators,
     there is a good basis for doing this sort of empirical
               And you'll see more when we get into the leakage
     and other correlations.
               MR. KARWOSKI:  In the proprietary handout I gave
     you, you have all the data or you have all the correlations
     and some of the correlation coefficients that Jack was
     talking about, but basically here is a summary for the burst
     correlation, since we were discussing it, for three-quarter
     inch tubes and seven-eighths inch tubes.
               Basically, there's 96 and 91 data points,
     correlation coefficient --
               DR. POWERS:  If I were to ask you a question, what
     is the probability that a random data set would produce such
     a high R-square given that there are 96 points, what would
     you answer?
               MR. KARWOSKI:  I would probably refer to the
               DR. POWERS:  R-squared values are virtually
     useless.  The important point to understand is what's the
     probability the random data set would produce such a high
     value of R-squared.
               MR. KARWOSKI:  Just since we're on that point, we
     have had a statistician look at any of these correlations. 
     The statistician has had a tremendous impact on the leakage
     analysis.  We've had these correlations looked at.
               DR. POWERS:  I'm fascinated in what you have to
     say about something at the 12 percent R-squared.
               MR. KARWOSKI:  That's the interesting one,
               DR. POWERS:  At this point, I want to recess, and
     apologize to Ken for interrupting his presentation, it's
     going awfully well, a very nice presentation, but let's
     recess and come back at 1:00.  At that time, Dr. Kress will
     be chairing the session.
               [Whereupon, at 12:05 p.m., the meeting was
     recessed, to reconvene this same day at 1:00 p.m.]
     .                           AFTERNOON SESSION
                                                      [1:05 p.m.]
               DR. KRESS [Presiding]:  Can we come back to order,
     please?  I will be the substitute Chairman till Dana gets
     back, which may be not too long from now.
               So we'll continue now where we left off before
               MR. KARWOSKI:  Thank you.  Okay, just to go over
     quickly what I did this morning, this morning I showed the
     first pressure correlation.
               I showed you how we determine the tube repair
     limits with respect to the one-volt, two-volts, and the
     upper repair limit.  I also discussed the inspections that
     were performed.
               That's the deterministic approach with respect to
     addressing structural integrity, but as I pointed out, there
     are several assumptions with respect to lower tolerance
     limits, material properties using a lower, 95-percent
     prediction interval.
               As a result, from a structural integrity
     standpoint for the entire steam generator, you need to take
     a bigger look at what the cumulative effect of all the
     uncertainties and of some of your assumptions with respect
     to using an average growth rate or a 95-percent confidence
               So, to ensure structural leakage integrity, the
     Generic Letter requires two calculations:  The first
     calculation is a conditional probability of burst under
     steam line break conditions.
               And that calculation is necessary to ensure that
     the repairs are adequate from a structural integrity
     standpoint.  And as I've just mentioned, it's because the
     values of the growth in NDE uncertainty may exceed those in
     the deterministic determination of the repair limits, it's
     because we used the lower 95-percent prediction interval for
     the burst pressure correlation.
               It's also because we only used lower 95-percent
     material properties.  You can have values less than those.
               It's also because you're only looking at a single
     indication and not the entire steam generator.  There is a
     cumulative effect.
               The other calculation that we do -- and I'll be
     talking more about how we do that, in a minute -- is, we
     determine what leakage will exist under postulated accident
               And that's necessary because with this
     voltage-based approach, there is no correlation between
     voltage and depth.  As a result there are through-wall
     cracks or near-through-wall cracks, can either remain in
     service after the inspection, or they may develop --
               And as a result, we have to do a calculation to
     determine the leakage under those conditions.
               Both of those calculations will require some
     knowledge of what's going to be present at the time of the
     next inspection, because from a conservative standpoint, you
     want to know, if I had that steam leak break at the end of
     the next operating interval, what would my probability of
     burst be and what would be my leakage?
               That's going to be the most limiting, because the
     tubes will have the chance to progress the most.
               Looking at this big picture, basically what you do
     is, you do your eddy current inspection, you find all the
     defects at the tube support plates, because under a
     100-percent inspection, you do your RPC examinations.
               With all the indications you detect, you then make
     a POD adjustment.  We use the constant value of .6 as the
               And I'll discuss the basis for the .6 later today
     in then presentation on NDE capabilities.
               DR. CATTON:  What is POD?
               MR. KARWOSKI:  Probability of detection.
               DR. BALLINGER:  Is that the 40-percent level,
     40-percent through-wall?
               MR. KARWOSKI:  We applied that .6 value to
     everything that you find.  Remember, what you're going to
     have is at the beginning of the cycle -- this graph doesn't
     really show it.
               What you're going to have, after you do your
     inspection, you're going to have a distribution of
     indications.  Some of those will be RPC-confirmed; some of
     them won't.
               They will be a function of voltage, okay?  So it
     has nothing -- any given voltage can have a range of depths
     associated with it; there's no correlation.
               We say that our probability of detecting a large
     voltage indication is the same as our probability of
     detecting a low voltage indication.
               And we assume a constant value of .6 throughout
     that range.  So, if you were to say the worst degradation is
     the largest voltage, and that the lower voltage indications
     are minor, we're saying that you have an equal probability
     of detecting both of those.
               It's a very conservative assumption, which we'll
     get into this afternoon when I talk about the POD.
               In general, you would expect to find some of the
     more significant flaws easier than some of the more minor
               So we applied this .6 value.  So everything that
     you find during an inspection, you divide it by .6, which is
     roughly equivalent to multiplying it by 1.6-something.
               And then you subtract out the indications that you
     repaired.  That will be your beginning-of-cycle
               It's very conservative in the sense that if you
     found a ten-volt indication, you would assume that roughly
     -- that you have roughly .67 of those indications left in
               DR. BONACA:  Could you had a defect for which you
     have no indication whatsoever?
               MR. KARWOSKI:  Yes, where you missed it during the
               DR. BONACA:  So for this, really, the conservatism
     doesn't apply, the statement of conservatisms doesn't apply,
     because simply you don't detect it.
               MR. KARWOSKI:  But that's one of the purposes of
     the .6 adjustment, is to account for that.  It's to account
     for the fact that you can miss flaws during your inspection;
     that's one of the purposes.  There is also another purpose,
     and I'll get into that.
               So you divide what you find during your inspection
     by .6, and then you subtract off the indications that you
               DR. KRESS:  Now, suppose you found no indications?
               MR. KARWOSKI:  If you found no indications, you
     won't be implementing the repair criteria, you would just --
               DR. KRESS:  You don't assume that you might not
     have detected --
               MR. KARWOSKI:  Utilities would normally not apply
     for this repair criterion, unless they had a high likelihood
     of finding it.
               So, then you take this beginning-of-cycle
     distribution, and you need to add in growth and NDE
     uncertainty to get to the end-of-cycle distribution.
               Then with that end-of-cycle distribution, that's
     what you use to calculate your probability of burst.
               DR. KRESS:  Voltage growth is based on
     extrapolating fast growth rate?
               MR. KARWOSKI:  The way voltage growth is
     determined as part of this generic letter, is, when you go
     in and inspect -- if today was your inspection, you would
     inspect you'd find a distribution of indications.  You would
     have the voltages associated with those indications.
               You then go back at that location, at your prior
     inspection, and see what it was then, and you take the
     difference, okay?
               DR. KRESS:  Fine.
               MR. KARWOSKI:  And the time, and you make the
     appropriate adjustments for whatever your operating cycle
     is, but you take the difference between those two, you
     adjust it for the appropriate time, and that will be your
     growth rate.
               There are provisions in the Generic Letter that
     address how many datapoints you need in order to use the
     growth rate, the concern being is that if you didn't have
     enough data, how could you project?
               If this is one of your first cycles, you only have
     40 datapoints, how well did you know that the growth rate of
     the tubes?
               And in those cases where there is limited data, it
     requires the utility to use a bounding growth rate based on
     other steam generators that are operated under a similar
               DR. KRESS:  And the assumption is that if the
     growth rate is changing, that that change may not be enough
     to worry about over one cycle?
               MR. KARWOSKI:  Yes, the assumption is that the
     growth rates -- you're looking at this from a population
     standpoint.  The assumption is that the growth rates that
     you observe during the course of that cycle will be -- when
     you operate it the next cycle, adjusted for the appropriate
     operating length, the growth rates will be comparable for
     the entire -- for the population.  That is an assumption.
               The other thing that we do with respect to the
     growth rate distribution, when you go in and do these
     inspections and you find, say, a 1.5 volt indication, or --
     that's probably not a good example.
               Say you'd found a half a volt indication; you
     could go back to the prior outage and notice that the
     voltage was actually .6 volts, and you could have a negative
     growth rate.
               How we address that in the methodology, to be
     conservative, is, we make the utilities assume that the
     growth rate was zero.  So all negative growth rates in the
     probabilistic analysis for determining the end-of-cycle
     distribution are assumed to be zero.
               DR. CATTON:  Because it's physically impossible?
               MR. KARWOSKI:  It's physically impossible.
               DR. CATTON:  But you don't do that with the
               DR. CATTON:  Just thought I'd mention that.
               Between two cycles, I can see how you're going to
     predict the third.  Do you ever go back and make a
     comparison of what was anticipated and what's measured?
               MR. KARWOSKI:  You're getting to the punch line. 
     I will present that.  That's a very important aspect of this
     methodology, very important.
               So, with the beginning of cycle voltage
     distribution, and the growth rate distribution, I also need
     NDE uncertainty.  The NDE uncertainty stems primarily from
     two distributions.
               I only have a picture here, but there are two
     distributions that get sampled.  The first is analyst
     variability, and that's a result of two different analysts
     using the same procedures, could look at the indication and
     get different voltages.
               There was a study performed by the industry when
     this methodology was being developed, which indicated that
     basically the mean of the distribution was zero, it was the
     normal distribution.  I believe the standard deviation was
     about ten percent.
               The important point is that they recognized that
     different analysts can call an indication different.  There
     is an analyst-variability portion to the NDE uncertainty.
               The other portion of the uncertainty is
     uncertainty associated with the wearing of a probe.  If a
     probe wears, it will be a different distance away from the
     tube, and it could result in a different voltage.
               As a result, the industry did some tests to assess
     the effect of probe wear, and there's another distribution
     which takes into account, the wearing of a probe.
               So those are the two components of the uncertainty
               To arrive at the end-of-cycle --
               DR. KRESS:  Are those distributions clad randomly
     to the original distribution?
               MR. KARWOSKI:  Yes.  You basically --
               DR. KRESS:  Sort of like a Monte Carlo.
               MR. KARWOSKI:  It's a Monte Carlo simulation.  You
     sample the beginning-of-cycle voltage distribution, you
     sample growth, you sample the two NDE uncertainty
               DR. KRESS:  Do that over and over till you get a
     new distribution?
               MR. KARWOSKI:  Right.  And the number of
     indications that you leave in service is a result of
     whatever the -- you take your detected, divided it by .6,
     you will grow everything that exists, and you will also have
     the indications that you missed.
               The one other factor, the .6 does not only account
     for indications that were missed during inspection, it also
     accounts for indications that could develop over the cycle.
               Because we do not explicitly say there could be 50
     more indications in the steam generator, the .6 POD accounts
     for both those factors, the missed indications and
     indications that can initiate during the course of the
               DR. KRESS:  What do you do with this bottom
     distribution, once you get it?
               MR. KARWOSKI:  With the end-of-cycle, that's my
     next slide.
               DR. KRESS:  Okay.
               DR. BONACA:  I would like to know, how does it
     account for those that are not detected?  I mean, the .6, if
     I understand it, you take the reading, which is the voltage,
     and you multiply it by 1.6 or whatever, or you divide it by
     .6 to get the new voltage value.
               MR. KARWOSKI:  To get the number of indications. 
     If you found one indication, and it was below the repair
     limit, and you could leave it in service, you would take the
     one indication, divide it by .6, and you'd end up with
     roughly 1.7 indications.
               You would take that 1.7 indications that would be
     at that specific voltage, because you're not repairing
     anything.  You'd sample 1.7 indications and propagate it
               DR. BONACA:  So the number of indications that you
     are separating then?
               MR. KARWOSKI:  Right.  It's the number of
     indications at that specific voltage.  So, recognize that
     one of the industry complaints of our model is they say that
     as the voltage gets -- as the voltage rises, they believe
     their probability of detection increases, because it's a
     much bigger flaw, the noise or the signal will come much
     clearer out of the noise and the analyst isn't going to miss
               So, one of their criticisms is this constant POD
     model.  If I had a 13.7 volt indication, and I detected it
     and I'm going to repair it, this model will require for them
     to leave in at the beginning of cycle, 7/10ths of an
     indication that is at 13.7 volts.
               Their criticism is, if we had a 13.7 volt
     indication, we would find it.  Their position is 100 percent
     of the time.  We say you need to leave .7 of an indication
               DR. KRESS:  When you divide by the .6 and get a
     number, the number of indications is an integer, a whole
     number.  Do you round it up to the next whole number, of
     just leave it as a fraction?
               MR. KARWOSKI:  The fractions are propagated.
               DR. KRESS:  The fractions are propagated, okay,
     which is all right when you're doing a Monte Carlo.
               MR. KARWOSKI:  But, yes, you're right.  But if
     you're counting multiple bursts or something, it poses some
     challenges, but we leave all the fractional indications in
               So what do we do with that end-of-cycle
     distribution?  I said there's two things we do:
               We do the probability of rupture calculation, and
     we do the conditional leak rate calculation.
               With respect to the probability of rupture, we
     start with this end-of-cycle distribution.  We have our
     burst pressure correlation that we discussed this morning.
               It has scatter around it.  We sample around it. 
     If we picked ten volts, we'd come over and say that for a
     ten-volt indication, what is the range of burst pressures
     that we can have?
               We take that sample.  Then we say this has been
     normalized to a specific material property.  We then come in
     here and take a sample of our material properties
     distribution, scale the burst pressure, determine what that
     burst pressure for that one indication is, and determine
     whether or not it's going to rupture under steam line break.
               We repeat the process for all of the indications
     in the steam generator and determine if there was a rupture
     in that steam generator during that one Monte Carlo cycle.
               Then we repeat it, tens, hundreds, thousands of
     times to determine the probability of rupture under steam
     line break conditions.
               Leak rate calculation --
               DR. CATTON:  And this is done with 100-percent
     evaluation of the steam generator, all the tubes are
               MR. KARWOSKI:  All the tubes are checked, 100
     percent at each intersection.
               Another conservatism in the model is there can be
     multiple indications in a tube.  The model treats them all
     as if they were independent tubes, so if you had two
     indications in the same tube, theoretically you could get
     two bursts from that and it's just counted -- they're
     counted as two multiples.
               DR. CATTON:  The multiples can be greater than the
     number of tubes?
               MR. KARWOSKI:  Yes, yes.  That's usually not the
     case, but in the extreme, you're correct.
               DR. SIEBER:  Just so I understand, it seems to me
     that if you repaired everything that you postulated would
     leak, the fact that you end up with -- break, excuse me --
     the fact that you end up with a probability of burst, really
     comes from all these uncertainties that you have factored
     into this.
               Otherwise, you would know it perfectly that
     everything would be accurate, and you could fix everything.
               MR. KARWOSKI:  Right, and that's one of the
     industry's criticisms of our model, because even if they
     repair everything, because of that probability of detection
     adjustment and the uncertainties, they can predict extreme
               DR. SIEBER:  There's going to be something in
               MR. KARWOSKI:  Right.
               DR. SIEBER:  Okay, thank you.
               MR. HIGGINS:  So you could you explain the
     probability -- after you do the probability of rupture
     calculation, is there an acceptance criteria there that
     would then cause them to go back and make additional repairs
     beyond what the voltage requires them to make?
               MR. KARWOSKI:  Yes.  The acceptance criteria --
     there's a reporting requirement.  If the conditional
     probability of burst exceeds one times ten to the minus
     second, then they are required to notify us.
               One of the corrective actions would be to plug
     more tubes.  Recognize, though, the other problem with --
     not problem -- one of the issues with the methodology is
     that you could start off with a very high probability of
     rupture because of that POD adjustment.
               MR. HIGGINS:  And has that happened?  What are the
     typical results?
               MR. KARWOSKI:  Typically, usually, the few high
     voltage indications dominate the burst probability, and so
     once you start leaving 7/10ths of an indication in service,
     that drives the probability.
               MR. HIGGINS:  I mean, have you had cases where you
     had to repair additional -- plug additional tubes beyond
     those that would have been called for by the one volt or two
     volt criteria?
               MR. KARWOSKI:  I don't believe that has happened,
     although I think that in one instance -- there is one
     instance that I'm definitely aware of where the probability
     exceeded one times ten to the minus two.
               I believe it was 1.2 times ten to the minus
     second, so I know there was one instance where it went over.
               DR. SIEBER:  The limit that you're looking for is
     one times ten to the minus two?
               MR. KARWOSKI:  Yes.
               DR. SIEBER:  Okay, thank you.
               DR. KRESS:  Where did that number come from?
               MR. KARWOSKI:  That is on a slide towards the
     back, but it's 1/5th the value that was assumed in the
     staff's assessment of risk assessment of steam generator
     tubes in NUREG 0844.
               The value was just 1/5th because this is only one
     degradation mechanism.  We assumed a probability of rupture
     in that report of five times ten to the minus second and we
     said we didn't want one mechanism controlling, you know,
     right up to the limit.  There are other mechanisms going on.
               The other reason is that it gives us some insights
     on whether or not any tubes may not meet the Regulatory
     Guide 1.121 structural criteria.  Even though we're
     calculating the probability of burst, we wanted some
     insights on whether or not there are any tubes that are
     starting encroaching on the deterministic structural
     margins, the worst case tube.
               DR. KRESS:  Where did the number -- what's the
     technical basis for the number as multiplied by five?
               You say you took one-fifth of the number.  What's
     the technical basis for the --
               MR. KARWOSKI:  For the five times ten to the minus
               DR. KRESS:  Yes.
               MR. KARWOSKI:  Somebody else -- basically I think
     they did a risk assessment that assumed a frequency of
     rupture of five times ten to the minus second, propagated
     that through a risk assessment, and determined that that was
               That's my understanding.
               MR. STROSNIDER:  That's correct.  The assumption
     in NUREG 0884 --
               MR. KARWOSKI:  0844.
               MR. STROSNIDER:  0844, I always get that mixed up. 
     But the assumption was made of a conditional failure
     probability, given a main steam line break, of five times
     ten to the minus second.
               And when that was worked through the whole risk
     assessment then, it was found that it gave an acceptable
     level of risk.
               All right, and then we reduced it to account for
     the potential for other modes of degradation.  I think Steve
               DR. KRESS:  It gave an --
               MR. STROSNIDER:  -- might be able to explain that
     in more depth.
               DR. KRESS:  Okay.
               MR. LONG:  I wasn't involved in 0844, but Emmett
     can correct me if I get this wrong.  Initially, they were
     trying to determine what they thought the conditional
     probability of burst would be for a main steam line break,
     based on experience, and largely that was experience of
     ruptures that had occurred and some estimate of the period
     of time that it would take to grow from where they could be
     susceptible to rupture when the depressurization occurred,
     to the period when they just ruptured during normal
               So there was sort of an exposure estimate in
     there.  And I think it was essentially that exposure
     estimate, with some adjustments for things they didn't think
     they really observed, it was put into the risk assessment in
     0844 to see if there was an acceptable or an unacceptable
               It wasn't intended to be a limit when they did
     that calculation.  And it wasn't a risk assessment that
     recognized severe accident sensitivities or that sort of
               So it was done about 1985, I guess.
               MR. MURPHY:  The report was issued in 1988.
               MR. LONG:  So that's sort of the first of three
     risk assessments that you will hear about, the one for 1477
     being the next, and 1570 being the most recent one.
               DR. KRESS:  We'll hear about this later, will we?
               MR. LONG:  To some degree.  We didn't intend to go
     into it that way, so that's why I'm explaining it now.
               The point I was trying to make, though, is, we
     didn't try to use the .05 as some sort of an acceptance
     criteria.  It came from experience, and it was essentially
     evaluated to see if it was something that we should try to
               MR. STROSNIDER:  But I might add that when we were
     developing Generic Letter 95-05, that's the risk assessment
     that we had to look at.
               And when we looked at it, we said, well, five
     times ten to the minus second, when that was propagated
     through the risk assessment for those sequences associated
     with main steam line break, it resulted in an acceptable
     level of risk.
               So, we said, okay, we'll use that as an acceptance
               DR. KRESS:  Yes.  What was your criteria for an
     acceptable level of risk?
               MR. STROSNIDER:  I don't know what it would have
     been in '88 in terms of -- we'll have to get back to you,
               MR. KARWOSKI:  The one other item that I should
     point out with respect to the probability of burst
     calculation is that it's evaluated at a 95-percent
     confidence value.
               It's not just whatever the probability is; it's at
     a 95-percent confidence value.
               The other portion, the leakage integrity portion,
     is depicted on this viewgraph.  It's a similar methodology;
     you do a Monte Carlo analysis.  You sample the end-of-cycle
     distribution for a specific voltage.
               You come to the probability of leakage
     correlation, and determine whether or not the tube will
     either leak or it won't leak.  If it leaks, you come into
     the leak rate correlation and determine --
               DR. KRESS:  If you have a probability of leakage? 
     That's like Schrettinger's cat; it's both dead and alive. 
     What do you mean, it won't leak or it will leak?  If it has
     a probability of leakage, it has a probability.
               I didn't understand your statement; that's what
     I'm saying.
               MR. LONG:  Oh, for a given voltage, there is a
     probability that a tube will either leak or it won't leak.
               DR. KRESS:  It's still Schrettinger's cat.  I
     don't quite understand.  If it's a probability of a leak,
     then one minus that is probability that it won't leak.  I'm
     still having trouble figuring out what you're saying.
               MR. STROSNIDER:  The point is that the probability
     depends on voltage.
               DR. KRESS:  Of course it does.  But it's a
     probability --
               MR. STROSNIDER:  But I think the point is that it
     either will leak or won't leak.  If it leaks, the
     probability is one, and those are the datapoints that are on
     the top.
               If it doesn't leak, the probability is zero. 
     Those are the datapoints that are on the bottom.
               DR. KRESS:  Yes, but that's a delta function.
               MR. STROSNIDER:  I'm sorry, I didn't hear you.
               DR. KRESS:  That's a delta function; that's not a
               MR. STROSNIDER:  Well, and this came up yesterday. 
     Art Buslick raised a question about how you fit the
     distribution to those data.
               DR. KRESS:  Once you have a distribution, though,
     it's just a probability.
               MR. KARWOSKI:  Let me try it this way:  You pulled
     these tubes, okay, and you test to determine whether or not
     they're going to leak under steam line break conditions.
               You've got various voltages, okay?
               DR. KRESS:  So you plot that.
               MR. KARWOSKI:  When you test this tube, it either
     leaks or it doesn't leak; there is no -- it either leaks or
     it doesn't leak.
               So you have the voltage associated with that
     indication, and you either know if it doesn't leak, or if it
               DR. KRESS:  Sure.
               MR. KARWOSKI:  Okay?  There may be five tubes with
     the same voltage.  Three of them may leak; two of them don't
     leak, okay, for a given voltage, okay?
               So when you come in there, say, you just had
     indications of that voltage, roughly 60 percent of the time,
     3/5ths, 60 percent of the time you will assume that that
     indication leaks; 40 percent of the time, you will assume
     that it doesn't leak.  Does that --
               DR. KRESS:  Yes, that answers my question.  It's
     just a probability.
               MR. HIGGINS:  Are you talking now about applying
     the methodology or the development of these curves?
               MR. KARWOSKI:  Also applying it.  It's the
     development of the curves and applying it, because once you
     have this function -- and I'll talk about this in a minute
     -- once you have this function, you have a relationship and
     you can say that there is a certain probability that an
     indication with that voltage will leak, and one minus that
     is the probability that that indication will not leak.
               So you go through this method; you sample your
     voltage, you sample your probability of leakage to determine
     whether or not the tube either leaks or it does not leak,
     you determine the associated leak rates with that voltage. 
     You add it up for the entire steam generator, and you get a
     value for leakage.
               You repeat this for all the indications in the
     steam generator, and you've got the one value of the leakage
     for that steam generator, you repeat it, tens, hundreds of
     thousands of times, and you will have a distribution of leak
               You order those, you take the 95th percentile, at
     the 95-percent confidence, and that's what you say your
     leakage is under steam line break conditions.  So it's a
     95/95 leak rate, okay?
               There was some discussion yesterday on the
     probability of leakage correlation, and this one is not in
     your handout.  What I have plotted here -- and it's probably
     not worth your effort to figure out which curve is which --
     but it's basically looking at six different functions of the
     probability of leakage.
               Okay, there is no theoretical basis for the log
     logistic curve that we are using.  We've documented that in
     NUREG 1477.  There's no basis, theoretical basis.
               DR. KRESS:  And there's not enough data to
     best-fit any of it.
               MR. KARWOSKI:  They all have equal -- so, why did
     we choose the log logistic over any of the others?  Well,
     before I get into that, I mean, if you look at this some of
     these functions -- and, truthfully, I don't even know which
     ones the log logistic predicts a probability of leakage for
     very small indications, most of them don't.
               These curves criss-cross.  To determine which one
     is conservative, you're not going to be able to do it,
     because it's going to depend on the distribution of
     indications you leave in service.
               You can do it only if you analyze that steam
     generator, because these curves are criss-crossing, and so
     it depends if you have a lot of low voltages, medium
     voltages, or high voltages.
               In NUREG 1477, we did some analysis where we
     shifted the distribution and determined the leak rates.  And
     in some cases, I believe it was the log co, she was
     conservative, and in other cases, the log logistic was
               So, the staff did look at, you know, should we be
     using a different function or how should we implement it?
               What the staff subsequently decided was that the
     log logistic was acceptable for several reasons, one being
     the POD adjustment was conservative; we're evaluating leak
     rate at the 95th percentile and a 95-percent confidence.
               Those are two primary reasons, so the staff did
     look into which curve to use, and we chose the log logistic. 
     The next few slides just basically describe what I said,
     conditional probability of burst.  It discusses the process
     and the acceptance criteria.  And this slide discusses the
     leakage distribution.
               I wanted to spend a little more time on here
     because I think, as Dr. Powers pointed out, you know, it had
     very low correlation coefficients for some of those leak
     rate correlations, and there has been considerable study of
     this data.
               The way the methodology works for the leak rate
     correlation -- and I don't believe this one is in your
     package.  This is something that I prepared subsequently.
               DR. KRESS:  No wonder I couldn't find that.
               MR. KARWOSKI:  If the linear correlation can be
     developed between the leak rate and the voltage -- this
     isn't the actual data, so you have the data in those
     proprietary summaries that I passed out -- but -- well, let
     me start over.
               When you look at this data, the original data, you
     could look at it and say, well, should the curve be like
     this?  Should it be like this?  Should it be like that?
               The industry did a linear regression and came up
     with a curve.  The staff was concerned, is there really a
     correlation there?
               We had a statistician look at it.  And basically,
     what he concluded, at least for the 7/8ths inch diameter
     database -- and it may have been the same with the 3/4 inch
     at the time, but for the 7/8 inch database, he concluded
     that there wasn't sufficient confidence that the slope was
     not zero.
               So, basically he said there is no correlation. 
     The implications of that to the utilities is that a tenth of
     a volt indication, the way we interpreted that is,
     regardless of the voltage, the indication will leak by the
     same amount.
               And that's what the Generic Letter describes, an
     acceptance criteria for showing whether or not you have a
     correlation or you don't.
               And it's a standard statistical test, a P-value
     test, and you have to have a 95-percent confidence that the
     slope of the line is not zero.
               DR. KRESS:  This is sort of a generic correlation
     that you build up a database for.
               MR. KARWOSKI:  Right.
               DR. KRESS:  And you're saying that before -- I'm
     not quite I understood.  You're saying that before you can
     use this in your alternative criteria, you have to have
     enough data to have a correlation?
               MR. KARWOSKI:  No.
               DR. KRESS:  I'm not quite sure what you're saying.
               MR. KARWOSKI:  What I'm saying is, if you can just
     demonstrate by statistical tests that the slope of this line
     is non-zero --
               DR. KRESS:  I thought you already said that you
     tried that, and it wasn't.
               MR. KARWOSKI:  The Generic Letter is more
     performance-based.  Instead of saying here is the
     correlation at this time, and there is the slope, we
     recognize that they're going to pull additional data. 
     They're going to get more data which --
               DR. KRESS:  At some point in time, you may have a
               MR. KARWOSKI:  That's correct, or you may go from
     correlation to not.  The bottom line is, when you get more
     data, you have to put it in these correlations and you have
     to use the most recent database.
               We didn't want to lock in a certain database,
     knowing that utilities will gain more experience.
               DR. KRESS:  Up to the point where they
     statistically can't say they have a correlation, what do
     they do up to that point?
               MR. KARWOSKI:  When they don't have a correlation,
     they have to assume that essentially the tube will leak at a
     specified value.
               DR. KRESS:  And that value is what?
               MR. KARWOSKI:  They basically do a Monte Carlo
     analysis and model the error and say -- around the
     regression line, what the slope at zero.  So basically they
     average the log of the leak rate, obtain a value, and then
     sample the uncertainty around that line, and basically
     assume that the leak rate is independent of voltage.
               A tenth of a volt indication will leak the same as
     a 25 volt indication.
               DR. KRESS:  Put that line through the average of
     the data?
               DR. CATTON:  That's what it amounts to.
               MR. KARWOSKI:  Through the average of the log, it
     will leak -- they basically do a -- right.
               DR. KRESS:  That doesn't sound like a very
     interesting thing to do.
               MR. KARWOSKI:  Well --
               DR. CATTON:  It's zero physics.  It's simple, too.
               DR. BALLINGER:  But what is the criteria, exactly,
     by -- what is the fence that they get over before they say
     it's a correlation?  What is the statistical test that has
     to be passed?
               MR. KARWOSKI:  The P-value has to be less than
     .05.  There has to be a 95 -- I hope I get this right; I'm
     not a statistician.
               It has to be a 95-percent confidence that the
     slope of that regression line is not zero.
               DR. KRESS:  That's the sort of standard rule of
     thumb for statisticians, I guess.
               DR. CATTON:  If you don't know a damn thing, you
     just average everything.
               MR. KARWOSKI:  Well, not only do you average it,
     but you also model the uncertainties.
               DR. CATTON:  The only thing you're bringing in
     over here is the distribution of voltages.  A tenth of a
     volt is probably not going to show -- you just toss out all
     the physics when you do that.
               MR. KARWOSKI:  This is an empirical --
               DR. CATTON:  It's not even empirical.  I mean,
     you've just thrown everything away.
               DR. KRESS:  There's no physics in there anyway.
               DR. BALLINGER:  But it just says there's no
     information in the data.
               DR. CATTON:  That's right.  So how do you pick the
     number that you use that's meaningful?
               DR. KRESS:  I think that's your point, right?
               DR. CATTON:  That's right, how do you know?
               MR. STROSNIDER:  This is Jack Strosnider.  I'd
     suggest that one of the things that might need to be pointed
     out is that there is a very large uncertainty -- not
     uncertainty but actually variability in scatter and leakage
     rates through cracks.
               And we're talking orders of magnitude, as I
     recall, three leakage values.  And that's part of what
     drives this, is there is a large variability.
               And there was discussion yesterday about what sort
     of particulate might be in the cracks, and what the
     morphology is and that sort of thing.
               DR. CATTON:  That's right.
               MR. STROSNIDER:  And even when you grow single
     stress corrosion cracks in a tube, you get very large
     variability.  So trying to get a lot of information out when
     you've got that much scatter, that may contribute to some of
     the problem here.
               But anyway, that's -- the industry was not happy
     with what was sometimes referred to as the flat earth model,
     where we said, okay, just take this horizontal line.
               But as Ken indicated, we tried to build into it,
     as the database grew, if the correlations became more
     obvious, then it could be used.
               DR. KRESS:  We have an imminent --
               MR. SHACK:  This is Bill Shack.  Let me just take
     a crack at it.  This is a bad joke here.
               DR. KRESS:  Fine.
               MR. SHACK:  One of the reasons that -- you know,
     physically, I think this thing sort of works out the way you
     expect it to work out.
               There is a rough correlation for cracks up to a
     half an inch between the crack length and the voltage, that
     is, the voltage increases rather rapidly with crack length
     up to about half an inch, and then it kind of flattens off.
               Well, most of the cracks of interest here are on
     the order of something less than a half an inch, so that an
     increase in voltage is a measure of crack length.
               Burst pressure depends only on crack length.  So,
     I would expect to get a reasonable correlation between burst
     pressure and voltage.
               Leak rate doesn't depend just on crack length; it
     depends on crack depth.  And so I expect to get a hell of a
     lot more scatter in my voltage versus leak rate correlation,
     than I do in my voltage versus burst correlation, and so I
     get a better statistical fit for the pressure, burst
     pressures, than I do for the leak rate, because I'm trying
     to look at both.
               And as Jack said, even if I knew the depth of the
     crack and the length of the crack, I still have more
     uncertainties in the leak rate, because it depends on lots
     of things.
               DR. KRESS:  Don't you have to have a through-wall
     crack to get a leak rate?
               MR. STROSNIDER:  Right, and that's probably the
     biggest thing here, but that's sort of accounted for in the
     zero to one.
               Either I've got a through-wall crack or I don't.
               DR. KRESS:  That's sort of wrapped up in that
               MR. STROSNIDER:  That's wrapped up in that
     distribution.  But then once I do that, even though I have
     decided I've got a through-wall crack, I really don't know
     how much the through-wall length is, where the burst
     pressure is.
               I just keep upping the pressure until I rip the
     thing open, and I know really how long it was.    
               All I'm arguing is that the fact that you have
     lots of scatter here and you get a better correlation, the
     burst pressure, isn't a surprise.  But the answer is, you
     shouldn't expect a terribly good correlation here, so what
     are you supposed to do?
               DR. CATTON:  And it's a nice physical explanation
     of the observations.  But the question still remains, what
     are you supposed to do?
               I guess the only thing is that you have a low-end
     cutoff on the voltage; don't you, with that probability of a
     leakage.  If the voltage is less than some number, it
     doesn't leak.
               So when you say even a tenth of a volt has a leak,
     it doesn't, because there is a cutoff.
               MR. KARWOSKI:  Right, wherever there is some --
               DR. CATTON:  There's a cutoff.  And I bet that
     you're at zero at a tenth of a volt.
               MR. KARWOSKI:  You could be.  I don't recall.
               DR. CATTON:  That's what that is, it's a gate that
     sits right in the middle.
               MR. STROSNIDER:  This is Jack Strosnider.  Art
     Buslick could address this better than me, but I think all
     those fits go through zero.  But the probabilities do become
     very, very small.
               DR. KRESS:  For the log, the logistic, you don't
     have a cutoff; it goes to zero asyntotically.  There is
     still a small probability.
               MR. STROSNIDER:  It could be a small number, but
     the utility, the thing they didn't like about it is that if
     they had a large number of small voltages, that they could
     still generate some sort of leakage.
               DR. CATTON:  I would be concerned if I were them,
               But from the other side, you'd probably get a
     too-low rate at the high voltage.
               DR. KRESS:  Basically what they're saying is that
     those two sets of data on the top and bottom, and when you
     get down that low, there are no overlapping, although this
     curve would have said there was some overlapping.
               MR. STROSNIDER:  I think the answer to your
     question with what you do with it -- and this may just spur
     more discussion -- but my response is that you take a
     conservative approach, which is what we think we did, in
     terms taking the constant leakage --
               DR. CATTON:  Where you put the line is on the high
     side, rather than the low side?
               MR. STROSNIDER:  Well, Ken can explain it.
               DR. KRESS:  I think we may have to.
               MR. STROSNIDER:  When you go through this
     evaluation, then you look at some 95th percentile.
               MR. KARWOSKI:  If you look at the type of voltages
     that the plants are running at, giving it the zero slope or
     the flat earth, however you want to look at it, that's going
     to be more conservative, because usually there aren't a lot
     of large voltage indications.
               What will drive the probability is the leakage
     from those low voltages.  You still have a finite
     probability that those will leak.
               MR. MUSCARO:  Joe Muscaro with the NRC staff, I
     just have a point of clarification.  I think Bill mentioned
     the phenomenon in reverse.  I think he said that the leakage
     depends on the length and depth and burst on length.
               Well, it's the reverse, of course.  Leak rate
     depends on the length of the flaw, but burst depends both on
     the length and depth.
               The other point was the physical basis for whether
     there should be a correlation or not with respect to voltage
     versus crack length, which is important for leakage.
               And there some studies we have done in the past
     and have show that the voltage starts at a crack length of
     about 3/10 of a inch, which makes this fairly important for
     the application when we're talking about cracks that are
     less than 3/4 of an inch long.
               So there is a saturation effect on the voltage. 
     The physics limits it.  I mean, it only sees a certain
     portion of the crack, so there is no additional voltage
     beyond about a 3/10 of a inch crack with the coil that we
     use today.  Of course, that's a function of the design of
     the coil.
               MR. HIGGINS:  Ken, you said that this is being
     updated, and how is that done?  Is somebody the keeper of
     the curve for all of industry, and then people use that?
               MR. KARWOSKI:  Essentially, that's correct, either
     EPRI or NEI -- and I don't recall which one.  I believe that
     NEI sends in the formal report, but it's an EPRI report.
               But basically, annually they update.  There is a
     specific protocol, and I believe it's annually.  They
     incorporate all the pulled tube data from that year, they
     put it in the correlations, they develop revised
     correlations, and they give those to the industry.
               The case where I said that one plant exceeded the
     one times ten to the minus two burst probability, what
     happened there is, they did their inspection, they
     calculated the probability of burst to be less than ten to
     the minus two.
               They incorporated more data into the burst
     pressure correlation, and when they did that and reran their
     burst results, they ended up slightly greater than one times
     ten to the minus second.  That's what happened in that case.
               So, utilities, when they do these calculations are
     supposed to use the most recent database.
               DR. CATTON:  Is this number increasing or
     decreasing with time?
               MR. KARWOSKI:  The?
               DR. CATTON:  The leak rate, the uncorrelated leak
     rate number?
               MR. KARWOSKI:  I believe there is a correlation
     now for both the 3/4 inch and 7/8 inch database.
               DR. CATTON:  So it's beginning to get a little bit
     of a --
               MR. KARWOSKI:  A slope, right.
               DR. KRESS:  So at some magic point in time, people
     will quit using this flat earth average with the
     distribution around it, and go to this actual curve?
               MR. KARWOSKI:  With also distribution around it,
     because as was pointed out, there is a lot of scatter.
               DR. KRESS:  And you won't be penalizing the small
     cracks as bad?
               MR. KARWOSKI:  That's right, and it makes a --
     once again, it's going to depend on your distribution of
     indications, but for the one plant that I'm aware of, it
     reduced their leakage by a factor of three.
               They were predicting something on the order of 13
     gpm, and when they went to this it was more like four or
     five.  So, it reduces the leakage considerably.
               Okay, one of the important aspects of this Generic
     Letter is that it requires the licensees to submit certain
               With that data, you can go back and compare the
     projected and actual end-of-cycle distributions.  That
     allows you to check various things.  Is the .6 POD, is that
     accounting for new indications and the probability of
     detection accordingly?  Was your growth rate assumption
               Was my NDE uncertainty realistic?  Because you can
     compare what you actually found to what you projected. 
     That's a very important aspect of this.
               These comparisons have generally shown the
     methodology to be conservative.  That's not to say that
     they're perfect; that's not to say that they're haven't been
     indications with larger voltages than we predicted, as was
     pointed out yesterday.  I will discuss that specific
               But the staff did do a comprehensive review of
     what I have termed the 90-day reports, where the utilities
     supply their inspection results, both their projections and
     their actual results.
               DR. KRESS:  This is one of those cases where you
     hope you're not gently flowing down the stream and suddenly
     about to go over a waterfall, a cliff-edge type thing?  I
     don't know how you deal with that in terms of projecting
     forward in time, based on past history.
               MR. STROSNIDER:  This is Jack Strosnider.  I'd
     just make a short comment on that, which is that I think
     what you're talking about is how can I foresee what's going
     to happen in the next cycle of operations?
               DR. KRESS:  Yes.
               MR. STROSNIDER:  That's an issue that exists,
     regardless of what --
               DR. KRESS:  No matter what.
               MR. STROSNIDER:  -- what repair criteria or
     inspection method you use.  And you can go to laboratory
     data to get some insights, all right, but we have found,
     historically, we think, that the best predictor is what
     happened in the last cycle.
               That doesn't mean that you won't some day be
     surprised with a new form of degradation or some higher
     growth rate, and you have to deal with that when it occurs.
               But nobody has a crystal ball to say exactly
     what's going to happen in the next cycle.
               CHAIRMAN POWERS:  You're going to show us some
     examples of where the methodology has been compared?
               MR. KARWOSKI:  Yes, I will show you -- I have two
     examples.  I just pulled out two.
               But back in 1997, we did do a comprehensive review
     of, I believe it was eight 90-day reports, and there were
     some issues that were identified as a result of that.
               One of the issues was, when you have a low number
     of indications, your projections typically are off, but with
     respect to the distribution that you find in the next cycle
     -- but that necessarily is not a bad thing.
               When you look it from the probability of rupture
     or leakage, what you're finding out is, you know, you
     predicted a ten to minus four probability of rupture, and
     instead, it's five times to minus four.
               In general, in all of these assessments, in not
     one instance did we exceed the acceptance criteria of one
     times ten to minus second for burst, or the applicable
     leakage limit at that plant.
               The other thing I'd point out is that as a result
     of implementing this repair criteria, there has been no
     significant operational leakage.
               DR. CATTON:  Your second paragraph says
     comparisons have generally shown methodology to be
               MR. KARWOSKI:  Yes.
               DR. CATTON:  What's your measure?
               MR. KARWOSKI:  The measure is several things:  We
     look at what the distribution of voltage is.  Did we predict
     the peak voltage?
               Did we -- how did we do with respect to burst and
     leakage?  What was our predicted probability of burst and
     what was our actual probability of burst, based on the
     inspection findings.
               DR. CATTON:  I can buy into that, but now what
     about leakage?
               MR. KARWOSKI:  The same thing for leakage:  What
     did we predict for leakage, and what will we predict, based
     on our actual end-of-cycle findings?
               DR. CATTON:  End-of-cycle findings is a measured
     leak rate for the steam generator?  What is the end-of-cycle
     finding that you compare with leakage?
               MR. KARWOSKI:  Okay, when you go in and do an
     inspection today, okay, you're going to have a distribution
     of indications.  Before I do any repairs, I say, how much
     leakage would I have gotten from that distribution of
               DR. CATTON:  Okay.
               MR. KARWOSKI:  Okay?  Now, I go back to the prior
     cycle.  What did I predict I was going to get?
               If I predicted --
               DR. CATTON:  But you haven't measured leakage and
     compared it with prediction?
               MR. KARWOSKI:  No.
               DR. CATTON:  So this is all just paper?  It's an
     earlier estimate with the present estimate, but there is no
     actual comparison.
               So you don't know whether you're conservative or
     not.  You may have been non-conservative in both cases, one
     must more than the other or less than the other.
               MR. KARWOSKI:  The burst and leakage are a
     comparison based on the methodology.  The actual findings is
     a comparison of what you have.
               MR. STROSNIDER:  This is Jack Strosnider.  What
     you have --
               MR. CATTON:  I thought I asked and you said no.
               MR. STROSNIDER:  What you have compared is you
     have compared the predicted versus the measured end of cycle
     voltage distribution.
               MR. CATTON:  Yes.
               MR. STROSNIDER:  That is what you have compared.
               In terms of what leakage would be associated with
     those two distributions, it uses the same methodology.  As
     you say, if there is some bias in that methodology it would
     be there in both --
               MR. CATTON:  So you really don't know where you're
               DR. KRESS:  There's no additional information --
               MR. CATTON:  That's right.
               DR. KRESS:  -- in going to that second comparison,
               MR. CATTON:  So this second statement, comparisons
     have generally shown methodology to be conservative we don't
               MR. KARWOSKI:  In predicting the end of cycle
               DR. KRESS:  With respect to that you can say that.
               MR. CATTON:  It only has to do with voltage.  It
     has nothing to do with the leakage.
               MR. KARWOSKI:  Yes.
               MR. CATTON:  We have a model that we might
     believe --
               DR. KRESS:  You're comparing the bursts --
     comparing the voltage and then comparing the leakage tells
     you nothing, no additional information.
               MR. CATTON:  Bursts I buy because they actually
     have correlations and so forth but the leakage is so all
     over the map I don't think you can come to a conclusion.
               DR. KRESS:  But even comparing -- you know, it
     makes no sense to compare predicted bursts to actual bursts
     or predicted leakage to actual leakage.  The comparison you
     are getting is voltage to voltage, predicted versus actual,
     and that is the only information you have really.
               MR. CATTON:  That's right.
               MR. HIGGINS:  But the leakage database should be
     getting better as you go over the years because you are
     adding more and more pulled tubes that you are testing.
               DR. KRESS:  Yes.  Yes, the database ought to get
     better.  Your ability to convert the number in the leakage
     is getting better.
               MR. STROSNIDER:  I think I'd just comment I think
     it's kind of indicated there is a correlation in the leakage
     database now -- you know, because additional data have been
     added and it meets the criteria that were established but
     again I would come back and make the point again that when
     we start talking about leakage under main steam line break
     conditions that we are always relying on a model.
               DR. KRESS:  Oh, yes.
               MR. STROSNIDER:  Okay?  We have a model here that
     is tied to voltages.  If you had crack measurements that
     were accurate that you believed you would be going to
     something like CRACKFLOOR or one of the other models that
     was discussed yesterday, so yes, we are constrained by
     having a model.  That is just a reality of it.
               DR. KRESS:  These leakage correlations were
     developed using the normal operating delta p, right?
               MR. KARWOSKI:  No, these are steam line break --
               DR. KRESS:  Those are steam line break leakages
     that used the actual steam line break delta p.
               MR. KARWOSKI:  Right, and as I mentioned this
     morning there are some adjustments to that data.
               The test procedure calls for them to be run at
     operating temperature.  There are some data -- I looked at
     lunch -- there are some data that are at room temperature
     and they are adjusted over here.
               The delta p could differ.  The delta p for the
     test --
               DR. KRESS:  You might not have tested at the delta
     p --
               MR. KARWOSKI:  At 2650 -- it could be 2500, 2400. 
     I would have to look at each individual datapoint but there
     is a range of differential pressure.
               DR. KRESS:  They would have corrected for that
     some way?
               MR. KARWOSKI:  They would have corrected --
               DR. KRESS:  If they knew how leakage varied with
     delta p they would have corrected maybe.
               CHAIRMAN POWERS:  They would know leakage varies
     with delta p?
               DR. KRESS:  I don't, do you?
               CHAIRMAN POWERS:  I thought you knew everything.
               DR. KRESS:  If they were flowing through a pipe
     I'd know.
               CHAIRMAN POWERS:  So how can they do the
               MR. KARWOSKI:  I am not aware of all the details
     with respect to that correction procedure.  I know that they
     have corrected.  I don't know the specific details of that. 
     We would have to get back to you on that.
               The procedure is documented in the EPRI test
               MR. HOPENFELD:  I'd bring to your attention that
     this was a major point that I was making yesterday and I
     wouldn't let you out of this room until you answered it.
               MR. STROSNIDER:  I think that the Staff committed
     to get back on that subject and we will.  Thank you very
               MR. HOPENFELD:  Okay.
               CHAIRMAN POWERS:  I regret that I was called away. 
     Have we had a chance to discuss the famous log logistics
               DR. KRESS:  We passed right through it just like
     that.  You want to go back to it?
               MR. BALLINGER:  Not without getting a definition
     of what they defined as being proof.
               CHAIRMAN POWERS:  Okay, but sometime I would like
     to hear about the log logistic curve just because I happen
     not to know what a log logistic curve is.
               Please continue.
               DR. KRESS:  We decided it was conservative for
     very small cracks because it doesn't have a bottom cutoff
     for it.
               MR. KARWOSKI:  Here is one example of a comparison
     of actual and predicted.  I just -- I don't want to spend a
     lot of time on this one.  I would rather go to the following
     one that was discussed yesterday.
               Basically if you look here the actual is the open
     and the predicted with the POD of .6 is in black.  This
     other one is an approach proposed by EPRI that the Staff
     hasn't approved, but if you look at this, here is the actual
     number of indications predicted in this voltage range versus
     the predicted and in general although you can't see out
     here, in general we have been conservative.
               CHAIRMAN POWERS:  Maybe I need a little more
               You have plotted a number of indications versus
     bobbin voltage and the black bars are what you predict and
     the open bars are what was actually measured --
               MR. KARWOSKI:  Right.
               CHAIRMAN POWERS:  -- and when I look at the lower
     areas you get more low voltage indications than you predict
     but as you move up the voltage then you predict more than
     you actually observe.  Is that correct?
               MR. KARWOSKI:  But there are exceptions but in
     general you tend to be conservative in this.  This was just
     one example.  You are right.  There are exceptions and the
     Farley example
               MR. STROSNIDER:  Ken, I just might point out that
     I think it gets back to using the leakage model, okay?
               When you ask yourself is that distribution
     conservative or not, what you do is use the predicted versus
     the actual, calculate the leakage and say does this end of
     cycle distribution result in more or less leakage than would
     have been predicted.
               Again, I think Ken said earlier that when we do
     that in every case the leakage has been bounded, is that --
               MR. KARWOSKI:  What I said is that in every case
     when you do that the leakage is always less than the
     acceptance limit based on the dose equivalent of Iodine 131
     in the tech specs.
               In some cases it may have been higher than the
     predicted but it has always been less than the dose allowed,
     the leakage that will be permitted --
               CHAIRMAN POWERS:  Do you have the numerics on
               MR. KARWOSKI:  Numerics?  Like the number of times
     it's happened or --
               CHAIRMAN POWERS:  Well, like a leakage predicted
     versus a leakage actual -- I'm sorry.  A leakage predicted
     versus leakage predicted from the actual distribution?
               MR. KARWOSKI:  We have that data.  I think I may
     have it for the Farley.
               CHAIRMAN POWERS:  Oh, good.
               MR. KARWOSKI:  But I don't know if I wrote it
               This is the Farley example.  Getting at the
     comparisons, the statement that the comparisons have
     generally been conservative, this is an excerpt from a
     Farley submittal.  This would be their end of Cycle 14
     projections, what they planned on, what they expected to
               Here's the number of indications that they
     expected.  Here's the maximum voltage that they projected. 
     Here's the burst probability, single tube burst probability
     and here is the steam line break leak rate, okay?
               If you look, let's look at the number of
     indications.  In all cases the projections bounded the
     actuals.  The max voltage, in this case they are equal.
               The projection, in Steam Generator B the
     projection was greater.  In Steam Generator C this is the
     indication we were talking about yesterday.  It was 13.7
     volts but this value is adjusted for NDE uncertainty and
     that is why it is listed as 14.9 but it is the same
               In this case we underpredicted the max in the
     cycle voltage.
               With respect to burst probability, if you look at
     these values --
               CHAIRMAN POWERS:  These means or are these the 95
               MR. KARWOSKI:  These are the 95 percentiles.
               Steam Generators A and B we conservatively
     predicted and the burst probability Steam Generator C we
               What I was saying was this value was still less
     than 10 to the minus 2.
               I would also point out that what is driving this
     burst probability is that single, is that large voltage
               With respect to leakage with Steam Generators A
     and B our projections were conservative compared to here. 
     Likewise for Steam Generator C.
               CHAIRMAN POWERS:  Why was that?
               MR. KARWOSKI:  It was probably because they were
     using the leakage correlation which had a zero slope.  That
     is probably what was causing that.  I don't know that, but
     that would be my guess.
               MR. BALLINGER:  Do you have information on what
     the end of Cycle 13 actuals were?
               MR. KARWOSKI:  We would have to dig it up.  I
     don't have it here.
               DR. KRESS:  Is there a consistent underprediction?
               MR. KARWOSKI:  I tried --
               DR. KRESS:  For two cycles or --
               MR. KARWOSKI:  During lunch I tried to get that
     information because the end of Cycle 15 has already
               From what I was told and I have not reviewed this,
     from what I was told this did not occur in the next cycle. 
     I would need to review that and provide that.  I tried to do
     it during lunchtime.  I just ran out of time.
               MR. STROSNIDER:  Again I think it might be worth
     pointing out too that in this methodology that 14, almost 15
     volt indication would get folded back into the prediction of
     the next cycle's end of cycle distribution, all right?  So
     the fact that that occurred does influence the assessment of
     the next operating cycle.
               MR. KARWOSKI:  Absolutely and if you look at the
     end of Cycle 15 projections for Steam Generator C, your
     burst probability of 9 times 6 times 10 to the minus 3 is
     dictated by that seven-tenths of an indication that you left
     in there at roughly 13.7 volts.
               DR. KRESS:  Will they repair that one or --
               MR. KARWOSKI:  Absolutely.  That indication was
     actually --
               DR. KRESS:  So if they repair that one, how do you
     fold it back into your projection for the next --
               MR. KARWOSKI:  Oh, because that's -- you just do
     that on paper.  You plug a lot of tubes but you still
     include them in your analysis -- through .6 POD so --
               DR. KRESS:  Okay.  They can never escape that .6.
               MR. STROSNIDER:  You are assuming that you missed
     another one of those at some probability.
               DR. KRESS:  You never escape that -- that's right.
               CHAIRMAN POWERS:  You have an acceptance value for
     the burst probability.  What about the leak rate?
               MR. KARWOSKI:  The leak rate is based on the dose
     equivalent Iodine 131 and whatever value that have in the
     tech specs there's associated leakage which they --
               CHAIRMAN POWERS:  Yes, I was asking do you know
     what the number is --
               MR. KARWOSKI:  For Farley?
               CHAIRMAN POWERS:  We are asking you a lot.
               MR. KARWOSKI:  I looked at all this and I have it
     written down in my office.  I don't have it here but I think
     it was -- I think the value was on the order of 11 GPM,
     something like that.  I would have to look it up.  There's a
     history associated with that.
               DR. KRESS:  Let me ask you about this --
               MR. KARWOSKI:  I can tell you this value is less
     than whatever was in the tech spec at that time.
               CHAIRMAN POWERS:  That is really what I wanted to
               DR. KRESS:  Let me ask you about these phantom
     particles -- I mean phantom cracks -- regarding the .6.
               Let's say I have this 14.9 voltage indication and
     I say all right, I am going to repair that one but I have
     got another one in there at .6 that I am going to carry to
     the next cycle and predict the voltage and the leakage.
               If I go to the next cycle, if I go in and make a
     bunch of measurements, now I don't see this 14.9 again
     because I prepared it and I really didn't have that phantom
     crack that I thought I did.  Do you now throw it away, the
     phantom crack?  Do you throw that away although --
               MR. KARWOSKI:  The growth rate in this may include
     remnants because when you do the growth distributions you
     have to take the most conservative of the two consecutive
     cycles, so there may be a part of that 14 volt indication
     hidden in the growth, because in this case you had like a 12
     volt --
               DR. KRESS:  So you don't carry these phantom
     cracks forever?
               MR. KARWOSKI:  No, they eventually will disappear.
               MR. HOPENFELD:  May I ask Dr. Powers a question?
               I think in a case of Farley I think originally
     they didn't have iodine spike in their tech specs and they
     didn't take it into account, and I think it was something
     like 60 and then it was pointed out to them that they had to
     take iodine spike into account they backed up to whatever it
     was, something like 20 or something -- I think 20 to 30,
               MR. KARWOSKI:  That specific tube -- this
     viewgraph which isn't in your handout also basically just
     summarizes the Farley and the Cycle 14 results.  Tube was
     pulled.  Predictions bounded the actuals except for Steam
     Generator C.  We discussed the two exceptions.
               This basically says that they were still within
     their limits for burst and leakage.
               The tube was pulled for destructive examination. 
     It grew from 1.4 volts to 13.7 volts so 12.3 volts changed
     during the cycle.  All the voltages used in the correlation
     are prepulled voltages.  When you pull these tubes if there
     is any cellular component it can open it up and change the
     voltage.  It can cause some damage to the crack.
               The post pull voltage was 28 and a half volts.  I
     just point that out just to show that there may have been
     some damage.
               This tube burst, slightly higher than 1.4 steam
     line break, which I believe would be expected based on the
     correlations.  This tube also leaked at three-quarters of a
     gallon per minute, and the other observation I would make --
     they put an in situ pressure test and tried to leak test
     this while the tube was still in the steam generator so the
     support plate is still there.  It's still packed with
     corrosion products.
               During that test there was no leakage but it did
     leak in the laboratory test at three-quarters --
               CHAIRMAN POWERS:  If we had done that leak test
     with a guy whanging on the support plate with a 16 pound
     sledgehammer, would it have still not leaked?
               MR. KARWOSKI:  I can't say.  All I can tell you is
     the way we assume it in the methodology is that it leaks at
     three-quarters a gallon per minute.
               CHAIRMAN POWERS:  But depending on crud and
     what-not to prevent it from leaking may not be applicable
     under a main steam line break.
               MR. KARWOSKI:  That's right, and our methodology
     assumes, and I might not have pointed this out, all these
     leak tests and burst tests take no credit for the support
     plate.  It assumes the degradation is entirely free-span.
               CHAIRMAN POWERS:  Okay, so this last line is just
     a point of interest?
               DR. KRESS:  As a point of interest.  It's a point
     of a lot of interest.
               When you take those tubes out, do you do anything
     to them like clean them before you leak test them or just
     take them over and leak test them?
               MR. KARWOSKI:  There is no cleaning --
               DR. KRESS:  No acid wash or anything like that?
               MR. KARWOSKI:  They take them from the field. 
     Whatever damage is done, you know, from the scraping through
     the other plates and through the tube sheet they take it and
     leak test it.
               DR. SIEBER:  Do they decon it at all?
               DR. KRESS:  That was really my question, decon.
               MR. KARWOSKI:  I don't know, to be honest.
               DR. KRESS:  Because that could be --
               Do you have any idea why this thing went from 1.4
     volts to 13.9 volts?  That's that cliff edge I was worried
               MR. KARWOSKI:  The tube was pulled, and they did
     destructive examination.  The tubes at the tube support
     plate intersections at most plants have intergranular stress
     corrosion cracking.
               DR. KRESS:  They did.
               MR. KARWOSKI:  When they did destructive
     examinations of this tube, they noticed two things:  They
     noticed some transgranular stress corrosion cracking, and
     they also looked at -- what they have said is that they have
     noticed some fatigue type degradation at some fatigue
               What they postulated is two things:  The
     transgranular stress corrosion cracking may have been
     contributed to by the presence of lead in the steam
     generator, which is a known mechanism.
               Two, they think that they had done some pressure
     pulse cleaning during the prior steam generator inspection,
     and that this tube was at the location of where that nozzle
     was, and so they believe that they may have propagated that. 
     That is what they have put in their reports.
               DR. BALLINGER:  This whole thing is predicated on
     the fact that you don't introduce an additional degradation
     mechanism into the system.
               And what you're saying is that this datapoint is
     exactly that.  It's a datapoint for which you don't have
     intergranular stress corrosion cracking and for which you --
     that's not the mechanisms we're dealing with here.
               This datapoint is basically useless.
               MR. KARWOSKI:  There was some transgranular
     components.  I didn't mean to imply that it was
     predominantly intergranular stress corrosion cracking with
     some -- I believe they said minor transgranular.
               I did not look at it in any more detail than that.
               The Generic Letter 95-05 approach has some
     advantages:  Basically, the licensees have to go in, do
     their inspections, make projections to the end of the next
     cycle, and then with those projections, you can go back and
     say, well, how well was my methodology performing by doing
     the -- when you do the next inspection.
               And that's basically what condition monitoring is. 
     It's basically monitoring and evaluating the as-found
     conditions in the steam generator, and comparing them to
     what you predicted that you would have during the -- from
     what you would have predicted from the prior cycle.
               In addition, you take your as-found and you
     determine whether or not you would have satisfied your burst
     and leakage criteria during that cycle.  And that's a
     backwards look to ensure that you had adequate tube
     integrity during the previous cycle.
               CHAIRMAN POWERS:  My understanding is that this
     condition monitoring and operational assessment is a program
     the licensees have committed to.  It's not required by the
     regulations, but they have just committed to it.
               MR. KARWOSKI:  They have committed to it, yes, and
     to the NEI 9706.
               MR. STROSNIDER:  But in terms of -- and maybe
     we're moving into the next assessment here, but -- or
               In terms of Generic Letter 95-05, it becomes part
     of their tech specs.
               MR. KARWOSKI:  Right.  The utilities, as part of
     95-05, have to submit certain information.  That information
     -- with that information, the staff can take a look at how
     well the methodology predicts.  It can determine what your
     -- the staff can do that condition monitoring analysis.
               The operational assessment is similar to all the
     projections.  Basically, you're taking a forward look and
     saying will I be able to maintain tube integrity during the
     course of the next inspection?
               And it required knowledge of NDE uncertainties,
     growth rate uncertainties, and the burst and leakage
               Before I talk about crack growth, I promised
     earlier that I'd talk a little bit about the three-volt
     alternate repair criteria.
               Once again, this slide is not in your package, but
     based on yesterday's discussion, I thought I'd clarify.
               The three-volt alternate repair criteria was
     implemented at one plant -- or at Byron I, one utility.  And
     it's a modification to the standard Generic Letter 95-05
     approach.  It's still a voltage-based approach, but it's
               What they did in this submittal is, they said we
     want to take credit for our support plates being there.  We
     want to say that that degradation doesn't get exposed.
               As a result, our probability of burst at that
     location for axial indications will be minimal.
               So what they did is, they went in and expanded
     selected tubes above and below the tube support plate, and
     essentially anchored the plate in place.
               There were some small deflections.  I think they
     were intending to limit the deflection to a tenth of an
               As a result, the probability of burst from an
     axial indication is minimal, however, these larger voltages,
     where you start to get concern then is axial tensile tearing
     of these indications.
               They developed another voltage correlation which
     indicated that you needed voltages on the order of, you
     know, ten to 20 volts.  I don't recall the numbers, but it
     would allow them to leave larger voltage indications in
               And the voltage limit basically is based on this
     axial tensile tearing correlation, and that's where the
     three-volt limit came from.
               This approach isn't identical to 95-05 in terms of
     the leakage assessment, because it introduces another
     concern.  If the tube can't burst, it may try to burst, but
     once it hits the edges of the support plate, it will stop,
     what they called indications restricted from burst or ERBS.
               And they had to develop another leakage
     correlation or another leakage database to say how much
     leakage can I get from these tubes that attempt to burst but
     don't fully open up?
               And so they had to modify their leakage analysis. 
     I didn't want to go into all the details of this
     methodology, but basically that's the three-volt criteria. 
     It's a different concern than the one and two volt
     amendments of Generic Letter 95-05.
               Byron and Braywood have subsequently replaced
     their steam generators.  No operating plants currently have
     it, although I believe there is an application inhouse for
     us to review this again.
               CHAIRMAN POWERS:  How long did Byron and Braywood,
     how many cycles did they operate with that criterion?
               MR. KARWOSKI:  This amendment was approved, I
     believe, in the '96 timeframe, so I'm going to say two
     cycles.  I'd have to look at it, but it's something like two
               CHAIRMAN POWERS:  Is the application that you have
     by another licensee to do that, is he also indicating that
     he will replace his steam generator in short order?
               MR. KARWOSKI:  I don't know in that case.  I know
     that there is a different methodology.  They're making
     different assumptions, and the staff will perform a detailed
               DR. KRESS:  There couldn't be a lot of database
     behind those correlations.
               MR. KARWOSKI:  With respect to the leakage
     database, they did an extensive test program as a result of
     proposing this criterion.
               DR. KRESS:  They did?
               MR. KARWOSKI:  So they did many tests with respect
     to how much leakage could I get, and they basically -- I'm
     not sure they took the bounding leak rate, but they took
     something near the bounding leak rate, and any tube that
     they predicted will burst, you know, but contact the plate,
     they would assign that limiting leakage to it.
               MR. STROSNIDER:  This is Jack Strosnider.  Ken, I
     think you're going to be going on to more general
     discussions now with regard to crack growth rate?
               MR. KARWOSKI:  Yes, I was going to touch on that.
               MR. STROSNIDER:  I just wanted to make that clear,
     again, that I think we completed the presentation on Generic
     Letter 95-05 and the voltage-based criteria.  And I just
     wanted to make a clear demarcation here before we move on to
     other issues, so they don't get confused.
               MR. KARWOSKI:  Okay.
               MR. HIGGINS:  Could I ask one final question on
     that to maybe wrap it up in my mind?
               Do you consider that these -- by applying this
     Generic Letter 95-05, and applying these alternate repair
     criteria, and then doing these special main steam line break
     analyses where you assume that the tubes will be rupturing,
     perhaps, or leaking, did you consider that for these plants
     to be an accident of a new type and a change to the design
     basis of the licensing basis for those plants?
               And, further, do you consider that you've
     addressed all of that by doing all these additional analyses
     and tech spec modifications, et cetera?
               MR. KARWOSKI:  I'm not an expert in that area, but
     I believe that our intent was to be consistent with the
     current licensing basis of the plant.
               MR. STROSNIDER:  These are processed as license
     amendments, changes to the technical specifications, and
     that becomes part of the licensing basis of the plant.
               It is a provision, but it is done on the licensing
     basis.  Does that answer your question?
               MR. HIGGINS:  Generally.
               MR. STROSNIDER:  I was just going to comment that
     I wrote down two things that we need to get back to the
     committee on:  One was some additional description with
     regard to the adjustment methodology used for taking the
     leakage data and adjusting it for pressure and temperature.
               And the other was, I think, a little more
     background on the ten to the minus fifth criteria that came
     from NUREG 0844.  So we'll get back to you with those two
               DR. CATTON:  Do we have somewhere, a figure that
     shows the measurements of leak rate as a function of
               MR. KARWOSKI:  That would be in the proprietary
     handout.  All the correlations of leak rate as a function of
     voltage are in there.
               This came out of a more detailed report which has
     much more details with respect to, you know, crack
     dimensions and whatnot, but this is an excerpt of the
     database, so it shows the actual data plotted.
               DR. KRESS:  Jack, it was five times ten to the
     minus two.
               MR. STROSNIDER:  Yes, you're right, 0844 was five
     times ten to the minus two, and we adjusted it to ten to the
     minus second, so we'll --
               DR. KRESS:  You said ten to the minus fifth.
               MR. STROSNIDER:  I'm sorry.
               DR. KRESS:  You confused me.
               MR. STROSNIDER:  Thank you for telling me.
               CHAIRMAN POWERS:  A modest difference.  Let me
     make sure I'm going to be able to derive everything I need
     to know about this log logistic curve for the rest of the
               DR. CATTON:  This looks a lot better than some.
               DR. KRESS:  If you have questions about that, you
     should ask them now.
               DR. CATTON:  I guess I just basically understand
     what the correlation is used for, and by the particular one
     that was selected.  I mean, it's an obscure one.  To say,
     that I don't know what a logistic is, is to overstate the
     case a little bit, but it's not the first one that comes to
               CHAIRMAN POWERS:  Just to help you before you go
     on, is this the data that you're talking about that has no
               MR. KARWOSKI:  That's the 3/4 inch.  There's a
     much stronger correlation.  There should have been another
     handout that you had.
               What I mentioned earlier, a tube either doesn't
     leak or it leaks and so what we have here is probability of
     leakage as a function of bobbin voltage.  If you were to
     look at the actual data, you would see tubes with certain
     voltages that didn't leak and tubes with certain voltages
     that did leak, and you have the actual data in the handout.
               The proposal made by the industry was to fit a log
     logistic curve through this data.
               There is no theoretical basis for the log
     logistic.  There could be other curves that fit through the
               As part of NUREG 1477 the Staff looked at some of
     these other correlations and what this plot has are some of
     these other correlations.
               The only thing I want to point out is you can see
     that for this function you will have a higher probability of
     leakage than these functions.
               These curves criss-cross each other also, so which
     curve will be conservative, which is a function of what the
     voltage distribution is to some extent because depending on
     what your distribution is you -- depending on which
     probability of leakage curve you use, you'll get a different
     answer, so as part of NUREG 1477 the Staff looked at various
     correlations and various distributions.
               I forget the exact numbers but if you have a
     distribution centered around one volt you may conclude that
     the COSHI is conservative with respect to the other models.
               If you go to a higher voltage at 1.5 volts based
     on some of these correlations criss-crossing you may
     conclude that another model is conservative like the log
     logistic or the log normal.
               What the Staff then did was say, well, which
     correlation should we use or which function should we use,
     and what the Staff concluded was given the other
     conservatisms in the model and the fact that each one of
     these functions had roughly the same degree of fit to the
     data that the log logistic was acceptable and that is why we
     used the log logistic.
               CHAIRMAN POWERS:  I think you may be too strong
     when you say there is no rationale for it, because log
     logistic is an extreme value distribution, so what you have
     got here is an on/off switch sort of phenomenon fitting in,
     and so I think there's more justification for it than maybe
     the normal distribution. 
               Now the question that comes to mind is that my
     recollection of the data -- I have to look again to remind
     me -- is if we take a value of, say, 4 volts, maybe 5, we
     will find tubes that had 5 volt indications that leaked with
     100 percent probability because they were tested.
               MR. KARWOSKI:  Right.
               CHAIRMAN POWERS:  Okay, and at 4 volts you would
     find tubes that didn't leak with 100 percent probability
     because they were tested, so now I am wondering why would I
     want to use a continuous high entropy distribution like this
     at all for this.
               Why wouldn't I just come through and say, okay, my
     minimum voltage at which I ever observed a leakage was 4.5
     volts, say --
               MR. KARWOSKI:  The industry would probably like to
     do that.
               Actually, I think they proposed that, below a
     certain voltage they didn't need to consider leakage, but
     that isn't necessarily conservative, so we fit a continuous
     distribution to it because you get into how much overlap of
     the data do you have -- do you have enough datapoints to
     sample the actual data?
               Although there are a lot of datapoints in this
     overlap region I don't think there's enough data.
               CHAIRMAN POWERS:  So what you really were trying
     to do is put a non-zero probability for leakage on those
     that did not observe leakage in that voltage range where
     your -- all your datapoints said there was no leakage.  You
     wanted to put a non-zero probability there.
               MR. KARWOSKI:  Correct.
               CHAIRMAN POWERS:  And you did that --
               MR. KARWOSKI:  This is an imperfect correlation.
               CHAIRMAN POWERS:  And you did that at the expense
     of putting a nonunity probability for -- in that voltage
     range where you had datapoints that said that it would leak?
               MR. KARWOSKI:  Right, but on the other hand this
     data overlaps.  I think if you look at the data, I would
     have to look, but there's points which don't leak at like
     maybe 8 volts and I am making these numbers up, and things
     that leak at 6 volts and vice versa so you are right.
               But given the other conservatisms in the
     methodology the Staff believed that that was an
     acceptable --
               CHAIRMAN POWERS:  Well, I may be preaching to the
     choir, but coming in and defending an action because there
     are other nonconservatisms all on top of nine conservatisms
     just emphasizes the fact that we end up not knowing what the
     conservatism of the whole is.
               DR. KRESS:  The log logistic has a cutoff at the
     upper end?  It goes to one at some value?
               CHAIRMAN POWERS:  Well, I think it goes near one.
               MR. KARWOSKI:  It goes near one.
               DR. KRESS:  That's why they call that the
               CHAIRMAN POWERS:  I think my recollection is --
               DR. KRESS:  I thought it went to a value that you
     had to stick in there.
               MR. KARWOSKI:  There are functions like that. 
     This one doesn't -- where you specify at what voltage you
     get a zero.  There are functions like that and the industry
     has used them in POD but they did not use that here.
               CHAIRMAN POWERS:  I mean I think my recollection
     of it, it's very hard to invert because that is given a
     probability of what is the value on the horizontal axis it
     is hard to invert because it goes up so tightly --
               DR. KRESS:  Essentially one.
               CHAIRMAN POWERS:  That is my recollection on the
     thing but I can't swear that it doesn't actually --
               DR. KRESS:  Does it really have that little
               MR. KARWOSKI:  It definitely does not have that.
               MR. STROSNIDER:  This is Jack Strosnider.  I
     wanted to make two comments.
               One is just with regard to Dr. Powers' discussion
     about putting a non-zero for these low voltages.  Part of
     the discussion that the task group had when we were
     developing 1477 was the likelihood that you could have a low
     voltage indication but that voltage might be coming from one
     crack as opposed to a network, and the possibility that
     there is an outlier, more or less, and I am not sure that
     this completely addresses that issue, but there was some
     discussion about should it ever really be zero, likelihood
     of that sort of thing.
               CHAIRMAN POWERS:  I mean the statement was there
     was no technical basis for it and in this discussion I found
     at least two.
               One is it's an extreme value, it's tradition, so
     it's appropriate for these things, and the rationale was
     putting on sort of probabilities for whatever reason down
               MR. STROSNIDER:  The second comment I wanted to
     make was come back, changing subjects on you here to the
     correlation issue again, and Ted Sullivan of the Staff just
     pointed out to me that there was actually more going on than
     just adding data to the database, that in fact the industry
     realized that they were not applying the P test correctly. 
     They were doing a two sided test and it should have been a
     one sided test and they did the one sided.  The correlation
     popped out.
               If you look at the original data you might
     conclude it was there all the time then.  I don't know, but
     there was a little more to the story than what I gave you
               MR. CATTON:  In looking at these figures, for the
     three-quarter inch tubes it looks like there is a pretty
     strong dependence on the voltage and it's rather weak for
     the seven-eighth inch.  Is there any explanation for that? 
     That's only an eighth of an inch difference.
               MR. KARWOSKI:  Right and they're scaled tubings
     with respect to the tube.
               I believe the industry would argue and I would
     have to go back and look because it's been awhile since I
     have looked at that database, the industry has proposed
     excluding certain datapoints based on various reasons, and
     they would argue that some of those leak rates are
               The Staff did not agree with all the exclusion
     criteria that the industry wanted to apply to the data.
               MR. CATTON:  Which, the seven-eighths?
               MR. KARWOSKI:  To both.  It actually applies to
     both but I think the outliers were more in the seven-eighths
     inch database, but I would have to look it up.
               MR. CATTON:  So when this process is exercised,
     the one that you explained, probability, voltage
     distribution and so forth, you then come to the break flows. 
     If it is a three-quarter inch tube they use this figure, the
     figure 6 that is in this document?  This one?
               MR. KARWOSKI:  They would use that.
               MR. CATTON:  And if it is seven-eighths they would
     use this other one?
               MR. KARWOSKI:  Correct.
               MR. CATTON:  Thank you.
               MR. STROSNIDER:  I think it's empirical.
               MR. CATTON:  I can't understand the difference
     really, but --
               MR. KARWOSKI:  There's also observed differences
     in the burst pressure with respect to the one and two volts.
               MR. CATTON:  One has a thicker wall.
               MR. KARWOSKI:  One has a thicker wall but the
     diameters are different so the ratios are essentially the
               MR. STROSNIDER:  Actually there were some
     theoretical analytic studies done back when this was being
     developed to try to understand that difference, R over T
     ratios, et cetera, and I don't think anybody could ever put
     their finger on it.
               I don't think we have a good answer.
               MR. CATTON:  Are there more generators for
     three-quarter than seven-eighths?
               MR. KARWOSKI:  Actually more -- with respect to
     the people who apply it, more are seven-eighths inch than
     three-quarter inch, the Sequoyahs, the Beaver Valleys, the
     Farleys, Diablo Canyon, Prairie Island -- they are all
               I think Watts Bar and South Texas are the only two
     that are right now three quarters.
               MR. CATTON:  Because you got some really low
     values, very high voltage, and those are built into all the
     averaging.  That's not comforting.
               MR. KARWOSKI:  As Jack pointed out, I would like
     to now talk about steam generators in general rather than
     Generic Letter 9505, although I will pull in portions of
     9505 in this discussion.
               With respect to tube repair criteria that have
     been approved, the two dominant ones are the 40 percent
     depth base limit, which was developed 25 years ago and you
     have the Generic Letter 9505, which is the voltage-based for
     ODSCC at the support plate.
               The crack growth assumption in the 40 percent tube
     repair criteria we kind of discussed this morning, but the
     growth rate assumption in there was that the NDE uncertainty
     in the growth rate was somewhere on the order of 20 percent
     and they assumed infinitely long degradation.
               The crack growth rate for the alternate tube
     repair criteria is either based on plant specific data if
     you have enough datapoints or bounding generic data if you
     do not have enough datapoints.
               One of the questions that cam up is why don't we
     use laboratory crack growth rate data.  While there's many
     factors that influence crack growth, there's operating
     parameters like temperature.  There's water chemistry, bulk
     versus crevice, how well do you know the type of crevice
     chemistry that you are having, the tube material affects
     crack growth.
               Many of these factors, and it is not intended to
     be all inclusive, but many of these factors are not only
     plant specific or steam generator.  They can be in some
     cases tube specific with respect to what is happening in the
               It is difficult to apply laboratory growth data to
     the field because the assumptions made in the laboratory are
     usually conservative to try to bound a variety of conditions
     and they may or may not be representative of what is
     happening in the steam generator.
               For that reason, you know, in Generic Letter
     95-05, it's a voltage-based approach.  There really is no,
     quote/unquote, crack growth; it's how much voltage
     progression do I have over the course of the cycle.
               This basically describes the methodology for
     determining the growth that I previously described this
     morning.  And there are two growth rate calculations that
     are performed:
               One for the deterministic determination of the
     structural repair limit of 5.5 volts, and that's basically
     an average growth rate.
               And then there's a growth rate distribution which
     is used in the Monte Carlo analysis for determining the
     conditional probability of burst.
               It's in this where if you do not have enough
     datapoints, that basically you'll use the bounding generic
     database, rather than a plant-specific.
               And based on the predictions of the end-of-cycle
     voltage distribution, in general, the growth rate -- I'm
     sorry.  In the predictions of the end-of-cycle voltage
     distribution, negative growth rates, as we discussed before,
     are treated as negative in the Generic Letter 95-05
               DR. BALLINGER:  Is treated as zero, right?
               MR. KARWOSKI:  Is treated as zero.
               DR. BALLINGER:  You said they were treated as
               MR. KARWOSKI:  Negative growth rates are treated
     as zero.
               So, the real question is, with these growth rate
     distributions -- and really the only growth rate
     distributions that the staff uses is for Generic Letter
               As I pointed out earlier, those predictions are
     usually pretty accurate.  I'm sorry, the predictions of the
     end-of-cycle voltage distributions tend to be conservative,
     as I pointed earlier, and licensees are required to evaluate
     their inspection results as a result of NEI 9706.
               DR. SIEBER:  If you were using the tech spec, the
     old time tech spec values for maximum flaw depth of 40
     percent through-wall, that has built into it, a ten-percent
     growth, roughly.
               MR. KARWOSKI:  Roughly.
               DR. SIEBER:  How do the actual flaw growth data
     compare to the ten percent, if it's built into the 40
     percent through-wall?
               MR. KARWOSKI:  There will be tubes that exceed it
     and tubes that are less than that.  In general, for the
     wastage and wall thinning, it would be plant-specific on
     what growth rates they observed.
               It's only until NEI 9706 that licensees now start
     doing those condition monitoring and operational assessments
     where they start doing more detailed assessments of what the
     conditions will be at the end of the cycle.
               DR. SIEBER:  Now, it would be interesting to know
     at some time, whether the original 40 percent through-wall
     was conservative or not.
               MR. KARWOSKI:  With respect to when you include
     NDE uncertainty and growth?
               DR. SIEBER:  That's right.
               DR. BALLINGER:  Well, when you look at it -- I've
     been thinking about that, and if you take a look at all of
     the steam generator tube ruptures that we've had, it's
     pretty much been independent of whether anybody has been
     applying the 40-percent criteria or not.
               DR. SIEBER:  That's right.
               MR. MURPHY:  Ken, if I might add one thing, this
     is Emmett Murphy.
               Condition monitoring programs have been conducted
     by licensees routinely now for several years.  In general,
     these condition monitoring programs are successful in
     demonstrating that all tubes have adequate margin at the end
     of the cycle.
               So, this early experience indicates that a
     situation where implementation of the 40-percent plugging
     limit, in general, that approach does ensure that adequate
     margins are maintained at end of cycle; not always, but in
     the vast majority of the cases.
               CHAIRMAN POWERS:  I think what you said is
     absolutely true, but it looks to me like it's close in some
     cases.  I mean, we're getting close to the ten to the minus
     two acceptance probability for burst in the Farley example.
               And it looks like in the projection of the 15th
     cycle, you know, they were close.  There's some of Tom's
     virtual character to that 15th cycle, I'll admit.
               I mean, I guess the issue is, is there -- are the
     acceptance limits set sufficiently high that getting close
     is not a source of concern?  And correct me if I'm wrong,
     Jack, but in the original discussion, that acceptance limit
     was really five times ten to the minus two?
               MR. STROSNIDER:  If you go back, again, talking
     about Generic Letter 95-05, and the original assumption in
     NUREG 0844 was five times ten to the minus second.
               And we reduced that by a factor of five to account
     for the fact that there could be more than one degradation
               The thing I'd ask you to think about, though, is
     putting the voltage-based criteria aside, criteria that are
     in the licensing basis that the plants need to meet are
     three-delta-P on normal operating pressure, and 1.4 on main
     steam line break.
               And what's being done now in terms of the
     condition monitoring is not only eddy current testing, but
     in situ pressure testing, all right?  And I think what
     Emmett was indicating is that in the majority of case where
     they look at what they think is the worst defect in the
     steam generator and they do this in situ testing, it
     satisfies those factors of safety.
               So, moving away from the voltage-based, there are
     other criteria that come into play.
                    CHAIRMAN POWERS:  I guess the nagging concern
     here is that there are a lot of point examples, and I don't
     have enough collection data together to get out of the --
     effect, you know, enough cases to persuade me that this
     isn't just a quick of nature, and that tomorrow we have one
     that's an egregious example.
               MR. STROSNIDER:  Well, I guess I can offer two --
     the only response that I think I can give is, one, we'll
     continue to collect data, all right, and hopefully collect
     more confidence in that regard until the generators are
     replaced and nobody's dealing with this one any more.
               CHAIRMAN POWERS:  The real answer.
               MR. STROSNIDER:  Yes, but I'd also come back to
     the point that I made earlier, that there is always the
     potential for some new form of degradation or for some
     change in degradation mechanism in terms of growth rates.
               I would point out that the industry has moved to
     more stringent controls, for example, in water chemistry. 
     There is more consistency there.  They are looking now in
     terms of corrective actions.  
               People, on occasion, will lower operating
     temperatures, so in that sense, things are being done that
     can be done to try to make things a little more predictable.
               However, you can always get to a point where you
     reach the incubation time for a new type of degradation and
     it shows up.
               CHAIRMAN POWERS:  We have the famous 13.7 or 14.6
     that seems to come about because of something unanticipated.
               MR. STROSNIDER:  Right, and if you look at the
     tube rupture list, you will see that there are a number on
     there that were caused by loose parts.
               Just a few other observations there:  One is that
     with regard to performance criteria -- and we weren't
     planning on getting into 9706 and the operational
     assessments and that sort of thing a whole lot, but we
     really did take a look at trying to establish performance
     criteria that left sufficient margins such that even if they
     were violated, it didn't represent the end of the world.
               Similarly, I think -- and as I indicated, we'll
     have to get back to you with some more detail on the 0844
     evaluation, but my recollection is that from a -- and let me
     characterize it as a risk-based point of view -- that you
     actually could have driven that conditional failure
     probability higher, an still come up with an overall
     acceptable risk, given the frequency argument.
               And, in fact, we had that discussion with the
     industry where they wanted to use a much higher acceptance
     criteria, and we felt that in terms of maintaining margins
     and defense-in-depth, that we needed a lower number.
               CHAIRMAN POWERS:  Have you given thought to the
     issues that accompany --
               MR. STROSNIDER:  I'm sorry, I can't hear you.
               CHAIRMAN POWERS:  Have you given thought to what
     happens as we go to higher levels of burnup or higher
     boration of the water or higher power, operating power
               MR. STROSNIDER:  With regard to power up-rates, a
     look at the steam generators is, in fact, part of our
               I'm not aware that any significant issues have
     come up with regard to those reviews.  I can't really go
     into a whole lot more detail than that.
               CHAIRMAN POWERS:  Does boration level cause any
               MR. STROSNIDER:  Not that I'm aware of.
               MR. HOLOHAN:  I think licensees, at least to date,
     have not been going to additional boration as a part of
     longer cycles of power uprates.  They're using burnable
     poisons, and that goes to the poison concentrations are
     controlled by things like moderator temperature
               Now, if we were to relax our limits on things like
     moderator temperature coefficients, then I think the
     chemistry might -- I think the industry would like to use
     more soluble boron and less burnable, but we haven't done
     that to date.
               MR. KARWOSKI:  When I first started off, I said
     there were three issues that I was going to talk about.  The
     first one was steam generator regulatory framework and
     operating experience, and I did that this morning.
               The second one was Generic Letter 95-05, its
     technical basis, and also included a discussion of growth
     rates, and I just completed that.
               The third topic was NDE capabilities with respect
     to detecting and sizing flaws, and that's what I'd like to
     discuss now.
               The primary means for inspecting the steam
     generators tubes is eddy current testing.  There are a
     variety of different probes that are used during the
     inspection of a steam generator tube, and I'm talking now in
     generic terms, not Generic Letter 95-05, specifically.
               The bobbin probe is the tool that's frequently
     used just for screening the tubes for defects.  It's
     relatively fast, can do 24 to 48 inches a second, but it's
     relatively insensitive to circumferential degradation.
               Okay, it's also poor at characterizing
     degradation.  As a result, there's an alternate probe that
     is used by licensees, and those are frequently referred to
     as rotating probes, rotating pancake coil probes.
               There are various types of coils that go on the
     probe.  It can be a pancake coil that is sensitive to axial
     and circumferential flaws; a plus-point coil which is
     sensitive to both also; and axially-wound coil that is only
     sensitive to circumferential flaws; and a
     circumferentially-wound coil that is sensitive to axial
               DR. CATTON:  Just a quick question:  Why is it
     that they chose the bobbin to do these leak rate
     correlations, when it's the worst measurement speed.
               MR. KARWOSKI:  It's 100-percent inspection.  It's
     sensitive to the axial type of degradation that occurs
               DR. CATTON:  But I thought that before they pulled
     the tube, they went in with the rotating probe to be sure
     that whatever they saw was right.  So don't they have the
               MR. KARWOSKI:  They would have the rotating probe
     data for the pulled tubes, because they --
               DR. CATTON:  Which is the database.
               MR. KARWOSKI:  Yes, but they don't do rotating
     probe inspections at every intersection in the steam
     generator.  And you need something -- as a result, you need
     something to correlate those intersections that have those
     bobbin indications to something, and you're not doing
     rotating inspections at every elevation.
               DR. CATTON:  But if you're trying to develop a
     correlation, and you've got such huge data scatter, why do
     you use the worst measurement for your correlation?
               MR. KARWOSKI:  I don't know if it's the worst.  I
     don't know how the correlation of both RPC voltages would be
     compared to like burst pressure or to leakage.
               DR. SIEBER:  Maybe I can answer that.  The bobbin
     coil probe moves at about two feet a second.
               DR. CATTON:  Oh, I see this up here.
               DR. SIEBER:  So it flies through the steam
     generator and you can examine two or three thousand tubes in
     seven days, eight days.
               A rotating pancake coil goes a half an inch to six
     inches a second, and it just takes forever, and so it's a
     matter of what can I use to keep my outage down to the
     minimum, still do the inspection, and get reliable data.
               DR. CATTON:  I understand this, but maybe I'm
     missing something in the process. You do the bobbin coil,
     and then where it looks like you might have a problem, you
     check it with the rotating probe before you pull the tube,
     or do you pull the tube?
               MR. KARWOSKI:  Okay, I have to answer this in two
     parts:  When licensees pull tubes, they will stick a variety
     of probes through there.  So, for the tube-pull database,
     yes, you would probably -- you probably have some data with
     respect to the rotating pancake coil voltage at specific
     locations on that -- along that crack.
               The bobbin coil integrates around the
     circumference, okay?
               DR. CATTON:  I understand.
               MR. KARWOSKI:  So for the pulled-tube database, I
     am sure that there is RPC data for the vast majority of the
     pulled-tube database.
               When you do the inspection, though, you don't
     RPC-evaluate every intersection.  As a result, you would
     have nothing to compare to your correlation.
               DR. CATTON:  You don't RPC?
               MR. KARWOSKI:  RPC, rotating pancake coil probe. 
     You don't do RPC probe inspections at every intersection.
               DR. CATTON:  You do it at the intersections that
     the bobbin coil told you might be a problem.
               MR. KARWOSKI:  Only if the voltage is above one
     volt for 3/4 inch tubes, and two volts for 7/8ths inch
     tubes, so you don't have that inspection data.
               DR. CATTON:  So above one volt and above two
     volts, you could check bobbin, RPC leak rate, and then you
     could generate a nice correlation.
               MR. STROSNIDER:  This is Jack Strosnider, and I
     want to point out one other thing here.  It's not clear in
     my mind that the RPC is going to be easier to correlate to.
               As Ken pointed out, the RPC is a much smaller
     probe, and it examines -- I mean, you get an actual profile
     around the tube, so you're going to have to say, you know,
     which part of that profile do I want to make the correlation
     with?  The peak?  The average, or something else.
               The bobbin probe is sort of an integral look at
     that intersection.  And so at first you'd have to decide
     that it may be possible that you could go through there and
     pick something off of there to correlate, but I wouldn't
     assume that I could necessarily get a better correlation.
               DR. CATTON:  But if you did -- but I might be able
     to explain why I got three decades variation in the data,
     because I would know more about what it is I'm looking at.
               CHAIRMAN POWERS:  You don't get a single number
     out of an RPC; you get a flattened out geography, 3D
               DR. CATTON:  That might help the mechanics guy
     figure out why the hell the thing is leaking.
               MR. STROSNIDER:  And as I mentioned earlier,
     though, if you go run leak tests, not on intergranular
     stress corrosion, not on this network, ODSEC type cracks,
     but on single stress corrosion cracks, you will get the same
     sort of distributions in variability in leakage.
               CHAIRMAN POWERS:  If you've got an absolutely
     perfect correlation with the RPC, you would still have to
     have your bobbin coil distribution.
               MR. KARWOSKI:  Or we would have to change the
     Generic Letter and require licensees to inspect with a
     rotating pancake coil at every support plate.
               CHAIRMAN POWERS:  Yes, you could do that, but
     given that you didn't do that, you'd still need a bobbin,
     and it would still look just like it does.
               MR. KARWOSKI:  Right, you would need something to
               CHAIRMAN POWERS:  They've got to account for all
     of the indications that they find in carrying out the
     process, not just those that are over some voltage limit, be
     it one volt or two volts.
               MR. KARWOSKI:  That's right.
               CHAIRMAN POWERS:  You have to invert those
     distributions in some way to end up with a predicted leakage
               MR. KARWOSKI:  That's right.  Another probe is
     used.  It is a Cecco probe.  It's a transmit, receive and a
     ray-type probe.  It is medium speed, around 12 inches per
     second.  It's sensitive to axial circumferential flaws.
               Some utilities choose to use the Cecco probe
     instead of the bobbin and rotating.  Other utilities feel
     more comfortable using the bobbin and rotating.  It is up to
     the utility.  The tech specs do not dictate what probes to
               The other thing that I put on this slide is that
     ultrasonic testing is also sometimes used to inspect steam
     generator tubes.
               Usually it's as a supplemental technique to help
     characterize degradation.
               CHAIRMAN POWERS:  Before you launch into that, I'd
     just raise a question that the former Commissioner Rogers
     raised on several occasions.
               Is there a growing technology in this area?  Are
     people trying other kinds of technologies to do better on
     these things?
               MR. KARWOSKI:  The technology is evolving.  A
     couple of the slides I have, there's different algorithms
               There's new probes that are coming out.  A lot of
     them are still based on eddy current technology but there
     are advances being made and you will hear about some of the
     work being done at one of our contractors.
               The probes used to inspect steam generator tubes
     have changed over time.  Originally in the 1970s they used
     the single frequency bobbin coil and I think somebody
     described it before where they had a oscilloscopes where
     they were analyzing the data.
               That was good for general wall loss type of
     degradation mechanisms, not so good for stress corrosion
               In the last late '70s and the '80s, multiple
     frequency bobbin coil techniques started to be developed
     along with rotating pancake coils probes.  In the early
     '70s there were no rotating probes.
               The multiple frequencies allowed mixing out some
     of the unwanted signals and it allowed you to focus at
     different parts of the tube while just pulling the probe
     through once rather than several times.
               The rotating pancake coil probe, as I said
     earlier, was better at detecting and characterizing stress
     corrosion cracking.  It is better in geometry changes.  It
     is sensitive to circumferential flaws.  It was initially
     used primarily at the expansion transitions.
               Widespread use of the rotating pancake coil probe
     began in the late '80s, early '90s.  People, licensees,
     really started to inspect their expansion transitions.
               The plus point coil, which you probably heard
     about, merged in the mid-1990s.  Its first major application
     was at Maine Yankee, where they had problems with
     circumferential cracking at the expansion transition and new
     probes and data analysis software and techniques continue to
     be developed.
               So what drove these improvements in technology? 
     Well, both economics and regulatory concerns.  If you
     remember from this morning I showed a plot of the forced
     outages as a result of leakage.  Back in the '70s and early
     '80s there was a number of outages.  Outages are costly.
               What caused those leakage outages?  Well, it can
     be a variety of factors.
               It could be the technique capability -- how good
     was that single frequency bobbin coil at really inspecting
     the tubes for the degradation mechanism of interest?
               Could have been analysts' reliability.  How well
     were those analysts trained on those techniques?  A lot of
     those techniques were evolving at the time.
               Could have been high growth rates.
               It could have been any combination of those three.
               In the mid-'80s the Office of Research had Pacific
     Northwest Laboratory analyze the removed steam generator
     from Surry.  They shipped the steam generator from Surry up
     to PNL -- Hanford? -- and they did a bunch of analysis. 
     They did leak testing, burst testing.  They developed
     various correlations.
               Under that contract they also determined some
     probability detections.  The dominant degradation mechanism
     or one of the prevalent was wastage.  However, as part of
     that program they did a mini-round robin of laboratory
     samples, not from the Surry steam generator -- laboratory
     grown samples, and determined the probability of detection.
               The probability of detection varied from team to
     team and I don't recall the exact ratios but some of them
     were pretty poor -- .3 probability of detection -- to
     larger, maybe .8 POD independent of depth.
               The average turned out to be about .6, and that is
     where we got the value for the generic letter 9505
     correlation, so we used a POD of .6 based on techniques
     available in the mid to late '80s and we applied it to the
     Generic letter 9505 approach.
               Much has happened since then.  In the '80s and
     early '90s the industry started developing ISI guidelines. 
     They needed to be able to detect this degradation sooner. 
     They didn't want to have forced outages.  They wanted more
     reliable inspections.
               These guidelines started to specify criteria for
     the probability of detection.  Some of the versions in the
     early '90s said we could have an 80 percent probability of
     detection at 90 percent confidence and there's various
     criteria with respect to what are the depth distributions of
     the degradation.
               The only thing I just wanted to point out is that
     the industry guidelines really started evolving in the late
     '80s and early '90s.
               They also developed a qualified data analysts
     program, a rigorous training program, with the analysis
     qualified to detect specific types of degradation.
               The other issue that was starting to emerge in the
     early '90s was generic versus plant specific qualification
     of techniques.  The role of plant specific factors in the
     detection of flaws became a concern.  Yes?
               DR. SIEBER:  About two hours ago you were talking
     about the NDE uncertainty distributions.
               MR. KARWOSKI:  Yes.
               DR. SIEBER:  And you said it was made up of two
     elements, analysts' variability -- that was about 10
     percent? -- and physical variability, which I presume
     includes systematic and random calibration errors, probe
     wear --
               MR. KARWOSKI:  It was predominantly probe wear.
               DR. SIEBER:  Okay, because other factors were in
               MR. KARWOSKI:  It was specifically probe wear. 
     They shaved a probe and analyzed what the change in voltage
     response was as a result of physically wearing down a probe.
               DR. SIEBER:  How did they accommodate things like
     calibration errors and random errors that occur just in the
     process of any kind of sampling technique?
               MR. KARWOSKI:  All of those types of errors will
     be captured and all of the correlations, because all those
     pulled tube datas will have all those different errors
     promulgated through it.
               DR. SIEBER:  How did they come up with the number
     for analysts' variability?
               MR. KARWOSKI:  Analyst variability was by having a
     group of analysts evaluate several different -- well,
     hundreds of different indications and determine what was the
     difference between the voltage calls between the
     different --
               DR. SIEBER:  Who is smart and who is not, right,
     essentially, so there is actually a basis for these
     distributions that go into that for every element of it?
               Do you have a list of all the elements, what the
     distribution looks like?
               MR. KARWOSKI:  For the two distributions, there
     are only two distributions --
               DR. SIEBER:  Only two.
               MR. KARWOSKI:  -- that the probe wear --
               DR. SIEBER:  And the analysts.
               MR. KARWOSKI:  -- and the analysts' variability,
     and we do have that data.  We can provide it to the
               DR. SIEBER:  If it is not too lengthy --
               MR. KARWOSKI:  No, it is actually --
               DR. SIEBER:  Two pages.  Thank you.
               DR. BONACA:  You said before that the POD, the
     licensees contend that the POD depended on the entity of the
     defect, that for a bigger signal you would have -- do you
     have any inputs on distributions from the licensees?
               MR. KARWOSKI:  Yes.  I will show you several of
               DR. BONACA:  Okay.
               MR. KARWOSKI:  In the mid to late '90s the
     industry and the NRC developed additional guidelines which
     addressed various factors like plant specific considerations
     and the concern of what is the probability of detection.  Is
     the technique capability or is it the entire system?
               There is currently an evaluation of steam
     generator mockup samples being performed by Argonne National
     Laboratory as a result of a contract with the NRC.  At the
     very end of this presentation I am going to ask Dr. Muscara
     to present some of that work and their results with respect
     to detecting and sizing flaws.
               There are a number of factors that affect
     detection of flaws.  There's equipment and technique
     variables.  There are -- the analyst plays a role in
     detection.  There's also plant specific considerations.
               With respect to the essential variables, there are
     equipment variables -- what equipment do I use to get the
     data, what type of acquisition system, what type of probe am
     I using, what type of cable, is there enough shielding in
     that cable to prevent noise signals from being picked up.
               There's technique variables.  What are the
     frequencies, the dry voltage calibration method, how much
     data am I obtaining, the digitizing rate, how do I scan the
     tube -- what is the direction, do I gather the data on the
     push or pull?
               There's analysis variables that also affect
     detection, including what the data review requirements are,
     the algorithms used in the software, and the calibration.
               Of course, analysts' reliability plays a role in
     detection and there is also plant specific considerations.
               There's the role of deposits.  Are those deposits
     conducting, nonconducting, ferromagnetic.  How do those
     deposits affect the signals?  Dents and geometry changes
     affect your ability to detect degradation.  Support
     structures.  Do I have other interfering signals that are
     coming in.  The crack orientation, is it axial,
     circumferential?  Is it on the ID or the OD of the tube? 
     Also there is noise.
               CHAIRMAN POWERS:  You have noise, electro: 
     tube -- is it tube noise?
               MR. KARWOSKI:  Tube noise is basically the surface
     of the tube is irregular.  Also tube noise can come from
     deposits.  They kind of overlap.  Noise comes from a variety
     of sources.
               Okay.  The industry qualifies specific probes,
     specific sized probes for specific degradation mechanisms
     under specific circumstances at specific locations, so when
     we say what techniques are qualified for detecting, it
     depends on what you are looking for and how you are looking
     for it.
               Each one of these techniques has a list of
     essential variables, so what does this mean?
               Basically a given size plus point coil is
     qualified to detect circumferential primary water stress
     corrosion cracking at a specific frequency in dented
     locations.  The industry has a dataset which they believe
     demonstrates that they have an 80 percent probability of
     detection at 90 percent confidence.
               The industry has lists of essential variables that
     go with each one of these techniques.  I need to keep this
     probe or I need to acquire the data in this fashion and the
     dataset that supports qualification has this much noise. 
     The industry has an extensive program with respect to the
     ability to detect degradation.
               There are a number of issues that have been raised
     with respect to what is the probability of detecting flaws
     under certain circumstances, and I have listed some of them
               One of them was axial versus circumferential
     cracks.  How does your ability to detect degradation depend
     on the orientation?
               Well, the best way I can answer it is it depends
     on the probe.  A bobbin probe will not reliably detect
     circumferential degradation.  Unless that circumferential
     crack has opened up a lot axially it won't seal.
               The bobbin probe also has weaknesses at detecting
     axial degradation under certain circumstances, namely in
     dents, severely dented tubes, U-bends, and expansion
               The pancake and plus point coil, on the other
     hand, are qualified for detecting those cracks which the
     bobbin coil would not be qualified for.  For example, axial
     degradation at those locations or circumferential --
               CHAIRMAN POWERS:  Initial screening done with a
     bobbin doesn't detect circumferential cracks reliably, that
     is what you are saying?
               MR. KARWOSKI:  Right.
               CHAIRMAN POWERS:  And are those, is the rationale
     then for using the bobbin coil for the initial examination
     then that circumferential cracks are sufficiently rare that
     missing them if of little consequence?
               MR. KARWOSKI:  Licensees in general do not
     normally just use the bobbin coil.  The industry is aware
     through numerous generic communications that the potential
     for circumferential cracking exists at various locations,
     namely at the expansion transition, at dents and U-bends,
     and in sleeves, and as a result consistent with Appendix B
     they use techniques that are qualified for detection.
               If you look at what licensees do, they would, in
     those locations they would do some type of sampling program
     to ensure that they are detecting the forms of degradations
     that those tubes are susceptible to.
               The Staff has issued generic communications
     highlighting the weaknesses.
               CHAIRMAN POWERS:  So I understand this better,
     talk about circumferential cracks in the free span area. 
     Are those sufficiently rare that you think there is no need
     to go around looking for that?
               MR. KARWOSKI:  There have been no circumferential
     cracks in the free span area.
               CHAIRMAN POWERS:  That's why I picked the example.
               MR. KARWOSKI:  The answer is yes.
               You would have to look at are there any stresses
     sufficient to induce that type of cracking in the free span,
     and in general the likelihood of that is very small and
     so -- and that supports operating experience where none have
     been identified either through leakage or through
               The bobbin coil I did say is relatively
     insensitive, unless those cracks open up.  If it were
     happening in the free span in a nondented area, you would
     have either, you know -- the cracks would eventually start
     growing and you would either detect it by bobbin or through
     leakage.  We haven't observed that today.
               The other issue is, how well can I detect with
     respect to isolated cracks versus cracks in clusters?  The
     comment that I make there is that, in general, the more
     material you use, the less ligament paths that you have, the
     easier it is to detect that type of degradation, but
     characterization of the flaw is much more difficult.
               DR. POWERS:  Is there a well recognized
     description of the width of cracks?
               MR. KARWOSKI:  Of the what?
               DR. POWERS:  Width of cracks.  I mean a very, very
     fine crack, different from one that is opened up a ways.
               MR. KARWOSKI:  I am not sure I understand what you
     are asking.
               DR. POWERS:  Well, it is this volume, missing
     volume.  The more missing volume, the easier it is to detect
     clusters.  What I am thinking is, suppose I have an isolated
     crack and have a crack that is really hairline wide and has
     lots of cross ligaments throughout its length, or I can have
     another isolated crack that actually has some canyon, open,
     it is a canyon, I can put something down into it.
               MR. KARWOSKI:  Right.
               DR. POWERS:  The two are very different, and I am
     wondering how you -- I am having a hard time describing
     these cracks.  Is there some measure or something like that
     that does a better job than I am on describing these two
     different types of cracks?
               MR. KARWOSKI:  In terms of NDE, no.  But you could
     describe what the crack opening area is, but in terms of
     NDE, you know, the only thing you would notice is that you
     get a much larger signal from an EDM notch than from a
     crack.  I mean the wide open one is what I am thinking of.
               DR. POWERS:  What I am thinking of is there are
     going to be some cracks, I mean I can imagine a crack,
     whether one actually ever existed, and which, across the
     length of it, there are ligaments and metal that are still
               MR. KARWOSKI:  Right.
               DR. POWERS:  That might be very different than one
     in which there were no ligaments.
               MR. KARWOSKI:  Absolutely.
               DR. CATTON:  And then if you fill those spaces
     with some kind of crystals of something or other, it would
     be completely different again.
               DR. POWERS:  Or if it was amorphous sludge, it
     would even be worse.
               MR. STROSNIDER:  This is Jack Strosnider.  That is
     certainly true, and that is just describing physics and the
     reality, what is out there.
               I guess what I think is really relevant here,
     though, and we have had a lot of discussions with the
     industry, and if you look at our Draft Reg. Guide 1.174 that
     was put out for public comment, when you talk about the
     qualification process, it is very important to use what you
     might characterize as prototypical cracks.  And you give a
     perfect example where the use of EDM notches may not give a
     good qualification demonstration.
               And the industry has made some progress in that
     area.  We continue to push on it because it is very
     important.  And some of what we are discussing in the 97-06
     framework is, you know, the need to use cracks that have
     signals that are representative of what is in the field,
     whether they be autoclave or pulled tubes.  There are some
     EDM notches used in the qualification database, but, you
     know, we push to minimize that.  And I don't know if that is
     part of what you were thinking about, but it is an important
     aspect of recognizing the difference.
               MR. KARWOSKI:  Some other issues they came up
     with, how is my ability to detect cracks that are plugged? 
     Once again, this issue depends on the nature of the
     deposits.  In general, deposits on the tubes are on the
     outside surface of the tube.  They are not -- these stress
     corrosion cracks tend to be very tight.
               But it would depend on the nature of the deposits. 
     If they are conducting, it is going to lower the eddy
     current response, making it more difficult to detect. 
     Ferromagnetic deposits, you know, will increase the
     response, but it will mask the flaw.  If the deposits are
     not conducting and no effect on tube noise, you probably
     have similar detection probability.
               The other thing is, what is my ability to detect
     cracks relative to location with respect to tube support
     plates or bends?  In general, the more geometry changes that
     you have, the harder it is to detect a flaw.  However, there
     are techniques that are qualified for giving locations in
     order to provide detectability.
               Operation speed was also -- how does that affect
     your ability to detect degradation?  Utilities have done
     various assessments of this.  The speed of the bobbin coil
     has gradually gone up as the ability of the hardware to
     process this data has gone up.  Typically, the run the line
     tests where they change the speed and determine whether or
     not they would have detected the same tubes, you know,
     regardless of the speed.
               What is interesting to note, at first you would
     think the higher the speed, the more difficult it is.  At
     one of the plants, they increased the speed, I believe the
     ratio was 12 to 24 inches per second, but what they found
     out, that increasing the speed actually reduced the noise
     that they were observing and the detection was comparable.
               That is not to say, though, well, let's go up to
     the next speed and it is going to be better.  There is a
     problem with too fast a speed and that is because if you
     have any geometry changes, which you do, in several
     locations in the steam generator, that probe can jump,
     resulting in noisy data, missed data and cause problems.  In
     addition, too fast a speed, because of the software that
     processes this data, you can have some frequency effects if
     you don't have proper compensating software.
               The next part of the presentation shows you
     probably detection curves for various degradation types. 
     These are all industry data.  The staff has issues with
     them.  I will point some of these issues out as we go along,
     but the committee indicated it wanted to know how we can do
     with respect to detection.  I am going to present some
     industry data.
               Let's start with wear, general wall loss type of
     thing.  In general, detection is pretty good.  What this has
     on this plot is the fraction detected as a result of the
     throughwall extent of wear indications, under, you know,
     given frequency indications.  At face value, and this is the
     industry data, from December '93, at face value, you might
     say, well, I can detect 100 percent of flaws affected by
     wear.  The staff isn't saying that, but that is what this
     data may tell you.
               And at the end of presenting all these probability
     of detection curves, I will go over some of the issues that
     we have with respect to this data.  But, in general, the
     staff expects that, you know, sizing or detection of general
     wall loss indications is pretty good.
               DR. POWERS:  What would it be at 99 C/L?
               MR. KARWOSKI:  What that is is what is the
     probability of detection at 90 percent confidence.  So even
     though you detected 100 percent, you know, you only had 13
     samples and there it is.  Remember, the acceptance criteria
     that I believe the industry is still using is 80 percent
     probability of detection and 90 percent confidence.
               Okay.  This next plot is for plus point coil
     detection in a sludge pile region.  Once again, in this case
     they fitted a curve to the data, you have probably a
     detection as a function of maximum depth.  You get into the
     same issues, why a logistic fit versus other fits. 
     Basically, what this says is we have got somewhat of a high
     probability of detecting larger flaws, a lower probability
     of detecting smaller flaws.  That is the sludge pile.
               This is also for sludge pile.  That first graph
     was maximum depth.  This one has several different curves as
     a result of maximum depth and average depth.  And as you
     might expect, the probability of detection for the maximum
     depth is less than the average depth, and that is because
     you have a larger flaw when your average depth is greater
     than just the peak.  But, in general, for the average depth,
     the probability of detection is larger.
               The dots indicate the bobbin coil probability of
     detection.  This data, once again, industry data, indicates
     that the probability of detection with the bobbin coil is
     better than the plus point for these low voltage
     indications.  To what extent that is an artifact of the
     distributions they chose, I don't know.  I am just
     presenting what they submitted.
               This next graph is for --
               DR. SIEBER:  A question.
               MR. KARWOSKI:  Yes.
               DR. SIEBER:  The plus point has a whole bunch of
     different coils, some of which look like bobbin coils and
     some of which are rotating.
               MR. KARWOSKI:  The plus point coil is a specific
     coil that will fit on a rotating probe.
               DR. SIEBER:  Okay.
               MR. KARWOSKI:  The plus point coil has an axial
     coil and a circumferential coil.
               DR. SIEBER:  Okay.  But you can --
               MR. KARWOSKI:  Okay.  Wound together.
               DR. SIEBER:  -- mathematically play with it.
               MR. KARWOSKI:  Right.  And one of the advantages,
     or the advantage of the plus point coil, theoretically, is
     that you have some general disturbance area, those two
     coils, the signal from those two coils will cancel out. 
     That can also be a disadvantage of the crack if a crack is
     perfectly, you know, symmetric and hits both coils at the
     same time.  But that is not -- that is theoretical general,
     those types of flaws don't exist.
               Here is a plot from December '93 of probability of
     detection for outside diameter stress corrosion cracking at
     the support plates.  Staff used a value of .6 for the
     Generic Letter 95-05 methodology.  What the industry
     presented in December '93 is basically for everything over
     40 percent throughwall, we were detecting.  The issues had
     issues with respect to that, and that is why we used the .6. 
     But here is what the industry presented back in December
               PWSCC occurs at dented tube support plate
     elevations.  Here is a plot of the fraction detected versus
     maximum depth.  What I will point out on here is this has
     the fraction detected for the plus point coil, the bobbin
     and the Cecco.
               Just to point out some of the issues that you have
     with limited data sets, you would conclude here that your
     probability of detection may be higher in the 0 to 10
     percent range than in the 10 to 20.  That is an artifact of
     the amount of data and shows some of the difficulties that
     the staff has with respect to when somebody says, what is
     the probability of detection?  It all depends on the data
     that supports the correlations.
               The other thing to note is, you know, why would
     you have a lower probability of detection at the higher
     depths?  And, generally, you would think the deeper the
     degradation, you are better your probability of detection. 
     But, nonetheless, this basically shows, you know, reaching
     towards 100 percent when the maximum depth hits around 50
     percent for PWSCC at dents inspected with the plus point. 
     Once again, this is all industry data.
               Here is another example for PWSCC at dented tube
     support plate intersections.  Some of the data comes from
     that previous graph.  I put this up because it compares the
     bobbin and plus point, and this is a result of fitting a
     specific function recommended by the industry through the
     data.  And what I wanted to point out here is here a
     function, the bobbin POD is a function of depth, here is the
     plus point, the two cross.  In general, that is probably a
     result of either the curve fit or the limited amount of
     data, or the fact that, you know, you missed one indication
     with the plus point and it results in a worse probability of
               In general, the industry and the staff believe
     that the plus point is probably better than the bobbin in
     that area.
               So how does the staff use the probability of
     detection?  Usually, probability of detection is only used
     in Generic Letter 95-05 tube repair criteria.  And in that
     analysis, as I pointed out this morning, that we used .6,
     and that is based on the roundrobin analysis of the
     laboratory stress corrosion cracking samples that was done
     in the late '80s.
               As I pointed out this morning, that is used not
     only to account for missed indications, but also indications
     that may initiate during the course of a cycle.
               And here I have a rhetorical question, is .6 the
     correct value?  I have showed you various data the industry
     would argue for deeper flaws were better than .6, and there
     may be some more data forthcoming from some of the Argonne
     roundrobin tests that may support that, I don't know, but I
     will say that the .6 is conservative and accounts for other
     things than just missed indications, and that is based on
     the operational assessments.
               MR. HIGGINS:  Do you know the breakup, breakdown
     between missed and the ones that would initiate during the
     cycle?  And have you looked at end of cycle, beginning of
     cycle test results for the last few years on 95-05 to see if
     that number of those that initiate during the cycle is
     reasonable with the actual data?
               MR. KARWOSKI:  The staff has looked at the 90 day
     reports, and the industry has, with respect to, you know,
     did I detect something in the prior cycle?  The industry has
     actually proposed an alternative way for POD where they look
     -- and I don't recall this methodology in detail, the staff
     hasn't approved it, but, basically, they do look back and
     say, was there a signal there?  And in some cases they
     missed it, in which case that would be a missed indication. 
     In some cases, they would say, well, analysis wouldn't have
     called that, so that would be a new indication.
               I don't know if anybody has ever done a
     comprehensive assessment of, you know, how many indications
     are new versus how many indications were missed.  I know the
     industry has proposed an alternate probability of detection
     model based somewhat on that type of approach, but, to date,
     the staff hasn't accepted that.
               MR. STROSNIDER:  I would just add to that, it
     might be difficult to separate the two, although, perhaps
     with a hindsight review, when you detect something in this
     outage, if you go back to the prior outage with some
     knowledge, maybe you could say that it was there.  But I
     think the important think is you asked, is it being
     benchmarked, and the sort of histograms, if you will, of
     voltage versus number, you know, that is one of the reasons
     we look at that, and one of the reasons we concluded that
     the .6 does a reasonably good job of accounting for those
     that are missed in inspection and new indications.
               If we saw that those distributions were radically
     different, one thing you could modify is that .6 factor and
     try to bring them back into alignment.
               MR. LONG:  This is Steve Long.  Let me add one
     thing.  By the time these things get to me it is usually
     because they are doing some sort of risk-informed license
     amendment request, so I guess I probably see the problem
     ones more than anything else.
               We had a problem with Arkansas Unit 2 this past
     spring and their proposal to not perform another mid-cycle
     inspection where they would have to take two inspections in
     the middle of a fuel cycle.  And we had a problem with
     reconciling what they were projecting as the flaw
     distribution of the tubes during the remainder of the fuel
     cycle with what they had found in the last inspection and
     what they had projected to find in the last inspection.
               And it comes down to a question of a combination
     of the growth rate and the POD in the previous inspection,
     is your growth rate right or your POD right?
               Arkansas was insisting that the things that they
     missed in their inspection before last, they could find when
     they did a lookback they were missed, and that their growth
     rates were consistent once they found those things in the
     lookback, that the growth from what they probably should
     have seen in the inspection before was what they would
     expect up from the last inspection.
               So we asked them, then what does that say about
     your POD?  And I believe the POD was about .4, which was one
     of the reasons we couldn't probably work with that, because
     some of the larger flaws that we thought they would need to
     be able to detect, there would need to be performance --
     screening criteria.  They really didn't have a very good
     probability of detecting those in the inspection before
     last, and we couldn't credit any change in the inspection
     process for improving that over the last inspection.
               So there are problems occasionally.
               DR. HOPENFELD:  This subject was discussed
     yesterday and I pointed out that there is a possibility of
     differences between running a test in a laboratory POD,
     determination in a laboratory or at PNNL, versus in real
     life, and I think this is a very good example, except that
     this is only one.
               And one of the questions that we didn't get to
     discuss yesterday, this pertained to this very item, that we
     need more information from plants to determine what that POD
     is.  Keeping this in perspective, I don't think it is proper
     to say that what we are using is a conservative number.  We
     don't really know it is conservative.
               DR. POWERS:  Let me ask how much longer you have
     to go on this presentation?
               MR. KARWOSKI:  A half hour.
               DR. POWERS:  Why don't we take a 15 minute break
     now.  We will recess until five of the hour.
               DR. POWERS:  Let's go back in session.  Pardon me
     for interrupting you yet again, but I firmly ascribe to the
     belief that the mind will ultimately absorb what the body
     can endure.
               MR. KARWOSKI:  I am aware of that.
               DR. CATTON:  You know where the limits are, so you
     are going to push them.
               SPEAKER:  You say we are staying until what,
               DR. POWERS:  There is nothing sacred about 10:00.
               MR. KARWOSKI:  In the interest of time, I will try
     to finish these last few slides.  The last thing I wanted to
     say about POD is there is a lot of issues.  Some of those
     curves showed it.  We don't have 100 percent probability of
     detection.  It does, you know, 5 percent degradation for
     some of those mechanisms.
               Some of these concerns have already been raised. 
     Lab data versus field data.  Is the field data -- or is the
     lab data representative of the signals in the field?  If
     not, is it appropriate to use it.
               DR. CATTON:  When you say lab data, is that a lab
     created defect as well, or is it just a lab measurement of a
     pulled tube?
               MR. KARWOSKI:  It is like a model boiler specimen,
     a laboratory created defect, like a stress corrosion crack
     developed in a model boiler.  Is the signal that I get from
     that representative of the signal that I would have observed
     in the field at that location?
               DR. POWERS:  Ken, you didn't discuss -- one of the
     documents that we got, and I cannot remember which one,
     spoke of a rather elaborate set of measurements on a steam
     generator that had been removed from service at Surry, and
     in which there was quite a lot of effort to address the
     issues of probability of detection and whatnot.  You didn't
     bring that data up.  Is there any particular reason why?
               MR. KARWOSKI:  The only thing, the Surry steam
     generator, and Dr. Muscara can correct me if I am wrong, the
     dominant degradation mechanism there is wastage and pitting,
     and as a result, a lot of that was probability of detection
     curves.  Although they may be appropriate, it is not the
     degradation mechanism of interest.
               As part of the program, they did do that stress --
     laboratory grown stress corrosion cracking mini-roundrobin,
     and that is where the .6 came from.  With that said, towards
     the end of this presentation, I am going to have Dr. Muscara
     present the results of another roundrobin that is going on
     now.  Results should be available at the end of this year,
     sometime next year, and he will describe that program, which
     is probably more relevant to inspection capabilities today.
               The other thing is -- another POD issue is the
     overall system versus technique capability.  When you
     analyze some of these tubes, it is part of the qualification
     program.  Assume they are all field data that you are
     getting.  These tubes are analyzed by a lot of people under
     controlled conditions and get a much more detailed
     evaluation than necessarily a production inspection where
     the analyst is asked to look at thousands of tubes, you
     know, in an outage.
               So the question is, what are these curves really
     measuring?  Are they measuring what the technique is capable
     of doing, or is it measuring the overall system, how the
     analyst is going to perform under actual field conditions?
               The other POD issue is, how pertinent is this
     probability of detection curve to the plant that I am
     applying it to?  There are plant-specific circumstances that
     may affect detection.  Do I have copper deposits?  Are my
     deposits uniform such that I may be able to mix them out? 
     Are they spotty, causing problems in detection?  Do I have a
     lot of denting, a lot of noise from a variety of sources? 
     That is another issue with respect to POD.
               The other is, how do I evaluate this data, and
     what curves do I fit through it?  Is it a function of
     average depth, maximum depth?  Do I use the log logistic or
     what type of curve do I use to fit the data?
               The other issue that I have put up is false calls. 
     When you do these inspections, when you pull a tube and you
     look at it, you may tend to over call with respect to some
     of these indications and say there is something there, but
     then it is not there.  Does that count against you in the
     probability of detection calculation?  Well, maybe it should
     if you are not using the exact same criteria in both
     applications.  Those are just some of the issues that we
     have with respect to the POD curves.
               The first part of the presentation, detection. 
     Can techniques detect degradation?  The next part is sizing,
     and I am going to go through this relatively quick and just
     provide some examples.  There is a lot of examples in your
               The first thing I would like to point out is a
     technique may be qualified for detecting a form of
     degradation but may not be qualified for sizing it.  And
     that is why I have the bullet -- Utilities routinely use the
     bobbin coil for detection and other probes such as like a
     rotating plus point probe for characterizing it.  And sizing
     can be in terms of length, depth, voltage.  It depends on
     what type of correlation you have for your structural
     leakage integrity.
               What is considered qualified with respect to
     sizing?  In the past the industry has used the root mean
     square error approach.  There is limitations to that. 
     Probably a more appealing approach might be just
     understanding the uncertainties in your technique and then
     applying those uncertainties in your condition monitoring
     and operational assessment.
               With respect to what is considered qualified,
     generally, the bobbin coil is considered qualified for
     sizing wall loss type of indications.  The bobbin coil is,
     quote-unquote, qualified for sizing via voltage for the
     Generic Letter 95-05 methodology.  And the NRC has approved
     the use of the plus point coil for depth sizing degradation
     at dented tube support plates, primarily axial PWSCC.
               There is several pages in your handout with
     respect to sizing curves, how well techniques do with
     sizing.  Once again, this is industry submitted information. 
     There are some issues with respect to this.  I will just put
     a couple of them up.  If you have any questions, I will be
     glad to answer them.
               Here is a plot of the estimated throughwall depth
     versus the true -- or throughwall depth as a result of
     metallography.  This is for wear indications and, in
     general, you have a pretty good -- you can estimate the
     depth of these indications pretty well, and that is
     generally accepted throughout the industry.
               And there is various other correlations.  I don't
     want to spend too much time on them given that we are
     already behind schedule.  But this is for sizing sludge pile
     ODSCC, destructive exam maximum depth versus NDE depth, and
     you can see that there is a lot of scatter in the data.  And
     there is various -- in your handout, there is various
     correlations with respect to how well different techniques
     can size specific degradation mechanisms in terms of length
     and depth.
               The burst characteristics of a tube depend,
     basically, not just on, you know, a single parameter of
     length or depth, but more a function of a composite of the
     crack and there may be a limiting form -- a limiting portion
     of that crack.
               This plot here is a plot of a circumferential
     crack located at an expansion transition which was pulled. 
     The metallography, this tube was pulled in the '95-'96 time. 
     The metallography is shown here.  This was a deep
     circumferential crack with some ligaments in between, two
     deep portions of the crack, I guess it is wrapping around,
     but there is a ligament there.  That is the destructive exam
     results.  If you look at what the NDE analysts called this,
     they significantly undersized portions of this crack.
               DR. POWERS:  Maybe clarify what the vertical axis
               MR. KARWOSKI:  The percent through the wall.
               DR. POWERS:  Throughwall, yeah.
               MR. KARWOSKI:  So this is the crack profile. 
     Basically, it is 100 percent through the wall, in this
     region there was a ligament, it went back to nearly 100
     percent and then there was -- and this using an 080 pancake
     coil, and that is just sizing of indications,
     circumferential ODSCC at the expansion transition in '95-'96
               I just point that out to show --
               DR. CATTON:  This doesn't say anything about the
     cross-sectional area.
               MR. KARWOSKI:  Cross-sectional area.
               DR. CATTON:  Well, I mean what is the flow area
     through a crack like this?
               MR. KARWOSKI:  No, it doesn't say anything. 
     Typically, the eddy current data --
               DR. CATTON:  You just take a slice?
               MR. KARWOSKI:  Well, they look at the various
     ligaments and they develop, you know, somewhat of a
     composite type of crack.  But, you are right, it is a slice.
               There is a couple of more plots of that same tube
     with different types of probes.  But just to show you a
     little difference, one of the qualified techniques, or a
     technique where we approved an alternate repair criteria,
     here is a tube that was sized with a plus point coil for
     primary water stress corrosion cracking at dents.  That is
     not listed on here, but that is the type of degradation.
               And, in general, you see the destructive
     examinations and the solid symbols, and you have the
     analysts.  Much better agreement with respect to both the
     length and the depth of the degradation.  And there are
     several examples of this type of degradation in the handout.
               DR. POWERS:  And you said this was primary water
     stress corrosion cracking?
               MR. KARWOSKI:  Primary water stress corrosion
     cracking at dented tube support plate elevations.
               There are many factors that affect the ability to
     size, and a lot of them are similar to those with respect to
     detection.  What technique, what type of coil, the location
     of the degradation, frequency.  What are the interfering
     signals?  Noise.
               Plant-specific considerations play a role. 
     Typically, the qualification, though, is done generically. 
     Licensees, however, need to assess whether or not that
     technique is applicable, whether or not they can use that
     generic qualification at their plants.
               One of the things that some of the tube pulls
     programs that have been done revealed is that, although you
     can't necessarily determine the quantitative size of the
     degradation, the general severity can be inferred from the
     eddy current results.  And what this allows licensees to do
     is, although they -- was that me?
               DR. POWERS:  Your battery is probably going out.
               MR. KARWOSKI:  What this allows licensees to do is
     to select some of the more limiting tubes for in situ
     pressure testing to determine whether or not the tubes meet
     the required structural and leakage integrity requirements.
               There are a number of questions with respect to
     the factors affecting the ability to size as a function of
     different parameters.  Crack orientation.  Basically,
     circumferential cracks are located in locations where there
     is geometry changes that typically will make it more
     difficult to size.  Isolated cracks versus crack in
     clusters.  The problem there is the eddy current coil has
     such a width that it may not be able to discern some of the
     individual cracks in a cluster of cracks.
               With respect to plugged cracks or cracks occluded
     with crud, once again, it depends on the nature of the
     deposits and crack location relative to support plates.  The
     more interfering signals that you have, the more difficult
     it is to size.
               DR. POWERS:  Well, you have indicated a couple of
     times that the plugging material affects it depending on its
     particular nature, whether it is ferromagnetic conductive
     or, I guess, if it is insulating sludge, it is just like air
     getting in there.  What do you typically have?  Or is there
     a typical?
               MR. KARWOSKI:  With respect to inside the crack,
     it tends to be very tight and there is not really a lot of
     deposits inside the crack.  Most of the deposits are around
     the outside of the tube.  Okay.  Those deposits, if they are
     uniform, you know, if they are non-conducting, they may
     contribute noise which will make it more difficult to
               If they are conducting and they are uniform, you
     probably have a better capability to detect the flaw that if
     the deposits are conducting and they are not uniform,
     because then you are going to get a lot of individual
     signals where you won't be able to discern what is noise
     from what is a defect.
               Does that answer the question?
               DR. POWERS:  Well, I guess the one I am interested
     in is the cracks are tight, there is very little material
     within the crack, but surely there must be some material in
     there.  I am sure there is oxide coating on things.
               MR. KARWOSKI:  Right.
               DR. POWERS:  If indeed these are oxides or
     spinels, they can't be -- at least any ferromagnetic.
               MR. KARWOSKI:  Right.  And so these deposits will
     interfere, but, in general, I have shown you some of the
     data that the industry have presented.  In general, that
     will come out in whatever sizing curves that they develop. 
     So it will affect it, the magnitude.
               DR. POWERS:  Well, I guess what you are telling me
     is, whereas, in principle, the cracks can be affected by the
     crud that is in them, or around them, in fact, it is either
     accounted for in the empirical determinations or it is just
     not a very big affect.
               MR. KARWOSKI:  That's correct, that would be my
               I have presented basically industry data with
     respect to detection and sizing.  The Office of Research has
     a program at Argonne National Lab which is also looking at
     the ability to detect and size flaws.  So at this point I
     would like to turn it over to Dr. Muscara, who is going to
     discuss some of the work being done at Argonne.
               DR. POWERS:  I have some experience with the work
     Argonne and we won't hold that against you.
               DR. BONACA:  Just I have a question I would like
     to ask you before.  Regarding the information distributed
     this morning.
               MR. KARWOSKI:  Yes.
               DR. BONACA:  For those correlations.  Is it all
     field data or is it also laboratory data?
               MR. KARWOSKI:  It consists of both field and
     laboratory data.
               DR. BONACA:  I looked for information on
     separation of the two, I couldn't -- maybe I have to look
               MR. KARWOSKI:  Some of the plots may discern
     laboratory from field.  I don't know if those do.  But if
     not, we can provide you the raw data that shows you which
     ones are model boiler specimens and which are field.
               DR. BONACA:  A little understanding of --
               MR. KARWOSKI:  The relative counter.
               DR. BONACA:  -- how preponderant one group or the
     other is over the other.
               MR. KARWOSKI:  Right.  There is a lot more field
     data now than there was in '95, but we can provide that to
               DR. BONACA:  Okay.
               DR. CATTON:  Joe, what is a model boiler?
               MR. KARWOSKI:  When I said a model boiler, it is
     just -- how should I?  It is a means of creating laboratory
     cracks, where you basically subject a tube to accelerated
     corrosion tests, or accelerated corrosion, so that you can
     develop a flaw in a subsequent test.
               DR. CATTON:  Boiler, okay.  And what are added
               MR. KARWOSKI:  Added tubes.  Oh, with respect to
     those correlations.
               DR. CATTON:  Yes.
               MR. KARWOSKI:  The industry updates the database
     from year to year, so the added on that means we have added
     new data from the previous one.  So what they are doing is
     assessing the changes with respect to adding the new data,
     that is what those curves are referring to.
               DR. CATTON:  Okay.
               DR. MUSCARA:  Thank you, Ken.
               I am not sure whether I should stick with my
     viewgraphs.  I mean I have heard a lot of things that I
     would like to respond to, but I know we probably won't get
     into that.  But before I do get to the viewgraphs, there are
     a couple of points.
               I was really shocked yesterday to hear that in
     NUREG/CR-2336, we had data on the probability of detection
     that the tube support plate location, I think it was set at
     the tube intersection, but tube support plate location.  I
     was surprised mainly because I had planned that work and
     managed it for many years, and we did no such thing.  There
     was no work done that evaluated POD at the support plate.
               And Dr. Powers was correct, we did a lot of work
     on the Surry program to quantify the capability of inservice
     inspection for the Surry generator.  In general, we had, as
     was mentioned earlier, mostly wastage and pitting, and we
     did a thorough job of evaluating that type of degradation.
               We had a number of industry teams inspecting the
     generators, the same way that they inspected field
     generators, and we got some valid data.
               Well, this work was done essentially -- well, the
     entire Surry work was done in the time period between 1982
     and 1986.  We did have lots of cracking in the Surry
     generator at the support plate location due to the gross
     denting that was going in this generator.  But at that time
     inspectors refused to give us information about support
     plate, they knew they could not inspect in that condition.
               The denting we are talking about in those days was
     much, much more gross than what we are seeing today.  So we
     had no attempt at evaluating probability of detection of
     cracks to support plate.
               MR. BALLINGER:  I have got four PNNL reports, one
     of which does contain some stuff on POD, on a little test, a
     roundrobin looking test where they did it.
               DR. MUSCARA:  Yes.  Yes.
               MR. BALLINGER:  And that was -- it was in a report
     related to the Surry generator.
               DR. MUSCARA:  Yes.  Yes.  It was done during that
     time period.  This is what I was getting to.  But as far as
     evaluating POD at the support plate, that wasn't done. 
     Because what did we do?  In that time area, we were, of
     course, beginning to experience cracks, stress corrosion
     cracks, let's say the modern day stress corrosion cracks,
     where we have families of small cracks with ligaments, not
     the planar stress corrosion cracks that we experienced early
     on in the life of these generators.
               So we decided that we needed to do something to
     provide some data on stress corrosion cracking besides
     having the very thorough work done on the wastage and
     pitting.  And so we did run a small roundrobin.  Now, this
     roundrobin contained 17 samples.  There was one sample at 85
     percent throughwall stress corrosion crack, one sample was
     throughwall.  Twelve of the 17 samples had cracks above 40
     percent, but many were between 40 and 50, the rest were
     below 40 percent.  So it was not a great deal of work.
               We did include in the sample set, samples that had
     copper-coating, because we know that this complicates the
     inspection.  And in four of the 17 we had support plate
     simulation with the specimen.  Again, the intent wasn't to
     really evaluate POD at the support plate location, the idea
     was to get an idea of how teams at that time might be
     performing on stress corrosion cracks.
               So the numbers that were given for POD at the
     support plate location, yes, they were somewhere between .27
     and .5.  A little bit about what kinds of teams looked at
     this, at this information.  We clearly had sent a small
     mockup to a number of inspection agencies and they used
     their field teams.  We also asked them to look with their
     most advanced techniques and their researchers, not
     necessarily just the fuel technicians.
               We had looked at the bobbin coil on these samples. 
     Pancake probes were beginning to get developed in those days
     and beginning to be getting used, so we also had pancake
     coil inspections.  And there was one probe that was under
     development which never really got into the commercial
     arena, and this was called, in our report, we called it an
     alternate bobbin call.  This was what was called a segmented
     coil.  The idea here was to segment the coil so that you
     might get some information about the location of the flaw.
               As you know, the bobbin coil, the encircling coil
     essential integrates around the circumference of the tube,
     so it gives you some information about the flaw, but not
     necessarily the location of the flaw.
               As a matter of fact, we do have some probes here
     that we could send around.  Thank you, Bill.
               This is a typical bobbin coil, you see the
     encircling coil there.  And this probe head has three coils
     on it, there is a plus point and two pancake coils.  The two
     pancake coils are different sizes.  The larger size gives
     you more sensitivities, a larger signal, but less
     resolution, so they have the combination of these two,
     depending on whether you are interested in resolution or
               I guess I might mention, we talked about the
     bobbin coil, and, you know, everything is bad about the
     bobbin coil, it doesn't detect circumferential cracks. 
     Well, there are some things that are good about the bobbin
     coil.  Of course, one was already mentioned, it is the
     speed.  But if you are looking at a small level signal,
     let's say, from an actual stress corrosion crack, the bobbin
     coil actually gives you a larger signal than these pancake
     probes, which these are small coils.
               They don't have the resolution.  Of course, if you
     are trying to evaluate the size of the flaw, if you are
     trying to map the shape and size of the flaw, you are better
     off with these pancake probes.  But from a point of view of
     detection, especially for small signals, the bobbin probe is
     a better probe.  So in a voltage based criterion, where we
     are looking at accepting flaws that are less than two volts,
     it makes sense to use a bobbin coil.  You know, we do get
     more sensitivity to those kinds of flaws.
               Again, before I get to the viewgraphs, there are
     several things we could say about POD and how people do
     these POD tests.  Just a couple of points in general, we
     have had the experience of doing roundrobin inspections for
     many different components, not just steam generator tubes,
     but also piping invessel.  So we have done a lot of work on
     evaluating the POD of different techniques, say,
     ultrasonics, eddy current for the different inspections. 
     And we also have been involved in the work not only in the
     States, but international work.
               And when you talk about the reliability of
     inspection of POD, it is made up of at least two components. 
     We like to talk about reliability of inspection in terms of
     the NDE system capability, and the system is really made up
     of the equipment, the procedure and the personnel, and each
     taken together give us some idea of the reliability of the
     inspection process.
               So a lot of the work that we do in evaluating POD,
     of course, is laboratory work, so, in a sense, you know,
     people know they are under test conditions, so you get more
     or less an upper bound of what you might expect for a field
     inspection.  Very often we do not have enough samples in
     sets of samples.  If you are trying to evaluate POD, a high
     POD at a high confidence level, you need hundreds of flaws,
     not what we do in qualification where we are looking at a
     handful of flaws.
               We often use notches, which, again, are not
     realistic when one is trying to do POD data.
               In our work that we have done, where the work has
     been robust, we are really trying to determine reliability
     of inspection, we find that you never get to 100 percent POD
     when you use the system, the person, the procedure, the
               Now, we can break this down into capability. 
     Depending on the physics, the equipment can have the
     capability to detect 100 of the flaws it is supposed to
     detect.  But then we put this into the hands of an inspector
     and the human reliability comes into play, and we do not get
     100 percent POD.  Regardless of what some of the data shows
     us when you look at three, four, five, ten flaws, detect all
     of them, therefore POD is 100 percent.  That just is not the
     case when you use hundreds of flaws and inspection teams
     outside of the laboratory, more on a situation like a Surry
               I have seen information on POD, for example, where
     information is shown as POD going up to 100 percent at about
     the 50 percent level of degradation.  But when you question
     how this information was obtained, the number of specimens
     is somewhere around 30 or 40.  The mean size in the sample
     set was 27 percent throughout wall depth, the maximum depth
     was around 36.  Yet they show us a curve of POD, you know,
     at 50 percent throughout flaw, POD is 100 percent and it
     stays 100 percent from thereon out.
               Well, in questioning about how this was developed,
     we used the logistic curve fit.  So, you know, the data set
     is down -- 27 percent is the mean depth of the flaw, one
     flaw at 36 percent, and with logistic fit, we wind up having
     100 percent POD.
               DR. POWERS:  How do you use a POD when you are
     talking about a production process?  Suppose I have got a
     run through a particular tube and that tube has -- in some
     way we know absolutely that the tube has five indications in
     it that are, let's say, 50 percent throughwall, okay.  Now,
     and I have a probability of detection at 50 percent
     throughwall of, say, 80 percent with a 90 percent confidence
     level.  And I ask what is the probability that my analyst
     will find all five of them?
               Is it 80 percent times 80 percent -- 80 percent to
     the fifth power or something like that, or is it another
               DR. MUSCARA:  I guess, like Ken said before, I
     have to defer this to our statistician.  But we have done
     the statistics and determined the number of flaws that you
     need to evaluate POD at different levels.  And the way we
     have set up some our roundrobins are based on this.  When we
     report our POD data, they have a confidence level that is
     statistically based.
               I Ken was showing some of his viewgraphs, 13 out
     of 13 giving 100 percent POD, but then we apply the number
     of samples that were use.  The 90 percent confidence on that
     was really 80 percent.
               DR. POWERS:  What I am driving at is -- I think it
     is just what you have been saying.  If you give me a small
     set of samples to do, and a relaxed period of time to do it
     in, then essentially I am doing each indication alone, it is
     a separate experiment and I get a particularly probability.
               But now when I am running this detector through
     the tube in one big operation, now the question is not
     individual cracks but what is the probability I will detect
     all five of the indications that are known to be there?  And
     is each one of them an independent event, or do I get a set?
               DR. MUSCARA:  Yeah.  In fact, in order for the
     statistics to work, it has to be an independent event.  And
     when we evaluate our roundrobin data, we essentially divide
     up the test section into what we call grading sample,
     grading units.  And there are certain requirements for the
     flaws.  For example, in order for the numbers to be
     independent, the signal from one flaw cannot be interfering
     with the signal from the other flaw.  So there are a number
     of rules that are set up to separate these so that when we
     do run the statistics, we get the correct answer, that each
     measurement is essentially independent.
               DR. POWERS:  But are they independent when I am in
     a production run?  I guess that is the question.
               MR. STROSNIDER:  This is Jack Strosnider.  Just if
     I could interject just for a second, Joe, I guess.  The way
     this actually happens in the field is typically there is two
     reviewers, and they are working independently.  And then
     depending upon whether they agree on their calls, it goes to
     a third reviewer for disposition.
               And we have had a number of discussions with the
     industry, and I am not sure how consistently this is being
     done now, but one of our concerns, first of all, you have
     the question, you have got two analysts looking at the same
     signal.  Can you that their probability of detecting the
     flaw is truly independent?  Now, you can make that
     assumption, but, in fact, there may be noise or something in
     the signal that makes it difficult for both of them.  There
     is probably some dependency there, but hard to quantify.
               The other issue that has come up in some of the
     reviews we have done is after they go through their
     comparison, they give it to this third fellow who is usually
     a more senior level analyst, and he makes the decision.  So
     it comes down to, you know, what he is deciding.
               So, I don't know, and staff can fill me in, that
     there has been any real methodical study where we can tell
     you what the probability of missing an indication is even
     with a qualified method.  There is some finite probability. 
     It is, you know, it is not a foolproof process, that is for
               And without going into a lot of detail, I would
     just say, when you recognize that, you have to recognize
     that inspection is just one layer in defense-in-depth that
     is applied to managing steam generator tube integrity.  You
     have leakage rate limits.  You have the fact that it is a
     design basis accident.  You have your operating procedures,
     and so on.
               So, we recognize that inspection is not, you know,
     not 100 percent reliable.
               DR. POWERS:  Well, I guess I am just worried about
     the theoretical issue of whether, in a production run,
     looking at just one tube, it is a set of independent
     indications or it is a collection.  And how you do the --
     how I divide the probability of detection, I think the way
     you are applying it is all independent isolated events.
               MR. STROSNIDER:  Yeah.  Well, let me give you one
     other thing there just to add some perspective on this.  It
     might require some more discussion later.  But we talked
     about the voltage based criteria, and you heard some of the
     discussion about how the probability of detection, et
     cetera, is applied there.  Ken mentioned one other plant
     that has an alternate repair criteria for primary water
     stress corrosion cracking at the tube support plates.  And
     they -- and I guess maybe I am jumping a little bit ahead,
     because it is not just POD, but it is sizing.  And those are
     the two alternate repair criteria, we pretty much rely on
               Most of the operational assessments that are done,
     all right, there is not a whole lot of calculating and the
     kind of stuff that we have been talking about, it is
     basically, do the condition monitoring at the end of the
     cycle, which relies to a large extent on the in situ
     testing.  And if you show that you meet the margins when you
     do that, the assumption pretty much is that your probability
     of detection and growth rate is such that things remaining
     the same, without any, you know, significant changes, you
     ought to be able to operate the same length of time again.
               Like I said, there is always the possibility that
     new things show up in between.  But I think people have the
     perception that, you know, that every review and every
     operational assessment that is done, that people are going
     in and using all these numbers and stuff, and that is not
     really the case.
               But it does come up, it came up in the Indian
     Point review.  It came up in the Arkansas review, it came up
     in Farley.  We will talk a little bit about those tomorrow.
               So I don't know if that is helpful, but that maybe
     provides a little perspective on how it is actually applied.
               DR. POWERS:  Well, certainly, it provided a
     perspective on the overall problem, the challenge that Joe
               MR. STROSNIDER:  And just to follow up on that, as
     we move more toward these risk-informed and start doing more
     risk-informed amendments, there will be more reliable on
     this.  You know, part of what we are trying to get across,
     working with the industry to get, is reliable data that can
     be used in those type of analyses.  And there is certainly
     room for improvement at this point.
               DR. BONACA:  I would like to ask one more question
     on this issue.  When they ran the bobbin coil and they get
     these five signals in a tube, first, that will have to the
     one of deciding what kind of indications these may be.  For
     example, they are not all going to be one type of defect. 
     There is going to be different types of defects.  So I
     imagine that they have some techniques by which they control
     these defects in different bins.
               And I imagine that, for example, correlating one
     defect with the position of the plates, and so on and so
     forth, will help the selection, but, you know, it is not
     clear to me how this complicates the process.  I think we
     had an overhead that showed that there was some
     consideration of the process as one complicating factor. 
     But I imagine it is a complicating factor.
               MR. STROSNIDER:  I guess you are saying you are
     trying to understand exactly what the type of degradation is
     that you are dealing with.
               DR. BONACA:  Yeah.  Because I mean all we have
     talked about in these past two days is one type of defect,
     and characterizing it, and we have seen a distribution of
     that versus voltage.  But, really, this is the process by
     which they are identifying all the defects.
               MR. STROSNIDER:  You can get some information from
     the eddy current, but, as we said, you know, it is not -- it
     has limitations in its ability to characterize a defect. 
     You also, you know, based on operating experience, and as
     you suggest, the location of the defect, draw some
     inferences from that.
               When people find some new things, or some things
     that are unusual, two pulls are the way to get some solid
     information, but there is a challenge here.
               One other thing I would add, too, which may not
     have come across in all the discussions we have had so far,
     is that, aside from these alternate repair criteria that we
     talked about, which are relatively few, the industry
     practice it to plug on detection.  So when they find a
     defect, a stress corrosion crack in particular, they are
     going to plug that.
               Now, thinning and that sort of thing where they
     have some qualified and reliable sizing method, that is not
     true, but for IGSCC, basically, plug on detection.
               DR. MUSCARA:  There are codes that the industry
     uses for characterizing flaws, but, generally, they are
     based on past experience.  A lot of it is based on location. 
     But, generally, you can discriminate between large volume
     defects and small volume defects.  We can discriminate
     between cracks and wastage or pitting.  And then within the
     crack regime, we can discriminate the circs from the axials.
               So there is some capability even with the
     detection probes.  And then, of course, if you are doing
     more careful work with some of these rotating probes, you
     have additional capability for characterizing the flaws.
               DR. BONACA:  Yeah.  I just was wondering, for
     example, if the fact that you are going through and picking
     up a lot of signals could confuse this detection ability.
               DR. MUSCARA:  Right.  With the detection, the
     problem is if the signals are close together, then it could
     confuse it and you could mess up the statistics.  In the
     tests, of course, we do make sure that we have independent
               In the field, if you are finding different kinds
     of flaws very close by, that confuses the issue.  But,
     generally, I don't think that is the case.  We find a
     cluster of flaws at the support plate, we know the type of
     flaw they are, they are in a certain zone.  The next flaw
     you would find maybe at the next support plate.  So they are
     not really -- one is not really affecting the other.
               I guess just to finish up what I had started on
     the NUREG-2336, the loan numbers were developed when we were
     using this, you know, I mentioned there was an experimental
     probe, a segmented bobbin coil, so that is where the 27
     percent came from.  That has never been used in the field.
               I guess also I should mention that in that test,
     we were using single frequency eddy current at the time.  So
     when you look at the data from the normal bobbin coil and
     the pancake coils, the average POD was, as was stated
     earlier, was .63, I think we are using .6.  I think the
     maximum we found in that small roundrobin was about .75.
               But one of our main objectives, let me just
     mention it, the Surry work was I think very useful, we had
     very valid data.  That was part of an international program. 
     The Surry part of the work cost $17 million, and the flaw
     types of a different nature these days, we need to do
     similar kind of work, but we can't afford to spend another
     $17 million to get these POD curves.
               So what we are trying to do is set up a mockup and
     an inspection process that mimics what goes on in the field. 
     And so we are trying to set up this mockup so that it has
     the kinds of conditions one runs into in the field, so that
     the flaws are typical of what is in the field, and so that
     the inspection process is also conducted according to the
     qualified procedures and so on.  And I will get into some of
     this work.
               Unfortunately, I will not be presenting a lot of
     new results right now.  We will have information by the end
     of this calendar year.  We are in the midst of conducting
     the roundrobin.  We are trying to keep this a blind test. 
     There are some other teams that we need to bring on board,
     so we cannot release a lot of the information, but I can
     give you some trends.
               We also mentioned earlier some advanced
     techniques.  I wasn't planning on talking about the work we
     are doing on advanced techniques, but we are doing research
     both in characterizing the reliability of current inspection
     methods, most of this is with the mockup and the roundrobin
     testing, but we are also doing work on advanced eddy current
     techniques, in particular, data analysis procedures bring
     some of this in, and that we are also using this for
     characterizing the mockup.
               And I have probably mentioned already what is in
     the first viewgraph.  The purpose, again, is to evaluate the
     reliability of current day inspection, both with respect to
     probability of detection and sizing accuracy, and we will be
     using a mockup.
               I guess while I am going through the viewgraphs, I
     also mentioned a couple of items.  When we talk about
     qualified techniques, you know, that is very soothing.  When
     we talk about something being qualified, we think it must be
     good.  I think we need to pay particular attention to what
     we mean about qualified techniques with respect to what is
     being qualified for inservice inspections.
               When we talk about qualified detection techniques,
     the technique can be qualified if it passes a particular
     test.  There are a certain number of samples that are
     involved.  Normally, there are not a great deal, a number of
     samples.  But the passing criteria is that you need to get
     80 percent of the flaws at 90 percent confidence level for
     flaws that are 60 percent deep and deeper.  So if we are
     talking about a 40 percent plugging criterion, do I always
     know what the probability of detecting a 40 percent flaw is
     when the qualification is at 60?
               In the sizing arena, when we started doing
     qualification on sizing, the criteria had been 25 percent
     root mean square error.  We are no longer using that.  So
     what is implied in a qualified sizing technique is that the
     process has gone through the system, a test has been
     conducted, but there is no passing criteria.  But they do
     record how the person and the system performed.  So a
     qualified technique would be something that gives you a
     sizing accuracy of plus or minus 50 percent.  If it has gone
     through the system, it is qualified.
               So we need to understand that the qualified
     doesn't necessarily mean it is very good, but at least we
     know how it performs.  And then that information, of course,
     is used in the operational assessments, and that is the
     important point.  But we shouldn't be left with the idea
     that a qualified sizing technique may be a very accurate
               Just a very brief description of the mockup, we
     have essentially 400 tube openings.  Each tube is made up of
     nine test sections, so there are nine individual one foot
     sections.  They may have a flaw, they may not have a flaw. 
     But there is the option of having 3,600 test sections in
     this mockup.  At the top of the mockup there is a three foot
     run out section, and that is there so that -- well, the
     probe doesn't fall out of the tubes when we do inspection,
     but more importantly than that, we want to make sure that
     when the probe hits the first sample, that the probe is up
     to speed, so it has a constant speed throughout the
               I mentioned they were trying to make this mockup
     realistic.  We have literally hundreds of flaws.  Again,
     since it is a blind test, I don't want to mention how many
     hundreds, but it is several hundreds of flaws.  The types of
     flaws we have are mostly stress corrosion cracks from the
     ID, axial, circumferential.  We have some IGA.  There are a
     few EDM notches and a few fatigue cracks.
               We also try to reproduce conditions in this
     generator, so that besides the straight sections of tubes,
     we have tubes that are rolled into tube sheets.  We have the
     same roll transition in these tubes as we have in operating
     plants.  There are dents in the tubes.  We have sludge
     piles, we have magnetite.  So that we have tried to
     reproduce the conditions that are important that affect an
     inservice inspection signal.
               MR. BALLINGER:  No U-bends?
               DR. MUSCARA:  No U-bends, correct.
               DR. CATTON:  22.2 millimeter diameter is 7/8ths of
     an inch?
               DR. MUSCARA:  That is three-quarters, right next
     to it.  So, yes, the other items that we do have an actual
     carbon steel support plate, we have three simulations of
     these in this mockup.  So that is the same size as a support
     plate out in the field.
               As I mentioned, we are trying to mimic the
     inspection process that goes on out in the field, and we
     know a lot about that inspection process.  Our researchers
     at Argonne know something about that.  But we really wanted
     to make sure we were doing this right, so we put together an
     NDE task group.  And the idea here was that we wanted to
     have some input that actually do these inspections, people
     that develop the inspection plans.
               So we put together this task group and the members
     were from Argonne, from NRC, from EPRI, from FDI, which was
     the old Babcock & Wilcox, ABBCE, from Zetech, which is a
     major inspection company, provides inspection services and
     also equipment, Westinghouse, Northern States Power,
     Commonwealth Edison and Duke Power.  We met a number of
     times to discuss this test.  But the main input we had from
     the members was that we wanted to know if the signals that
     we had from the cracks in this mockup are typical of what
     they see out in the field, because we wanted to make sure
     that the cracks are prototypic both from the point of view
     of the morphology, from a metallurgical point of view, and
     also from the eddy current signal point of view.
               And so we have compared these cracks to signals
     that you get out in the field, and they are typical.  We
     also compared them to the metallography of stress corrosion
     cracks that we get from pulled tubes and they are quite
     typical.  Of course, stress corrosion cracks, if you have
     seen one, you have seen they are all, but there are minor
     variations, and we cover the range of the stress corrosion
     cracks that you do notice in the field.
               Now, we do have in the mockup cracks that come in
     clusters.  We have single cracks, but many of them are
     today's type of crack where we have small cracks with
     ligaments in between, and these are distributed around the
     circumference in one more than crack and also axially along
     the tube.
               DR. POWERS:  How did you make these cracks?
               DR. MUSCARA:  Well, these cracks were made in the
     laboratory.  When we started out, we were using autoclaves,
     high temperature caustic solution.  That got to be too
     time-consuming and too expensive, so we have been working
     for a number of years, one or two years, to just develop
     methods for coming up with these cracks.  We essentially
     heat treat the tube so it is sensitive to cracking and we
     conduct the cracking at room temperature in one more
     solution of sodium tetrathionate.
               DR. POWERS:  Tetrathionate.
               DR. MUSCARA:  And we can get cracking with this in
     time periods of the order of a day to three or four days.
               Now, all these cracks are very well characterized. 
     I mean we know where the flaws are because we are
     introducing them.  But they undergo a battery of tests where
     we used advanced NDE techniques, whether it is ultrasonics,
     mostly eddy current, die penetrant.  We do a lot of work to
     characterize these cracks before we accept them for the
               Again, we want to make sure that they are
     realistic and sometimes we aim at certain kinds of cracks. 
     We can produce fairly closely what we need, but it is a
     random process.  So, you know, sometimes we reject some of
     the cracks, they may be too wide open for us.
               Well, in addition to assuring that the cracks are
     typical and the conditions are typical, we also wanted to
     make sure that the roundrobin is conducted in a manner
     similar to inspection conducted in the field.  So we
     effectively treated the generator -- in the field, of
     course, there is an owner of the generator, and the owner is
     responsible for what goes on with this generator.  The owner
     is responsible for coming up with the inspection program. 
     So we assigned Argonne National Laboratory the ownership of
     the generator, so they act as the owner, and they are
     responsible for developing the inspection program.
               Now, when developing the inspection program, a
     number of things are taken into account.  For example, the
     owner is responsible for doing a defect analysis, and so
     they are required to sit down, determine for their plant the
     kinds of degradation they have experienced in the past, and
     determine for sister plants what kind of degradation they
     are experiencing.  And then they are required to make sure
     that the techniques used for inspection match the kinds of
     degradation that they are experiencing.
               So, they are supposed to be using qualified
     people, but, in addition, the personnel needs to be
     qualified at the plant site.  So they need to take a
     plant-specific examination, both a written examination and
     an examination, an actual examination of inspecting data
     from their plant from the past where they know what the
     situation of the flaws are.
               So a lot of information was gathered, a lot of
     documentation was written, very similar to what is conducted
     in the field.  And our task group was very helpful in
     providing us with a lot of this information.  So we had a
     lot of information, for example, on inspection plans that
     are used at actual plants, and so we mimicked our process
     along that information for the mockup.
               For an actual inspection, there is usually at the
     utility is a Level 3 inspector who is responsible for
     approving the inspection program.  And, similarly, for this
     mockup, for our roundrobin, we had the task group had the
     responsibility to review all the information and approve it,
     that the techniques we are using match the requirements and
     that they are appropriate for the kinds of degradation that
     we have in the mockup.
               So, what I really wanted to stress is that when
     you do see our information, come December or January, that
     you do have the feeling about how the work was done.  This
     is not just a laboratory test.  You know, clearly, I can
     mention laboratory tests and roundrobin that we have done in
     the past, some international work where they use all
     notches, 100 specimens, 95 which were notches, five were
     cracks, and they tried to develop UOD curves from that.
               This work is laboratory, but it is a mockup and it
     is trying to reproduce the conditions of the field, and
     inspections are conducted in a manner similar to what is
     being conducted in the field.
               After assembling the mockup and doing a lot of
     work on our own to characterize the nature of these flaws,
     we started the actual roundrobin in February of this year. 
     We are dealing here really with an analysis roundrobin.  In
     the past, if you know the work from Surry, we have done both
     what we call data acquisition and analysis roundrobin, and
     we also conducted analyses roundrobin.
               What we found is that the data acquisition,
     regardless of who performs the data acquisition, you get the
     same result.  It is the same procedures used, the same
     equipment, and the flaw is the same flaw, so that we found
     very little variability in having many teams gathering the
     data, the data was the same.  So that we decided here that
     we needed a run, an actually roundrobin, this is where the
     variability in POD comes from, not from gathering of the
               So we had a qualified team from Zetech gather the
     data.  There was some oversight of the team, there was a
     proctor present making sure that the data was gathered
     according to the procedure.  But then this data was given to
     a number of independent commercial teams to do the analysis,
     provide us the information about what they have detected,
     and we also required information on sizing.
               At this point I believe we have five teams that
     have done the analysis roundrobin.  We have incorporated
     most of the major inspection agencies that conduct
     inspections in this country.  One clear exception at this
     point is Westinghouse has not been able to participate yet.
               I should mention that the program I am talking
     about is an international program.  The participants in this
     program are Westinghouse, EPRI, Canada -- there is one more,
               So Westinghouse is very willing and has several
     times scheduled to do the analysis roundrobin. 
     Unfortunately, they have been pulled away on other
     activities.  The last one they were scheduled to do the
     analysis roundrobin for us in May and, unfortunately for us,
     they got pulled away with Indian Point 2.  They are now
     scheduled I believe for November, and, hopefully, in
     November they will do the roundrobin, and we can include
     them with the set of information we already have.
               Let me describe a little bit the teams.  In
     effect, as I mentioned before, we conduct it the same way as
     the inspections are conducted in the field.  So the
     inspectors have been tested, they are qualified inspectors. 
     They have been qualified through the EPRI NDE Center.  We
     use a five person analysis team, and this is what is going
     on today.
               I also must mention that this technology is
     evolving and it is improving fairly rapidly.  Jack mentioned
     we have two inspectors.  In fact, when we planned the
     roundrobin, there were three inspectors involved in the
     team, now there are five.  The description of the five
     member team is that there are two analysts, we call them
     primary and secondary, but, again, you know, they do the
     same function.  A secondary team doesn't mean it is less
     qualified or the result is less important.
               There are two independent teams that do the
     analysis.  In the past, if these two teams did not agree,
     then a resolution analyst, who is a Level 3 rather than a
     Level 2, will do the first -- the primary and secondary can
     be Level 3.  They are normally Level 2 and Level 3, but the
     resolution analyst is usually a Level 3, and he decides what
     the true call is if the primary and secondary can't agree. 
     That was the past.
               Now, we are using five teams.  So we have two
     initial inspectors doing the analysis, primary and
     secondary.  There are two resolution analysts, and they have
     to come to a consensus on the call.  And there is a fifth
     member of the team which is called the independent QDA or
     the independent qualified data analyst.  And this fifth
     member is usually a member of the utility rather than the
     inspection agency, not always, but usually.
               So the makeup of our analysis team is made up of
     these five inspectors.  The true independent who looked at
     the data, if there is something to be resolved, the
     resolution analysts look at the data.  And then finally, the
     independent QDA has an opportunity to look at the data and
     provide a final answer.
               We have mentioned there are not too many sizing
     techniques that are qualified, there may be one or two.  But
     we are requiring these teams to provide us with sizing
     information, at least to give us the maximum size of the
     degradation, and that is a sizing technique that is based on
     the face angle of the indication.  If you have to do sizing,
     this is a typical method for sizing flaws.  And it is very
     similar, what we are requiring for the max size is very
     similar to one of the qualified techniques for sizing.
               I must mention also that, in addition, we plan on
     getting a subset of this data to a number of commercial
     teams to provide us with sizing information, not just the
     maximum size, but we will ask them to do the entire mapping
     of the flaw.  This is not something that is required or is
     qualified, but we are trying to get some idea about the
     sizing accuracy also in this work.
               In order to be able to grade or to evaluate a
     roundrobin, we must know what the true state of the mockup
     is, so we must know what the actual size, and type, and
     location of the flaw is.  Well, as far as location, we know
     that.  The most difficult part is to try and determine what
     size these flaws are.
               We want to be able to use this mockup in the
     future for evaluating emerging technology.  It is very
     time-consuming and expensive to produce these tubes that
     have realistic flaws.  I guess, just to mention the mockup
     itself, putting it together, making some of the flaws cost
     over a million dollars.  So these tubes are very valuable
     and we do not want to destroy them all.  So we are trying to
     find some techniques for getting a true state of these flaws
     so that we can then use in evaluating the performance of the
               And I will not spend a lot of time on this, but we
     tried many techniques, including ultrasonics and high
     frequency ultrasonics, land waves, all kinds of eddy current
     techniques.  Just to summarize, none of those worked that
     well for all kinds of flaws.
               We are concentrating now on one technique, which
     is part of the research work we are doing not to evaluate
     the reliability, but research that we are doing on advancing
     data analysis techniques.  And so right now we are
     benchmarking a technique that was developed at Argonne
     National Laboratory.  It uses multi-frequency eddy current,
     but in addition to the multi-frequency eddy current, we do
     filtering, we do deconvolution.  And we have developed a
     rule based smart system, that is, we are incorporated into
     this algorithm the kinds of things that the good inspectors
     do when they do an analysis and try to decide whether it is
     a flaw or not a flaw.  So all of these rules have been
     incorporated into this system.  So one major aspect is the
     multi-frequency correlations to flaw sizing, and that is
     incorporated in this.
               And what I wanted to show you next, just very
     briefly, is some of the capabilities for sizing.  We are
     validating the technique by destroying -- by inspecting this
     set of tubes, having the inspector provide us with the
     mapping of the flaw, and then we are destructively
     evaluating these samples to determine how well this
     technique is working.
               It is just an example of the result we get from
     the technique.  You have seen the kind of graph that you see
     on the left before.  A key aspect of this is that it has no
     resolution.  One of the key aspects of our rule based
     automation calibration and deconvolution that we are doing
     is to improve the signal to noise ratio.  And the key
     parameter in being able to detect and also size flaws is to
     have a clean signal.  So if we can reduce -- if we can
     increase the signal to noise, that helps both the detection
     and sizing.  And one major aspect of this work is that we
     are really reducing the signal to noise -- increasing the
     signal to noise, reducing the noise a great deal.
               So that shows the kind of information we get, and
     on the right, we just show that you can section this
     information, looking at the flaw either from a
     circumferential, from an axial, or from a longitudinal view,
     and you can get the profile of the flaw.  And we are
     evaluating how accurately we are doing this by destroying
               Out of the 29 samples, we have finished that work. 
     All of those have been destroyed and compared to the eddy
     current result.  This is just a set of three samples that we
     have looked at and compare the eddy current profile versus
     the actual metallographic profile.  I could spend some time
     on how that is done, but if you have specific questions, we
     can try and answer them, but in the interest of time, I will
     move on.  I just want to say we are doing a careful job of
     metallographically evaluating the flaw.
               DR. KRESS:  How do you cut the tube?
               DR. MUSCARA:  Well, we don't cut the tube.  The
     best way we have found, that gives us very good information
     that is more effective from a cost and time point of view,
     is to pressurize the tube a small amount to open up the
     flaw.  We then look inside the flaw face, the tube is heat
     tinted, so we know what the prior flaw is from the heat
     tinting, and, also, it is an intergranular crack which is
     different from any quote we might have had from the
               We take a digital picture, the picture is
     digitized and we do digital analysis.  And looking at the
     light areas and the dark areas, we map out the flaw.  It is
     a very difficult and time-consuming process because the
     flaws we have in some of these tubes are literally dozens to
     hundreds of flaws, small flaws with ligaments.  And we are
     trying to evaluate those very carefully both with the
     metallography and with the eddy current.  And to my surprise
     at least, we are doing a lot better than I thought we could
     do with the eddy current technique.  We are really getting
     much resolution from this technique.  And, as I say, we are
     checking it out against samples, so know that it is real.
               Well, this shows a comparison of three samples,
     the eddy current by using this technique versus the actual
     destructive examination.  And you can see it is quite close. 
     In some cases, for example, the eddy current here does not
     pick up the full length of the flaw, and that is fairly
     typical.  The probability of detecting shallow flaws is
     small.  So in these matters, if we turn to a length sizing,
     we often undersize because we do not pick up the part of the
     flaw that is shallow.  That is a fact.
               The interesting thing is that when you try to
     evaluate these flaws and calculate a burst pressure, you
     don't really need to know the shallow part of the flaw
     because that does not contribute to the failure pressure of
     these complex flaws.  In general, what we found by running a
     number of tests, and Bill will talk about some of this
     tomorrow, but the portion of the flaw that is less than 70
     percent throughwall usually does not participate in
     determining the failure pressure.
               So when we look at these flaws and we go through a
     process of characterizing the flaw where we look at the
     equivalent area or an equivalent flaw, length and depth,
     because these are not rectangular flaws, and then use that
     in our integrity correlations, we can estimate the burst
     pressure very well by using these profiles, even though we
     might miss the shallow part of the flaw from the NDE.
               DR. KRESS:  When you do the destructive test, is
     there any chance that you change the flaw characteristics by
     doing that?  It looks like you --
               DR. MUSCARA:  Well, of course, there is always the
     chance, but, again, we are careful.  We do not open these up
     a great deal, we just want to open them enough so that we
     can look into the face of the flaw.
               DR. KRESS:  Yeah, and you can tell where you might
     have changed it.
               DR. MUSCARA:  Right.  And if we do change it, then
     we know that that is different from the heat tinted area,
     number one, from the intergranular nature of the crack.
               DR. KRESS:  And you can see what has changed.
               DR. MUSCARA:  So we can see.  We do look at these
     things on the scanning microscope, so that --
               DR. KRESS:  Oh, you look at them on a scanning
               DR. MUSCARA:  Oh, yeah.  Yeah, when we need to.  I
     mean some cases we don't need to.  But in many cases we do
     look at the surfaces on the scanning microscope before we
     decide what the profile is.
               Well, again, as I said, I wasn't going to -- I
     really wanted to come in and show you some example PODs, and
     we are not doing that, partially because we haven't fully
     characterized the generator.  We are still in the process of
     evaluating the data.  We are shaking down a statistical
     package we have for conducting these analyses, a number of
     reasons.  And, also, you know, it is a blind test and I
     really didn't want to have in the public some of these POD
               But I can tell you, qualitatively, we remember the
     Surry kind of information.  We are not too far from that. 
     If you remember at Surry, we had some fairly high PODs for
     large flaws, but never went to 100 percent.  Real teams miss
     flaws even though they are big.  All they have to do is
     blink while they are looking through the record.  So that in
     reality, some teams miss flaws.  And we know in this case
     also, some teams missed once in a while a large flaw.  So
     the POD does not go up to 100 percent, nor is it 60 percent
     for the large flaws.  So we are doing better than 60
               I say in general I think we are doing quite well,
     but you will see all this information in several months in a
     much more quantitative way.
               DR. KRESS:  Is your objective to get a POD versus
     flaw size?
               DR. MUSCARA:  POD versus flaw size as a function
     of the technique that was used, which is qualified, so it is
     POD as a function of the flaw type, the technique, the
     location in the generator.  We are going beyond that.  I
     mean in the past we looked at POD as a function of the
     maximum depth.  Well, maximum depth is not a really good
     parameter for determining burst strength of these tubes when
     we have a complex flaw.  It is if it is a simple rectangular
     flaw, but for these complex flaws it is not a good
     parameter.  So we will be looking at POD as a function of
     other things.
               One of the items that works very well, that we
     find worked well for predicting burst pressure is this M sub
     P.  M sub P is a correlation factor, it is almost a stress
     magnification factor that describes the stress at the
     ligament of the flaw that is used for predicting burst
     pressure of different types and sizes of flaws.  So it takes
     into account the geometry of the flaw.  And Bill will cover
     a lot of this development tomorrow.
               But one of the important parameters here for
     describing the severity of the flaw is M sub P.  So one of
     the things that makes a lot of sense to us is to try plot
     POD as a function of M sub P.  And it is not just the
     research work, I mean even in the field, we are moving
     towards, we are using this evaluation, we are using M sub P
     for predicting burst pressures.
               Besides the voltage criteria, and you have heard
     there are a few other criteria out there, one of the most
     recent ones is a criterion where you are actually using
     length and depth of the flaw to predict its burst pressure. 
     And it is not just length and depth, in fact, it is what I
     showed you before, it is the profile and how to calculate
     the burst pressure of those tubes.  Well, you need to have a
     severity factor which is this M sub P.
               So, you know, the laboratory work, yes, is leading
     some of this, but it is winding up the field, and we are
     doing those kinds of analysis.  And, in fact, we have an
     ultimate plugging criterion at the support plate and dented
     region where we use this kind of an evaluation for
     calculating a burst pressure and making sure that it meets
     the 3 delta P.
               And so with that, you come up with something other
     than 40 percent, depending on the reliability of sizing, the
     crack growth rate and the strength of these tubes.
               So one of the things that makes a lot of sense for
     us is to evaluate POD as a function of M sub P.  And since
     we are using voltage and we get that free, the voltage
     always comes with the signal, we will be plotting, I am
     sure, POD as a function of voltage for these different kinds
     of cracks.
               And then again, for the first time, we will have a
     comprehensive data set where we know what POD as a function
     of voltage is.  When we looked at this POD of .6, it was as
     a function of a handful of flaws of varying sizes.  And
     normally POD is a function of size, it is not POD is a
     function of voltage.  But we will have that information once
     we are done with these analyses.
               I am not sure if I should go through this.  I mean
     you can read it as well as I can.  But we find is that the
     POD for the larger flaws, or for the large segments of the
     flaw can be fairly high, above 80 percent.  Again, it is not
     100 percent.  We have missed sometimes large flaws, but it
     is more than .6.  And so there is -- we realize that .6 is
     conservative, and in a voltage based criterion, .6 covers,
     as we mentioned earlier, a number of things, not just the
     POD but the crack's initiator in cycle, for example.
               So the POD will have detailed data, can get fairly
     high.  On the other hand, it is very low for flaws that are
     smaller than 40-50 percent, and that is not a surprise, I
     think we expect this.
               I think you can read the rest at your leisure.
               DR. POWERS:  Everything else is pretty much as
               DR. MUSCARA:  Right.  Just very briefly, we have
     been talking about sizing and the difficulty sizing.  Sizing
     is usually based on a calibration, so you have a set of
     standards with different depths of holes or notches, and you
     look at the face angle for each one of these notches, and
     you have a calibration curve for sizing.
               We also have indicated -- maybe we haven't, but
     sizing ID flaws is more troublesome than sizing OD flaws,
     and this graph shows you the reason why that is.  If you are
     looking at the ID flaws, that is the portion of the curve in
     red.  You can got from 100 percent -- from zero ID flaw size
     to 100 percent through the wall size, and you are just using
     up 30 degrees of face shift.  So within 30 degrees, we have
     the full span from nothing to throughwall.  And when the
     signals are complex and complicated by noise, and it is
     difficult to pick out where one should measure the face
     angle, then you get into a problem with getting good,
     accurate sizing.
               For OD cracks, they normally can be sized a little
     bit more accurately.  There is a larger span than covers
     from 0 percent depth to 100 percent.  But, at any rate, so
     sizing normally is conducted with a calibration curve.  We
     know whether it is ID or OD based on which, what quadrant
     the signal fall from, from 0 to 30 percent, it is ID.  From
     30 percent on up, it is an OD.
               Well, this is similar to the second to last
     viewgraph.  Stress corrosion cracking depths less than 50
     throughwall, we find that is not reliable, and it is not
     unexpected.  Smaller flaws give small signals and they are
     complicated by other conditions, and it is difficult to
     select the proper face angles.  But what you find in general
     is that these flaws are overestimated, but we see they are
     unreliable because that is not always the case, sometimes
     they are underestimated.
               Well, and the orientation we have found is quite
     difficult.  Circumferential cracks at the top of the tube
     sheet, when they are small cracks, they are really difficult
     for the teams to get a good sizing on.
               This is all that I had.  I had prepared to, again,
     give you a view of the work that is in progress and the kind
     of data we were looking forward to getting.  It will be
     quite useful in evaluating submittals that come in and
     getting a feeling for what the real probability of detection
     of these flaws is.
               MR. STROSNIDER:  This is Jack Strosnider.  I don't
     know if you had any additional questions, but thanks, Joe.
               This is some really useful work which I think is
     going to help NRR in terms of our review of licensing
     amendments and activities that come in.  And I think the
     industry, and I mentioned earlier this sort of simplified
     approach to operational assessments, but I don't want to
     give the wrong impression, I think licensees may actually be
     out there doing these calculations and this is going to help
     them do their work.  I was talking about the sort of sanity
     check that we give those evaluations.
               In terms of schedule, we are almost finished with
     Item 10.  Actually, under Item 10-G, Number 1, it talks
     about laboratory studies and why these are applicable in
     light of vibrations induced by blowdown, et cetera.  We
     interpreted that as wanting to hear some more about the
     issue that Mr. Spence discussed yesterday with regard to
     blowdown effects.
               And Jack Rosenthal from the Office of Research is
     here.  You know, this issue has been -- Research has been
     asked to take a look at it in terms of the GSI process, and
     so to address that issue, we are going to ask Jack to give
     you a little status on where that is at.  And I don't know
     how much he has got, but when we finish that, that will
     conclude Item 10, and then we can decide how to go forward I
     guess with the rest of the agenda.
               DR. POWERS:  Well, I will tell you what the
     decision there is.  We will take a little break after Jack
     and then we will trudge right ahead.
               MR. STROSNIDER:  Okay.
               MR. ROSENTHAL:  Really, my comments are
     programmatic and short, so I will go fast.  Okay.  My name
     is Jack Rosenthal, I am the Branch Chief of the Regulatory
     Effectiveness Assessment and Human Factor Branch in the
     Office of Research, and one of the teams in my branch is
     responsible for working generic issues.
               Yesterday that was some discussion that we have
     been slow about working some generic issues, and that is
     true.  But since 1981, we have approached 632 issues,
     prioritized them, et cetera, 283 of them actually were
     worked as generic issues with some sort of technical
     approach to them.
               At least of recent, I think we are doing much
     better at working the issues.  So from 600 issues, of
     course, the tough ones that take years, we resolved five in
     '99, six in Fiscal 2000.  There is seven on the books right
     now.  Our real viable process has new issues coming in and
     old ones getting resolved, but the big backlog of prior
     years is no longer.
               The ACRS has been kind to us, and you will see we
     have, with some regularity, been coming forward to you with
     the issues as we resolve each technically.  And you are
     familiar with these because we have discussed these with you
               Before us now is -- that is the list of current
     issues, and monthly we tell Pete Domenici where we stand on
     resolving issues.  There is some thrust to get them
     resolved.  When this slide was made up, we didn't have
     GI-188, which is the most recent one.
               I was going to talk about 163, but looking through
     the material, Jack Strosnider did a good timeline review at
     the beginning of the day, so I won't do it again.  You will
     find all the information on the NRC web, and there is a
     commitment there that following this panel's deliberations,
     we will figure out what to do in terms of a program plan for
     resolution of the multiple tube rupture issue.  And in that
     document sitting on the web page, it says, within a month of
     you finishing your work, we will come up with a plan to
     finish ours.
               The last slide is 188, it is resonance vibrations
     of steam generators tubes in a main steamline break event. 
     That is just a title that has been given to it.  It has been
     entered into our system, and we are starting to work the
     issue.  And I just -- as I understand, and this is what
     needs to be worked out, the postulate is that, and it is not
     surprising, if you have a fluid system and you suddenly open
     that system, or you suddenly close that system, yes, one
     would have pressure pulses in the system which would induce
     mechanical motion in the system, et cetera.  That is really
     not a surprise.
               At least a preliminary look, would the vibrations
     be -- or the number of fatigue cycles that you put on it be
     bounded by the current design of the steam generators? 
     Well, it is not so obvious because just the amplitude might
     be different.  It is something where we can't dismiss it out
     of hand.  It does appear to warrant some technical work.
               We are following the pilot application management
     directive 6.4, which we brought before the ACRS, and the
     ACRS was very kind to us in retrospect when you said, look,
     why don't you try it out for a year before you adopt it. 
     And as is proven, we have had some lessons learned from
     that, so thank you.
               In that process, --
               DR. POWERS:  We will help you, Jack.  Come back to
     us again and we will still harass you.
               MR. ROSENTHAL:  In that process, the big change is
     the management directive, is to say that for issues that we
     current worked, resolve really means resolved as somebody in
     the street would understand the term "resolved."
               DR. POWERS:  Best move you can possibly make.
               MR. ROSENTHAL:  Okay.  And that is that you bring
     it through, figure out what you want to do and actually do
     it and figure out, okay.  And some of the activities upfront
     are handled by RES, and then some of the issues, I mean NRR
     has responsibility for writing rules, doing inspections, et
     cetera, so it is a joint effort.  But what we have said is
     in terms of the public, that resolved ought to be mean
     resolved all the way through verification.
               We are in the identification stage of this issue. 
     Initial screening.  We have a panel of experts, Milos
     Chochki is the panel chairman on that, and the next meeting
     is scheduled for 10/18.
               What we do is, based on what we have heard here,
     and the information that is brought forward, we are going to
     try to write down what we think is the issue, get agreement
     on the issue.  And then -- not so simple.  Because we want
     to know upfront whether we are going to include things like
     motion of the lowest support plate or not.  Are we only
     talking about the tubes?  Are we talking about other
     mechanical aspects of the steam generator?  And just what is
     the issue?
               And what we have learned from other go-rounds is
     that defining the issue is quintessential.  Then within the
     sense of the Generic Issue process, you decide if it is a
     compliance issue, it was already covered by the regulations. 
     Is it an adequate safety issue?  Typically associated with
     what you think of as this 3 to the minus 3 delta CDF type
     issues, which I don't perceive this to be.  Or is it a
     safety enhancement issue?
               Following that, we would then develop a program
     plan for how we would attack the issue, and then everything
     the NRC does goes through a PBM process and we would get
     resources to work the issues.  That is where we stand.
               DR. POWERS:  I mean that is great, and I am glad
     to see that the process is being exercised, and we will be
     anxious to hear how it comes out.  But we are left with a
     problem now.  We have a contention that says, gee, when you
     set up this Generic Letter 95-05, you guys didn't take into
     account the fact that you are going to get these violent
     pressure pulses and vibrations in here that could lead to a
     couple of things, growth of cracks that otherwise wouldn't
     have grown, and enhanced leakage, and unplugging of cracks
     that have been plugged by corrosion products, okay, and that
     would give you enhanced leakage.  So your leakage estimates
     that you had in mind when you set up Generic Letter 95-05
     just don't take into account this physical phenomena.
               And the question is, what is the response to that? 
     Now, what we heard from Ken is he says the cracks are very
     tight, and there isn't much in those things, so the
     unplugging cracks may be not such a major issue as it is
     other contexts.  But the growth of cracks due to the violent
     vibrations is still, I think, an open issue here.
               MR. STROSNIDER:  You are looking for a response.
               DR. POWERS:  Yes.
               MR. STROSNIDER:  This is Jack Strosnider.  I guess
     the answer to that is, number one, I think, yeah, we do need
     to do some work to understand what this phenomena is.  I
     don't think there is anybody here right now that say how
     significant it is or isn't, you know, what it is going to
     do, and it is just going to require some technical work to
     go figure it out.
               You know, we have emerging issues in regulatory
     space all the time, all right, and that is why these
     processes are set up to deal with them.
               The other point I would make is that, based on
     what I heard yesterday, and some of the concerns that have
     been expressed, it is not clear to me that this is just a
     Generic Letter 95-05 issue.  You know, some of the
     suggestions with regard to the significance of this
     transient, you know, if some of what we heard is, in fact,
     what we find out when we go look at the technical aspect of
     this, it is broader that voltage based repair criteria, it
     has some much more fundamental issues.
               DR. POWERS:  That's fine.  But right now I want to
     work on what it has to do with alternate repair criteria.
               MR. STROSNIDER:  Yeah, and I think, you know, my
     response is, like I say, we have emerging issues that come
     all the time in regulatory space.  We have a process for
     dealing with them.  When we talk about going out and
     changing the licensing basis for plants, et cetera, we need
     to do that, you know, in a methodological way, and that is
     what the process is there for.
               MR. ROSENTHAL:  Can I make a comment?  Let me just
     make one more comment and then I will give you the mike. 
     And that is that, depending on what goes on with this panel,
     okay, we have options to incorporate the resonance issue in
     with 163 into a major -- into one big issue.  We could parse
     it out amongst its pieces.  And we just haven't made a
     decision pending hearing out the results of this work, plus
     the panel meeting to discuss in greater depth that technical
     work.  And then we just have to put together.
               But we are dismissing the issue.  And as we look
     at it, we see that there is interesting technical aspects.
               DR. HOPENFELD:  Let me relate to you my 40 years
     of experience in Research.  You don't look, you don't find. 
     Ten years ago, nine years ago, the broad spectrum of
     problems were really identified.  We didn't go into the
     detail in that GSI-163 in the DPO, but NRR chose not to look
     at it, chose to set it aside.
               And now you tell me -- I am positive that
     somebody, that if that work had started then, all these
     problems would have been identified.  So I am kind of a
     little bit frustrated in you telling me that this is a new
     thing that you are discovering today.  That is water over
     the bridge.  The point is that with this kind of attitude, I
     think we should start this new vibration program.
               But if you are going to proceed in the same way
     that we have done before, there will be other things here,
     because it is a very complex problem.  You ask yourself --
               DR. POWERS:  That deals with issues of management
     and whatnot that are out of our spectrum.  I think we are
     interested in the technical issues here, and how it impacts.
               MR. STROSNIDER:  I would provide two additional
     comments, too.  I mean this is -- obviously, you as the
     special subcommittee have been tasked with dealing with the
     issue, and so this is just my perspective, okay, and take it
     for what it is worth.  I think, you know, there is a
     question, and Dr. Hopenfeld just pointed to it, you know, is
     this issue, was it part of the original DPO or not?  And you
     can take a look at that, you know, it is open to the
     discussion probably or debate.
               But the more important thing is, and I tried to
     talk about this this morning in terms of what it takes to
     resolve a DPO, or any other, you know, emerging issue and
     how we deal with them, okay, saying that, you know, that in
     an ideal situation you come up with "the" technical answer. 
     You know, we would all like to have a lot more information
     on what transpired after the event down there as described
     yesterday and, you know, all sorts of analyses, and we could
     look at them today and say this is the answer.  You know, we
     don't have that.
               The resolution to many DPOs, if you go back and
     look at it is to say, we are going to go.  You know, we
     acknowledge that it is an appropriate issue for further
     study and that is what we are going to do.
               So that is just my perspective on it.  You know,
     you as a committee have to decide how you want to deal with
               MR. HOLAHAN:  Let me just add something.  This is
     Gary Holahan.  When an issue is referred to the Generic
     Issue Program, in effect, you have made a judgment already
     that you don't need to take immediate regulatory action.  I
     know, you know, Jack referred to the judgment about this as
     concern associated with not a very high probability event,
     and I think that is part of the judgment.
               And I think, Jack didn't mention it, but part of
     his panel's responsibility as they get into the issue is, in
     fact, to identify for themselves whether this is an
     immediate safety problem which could be kicked back into the
     regulatory process for a Bulletin or a Generic Letter, or
     calling in an Owners Group or dealing with on a more
     immediate basis.
               By its very nature, these things are judgmental,
     because you haven't done the research work and you haven't
     put all the information together, okay.  But there is,
     within the process, a judgment being made about this is an
     issue that should be worked, and it is reasonable to take
     some time to do it.  And we have these sort of issues, you
     know, every once in a while.
               I think back to when we had problems with, you
     know, fire barriers, and we talked to people, and we tried
     to figure out whether that was a concern or not, and we
     dealt with it a while.  And then we observed the test, and
     in the test, there was an immediate and obvious failure, and
     two days later we wrote a Bulletin that told the industry
     they had to do something in the meantime.
               So when an issue moves from a concern, you know,
     to a clearly known problem, we can deal with that.  I think
     this issue is at the concern stage.  We realize that, you
     know, I mean we have 2,000 years of operating experience and
     we, you know, haven't had any main steamline breaks, you
     know.  So this issue is something that needs attention but
     doesn't need attention today or this week, and can go
     through a deliberate process.  But as part of that process,
     people have a responsibility to say this looks like more and
     more like it will be resolved and it is not a problem, or it
     looks like the evidence is building up that it is a real
     problem.  And the process has to deal with that.
               DR. POWERS:  I think I would have liked to seen
     what the thinking about it was.  Even if the outcome was
     exactly what was described, are you going to put it into the
     Generic Issue process?
               Why don't we go ahead and take a 15 minute break. 
     And then we will come back, and I guess we are doing damage
     propagation at that point, is that correct?
               SPEAKER:  Yeah, that is Item 11 on the agenda,
     that's right.
               DR. POWERS:  Let's come back into session.  I
     think at this time we are going to turn to the issue of
     damage propagation, in particular, the subject of jet
     cutting.  Okay.  And I have Joe and Steve listed down here. 
     I usually ask Steve why he is not working on the human
     performance program plan, but I won't ask him this time.
               So, whomsoever is leading off, please lead off.
               DR. MUSCARA:  In the interest of time, I could
     mention, as you said yesterday, you can all read.  We just
     need the viewgraphs.  We would rather answer questions.
               DR. POWERS:  Well, to tell you the truth, this one
     involves CFD calculations and whatnot, and I don't read CFD
     to be honest with you.
               DR. MUSCARA:  I don't either, that is why we have
     Steve here.
               Okay.  So I guess we are going to be talking about
     the agenda items 11 and 14, damage propagation actually. 
     Item 14 will be done tomorrow morning.  To do this section
     of the agenda, we have Steve Arndt, Steve Long and Bill
     Shack will be contributing parts of the presentation.
               Quickly, I will talk a little bit about our jet
     impingement work that we have planned or are in the midst
     of.  Jet velocities --
               SPEAKER:  Is your mike turned on?
               DR. MUSCARA:  Thank you.  Jet velocity and
     particle motion, Steve will cover, Steve Arndt.  The
     quarter-inch -- the basis for the quarter-inch crack, Steve
     Long will talk about that.  He is here.  Good.  And as I
     mentioned, Bill Shack will present work on different models
     for predicting behavior of cracked tubes under different
               Well, the issue of the jet cutting was brought up
     in NUREG-1570.  I think at this point the staff really had
     some concern, a lot of it based on some samples we had seen. 
     One of our staff members had done some work at a fossil
     plant, and he was doing a failure analysis of some tubes
     that had seen some jet cutting in a fossil plant, and very
     impressive tubes.  In fact, they did cut through -- these
     tubes, I believe they are stainless steel, they are about
     .44 inches think, and a jet from this fossil plant did cut
     through a number of tubes.  So there was some concern there.
               Well, based on this experience, the staff looked
     for some data that they could try to relate to the behavior
     of steam generator tubes under severe accident conditions,
     found some data on coal gasification and used this data to
     come up with some estimates.  In fact, if you look at the
     NUREG, some fairly high ablation rates were estimated with
     that work, where the ablation or erosion is due to
     mechanical processes or corrosion processes, or a
     combination of these two.
               In particle droplet impingement, generally, we are
     looking at a mechanism that is driven by mechanical
     processes, either by jet cutting or by fatigue of the
     surface layers.
               For particulates in a corrosive atmosphere, the
     removal mechanism can be either by the mechanical methods or
     by corrosion.  At low velocities, normally it is driven by
     the corrosion.  Intermediate velocity is a combination of
     the two.  And at high velocities, even in a corrosive
     atmosphere, the ablation is driven by the mechanical
               So we were interested in looking at this issue
     again to try and relate it more closely to the conditions
     that we have during severe accidents.  I guess I should
     mention, we will address both erosion under severe accident
     conditions and under steam line break conditions, but we
     need to separate those two.  Certainly, under severe
     accident conditions, we are dealing with high temperature
     superheated steam.  A compressible fluid in the steamline
     break, we are dealing with water droplets and possibly
               So we are going to separate those two.  We are
     planning some work on the severe accident conditions.  That
     work is underway.  We are planning work also under the steam
     line break conditions, that is just in the planning stages.
               So to address this a bit further, we decided to do
     a number of things.  One was to do a literature search and
     the second step was to bring together a group of experts to
     talk about the issues that might be involved, in particular
     with respect to the severe accident conditions and the
     ablation expected under those conditions, and also to talk
     about, say, the leak rates or, in particular, the creep
     crack opening of the steam generator tubes under the creep
     conditions we might experience in the severe accidents.
               So we held a specialists meeting at Argonne
     National Lab on November 19th, '99.  We do put minutes
     together and those are available to the public.  They were
     sent to the Public Document Room on December 10th.  At the
     meeting, it was open to the public, but we particularly
     invited a selected number of experts.  Among those in the
     erosion area, we had Ian Wright from Oak Ridge National Lab
     and John Stringer from EPRI.  I guess I should also mention
     that the data that was used in the NUREG from the coal
     gasification work was data developed by Ian Wright, among
     some others, but that was a major part of the data that was
               In the severe accident area we had Jason Schaperow
     from NRC and Mati Merilo from EPRI.  In the high temperature
     fracture mechanics we had Professor Saxenna from Georgia
     Tech, and then the various other from NRC and ANL, including
     staff from Combustion and B&W, or ABB and FDI.
               When we discussed these issues, certainly a number
     of things came up as being important in this area, and a
     number of clarifications were provided by the experts.  Both
     Stringer and Wright felt very strongly that the fossil
     experience with the superheated tube could not be used or
     extrapolated to the steam generator case.
               In particular, the fireside atmosphere in a fossil
     plant contains a heavy load of ash particles, sand and the
     large particle sizes.  And what happened in the cutting
     there is that the jet entrains these very abrasive
     particles, their large size, and they cause the cutting. 
     So, you know, we don't think this kind of particle is really
     present in the generator.
               DR. POWERS:  Numerous speakers have spoken of
     sludge piles and whatnot.
               DR. MUSCARA:  Yes.
               DR. POWERS:  The oxide itself is spinel.  It seems
     to me that there are some fairly hard particles in there.
               DR. MUSCARA:  Yeah, we actually discussed this
     with the experts, you know, the possibility of the jet
     picking up particles as it exits the tube.  Well, there are
     several locations in the generator where this could be
     possible.  One place in particular where you have sludge
     probably would be the top of the tube sheet.  Another place
     might be at the support plate.  I don't think we get a great
     deal of sludge there, you know, not as much as we get at top
     of tube sheet.
               The consensus was that, if you know the nature of
     the sludge, there is sludge lancing that goes on
     periodically to get rid of the sludge at the top of the tube
     sheet, and the loose particles are usually taken away by the
     sludge lancing.  But, in fact, the majority of the sludge is
     not even able to be lanced off.  The stuff is cementatious
     and it is very hard and sticks to the tubes.  So we thought
     even if the jet worked its way through a piece of sludge, it
     may pick up a few particles, it would tunnel through there
     and would not really pick up much more beyond that.
               DR. KRESS:  Under severe accident conditions that
     generated a lot of aerosols.
               DR. MUSCARA:  Yes, I will get to that, sure.
               DR. KRESS:  You are going to get to that later.
               DR. MUSCARA:  Sure.  Yeah.
               DR. POWERS:  Under design basis accidents, won't
     you be carrying in lots of the crud particles from the
     primary piping system in the jet?
               DR. MUSCARA:  Yes, generally you do get corrosion
     of the carbon steel area.  I mean much of the primary system
     is clad, but there is some carbon steel, you do get some
     product.  We have done some work in the past trying to
     characterize leak rates through cracked pipes, and, you
     know, we try to do a search and get information on the kinds
     of crud that you get from the primary side.  It is really
     not crud.  You may have some very small particles, and even
     if you have those, the loading isn't that great.
               So, you know, we are not -- we haven't quantified
     that.  Our feeling is that you do not have a large amount of
     crud due to the corrosion products that gets carried by the
     primary side fluid.
               Also, Stringer felt that the droplet erosion
     during design basis accident was unlikely, and the reasoning
     is that the erosion rate is dependent on the droplet size,
     and it is related to the diameter to the third power.  We
     have noted water droplet erosion in steam turbine, but this
     occurs because of fine droplets condensed in the turbine,
     and when they enter the turbine, they become larger drops
     and then the spinning blades hit these drops and you get
     erosion, which the insiders call baseball bat erosion.  But,
     again, you know, these are large droplets that the finer
     droplets are condensed and then are picked up by the blades.
               DR. CATTON:  So do the smaller droplets cause more
               DR. MUSCARA:  No, less.  The big droplets to the
     third power.
               The NUREG-1570, extrapolation of the data from the
     coal gasification plants, they assume that the ablation rate
     will be proportional to the density of the fluid and to the
     cube of the velocity.  The temperature affected the
     extrapolation only as it changed the density of the fluid. 
     But, in effect, the work that was done for coal
     gasification, the gas mixture is very oxidizing.  In
     particular, it is 1 percent H2S in this mixture, and nickel
     alloys under corrosion in these kinds of atmospheres.
               So what we are looking in the coal gasification
     data is one at done at high temperatures, much higher than
     we expect, and at higher temperatures the corrosion, you get
     a greater amount of corrosion.  In addition, the work was
     done at low velocities, 10 to -- I believe they had a set of
     data at 10 feet per second and a set of data at 100 feet per
     second.  And then, of course, this was extrapolated up to
     about 1,000 feet per second, using the correlation to the
     third power.
               DR. CATTON:  Can I go back to that first paragraph
     for a moment?  What is the scenario that you are looking at? 
     Isn't it the high pressure inside the tubes and its water?
               DR. MUSCARA:  Under steamline conditions, yes.
               DR. CATTON:  And isn't that what we are talking
               DR. MUSCARA:  Yes.
               DR. CATTON:  So the jet would expand from, I don't
     know what, 2,500 psi down to 1,000?  Isn't this what leads
     to the erosion, so it is the droplet sizes associated with
     the fragmenting jet, liquid jet?
               DR. MUSCARA:  Right.
               DR. CATTON:  So where does this fine droplet
     business come from?
               DR. MUSCARA:  In the turbine case, the water
     droplets coalesce, become large droplets.
               DR. CATTON:  But here you are starting with a
     liquid jet.
               DR. MUSCARA:  Right.
               DR. CATTON:  And it is going to fragment into
     small droplets.
               DR. MUSCARA:  Right.  So they are small --
               DR. CATTON:  How fine are the droplets?
               DR. MUSCARA:  Right.
               DR. CATTON:  They can be coarse.
               DR. MUSCARA:  We will be addressing the area of
     the jet behavior later.  But let me just mention right now,
     we --
               DR. SHACK:  This is just somebody's opinion, an
               DR. KRESS:  It is experts telling what they think.
               DR. CATTON:  Okay.
               DR. MUSCARA:  In the literature.  But let me
     just --
               DR. CATTON:  At the agency, we know quite a bit
     about this kind of process because this is what is
     associated with combustion.  So you don't have to think it,
     you could base it on something that is real.
               DR. MUSCARA:  Right.  Right now the first step was
     to concentrate on the severe accident condition.
               DR. CATTON:  Okay.  It just seemed you were
     throwing that one away.
               DR. MUSCARA:  Right.  I am bringing this up also
     because we will be doing some work in this area.  So my
     feeling is we need to understand the dependencies of the jet
     and how it expands, the particle size, particle density, et
     cetera, for the severe accident case because we can't really
     conduct tests under those conditions.
               We are also trying to understand how the droplet
     erosion would work under steamline break conditions, and we
     will try to understand that from the literature as much as
     we can.  However, we have developed a very nice facility at
     Argonne National Laboratory for conducting tests under
     prototypical conditions.  So regardless of what the theory
     tells us, my first step is to conduct -- well, they are
     concurrent steps, but we are conducting actual test under
     prototypic conditions with cracks, and whatever jets that
     are produced impinging on a sample.  So there we get some
     data on the prototypic conditions.
               Meanwhile, we will also try to understand it from
     a theoretical basis.
               For the severe accident case, there is no way that
     we can develop a rig to produce the kinds of conditions that
     you get under severe accidents.  So here we are depending
     more on whatever knowledge is there, what other research has
     been done.  So this is the one I would like to address
               DR. HOPENFELD:  If you want, I will make my
     comment later, but it is pertinent to this point, if it is
     okay with you.  I will make it very fast.
               Three years before the DPO, I asked Los Alamos to
     do a study as to what happens when a jet 2200 flushes into
     water and flushes into steam, into air.  To come up with
     some kind of estimate, what kind of particles, particle size
     you have.  They have done a very considerable amount of work
     on that.  The conclusion was, with all due respect to the
     expert, that you cannot really predict what size you have. 
     You can come up with sizes from one micron all the way to a
     fraction of a millimeter.
               So what I am kind of seeing here, that you are
     starting a new program without really looking at what
     happens based on a meeting.  Now that is not how you do
               DR. MUSCARA:  So when one extrapolates the coal
     gasification data, this is data really that is based on
     corrosion, not ablation, and the dependency to the third
     power doesn't hold.  In fact, when you look at the data
     itself, work was done at different velocities, different
     temperatures, it is inconsistent with their extrapolation. 
     And, also, the effect of temperature on corrosion was
               Based on the literature review, and the experts
     meeting, we identified some of the key parameters.  Two of
     these were the jet velocities and the associated particle
     motion that were some of the most important parameters,
     including the particle size.
               Having this background, we asked for some
     assistance from our Division of System Analysis and
     Regulatory Effectiveness to carry out calculations to better
     define the jet velocities and the particle motion that we
     would expect under severe accident conditions.  This work
     has been completed, and I think I would like to break at
     this point and ask Steve Arndt to address some of the
     findings from this work.  Steve.
               MR. ARNDT:  Thank you.  As Joe mentioned, my name
     is Steve Arndt.  This week, literally, I am the Assistant
     Branch Chief for the Safety Margins and Systems Analysis
     Branch in the Office of Research.  I am going to go through
     some of the work fairly quickly that we were asked by the
     Division of Engineering to look at to support some of their
     work in characterizing the kinds of damage propagation you
     can get.
               There have been several attempts to come up with
     an appropriate velocity impinging on the adjacent tube to
     this kind of damage mechanism.  We were asked to look at
     this for basically three primary reasons.  One, to get a
     better fundamental understanding of what is going on.  The
     previous analysis were fairly simple analysis.  Two, to
     understand what the particles within the fluid were doing,
     which had not been looked at previously, because the
     computational tools weren't available.  And, also, to
     support the work that the Division of Engineering is going
     to be doing at the University of Cincinnati, or is actually
     in the process of doing at the University of Cincinnati, and
     to benchmark the velocities that they need to test at.
               And when we originally discussed it, one of the
     things was, is 1,000 feet per second an acceptable number? 
     Will it give you the numbers?
               So, as you can see, this work was done by
     Professor Piomelli, who is a professor of mechanical
     engineering at the University of Maryland who does CFD
     calculations.  The code that we used was the NPARK code.  I
     believe Professor Catton is familiar with that.  It is an
     Air Force developed code that is specifically for high
     velocity flows.
               Because we were trying to understand the
     phenomenon and also provide input to the Division of
     Engineering, we wanted to look at, based on our
     computational study, what not only the important parameters
     were and the actual numbers, but what the sensitivities
     were.  So we looked at variations in the temperature, the
     pressure, the various steam geometries and the crack
     thickness.  I will show you that in a moment.
               For this particular study, we did a
     two-dimensional study, so we have a crack, we looked at two
     different thicknesses and assumed an infinitely long crack. 
     The particle size and densities were developed from a
     Victoria calculation, and this is a slightly misleading
     phraseology, Charlie pointed this out to me, we assume an
     equal distribution in the tube at the time of the crack.  It
     is not in the entire primary system, it is the particular
     density at the primary side of the crack.  And we also
     assumed that the particle velocities were calculated along
     with -- I'm sorry.  One of the goals was to calculate the
     particle velocities.
               DR. POWERS:  So you are looking really at the
     severe accident scenario?
               MR. ARNDT:  Yes, this is a support of the severe
     accident scenario.
               DR. KRESS:  Are these Victoria calculations, were
     they using the natural convection recirculating
     countercurrent flow conditions?
               MR. ARNDT:  That's correct.
               DR. KRESS:  They actually used those.
               MR. ARNDT:  We used the SKDEP calculation to
     develop the accident scenario and then used the Victoria to
     actually propagate the aerosols.
               DR. KRESS:  So these aerosols went back and forth
     with some residence time that may be relatively long while
     you are heating up and agglomerating perhaps and changing
     size, and you got all that out of Victoria?
               MR. ARNDT:  Charlie.
               MR. TINKLER:  Yes.  Charlie Tinkler from the NRC
     staff.  As it turns out, most of the larger aerosols are out
     of the stream by the time they get to the steam generator.
               DR. KRESS:  They fall out --
               MR. TINKLER:  They fall out.  So we are left with
     a distribution, I think it was 1 to 5, on the order of 1 to
     5 microns, something like that.
               MR. ARNDT:  Yeah, I will show the distribution
     here.  Actually, I will show it now just because we are
     talking about it.
               MR. TINKLER:  You know, we had a large, a
     relatively large inventory of non-radioactive aerosols that
     were floating through the system.
               DR. KRESS:  That was going to be my next question. 
     What was your source term for non-radioactive aerosols?
               MR. TINKLER:  I think we have three or four
     hundred kilograms worth.
               DR. KRESS:  Coming from the cladding?
               MR. TINKLER:  Coming from the cladding and
     structural materials in the core.  I think I actually show
     the number in one of my viewgraphs in tomorrow's
     presentation.  I think it is about three or four hundred.
               DR. HOPENFELD:  Can I just make one comment? 
     Because what I said yesterday, you cannot do those because
     of the agglomeration that you get, because the
     thermophoresis forces in the plenum.  So unless you have, in
     the mixing plenum, unless you have the temperature
     distribution, you can't figure out the residence time. 
     Right now they don't have it, it is a perfect mixing.
               DR. KRESS:  Do you include thermal phoresis at all
     in the calculation?
               MR. TINKLER:  Yes.  Yeah, we have thermophoresis
     in the model, and, typically, in the tubes themselves,
     thermophoresis is relatively small effect because the
     temperature difference between the vapor and the thin steam
     generator tubes is pretty small.  But in other parts of the
     system, you know, we use the SKDEP RELAP boundary
     conditions, you know, through a rather tedious process of
     imposing as boundary conditions on the Victoria.  We use
     their thermal hydraulic conditions, and, yes, we do have
               MR. ARNDT:  This is the relative particle size,
     out of particle mass, particle size and density of the
     distribution that we had at the time of the opening.  And,
     as you can see, the mean is in this couple of micron area.
               You might want to remember this because, for
     various reasons associated with the computation, we refer
     the mass as opposed to the particle size, which is not quite
     as intuitive in later calculations.  But I will keep that
     handy in case anyone needs it.
               Like I said, we looked at a variation of several
     different things, temperature, size of the crack -- I'm
     sorry, size of the crack which is this -- these are actually
     half-heights, because we use a symmetric system.  Two
     different sizes of a rectangular grid and a triangular grid. 
     These were designed to be similar in configuration to a
     Model 51 D type steam generator and a triangular grid from a
     combustion engineering.
               And what you have here, and, by the way, all the
     details are in this handout that you got.  I believe you now
     have the color version of this, with all the gory details. 
     What you see, and these are the physical properties.  Let me
     actually skip to the next couple of slides later, because it
     is a little easier to explain what is going on.  This is two
     slides later.  From the velocity curves as opposed to the
     thermal properties curves.
               What you have is a thin hole, a small hone, very
     high pressure, low pressure.  This is 16 megapascals, this
     is atmospheric, so you have an expansion pressure ratio of
     160, which produces a very under-expanded jet.
               You go through rapid pressure drop and velocity
     increase and you, because you have a blunt body here, form a
     shockwave.  The expansion would have continued out into, if
     you didn't have this actual blunt body here, to a typical,
     very high, under-expanded jet kind of phenomena.  We did
     some sensitivity studies basically by removing that and
     looking at what would have happened had it not been there
     and got pretty much what you would expect from a theoretical
               If these had been parallel plates, you would
     expect it to expand, then drop, the pressure would drop
     rapidly and then as you go over here, would increase almost
     to the original pressure.  The same for the velocity, you
     would start it at a lower velocity, expand rapidly to a very
     high velocity, the mock numbers are very high, as you can
     see, and then drop to almost zero here.
               DR. KRESS:  I presume these are steadystate
     calculations where you kept the primary side pressure
     conditions constant?
               MR. ARNDT:  Yes, that's correct.
               DR. KRESS:  Okay.
               MR. ARNDT:  Given the flow rates and the
     availability of steam on this side, basically, you can't
     deplete this in the kind of timeframes we are talking about. 
     And this sets up very quickly.  You are on the order of a
     couple of microseconds to set up that kind of steadystate.
               Because both of these barriers are curving away,
     the flow does not stagnate here, but actually shoots off in
     this direction.  In the rectangular grid, of course, there
     is another tube up here, and you would have another
     shockwave up here.  In the triangular grid, there is another
     tube over here, and, basically, what you have is a second
     nozzle type effect where you are shooting off fluid off this
     direction and off this direction.
               If you go back to the original graph and look at
     the thermal properties, you can see, after the shockwave,
     well, the jet shoots out very high density, expands rapidly. 
     After the shockwave, the pressure goes back up, and the
     density goes back up, but not nearly as high as the original
     pressure.  You go through a very rapid drop in temperature
     as well on the other side of the shock.  Because you are
     compressing the fluid, you increase temperature again.  And
     you can see that from this particular graph.  The density
     drops down dramatically, the temperature drops and then goes
     back up again.  This is the velocity in the X direction and
     the pressure.
               DR. CATTON:  You approach velocities of about 3600
     feet per second in that.  You have 1200 meters per second,
     about 3600 feet per second.
               MR. ARNDT:  Yes.  And if you look at the
     variations associated with the different geometries, you can
     see the basic phenomenology is very similar.  You expand
     rapidly, the pressure drops, the velocity goes up.  You go
     through the shock front, the velocities drop, the pressure
     goes up.
               DR. KRESS:  Where is the 1,000 feet per second on
               MR. ARNDT:  This is -- 1,000 feet per second, it
     would be right in here.
               DR. KRESS:  So that is where the number comes
               MR. ARNDT:  Well, I will show you where that comes
               DR. KRESS:  Okay.
               DR. CATTON:  Normally, you don't get such nice
     shocks when you use this code.  Did he do something to
     smooth them?
               MR. ARNDT:  We looked at --
               DR. CATTON:  You get more spikes, unless you do
     special effects.
               MR. ARNDT:  Yeah.  These are all center line
     calculations, along the --
               DR. KRESS:  Along the line of symmetry.
               MR. ARNDT:  Along the line of symmetry.  We will
     look at in a minute what it looks like off line of symmetry,
     and you will see it is a little more --
               DR. CATTON:  Anybody who gets such beautiful
     shocks, I don't trust it.  And I have used NPARK.
               DR. KRESS:  A shocking statement.
               DR. CATTON:  Usually you get wiggles, you get the
     wiggles just because the codes can't really treat the shock
     that well.  You have to do special effects in order to treat
     the shock.
               DR. KRESS:  Well, he had an extremely fine grid.
               MR. ARNDT:  Yeah.
               DR. KRESS:  And he had very, very small time
               DR. CATTON:  You get spikes.
               MR. ARNDT:  We also, like I mentioned, --
               DR. CATTON:  Magnitudes don't change a whole lot.
               MR. ARNDT:  -- did several sensitivities based on
     things like temperature.  We varied the temperature by 100
     degrees, and we saw fairly small changes.  We varied the
     size of the hole quite a bit.  We see significant amplitude
     changes, particularly in the pressure, because you are
     putting out a whole lot more fluid, so the pressure behind
     the shockwave will be considerably higher, but the basic
     phenomenology is fairly similar.
               Now, of particular interest is what is happening
     along the streamlines, and that is because one of the things
     we are really interested in is what is happening to the
     particles along this flowpath.  If you look at jet cutting
     tools, they are very high colonated, usually gets of water. 
     Reasonably high velocities, very high pressures, very high
     particle loading.  And they, of course, will turn when they
     hit the piece of metal you are cutting to, but the braces,
     as well as the actual water, will actually go forward.
               So, one of the things we wanted to look at was
     along the line -- not along the line of symmetry, but
     actually various jet streams.  The first is actually outside
     of this jet, and you can see it goes through a much
     different velocity and mock number profile.  If you look
     along these two, particularly, the third one here, which is
     fairly close to the center line, but off of it and does the
     turn, what you see is it, of course, accelerate, decelerates
     through the shock, comes to a steadystate during its turning
     here, and then as it goes up through here and starts
     accelerating again into the nozzle between the two, you get
     the accelerating again.
               This is basically where we got our 1,000 feet per
     second.  Somewhere in this range will be right off or right
     near the center line.
               Now, if you want to look at the particle
     velocities, you have to look at what the particles are doing
     in the fluid.  They are going to be accelerated with the
     fluid based on, in essence, a relative flow rate between the
     particles and the fluid, that gives you the driving force to
     accelerate them.  And in these particular cases, you can get
     all sorts of different forces associated with them, but the
     dominant one is the drag force on the particle.
               And if you use the basic Reynolds number for
     particles, the stand Stokes Law type calculation, what you
     get is kind of what you expect, although when we did it, we
     didn't think it was going to be this dramatic.  The smaller
     the particle, and if you will remember, our mean particle
     density was right in this area, a couple of microns -- I'm
     sorry, micrometers, what would happen is it would accelerate
     as it goes through the expansion, then it would decelerate,
     but the amount of acceleration and deceleration basically
     depending upon the size because you had -- you are driving
     the drag based on size.  We, as it turned out, for
     computational convenience, used the drag on a sphere.  We
     later looked at what would actually happen if it was not a
     sphere, which, obviously, a lot of aerosol particles aren't,
     and I will talk about that in a minute.
               Of particular interest, of course, is it takes a
     little longer for the heavier particles to accelerate, as
     you would think.  It also takes longer for them to
     decelerate.  Again, the particles that we were looking at,
     by and large were in this range.  And you see they drop off
     rather dramatically.  We have a few particles up in this
     higher range, but this wasn't real satisfying, so we want to
     look at this a little bit closer.
               If you look at the data for very high Reynolds
     numbers for particles -- let's see if I can find my graph
     here, you find that the standard and Stokes Law doesn't
     really apply very well.  And use the Stokes solution for the
     drag coefficient on a sphere with a relative Reynolds
     number, it will predict something like this.  If you go back
     and look at some of the experimental data in this, it
     doesn't really do that.  So if you go -- what we did was,
     for very low velocities, we used the Stokes solution.  For
     this intermediate range, we used an older solution, and then
     we also used the experimental data to try and redo this.
               What happens when you do that is the larger
     particles, even though they do slow down -- rather, speed up
     and slow down at a slower rate, they are considerably more
     dependent upon the fluid velocity than if you used the
     straight Stokes Law.
               So the real issue here, as we wanted to really
     find out, was what was the fluid velocity doing?  What was
     the particle velocity doing?  And then we can give that to
     our friends in --
               DR. CATTON:  Are these particles solid or what?
               MR. ARNDT:  They are assumed to be solid.
               DR. KRESS:  So your major conclusion is that the
     particles are going the same velocity as the fluid.
               MR. ARNDT:  They are going the same velocity as
     the fluid and, more importantly, they are moving with the
     fluid.  If you go back to the streamline analysis, they are
     moving with the fluid, and they are decelerating here, and
     they are also turning.  If they weren't moving with the
     fluid, they would have the tendency to go forward.  They
     would basically maintain their momentum and go forward in
     this direction.  So they are moving with the fluid and they
     are also moving at the fluid velocity.  So they do have the
     tendency to turn with the fluid due to the blunt body.
               DR. KRESS:  The first calculation using Stokes
               MR. ARNDT:  Yes.
               DR. KRESS:  They didn't follow the fluid.
               MR. ARNDT:  They didn't follow the fluid as much. 
     They tended to not be decelerated with the fluid because the
     drag coefficients were lower, so they would decelerate
     slower and also turn less.
               DR. KRESS:  Does that imply there might be an
     optimum drag coefficient?
               MR. ARNDT:  There probably would be.  Because
     aerosols are not nice perfect spheres, we also did a
     sensitivity study that increased the drag coefficient and
     decreased the drag coefficient by a factor of 10.  And I
     didn't plot it up for you because it is not in the report as
     a plot, but what basically happens is, by doing that, you
     move this up a little bit.  It comes in kind of like that.
               DR. CATTON:  So what this is saying is basically
     you can't erode the adjacent tube with a compressible flow.
               MR. ARNDT:  With this kind of compressible flow,
     with these kind of particles.
               DR. CATTON:  Is it because of the size of the
               MR. ARNDT:  That is primarily --
               DR. CATTON:  There are examples, in the old Nike
     Zeus program, they were going to steer it with the Cunard,
     and they just chewed a hole right through it.  In that case
     the particles were actually liquid, less penetrated.
               MR. ARNDT:  Yeah.
               DR. CATTON:  And the velocities weren't near these
     because it was still, it was in the nozzle, it was still
     turning.  And that kind of -- maybe the particles were
     bigger or smaller, I don't know.
               DR. POWERS:  I guess the question I have for Dr.
     Kress is, what impactors work?  That sonic jet is coming in
     on plates?
               DR. KRESS:  They work because the particles --
               DR. POWERS:  Can't make the turn.
               DR. KRESS:  Yeah, can't make the turn, that's
               DR. POWERS:  And don't stay with the flow
               DR. KRESS:  That's right.
               DR. POWERS:  And here they are tracking, this
     impactor won't work.  But one micron particles, one micron
     particles are the easiest particles in the world to get an
     impactor to work on, because they don't stay with the stream
     velocities at sonic levels.
               DR. KRESS:  Flow velocities through an impactor
     are smaller.
               DR. POWERS:  No, they can be sonic, but just
               MR. ARNDT:  Now, if this didn't --
               DR. CATTON:  The shock standoff distance seems to
     be quite large also.
               MR. ARNDT:  Yeah, it is.  If, for example, this
     was at sonic, or subsonic, you wouldn't have this kind of
     shock standoff.  Sonic velocities are down in this range for
     this particular fluid at this particular temperature.  Also,
     you have comparatively low particle loading in this
     particular case, which is something that we are -- I think
     Bill is going to talk about a little later.
               The sonic velocity is down in this range.  So if
     you assume that you have very near sonic velocity, say, for
     example, up in the next tube over, say, for example, this
     will expand and contract.  Then you are down here, but you
     are also at a much lower density not of the fluid, but of
     the particles themselves.
               DR. KRESS:  What do you mean lower density of the
               MR. ARNDT:  Well, as you spray this out, you are
     expanding the jet.
               DR. KRESS:  Oh, you are talking about number
               MR. ARNDT:  Number density, yes.  I'm sorry.
               DR. POWERS:  I also know its impact better when
     the number density is lower.
               MR. ARNDT:  Yeah.  This is the study we did and
     these are the conclusions we came up with.
               DR. HOPENFELD:  I would just like to make a quick
               MR. ARNDT:  Yes, sir.
               DR. POWERS:  Is this an item of verification?
               DR. HOPENFELD:  No, it is just a clarification,
     that is all.  For two phase flow, in subsonic flow, if you
     have gas and particles, the loading of the particles is an
     important factor because there is an interaction there, they
     tend to stack up.  That affects the standoff distance and
     their loading rate.  And I was just wondering, I am just
     making a suggestion, so I am not criticizing anybody here,
     maybe you should look also, look at it as a two-phase flow,
     set up the basic equation for it, and this way you can find
     out what the effect of concentration is, just like a
     two-phase flow equation basically, particles and gas.
               DR. KRESS:  I suspect your number density of these
     particles is so small, you are not going to affect the sonic
     velocity in this case.  It is a pretty small number density
     there, so it looks pretty -- it is mostly acting like a gas.
               MR. ARNDT:  And, of course, if you have any
     additional questions, I am available tomorrow, and, of
     course, we can provide additional input.
               MR. HIGGINS:  You didn't have a slide on the
     conclusions, but you said verbally that the conclusion from
     that was that they would not, the particles would not erode
     the other tube.  That wasn't really the objective of this
     part of the study.  Part of the study objective was to
     provide particle and velocity -- particle and fluid velocity
     calculations to the Division of Engineering so they can look
     at what particles moving at those kind of velocities, in
     those kind of densities would do, and they are going to talk
     about that next.
               DR. KRESS:  The particles that are right on the
     line of symmetry have nowhere to go except impact the tube
     -- so those at least will go on and impact.
               MR. ARNDT:  Yes.  And we would expect them to
     impact in the two or three hundred meters per second kind of
     time velocity.
               DR. KRESS:  I guess the question may boil down to,
     do those particular particles do some sort of damage to the
     next tube?
               MR. ARNDT:  Right.  And Joe is going to talk about
     some of the experimental work he is doing on velocity,
     particles of that velocity and that size on actual pieces of
     zinc alloy.
               DR. MUSCARA:  Okay.  So, based on the information
     we have been gathering, we have set up some tests, tests to
     address the jet impingement under severe accident conditions
     to be conducted at the University of Cincinnati with
     Professor Tabakoff, and we are also in the process of
     planning and running some tests at Argonne National
     Laboratory under steamline break conditions.
               The conditions we are considering for the severe
     accident conditions, a temperature of 700 degrees centigrade
     and a pressure 2350 psi.  The particle loadings, we
     discussed earlier, taken from the code.  You see most of the
     particles are silver, about 85 percent of the particles are
     silver.  There are some oxides, 10 oxides dominant and
     indium oxide.
               The total loading is 115 grams per cubic meter. 
     The medium --
               DR. POWERS:  It is a little surprising you don't
     have any urania in that mix.
               DR. MUSCARA:  Any?
               DR. POWERS:  Urania.
               DR. MUSCARA:  You know, I suspect it has to do
     with its melting and volatilization temperatures.  If it is
     not volatilized, it doesn't get picked up in the stream and
     condensed later on into an aerosol.
               MR. TINKLER:  I am not sure we are claiming it is
     zero.  I think we have just listed the dominant species and
     compounds that might be present.  I doubt very seriously if
     it was zero UO2 in there.
               DR. KRESS:  It looks an awfully lot like it is at
     the stage of the accident where you have just failed the
     control rods and attacked the plant a little bit, but
     haven't gotten --
               MR. TINKLER:  That is also true.  You know, in
     past presentations, I have indicated that typically these
     are the conditions at the time that we normally predict the
     surge line or hotleg to fail.
               DR. KRESS:  Okay.  So you haven't really --
               MR. TINKLER:  They are still relatively early in
     the core degradation, overall rows core degradation process.
               DR. KRESS:  You have probably entered the high
     rate of steam zirc reaction.
               MR. TINKLER:  Yes.
               DR. KRESS:  Just barely probably.
               MR. TINKLER:  We are into the temperature
     escalation of the cladding and the core, but we haven't
     gotten to the formation of a large molten pool or things
     like that yet.
               DR. MUSCARA:  That is why we try about 700 degrees
     centigrade, it reflects the temperature of the tubes at the
     time of surge line failure, which is at 684 degrees under
     the 6 RU scenario that is described in many of Charlie's
               DR. SIEBER:  Once the surge line fails, the
     driving force can make the jet --
               DR. MUSCARA:  This is why we are concentrating
     here, yeah.
               DR. SIEBER:  So that is a reasonable assumption.
               DR. MUSCARA:  So the mean particle diameter is 1.5
     microns, most of the particles were less than 3 microns.  I
     think the distribution I saw, there might have been a few
     particles at 5, but nothing at all beyond 5.
               So before we are planning this work, we looked for
     places where you could conduct some experiments.  And it
     turns out there are a couple of rigs around the country.  At
     the University of Cincinnati, there is this apparatus that
     has been used for many years and many erosion studies
     conducted by Professor Tabakoff.  We decided that this was a
     place we could conduct some experiments.
               This is the rig that is used.  Essentially, there
     is a propane burner atop of the rig.  Air is mixed with the
     fuel.  Below this there is a preheater for the particles, so
     the particles are fed out to the preheater, with some time
     in residence to pick up temperature.  And then the particles
     are injected in the stream and there is a fairly long
     tunnel, acceleration tunnel.  And at the bottom, here is
     where the test specimen is.  There is a capability for
     changing the angle of the specimen with respect to the
               Beyond that, there is an exhaust tank where
     effectively these gases cool, the particles can drop out and
               Well, the atmosphere certainly is not pressurized
     steam, but it is an oxidizing atmosphere.  Most of the
     combustion products would be CO2 and steam.
               DR. KRESS:  What particles do you use?
               DR. MUSCARA:  Well, that is one of the following
     viewgraphs.  The predominant particles that we had in the
     aerosol, as mentioned, was silver.  And we can't use silver
     for these tests, in particular because the silver would melt
     in the combuster.  So we were looking for a surrogate
     material we could use for silver and still be conservative. 
     So what is important here, of course, is the density and the
     size of the particles, and essentially the hardness of the
     particles at that temperature.
               So when we compared different materials to the
     major particles in the aerosol, we settled on using nickel
     for the majority of the particles and to simulate the oxides
     with nickel oxide.  And, also, to be even more conservative,
     we were looking at some aluminum oxide in conjunction with
     the nickel.
               We did need information on the velocities,
     however, when we run these experiments, we like to go beyond
     the particular velocity that was calculated, just to make
     sure that we have enough information.  So we run tests from
     a lower velocity, about 300 feet per second, up to 1800 feet
     per second.  The initial series of tests were aimed at
     determining the worst conditions, so we ran a number of
     tests at 1,000 feet per second by changing the angle of the
     target.  We looked at, I believe, 20, 30 and 45 degrees, and
     the maximum wear rates were obtained at 30 degrees.  This is
     similar to many other tests that have been conducted.  This
     is a similar angle that produces the worst results.
               So the subsequent tests were run at 30 degrees and
     we varied the velocity and also the particle mix.
               Again, I must say that these tests are not
     complete, but we have completed tests with the nickel
     powders at 300, 600, 1,000, 1,800 feet per second, 100
     percent nickel.  The particle size, 3 to 7 microns.  And
     there is the initial data on the erosion rates.
               We are also planning on running tests with nickel
     plus 15 percent nickel oxide and nickel plus 15 percent
     aluminum oxide, and have completed some tests with the 100
     percent nickel oxides, thinking that this would be as
     conservative as one could get, all of the particles are the
     hard oxide.
               DR. POWERS:  Your data seemed to indicate that
     something unusual happens between 1,000 and 1,800 feet per
               DR. MUSCARA:  Well, there is the relation of the
     wear with respect to velocity.  Professor Tabakoff had some
     tests some years ago using 70 micron quartz and, clearly, he
     gets higher wear rates, but the velocity dependence is
     similar, and it is representative of what happens with
     mechanical abrasion.
               DR. KRESS:  Now, the units on this are cubic
     centimeter per gram per second.
               DR. MUSCARA:  Yeah, actually, those are converted
     numbers.  What we get from Professor Tabakoff from the tests
     are milligrams of material lost per milligram or gram of
     particles impacting the surface.  So we converted those
     numbers and are taking into account the temperatures.  We
     convert to get an estimate of the amount, depth of material
     that is worn.
               And for the 300 meter -- well, 1,000 feet per
     second, and with the nickel powder, the wear rate on this
     material is about 4 mils per hour.
               Now, I am not sure if I have a viewgraph on this,
     but the experiments we have conducted with the nickel oxide,
     in fact, we did not get anywhere.  We effectively had
     deposition.  There is the sample weight more at the end than
     it did before.  But at these temperatures, of course, the
     material is fairly soft, and the hard, abrasive particles
     embed themselves into the material.  They plow the material,
     they don't cut the material, so we had -- we didn't have any
     wear there.  So now we are going back and trying the nickel
     with 15 percent nickel oxide and also nickel with 15 percent
     aluminum oxide just to see whether there is synergistic
     effect there, but I suspect limiting data will be the data
     with just the nickel powder.
               You know, I have indicated that we will be running
     some tests for the steam line conditions, but in some of our
     prior work for different purposes, we are running some tests
     on different size orifices.  We did have one test where one
     32nd inch hole was impinging on the inconnel target.  This
     was a test at room temperature, with 2500 psi pressure, a
     four hour duration test.  At the end of the test we noticed
     only very light burnishing of the tube.
               We will run tests under more prototypic
     conditions.  Well, first, conservative tests at 2500 psi and
     300 degrees C, and then following those tests, we will
     consider running some tests that more closely reproduce the
     accident scenario.  There is the actual pressures and time
               DR. POWERS:  And these are liquid tests that you
     are talking about?
               DR. MUSCARA:  This would be tests where we
     effectively, on the primary side, we have high temperature
     water.  The secondary side will be dry and we will see what
               Well, I think quickly to conclude, we believe the
     damage by jet impingement, due to severe accident conditions
     in particular, is not going to be a concern.  We are doing
     additional tests, I think that will be confirmed.
               I guess, also, we conclude for the rest of this
     section, which has to do with the work that Bill will talk
     about tomorrow, but effectively develop models for
     predicting the structural behavior of a good tube, as well
     as degraded tubes under normal operating design basis
     accident conditions and severe accident conditions.  We will
     see all of that tomorrow.  But the models have been very
     good in predicting behavior and we have quite a bit of test
     data to validate those models.
               So I think at this point, I am finished unless
     there are some questions.
               DR. POWERS:  Any other questions on this
               I don't know these results are all stunning -- I
     mean surprising, are they, to you?  I mean, typically, when
     you use jets to cut things, you work with much higher
               DR. MUSCARA:  Much higher loading on the particles
     and much larger particle sizes.  Our meeting with the
     experts, they really felt there would not be much erosion
     under those conditions.  We felt that there was enough
     evidence from the literature and from the meeting that that
     would be the case, but we wanted to run some tests to verify
               DR. CATTON:  I think the use of a CFD code like
     NPARK, which is really, it is a code that has been around
     for a long time, it was originally developed by Los Alamos
     and then the Air Force picked it up, and they actually have
     an office in St. Louis whose only purpose in life is to
     incorporate everybody's experience.  It is a reliable code. 
     The only question one might have is the shock standoff
     distance might not be quite right.  But looking at the
     particle sizes, they are correct, and the drag coefficient
     is anywhere near correct, the tracking of the particles to
     the fluid velocity, you could have that shock standoff
     distance and it still wouldn't cause much of a problem.  I
     think they did a fairly substantial job in demonstrating
     that this particular aspect is not a problem.
               DR. POWERS:  My concern remains the same, it is
     counter-intuitive to me to have particles like that tracking
     the velocity so closely.  Because usually we rely on the
     fact that they don't track velocity closely in order to
     sample and trap them.
               DR. CATTON:  That's right.  That's right.
               DR. POWERS:  But I mean I have no experience that
     at these kinds of velocities.
               DR. CATTON:  My only experience was the opposite,
     and I cut a hole right through the device, but it was a lot
               DR. KRESS:  I would follow up a little on Dana's
     comment.  The code you are talking about doesn't have
     particles in it, it calculates the stream lines.
               DR. CATTON:  It is pure and simple a compressible
     flow code.
               DR. KRESS:  The question I have then is how did
     one translate the drag coefficients in order to see whether
     the particles followed the stream lines or not.
               DR. CATTON:  Well, you have to make an assumption
     when you do this.  The assumption is that the particle
     density is low enough that it doesn't impact the flow.
               DR. KRESS:  That is a reasonable assumption.
               DR. CATTON:  If the loading starts to go up.
               DR. KRESS:  No, that is a reasonable assumption on
     his loading we have here.
               DR. CATTON:  If you can make that assumption, then
     it is just a matter of fitting the particles into the flow
     field and asking, where do they go?
               DR. KRESS:  Do you have the capability of putting
     them in the flow field and changing the drag coefficient?
               DR. CATTON:  Not with NPARK, no.
               DR. KRESS:  As you move from one spot to the
               DR. CATTON:  I suspect what they did is they just
     have a data set with a velocity field in it, and they stuck
     the particle in and said, where do you go?  Is that correct?
               SPEAKER:  Yeah.
               DR. CATTON:  Yeah.  So once they have the velocity
     temperature and pressure fields.
               DR. KRESS:  So all you have to do is put one
     particle of each size at a given spot and watch it go?
               DR. CATTON:  That's correct.  That's correct.  And
     then just look at its trajectory.
               DR. POWERS:  I mean the place where we run into
     problems with that is so much higher that I mean I don't
     have any trouble with these assumptions.  I have troubles
     with the conclusion because I mean, how do we move particles
     across boundary layers?  They don't track fluid velocities. 
     And especially when you get up to a micron, I mean it is a
     micron where we have impaction problems.  You get much below
     a micron, then, yeah, they track the stream velocities
     pretty well.  Certainly, if you get down as low as a tenth
     of a micron, then they really track stream velocities well.
               DR. CATTON:  What are the drag coefficients? 
     These are --
               DR. POWERS:  It is a drag curve, a lot like the
     one he showed with the dots that come across there.  I mean
     the drag coefficients you had were about -- seemed all very
     rational to me.  So I am perplexed, I mean my experience in
     shockwaves is exactly zero.
               DR. MUSCARA:  I had almost forgotten, but there is
     another item on the agenda, and that is to discuss the
     behavior, the reasoning for the selection of the
     quarter-inch crack.
               DR. POWERS:  Right.
               DR. MUSCARA:  Steve.
               MR. LONG:  After what just transpired, I think I
     need to remember everybody that I am about to talk about
     what happened first.
               DR. POWERS:  In the beginning there were
     quarter-inch cracks, right.
               DR. KRESS:  Your first test is to see if you can
     turn the thing on.
               DR. POWERS:  If you can't turn that thing on, then
     we are not going to believe a word you say.
               DR. KRESS:  It is the big long bar on the front.
               MR. LONG:  There we go.
               DR. POWERS:  Now we have to listen to him.
               MR. LONG:  Okay.  To put this in context, when we
     did NUREG-1477, we were dealing with really just
     measurements of cracks in terms of voltage, and we didn't
     have length and depth information.  We were somewhat
     concerned about severe accident issues where there would be
     high temperature flowthrough cracks in tubes.  We didn't
     really -- I'm sorry.  We didn't really have any way of
     working with that until we got some distributions of crack
     sizes.  So, through a research contract, Dominion
     Engineering produced some correlations of crack sizes and we
     could proceed when we did NUREG-1570 work.
               DR. POWERS:  Correlations of crack sizes with?
               MR. LONG:  Well, basically, they were giving us
     results of a lot of different analyses that the utility
     companies had done with their distributions in their plants,
     separated out by distribution -- by degradation type, and
     then trying to give us a distribution of lengths and a
     distribution of depths.
               DR. POWERS:  This is just the database they
     maintain on what people find.
               MR. LONG:  I don't know if they maintained it or
     produced it, but we received it through the subcontract. 
     They didn't correlate the length and the depth, and when
     they did the correlations to the depths with the data, they
     used gamma functions that basically fit the data in the
     exponential part of the function and had offscale low in
     depth and in length, extremely high artifact peaks that
     didn't fit any of the data.
               So the difficulty was we ended up, when we tried
     to combine the two to get a distribution of physical cracks
     estimated, we would end up with a very large number of
     extremely short but extremely deep cracks.
               Well, when we looked at the temperatures and what
     we expected the cracks to behave like at the temperatures
     the tubes would reach before RCS pressure boundary failure
     in core damage accidents, the type of behavior we were
     seeing would have said a crack that was maybe 4/10ths of an
     inch long would be about as short as you would expect to
     rupture with a typical limit load analysis based on the flow
     stress, as best we could extrapolate it.
               So, we were aware of the DPO concern about
     cutting.  I think there was also some consideration of
     cutting when NUREG-1150, accident progression expert
     elicitation was done.  So we wanted to try to represent the
     cutting somehow assuming the cracks that were still too
     short to rupture would open significantly and might be able
     to cut adjacent tubes, or for that matter, erode the hole in
     that tube that the flow was going through.
               But the problem was we had a large number of
     cracks that could be throughwall that were perhaps less than
     a hundredth of the inch long in the correlation, and if I
     just put that in there, I had a probable certainty that
     those cracks would be present.  Should I assume they cut?
               Talking to the materials people, this was
     seemingly resolved with sort of the classical back of the
     envelope argument that stress corrosion cracking had
     typically as aspect ratio that was at least five times
     length to depth and, therefore, for a 50 mil tube, we really
     shouldn't see throughwall things much shorter than a quarter
     of an inch.
               That sort of became the cut-off in NUREG-1570 for
     looking at the distributions that were given to us by
               That picture sort of stayed in vogue until we
     really started doing profiles of cracks that were coming
     from plus point analyses of flaws found in power plants. 
     And the first one I was afflicted with was from Farley when
     they requested essentially a waiver of a mid-cycle
     inspection on the last fuel cycle before they replaced their
     steam generator tubes.  And the way this data was being
     treated is that the eddy current signals were being treated
     as planar cracks with jagged shapes, and then these were
     being projected over the cycle to grow, at least in depth,
     and I have forgotten if they were growing theirs in length. 
     Sometimes they are not grown in length, sometimes they are,
     depending on who is doing the analysis.
               At any rate, once they are grown in a Monte Carlo
     process by depth, they are analyzed for the fraction of the
     crack that might go throughwall and perhaps create a leak or
     go throughwall and burst.  And this is done by
     mathematically taking a rectangle, taking a small length and
     moving it along the crack, taking the average depth within
     that length, calculating the stress magnification factor,
     then taking a slightly longer length and doing the same
     thing until the find the part of the crack that has the
     maximum stress magnification factor for pop-through and the
     maximum for burst.
               What Farley found, very late in the review
     process, actually, Westinghouse was doing the analysis, was
     that they had a near certainty that they would have
     something go throughwall by growth during that cycle.  The
     concern was that they thought it was very short, and did we
     want to treat that as a complete failure of the primary to
     secondary boundary for the risk analysis?
               This was a difficulty because now we weren't
     talking about a whole crack that went throughwall, it was
     sort of a simplified rectangular approximation to the crack
     shape.  Now, we were talking about long cracks, they might
     be half an inch, an inch long, but we were only talking
     about a small segment, so we couldn't argue they don't
     exist, they probably do exist.
               So we had to figure out, did we believe a crack of
     a certain length that was throughwall would really open
     significantly and leak significantly?  We didn't really have
     data that would allow us to do this back when we were doing
     the Farley analysis.
               So it ended up with a telephone conversation late
     in the game.  Bill Shack was on it, Joe Muscara was on it. 
     I am sure Bob Keating was on it.  I think Tom Pitterly was
     on it, but I have forgotten.  I was, some people from the
     Farley site, and we were trying to figure out what we would
     do in this case.  Would we basically reject the application
     on the idea that some crack, not matter how short, would
     penetrate the wall during the fuel cycle?  Or would we stick
     with the quarter-inch or set some other value?
               And I think the general feeling was, from the
     people that had some experimental evidence but hadn't really
     been able to quantify it, so it was a qualitative feeling,
     that the quarter-inch crack was probably not going to be
     severely cutting, not in the timeframe that we thought we
     had before some other part of the pressure boundary would
     fail, if, in fact, this didn't fail first and relieve
               We didn't really know what number to pick.  It
     wasn't a quantified judgment.  So at this point what we
     decided to do was leave the crack at the quarter-inch as the
     threshold for what we would consider to be a gross failure
     and proceed with the application review.
               We wrote the SER and pointed out that the results
     would be sensitive to this conclusion.  I will go into the
     practices of risk-informed decision-making on my slides
     tomorrow, so at this point I will just say that one of the
     principles is to look at the things that your decision is
     sensitive to and the uncertainties.
               We put in that this was a judgment, and I know
     that that upset the DPO author because he felt should have
     something better to make a relaxation.  The best we could do
     at the time was to make that clear, that it was not an
     analytical result, it was a judgment, that we were sensitive
     to that judgment, and to modify the DPO considerations
     document as well so it was clear in there that this was an
     issue that we needed more information on.
               Subsequently to that, RES started the work that
     you just heard about.  That was actually before we formally
     got the letter over to them to request them to do that.  And
     as you have heard, at least from the cutting angle, it
     doesn't seem as though there is a real problem with the
     quarter-inch cracks.  And there is another aspect of this
     that has to do with how much those cracks would open up and
     leak, and Joe Donohue is not here today to present that, so
     I guess we will have to deal with part of that tomorrow.
               There is still then, now we are talking about
     quarter-inch openings that might exist, there is still the
     potential issue about how much leakage would you get through
     them.  And there what we would like to do is make sure that
     we are at least staying below the 1 GPM that is the current
     tech spec limit.
               In that regard, you would want to have, you know,
     very few cracks.  And another part of the work that I didn't
     hear about was to try to add the creep aspect of the crack
     opening, so that you could get a crack area and get a more
     valid calculation of leak rate tomorrow.
               I hope that explains the history of not answering
     all the technical questions.
               DR. POWERS:  Okay.  Any questions on this?  We
     have a quarter-inch cut-off for cutting, which may not occur
     at all, but we still, we don't have any cut-off for leakage?
               MR. LONG:  The leakage has not been handled
     quantitatively at this point for very small cracks, in terms
     of looking at a distribution and quantifying it through
               DR. POWERS:  Any other comments that the members
     would like to make?
               [No response.]
               DR. POWERS:  Well, on that note, I will thank
     everyone for some very nice presentations, very informative,
     and invite you all to reappear at about 8:30 tomorrow for
     some more of this fun.
               [Whereupon, at 7:00 p.m., the meeting was
     recessed, to reconvene at 8:30 a.m., Friday, October 13,

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