Advanced Reactors (Workshop on Regulatory Challenges for Future Nuclear Power Plants) - June 5, 2001


                Official Transcript of Proceedings


Title:                       Advisory Committee on Reactor Safeguards
                               Subcommittee on Advanced Reactors

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Tuesday, June 5, 2001

Work Order No.: NRC-244                             Pages 341-705

                   		NEAL R. GROSS AND CO., INC.
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                          UNITED STATES OF AMERICA
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                               JUNE 5, 2001
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                            ROCKVILLE, MARYLAND
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                       The Subcommittee met at the Auditorium,
           Nuclear Regulatory Commission, Two White Flint North,
           11545 Rockville Pike, Rockville, Maryland, at 8:30
           a.m., Thomas S. Kress, Chairman, presiding.
                 THOMAS S. KRESS, Subcommittee Chairman
                 GEORGE APOSTOLAKIS, ACRS Chairman
                 MARIO V. BONACA, ACRS Member
                 F. PETER FORD, ACRS Member
                 GRAHAM M. LEITCH, ACRS Member
                 DANA A. POWERS, ACRS Member
                 WILLIAM J. SHACK, ACRS Member
           COMMITTEE MEMBERS PRESENT (Continued):
                 JOHN D. SIEBER, ACRS Member
                 ROBERT E. UHRIG, ACRS Member
                 GRAHAM B. WALLIS, ACRS Member
                 B. JOHN GARRICK, ACNW Chairman
           Introduction, Chairman Thomas Kress  . . . . . . 340
           Presentation by Ron Simard . . . . . . . . . . . 346
           Presentation of Dr. Neil Todreas . . . . . . . . 368
           Presentation by Dr. Andrew Kadak . . . . . . . . 422
           Presentation of George Davis . . . . . . . . . . 469
           Presentation of Dr. Michael Golay  . . . . . . . 480
           Presentation of Dr. Charles Forsberg . . . . . . 533
           Presentation of Adrian Heymer  . . . . . . . . . 580
           Commission Discussion  . . . . . . . . . . . . . 627
                                                    (8:31 a.m.)
                       CHAIRMAN KRESS:  Will the meeting please
           come to order?
                       I have to read this mandatory statement. 
           This is the second day of the meeting of the ACRS
           Subcommittee on Advanced Reactors.
                       I'm Thomas Kress, Chairman of the
                       Subcommittee members in attendance are
           ACRS Chairman George Apostolakis.  That's him right
                       DR. APOSTOLAKIS:  On time, as usual.
                       CHAIRMAN KRESS:  On time and under budget.
                       Mario Bonaca.  I almost missed that one.
                       Peter Ford.
                       Graham Leitch.
                       Dana Powers.
                       William Shack.
                       Jack Sieber.
                       Robert Uhrig.
                       And Graham Wallis.
                       Also attending is the Honorable ACNW
           Chairman John Garrick.
                       The purpose of this meeting is to continue
           our discussions of the regulatory challenges for
           future nuclear power plants.  The Subcommittee will
           gather information, analyze relevant issues and facts,
           and formulate proposed positions and actions as
           appropriate for deliberation by the full committee.
                       Michael T. Markley is the cognizant ACRS
           Staff Engineer for this meeting.
                       The rules for participation in today's
           meeting have been announced as part of the notice of
           this meeting previously published in the Federal
           Register on May 10th, 2001.
                       A transcript of the meeting is being kept
           and will be made available as stated in the Federal
           Register notice.
                       It is requested that speakers first
           identify themselves and speak with sufficient clarity
           and volume so they can be heard.  If the people from
           the audience wish to make comments, ask questions, and
           so forth, please use these microphones on either side
           and also identify yourself and speak with sufficient
                       We have received on written comments or
           request for time to make oral statements from members
           of the public regarding today's meeting.
                       The morning session up until lunchtime
           will be here in this auditorium.  The afternoon
           session, we lose this auditorium, and we have to move. 
           The afternoon session will be in the ACRS Conference
           Room, T2B-3 on the second floor.  I think everybody
           knows where that is.
                       I don't have any additional comments.  Do
           any of the members, co-chair have any comments?
                       (No response.)
                       CHAIRMAN KRESS:  Seeing none, we will now
           proceed with the meeting and call on Ron Simard of NEI
           to start us off this morning.
                       MR. SIMARD:  Thank you.
                       Dr. Kress and I were just reminiscing. 
           When we first met each other 30 years ago, he was
           working on Generation IV concepts down at Oak Ridge.
                       This is probably not the most interesting
           title for this talk.  Sometimes I've taken to giving
           this talk and calling it "The Future Isn't What It
           Used to Be," because -- Jenny, would you go to the
                       Just a reminder as to what's changed, and
           today let's try to understand why it's changed and
           changing so rapidly, and then I'll try to tie that
           back to what it means in terms of challenges to the
           NRC in being able to respond to those changes.
                       But just to summarize what's different
           about out view of the future now is it's clear that
           we'll need more electricity.  This has been coming for
           a while as demand has grown, as we've eaten into our
           reserve margins.  We've seen it in the annual
           projections by DOE, the Energy Information
           Administration, and now we have the National Energy
           Policy out, which makes it pretty clear.
                       And the problem we have with that is that
           we are looking at -- even at the lower end of DOE's
           estimates, we're looking at increasing our generating
           capacity by almost 50 percent.  Fifty percent of a big
           number is a very big number, and it's not going to be
           possible to meet it entirely with fossil fuels,
           whether it's natural gas or coal.  
                       It's becoming increasingly clear that
           there are long-term concerns about the price of the
           fuel, as well as the physical inability to add that
           many more megawatts solely of fossil fired generation
           without violating clean air constraints.
                       And, on the other hand, we're seeing an
           increased prospects for nuclear energy partly because
           their economics are being perceived as potentially
           better in the future and partly because with
           restructuring in the industry and consolidation, we're
           moving toward a situation where a number of large
           generating companies, a small number, are increasingly
           moving towards operating the majority of our plants.
                       Now, I think that this is partly
           contributing to the increase we're seeing in the
           performance of the plants, this consolidation of
           expertise, but it also means looking forward that
           these folks have the capital to consider adding more
           nuclear plants to the fleet.
                       We're also seeing a significant change in
           public support and certainly political support.  I
           think Thursday of this week, for example, you'll see
           Senator Bingaman's bill introduced, which will help
           expand the nuclear work force not only for the
           industry, but for the NRC, the full range of the work
           force, and the public support has completely reversed
           itself even in California where now 60 percent of
           Californians tell the field poll -- this is not an NEI
           sponsored survey.  This is an independent  poll --
           that more nuclear energy is going to needed.
                       And finally, and this is what we're here
           to talk about today, that last bullet, the potential
           is there for increased certainty in the licensing
           process, and this is important because it's a new
           business environment, and we have to be able to have
           certainty with respect to what it's going to take to
           bring these new plants to market now in a restructured
                       Remember that 60 percent of our nuclear
           plants today, 60 out of 103 units, are operating in
           states where electricity restructuring has occurred. 
           So there is a fair amount of effort underway, which
           I'll try to summarize for you, to prepare for what we
           know are near term business decisions.
                       We know that several companies are
           beginning today to make their business plans and their
           decisions about whether to add more nuclear to their
           fleet, and, Jenny, let's go to the next slide.  I
           think the next slide might be even better to show you
           the scope of activities underway.
                       You have a copy of this in your handouts,
           and what it does is it tries to tie together the
           activities I just showed you on that previous slide
           and show you how they all come together in an
           integrated way.
                       Up at the top of the slide there, we need
           to change the very top of that slide.  The very top
           box refers to a seminal document that we've been
           working from for the last few years.  It's a document
           that sets the direction for nuclear energy going
           forward.  There's a new document.  As of last month we
           have something called "Vision 2020," which I'll talk
           about a little bit toward the end here, but what I'd
           like to show you here on this slide is that from that
           "Vision 2020," or from that statement, which by the
           way has been bought into by the NEI board of
           directors, that means the chief executives of all the
           generating companies and a fair mix of the other
           companies across the industry that belong to NEI.
                       At that level of industry leadership they
           have bought into this, and in fact, what you'll see is
           that the NEI business plan, our whole plan for next
           year and our budget, will, in fact, mirror this
           "Vision 2020."  It will conform with the objectives
           that we're going to be talking about today.
                       And under that we have a plan, and this
           plan assigns work in four areas, and the intent of
           this work is to take on as many of the open issues as
           we can in the next couple of years roughly and provide
           that certainty that the executives are going to need
           in their business decisions.
                       I might just point out on the extreme
           right-hand side, I think one of the most challenging
           things for us is the infrastructure, and I'm talking
           here about not only the people, but also the
           manufacturing capabilities, the equipment suppliers,
           the engineering services.
                       We had a kickoff meeting of a task force. 
           It's the second one in from the right, the work force
           issues task force, at NEI yesterday, which has
           representatives from the generating companies, the
           labor unions, the contractors who supply contract
           personnel to our plants, NRC and DOE, and the purpose
           of that is to identify the manpower needs for the
           entire industry, all aspects of running this operation
           in the future, and then to identify where the gaps
           are, and finally to lay out actions, how we're going
           to fill those gaps.
                       Now, going back to the licensing area,
           that box in the middle, you're going to hear about
           that later today, the new plant regulatory framework. 
           That's the subject of a separate presentation this
                       Let's focus on the other boxes over there. 
           Jenny, would you please?  Let's go to the next slide.
                       And let's talk about licensing, and in
           three areas in particular.  We're talking about the
           licensing needs in the very near term with respect to
           working out the Part 52 implementation details.  Also,
           with respect to not only assuring the safety, but how
           other types of NRC regulations will apply to these new
           types of designs, the kind of designs you heard about
           yesterday afternoon.
                       And finally, reflecting the fact that the
           next group of plants that's going to be brought to
           market may not be brought to market by regulated
           utilities in a cost and service environment.  Rather,
           they will be merchant nuclear power plants competing
           on their own merits.  They're going to sell all or
           part of their electricity to the market, and they're
           going to be run by some new approach to the ownership
           and risk sharing in these projects.
                       So let's talk about those three areas. 
           With respect to Part 52, let's go to the next slide,
           Jenny.  Maybe it's even better to look at this in a
                       Compare the top and bottom here.  What we
           have on the bottom is an efficient new approach to
           licensing future plants, and what's relevant to our
           theme today, talking about the uncertainties in cost
           and schedule, is the fact that this framework holds
           the promise for being able to bring these plants to
           market with a certainty we've never had before.
                       On the lower left-hand side, with design
           certification, which the NRC has now certified three
           advanced designs; with design certification, we also
           have this concept of ITAAC, inspections, tests and
           analyses, that you can perform and then acceptance
           criteria that show that, in fact, you've built the
           design that was certified.
                       That's key because at the end, the bottom
           right-hand side here, the focus in post construction
           hearings is on whether or not those acceptance
           criteria have been met.
                       So with design certification and the fact
           that it's been applied now three times, I think we've
           made tremendous progress.  What still has to be tested
           though are the other two key pieces of Part 52.  
                       On the bottom left, early site permitting. 
           So one of the things that we currently have underway
           are interactions among the industry and between the
           industry and NRC and public meetings to work out
           exactly how early site permitting will apply.
                       For example, if we're going to add
           additional reactors to sites that already have
           reactors up and running, sites that have already been
           reviewed by the NRC, the environmental characteristics
           are know, for example.
                       But then the other key and the other
           challenge to the NRC now is working out the rest of
           that line along the bottom.  Once the construction
           permit and operating license has been granted and once
           the licensee has this extremely effective construction
           schedule now, which is capable of bringing these
           plants to fuel loading in three years or less, how can
           the NRC superimpose its inspection process, and
           especially how will they, beginning for the first
           time, use this -- verify that, in fact, the ITAAC had
           been met?
                       So I think one of the larger challenges
           that we're working on today is construction inspection
           and ITAAC verification, and that's key.  It's key not
           only to being able to meet the licensee's construction
           schedule, but, again, it's key to that arrow on the
           bottom right, to being able to demonstrate to all of
           the stakeholders here, the licensee, the NRC, the
           public, all of the stakeholders, the key to being able
           to demonstrate clearly and unambiguously that the
           acceptance criteria have been met.
                       This is the second area we talked about. 
           Not only are these designs likely not going to be
           brought to market by regulated utilities who are going
           to put them in a rate base, get a guaranteed rate of
           return, but we're now, as you saw yesterday, talking
           about different designs.  They are not necessarily
           light water reactors anymore.
                       Some are.  We have three advanced light
           water reactors that are certified.  They're on the
           shelf.  They're ready to go, but other designs, like
           the ones you heard yesterday are modular, for example,
           and there's a list of four questions you need to ask.
                       If it's not a single reactor unit anymore
           but a series of modules, well, then how do some of
           these NRC regulations apply?  For example, you need to
           bring clarity to whether or not you can issue one
           license for five, six, seven, ten modules at the site.
                       You also have to clarify the requirements
           under Part 140 or Price Anderson.
                       That third bullet is key.  What about the
           annual fees, which is on a per reactor basis?
                       And then finally, the NRC regulations are
           quit specific as to the number and qualifications of
           people in the control room.
                       Similarly, in the second bullet, if there
           are gas cooled designs, the regulations, for example
           5075, currently give estimates for how much money
           you'll need to set aside over time to decommission a
           PWR or BWR.  What about a gas cooled reactor?  What
           about the generic environmental impacts which are in
           Part 51, those two tables that you see there?
                       And finally, what about the fact that
           you're going to have to redefine what are the
           appropriate actions to take as part of your emergency
                       On the next slide, here's the third
           example now.  Here's yet a third example of a number
           of issues that need clarification by NRC, given the
           fact that, again, these are not necessarily regulated
           utilities applying for a license. 
                       So if it's a merchant plant, for example,
           some of the issues that you see currently being
           discussed and need near term resolution are the
           previous requirements for an anti-trust review, the
           requirements for NRC to determine the financial
           qualifications, and finally what mechanisms are
           appropriate in terms of setting aside that money we
           talked about a minute ago for decommissioning of the
                       So those give you examples, I hope, of the
           types of challenges that are before us.  Now, let's
           just remind ourselves of the urgency.  If you believe
           DOE projections, and, by the way, you shouldn't
           because they've been consistently low.  For the past
           ten years, their annual projections have been on the
           low side, but let's take them at face value.
                       At their low end of their projections, we
           would need to add 400,000 megawatts of new capacity to
           the grid by 2020.  Now, today 30 percent of our
           generating capacity is non-emitting.  It's nuclear;
           it's hydro and some renewables.
                       Now, if all you wanted to do was maintain
           that 30 percent contribution to avoid getting into
           even more problems with clean air, you'd actually have
           to add 60,000 megawatts of new nuclear, 60,000
           assuming you can get maybe another 10,000 megawatts
           out of up rates, 50,000 new.
                       That's the basis for "Vision 2020." 
           That's what the industry announced last month at the
           Nuclear Energy Assembly.  That's what's going to drive
           us to the future.
                       Could you raise it a little bit, Jenny? 
           Are you able to?
                       DR. POWERS:  There seems to be a body of
           opinion that takes issue with this though.  I can't
           reproduce their arguments, but they seem to think that
           maybe we don't need that much electrical energy, and
           that we, in fact, can achieve the necessary energy
           supplied by conservation.
                       MR. SIMARD:  No question that conservation
           and efficiency are important, but it's folly to think
           that you're going to conserve your way out of having
           to add almost a 50 percent increase.
                       I mean the gains that we have made in
           conservation have been impressive, you know, at times,
           and efficiency has really helped quite a bit, but
           there's no way that you're going to conserve your way
           out of the low end of this projection without
           disruptive impacts on the economy.
                       So, you know, take issue.  You don't
           believe we need 400,000 megawatts?  Okay, fine.  Cut
           it in half.  Let's suppose that we're able to bring
           the sort of passion to this that we brought to the
           Manhattan Project, and we're able to achieve
           unprecedented levels of conservation and efficiency
           and shave that in half.
                       DR. POWERS:  You don't look like you're
           intimately familiar with the passion of the Manhattan
                       MR. SIMARD:  Well, seriously, I think that
           what you find now across -- yes, it's true.  There are
           still some people who will question that, the need to
           have that much electricity and they might even go so
           far as to say that we can keep our current demand
           steady.  I don't know.
                       But you don't find them having prominent
           roles in policy making anymore.  What you find among
           the policy makers, whether you read the
           administration's national energy policy or whether you
           look at the Nuclear Caucus in the Senate or the House
           Nuclear Issues Working Group, when you look at the
           bills that are currently out there from Senator
           Dominici, Bingaman, Murkowski, Mr. Gramm, you see a
           growing consensus, I think, among the policy makers
           that this sort of aggressive action is going to be
                       I mean this is what we could do.  To
           maintain that 30 percent, as you work your way up the
           bottom here, there's a small yellow band, which
           actually it's small on the scale, but 10,000 megawatts
           from power upgrades is actually pretty substantial.
                       And then you see what would have to be
           added, some 50,000 megawatts, and again, that's just
           to maintain the brackets there.  That's just to
           maintain the current contribution and to avoid getting
           into even more trouble with clean air.
                       So let me just summarize then over the
           next couple of slides.  The future isn't what it used
           to be because I think the consensus is here now that
           the demand will grow, and we used to talk about the
           nuclear option.  It's not an option anymore.  It's an
                       The business case for new plants is pretty
           clear, but we have to have cost and schedules known to
           a greater degree of certainty than we ever had before,
           which leads us into the challenge for the NRC because,
           as you saw a minute ago, the ability to bring this
           plant to make depends upon being able to work out
           these Part 52 implementation issues in a timely
           manner, and having in place efficient and,
           Commissioner Diaz's word, "scrutable" processes for
           early siting and licensing and construction
                       And I think what's emerging here from this
           day and a half is the challenge for NRC to be able to
           respond to this with a whole new focus and discipline
           and efficiency.
                       Thank you.
                       DR. POWERS:  One of the persistent
           problems that we encounter when new things are brought
           to this particular body is the documentation is
           incomplete, documentation is not rigorous.  Those
           kinds of things slow the process substantially.
                       Is the industry doing anything to try to
           address those kinds of questions?
                       MR. SIMARD:  I think the challenge on our
           side is to bring in an unprecedented quality of
           application.  On our side, we need to bring the NRC
           the highest quality information and application.
                       And I think what you're seeing both with
           the Westinghouse and PBMR North America International
           with NRC now is an effort early on to really clearly
           identify exactly what the staff needs are going to be
           to be able to do their review.
                       So I think that's encouraging, but you're
                       DR. POWERS:  For heaven's sake, solve the
           momentum equation properly.
                       MR. SIMARD:  You're right.  We need to do
           better, too, on our side.
                       CHAIRMAN KRESS:  Ron, one of your slides
           pointed out some of the regulatory challenges
           associated with multiple modules on a given site, how
           you deal with that with respect to site permitting and
           certain financial issues associated with that.  It
           seems obvious to me that what you should do is get a
           site permit for the maximum number of modules you
           expect to put on that and call it one facility.
                       Is that something your guys are proposing
           or is that --
                       MR. SIMARD:  Yeah, and maybe -- in that
           area maybe "challenge" is too wrong a word here. 
           Maybe we're getting carried away by the theme of the
           workshop here.  Some of these things ought to be
           fairly straight.
                       CHAIRMAN KRESS:  Yeah, that one looks
           pretty clear to me.
                       MR. SIMARD:  But the point is they do
           though require either a clarification or a change to
           the current NRC implementation requirements.  So, no,
           I think that's a good point.
                       Some of these shouldn't be challenges. 
           They're pretty straightforward.
                       DR. APOSTOLAKIS:  In one of your earlier
           slides on new licensing process significantly reduces
           project risk where you have the chart, maybe we can go
           back to it.  They're not numbered, but, the heading is
           "new licensing process significantly reduces project
                       MR. SIMARD:  Yeah, it reduces the
           perceived business risk on the part of the licensee,
           and it certainly provides for earlier and more meaning
           parts of --
                       DR. APOSTOLAKIS:  It's the fifth or sixth
           from --
                       MR. SIMARD:  Yeah, she's got it now.
                       DR. APOSTOLAKIS:  Oh, yeah, that is the
                       When you say at the bottom here
           "acceptance criteria met," I guess the acceptance
           criteria, do we have those now or --
                       MR. SIMARD:  Yes, in the three designs
           that have been certified, a key feature and a high
           level of detail in those certifications are the ITAAC. 
           So they're clearly specified.  In the ABWR, for
           example, the high pressure core flooder system, I
           understand there were 31 separate ITAAC that clearly
           focus on the performance of a pump, for example.
                       What inspections or tests will be done on
           that pump and what acceptance criteria will be
           necessary to show that, in fact, that pump is going to
           deliver the amount of water you need at the time you
           need it?
                       So in the design certification, a key
           feature of them has been these ITAAC.  We need to add
           a few more that are site specific when the licensee
           brings you the application, but --
                       DR. APOSTOLAKIS:  So in terms of Part 52,
           which you cited as one of the major challenges, the
           implementation of Part 52, and if I look at this
           particular chart, where does the implementation of
           Part 52 come into the picture?  Just the whole
                       MR. SIMARD:  Well, there are actually
           three pieces to Part 52.  The bottom left there,
           there's one that outlines design certification.  Then
           there's one that outlines early site permitting, and
           then in the middle there on the bottom, there's one
           that talks about the conditions on granting a
           construction permit and operating license.
                       And then finally it also covers at the end
           of construction and prior to start-up the basis for
           the NRC determination that the plant is ready to go.
                       DR. APOSTOLAKIS:  Well, yesterday there
           was a lot of discussion of using risk information in
           all of this.  So if I were to choose one of the
           designs that have not been certified yet, then the
           potential for using risk information is on the left
           where it says "design certification"?
                       MR. SIMARD:  Oh, no, certainly.  But what
           about all the way across?
                       DR. APOSTOLAKIS:  All the way.
                       MR. SIMARD:  Yeah, when the NRC has to
           dust off its construction inspection and program and
           apply it now to these new designs, this new
           environment, but with the knowledge that we've gained
           over, you know, the past 30 or 40 years, it certainly
           would make sense to focus on the aspects of
           construction and the completion of SSCs that are most
           important to safety, and I think in our interactions
           with interactions with NRC on this subject, which are
           about to begin this month, we'll certainly be looking
           at it from our point of view.
                       DR. APOSTOLAKIS:  So we'll hear more about
           this this afternoon, I understand, right?
                       MR. SIMARD:  I don't know that you will. 
           You know, from Adrian Heymer you're certainly hear
           about the proposal that we have in mind for the
           overall regulatory framework, but in terms of the
           specifics of how NRC might modify the inspection
           manual --
                       DR. APOSTOLAKIS:  No, no, no, no.
                       MR. SIMARD:  No, that's still something
           that needs to be worked out.
                       DR. APOSTOLAKIS:  Sure.
                       CHAIRMAN KRESS:  Any other questions from
           the audience or other members?
                       DR. APOSTOLAKIS:  There is one here.
                       CHAIRMAN KRESS:  Ah, good.
                       MR. ALLEY:  Neil Alley.
                       In your projections for energy demands
           looking forward, what assumptions did you make about
           plan life extension?
                       MR. SIMARD:  You know, i'm not sure.  If
           you're asking specifically about "Vision 2020" and how
           we're going to meet the need for 60,000 new megawatts,
           I think that we assumed almost all the plants are
           going to go in for license renewal.  I can't tell you
           for sure though whether it was 100 percent or, you
           know, maybe we drop back a bit, but certainly the
           feeling in the industry is that all or almost all of
           the plants are candidates for renewal rate.
                       But also remember -- I'm sorry.  The real
           answer to your question is this is 2020.  All right? 
           So you wouldn't see a significant number of today's
           plants reaching the end of their life anyway before
                       DR. POWERS:  Yeah, there are a bunch of
           them.  Without license renewal, there are a bunch of
           them that are out by 2014, some by 2007.  Yeah,
           license renewal is very important.
                       MR. SIMARD:  But anyway, the answer is at
           this point it looks like all, if not -- it looks like
           all or almost all of the plants are candidates.
                       DR. POWERS:  About 80 percent.
                       MR. QUINN:  Dr. Kress, it's Ted Quinn.
                       Ron, good morning.  The reason for success
           in the license renewal process to a large extent was
           the project management role that was put in place with
           a lot of work by NEI with a lot of work by the NRC,
           and a suite of documents that became part of the
           process, the GALL report, the NEI guideline.
                       Have you considered working with NRC on a
           similar type of suite of documents to help us make
           this a more stable framework?
                       MR. SIMARD:  Yeah, I think you're right,
           Ted.  That's been a good model in the past.  By
           bringing to bear the range of industry resources and
           expertise on an area and combining that with the NRC,
           I think we've wound up with a better quality product
           in the end and improved the efficiency of the process.
                       So building on our success with license
           renewal, maintenance rule or other things like that,
           yeah, it's our intent to put a lot of thought from our
           side into how -- for example, the format of an early
           site permit application, and that's something we
           actually have underway, or with respect to
           construction inspection at ITAAC verification, it's
           our intent to bring together the folks who still have
           construction experience in the industry, if we can
           find them, and again, drawing upon their expertise and
           our knowledge of how Part 52 -- the basic principles
           of Part 52.
                       Again, it would be our intent in cases
           like that to bring in a document and ask the NRC for,
           you know, its review and reactions and use that as the
           framework for these productive discussions. 
                       CHAIRMAN KRESS:  Well, thank you very
           much, Ron, for this very informative and interesting
                       Then we will turn to the next item, safety
           goals for future nuclear power plants, and I'm
           certainly looking forward to hearing this one.
                       By the way, Neil, I know that you don't
           need any introduction, but the fact is I don't have
           any introductory material so you have to introduce
           yourself at this particular meeting.
                       DR. POWERS:  I'm dying to know what a
           KEPCO is.
                       DR. TODREAS:  KEPCO in the title speaks
           basically to the success of the Asian countries in
           developing nuclear power and up till now the lack of
           success in the U.S.   So the Korea Electric Power
           Company gave a chair to MIT in nuclear engineering,
           which I hold, and the Tokyo Electric Power Company
           gave a chair to nuclear engineering that Mughid
           Khazzami (phonetic) holds, and we're still waiting
           perhaps nationally for one of the U.S. utilities to
           step in.
                       DR. TODREAS:  Okay.  What I'm going to do
           is stand here.  My intention is to address you guys
           relative to this question of future nuclear plants and
           also bring the audience up to speed in terms of our
                       Yesterday, the DOE folks were here, and
           they talked about the program, and it's called really
           a Generation IV reactor development program, and it
           covers the near term, which is zero to ten years;
           deployment, in that period; and then from 2010 to 2030
           the development of what's called Generation IV plants.
                       So the word "future" here means a lot to
           different people.  What Ron just spoke about in terms
           of my focus was the near term deployment, mainly zero
           to ten years.  So you have to switch horses now in
           terms of the safety goals that I'm talking about
           relative to future plants are aimed at the 2010 to
           2030 developments.
                       You can take these goals, focus them back
           and ask what about the near term deployment plants,
           but in a sense that isn't fair because you know some
           of them are already certified.  If they're not
           certified like the ESBWR, they've been under
           development for years, and so they've been aimed
                       There are also nuclear power plants in
           terms of near term deployment, and you'll see that
           although I was given this title, our goals are on
           nuclear energy systems, the difference.  Nuclear
           energy systems brings in the whole fuel cycle.  In
           terms of our activities, we put the whole fuel cycle
           on the spectrum.
                       So with those introductory remarks, I just
           want to conclude by saying John Garrick is on the
           group with Saul and I, Saul Levy and I leading it, and
           we have five, six rather, other people on the review
           committee overseeing the DOE activity and offering
           comments, and John is a valued member of that
                       So if I could start, having talked to the
           people in front of me before at times, I thought I'd
           start off and tell you how not to construe this talk
           or how to misconstrue it to try to get you on the
           right approach.
                       So first, it's the talk and then the
           goals, and then we'll get into it.
                       So the way you follow this slide is four
           points here, is really what I'm talking about down
           below.  So I'm not talking about the NRC safety goals. 
           That's the first thing that probably jumps to your
           mind when I say safety goals.
                       We're generating what we call technology
           goals.  These are goals to drive new reactor systems
                       DR. WALLIS:  Are you going to mention the
           word "risk"?
                       DR. TODREAS:  Risk?  Maybe at the very
           end, but actually Graham, that is one of the themes. 
           What I want to do or what we want to promote through
           this program is technological innovation and
           development, and we want to structure things so that
           we can promote that and not clamp down too early.
                       Of course, risk has to be mentioned from
           the beginning.
                       We are not suggesting regulatory
           requirements for future plants.  These goals are
           formulated to stimulate innovation, as I've already
           said, and the goals, of course, as you're going to
           see, are general, and there's a group that's following
           up to put specific metrics on each of the goals so
           that we can use those.
                       We also use those to sort out concepts
           from among -- we've gotten effectively almost 100
           concepts or pieces of concepts submitted into the
           program, and these have to be sorted out, selected,
           and areas of R&D picked out either generic along a --
           if a set of concepts come together in a technological
           direction, will pick out the R&D that's relevant to
           this set, and push ahead.
                       And so we're going to need to make some
           selection, and the selection will be based on metrics
           which are derived from the goals which are now being
           worked on.  That's what the word "metric" means here.
                       I mention the point we're not talking
           solely about power reactors.  We're talking about fuel
           cycles, and the power reactor is part of this.  We
           started this before the national energy policy was
           announced.  It's interesting that there's some
           consistency there, but it wasn't a grand plot.
                       And then finally, I'm not talking about
           goals for near term deployment plants.  I mention that
           point.  We're talking in the range 2011, 2030 or 2010,
                       We go to the next slide.
                       I've got a few points to mention on how
           not to misconstrue the goals.  One way to misconstrue
           them is to assume that future plants must meet every
           goal or must even exceed every goal, and what you're
           going to see is these goals are fairly encompassing. 
           Just immediately, to put some meat on those bones,
           we've got issues of fuel utilization,
           nonproliferation, and waste, and through the fuel
           cycle there's obviously got to be a tradeoff among
           those areas, and the tradeoff -- there's multiple
           tradeoff solutions available and some of them will
           favor one of those factors.  Some of them will favor
           another factor.
                       I'm almost convinced that you won't be
           able to come up with some scheme that will uniformly
           meet and exceed all of these goals.  So --
                       DR. POWERS:  I'm glad that you mentioned
           the word "tradeoff."  One of the questions that comes
           to mind, especially after the previous speaker
           portrayed something of a crisis appearing, I wonder if
           in looking at these goals and looking at new systems
           that you compare the more modern or the existing
           plants against him to see if we really need all new
           concepts, and the 94 new concepts that were portrayed
           to us yesterday or, in fact, how well do the existing
           plants meet these various goals that you've laid out?
                       DR. TODREAS:  The answer to that is on the
           metrics that we're going to develop to assess these
           new concepts.  We've picked a standard, and the
           evaluation process will measure these new concepts
           against the standard.  Is it better, much better, et
           cetera, worse, much worse, and the standard we picked
           is the advanced LWR with once through fuel cycle.
                       The rest of your question asked me what's
           the answer going to be, and I don't know that yet.
                       DR. POWERS:  I find that a peculiar
           standard to pick because we don't have a whole lot of
           experience with advanced LWR, or if we do with
           existing machines, we have a lot of experience, and
           that experience, at least my friends at NEI certainly
           provide metrics that suggest that experience is
           outstanding right now.
                       DR. TODREAS:  And is the implication that
           the advanced LWRs will be less --
                       DR. POWERS:  I have no idea what they are.
                       DR. TODREAS:  -- performers than --
                       DR. POWERS:  I have no idea how they'll
           do.  I certainly have opinions on a couple of them,
           but I have no proof.  Whereas with some of the
           existing machines, I know exactly what they're doing. 
           I've got data I can point to.
                       DR. TODREAS:  I can see thinking about
           that, but if we're going to develop advanced systems,
           I would say from the vendor community and the
           development community, we've got ABWR experience to an
           extent, and we have some degree of real respect for
           what the designs have accomplished in the ALWR.
                       And I would say as a minimum you'd include
           both, but I certainly wouldn't go back just to the
           operating reactors as the standard for the future.  I
           wouldn't ignore the 15 years of ALWR development.
                       CHAIRMAN KRESS:  Well, you probably have
           three criteria.  You want them to be safe, and you
           want them to be economic, and you want them to be
           acceptable to the public and other people.
                       I would say the current place is certainly
           safe enough if you compare them to certain safety
           standards, but I would guess economics might be a big
           driver, especially the capital cost.  I'm not sure.
                       DR. POWERS:  The numbers I see suggest
           that they're producing power as cheaply as anybody.
                       CHAIRMAN KRESS:  I know.  That's because
           they've already gotten rid of their capital costs, and
           they're just talking about operating costs, but I
           would suspect these new designs are much cheaper to
                       DR. POWERS:  Well, I wonder how much it
           would cost to build a plant today, a current plant
                       CHAIRMAN KRESS:  Well, that's a good
           question, and I'm not sure I know the answer to that.
                       DR. POWERS:  I don't know the answer
                       CHAIRMAN KRESS:  My guess would be the new
           designs would be cheaper to build, but then there's
           that third attribute, and that's acceptability, and I
           suspect newer, safer, inherently -- plant that has
           these attributes that we're looking at might be more
           acceptable from the standpoint of the public.  
                       DR. POWERS:  Yeah, I don't know.
                       CHAIRMAN KRESS:  I don't know.
                       DR. POWERS:  You're giving up 3,000
           reactor years of operational experience when you make
           those statements, and --
                       CHAIRMAN KRESS:  Well, maybe.
                       DR. POWERS:  -- I don't think we've begun
           to discover all of the ways that you can run afoul on
           some of these modern control systems.
                       CHAIRMAN KRESS:  Yeah, you have a good
           point there.
                       DR. TODREAS:  Okay.  Well, I think you
           guys will have plenty of time to focus on that one
           actually when you get your next certification
           application as well, but let's say that point's on the
           board.  We can chew it further later if we desire.
                       I'll carry on on these goals down at this
           point.  The desirable outcome from this program and
           effectively the goals which are going to drive this
           program I believe is a spectrum of designs, each of
           which best meet possible future market conditions.
                       For example, we don't know, although we
           think uranium will be cheap in the future, in fact, as
           cheap as it's been in the past, but we don't know that
           for sure.  So it would be nice to have advanced
           designs on the table as the output which could respond
           in either direction.
                       If you want to have designs which would
           respond in either direction, then these alternate
           designs effectively would be aimed at optimizing and
           exceeding certain goals in one direction and then
           meeting, but exceeding other goals in the other
                       So you want a spectrum of results, and
           therefore, different goals will drive you in these
           different directions.
                       the next point is some of the goals, in
           fact, one presently appears unattainable.
                       CHAIRMAN KRESS:  That one really surprises
                       DR. TODREAS:  Well, why don't we wait for
           the full discussion when I get there?
                       CHAIRMAN KRESS:  Okay.
                       DR. TODREAS:  But the point I want to make
           is don't jump on it now.  We want a goal that will
           drive design and innovation.  We can't meet it no, but
           does that mean we shouldn't write it in?
                       That's the question.  I know you've read
           ahead.  We'll get to it where we cover S&R3, Safety
           and Reliability 3.
                       And then finally, as I mentioned, the
           goals in terms of their specificity purposely have a
           little generality to them because we are talking about
           reactor systems that we want to bring on in this time
           frame, 2010 to 2030, which gives us an opportunity to
           innovate.  So we don't want to squeeze down too early
           on that.
                       DR. WALLIS:  And, Neil, we're still not on
           the subject of misconstruing goals, are we?
                       DR. TODREAS:  Yeah, I am.
                       DR. WALLIS:  You are?  Okay.
                       DR. TODREAS:  Yeah.  The point of
           misconstruing there is why are they general.  They're
           general to open the door.
                       Next point.
                       The next point is that one can misconstrue
           these goals by assuming that all the safety
           considerations are under the title of the grouping
           "safety and reliability goals."  
                       To go ahead, we have sustainability goals,
           three of those; safety and reliability goals, three of
           those; and economic goals, two of those.  So a quick
           reading would say, hey, let's just look at the safety
           and reliability goals for safety implications.
                       Now, we should be all smarter than that to
           realize that future designs are going to involve new
           cycles and a broader range of energy products.  So
           we're going to get into new fuel materials, higher
           burn-ups, longer operating cycles, higher temperature
           operation, and all those design directions bring in
           safety considerations as part of it.  They have all
           been reduced specifically to risk criteria, but
           there's tremendous safety opportunities and safety
           factors that one must consider as part of the
           sustainability and, in fact, the direction that the
           economic goals will drive us to.  That's the point of
           this figure.
                       Now, with that, we can go to the next one
           and start on the goals.  the logic in framing these
           goals cycled many times because obviously there was a
           large community involved in deriving these goals.
                       What we finally felt was it would be
           desirable to group them and then have these
           subcategories, and the first grouping that we picked
           was sustainability with the idea that if nuclear power
           was going to stand head and shoulders strong relative
           to alternate energy generation approaches into the
           future. we had to address and label part of the goals
           through the sustainability label and really place or
           position nuclear power and the product that came out
           of this product as a sustainable product.
                       You can get into arguments on this in the
           sense that sustainability if you go through the formal
           definition kind of projects it out without any time
           bound, and yet nuclear power in terms of fuel that
           we're going to use has a long time horizon, but it's
                       There we didn't basically accept that
           point and, therefore, say nuclear power will no be
           sustainable, but we really took the bit and through
           the first goal effectively positioned nuclear power
           product as a sustainable product.
                       This, I've given you the words, but the
           words in red are the words that we got into the most
           discussion about  because this went through the NERAC
           process, and NERAC is -- let me call it a balanced
           committee.  So there's viewpoints on all sides of the
           drivability and the effectiveness of nuclear power.
                       If you've been in the business a longer
           time and you're a nuclear engineer, when you think of
           fuel utilization, the word "high fuel utilization"
           jumps to your mind.  This word that's here, which is
           "effective," is a long, negotiated word.  It doesn't
           say we've got to go toward high fuel utilization
           because if you say you've got to go toward high fuel
           utilization, you immediately prejudice the outcome, so
           it is viewed, and with some justification.  You
           prejudice it toward the fact that you definitely need
           a breeder, and also that fuel economics are going to
           come and constrain you in this 20-year time frame.
                       And that definitely is a view that
           definitely is not held throughout the review
           structure.  So the word "effective" here means that
           you balance fuel cycle economics with environmental
           considerations and with nonproliferation
                       So effective fuel utilization implies that
           a tradeoff is going to be made between those factors
           because when I said fuel cycle economics, if, in fact,
           we have uranium constraints, that will drive up the
           price, and that will be reflected in fuel cycle
                       In terms of Sustainability 2, that issue
           comes down to saying something about nuclear waste. 
           We have got two key words here, minimize and manager. 
           Manager is not controversial, but the word "minimize
           nuclear waste" was very controversial, and it was
           controversial in the sense that the other viewpoint
           was that minimization isn't really what you're after. 
           What you're after is even beyond toxicity.  It's
           ultimately burden to public health and safety, and
           there's a lot of different factors and a lot of
           different streams that finally get you down to that.
                       We effectively pick that up through
           reduced long-term stewardship burden, but we -- and
           now I'm talking about our review committee and the DOE
           whole project -- we still felt that there's great
           advantage going into the future with systems that
           minimized the waste generation because if you minimize
           the waste generation, you at least tend to reduce
           pressure which comes from the pile-up of large amounts
           of waste, and the question of what do you do after
           Yucca Mountain.
                       And I was going to say hopefully.  What do
           you do hopefully after Yucca Mountain, with the
           "hopefully" being hoping Yucca Mountain gets moving?
                       On the third one on Sustainability 3, this
           has to do with nonproliferation, and there was a
           special group that was run by John Taylor called TOPS
           on nonproliferation where that issue was debated, and
           they effectively came up with these words:  very
           unattractive and least desirable group.
                       And that comes from the view that we're
           going to have intrinsic and extrinsic barriers to
           proliferation.  Hopefully they're mutually supportive
           in that you can do something intrinsically that may
           have a positive effect on external barriers and vice
           versa, but the view is that there's no silver bullet
           here.  We're not going to come up with a fuel cycle
           that from an intrinsic point of view puts the
           nonproliferation issue to bed.
                       And therefore, we're going to come up with
           schemes that are very unattractive and are the least
           desirable group.  That's how those words came about
           and why they're important.
                       We go to the next slide.  Here we have the
           safety and reliability slides.  They're set up in the
           logic of maintaining excellence in safety and
           reliability.  Here we're really focusing on accident
           initiators, reliability of operation of plant. 
                       Actually it stimulates a point relative to
           what Dana Powers mentioned.  We do want to capture all
           the lessons, all of the positive lessons from
           operating plants and put those into these Generation
           4 systems relative to their ability to operate with
           safety and reliability.
                       This goal, when you're working on advanced
           plants, you really at least in the conceptual stage,
           you really always focus down on the second two goals,
           and what we wanted to do was actually put something
           right up front that reminded all of the designers, all
           of the conceptual innovators that fundamentally the
           plant operating through steady state and through
           transience had to capture this base.
                       Now, when we come to the second goal, then
           we get into the traditional language, dialogue that
           we're all used to about low likelihood and degree of
           core damage.  So we, of course, want to emphasize
                       DR. POWERS:  One of the ways of assuring
           that you have minimal --
                       DR. TODREAS:  What was the verb you used? 
           One of the ways of?
                       DR. POWERS:  Assuring --
                       DR. TODREAS:  Assuring.
                       DR. POWERS:  -- that you have minimal core
           damage would be to release all of the fission products
           so that you have no decay heat.  Release them as
           they're generated.  That would meet this goal.
                       DR. TODREAS:  You would have to release
           them and sequester them because we're talking about
           systems, but along the line you're talking about, we
           get them out of reactor core system where we might
           have less control into a system that wasn't operating. 
           Not a bad --
                       DR. POWERS:  My point really is that I
           think this goal is perplexing in the context of the
           kinds of designs that people are coming up with where
           classical core damage doesn't really occur, but you
           still worry about fission product releases.
                       And why not cast the goal in terms of
           release of radioactivity?
                       DR. TODREAS:  Oh.  It's -- maybe, maybe. 
           That effectively leads to number three, where we're
           talking about the need for off-site emergency
           response, various ways to do that and fission
                       Fission products actually could be the
           whole story down here, and you might think about
           writing it that way.  I'm not sure, Dana, whether just
           off the top, whether writing it that way would capture
           the end product or not, but it's simulating --
                       DR. WALLIS:  I think that while you're
           being innovative, you should not use -- you seem to be
           here really talking about core damage frequency, and
           that just may get you in a box, and I think to be
           innovative, to follow up with Dana, you really ought
           to get away from these terms of the past and be more
                       CHAIRMAN KRESS:  And after all, I think it
           is fission products we're worried about.
                       DR. TODREAS:  I think that's a reasonable
           point.  If I've got you guys or if you've got me
           saying that we ought to get away from terms of the
           past which will lock us into certain design directions
           and means of dialogue, that is really my whole
           message, too.
                       And if you're offering me a suggestion
           that says, hey, what you wrote doesn't go that way;
           you should go a different way, then I'd perfectly
           accept it.
                       DR. GARRICK:  I think we have to be a
           little careful to unduly focus on fission products
           because for many of the most important scenarios it is
           not the fission products that's driving the long-term
           performance of Yucca Mountain.  It's mainly -- well,
           technetium and Iodine 129 certainly are in there, but
           depending on the scenario and depending on how you
           look at it, Neptunium 237 is the principal driver.
                       And also, in most low level waste
           situations, you find that much to our surprise most of
           the low level waste is uranium contaminated.  So,
           again, the fission products are not driving the long-
           term stewardship or management of a lot of the low
           level waste, but rather it's actinides.
                       The same thing is true in WIP for
           transuranic waste.  Again, it's not fission products,
           but it's plutonium.  So --
                       DR. POWERS:  The distinction between
           captured products and fission products I'm not sure I
           would draw.
                       DR. GARRICK:  Well, it sounded like you
           were drawing that.  It sounded like you were drawing
                       DR. POWERS:  I wouldn't do that.  I would
           call them radionuclides maybe.
                       CHAIRMAN KRESS:  We put quotes around the
           words "fission products" at ACRS.  When we say that,
           we mean all of those things that you talked about.
                       DR. GARRICK:  Well, then I think we need
           to be more precise.
                       CHAIRMAN KRESS:  Yeah, precision would
           have helped there.
                       DR. TODREAS:  But that also refers back to
           the sustainability goal.  It really doesn't obviate
           the suggestion relative to S&R 2 here relative to core
           damage.  I say that because what Garrick's comment
           really impacts on is the waste issue, not effectively
           the immediate release through core damage.  Okay.
                       CHAIRMAN KRESS:  I'm intrigued by that
           third bullet.  Are you going to talk about it some
                       DR. TODREAS:  Yeah.
                       CHAIRMAN KRESS:  In particular, do you
           have some sort of criteria on what it would take to
           eliminate this need?
                       And if so, does that criteria encompass
           some sort of measure of defense and depth also?
                       DR. POWERS:  I would go even farther and
           say that what more tangible proof of the concern over
           the public do you have than an emergency preparedness
           zone, and what are you going to replace that tangible
           proof with?
                       CHAIRMAN KRESS:  That's another way to
           view it, yeah.
                       DR. TODREAS:  Yeah, but that's how you
           guys ought to look at it.  
                       Will you skip to S&R 3?  It's the third
           viewgraph after this.
                       CHAIRMAN KRESS:  Number nine.
                       DR. POWERS:  Number nine.
                       DR. TODREAS:  Yeah, page number 9.
                       From the point of view of a regulator or
           a group advising a regulator, and we got into this
           discussion immediately, the immediate question comes
           to mind.  Okay.  It's find that you guys got this
           goal, but what are we going to do about it?
                       And this goal doesn't say at all that in
           the first instance you people need to back off about
           planning for emergency response.  This is about the
           misconstruing right at the beginning.
                       These are technology goals.  These are
           goals we want to drive the designers into thinking
                       CHAIRMAN KRESS:  How would you know if you
           met that goal?  That was my question.  What is the
           measure that you're going to use to say, "Okay.  The
           technology we have here meets that goal."  Whether or
           not it actually comes about or not is another thing.
                       DR. TODREAS:  The measure has got to be
           release of I'd say fission products or radioactivity
           of a certain amount past the boundary.
                       DR. POWERS:  I can always find a way to
           get that many fission products out.  There's no
           conceivable design; I can't imagine a scenario that
           will result in release of excessive amounts of fission
                       DR. TODREAS:  That would prevent it or
           that would --
                       DR. POWERS:  Any design you come up with
           I can find a mechanism to get the fission products
           out; the point that it violates some emergency
           planning guide.
                       CHAIRMAN KRESS:  Yeah, there has to be a
           frequency involved there is what he's saying partly,
           and my question is:  is that value of fission products
           a value that you would meet, for example, the early
           fatality safety goal without evacuation?  That's one
                       DR. TODREAS:  That's one possibility. 
           What I did here is, well, we have written a discussion
           under each goal.  I worked hard on Paragraph 1.
                       The debate was effectively you write down
           something now that you don't have a way in your own
           mind of achieving or do you come short of that and,
           you know, put some numerical or put something that
           kind of reflects current technology?
                       So in the interest of intellectual
           honesty, we wrote in its demonstration may prove to be
           unachievable, and this is what Dana Powers basically
           just said.  He's saying as he sits on this group, and
           I presume and I hope he'll sit on it for a number of
           years, all of these designs which come through which
           claim that they can meet it, he's going to shoot the
           hole in them.  Quite possible.
                       But --
                       DR. APOSTOLAKIS:  Dana would never do
                       DR. TODREAS:  But that is a reason to
           write this goal down, because if you're really talking
           about future systems and vulnerabilities of future
           systems, it's this whole -- and ultimately public
           acceptance, it's this whole idea of off-site response
           that's a very, very significant issue.
                       DR. WALLIS:  Now, this includes you
           started your talk saying you were looking at the whole
           fuel cycle.  So presumably this includes fuel
           fabrication, transportation, any kind of reprocessing.
                       DR. TODREAS:  Yes.
                       DR. WALLIS:  You seem to have focused,
           again, on the reactor in this discussion, and --
                       DR. TODREAS:  In the discussion below, not
           in the goal above.  I'm just scanning it.
                       DR. WALLIS:  Off site radiation then means
           in the fuel fabrication facility as well, for
                       DR. TODREAS:  What was the word you --
                       DR. WALLIS:  Well, you're looking at the
           whole fuel cycle you said in the beginning of your
                       DR. TODREAS:  yeah.
                       DR. WALLIS:  And now I got the impression
           in talking about these goals you were focusing once
           again on the reactor itself.
                       DR. TODREAS:  Yeah.  It may be true that
           in the oral persona that I'm putting across my years
           as a reactor designer come through, and I should be
           pulling back, being consistent with nuclear systems,
           and as I read this discussion here, there's nothing
           here that's focused on the reactor.  It's general to
           all of the facility.  
                       So it's --
                       DR. WALLIS:  Well, it talks about off
           site.  I mean off site presumably in transportation
           includes off the truck or something.
                       DR. TODREAS:  Yeah, okay.  Off site, of
           course, carries with it, yeah, we have to -- we have
           to go through and scrub it.  I agree.
                       CHAIRMAN KRESS:  But I would love for
           someone to tell me exactly what it takes to meet this
           goal.  I personally think I know, and I'd like to have
           some corroboration of that some time.
                       DR. TODREAS:  Okay.
                       DR. POWERS:  And I'd like to know why
           you'd want to.
                       CHAIRMAN KRESS:  Well, that's another
           issue, yeah.
                       DR. APOSTOLAKIS:  I'd like to come back to
           the safety and reliability, goal number two.
                       DR. TODREAS:  Could you flip back the
                       DR. APOSTOLAKIS:  Page 6.
                       DR. TODREAS:  Go to page 8.  It gives you
                       DR. APOSTOLAKIS:  Yeah.  In fact, I was
           looking at page 8.  
                       It seems to me that when the discussion a
           few minutes earlier brought up the issue of fission
           product releases and as a possible candidate for
           replacing this, it focused too much on the safety, and
           here it says safety and reliability, and if you go to
           page 8, it says this goal is vital to achieve
           investment protection.
                       So it seems to me that I can have serious
           damage even with the new designs to my investment, and
           still I don't release anything.  So the words "reactor
           core damage," I think, were a little bit provocative
           here because yesterday we heard speaker after speaker
           saying this is something of the past, and you know,
           this core cannot be damaged. 
                       But I'm sure that one can define what we
           call plan damage states in PRAs, where you are not
           really releasing anything outside anyway, but your
           investment has been, you know, severely hurt, and the
           NRC is up in arms. 
                       So the challenge will be to define those
           states, but I think by taking the words out, "reactor
           core damage," and finding some other words, not going
           all the way to fission product release, this goal will
           serve safety and reliability.  You may need a fourth
           goal regarding fission product release.  I don't know,
           but that, again, as you say, these are technology
           goals.  They are not regulatory goals.
                       We will definitely have to look at fission
           product release.  I mean there's no question about it.
                       DR. POWERS:  You think?
                       DR. TODREAS:  Yeah, let me pick up on
           that.  This is on page 8, if you back into that.
                       We very much had investment protection on
           our mind as well, and in fact, that's why on the
           second line I've got that highlighted.  Originally, or
           through a large part of this dialogue, in that goal we
           had the additional statement about preserving the
           plant's ability actually to return to power I won't
           say promptly, but to return to power over a period of,
           let's say, months, with the idea that we wanted to
           preserve the investment by having a design that
           actually could come back.
                       So that's what was in the second line. 
           That one in the discussion, the comments actually came
           back as in the third one as to how would you ever do
           it.  If you got core damage, it's just so much based
           on our experience that core damage, even to a minor
           degree, is going to really impact negatively the
           ability of the plant to return to power.
                       DR. WALLIS:  Well, supposed you have a
           core which is fluid.  You just flush out the back part
           and start again.
                       DR. TODREAS:  Yeah.  Well, see, that's the
           point.  If you get locked back into solid fuel pins,
           et cetera, you can't conceive --
                       DR. WALLIS:  But you're being creative.
                       DR. TODREAS:  What?
                       DR. WALLIS:  You're being creative. 
           You're looking at all kinds of things.  There may be
           things where you can just flush out the damage and
           keep --
                       DR. TODREAS:  Well --
                       DR. APOSTOLAKIS:  How about if you
           replace, say, generation for nuclear energy systems
           will have a very low likelihood and degree of plan
           damage, period?  To be determined later.  At this
           point you're high level.
                       DR. TODREAS:  Well, in relation to
           Graham's point, we kept the idea here by actually
           putting it in the second sentence.  The --
                       DR. WALLIS:  The second sentence is
           terrible.  The possibility is either zero or one, and
           you reduce the possibility.  I mean, that's crazy. 
           You're just trying to avoid the word "probability."
                       How did you ever let anybody use the word
           "possibility" in here?  That zero or one, isn't it?
                       DR. TODREAS:  Where is "possibility"?  Oh,
                       DR. WALLIS:  On three.
                       DR. TODREAS:  The second -- yeah, the
           third line, "reduce the possibility."
                       DR. WALLIS:  Well, we shouldn't pick on
           words, but I mean, I think --
                       DR. TODREAS:  No, that is fair because
           these words in this paragraph get reduced to more
           specific items subsequently.  So the guidance in this
           paragraph is aimed at developing more specific
           metrics, and to the degree if that occurs that these
           words cloud the ability of the subsequent group to
           develop the metrics, it's fair game.  So you've made
           the point.
                       Follow up.  You're shaking your head.
                       DR. WALLIS:  Well, the word "possibility"
           is inappropriate.
                       DR. TODREAS:  Oh, that's what I said. 
           You've made your point.
                       DR. WALLIS:  All right.  Okay.  So you
                       DR. TODREAS:  The other point that I
           wanted to make down here was there was a lot of
           discussion about passive safety features, and this is
           written basically to say evaluate them, but there is
           a community and a viewpoint that passive safety
           features compared to active safety features should be
           strongly encouraged.
                       It seemed to those of us putting these
           things together that that was a design tradeoff.  It's
           not necessarily obvious that the passive safety
           features throughout to be preferred, to be preferred
           and to push out active features.
                       That's more of a detail, a trade-off, and
           while we wanted to have passive features examined, we
           didn't want to push them unduly.  That's the
           significance of these words at the end.
                       I haven't followed all of your
           deliberations and views on that, but I would presume
           it's consistent.  If not, I presume I'll hear about
                       DR. APOSTOLAKIS:  I have a comment in the
           middle of the paragraph.
                       DR. TODREAS:  Yeah.
                       DR. APOSTOLAKIS:  This is a factor of
           about ten lower in frequency by comparison to the
           previous generation of LWRs.  That's not quite
           accurate.  In fact, it is inaccurate.
                       It is a factor of ten lower than the
           regulatory goal of ten to the minus four.  There are
           many LWRs right now that have core damage frequency
           ten to the minus five or less.  So it's less than the
                       DR. POWERS:  There is a body of opinion
           over here that thinks that that may be true for
           operational events, but not for the total core damage
                       DR. APOSTOLAKIS:  That's right, but I
           don't think that's what they meant here.
                       DR. POWERS:  Well, I think he should be
           looking at all of those things.
                       DR. APOSTOLAKIS:  This is a factor of
           about ten lower in frequency by comparison to the
           previous.  I don't think you have any basis for saying
           that it's a factor of ten lower than the current
                       There are plants that are low even now.
                       DR. POWERS:  Plants that certainly claim
           to be low.  That's right.
                       DR. APOSTOLAKIS:  That's right.
                       DR. GARRICK:  But you do have to remember,
           George, that the PRAs still are limited in scope with
           respect to such subtle issues as modeling uncertainty.
                       DR. APOSTOLAKIS:  Sure.
                       DR. GARRICK:  And a real genuine treatment
           of uncertainty, which is still lacking in a lot of the
           contemporary PRAs.
                       DR. APOSTOLAKIS:  What I'm saying is that
           it should not be the intent of a document like this to
           pass judgment on the current generator of reactors. 
           The factual statement is that this is a factor of ten
           lower than the goal.  Now, whether it's reality is a
           different story. 
                       DR. TODREAS:  Yeah, the objective of this
           was to report reality, not to pass judgment.  I mean,
           certainly your statement and your point is clear and
           noncontroversial.  If this goes over the step, then --
                       DR. APOSTOLAKIS:  Well, then it seems to
           me that somewhere else you should say that these
           probabilistic risk -- I mean that these goals that are
           being stated here should be from all modes of
           operation, from all -- you know, to make sure that --
                       DR. TODREAS:  That's the second sentence,
           an additional sentence that we could put after that.
                       DR. GARRICK:  But the real thrust of this
           was the recoverability issue.  If you're going to have
           a goal and improve on it, you'd like to, if you have
           another Three Mile Island, to be able to recover the
           plant, and that's why there was --
                       DR. APOSTOLAKIS:  So plant damage we're
           talking about.
                       DR. GARRICK:  Yeah.
                       DR. APOSTOLAKIS:  Not core damage.
                       DR. GARRICK:  And so the other thing
           that's important, too, with respect to words like
           "possibility" is that we were trying to be extremely
           sacred with respect to what's in the box.  The rest of
           this is discussion and explanation, but it's what's in
           the box that we were hopeful --
                       DR. APOSTOLAKIS:  "In the box," what do
           you mean by "in the box"?  Which box?
                       DR. TODREAS:  Well, in the box at the top.
                       DR. APOSTOLAKIS:  Oh, oh, oh.
                       DR. TODREAS:  But nevertheless, John, as
           I said, the follow-up does take the write-up and
           transfer it to metric, but what's in the box, do you
           see what's in the box now, George?  Is the specific
           goal statement.
                       DR. APOSTOLAKIS:  Yeah.
                       DR. TODREAS:  So there you can go after
           core damage versus broader.  That would affect the
           very specific goal.
                       DR. APOSTOLAKIS:  And also I'm not sure
           that you need both the likelihood and degree.  A very
           low likelihood of plan damage, period.  At this high
           level I think that would do it because plan damage can
           be anything, and then you can define plan damage as
           something I can recover from very easy.
                       DR. TODREAS:  No, but see, degree is in
           there because degree leads to the ability to recover.
                       DR. APOSTOLAKIS:  Yeah, but that's
           inherent there.  I mean it's understood.
                       DR. TODREAS:  No, I mean, you could have
           plant damage extent across a spectrum, and we wanted
           to cut that spectrum back.  that's why the word
           "degree" --
                       DR. APOSTOLAKIS:  I think very low
           likelihood and degree -- that doesn't sound good to
           me, but --
                       DR. TODREAS:  Okay.
                       DR. APOSTOLAKIS:  -- because the
           likelihood refers to the degree, right?  It doesn't?
                       PARTICIPANTS:  No.
                       DR. TODREAS:  No, I don't see it that way,
           but --
                       CHAIRMAN KRESS:  I think the two go
           together.  I'm with George on this one.  You have a
           likelihood of something.  That something is a degree
           of core damage, and there's a spectrum, but the
           likelihood goes with --
                       DR. APOSTOLAKIS:  I want to have very low
           probability and the non-damage states.  What does that
                       DR. TODREAS:  You say likelihood of
           significant plant damage, but I think you have to
           qualify it or add something to it some way.
                       DR. APOSTOLAKIS:  but you have to say
           something as to which noun the word "likelihood"
           refers to.  Likelihood of what?
                       CHAIRMAN KRESS:  Core damage.  It's the
           likelihood of core damage of such a degree that it is
           recoverable from.
                       DR. APOSTOLAKIS:  That's the correct --
           yeah, that's the complete statement.
                       DR. TODREAS:  Okay.  Except we are not
           going to go in in the box statement of the
           recoverability from that explicitly.  We just got all
           tied up on that.
                       DR. WALLIS:  Now, to be general, your core
           damage also includes what happens to it when it is
           taken out of the reactor.
                       DR. TODREAS:  Yes.
                       DR. WALLIS:  And put in a pool, for
                       DR. TODREAS:  The whole --
                       DR. WALLIS:  The whole smear.
                       DR. TODREAS:  Okay.
                       CHAIRMAN KRESS:  Do you feel like we're
           picking on you, Neil?
                       DR. TODREAS:  No, because what I was going
           to do, I was going to request from the Chairman that
           we get a letter with some suggested comments and --
                       PARTICIPANTS:  No.
                       DR. TODREAS:  -- and I did.
                       DR. POWERS:  The only one that can request
           letters from us is the staff and the Commission.
                       CHAIRMAN KRESS:  We only write letters to
           the Commissioner.
                       DR. POWERS:  We only write reports.
                       DR. APOSTOLAKIS:  -- write to the
           Commission commenting on the goal.
                       DR. TODREAS:  We'll take your comments and
           suggestions and views any way we can get them, but
           they would be helpful.
                       DR. APOSTOLAKIS:  By the way, in two or
           three days there will be a transcript available.
                       CHAIRMAN KRESS:  Yeah, transcription.
                       DR. TODREAS:  That's fine.
                       Let me go to number ten, which is the
           economic goal.  Two points here.l  In the discussion
           of economics, the word "clear" is here with
           considerable debate.  Again, there's several
                       The pragmatic and certainly the majority
           viewpoint was that if nuclear power of these nuclear
           energy systems are going to have a future, they're
           going to have to penetrate a market, and the only way
           you penetrate a market, particularly given the history
           of nuclear power costs, is for the new product to have
           a clear advantage.
                       The other viewpoint is that nuclear power
           is going to be needed in the future.  There will be
           environmental imperatives that will promote it and
           draw it in, and it's unfair to require that it have a
           clear advantage.  All it needs to do is be
           competitive, available, and await the demand from the
           evolving market, which will emphasize new
           environmental points of view.
                       DR. WALLIS:  Well, presumably all you have
           to do is put the environmental cost into the cost and
           add up all of the costs and then your statement is
                       DR. TODREAS:  Yeah, well --
                       DR. SHACK:  What as a technology goal, I
           don't think clear -- certainly as a goal you'd want to
           have a clear advantage.  Now, whether you need that to
           be economically competitive is another question
                       DR. TODREAS:  Going back to Graham's
           point, what I interpret you're saying is take all of
           the energy systems take all of their costs and make
           them internal to them.
                       Interestingly on the NERAC Committee where
           we've debated this one extensively, the non-nuclear
           members, and particularly the non-nuclear economic
           people basically say that will never happen.  Don't
           hold that as a pipe dream.  Proceed and compete on the
           situation as it presently exists, and effectively
           don't wait for the non-nuclear energy systems to
           actually have their extrinsic costs picked up.
                       So while it sounds great, we all agree
           it's logical.
                       DR. WALLIS:  It's like Safety and
           Reliability 3.  Maybe even if it seems unattainable
           you should try.
                       DR. TODREAS:  But we basically didn't want
           to -- well, let me actually back up and ask you again. 
           Your point I got was an observation that if other
           energy systems made their external costs intrinsic,
           then this would fall out.
                       DR. WALLIS:  No, I think it comes out
           politically, too, and if the coal plants in the Middle
           West that claim the fish in the New England lakes,
           then that is a cost to somebody, and it's not a
           negligible thing.  It figures out in the political
           decision somehow.
                       DR. TODREAS:  It's a huge cost.
                       DR. WALLIS:  Right, right.
                       DR. TODREAS:  Well, we agree.  The
           question will then come when you make this judgment
           have you brought in into the alternatives their full
           life cycle cost.
                       DR. WALLIS:  Right.
                       DR. TODREAS:  We're together on that.
                       And the only point I was making, the
           advice we got is don't hold your breath till
           officially those are subsumed, and in fact, those
           people are not pushing that these other alternative
           energy sources should subsume and have them made
           visible, which is what I think the real deficiency is.
                       Okay.  And then finally on Economics 2,
           the question came up and came up fairly strongly:  why
           have it?  If you've got Economics 1, you've got the
           financial risk reflected already in the life cycle
           cost, and so Economics 1 effectively is a complete
                       The response to that was to get nuclear
           energy systems going, somebody is going to have to put
           up the capital to start with, which is a risk capital,
           and although all might be balanced out, ultimately in
           the life cycle cost analysis, you still have to come
           up initially with this capital, and that is going to
           need to be bounded, and therefore, it needs to be
           focused on.
                       DR. WALLIS:  Well, I'm not quite sure
           here.  It seems to me that one and two go together. 
           If the nuclear energy systems have a tremendous cost
           advantage and they're very profitable, people will be
           willing to take more risks to invest in them.  So
           they're not independent, as you know.
                       DR. TODREAS:  Yeah.  That's what I just
           got finished saying.  I agree with you, but at the
           beginning of the project, you still have to put up an
           investment, and it's still a risk, and if that amount
           is focused on minimized or comparable, then getting
           the ball rolling is easier.
                       And so Economics 2 was put in there in
           reflection of that view.
                       Okay.  So then the last figure is just a
           summary as to where I've been, but an important
           summary.  So let's go to that.
                       I've done it in three bullets.  The first
           bullet is to reemphasize to you that future reactors
           fall in three categories or more, but at least three: 
           those that are certified or derivatives of certified
           designs, those designed to a reasonable extent and
           based on available technology, and then those in
           conceptual form only, with the potential to more fully
           satisfy the Gen. IV goals, and it's this third group
           that these goals are directed at.
                       There's a lot of activity in the second
           one.  You'll hear about the gas reactor, IRIS, et
           cetera, but these goals are directed at Gen. IV plants
           in the 2010 to 2030.
                       DR. WALLIS:  Well, this is true.  I'm
           sorry, but it seems to me that a case could be made
           that present plants satisfy almost all of your goals,
           except for this off-site emergency response one; that
           they're becoming more economical; they're profitable;
           that they're safe.  They have a low probability of
           core damage. 
                       I mean it's all done already.
                       DR. TODREAS:  Yeah.  With some respect to
           you, Graham, if you go back to Sustainability 1, you
           will get into one hell of an argument that present
           plants or advanced ALWRs or anything on the once
           through fuel cycle is responsive to the sustainability
           goals, one, two and three, to enough of a degree.
                       That's where the argument is focused.
                       DR. POWERS:  I mean, it seems to me then
           you're complaint, your argument is with Congress over
           the reprocessing issue.
                       DR. TODREAS:  Or recycling, but there's no
           argument.  What we want to do and what we've got
           imbedded in this program is an ability to reexamine
           the fuel cycle, and so my point is this.
                       DR. POWERS:  I mean that seems like a big
           enough challenge that I would leave the plant alone
           and go reexamine the fuel cycle.
                       DR. TODREAS:  The plant is a piece of that
           fuel cycle, but when you say that plants in the --
           either operating plants or the first two out of the
           three bullets meet these goals, they don't -- the
           sustainability goals is a spectrum, of course, on
           there, and there are views that with regard to
           nonproliferation, with regard to waste those plants on
           the once through fuel cycle are good enough.
                       But if we're going out 30 years, we get an
           opportunity to do something better in that, and even
           if you're debating the whole spectrum of people who
           impinge on nuclear power decisions, they won't accept
           that the operating plants are good enough on those
           sustainability goals.
                       That's where it's focused.
                       CHAIRMAN KRESS:  Actually our assumption
           at this meeting in general is that NRC will be faced
           with licensing some sort of new reactor or Gen. IV
           reactor or Gen. III reactor.  Therefore, the question
           is a bit moot, I guess.  What we're interested in is
           what are the challenges that are going to be faced
           through the regulatory process when and if such a
           design comes forth.
                       We know how to license the present
           reactors.  So, you know, I think it's a different
           subject as to whether the present reactor ought to be
           the next iteration or whether or not we should focus
           on the advanced reactors.
                       This is an Advanced Reactors Subcommittee. 
           So I'm making the assumption that there will be some
           sort of advanced reactor that we have to deal with in
           the regulatory process.
                       DR. TODREAS:  Okay.
                       CHAIRMAN KRESS:  That's just to put things
           into perspective.
                       DR. TODREAS:  Yeah, I would just say a
           follow-up to this along the lines you're talking about
           is what I was prepared to discuss later in the
           afternoon, the challenges, but my challenges are going
           to be technological challenges coming out of the fuel
           cycle.  That's the bottom line.
                       CHAIRMAN KRESS:  Okay.
                       DR. TODREAS:  Okay.  Then the second
           bullet says we're looking for a range of design
           options that respond to various marketing demands, and
           I've got those in the four subpoints, and then the
           final bullet down here is I think what we started off
           agreeing on earlier in the discussion, that the
           dialogue, at least my point is the dialogue between
           the regulators and the designers relative to advanced
           plants, and I'm talking there about these Gen. IV
           plants has got to be framed to promote and encourage
           fundamental design evolution, revolution directions.
                       And in that sense, the interactions that
           come out of this I think require -- here I'll mention
           the word "risk" now -- require the development of a
           regulatory framework which is based on risk based
                       And I think we need to move to that kind
           of structure and certainly that kind of dialogue as
           you interact and as the staff interacts with the
           conceptual and the development of these advanced
                       That's the bottom line message.
                       CHAIRMAN KRESS:  Questions or additional
                       MR. LYMAN:  Ed Lyman from Nuclear Control
                       I think that there are a few goals that
           are really missing from this whole formulation.  First
           of all, under sustainability you refer to one that
           minimizes, that a goal is minimizing and managing
           nuclear waste, but at the same time, you really should
           impose a requirement that the routine emissions from
           the entire fuel cycle, as well as, let's say,
           occupational exposures are also minimized because one
           of the concerns with fuel cycles that involve
           reprocessing are these additional routine emissions,
           and you have to balance whether the reduced risk in a
           repository is justified by increased short-term
                       So that's really something you have to
           keep to minimize at the same time or it doesn't make
                       Second of all, under the financial goals
           issue, you didn't really dwell on the one that
           requires or suggests that the financial risks should
           be comparable to other energy projects, and I was
           wondering if in that context you would also have a
           requirement then that Price Anderson protection not be
           extended to Generation IV plants because other energy
           projects don't require that kind of protection.
                       DR. TODREAS:  Yeah, on the first point you
           brought up, the specifics of that have been recognized
           and will come up in Safety and Reliability 1 because
           there we are talking about across the whole fuel
           cycle, and those routine emissions are picked up
           there.  They could be picked up either place, but
           that's where they come up.
                       And on Price Anderson, we didn't get into
           the specific item within the structure of the goal
           that can be picked up and debated.  It's been debated
           to some extent, but we didn't pin it down and resolve
           it specifically.
                       I know that's coming up legislatively.
                       MR. BARRETT:  I'm Richard Barrett.  I'm
           with the NRC staff.
                       And my question relates to the methods
           that we use for estimating the likelihood of core
           damage and the likelihood of release of radioactivity.
                       If NEI is correct and we have 50,000 new
           megawatts of capacity out there, and those are modular
           reactors -- that's 500 cores, and in an environment
           like that you find yourself striving for lower and
           lower core damage frequencies, and as you do that, you
           begin to put more and more stress on the current
           methods of estimating core damage frequency, and you
           begin to get to the point where many people think
           you're beyond the capability and the limitations of
           the method and the ability to have a complete model.
                       And in addition, as you move to different
           types of reactors, you find that you're depending less
           and less on highly reliable, redundant, and diverse
           systems and more and more on the intrinsic capability
           of the core itself to withstand these accidents, and
           to withstand them either indefinitely or for long
           periods of time.
                       And, again, the methods that we have today
           really don't deal very well with this kind of
           intrinsic, passive capability.
                       So my question to you is the stated
           purpose of your effort is to stimulate innovation in
           the design of the reactors, and my question is:  could
           you also complement that with trying to stimulate
           innovation in the methods that we use for analyzing
           the risk associated with these reactors?
                       DR. TODREAS:  Yeah, I would answer that
           two ways.  First, it's a good suggestion and a fair
           suggestion.  There's nothing implicit in -- what's
           going to come out of this fundamentally is a spectrum
           of concepts to focus on, but much more than that, an
           R&D road map of activities to flesh up those concepts
           and the methods associated with those concept
           development is certainly part and parcel of that.  So
           we could do that.
                       The other thing though that I'd say
           implicit in a response is, you know, if the future
           were to evolve the way it is and even if we were to
           develop the methods, and we're going to have to reduce
           core damage frequencies further to get a desired
           output.  So that really leads you to say that if you
           go with concepts now that are clones or like -- I'm
           talking about 20, 30 years down the road -- that are
           like these, you're going to reach a point where the
           methods can only go so far based on the existing
           approaches, and so that's a clarion call to change
           those approaches and go toward -- well, first, you go
           toward situations that avoid core melt, but that's
           very limited in a sense that what you really want to
           do is do what Dana Powers was talking about.
                       It's not core melt.  It's the fission
           products, and it's the radioactivity in the dose from
           that, and that's what you've got to get after.
                       So I would say we certainly would accept
           and develop methods, but what we are trying to do is
           stimulate.  I'm talking about real innovation, beyond
           that, to try to open up approaches that really change
           the playing field.
                       MR. HOCKRITTER:  Larry Hockritter, Penn
                       It's not clear to me why in your
           conclusions you have to have small versus large power
           ratings.  It seems like you're biasing yourself
           already towards a particular class of designs.
                       DR. TODREAS:  Yeah.  Yesterday I presumed
           the whole layout of this program was announced or was
           explained as an international program with eight to
           nine countries now, and one of the goals of the
           program in all the specific directions is to come up
           with design solutions or concepts that meet markets
           internationally, and there are some international
           markets, and also if you listen in the United States,
           too, depending on the grid size, there are some
           markets that have a priority toward low rated systems.
                       And so you have some of those, and then
           you also have the traditional, if you talk about Asia,
           Japan, Korea, Taiwan, large systems.
                       So inherent in the whole program, since
           it's looking at worldwide markets, we're going to have
           this dichotomy, these two parts, and not one reactor
           thrust or direction is going to meet them.  So you're
           going to have to come up with systems in both
                       Now, your point may be fine, but they're
           not going to be sellable in the United States or the
           industrialized world.  That's fine, but we'll have a
           product for that.  We just may not use the other
                       MR. KHADAMI:  My name is Presar Khadami. 
           I'm with the NRC staff.
                       If I understand the rules by which the
           South Africans are trying to license their plant, one
           of their goals is that in the long term the concepts
           employed should be amenable for society to make a
           decision that higher levels of safety need to be
           obtained from these energy systems.
                       And therefore, one of their goals, as I
           read it, and if I should be corrected, I'd like
           somebody to point this out; one of their goals is the
           design should be amenable for society to demand higher
           levels of safety at some future time if we take, you
           know, these systems as operating for many decades.
                       Where does such a concept fit into the
           kinds of goals that you have articulated?
                       DR. TODREAS:  Okay.  On this let me give
           you a brief answer and ask for some help because I am
           not knowledgeable about a specific or the specific
           South African drive that you're talking about.  I just
           haven't interacted with them specifically.
                       I would say that even though these are
           general, we are going to have some kind of constraint
           because we're going to come up with a set of specific
           metrics that go with each of these goals.  They're
           going to be as we go on a year or two -- there's going
           to be some numbers and some specificity here .  So. 
           There's going to be a little bit of a lock-in, and
           that sounds to me like it's inconsistent.
                       The way I interpret what you're saying is
           you come up with a design.  Society decides they want
           more safety, and so this design has somehow got to be
           expandable or have margin or a way to capture more
           safety.  That's how I understand it.
                       So I don't know the answer.  These goals
           have been pushed in through a discussion with the so-
           called GIF countries, of which South Africa is a part
           of, and we didn't get any effective comment back from
           them that's relevant to what you said.
                       But if Andy or somebody else can speak
           specifically to that, that would help me.
                       DR. SLABBER:  Mr. Chairman, the South
           African concept, the baseline was to use existing
           technology as far as possible, existing technology
           that has been qualified and tested and proven to be
           acceptable for use in the PBMR&S, and with a basis
           that the fuel is the central point of focus.
                       And within that framework, we do the
           system design, that it fulfills the requirements that
           imbedded in the design without reliance on operator
           actions is imbedded a term, and I again say, in
           inverted commas, inherent safety and small units, and
           usable for not only producing nuclear power, but also
           some other usable byproducts specific for South
                       DR. TODREAS:  Can I build on that maybe in
           answer to his question?  You stay there because I'll
           need you.
                       I would say with that focus and the
           ability, as you went to successive improvements in
           fuel fabrication and fuel reliability, you could
           actually enhance your safety profile if the key focus
           is fuel, and that would be an answer back to how you
           reflect the future, the fuel.
                       DR. SLABBER:  Yes, and I think the
           objective of any new innovator system should be to
           improve, but there is a limit because it's also
           costly.  So improvement, the improvement for public
           acceptance, improvement of safety, that the boundary
           made improvements so that you do not have to shelter
           and evacuate, but these are all factored in to provide
           a facility which is still affordable and reliable.
                       CHAIRMAN KRESS:  Thank you very much,
                       At this time I'm going to declare a 15-
           minute break.  Be back at 20 till.
                                   (Whereupon, the foregoing matter went off
                       the record at 10:26 a.m. and went back on
                       the record at 10:45 a.m.)
                       CHAIRMAN KRESS:  Before we move on to the
           next speaker, I want to reiterate my announcement I
           made this morning, that we are changing rooms for this
           afternoon's session, and the room we're changing to is
           the usual ACRS meeting room, which is on the second
           floor of White Flint 2.  There may have been some
           confusion in people's mind.
                       And if you're signed in this morning, we
           will have a -- you have to have a badge to get up
           there, and there will be a temporary badge available
           for those people who have signed in at the security
           desk in White Flint 2 lobby, and that will be
           available after lunch.
                       But if you haven't signed in at all or are
           not currently badged, you will need to go through that
           and get a temporary badge before going up to the
           second floor.
                       So with that little aggravation, we'll
           move on to the next talk, which should prove to be
           very interesting, and as I mentioned earlier, I have
           no introductory comments.  So you have to introduce
           yourself, Andy.
                       DR. KADAK:  Thank you.
                       CHAIRMAN KRESS:  And then I'll turn it
           over to you.
                       DR. KADAK:  My name is Andy Kadak.  I'm
           professor of the Practice at MIT.  You can ask me
           later what that means exactly.
                       I was formerly a president and CEO of
           Yankee Atomic Electric Company.  So I've been able to
           see directly and experience the strengths and
           weaknesses of the NRC regulatory process, and I'll
           just leave it at that.
                       DR. KADAK:  When I first came to MIT --
                       DR. POWERS:  Because if you went through
           all of the strengths, it would take too long.
                       DR. KADAK:  Absolutely.
                       DR. POWERS:  I understand.
                       DR. KADAK:  When I went to MIT in 1997 as
           a visiting lecturer, Professor Ballenger and I engaged
           about 11 students under an American Nuclear Society
           program called the Economic and Environmental
           Imperative, and it was aimed at stimulating student
           interest in looking at innovative, new reactor
           technologies, and to see how we could make nuclear
           plants competitive, safe, and politically acceptable.
                       In 1996, the students chose a pebble bed
           reactor as the technology to develop since it appeared
           to best meet our attribute.
                       We then convinced the Idaho National
           Engineering and Environmental Laboratory that, of this
           particular fact, and they supported much of our
           research for the last three years.
                       Overall our objective is to develop a
           conceptual design of a complete power plant based on
           the concepts and ideas that we formulated in 1998.
                       We're now working in the following areas,
           just to give you a sense of the scope of our effort. 
           We're doing and developing a fuel performance model,
           which includes and will include the manufacturing
           aspect of it.
                       We're doing some experimental work on
           silver and palladium, effect on silicon carbide. 
           We've got a core neutronics capability, and ultimately
           hope to verify and validate using MCNP, a lot of the
           core neutronics.
                       We're developing a balance of plant design
           and a simulation capability to assess normal operating
                       We're also working in the area of safety,
           loss of coolant and air ingress analysis.  We've done
           some work on nonproliferation, waste disposal, and
           we're also now engaged in what I call true modularity,
           namely -- and this is the innovation -- true factory
           manufacture of essentially the balance of plant for
           site assembly.
                       We are also working with the University of
           Cincinnati on developing of a burn-up monitor for
           these pebbles.
                       If we get additional funding, there will
           be work on advanced INC with Ohio State.  We're
           looking at management issues and a PRA.
                       So ultimately, if our work is successful
           and we continue developing this concept, our plan is
           to build a combination research and demonstration
           facility to test the technology, help validate the
           technology and operation, and essentially use it as a
           continuous test bed for the life of the plants should
           they be built in the future.
                       This is sort of an introduction to what
           I'm going to talk about today, which is this license
           by test, which I've been thinking about for many
           years.  I've talked to many of the NRC staff about the
                       Now, this presentation that I'm going to
           make today does not claim to have all the answers
           about how such a process might work, but it is meant
           to address some of the high level issues and the
           approach that we might consider.
                       And to determine whether this concept is
           workable, it is recommended, and that's my bottom line
           recommendation, that the NRC, we and other interested
           parties work to see if such a process can work rather
           than jumping on all of the reasons that it can't.
                       So with that, let me just begin.  Here are
           the challenges as I see them.  The regulations, as you
           all know, are focused very much on water.  The
           knowledge of the technology, particularly in new
           technologies -- forget the pebble bed for the moment. 
           This is generic -- knowledge of these knew
           technologies is generally lacking, and the
           infrastructure to support some of these new
           technologies is also lacking.
                       We've heard plenty of that yesterday,
           regardless of whether it's gas, liquid metal, lead
           bismuth, whatever the technologies are.
                       And changes in the system, what I call the
           system is the regulatory system, take a very, long
                       So how do you introduce a new technology
           in less than a lifetime?  And yesterday I heard hints
           of lifetime project.
                       We need to go back to the basic safety
           fundamentals.  We need to work within the existing
           regulatory high level objective, use -- and here we go
           -- very early in the game, risk informed, which I
           define as risk based with deterministic analysis,
           approaches to determining safety; assess our gaps in
           the knowledge, especially if it's new technology to
           see what we understand and what we don't understand
           very objectively; prioritize namely what are the
           significant risks associated with what we don't know
           and what we do know; and then try to license this
           thing by test.
                       Well, here we got.  Relative to
           establishing the safety goal, we would use a public
           health and safety goal, not a core damage frequency,
           and I think you were sort of getting at that yesterday
           in terms of releases.
                       You look at this public health and safety
           goal, and then you start to define your plant risks,
           whether they be normal operating risks, events,
           transience, accident scenarios, and then identify the
           safety margins as bets you can using deterministic
           analysis.  Then begin or attempt to quantify the risks
           as you know them using a PRA, and then show defense in
           depth, and what I will describe later about defense in
           depth is how many barriers are there to prevent a
                       CHAIRMAN KRESS:  Is that what you mean by
           defense in depth?
                       DR. KADAK:  That's what I mean by that.
                       And I'm not defining the barrier, and how
           do I deal with the uncertainties that recognizably
           exist in this technology.
                       Next slide, please.
                       The risk informed approach then really
           attempts starting with the safety goal, and it's a
           public health and safety goal, by applying what we
           know and using the probabilistic techniques that we do
           know in a scoping kind of a sense.  We will obviously
           not know the performance of helium high temperature,
           high temperature helium turbines or compressors
           because the size that we're talking about hasn't been
           built, but we can estimate it based on other
                       Are these health and safety goals
           something different than the quantitative health
           objectives that we currently have?
                       DR. KADAK:  they would be based on
           fatalities, ten to the minus -- pick a number -- ten
           to the minus six.  Start at that level.
                       CHAIRMAN KRESS:  Yeah, but do you think
           that those we now have are sufficient or do we need
           something else?
                       DR. KADAK:  I would say at that level it's
                       DR. POWERS:  Why do you focus on
                       DR. KADAK:  It's an easy measure.  You
           could talk about injuries, if you like as a separate
                       DR. POWERS:  I mean if we're going to
           learn something out of accidents that have occurred,
           the most transparent consequence of Chernoble has been
           radiation injuries rather than fatalities.
                       Line contamination could arguably be the
           other thing that we've learned.  Why not change the
           measures in response to things we've learned?
                       DR. KADAK:  We could do that.  I'm not
           limiting it.  I'm just saying establish something that
           everybody is comfortable with, and I mean societally
           comfortable with.  And if it talks to land, if it
           talks to injuries or if it talks to fatalities,
           fatalities is the one that we now have.
                       CHAIRMAN KRESS:  Well, you know, part of
           the purpose of this meeting is to identify regulatory
           challenges, and my question was aimed at saying do we
           have appropriate let's call them safety goals now or
           should the Commission be thinking about something
           different for safety goals for the advanced reactor,
           and that --
                       DR. KADAK:  My sense right now is we have
           already essentially established the policy that
           says -- we established the public health and safety
           goal.  Let's start there.  If there's more that needs
           to be done, add it, but I don't see that as a priority
           issue right now.
                       From what I understand of the British
           system, they're trying to harmonize safety goals
           across all technology, and perhaps we can learn
           something from that to be able to judge whether
           nuclears are in the right ballpark.
                       CHAIRMAN KRESS:  Okay.
                       DR. KADAK:  So we would then apply these
           deterministic and probabilistic techniques as best we
           can to see if the goal is met, and then using the
           risk-based techniques, identify dominant accident
           scenarios and what critical systems and components
           need to be tested as a functional system.
                       And in this case I'm trying to avoid the
           use of design basis access.  I'm trying to see what
           really matters for safety and use the risk approaches
           to identify those.
                       The next slide gives an approach that I
           think has been used in the past where you go through,
           you know, the risk informed approach, namely,
           identifying on a very high level basis the issues of
           protection of the public, evaluate risks against the
           safety goals, use the PRA to quantify obviously larger
           uncertainties, limit core damage, mitigate releases,
           and then mitigate consequence.
                       Now, this is sort of a standard kind of
           approach.  What I would suggest is that's where you
           start, and the master logic diagrams would be more or
           less technology specific relative to the kinds of
           vulnerabilities of the particular technology might
                       The next slide gets into a description of
           a master logic diagram, but that's for water reactors. 
           One of our students at MIT is now attempting to try to
           define this better for, say, the pebble bed reactor,
           and we're going to start with a basically different
           approach at least from my perspective, and that is,
           you know, starting with the plant and how do I protect
           the public working backwards, and what events can
           cause release.
                       We're going to try to do a different
           master logic diagram on that basis.
                       Next slide, please.
                       This chart here, which you can't see very
           well, but it's in your handout, is a summary of what
           the South African national nuclear regulator is using
           for their assessment.  They've got a very similar
           system to what I'm proposing, at least at a higher
           level, and they developed some requirements that
           starts from the public health and safety goal and
           establishes various safety criteria in a range of
           events which I think we heard about yesterday.
                       It's in the handout, and hopefully you can
           read it better, but I bring that up only to allow one
           to see that there is a logical frame of reference from
           which to proceed to establish such a process of using
           risk informed to establish and correlate that with the
           public health and safety goal.
                       The next slide, please.
                       We do have an existing regulatory
           structure, and I'm still trying to do this in less
           than a lifetime.  So what we're going to try to do if
           we get a chance to is -- and it's already been
           discussed, I think, by Exelon -- and that is review
           the existing regulatory structure for the gaps that
           exist relative to that particular technology.  For
           example, as far as I know, there's no error ingress
           safety criteria.  We might need to have such a thing
           developed, but identify those kinds of issues as you
           look at the existing regulatory guidance.
                       And, in fact, look at the general design
           criteria and say how do we and how can we implement
           those, given what we think are the high level safety
           objectives that we've established in the previous
                       Where it gets confusing and where it will
           get difficult is trying to meet the general design
           criteria for non-standard or non-order technology, and
           it's in the details that you really get hung up, and
           that's where the whole process of show me that it
           doesn't require this criteria happens.
                       So we're trying to say by reviewing the
           existing structure, applying it to say the pebble bed
           reactor, and then being able to say on a risk based,
           you know, foundation what does and does not require it
           in terms of the fundamental design for the regulation
           that would apply to that.
                       Next slide.
                       So, and I use the word "design basis
           accidents" using risk based techniques.  I really
           wanted to keep to the word design the dominant
           accident sequences using risk based technique, which
           you would then analyze to try to assess how much
           defense exists in those accident sequences.
                       DR. WALLIS:  Can I ask you something here?
                       DR. KADAK:  Surely.
                       DR. WALLIS:  I mean, you seem to be
           applying what we do today to what we might do
           tomorrow, and did you question whether we really need
           design basis accidents in their present form?
                       DR. KADAK:  My approach would say --
                       DR. WALLIS:  Or would it be replaced by
           something else which might be less plant specific and
           be more effective?
                       DR. KADAK:  The process that I would
           recommend is developing dominant accident sequences as
           part of the regulatory process, and don't call them
           design basis accident.
                       DR. WALLIS:  But you just did.
                       DR. KADAK:  Well, I made a mistake.
                       DR. KADAK:  I was revising my slides, and
           I was looking for design basis accidents, hopefully
           not to include it, but I made a mistake.  It should be
           establish dominant accident sequences.  Okay?
                       CHAIRMAN KRESS:  If you go back two slides
           to the one we couldn't read --
                       DR. KADAK:  Yes, the big -- yes.
                       CHAIRMAN KRESS:  It seemed to me like
           that's at least three points on it, a frequency
           consequence curve.
                       DR. KADAK:  Right.
                       CHAIRMAN KRESS:  It seems to me like such
           a curve encompasses all of the accidents, the whole
                       DR. KADAK:  It attempts to cover them all.
                       CHAIRMAN KRESS:  If you meet some sort of
           regulatory requirement on this, and it may have to
           have confidence limits or something, and then
           encompasses the whole shebang, doesn't it?
                       DR. KADAK:  We're trying to cover the
           regime of accidents possible for this technology. 
           Okay?  And looking at the categorizations placed under
           A, B, and C, it appears to cover logically what one
           would need to worry about, but I can't --
                       CHAIRMAN KRESS:  So if you just tell the
           designer or the license applicant that he has to meet
           this curve -- I call it a curve -- at a certain
           confidence level, what else do you need?
                       DR. KADAK:  I guess --
                       CHAIRMAN KRESS:  The thing that seems to
           be missing to me is defense in depth.  We can get into
           that later.
                       DR. KADAK:  Where I get hung up is for new
           technologies doing that is going to be extremely
                       CHAIRMAN KRESS:  Because it requires a
           pretty good PRA.
                       DR. KADAK:  It requires a good PRA.
                       CHAIRMAN KRESS:  And a good knowledge of
           the phenomena that go into the accident sequences.
                       DR. KADAK:  Yeah, and a lot of data that
           supports the probability --
                       CHAIRMAN KRESS:  Which is the part that's
           usually tempted to be covered when you have that
           situation by defense in depth.  That's why I keep
           harping on we need a firmer definition of defense in
           depth and how it fits into a regular or a system like
           this, for example, with new technologies where you
           don't really have core melts, and you don't really
           have the standard barriers against fission products.
                       But, anyway, that's another subject.
                       DR. KADAK:  Well, my sense of defense in
           depth is how much margin do you have to, say, core
           melt or in this case release.
                       CHAIRMAN KRESS:  Yeah, that's a sort of a
           defense in depth.
                       DR. KADAK:  Sort of.
                       CHAIRMAN KRESS:  It's not my definition.
                       DR. KADAK:  Okay.
                       DR. WALLIS:  What's your measure of
                       DR. KADAK:  I hate to say this, but
           engineering judgment.
                       DR. WALLIS:  That to me always is an
           ignorance factor than --
                       DR. KADAK:  Absolutely, and I'm just
           suggesting that when you introduce new technologies,
           there will be a lot of uncertainties which you cannot
           precisely calculation.
                       DR. WALLIS:  Your engineering judgment is
           maybe ultimately different from somebody else's.  So
           how do you explain or argue with that person?
                       DR. KADAK:  It depends on the design.
                       DR. WALLIS:  I think you have to be
           quantitative in some measure which you can agree upon.
                       DR. KADAK:  If you can do deterministic
           analyses and show that the worst situation as was
           presented, I believe, yesterday is acceptable and
           analytically, deterministically.  That's why it's not
           purely a probabilistic approach.
                       Using the best tools that you have and, in
           fact, being able to, as I will get to, the license by
           test scenario to demonstrate such things, I think your
           confidence levels will be greatly increased, and
           that's the bottom line.
                       What makes me very nervous is just relying
           on numbers with confidence levels because as we know,
           even with our PRAs things happen that are not in the
                       DR. KADAK:  Okay.  If I could catch up to
           where I was, okay, then if you'd just back up that
           one, I want to -- to develop the defense in depth
           basis using the natural physical attributes of the
           designs, what that basically means is if there are
           significant natural physical attributes and not so
           much reliance on active systems or passive systems
           that must function, you are in a much better position
           to develop the confidence level you need relative to
           defense in depth, and you can argue about how many
           barriers or whatever, but that is a key part of this,
           and that's a key direction, I believe, that the
           regulators ought to encourage relative to new
           technological develop, and that is natural physical
                       CHAIRMAN KRESS:  I interpret that
           statement to mean that there's probably less
           uncertainty associated with determining the risk of
           those than when you have a complicated system with
           lots of barriers and lots of active --
                       DR. KADAK:  That's the point.  We want to
           try to limit those active --
                       CHAIRMAN KRESS:  Therefore, since you have
           less uncertainty and higher confidence in the risk
           results, the less defense in depth might be needed?
                       DR. KADAK:  Again, the less defense in
           depth is not the right term.
                       CHAIRMAN KRESS:  Is that too big of a step
           to take?
                       DR. KADAK:  Now, the point is to
           demonstrate the defense in depth exists and give
           credit to natural physical attributes, I think is the
           direction that I would be heading.
                       And then to whatever degree possible,
           establish confidence levels in the analysis using risk
           assessment method.
                       Next slide, please.
                       All right.  License by test.  Depending
           upon the technology, and in my case it would be sort
           of the pebble bed for an example, build a full size
           demonstration facility.  Perform these critical tests
           on those components that you identified as dominant
           risk contributors.
                       DR. WALLIS:  I don't quite understand
           that.  Are you going to have a near core melt or a
           near containment failure in order to do a critical
                       DR. KADAK:  Let's just say, for example,
           if LOCA is a major accident sequence --
                       DR. WALLIS:  Do you have a LOCA in your --
                       DR. KADAK:  You would perform a LOCA.
                       DR. WALLIS:  You would perform a LOCA. 
                       DR. KADAK:  Or to the degree, at least,
           that you can validate your computer models and
           methods.  And that's why these physical features
           become very important.
                       DR. POWERS:  Have you imagined what the
           environmental impact statement on this federally
           funded examity (phonetic) is going to look like?
                       DR. KADAK:  Sure, and what I didn't
           mention and I probably should was that for the purpose
           of this research, combination research demo facility,
           we put a containment on it.
                       DR. POWERS:  Well, I thought you just put
           it in Idaho and nobody would care.
                       DR. KADAK:  For the record, Idaho is a
           beautiful state, has lovely people.
                       DR. KADAK:  Nature abounds.
                       DR. POWERS:  Probably do $10 million worth
           of improvements in New Mexico.
                       DR. KADAK:  Okay.  So clearly it's a
           research facility that needs to have a containment,
           but the purpose of the containment is to prove you
           don't need one, if that, in fact, turns out to be the
                       DR. POWERS:  How would you do that?  I
           mean, suppose you ran this test and, indeed, it did
           just fine, and some skeptical guy like Ed Lyman over
           there came along and said, "But if you'd done a
           different test" --
                       DR. KADAK:  Well, that's what I want Ed
           Lyman to work with us.  When I said all interested
           parties, I'd like to have Mr. Lyman, Mr. Lockbaum, and
           Mr. Gunther involved in this because I think that's
           part of the process.
                       DR. POWERS:  And still no matter what test
           you did, somebody else could come along and say, "But
           if you'd just done this other test."
                       DR. KADAK:  Yeah, but Mr. Lyman will be
           explaining to this other person why these test series
           are adequate, not me.
                       DR. WALLIS:  Well, I think the problem you
           get into --
                       DR. KADAK:  Sorry.
                       DR. WALLIS:  -- is the basis of scientific
           testing is to try to disprove your hypothesis.
                       DR. KADAK:  Yes, or to prove it.  I think
           you'd like to try to prove it.
                       DR. WALLIS:  Of course, by the very fact
           that you could disprove it, you would have had an
           unacceptable release presumably.  So it's a little
           difficult to design that crucial test to disprove a
           hypothesis that it's safe.
                       DR. KADAK:  Well, again, there's a reason
           for the containment, and obviously you'd be a little
           more creative about the type of test you run so that
           you understand what the possible outcomes would be,
           but theoretically it's conceivable, and it obviously
           depends on the plant and type of design.
                       DR. WALLIS:  I guess we're asking these
           questions because we're kind of intrigued by the idea.
                       DR. KADAK:  Good.
                       DR. WALLIS:  But we're skeptical.
                       CHAIRMAN KRESS:  Yeah, one purpose --
                       DR. KADAK:  Wonderful, marvelous.
                       CHAIRMAN KRESS:  -- we attribute to
           integral tests are to -- two purposes:  one, to see if
           there's something going on that we hadn't thought of;
           two, to validate our computerized analytical tools so
           that they can be used in an extrapolatory sense to
           cover the things we can't do inn the test.
                       Would that be your view of what this test
           might do for you?
                       DR. KADAK:  Next slide.
                       The needs.  Why?  To validate analysis. 
           Okay?  To shorten the time for paper reviews; to try
           to prove in quotes what's debatable; to reduce
           uncertainty, and this is very important; to show the
           public and the NRC, and I include them as the public
           in this case, that the plan is, in fact, safe.
                       And that's what it's all about.  Can we do
           the -- you know, can we try to melt the core?  If we
           believe that we can do it without melting the core,
                       DR. WALLIS:  So what you should do is you
           should give an operator carte blanche to try to melt
           the core, and he or she will fail.  Is that your test?
                       DR. KADAK:  Depending upon the design,
           yes.  I mean, theoretically that would be the test,
           but I would structure it more carefully than that.
                       DR. KADAK:  See, we're going to hear about
           radiological sabotage in a few minutes, I'm sure, and
           maybe that's the test that Ed would like to run, but
           we don't know yet.
                       Yes, I'm sorry.
                       DR. GARRICK:  Andy, we have a bit of a
           model for this in that we once had something called a
           national reactor testing station, and we once had
           something called the borax experiments, and we once
           had something called the spurt experiments, all of
           which have a kind of familiar ring as to what they
           wanted out of those experiments in terms of what
           you're describing.
                       Does that experience, just from the
           standpoint of answering the questions of one scenario
           versus another scenario, I want to test my scenario,
           Dana wants to test his scenario, and so forth; is that
           experience relevant at all in what you're proposing
                       DR. KADAK:  I'm not sure, but I recall
           some of them actually wanted to break fuel like no
                       DR. GARRICK:  Right, but they were talking
           about various degrees, and they tried very desperately
           to come up with an experimental program that gave them
           the biggest bang for the buck possible, and what they
           were really trying to do was get closer to a
           quantification of the loss of coolant accident, and
           better parameter information with respect to the
           containment and so forth.
                       DR. KADAK:  Clearly, you know, that
           experience would be certainly helpful, but again, I
           don't have all of the answers.  I'm just giving you an
           idea of what I think might work, but how to exactly do
           it and what to build on, I just am not all that
                       What I hope to do after this presentation
           is you're so excited about this concept that you'll
           ask the NRC staff to work with us to try to figure it
                       MR. LEITCH:  Andy, I have a question about
           your second bullet up there, shorten the time for
           paper review.
                       DR. KADAK:  Yes.
                       MR. LEITCH:  I'm not exactly sure what you
           mean by that.  Does that mean that the paper reviews
           would not be as detailed or not exist at all --
                       DR. KADAK:  No, no.
                       MR. LEITCH: -- in lieu of this test?
                       Or talk a little bit about would the paper
           reviews be less detailed than they would normally be,
           and if not, how would the time be shortened?
                       DR. KADAK:  See, that depends on what
           licensing action you have.  Let's just take the most
           recent paper review, AP 600.
                       MR. LEITCH:  Okay.
                       DR. KADAK:  All right?  I'm told -- I do
           not know -- it took roughly ten years.  I'm told, but
           do not have the number confirmed, it cost around $249
           million, which included a lot of testing as well.
                       And the end of that process was a
           certification, a piece of paper.  What I'm suggesting
           here is for $249 million I could probably get part of
           a plant built that looks like a research facility that
           could be used to answer some of these tests, some of
           these questions.
                       In terms of submittals, I don't see much
           different in terms of what the design is.  The
           submittal would largely be here's the design.  Here's
           why we think it's comfortable and appropriate, and
           here's the testing program that we're planning to
           perform here to validate these areas that are in
           question or to validate some computer code.
                       So the approval would be more of an
           approval to conduct tests on a facility than to grant
           a license or a certification.  That certification
           would come after the test had been completed,
           hopefully successfully and whatever design
           modifications made.
                       So I think in time scale, we're probably
           going to be about the same, say, five to ten years,
           you know, including the building the plant.  What you
           will have at the end of that process not only is
           certification, but also a plant that theoretically is
                       DR. WALLIS:  Are you asking for a kind of
           full scale LOFT test?
                       DR. KADAK:  Full scale LOFT test, I
           suppose in the sense of a LOCA.  There will be others
           on a facility, and one of the things it avoids is
           remember the scaling issue that you've had to fight
           over?  I mean, clearly the scaling issue sort of goes
           away if you do a full scale plan or a large enough
           scale to be able to say scaling is not a factor.
                       DR. POWERS:  I still get hung up over
           these.  When George does a PRA, he comes up with more
           sequences than I can count, and you're going to have
           to validate all of them?
                       DR. KADAK:  Not all of them, no.
                       DR. WALLIS:  Well, some significant
           fraction of them?
                       DR. KADAK:  You'd validate obviously the
           dominant accident sequences that are really important
           for public health and safety.  That's the ones that --
                       DR. POWERS:  So maybe 12, 13 major full-
           scale tests?
                       DR. KADAK:  Probably.
                       DR. POWERS:  And what happens if, I mean,
           just one of them kind of goes awry?
                       DR. KADAK:  Fix it.  You make the design
           change.  That's why it's called a research facility.
                       DR. POWERS:  Well, cleaning out a full
           scale facility contaminated with radionuclides does
           not strike me as a low cost operation.
                       DR. KADAK:  Well, clearly you wouldn't do
           these if you had any question in your mind that it
           wouldn't work.
                       DR. POWERS:  Oh.  So there's a certain
           level of uncertainty that I can't have.
                       DR. KADAK:  That's right.  I mean, clearly
           you wouldn't build a plant that you didn't feel could
           withstand the test.  
                       DR. POWERS:  You're going to have a hard
           time buying the insurance policy.
                       DR. KADAK:  Well, that's why we have this
           containment.  I mean, no --
                       DR. SHACK:  Well, somebody has got to
           clean up the mess just in case it goes wrong.
                       DR. KADAK:  Well, again, the confidence
           level basically is that of the designers and the
           engineers after a lot of review and approval to say
           that this thing will work.
                       I mean, clearly, you wouldn't do anything
           stupid, and that's the point.  If you have confidence
           in the technology, you could do this.  Maybe not all
           technologies are amenable to this kind of an approach,
           but those technologies that have the kind of margins
           that I think exist relative to the melting or fuel
           failure certainly could try.
                       But let me continue and you can get the
           full scope here.
                       MR. SIEBER:  Well, who would finance the
           demonstration plant?
                       DR. KADAK:  Good question.  It is a
           research facility, bottom line, and if, in fact, it's
           as broad a scope as we are talking about here, I think
           it's a legitimate government expense.
                       DR. APOSTOLAKIS:  I think that's the way
           you lose Mr. Lyman.
                       DR. KADAK:  Well, he's going to be a
                       DR. APOSTOLAKIS:  You wanted him to work
           with you, but --
                       DR. KADAK:  But he could be a player.  I'm
           saying that, you know, there's obviously some industry
           money that's going to be required as well, but how
           much of it is research and how much of it is
           application and certification relative to usable
           technology is the matter to be discussed, but clearly,
           you know, this kind of facility would be, I think, a
           government supported --
                       MR. SIEBER:  Well, it seems like it would
           be very expensive, and in a competitive environment
           I'm not sure that licensees would be willing to ante
           up a lot of money.
                       DR. KADAK:  Well, let me just give you
           some rough numbers.  If my numbers about AP 600 are
           right, that's, say, 250 million.  I've done some
           preliminary cost estimates to engineer and design this
           facility would be around 500.  A 50-50 split sounds
           fair to me.  It may not be the right numbers, but
           that's kind of what we're talking about.
                       MR. SIEBER:  In this facility you would
           have active fuel in it?
                       DR. KADAK:  Oh, yeah.
                       MR. SIEBER:  So you would have to license
           it just to have the facility, would you not?
                       DR. KADAK:  That's, again, part of the
           process.  The licensing basically is the thing that
           Graham was talking about.  What is the NRC review and
           approval process?
                       So it would be licensed, if you will, as
           a research facility.
                       Okay.  Let me move on.  The test that I
           think would be required are, you know, you're never
           going to get away from the traditional performance of
           component.  There will probably be some small scale,
           integral tests to verify so that we don't have this
           scenario about cleaning up fuel, but you then would
           use these risk based techniques to identify the kinds
           of accident scenarios that are important, critical
           systems, critical components, some integrated tests
           which may be in a smaller scale.
                       Next slide, please.
                       And the test that I was considering may be
           more.  I don't know if it adds up to 13 quite, but
           loss of coolant, depressurization, natural
           circulation, see if we can get it or not.  In our case
           we don't want it.
                       Rod withdrawal, reactivity shutdown
           mechanism, cavity heat up and heat removal, and then
           other key component failures that you find become
           dominant in the PRA.
                       DR. WALLIS:  Now, if you just look at loss
           of coolant, there are all kinds of sizes of breaks in
           all sorts of places.
                       DR. KADAK:  Yes.
                       DR. WALLIS:  So what you presumably would
           do is you'd do a lot of analysis ahead of time and say
           this is the one we're really worried about?
                       DR. KADAK:  Could do that.
                       DR. WALLIS:  Then you're going to miss Dr.
           Kress' point because, you know, the whole purpose of
           doing the test is to find out things that gave you a
                       DR. KADAK:  We could do it by expression. 
           I mean, this facility, my hope would be it would be
           designed in a way that it is, in fact, a research
           facility with different abilities to blow down by
           size, if that's the --
                       DR. WALLIS:  So loss of coolant might be
           a whole sequence of tests.
                       DR. KADAK:  Could be, yeah.  Again, I have
           not designed it, but in concept, yes.
                       So next slide, please.
                       Additional tests.  Oh, here.  I guess I
           put up to my 14 or 15 now.  Balance of plant failures,
           the traditional things that we worry about in
           liability space, turbine over speed, failures of
           various components, rod ejection or rapid withdrawal. 
           I'm not sure we want to do a rod ejection per se.
                       Cavity heat-up.  Again, we want to
           validate the core physics models.
                       DR. POWERS:  Let's look at that control
           rod ejection because it's a fun one to look at.  The
           scenario that we're now worried about is one where the
           fuel had extremely high burn-up.  How are you going to
           do that in your test?
                       DR. KADAK:  That would have to be outside
           of the reactor.  We can't do that for -- you know. 
           There would be a whole series of fuel tests as part of
           this program.
                       DR. POWERS:  Well, and the problem that
           plagues the right ejection accident is an argument
           over how it propagates within the whole course.  So if
           you do this test at the FABRI (phonetic) facility with
           one rod, that doesn't answer the question.  I need a
           whole bunch of rods.
                       DR. KADAK:  Well, I think we could do like
           I said, a rapid withdrawal, and we could model it from
           the standpoint of what we expect as a reactivity
           transfer and to see whether those codes, in fact --
                       DR. POWERS:  I mean, that's where the
           argument is, is whether the codes are right or not,
           and whether they give you the right amount of heat
           going into the clad and not into damaging fuel.
                       DR. KADAK:  Well, the first is the
           reactivity.  Then we can go to heat, right?
                       DR. POWERS:  No.  This is a time scale
           where those two are very coupled together.
                       DR. KADAK:  Okay.  Then xenon, we talked
           about xenon.
                       DR. WALLIS:  Some would argue that the
           technologies are fine, and that most of the major
           accidents are caused by people doing something out of
           ignorance, stupidity, whatever.
                       I don't see that as part of your testing. 
           I'm not quite sure how you would test it anyway.
                       DR. KADAK:  Oh, we could do your earlier
                       DR. POWERS:  Graham, I'm shocked.  People
           don't make mistakes out of ignorance and stupidity. 
           It's an error shaping factor.
                       DR. POWERS:  Forcing factor.  You've got
           to learn this language, sir.
                       MR. LEITCH:  Andy, would you be talking
           about fully integrated tests here?  For example, if I
           may ask the question this way.  In the start-up of a
           normal power plant, there are those who would advocate
           walking up to the generator breaker at 100 percent
           power and opening it and seeing what happened.  I
           mean, I always thought that was a little like testing
           para chutes, and what I'm saying --
                       MR. LEITCH:  -- we would demonstrate that
           the turbine would trip and that it had contacts that
           would make the reactor scram, and we would demonstrate
           separately that the reactor would scram.
                       But I mean, I really think some of these
           integrated tests would unnecessarily put the plant
           through perturbations that could be demonstrated
           piece-wise.  And I'm just wondering if you have
           thought about the piece-wise demonstration of this or
           would you be talking fully integrated tests?
                       DR. KADAK:  I think what the final test
           program ends up being is that which is judged to be
           such that it can demonstrate where the safety concerns
           are.  Now, if there's too much of a strain, for
           example, and the plant could just trip a breaker and
           see what happened, and people say, "Well, I can get
           the same information from these separate tests," I
           think that would be fine.  
                       I'm not here to design the test, but I
           think that would be part of the process, working with
           the regulator to develop what evidence do they need to
           show the plant can do what we think it can do.
                       So it doesn't have to be the crazy.
                       Okay.  The next slide, please.
                       Continuing on with the test so that it's
           more than 15, dual performance, which gets to Dana's
           question about, you know, high burn-up, cycling, most
           heat-up, most accident heat-up, ingress to validate
           this chimney question, and water ingress if you'd look
           at the reactivity effect and the possible fuel damage.
                       My sense is those would be done probably
           outside the core on varying degrees of fuel and
           varying size of the facility, and I think the Germans
           have done many such tests already.
                       Next slide.
                       Well, what I started talking about was a
           prototype, and as a suggesting, using the pebble bed
           reactor as such a prototype.  It's built full sized
           with the containment as I mentioned.
                       Implement the structure test program, and
           as part of this process, and I call it a process, we
           would develop what rules might be appropriate for
           introducing new technologies that don't have, you
           know, 25 years of regulatory history.
                       So we would not only test the facility,
           but also see if this process that I've outlined can
           work with new non-water technologies, for example.
                       And if, in fact, the process works, apply
           it generically to other technologies.  That was sort
           of the idea.
                       And then if all goes well, you have a
           certified design, and you have a reactor that's sort
           of the fleet innovator, if you will, for the next 40,
           50 years, however long the fleet exists.
                       Next slide.
                       Will this answer all of the questions,
           categorically, no, but at least it gives us a good
           shot at answering hopefully the most significant ones,
           but in combination with all of these subtier component
           tests and small scale tests, we'd probably have a
           good, relatively high level of confidence about
           critical safety performance.
                       Next slide, please.
                       Will this license by test instill public
           confidence?  I say yes, in the sense that it gives the
           public -- giving the public and the media an
           opportunity to observe these tests, hopefully the
           confidence in this technology will be increased so
           that you avoid -- and I'm sorry, George -- ten to the
           minus pick a number is not understandable for public
           communication, although it may be very well understood
           here, but it doesn't really work out there.  They'd
           like to see this thing work, and if successful, the
           core doesn't melt --
                       DR. WALLIS:  Do you think using words like
           one in a billion would be more appropriate?
                       DR. KADAK:  You know, one in a billion
           people still win the lottery, you know.  So what does
           that mean?
                       DR. POWERS:  I think in pursuing this
           viewgraph, you ought to look at the experience they
           had at the Phoebus (phonetic) facility, which was
           doing an experiment, which amounted to melting down 21
           fuel rods, two of which were fresh fuel and the rest
           of them were irradiated, and the public responds prior
           to the first test there, and how eager they were to
           watch that particular test.
                       DR. KADAK:  I'll look it up.  I'm not
           familiar with it.
                       CHAIRMAN KRESS:  They had people with
           placards marching around.
                       DR. POWERS:  They were invading the test
                       DR. KADAK:  Well, it could happen here,
           too, but hopefully we will engage them long before and
           get them to buy into the objective of all of this, and
           if this approach works, I think it will encourage the
           development of what we would all a more naturally safe
                       Next slide, please.
                       Well, how about the traditional regulatory
           approach?  I think we need to just ask a few people,
           which I've done from time to time, and maybe they can
           answer your questions about, you know, how well that
           worked for them.
                       As you know, with the MHPGR, Candu and
           Canadians, I think Westinghouse will have a nice
           authority to tell them, and I think the AP 1000 is
           still an open issue, and answers are not always
           possible to the extent that it can always satisfy the
                       And I am very familiar with bring me the
           rock process.  I don't think it's very effective, and
           maybe this approach is an alternative to that work.
                       So with that I'd like to conclude and
           answer any other questions in the house.
                       DR. POWERS:  I'm intrigued by your
           students looking at the pebble bed reactor.  Do you
           have any of them looking at the potential for that
           particular machine to be used for the fabrication of
           239 plutonium?
                       DR. KADAK:  We looked at proliferation. 
           Yes, we did.
                       DR. POWERS:  Find out anything?
                       DR. KADAK:  Yeah.  In a normal operating
           elevator reactor, the number of pebbles required to
           accumulate eight kilograms of plutonium at end of life
           is roughly 250,000, and the isotopics at that level
           are very uninteresting for a nuclear weapon.
                       If you're deciding to do that, well, let's
           only run the pebbles through one pass to accumulate
           eight kilograms.  That's around 800,000, which makes
           it an unlikely target for delivery.
                       You could be clever relative to the
           technology, but in that case, as in all nuclear
           technology, you need extrinsic measures to detect --
           as you recall, the system is a closed system, does not
           have a spent fuel pool, and so even at that point it
           would be very difficult to get, but we've looked at
           that, and we need to be real careful in that area.
                       At some point I hope you invite me back to
           talk about our work because it's really quite
                       CHAIRMAN KRESS:  Other questions?
                       DR. KADAK:  My new collaborator.
                       MR. LYMAN:  Ed Lyman, NCI.
                       Here's a practical question.  So you're
           proposing that the test facility go with a containment
           which is not the same containment that the pebble bed
           is planned to have?
                       DR. KADAK:  Only because it's a research
                       MR. LYMAN:  Right.  So I've heard the
           argument that the passive cooling of the pebble bed is
           incompatible with a leak tight containment and it
           would interfere with, for instance, the design base 
           LOCA heat removal.  So --
                       DR. KADAK:  Well, we'd have to look at
           that to see whether or not and how we could make it
           compatible for this particular facility.  We'd have to
           look at whether, in fact, we need to make additional
           modifications to the facility to accommodate the
           passive cooling feature.
                       MR. LYMAN:  But if it could be done for
           the test, then it could also be done for the real
           thing, I guess, if you had to.
                       CHAIRMAN KRESS:  Yes, ma'am.  Please
           identify yourself.
                       MS. FABIAN:  Hi.  Teka Fabian from Nuclear
           Waste News.
                       It's not as exciting as melting down the
           core, but I'm wondering if as part of your conceptual
           design process you've done the sort of things that the
           fusion materials program has done, is looking forward
           to end of plant life and looking at lower activation
           materials that are easier to dispose of, possibly
           easier to resmelt and reuse in a nuclear facility,
           designing the plant for decommissioning using robotics
           and remote technology; if any of this has played a
           part in the design process.
                       DR. KADAK:  Not at this stage, although we
           are following what's going on in Germany  as they're
           decommissioning their AVR reactor.
                       Clearly, one of our initial objectives was
           to design a plant with decommissioning in mind, also
           having a lot of personal experience about
           decommissioning the Yankee Row plant.  So I'm very
           sensitive to that issue.
                       But we haven't really looked at it, and
           we're not really at that level of detail yet.
                       MR. HOCKRITTER:  Larry Hockritter, Penn
                       As an AP 600 design certification
           survivor, I'm familiar with the testing that we had
           done and a number of questions that we got from the
           NRC, which were large.
                       But when you structure a test program,
           usually you build on separate effects tests to try to
           identify and create a model that you then put into an
           integral code, and then you use integral tests for
           verification of that model.
                       I think one of the problems that we have
           in the water reactor technology world is that we don't
           have very good integral systems tests.  The loft
           tests, which are the largest integral systems tests,
           that we've all used for a code validation, there's a
           lot of questions on the accuracy of the
           instrumentation, which are really measuring versus
           what you think you're measuring, and so forth.
                       And there may be a lot of potential
           problems for that in this type of a program unless
           it's very, very structured very carefully, and then if
           you add the instrumentation that you want to add, you
           can start to distort the things that you're trying to
                       So I think that you're -- I like the idea. 
           Okay?  But I think that you really have a background
           of tests that you're going to have to provide in
           addition to a large, full scale test where you build
           the technology so that you can have confidence then in
           the code that you'll use to predict the test, which
           you'll then try to run in the facility.
                       Otherwise you may have some unpleasant
                       DR. KADAK:  I think a lot of that stuff
           that we're talking about, some of which at least I
           should say has been done in Germany, we don't know. 
           I don't know, first of all, and like it's sort of the
           code of record essentially is based on, which really
           has no experience in the United States, but we're
           learning how to use it, and that's got a lot of models
           built into it and has been benchmarked against some of
           the tests that they've done in Germany.
                       We would hopefully use that data, disrupt
           your test, but I think your point earlier is exactly
           right.  This is a research facility.  In order to be
           effective, it's got to be well instrumented, and that
           is going to cost much more money than just building a
           straight power plan.
                       MR. HOCKRITTER:   That's right, and you'll
           have conflicting objectives in the design of the plant
           versus the measurements that you want to make.  I
           mean, that's the problem that LOFT had.
                       MS. HAUTER:  Wenonah Hauter, public
                       Who should assume liability for this test? 
           How does Price Anderson play into this?  What kind of
           radiation releases is it appropriate to expose the
           public to?  And should there be a public process,
           public hearings and so forth to determine if this is
           something that the public would want to buy into?
                       DR. KADAK:  Let me answer the last
           question first.  I think clearly the public has to buy
           into this process, and relative to the public
           hearings, you know, I'm not all that familiar with how
           that would occur, but my sense is it would have a
           licensing proceeding, but it would be a licensing
           proceeding, licensed and experimental facility, and if
           successful, probably another licensing facility, say
           it's ready for operation.
                       The Price Anderson question, I'm not an
           expert on Price Anderson, but, you know, depending
           upon who ultimately ends up being the builder, whether
           it's the DOE or some private government partnership,
           those people would obviously have to pay the insurance
           costs for that.
                       In terms of releases, again, you would
           design the test such that they would be essentially
           over this.
                       DR. POWERS:  On the other hand, we could
           test the validity of our consequence code.
                       DR. KADAK:  That's on your nickel.
                       DR. SLABBER:  Mr. Chairman, just Johan
                       Just a comment in support.  I'm not
           claiming and proposing that part of the PBMR
           demonstration unit in South Africa will be used as
           part supplying all of the information to Andy Kadak,
           but part of our objective as a demo. unit, and it's
           not a prototype; it's a demonstration unit; it will be
           instrumented to such an extent that critical
           parameters during transience, like load rejection, may
           be loss of coolant, could be measured, and this is not
           making an open statement.
                       We've got quite a good technological base
           for proposing something like this because in an AVR,
           they have done loss of coolant simulations, as well as
           reactivity excursion experiments.  It is documented,
           and they found, and this is, again, coming back to the
           integrity and the quality of the few, that they did
           not observe any significant increase in releases,
           although the core was filled with fuel, with a
           variable degree of quality and burn-ups, and they've
           also substantiated the reactivity predictions, the
           temperature coefficient predictions.
                       So, in fact, there is a base where we can
           stand on to claim that some of the tests that are
           proposed in such a reactor has got some supporting
           evidence in Germany.
                       DR. KADAK:  Just as a follow-up, to the
           extent that it's appropriate and doable, I think many
           of these tests could be done on the south African
           demonstration facility.  So the concept is a generic
           concept suitable for, I believe, any type of advanced
           reactor that has certain characteristics.
                       CHAIRMAN KRESS:  I'll take one more
           question, Larry, and then we need to move on.
                       MR. HOCKRITTER:  One of the things that we
           dealt with a lot in the AP 600 was looking at
           uncertainty, uncertainty in the predictions,
           uncertainty in the analysis.  Do you know if they've
           done that with these code for the pebble bed in
                       DR. KADAK:  I don't know.  Perhaps Johan
           knows better, but I have not been able to get at some
           of the qualifications.
                       MR. HOCKRITTER:  I know our class also
           looked for that type of information, and we weren't
           able to find that either.
                       CHAIRMAN KRESS:  That's a good comment,
           Larry, because I think having pinned down the
           uncertainties in, for example, you fission product
           release models is key to whether or not you really
           need a strong containment or weaker containment, and
           it has to do with how certain you are in your risk
           analysis results.
                       So I think it was a really good comment. 
           So with that --
                       DR. KADAK:  Could I just make one final
                       CHAIRMAN KRESS:  Yeah, go ahead.
                       DR. KADAK:  I don't think we should get
           hung up on the fact that we're putting this
           containment on a research facility as implying that
           you need one.  Again, the purpose is to show that the
           fuel and the performance of the plan is such that you
           don't need it.  End the debate.
                       CHAIRMAN KRESS:  Okay.  With that, let's
           move on to the next part of the agenda.
                       DR. POWERS:  Mr. Chairman.
                       CHAIRMAN KRESS:  Yes.
                       DR. POWERS:  I notice that Sandia National
           Laboratories may be some partner in this presentation. 
           I'm not familiar with this particular work, but
           sometimes I associate with people from that
           laboratory, and so members should discount anything I
           have to say.
                       CHAIRMAN KRESS:  We usually do anyway.
                       DR. POWERS:  I noticed that.
                       CHAIRMAN KRESS:  And I don't see why
           anybody would associate with people from that
                       DR. APOSTOLAKIS:   And, Mr. Chairman, I
           have a direct conflict of interest here.  So you will
           have to do without me.
                       CHAIRMAN KRESS:  You don't have to leave,
           George.  You can stay.
                       So thank you, Andy, and I don't know who
           the next speaker is.
                       PARTICIPANT:  I follow George.
                       CHAIRMAN KRESS:  You follow George.
                       Okay.  George, as I told everyone else,
           you have to introduce yourself.
                       MR. DAVIS:  Okay.  My name is George Davis
           with Westinghouse.
                       I always like to start off with saying I
           worked in the same place in Windsor, Connecticut for
           about 28 years now, and I'm on my third company.  We
           started out as Combustion Engineering and then became
           part of ABB and then last year became part of
           Westinghouse, which is an indication of how the
           industry is consolidating nowadays and how much things
           are changing.
                       I'm not really going to give today's
           presentation.  The meat of it is going to be given by
           Mike Golay.  Mike Golay is going to talk about what
           we're looking at under a DOE NERI project, Nuclear
           Energy Research Initiative, NERI program, looking at
           the process for how one would go about applying risk
           informed insights into not only deregulation, but the
           design of your nuclear plants, such as Generation IV
                       But before Mike goes into that, I wanted
           to first give you a little bit of a brief overview of
           what we're looking at in a group of three projects
           that includes this one all tied together.
                       Basically, a couple of years ago we put
           together a team of industry labs and university
           people.  Besides ourselves from Westinghouse, we have
           Duke Engineering from the industry side; Idaho
           National Lab and Sandia; labs at MIT, N.C. State.  In
           fact, in one of the other projects we also have Penn
           State that should be mentioned up here.
                       And then as we were looking at regulatory
           issues, we even had a law firm, Egan & Associates, get
           involved so we could bring in some of the insights
           from Marty Mulsh to be here at the NRC.
                       Next slide.
                       What I wanted to do first is time to give
           you an overview of where we see these three projects
           that we're working on going in the long run and how
           they fit together, and then introduce that as a lead-
           in to Mike's presentation on the actual processes for
           design and regulation.
                       The driving force for what we were looking
           at in these projects was the issue of capital cost. 
           Basically when we step back and look at what we see as
           the biggest challenges to nuclear plants being ordered
           in a deregulated marketplace, we keep coming back to
           capital cost as the big issue that we're having to
                       Production costs are looking pretty good
           on the operating plants today.  Fuel plus operating
           maintenance are coming down.  If you look at the best
           performing plants, they're getting close to that one
           cent per kilowatt hour production cost, and with the
           consolidation going on in the industry and continued
           improve, we don't think there's a whole lot of room
           for continued improvement there compared to what you
           can do on the capital side.
                       Secondly, there's the issue that with a
           deregulated marketplace instead of taking 30 years to
           pay back the mortgage on a plant, the investors in a
           deregulated market are going to be looking for capital
           costs to be paid back on a probably 20 year period or
           less, which creates even more pressure to reduce
           capital cost compared to what we saw with the old
           regulated utility environment.
                       And so basically we come to the conclusion
           that if we want to assure that nuclear can be
           competitive against other alternatives, such as large
           coal plants, where we see coal plant costs going,
           we're looking at a need to reduce capital costs on the
           order of about 35 percent or so below where we are
           with a large ALWR, our System 80 Plus design.
                       If we want those to truly be competitive
           against coal plants in the U.S. marketplace for the
           long term, and that means we need to be looking at
           overnight capital cost as a goal, somewhere around
           $1,000 per kilowatt electric, and being able to get
           these plants up and running in about a three year
           production period.
                       So what we've done in these programs is
           rather than tackle a particular reactor design, we
           decided to step back and address the processes and ask
           ourselves what can we do to improve the processes, the
           tools that would be used for designing and licensing
           future plants with Generation IV reactors that could
           help to drive down the costs and cut a lot of fat out
           of the process and provide designers with the
           flexibility they need to be able to really come up
           with new, innovative designs and get those licensed.
                       And so we have three projects that we're
           working on.  The first is looking at risk informed
           assessment of regulatory and design requirements. 
           It's basically looking to develop methodology for how
           designers would use PRA insights in the design process
           in a much more radical approach than we've done in the
           past and how that could also be translated into the
           regulatory process for getting plants improved.
                       Next is the area of smart equipment, and
           basically there we're looking at methodologies for how
           you could put self-diagnostic, self-monitoring
           features into plant equipment, such as pumps and
           valves, as a way to improve reliability at the
           component level.
                       All of this would obviously have some
           benefits from an operating standpoint.  The way we
           think it would help on capital cost is if we can
           address reliability at the component level.  Then that
           should allow us in the above-program on the risk
           informed design process to step back and look at
           simplifying on a system level.
                       In other words, if you can count on higher
           reliability of the components you're using because of
           these smart features built in, self-diagnostic, self-
           monitoring features, then you should be able to look
           at further simplification and not as much redundancy
           being required at the system level if you can 
           encounter a more reliable components.
                       And in the third project we're looking at
           are technologies that can be used for design,
           fabrication, and construction of new plants, again, to
           reduce the cost of those processes.  And there we're
           looking at what can be borrowed from the aerospace and
           automotive industries and the approaches that they've
           been developing over the recent years, again focusing
           heavily on computer based application, to do things
           like collaborative internet based engineering
                       We see that as being related to design of
           regulatory process in the initial program, the top
           program up there, because if you've got designs being
           developed on an Internet based collaborative approach
           like they're doing in the automotive and aerospace
           industries today, then you could talk about in the
           future getting to the point where the NRC and even the
           public can have some limited degree of access.
                       You may have to have firewalls for
           proprietary information in some areas, but the point
           is you could have the whole design process a lot more
           transparent and open where it could be looked at by
           reviewers and the general public as the long-range
           goal for where you're going.
                       So even the tools you used in the design
           process could have some benefits for the regulatory
           approach down the road.
                       MR. LEITCH:  George.
                       MR. DAVIS:  Yes.
                       MR. LEITCH:  Regarding your second
           project, I can see how smart equipment may improve the
           reliability and safety, but I don't quite see how it
           would improve capital costs.  In fact, it would seem
           to me just the opposite would be the case.  Could you
           run that past me again?
                       MR. DAVIS:  For the individual component,
           it would increase the capital cost of that component. 
           If you put in a smart valve, adding those monitoring
           features and the computer software to go with it, it's
           going to add to the cost of that valve.
                       However, let's say you've got in an ALWR
           like our System 80 Plus.  You've got a four train,
           high pressure safety injection system.  If you can
           show high enough improvement in reliability and
           individual components, you can go back and question do
           I really need four trains of redundancy, if I can
           count on the reliability of the individual components
           in each system.
                       MR. LEITCH:  That would be in a future
           generation plant though.
                       MR. DAVIS:  Yes, this is all looking down
           the road at Generation IV type reactors.  I mean, none
           of these projects as I see it can lead to processes
           that are going to be immediately available and can be
           applied today.  These are things that would be applied
           down the road for Generation IV.
                       Now, we do see some potential that there
           could be some spinoff applications along the way for
           things like the pebble bed modular reactor, things
           that might be developed for that, but these projects
           were originally set up with the goal of developing
           some very long range programs that would lead to
           design activities of Gen. IV reactors in about ten
                       This figure, it looks like the cross-
           section of a circular firing squad the way it's
           pointed in, but the point here was that in looking at
           how you risk inform the process, one could start out
           at the very left side of the figure with the
           deterministic requirement we have now and then looking
           at those case by case, individually like we're doing
           with the operating plants and asking where it can be
           risk informed, those individual deterministic
                       At the other extreme on the right-hand
           side, one could go to a more risk based approach where
           you design based on the PRA, but recognizing that
           state of the art PRAs are such that they're not
           perfect and there are uncertainties not only in the
           techniques, but in the database for PRAs, that you're
           going to have to back up and add some degree of
           deterministic requirements in to make the process work
           to cover those uncertainties in PRA capabilities.
                       We basically started out in this project
           thinking that we would start on the left side and work
           across, but we quickly got to the conclusion that the
           only way we're going to be able to come up with a
           revolutionary new approach is for designing and
           licensing plants that were going to allow some
           substantial cost savings, was if we went to something
           more revolutionary, where we went to a more risk based
           approach and then back up to decide what needs to be
           entered in.
                       And that's a good example, I think of
           where having labs, university, and industry working
           together has been a good synergy, because from an
           industry standpoint, we started off thinking in the
           box on the left side, and the input we got from the
           lab university people really caused us to step outside
           the box and think more revolutionary on how we needed
           to go with this, starting with the right-hand side of
           the figure.
                       Basically, as far as these projects are
           concerned, because they're rather limited funding,
           they'll wrap up next year.  They're just intended to
           lay a framework or a foundation for where we would see
           these methodologies going.
                       The ultimate implementation of these is
           going to depend upon several things happening.  One is
           we're starting to coordinate our effort with NEI.  As
           you'll hear from Adrian Heymer later this afternoon,
           I believe, he's going to talk about NEI's effort, that
           they're cranking up a task force to look at developing
           a risk informed framework for further plants.
                       And it's our intent to coordinate what
           we're doing in our project with them, but we'll have
           a representative on their task force, and the goal
           would be to make sure that what we do in our project
           gets folded into what they're thinking about in that
           task force and that we come up with consistent
           results.  They may not have to match up exactly, but
           we obviously would like to try and have some
           consistency there.
                       Very importantly, I think we want to wind
           up in a situation where the technology road map
           activities for the Generation IV reactors, that road
           map that's being developed, needs to think about not
           just developing new designs, but developing processes
           to be used in designing and licensing those Generation
           IV reactors, too.
                       So we're hoping that what we do in laying
           the foundation for these engineering projects get
           reflected in the thinking for the Gen. IV road mapping
           effort so that there's some consideration of
           processing as well.
                       I might also add as a final point I've
           also participated in an IEA activity where they're
           putting out a technical document later this year on
           optimizing technology for water cooled reactors. 
           Although it says water cooled reactors, it's really
           applicable to all three reactors, and it will embody
           a lot of the same philosophies that we're looking at
           in the engineering project.
                       With that I'll turn it over to Mike to go
           into the discussion on what we're looking at in this
                       DR. GOLAY:  Thank you, George.
                       Could we go to the next slide, please?
                       I'm going to speak about the specific work
           that has come out of the regulatorily oriented process
           among the three that George described, and I'm
           reporting on behalf of the overall project and
           particularly of the team from MIT, Sandia, and
           Westinghouse, where the most active members are listed
           here.  Half of that team is in the room, and so if you
           want to follow up after this meeting and discuss
           things with them, they'll be available to do it.
                       Go to the next slide.
                       The thing that we have been focusing on is
           really to try to create a comprehensive regulatory
           approach that comes up with a method which is both
           comprehensive and systematically consistent logically
           and can be expected to create incentives such that
           designers will naturally have reasons to do the things
           which regulators recognize as being important in
           coming up with good technologies.
                       So we've looked at it from the point of
           view of an overall system to produce electricity
           successfully where the designer's task is really in
           both areas, and today we're going to focus on the part
           having to do with safe production, but we recognize
           that the designer has to produce an economically
           attractive plant and hopefully corresponding to some
           of the goals that Neil Todreas outlined earlier in the
                       So the focus here is going to be over on
           safe production, but we want to have the incentives
           aligned so that you achieve both of these and do a
           good job on safety.
                       What I want to do is begin by posing two
           questions to the ACRS, and that is fundamentally the
           issue, I think, for the NRC is what do you do in terms
           of regulatory reform.  The fact that this session is
           being held is a recognition that the current process
           needs improvement.
                       The fact that every new applicant for a
           new reactor concept comes in where a part of his
           proposal is a new regulatory treatment is, again, a
           symptom of the need to improve things, and so the
           issue is not whether improvement is needed, but rather
           what should be recommended by ACRS and what role
           should NRC play in achieving the improvement.
                       My specific suggestion is that we need an
           effort where the overall national effort for advanced
           reactors includes a component of regulatory reform
           with the NRC being involved, but I think realistically
           given the funding situation that the NRC faces, it
           probably is not in a position to take the lead.
                       But that's a question I'd like to ask the
           ACRS to ponder, and if you feel like offering advice
           to do so.
                       And the second thing I want to do is
           outline then for you the kind of product that we have
           been able to develop so far where essentially it's a
           work in progress, where there are some ideas of how to
           attack this problem that we'd like to present so that
           to the degree that you accept them, they can begin to
           soak in, and to the degree that you think we need to
           reconsider things, we can get the benefit of your
                       Some of the fundamental ideas are listed
           here, and they're somewhat revolutionary.  The top one
           is that the process of regulation is guided by
           decisions which are made based upon the beliefs of the
           decision makers, that is, the regulatory personnel.
                       This idea of beliefs as opposed to
           evidence is very important because what we would like
           to do is find a way so that those beliefs which
           cumulate in the evaluation of a reactor concept and
           how it's operated, that one way we can state this is
           in a probabilistic format, essentially using for
           continuous variables a probability density function as
           a way of addressing the relative likelihoods of the
           range of possible values that the evaluator thinks are
           worth considering.
                       And that when we approach things in this
           fashion, what you're naturally led to is that when we
           try to formulate acceptance criteria, that we do it in
           terms of expected performance and also associated
                       And Tom Kress already alluded to the idea
           of making your acceptance decisions based at some
           level of confidence, which would be an example of how
           you might approach that.
                       DR. WALLIS:  Your choice of words is
           interesting.  "Belief" tends to be associated with
           yes/no, I believe, I don't believe, I believe in
           nuclear power, I'm against it sort of thing.
                       DR. GOLAY:  No, I'm not talking about
                       DR. WALLIS:  I know you're saying it has
           to be probabilistic.  So I tend to agree with you. 
           It's just the choice of the word "belief" is a little
                       DR. GOLAY:  Let me distinguish.  I'm not
           trying to speak about values, which perhaps is the
           version of that term that you're honing in on, but
           rather, in terms of the conclusions that an evaluator
           will reach regarding the relative likelihoods of
           alternative answers.
                       CHAIRMAN KRESS:  It's the Bayesian concept
           of probability.
                       DR. GOLAY:  Exactly, exactly.
                       DR. WALLIS:  A state of knowledge is
                       DR. GOLAY:  Right, exactly, and so what
           we're leading to is a formal statement of that in a
           formalism that is scrutable by everyone, and what this
           really flows from is a conclusion that the problem of
           safety regulation is not one of expected performance,
           but rather of treatment of uncertainties.
                       Now, I know this is probably not a novel
           concept to the folks here, but if you look at
           proposals that we have had for regulatory improvement,
           they're almost always focused on what should be the
           deterministic expected performance criterion, and then
           how the things perform in terms of that, when, in
           fact, the big problem is dealing with the associated
                       And what we've tried to do is turn the
           problem around and make sure that uncertainty is
           imbedded in what we do from the very beginning so that
           it has prominence at the same level of expectation and
           is handled in a formally explicit fashion.
                       So that's what's behind what I have there. 
           We go to the next page.
                       DR. WALLIS:  This is an unfortunate term. 
           I mean, if you tell the public you're uncertain --
                       DR. GOLAY:  Yes, and I frankly want to
           separate the problem of public communication from
           technological evaluation, and the reason is that I
           think that I didn't really mean to get diverted on
           this, but I have an answer for it, which is that I
           think we have made a mistake among engineerings of
           falling into engineer-speak where the idea in public
           communication is that if I communicate in the
           vocabulary which I feel is most valid and with which
           I am most familiar, I can also be most effective, and
           I submit that the task of public communication is not
           one of communicating a message concerning how hardware
           will perform, but it is focused on helping the public
           in their search for who to trust for dealing with the
                       And so the format for what we're
           presenting here is not amenable to public
           communication, but the task that has to be
           accomplished in successful communication is really a
           different one of giving people a reason to trust that
           you will make good decisions.
                       Now, that's my answer.  Other people will
           have other answers, but I'd like to separate the two.
                       Okay.  On the approach which we have,
           we're also stating that regulatory questions,
           unanswered issues concerning license submittal or
           licensee behavior and their acceptance criteria, if
           we're going to use a probabilistic framework, then
           these questions and criteria have to be stated in that
           framework as well.
                       So what we do is really use a
           probabilistic treatment as the integrating and
           systematic basis of evaluating a submittal, but we
           continue to use deterministic models, data, tests, all
           of the tool kit of evidence that we've always used,
           but use it to support the probabilistic presentation
           and to try to incorporate all of the questions which
           are relevant to successful performance into what is
           essentially a much expanded PRA.
                       This would require that both the license
           applicant, who right now has the burden of proof in
           terms of evidence, and the regulatory staff in
           parallel justify their decisions explicitly in this
           probabilistic framework.
                       This is partly in answer to Andy Kadak's
           point about the bring me a rock syndrome, and that is
           what we would do if you accept the approach which
           we're suggesting is that the warm, fuzzy feeling and
           the bring me a rock would be translated into state
           your evidence in a probabilistic format that we're
           suggesting here just as the licensee must do.
                       And as part of this, you're very quickly
           led to the need for subjective judgment and
           incorporating that into the overall process, which if
           you think about it, we do today, but we don't do it
                       And the one use of the probabilistic
           format is to provide a vehicle by which to state those
           judgments and, again, make them scrutable and to
           incorporate them formally into the answer upon which
           you base your regulatory decision.
                       That is a subtle thing to do, and it
           requires development of processes for capturing those
           judgments.  Today what we have are informal processes,
           but we use them.  You know, the ACRS is a good example
           of that.
                       CHAIRMAN KRESS:  I'm going to ask you my
           standard question.  In this type of regulatory
           framework --
                       DR. GOLAY:  Keep going.
                       CHAIRMAN KRESS:  -- which I'm very taken
           by, how do you see the words "defense in depth"
           fitting into that?
                       DR. GOLAY:  Fitting indirectly.  I'll come
           to it.
                       CHAIRMAN KRESS:  Okay.
                       DR. GOLAY:  Give me about five more
           slides, and if I haven't answered it, ask me again.
                       CHAIRMAN KRESS:  Okay.
                       DR. GOLAY:  Okay, and because
           disagreements in these evaluations are inevitable,
           some process of resolution will be required, just as
           today in the regulatory system we have an appeals
           process, but it's formulated more looking at things in
           a deterministic fashion.  So we anticipate the need
           for that.
                       Okay.  You see this kind of hierarchy
           structure going from high level safety goals down to
           inspection requirements and things like that.  We
           would basically stay with this, but what we would do
           is try to handle things, as I say, using PRA as the
           integrating method and continuing to focus on the same
           kinds of essential safety functions that you want to
                       So nothing has really changed in the
           structure here, but the way you would go about trying
           to show satisfactory performance is what we would
                       Could we go on?
                       CHAIRMAN KRESS:  How would you deal with
           the issue that Dana gets very concerned about, and
           that is the PRAs are traditionally, the ones we have
           now, very incomplete.  They don't deal with shutdown
           conditions very well.  They don't include fires very
           well, and seismic even is often not treated very well
           in human -- would you incorporate those kinds of
           missing ingredients into the uncertainty of
                       DR. GOLAY:  Yes.  Now, basically the way
           you would incorporate them is through a statement of
           the subjective judgment of those who have to assess
           what practices --
                       CHAIRMAN KRESS:  That's where your
           subjective uncertainty comes into play.
                       DR. GOLAY:  That's right.  So where
           objective evidence reaches its limits, then you have
           to go to subjective, as we do today.  We just don't
           spell it out.
                       DR. POWERS:  Let me ask a question. 
           You're going to expand the capability of PRA to carry
           this out.  One of the areas you're going to expand it
           to carry it out is in the shutdown risk.
                       Now, I presume that you have a plant here
           that you say is going to have some history, and during
           that history it's going to have various kinds of
           shutdowns, those that it planned, which is going to do
           a variety of activities that are going to be quite
           different, and it's going to have an occasional
           unscheduled shutdown.
                       And you can prognosticate all of those
           things, all of the different configurations of the
           plant that go on during a shutdown, a scheduled
           shutdown for refueling and whatnot.
                       DR. GOLAY:  I would say that your task in
           those areas has not changed from the task that people
           have today; that when you go to consider a license
           application, you try to consider the spectrum of
           conditions under which it will be operated, and using
           evidence appropriate for each condition, judge whether
           it will be operated successfully.
                       So that --
                       DR. POWERS:  But now we don't try to
           quantify --
                       DR. GOLAY:  That's right.
                       DR. POWERS:  -- those times and
           configurations, and yet you want us to do that.  How
           is this possible?
                       DR. GOLAY:  Well, I think that the
           development of shutdown risk analysis provides an
           illustration of how you do that in, say, a non-power
           state, and when you're comparing operations between
           those states, you, as Tom just brought out, you
           inevitably come to situations where the available
           objective evidence is not sufficient for you to
           determine, say, which practice is better.
                       Do you do maintenance while you're shut
           down or do you do it on line, for example?  And,
           again, subjective judgment has to come into the
                       And what I'm submitting is that we use
           that subjective judgment today.  We simply don't spell
           out loud the factors the way that we're weighing the
           factors, and what's changed with the approach that
           we're suggesting is that we state it in probabilistic
           terms and incorporate it into the PRA.
                       CHAIRMAN KRESS:  Let me expand on Dana's
           question a little.  What I'm interested in is the risk
           associated over the full lifetime of the plant.  That
           means shutdown number 85 is going to take place n
           years from now I need to incorporate into my risk
                       Now, since I don't know what that shutdown
           consists of, what planned maintenance they're going to
           have because it hasn't even come about yet, it may
           even be an unplanned shutdown.  How do I know how to
           incorporate the short time during shutdown, short
           compared to other things?  That risk, how do I put
           that risk component into my risk assessment when I
           don't even know what it -- we're dealing with a
           change, a variable configuration in time rather than
           a fixed configuration, which is what PRAs usually deal
                       How do I deal with that in a PRA?  Is that
           something that needs a new PRA methodology for?
                       DR. GOLAY:  I would submit not, but let me
           go to why  The first question that may arise is why do
           you  need research on regulatory reform.  Why can't
           you just get a few people to go off and think in the
           corner for a time and come up with some proposals and
           then try them out?
                       My experience has been that you don't know
           what is a good idea until you've gone through some
           feasibility attempts; that there's an iterative
           process here, and that's the heart of doing that kind
           of research, to find out what's feasible and then from
           that find a good blend of feasible approaches
           consistent with an over arching logical framework.
                       In terms of the question you've asked, I
           would suspect, without having tried to do the analysis
           you said, that, first of all, the level of detail
           required is probably not necessary; that approaching
           it from the point of view of looking at safety during
           shutdown and trying to anticipate a range of
           conditions that you think are reasonably plausible,
           which is the approach we have today, I think that that
           will work.
                       And what I would try and do is turn it
           around and try and use a real probabilistic treatment
           of the safety, but not to try and anticipate the fine
           detail the history of a plant that might occur or
           might not occur.
                       CHAIRMAN KRESS:  You could use past
           experience of what has occurred.
                       DR. GOLAY:  That certainly would be part
           of it.
                       CHAIRMAN KRESS:  The database maybe.
                       DR. GOLAY:  Yes, exactly, exactly.
                       Does that respond to what you brought up,
                       DR. POWERS:  Yea, I was bringing it up for
                       DR. GOLAY:  Okay.  All right.  Let's move
           on or we're going to be here until four just on this
                       George showed this slide earlier, and
           essentially where he said that we are in our work is
           over on the right-hand side, which is taking a top-
           down and probabilistically based approach, and it's in
           complement to most of the other approaches that I've
           seen, which are really trying to find an accommodation
           with the existing approach, partly because they're
           driven by the need to get a license.
                       You know, as people say, you don't drain
           the swamp when you're to your rear in alligators, and
           that tends to be the situation for most of these
           projects, although I'm sure that many people are
           thinking about the whole range of this.
                       But our starting point is over here, and
           that's one way in which as far as we know, our work is
           somewhat different from the others.
                       However, the elements that go into it are
           the kind that you see always, which are that you want
           to find a way to incorporate defense in depth and
           safety margin.  These are good design practices
           regardless of the regulatory approach.
                       And one of the things that led us to the
           suggestion we're making today is that we wanted a way
           to state the benefit that you get from these various
                       DR. WALLIS:  Do you have a good measure of
           safety margin in a probabilistic sense?
                       DR. GOLAY:  Yes.  If you're using margin
           on let us say approach to melting temperature or
           something of that kind, what that would translate into
           would be to formulate your acceptance criterion from
           the design point of view at a very, very high
           confidence level so that you insure -- and you, of
           course, could say that let us say your 99 percent
           level could be somewhat reduced from what you think is
           the actual failure point, would be a way that you
           would do that.
                       DR. WALLIS:  But once you start saying
           there's a failure point, you are making things
           deterministic, which really are not.
                       DR. GOLAY:  Well, I'm trying to relate it
           to the current design process.
                       DR. WALLIS:  That's right, but I think it
           would be interesting to see what you could do with a
           definition of margin which got away from these ideas
           of having a point or --
                       DR. GOLAY:  Right, and what you would do,
           as you're hinting, is really to use a distribution on
           all of the performance limits, and that would be a
           natural evolution that I think we would go to and
           probably quicker than I'm anticipating.
                       DR. WALLIS:  You would look at the
           probabilities of all of those and the consequences of
           all of those.
                       DR. GOLAY:  Right.  That's right.
                       So what you expect is that if people are
           using the approach we're suggesting well, they would
           have natural incentives to put defense in depth into
           their designs partly because they could see a benefit
           for doing it when they go and make a regulatory
                       The same thing with margin.
                       CHAIRMAN KRESS:  How do I decide what
           confidence level constitutes an acceptable margin?
                       DR. GOLAY:  My short answer is you have to
           work on it.
                       DR. GOLAY:  Well, it's partly a social
           policy and has to be worked out with --
                       DR. POWERS:  We've been working on it, by
           the way --
                       DR. GOLAY:  -- the regulator.
                       DR. POWERS:  -- for four years that I know
                       CHAIRMAN KRESS:  I'm glad you said that
           because that's my belief also.  It involves things
           like the loss function, for example, in decision
                       DR. GOLAY:  Right.  And so if we're
           successful in our work, what we will do is kind of set
           some directions for future work to pursue because some
           of these, as you know, are very subtle.  But if we
           accept the overall approach that we're trying to lay
           out, that's the most important thing that we really
           want to get across.
                       And then there is a lot of research for
           professors to do, keeping lab personnel out of
                       CHAIRMAN KRESS:  Yeah, we've got to keep
           them occupied.
                       DR. GOLAY:  Right.  There you go.  Well,
           that's never been a problem.
                       Could we go to the next slide?
                       One of the other points that I want to
           make is that we tried to come up with a regulatory
           approach which would be useful at different conceptual
           stages of development.
                       One of the things which I've observed
           makes consideration of regulatory change, makes those
           discussions difficult is that if you don't state the
           level of maturity of the concept, what's approach
           becomes a difficult conversation because what's
           appropriate in one circumstance may not be in another.
                       But this notion that you're using a
           combination of probabilistic analysis and essentially
           your best set of probabilistic with deterministic test
           experience and judgment at any stage of maturity is
           the consistent part.  And I'll come back to this in a
                       And the idea is that as the maturity of a
           concept grows, that the level of detail and our
           ability to introduce concepts that we're familiar with
           from light water reactors, such as DBAs, design basis
           accidents, that that will also grow, but that at an
           early stage, some of this may not be applicable.
                       Can we go on?
                       So in this table, what we've tried to do
           is put together an illustration of what we're talking
           about in terms of different levels of maturity as we
           go from an initial concept to the nth plant as we have
           with light water reactors, where there are many of
           them around and where we have a lot of experience
                       And basically the regulatory system gets
           into it in the lower three rows of this figure, where
           you may have an initial detailed design, but where
           it's not feasible to do more than formulate the high
           level acceptance criteria, and where our level of
           detail in the knowledge of the system is also fairly
                       The idea that I want to get across is that
           as we work our way down the figure and later into
           time, that the amount of detail, the number of finely
           crafted performance goals that you can come up with,
           and your ability to translate those into deterministic
           decision rules will tend to grow, but in the early
           stages, you tend to stay high level and mostly
                       DR. WALLIS:  It's an interesting idea, but
           it seems to me that as you learn more about a plant,
           you might actually get less detail than any kind of
           plan.  You might really know what you have to worry
           about and you don't need all of this detail.
                       DR. GOLAY:  Conceivably, and we've seen
           that, for example.  I would say that the evolution of
           the passively based water cooled reactors could be an
           illustration of that.
                       But one reason for putting this figure
           together is to address this question of where does the
           design basis accidents and general design criteria
           come into the picture here, and I would say it's a
           tentative conclusion, not a firm one, that those
           really play a role when you get to the detailed design
           and later stages of things because when you try to
           formulate design basis accidents, you have to have a
           design.  You have to have a concept in which to think
           about and have some seasoning in terms of your
           understanding of its weaknesses, things of that kind.
                       And if you look at what we've done with
           light water reactors, we've gone through the evolution
           shown here, but with not quite knowing it or not
           saying it out loud, and especially the reason I've put
           this up concerns general design criteria.
                       That is, if you look at the general design
           criteria that we have for light water reactors today,
           most of them are motherhood statements.  They're
           essentially do good things, put in margin, put in
           conservatism, defense in depth, and so on.
                       There are a few things like have a
           containment, have redundant shutdown systems, which
           are spelled out, but most of the criteria are not, and
           they're formulated in a way which reflects what's
           feasible, mostly driven by light water reactor.
                       And one idea which we think is worth
           exploring is whether that the formulation of GDCs
           should be done at a concept specific basis, reflecting
           some accumulation of study and experience.
                       And it bears on the question, for example,
           of whether you need a containment for the gas cooled
           reactors, and I'm not going to offer an answer for it. 
           I'm just suggesting that with this framework, you
           might delay trying to answer that question until
           you've gone through some evaluation in this as opposed
           to starting by, you know, God said you have to have
           containments, and then from that we go on to other
                       DR. POWERS:  And He did.
                       DR. GOLAY:  Or She.
                       DR. GOLAY:  Okay.  Can we go on?
                       The other point I want to make is that
           there's nothing in what we've prepared which is
           inconsistent with the cornerstones, with the approach
           that the NRC has been taking in terms of restructuring
           the emphasis in the design and regulatory concerns.
                       What we have focused on in our work on
           examples is over here in the reactor safety part of
           the structure, but when we've looked at it, we don't
           see anything that would stop you from going to the
           other issues.  We just haven't had the resources to
           work on them.
                       Can we go on?
                       And in terms of setting performance goals,
           what we've done, this is an illustration of a master
           logic diagram to help you identify initiating events
           that would be important in your event sequences or
           your accident sequences, as Andy Kadak had suggested,
           replacing the design basis accidents by the risk
           dominant event sequences has some attraction.
                       And what we've concluded is that you
           really have to break this into two parts.  One is a
           general treatment at a very high level where you have
           certain performance goals, and as we go down in the
           hierarchy here of this fault tree, going to finer and
           more finely defined events or the concatenation into
           creating a public threat, that there's a general level
           at which you can set performance goals and where the
           safety goals are examples of that, and then below
           that, when the details of the concept become
           important.  The kinds of failures that you worry about
           and the combinations of events then will be concept
                       And so we're seeing a two-step way of
           approaching the fault tree and from that the master
           logic diagram and eventually the initiating events,
           which are of primary importance.
                       So, for example, what's in the handout
           figure is kind of our first shot at how you would draw
           this for a gas cooled reactor.  It's by no means
           complete or even correct in every detail, but the
           purpose is to illustrate how some of the initiating
           events and failure modes that show up are not those
           which show up for water cooled reactors.
                       For example, one of the things in here is
           failure of the radiative cooling path, which in the
           water cooled reactors we don't even worry about.  I
           mean, when you think about it, this becomes obvious,
           but it's an illustration of how you would go about
                       Okay.  Could we go on?
                       How much time do I have, Mr. Chairman?
                       CHAIRMAN KRESS:  We are supposed to -- you
           have about 15 minutes more.
                       DR. GOLAY:  Okay.  Keep going.  I'm going
           to skip over the next, I think, three.  Right.  Stop
           there, please.
                       Okay.  The last thing that I want to move
           to is interaction between the applicant and the
           regulator, and what are the implications for the
           approach that we're suggesting?
                       And what we're really focusing on is that
           when you have an applicant come in with, let's say, a
           new reactor design application, what they do, they
           submit all of their documentation, of course.  They go
           through review under the standard review plan, and all
           of that is preliminary to what is a negotiation
           between the licensee and the applicant regarding
           what's acceptable or unacceptable about the design,
           and then it's up to the applicant to find a way to
           satisfy the regulator.
                       We expect that that process would
           continue, but that it would be replaced.  Today it is
           really focused around how will systems do concerning
           design basis events with consideration being given to
           evidence from things like the PRA and treatments of
           uncertainty and so on, but the DBA has played a
           central role in the way things have been structured.
                       What we would do is reverse that and have
           the probabilistic integration of the system
           performance be the primary vehicle used for the
           evaluation, but the much more comprehensive version
           spoken about, and that the acceptability negotiation
           would be conducted in the context of the RPA, where we
           would need consistent procedures, tools, and
           termination criteria for this negotiation process.
                       That's for reviewing new designs.  We
           anticipate that for the regulation of construction and
           the regulation of operations, that formulation of a
           set of deterministic rules, but based upon risk based
           information could be done, and we think that that's
           desirable for practical reasons, for people in a
           construction site.  You don't want them running PRAs
           all the time and making decisions.
                       But we're suggesting that if the review of
           the new design, that it is a practical thing to
           undertake today, particularly when you're looking at
           marginal changes in the performance.
                       Okay.  Can we go on?
                       And so I want to give an illustration of
           how this negotiation or discussion might proceed,
           where the idea is that initially a designer would come
           up with a plant design satisfying the goals of that
           first figure that I showed, producing economical and
           safe electric power, and that it's his or her
           responsibility to come up with a design that will do
           that very well.
                       When the designer, design team, more
           realistically, thinks that they have satisfied the
           performance goals that have been formulated by the
           regulator, they submit their application and it's
                       Presumably there will be some areas of
           disagreement regarding the adequacy of the submittal
           because that tends to be the nature of the licensing
           process.  However, what we're expecting is that the
           disagreements should be in terms of the expected
           performance, safety features, the performance criteria
           that were used internally to decide that they would do
           well, and the methods and analysis, that is, the data
           and models used, and that this process be documented,
           again, in the probabilistic terms.
                       Can we go on?  We seem to have lost
           something here.  Yes.
                       DR. WALLIS:  Let's try to think about
           this.  The method of design and analysis is going to
           be in probabilistic terms.  You mean that every time
           you put a correlation in a code, you have to do
           something probabilistic with it?
                       DR. GOLAY:  Only if it propagated through
           into your risk evaluation.
                       DR. WALLIS:  It probably does.
                       DR. GOLAY:  Yeah.  For example, if your
           new correlation had a different uncertainty treatment,
           you would expect that to be propagated through, yeah. 
           That's right.
                       Okay.  Can we go to the next one?  This
           one isn't coming through, but what it's meant to
           illustrate, I'll tell you what you would be seeing if
           it were showing up, which is above the line showing an
           iterative risk based design process, and below the
           design, showing an iterative risk based review and
           feedback of that process.
                       So below the line we're dealing with the
           negotiation between the designer and the regulator. 
           Above the line, we're dealing with the designer trying
           to do a good job in the first place.
                       Ah, there we go.  Okay.
                       And hopefully when they've gone through
           this, they will eventually reach satisfaction on the
           acceptance criteria and gain a license.
                       Okay.  Let's go on.  Oh, no, not another
           one.  That's the same one.  Is there any way to turn
           this off and move ahead?
                       DR. APOSTOLAKIS:  It was too fancy.
                       DR. GOLAY:  Yeah, I can see that.  I can
           see that.
                       And this is what we foresee that the
           designer would be doing, and that is -- and I'm going
           to give you an illustration of this, which is start
           off with what we call the bare bones design, and this
           is only an illustration of how we think it might
           proceed.  This isn't a requirement for anybody to do,
           but essentially create a design to produce
           electricity, and then go through and ask:  well, what
           are initiating events which could cause a safety
                       And it doesn't just have to be core
           damage.  It would be in all the cornerstones.
                       To use a PRA to identify the dominant risk
           contributors, and from that to identify mitigative
           features and systems that could be used to alter that
           PRA profile and iterate on this until finally the
           design comes to satisfy a vector of acceptance
           criteria, which would be formulated at whatever is the
           right level for maturity.
                       DR. WALLIS:  Couldn't there be a scaler
           that says that whatever your PRA produces must be less
           than some number?
                       DR. GOLAY:  Within a certain area of
           performance, that would be the case, but we recognize
           that there will be many areas of performance.
                       For example, you may want to have the
           frequency of initiating events to be very low,
           satisfying one of the cornerstones, and you may also
           want to have a very low core damage frequency, as well
           as a very low frequency of activation of the off-site
           emergency plan.
                       So, in general, we're anticipating a
           vector, but each element would be stated in
           deterministic terms, and so this is what the designer
           would be going through before the submittal and then
           afterward, following the negotiation.
                       Okay.  Can we go on?
                       One of the things which we want to get
           across is, and this figure doesn't do such a great job
           of it, is that the formulation of the acceptance
           criteria, once you go below that line of concept
           specific performance criteria, has to be determined
           iteratively because how you divide what's acceptable
           in a high level performance goals into a set of
           subgoals depends on what's feasible.
                       And so, for example, I want to use the
           example of for a light water reactor LOCAs of
           different size.
                       Go on.
                       Where when we went through with the
           Westinghouse design team for the set of very small
           LOCAs, small LOCAs, and large LOCAs with a particular
           mitigative system, what we ended up with is this array
           of core damage frequency, where you see it's a non-
           uniform distribution, and that's the key point we want
           to get across in this illustration.
                       So that as you take the overall division
           of what's acceptable ways of having core damage, that
           you wouldn't necessarily divide them up uniformly
           among all of the categories of such events.
                       And that's a reflection of what we are
           trying to talk about when we say you have to do some
           work to see what is feasible to do, and the answers
           will be different from one concept to another.
                       DR. POWERS:  When I look at this table,
           I'm not sure what numbers I'm looking at.
                       DR. GOLAY:  Well, it's the right-most
           column that I really want you to --
                       DR. POWERS:  Yeah, I know, but I want to
           get to that right-most column.  Are these -- am I
           looking at products and means or something else?
                       DR. GOLAY:  Means.  These are for purposes
           of illustration.
                       DR. POWERS:  So mean time a mean equals a
           mean?  I don't think so.
                       DR. GOLAY:  Yeah, I think for purposes of
           what we're talking about, but if you want to do it as
           the integrated result to the stated confidence level,
           we can do it just as well.
                       The key point that  I really want to get
           across is that you can't simply sit in your office and
           decide, well, I'll slice up the risk pie in, let us
           say, a uniform way or some way that I particularly
           like; that it's always a compromise between what's
           feasible and what's desirable, where I would say
           what's most desirable would be to try to spread the
           risk among sequences as much as you can or not put
           your eggs in one basket, but for various physical
           reasons, your ability to do that may be strained.
                       DR. WALLIS:  Why do you need subgoals?  It
           seems to me that if you had a plant that had no LOCA
           probability at all because of its design, then you
           might trade this off and be allowed to have more
           probability somewhere else if something else and all
           you care about is the total.
                       DR. GOLAY:  But you care about the
           uncertainty associated with the total as well.
                       DR. WALLIS:  Yes, you do, but the total,
           the bottom line is the thing, not really how it breaks
           up in all these pieces.
                       DR. GOLAY:  Yeah.  Well, I would say that
           another reason why you want to do this is that in the
           long run for regulatory convenience and efficiency,
           you probably want to move -- try to find risk-based
           deterministic decision rules as you reach a high stage
           of maturity, and so there will be sort of natural
           incentives to formulate subgoals as the concept
                       And that's the reason we have this in
           here, simply to illustrate that you have to go through
           this iterative process.  It's not to carry it further
           than that.  Okay?
                       CHAIRMAN KRESS:  Would there be a guiding
           principle on how to -- this is more or less talking
           about rationing the risk among the various --
                       DR. GOLAY:  Right.
                       CHAIRMAN KRESS:  -- as a defense in depth
           concept.  One does this because he's uncertain about
           each of these results.
                       DR. GOLAY:  Right.
                       CHAIRMAN KRESS:  And so he wants to spread
           that uncertainty out, but is there some guiding
           principle one could come up with that says that that
           uncertainty, overall uncertainty, ought to be either
           minimized by selecting these distributions to optimize
           the level of uncertainty of each one so that it's
           minimized at the end, or so that it's acceptable, or
           is there a guiding principle on how to make this
           allocation of risk?
                       That's what --
                       DR. GOLAY:  I think we have to do some
           work on it before we really know the answer to your
           question.  My suspicion is that we want to go in the
           directions that you're saying, which is to try to make
           the distribution reasonably uniform and the total
           small at whatever your stated confidence level is.
                       But I'm sure it's more subtle than that.
                       CHAIRMAN KRESS:  There has to be some
           other principle that tells you how to do this.
                       DR. GOLAY:  Exactly.  And what I'm
           suggesting is the principle is really one of trial and
           error to see what it is that's feasible to do.
                       CHAIRMAN KRESS:  And, of course, that
           would enter into it.
                       DR. GOLAY:  Yeah, and I'm doing this
           because the message I want to get across is that
           formulating a practical system that people can really
           use takes some work, takes some sustained resources
           and is sometimes pretty subtle.
                       Okay.  Can we go on?
                       So I  want to go through how we did this,
           our team, concerning dealing with LOCA events where we
           came up with an improved system over the -- this is
           for light water reactor system.
                       Started off with a bare bones system and
           then from that added in some mitigative active
           systems.  So I'm not suggesting this is the best
           design you would want to use, but it's one that's
           consistent with the active light water reactors, such
           as we have.
                       And so we have two high pressure injection
           systems, one low pressure system.  I won't read all of
           this to you, but essentially some of the usual
           candidates, passive DC power, shared chemical and
           volume control system.
                       And from this, our designers contended
           that they had an acceptable design.
                       Can we go on?
                       And so what we're foreseeing for this
           negotiation is a process outlined, is in the flow
           chart on the next figure, where the applicant thinks
           he's done an adequate job and makes the submittal. 
           Upon review, the regulator says it's not adequate
           basically because of a dispute concerning modeling
           assumptions, which could be resolved by getting better
           data, and the reason is that the core damage frequency
           associated with the high pressure category of LOCA is
           seen to be too great.
                       One way that it could be solved is to have
           a research program, go out and get more data.  Instead
           the designer decides to alter the design, and what he
           does is go and decide he wants to make the response to
           high pressure LOCA be one of depressurization, and so
           he does this by putting in a train of depressurization
           capability in his shop, not going back to the
                       The result is that the core damage
           frequency is still too high.  That is, we have an
           acceptance criterion in terms of the core damage
           frequency or LOCA.
                       And so in the next iteration, the designer
           comes, and he puts in an additional train of
           depressurization capability, still finds that it's too
           high, and the reasons upon investigation are that
           common cause failures involving the cooling system and
           the emergency diesels are too high.
                       Could we go on?
                       CHAIRMAN KRESS:  Now, go through this
           process.  I have to have in mind a CDF that's
           acceptable for just LOCAs.
                       DR. GOLAY:  Yes.
                       CHAIRMAN KRESS:  Or for LOCAs of different
           sizes, which is kind of a tough number to come by. 
           You know, I've got an overall CDF in mind, but I don't
           know how to fractionate that up among LOCAs and other
                       DR. GOLAY:  Right, but what we're
           anticipating is --
                       DR. POWERS:  Why don't you just do it?
                       DR. GOLAY:  Now, we're not saying how the
           number was gotten at.  We just want to illustrate how
           the process would go forward, and if such a criterion
           were to be formulated, this is how we would expect it
           to be tested on whether it's acceptable.
                       In the very early stages, I think you'd
           have trouble formulating that.  In the later stages of
           maturity, you might be able to.
                       CHAIRMAN KRESS:  Somewhere along the line
           we've got this.
                       DR. GOLAY:  Right.
                       DR. POWERS:  Why would you want to wring
           your hands over it?  Why not just say, as is
           apparently done here, "I don't want it above two times
           ten to the minus sixth on a LOCA"?  Which one is more
           capricious and arbitrary?
                       CHAIRMAN KRESS:  It might very well be
           that my overall CDF goal is, say, ten to the minus
           five, and nothing contributes to that except the LOCA,
           and I might very well be willing to accept it as ten
           to the minus five.  That's the confidence level.
                       DR. POWERS:  You might well be willing to
           after the fact change things, but if you're just going
           through this exercise here that he's outlined, --
                       CHAIRMAN KRESS:  You're saying you don't
           need the -- when you look at the whole system in total
           and make some judgmental --
                       DR. POWERS:  Yeah, I think you can.
                       DR. GOLAY:  I think that may be a
           reasonable process, too.
                       DR. SHACK:  Well, it's a question of who's
           setting these numbers.  The designer can set it any
           way he wants to, and the question is whether the
           regulator then forces those numbers.
                       CHAIRMAN KRESS:  Well, my point was should
           the regulator come in at this point and have
           acceptance criteria related at this low a level or
           should he just focus on the endpoint?
                       And I think, you know, that that's the
           whole debate.  
                       DR. POWERS:  Sure.
                       CHAIRMAN KRESS:  Should you focus on the
           endpoint or should you come in at this point on the
                       DR. POWERS:  It is what point you come
                       CHAIRMAN KRESS:  Yeah.
                       DR. POWERS:  We know that they will come
           in more than at the endpoint.
                       CHAIRMAN KRESS:  And that's why I keep
           harping on defense in depth.  this is a defense in
           depth concept, whereas if you just focused on the
           endpoint, perhaps it's not.
                       DR. POWERS:  Right.
                       CHAIRMAN KRESS:  And this may be a way to
           bring in defense of depth or it may not.  I don't
                       DR. GOLAY:  Well, that's actually part of
           why we picked this illustration, because we're
           anticipating that as the maturity grows, there will be
           a natural evolution of performance goals formulated at
           a lower level. 
                       For one thing, it makes the design process
           more efficient and should make the review process more
           efficient, but that's why also I went through this
           business that where you set the goal depends on the
           maturity of the concept.  There isn't just one answer.
                       But we're assuming that things are mature
           enough that we can work at the system level with
           system specific or relevant goals, and so the idea is
           that after rejection, the designer goes back and using
           the kind of risk information we're showing here, keeps
           modifying his design until he thinks that he's got
           something ready for another path.
                       Could we go to the next figure?
                       Upon submittal, there are two paths that
           we consider to be worth thinking about.  One is the
           easy one down here, is Evaluation 2, which is that the
           performance goal is met.
                       The second may be that, let us say, when
           you're trying out a new lower level performance goal,
           you may find that satisfying it is pretty difficult in
           terms of cost-benefit tradeoffs, and that you might do
           a better job at meeting your higher level goal by some
           risk shifting.
                       So we see both approaches as being
           feasible, depending on the level of maturity of the
           concept.  But for today we're going to take it that
           he's trying to meet the standard, and we'll talk about
           how to do that.
                       Okay.  Could we go on?
                       Now, this is a table of how in our risk
           assessment the core damage due to LOCA, core damage
           frequency, changed, and we're listing here the median,
           the five percent, 95 percent, and also what we're
           calling the risk metric, and that is one of the ideas
           I want to get across in here is that we can consider
           uncertainty just as easily as we can expected
                       And so we are taking the postulated
           situation that the NRC has said that the acceptable
           risk metric will be one involving 75 percent of the
           median core damage frequency and 25 percent of the 95
           percent core damage frequency and requiring it to be
           less than seven times ten to the minus seven.
                       This is just as an illustration of how you
           might try to take uncertainty into account in an
           explicit regulatory acceptance criterion.
                       And the point is that if you look at the
           various entries here, what you see is that as we go
           from the initial no depressurization capability down
           through the different design iterations, that only
           until we get down to two train depressurization with
           an improved treatment of cooling water and diesel
           failure do you satisfy that acceptance criterion in
           terms of this risk metric.
                       But there's nothing harder about
           formulating a criterion involving uncertainty measures
           than formulating one which is strictly deterministic
           as we do today, or in terms of expected performance.
                       The trick is to make sure that the
           distributions that you're using reflect reality as
           well as you can, and if you do that and propagate
           these uncertainties, you should be able to get useful
           answers, just the ones we want you to think about.
                       CHAIRMAN KRESS:  How is this, the first
           metric that you selected, any different than just
           specifying a confidence level?
                       DR. GOLAY:  We felt we could have done it
           at, let us say, a 75 percent confidence level.  We
           felt that in reality that when people think about it,
           what they do is think about the expected performance,
           and they try to put on some margin factor for
           uncertainty, and we thought this was a way of trying
           to capture that.
                       CHAIRMAN KRESS:  It fits into that.
                       DR. GOLAY:  But how you do it is, again,
           some thing that there are different approaches for it. 
           The main thing I want to get across is that it's very
           easy to incorporate treatments of uncertainty, as well
           as expected performance here, and given that
           regulations about uncertainty, we think that this is
           a big contribution, at least potentially.
                       Could we go to the next figure?  Other
                       Okay, and this is just a graphic of the
           same change in the core damage frequency at different
           confidence levels, including this risk metric.  The
           blue one is the risk metric that we were using, and
           you see that it could play the role just the way that
           evaluation at a conservative confidence level could
                       So what's the best treatment would be for
           future work, but if you accept that the idea is worth
           exploring, that is a step forward.
                       Let's go on.
                       Okay.  We're almost at the end.  Lunch is
           in sight.
                       The point is in this example what we tried
           to show is how that we can have a natural way for
           concern about common cause failures and uncertainties
           to lead designers to incorporate some defense in
           depth, some use of safety margin, to show how we can
           take uncertainty into account in evaluating
           acceptance, and that the bottom line is really the one
           that is most important, and it addresses what you need
           to pay attention to in future research, which is that
           there are a lot of practical questions that need
           examination here, and to answer them you need trial
           examples, such as we just showed you.
                       You need some work to come up with
           standardized models, methods, and databases which are
           much more capable than those which we have today.
                       And one of the areas which we really
           haven't explored -- by "we" I mean everybody in this
           room -- very much, but which is quite important, is
           methods for treating subjective judgment, for
           incorporating it into the decision making process in
           a more formal way.
                       We suggest that through this process, we
           may be able to replace the need for general design
           criteria and DBAs, and we would probably have to alter
           the standard review plan in important ways.
                       So these are all practical problems that
           need to be investigated.
                       Can we go to the last slide?
                       So in summary, what I hope you've gotten
           is an understanding of a new design and regulatory
           process that we propose for development.  It's risk
           based.  It incorporates defense in depth and margin. 
           We think it would provide a more rational and
           consistent method regarding both design and regulatory
                       It provides a method of integrated
           assessment which we currently lack except in the
           treatment probabilistically in the background of the
           process we have now, and it should be applicable to
           non-light water reactor technologies in a
           straightforward fashion just as to light water
                       So in effect, the implicit favoritism
           which our current process bestows upon light water
           concepts could be removed through this and hopefully
           would lead us to somewhat better technological
                       And we feel that the development of this
           process should be supported as part of our overall
           attack on developing new technology, and that's all I
           have to say.
                       CHAIRMAN KRESS:  Okay.  Are there
           questions or comments?
                       DR. POWERS:  I guess the thing that comes
           most immediately to mind is actually on his first
           bullet there, where he says defense in depth when
           necessary to address model and data uncertainties. 
           Don't we do a defense in depth for other reasons?
                       CHAIRMAN KRESS:  Pardon?
                       DR. POWERS:  Don't we do a defense in
           depth for other reasons?
                       CHAIRMAN KRESS:  Yes, there are other
           reasons for it, I think.  What reasons would you have
           in mind?
                       DR. POWERS:  I guess two things come to
           mind, one of which you might put in the category of
           model uncertainty is, well, we don't account for
           sabotage in the PRAs.  I'd just as soon have some
           protection against a plausible threat to the plan. 
                       The other one is in your probabilistic
           studies you always come up with some probability of
           bad things happening.  Just between you and me and the
           gate post, I'd like to have something between me and
           the bad stuff when those bad things happen, regardless
           of how infrequently they occur.
                       DR. GOLAY:  Is that a question?
                       CHAIRMAN KRESS:  It's a comment more than
           a question.
                       DR. POWERS:  He asked for comments.
                       CHAIRMAN KRESS:  If you want to respond,
           you may.
                       DR. GOLAY:  Yeah, I will, and that is
           concerning your example of security, I don't know.  I
           haven't worked on security, and I don't know how you
           might try to handle it here.
                       My first reaction is:  why not try?  I
           don't know of anything that would preclude you from
           being able to include that successfully, and what I
           would like to do is sort of turn the burden around and
           make a presumption that we can handle the questions in
           a probabilistic framework until we have clear evidence
           we cannot.
                       Fundamentally you said that reason for
           defense in depth was not wholly treatment of
           uncertainty.  Yet the examples you brought up were
           essentially treatment of uncertainty examples, and if
           you think that a practice is beneficial in terms of
           getting a good safety result as a response to
           uncertainty, then you should be able to state it,
           state your belief concerning that fact in a
           probabilistic format.
                       So it's not disagreeing about the value of
           defense in depth.  I'm simply saying it's worth the
           try to incorporate anything that you think is
           important to the answer in the format.
                       MR. HOCKRITTER:  Larry Hockritter, Penn
                       On page 10, you talk about using best
           estimate performance, expectations and uncertainties. 
           And you really have two kinds of uncertainties.  You
           can have the plant uncertainties, but you can have the
           uncertainties in the model that you use to do the
           predictions, and with a light water reactor, we've got
           40 years of a database, experimental database so that
           we can quantify the models and the model uncertainty
           so that we have a good handle on that.
                       I don't know how you address that for a
           new design like we've been talking about for these
           Gen. IV designs where you really don't have much of a
           database at all.
                       So that's one question.
                       DR. GOLAY:  Should I answer?
                       MR. HOCKRITTER:  That was a question.
                       DR. GOLAY:  Yeah, with any concept,
           regardless of its level of maturity, I'll submit that
           as you try to do a risk analysis of comparing
           alternatives, let's say, that you ultimately end up at
           a point where the available objective data reach the
           limits, and you can find this with plenty of light
           water examples as well, that what you're really into
           is a situation where you -- I think always -- that's
           too strong a word because I don't have the basis for
           saying "always," but my experience has been so -- that
           you end up with a combination of objectively based
           evidence and you have to supplement that by your
                       And so the only suggestion that we're
           making is that you should state that in probabilistic
           terms and incorporate it into the PRA so that with the
           new concept, you reach that limit much sooner than
           with the mature one, but that the general structure
           holds up for both.
                       MR. HOCKRITTER:  Okay.  Well, I can now
           turn the question around and say if you would embark
           on this type of a licensing process, you could use
           this approach to structure the types of test programs
           that you would need --
                       DR. GOLAY:  Absolutely.
                       MR. HOCKRITTER:  -- for a Gen. IV type
           plant.  So I see a real benefit in that.
                       And then just one other comment.  The
           examples that you showed, the design examples, I know
           on the AP 600 we did use that process where we went
           through the PRA. We looked at the performance of the
           systems and the system sizes in this case changed.
                       DR. GOLAY:  Yeah, and what was lacking in
           that example is the regulator being prepared to engage
           you in the same vocabulary for making their decision.
                       MR. HOCKRITTER:  There was never a problem
           with the regulator engaging us.
                       CHAIRMAN KRESS:  Go ahead.
                       MR. PARME:  Larry Parme, General Atomics.
                       I have a question in regards to your last
           page or near there.  You mentioned possibly replacing
           the DBAs with the risk dominant events, and overall
           I'm supportive of your approach, but in the licensing
           approach risk based that we did for the MHTGR, one of
           the -- we were looking at that sort of approach, and
           we immediately ran into the problem that when you go
           and say that the risk dominant events replace DBAs,
           you find that certain non-risk dominant events are the
           only challenges, if you will, to certain key equipment
           or safety functions, and the risk dominant events may
           not demonstrate to the regulator the various ways that
           your safety functions are done.
                       And I hope you follow what I'm saying.  My
           question to you is:  did you think about this?
                       We had thought about this in the '80s,
           found that risk dominant events weren't a true
           substitute for DBAs and had to also use the PRA, but
           had to find -- pull from our event trees events that
           challenged each of the safety functions regardless of
           their risk dominance.
                       DR. GOLAY:  Right.  Let me try and
           translate it though, and that is what I think you're
           really saying is that there's a concern about the
           level of uncertainty associated with your risk based
           analysis, such that if you went in and claimed that
           you were doing very, very well, it wouldn't be a
           credible claim, and that it was necessary to, in
           effect, show that you could handle something tougher
           is in some way a defense in depth kind of capability.
                       CHAIRMAN KRESS:  I would have put that a
           little differently.  I would say that there are
           regulatory objectives that are more than just CDF,
           LERF, BES (phonetic) --
                       DR. GOLAY:  Sure.
                       CHAIRMAN KRESS:  -- ANDERS (phonetic), and
           those regulatory objectives can be captured.
                       And you had one little box called FC
           curves.  If you actually had acceptance criteria on
           those, I think it would capture these things that
           you're talking about that don't have much to do with
           LERF or probable fatalities, but how to function in
           being sure that you don't have smaller releases or
           worker exposure and that sort of stuff, which can be
           captured in F-C curves.
                       DR. GOLAY:  That's a good point, and I was
           taking for granted that the cornerstones had all been
           addressed, which in that era they were not.
                       CHAIRMAN KRESS:  Yeah.  I hate to do this
           because I think this has been one of the most
           challenging and interesting presentations, but I think
           it's time to go eat lunch.
                       We can return to this maybe in the
           discussion.  They are very provocative concepts and
           some very attractive thoughts.
                       DR. GOLAY:  Our team remains eager to
                       CHAIRMAN KRESS:  Remember at two o'clock
           up stairs in the White Flint II Conference Room rather
           than here.
                       (Whereupon, at 12:59 p.m., the meeting was
           recessed for lunch, to reconvene at 2:00 p.m., in the
           White Flint II Conference Room.)
                                A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (2:00 p.m.)
                       CHAIRMAN KRESS:  Okay.  It's time that we
           went back into the section again.
                       And the standard request is that you'll
           have to identify yourself and tell us why you're
           qualified to talk to this --
                       DR. FORSBERG:  August body, right?
                       CHAIRMAN KRESS:  Right.  So with that I'll
           turn it over to Charles and I'm looking forward to
           this talk.  
                       No, no, we're not recusable on this one.
                       So you might want to introduce yourself,
                       DR. FORSBERG:  I am Charles Forsberg from
           Oak Ridge National Laboratory.  I guess I've been
           involved in every type of fuel cycle you can imagine,
           plus some reactor designs, and I'd like to discuss
           some alternative reactors and fuel issues and future
           nuclear power issues.   
                       I think the workshop here is quite
           appropriate because we're looking at the long term
           issues of nuclear power, nuclear power options for 20
           to 30 years.  
                       But if you look out 20 or 30 years you
           have to ask some more fundamental questions.  The
           first fundamental question is:  what are you going to
           use the energy produced from a nuclear power reactor
                       There's an implicit assumption most of the
           time, and that is that electricity is the primary
           product, the primary final product of a nuclear power
           plant.  That assumption is, of course, historically
                       But if you look out to the future 20 or 30
           years, there may be other uses of nuclear power that
           may also be as significant as the existing nuclear
           power industry in the United States.  
                       It's this particular subject I would like
           to address.  In particular, I'd like to address the
           advanced high temperature reactor for hydrogen and
           electricity production.  
                       This is a joint effort of Oak Ridge
           National Laboratory and Sandia.  I should emphasize
           here that when we talk about the use of a reactor for
           multiple purposes, for example, hydrogen and
           electricity, it changes the technology and it may
           change the regulatory structure.
                       The production of hydrogen requires -- has
           some very special technical requirements, and those
           technical requirements may also impose some very
           unusual regulatory issues.
                       So I'd like to address both issues, the
           issues of hydrogen production and use the requirements
           needed for hydrogen production to define a reactor
           concept, which leads to some of the regulatory issues.
                       Could I have the next slide?
                       I'd like to discuss four subjects -- three
           subjects:  is a nuclear based hydrogen economy in our
                       Second, an advanced high temperature
           gas -- high temperature reactor for hydrogen
           production or electrical production.  
                       And third, regulatory implications.
                       May I have the next slide?
                       I start with a question:  is a hydrogen
           economy in our future?
                       And I put in parenthesis something I think
           that many people may not recognize, and that is it may
           already be here.  In fact, I'm going to talk about
           hydrogen economy with -- hydrogen economy without
           talking about hydrogen fueled vehicles.  I'm not going
           to talk about distributed hydrogen.  I'm going to
           spend one slide on that.
                       Rather, I'm going to talk about old
           fashioned hydrogen consumption, the old fashioned
           economy that uses a great deal of hydrogen.  
                       Could I have the next slide.  
                       We're seeing rapid growth as expected in
           industrial demand.  Currently the production uses --
           growth of hydrogen production uses about five percent
           of the natural gas in the United States, plus a large
           quantity of refinery byproducts.  It's a big energy
                       If the projected rapid growth of hydrogen
           consumption continues, the energy value of the fuel
           used to produce hydrogen will exceed the energy output
           of all nuclear plants by about 2010, and continue to
           expand at a very rapid rate like ten percent per year
                       There are two users, one which I suspect
           will be rather static over the next couple of decades. 
           That's the chemical industry, to bake ammonia and
           methanol.  It's a large consumer today, but it's
           probably not a rapid growth market.  
                       The rapid growth market and the driver for
           hydrogen consumption in the U.S. is the changing
           refinery conditions that are driving up the hydrogen
           demand.  I'm going to go into this in more detail, but
           there are basically three things that are happening.
                       The oil supply is changing.  We're
           beginning to use more heavy crude oils, fewer light
           crude oils.  
                       Second, there's a demand for cleaner fuel.
                       And third, there's a changing product
                       Thirty years ago, the primary use of crude
           oil was to refine it into home heating oil.  These
           days, of course, it's gasoline.    
                       Last, if non-fossil sources of hydrogen
           are used, lower value refinery streams can be used to
           make gasoline rather than hydrogen, and thus reduce
           oil imports.  
                       Could I have the next slide?
                       I want you to spend some time on this
           slide to explain what's happening in the refinery
           industry and why increasing use of more abundant crude
           oils reduces refinery yields, unless non-fossil
           hydrogen is used.  
                       This is where we were, let's say, 30 years
           ago.  We primarily used light crude -- light, sweet
           crude oils.  These crude oils you could put into an
           old Chevy engine, turn on the ignition, and it would
           start.  It would work.  Didn't even need a refinery. 
           Had a little bit of refining, produced the nice, dirty
           fuel, but it worked.  
                       Things are changing in two ways, in two
           dimensions.  The first, we're going from light, sweet
           crude oil to heavy, sour crude oil, like Venezuelan
           crude.  Venezuelan crude's about six percent sulfur. 
           If I put Venezuelan crude in one of these cups, I
           could turn it over after -- if it was at room
           temperature, and come back in a half hour, probably
           before it would stain this table.  It's thicker than
                       Needless to say, this does not work well
           in a car, and thus, it takes a tremendous amount of
           refining to make a clean fuel.  
                       So we're in a transition from the upper
           left to the lower right.  That's what's driving the
           hydrogen demand in the U.S.  
                       The very light crudes have a hydrogen to
           carbon ratio of about two to one, which is about what
           gasoline is, two hydrogens per one.  The heavy sour
           crudes from Venezuela have a hydrogen to carbon ratio
           as low as 0.8 to one.  To make gasoline you've got to
           get over to two to one.
                       So there's a tremendous hydrogen input if
           you take a sour crude and go this direction.  
                       At the same time people have decided to
           take sulfur out of crude oil.  They don't like sulfur
           in their tailpipe.  They've also decided they prefer
           to have a gasoline supply that is relatively nontoxic,
           that is, we're removing things like benzene from the
           gasoline supplies of the United States.  And the
           consequence of that is more and more hydrogen
                       DR. POWERS:  It even goes beyond that
           because by taking out the aeromatics you reduce the
           octane level -- octane rating of it, and so now you
           have to do more processing on the octanes.
                       DR. FORSBERG:  Yes.
                       This type of refinery has about 95 percent
           efficiency.  That is for every 100 BTUs going in here
           you get 95.  This type of refinery for every 100 BTUs
           you get about 80 BTUs out.  So the refinery efficiency
           is dropping.  
                       Now, what's happened is that 30 years ago,
           40 years ago refineries actually made excess hydrogen. 
           It was flared, surplus product.  Thirty years ago,
           they were hydrogen neutral.  These days they're
           hydrogen hogs, and they make their hydrogen by taking
           some bottoms of the crude and putting it into a
           hydrogen plant to make more hydrogen, and they also
           consume very large quantities of natural gas that goes
           into making gasoline.
                       The bad news, of course, as you've
           probably heard, is natural gas prices are up.  They've
           doubled, some cases tripled in the last couple of
           years.  We now have a situation where natural gas --
           where the gasoline prices are coupled to natural gas
           prices, as well as oil prices.  
                       This is something we have not previously
           seen in our history, different kind of economics,
           different kinds of issues.
                       A five dollar per million BTU natural gas
           makes expensive electricity.  Five dollar per million
           BTU natural gas is going to make very expensive
           hydrogen, and thus, there's a potential of a very
           large market if you can find economic methods to
           produce hydrogen for the refinery industry.
                       There's also a danger that if you don't
           find methods to produce economic hydrogen, what you're
           going to do is drive much of this industry offshore to
           areas that have low priced natural gas.  So what we
           have is a changing -- changing environment in terms of
           crude oil, a changing environment in terms of the
           product, and that in short is what's driving the
           hydrogen demand and causing the very rapid increase.
                       The question is can we find another source
           of hydrogen, that is, a non-fossil fuel source of
                       And today I'd like to discuss the
           possibility of using nuclear power or nuclear energy
           as that source of hydrogen.  
                       Could I have the next slide?
                       There are potential multiple economic
           benefits for non-fossil sources of hydrogen.  There
           are four of them, and they're independent of how you
           make the hydrogen:  increased transportation fuel
           yield per barrel of oil.  The lower value oil
           components are converted to transport fuel rather than
                       That would save you perhaps ten, 15
           percent on oil imports, and of course, that would
           reduce oil imports and also reduce natural gas.
                       Second, if you have cheaper hydrogen, one
           can make greater use of heavy crude oils.  They're far
           more abundant than light crude oils, and more
           importantly, most of the heavy crudes are in the
           Western hemisphere, happen to be what we have, what
           the Venezuelans have, and what the Canadians have.
                       In the United States it turns out our
           worst crudes are in California, by convenience.  
                       DR. FORSBERG:  Third, competitive chemical
           industry.  There's a real concern in the chemical
           industry that if those high natural gas prices
           continue, we're going to drive much of the chemical
           industry offshore.  
                       And last, of course, you have much lower
           carbon dioxide emissions.
                       In short, what's happened is the chemical
           industry is having a changing world.  
                       Now, I thought I should put in one slide
           about the hydrogen economy because if you pick up all
           of the popular newspapers and magazines, what they
           always talk about is the hydrogen economy, and what
           they mean by the word "hydrogen economy" usually is as
           liquid hydrogen or pressurized hydrogen is a transport
           fuel, and distributive power. 
                       I won't make any claims whether or not
           they hydrogen economy will fly.  Don't know.  What I
           do know is if you're ever going to get here, you
           better have a very large infrastructure today to get
           to a hydrogen economy because otherwise you'll never
           get the economics of scale, and making this transition
           would be extremely difficult.  
                       So the development of non-fossil hydrogen
           is important, both for the refinery and chemical
           demand, but it's also very important if you want the
           option of a hydrogen economy, because a cold start of
           a hydrogen economy would be an extraordinarily
           difficult thing to do if you had to bring up large
           hydrogen production facilities with economics of scale
           at the same time while you're developing the uses for
                       I'll start at the nuclear side of the
           issues here.  Hydrogen can be made from -- hydrogen
           can be produced with heat from a nuclear reactor. 
           Basically heat and water equals hydrogen and oxygen. 
           Nuclear energy would compete with natural gas for
           hydrogen production.  
                       Natural gas is a primary way we make
           hydrogen.  We do have very high natural gas prices
           right now, about five dollars.  There are a couple of
           things that are, of course, very nice about nuclear. 
           In terms of refinery demand, the hydrogen demand is
           almost constant, which means you have a constant
           hydrogen demand, which would, of course, better match
           a nuclear low.  
                       Well, that's the good news.  The bad news
           is it's not easy to make hydrogen from water.  There
           are processes with projected efficiencies greater than
           50 percent.  However, big point to be made here:  high
           temperature heat is required, 800 to 1,000 degrees C. 
           If you're going to make hydrogen from nuclear power,
           it's going to take a very special machine to do so.  
                       Existing commercial reactors cannot
           produce heat at these high temperatures.  You have to
           have an alternative reactor concept or concepts.  
                       I'm going to -- the next slide I will show
           you one example of a hydrogen cycle.  This is a
           chemical process to convert high temperature heat and
           water to hydrogen and oxygen. 
                       About 1,400 cycles have been invented. 
           People have examined them.  The competing -- most of
           the competing cycles are called sulfur cycles.  This
           one currently is the leading contender, the one that's
           receiving most of the research in Japan, which has a
           moderate sized program in this area.
                       It's called the iodine-sulfur process.  we
           start with heat at 800 to 1,000 C.  We produce oxygen
           and hydrogen with, of course, the input of water.  The
           key chemical step that couples with the nuclear
           reactor is the decomposition of sulfuric acid into
           water, sulfur dioxide and oxygen at 800 to 1,000 C.
                       The oxygen, of course, is a byproduct, or
           a waste product.  The sulfur dioxide is circular --
           cycled around, mixed with water and iodine to form
           hydrogen iodine and sulfuric acid.  The sulfuric acid
           goes back through this cycle.  They hydrogen iodine
           goes through a second cycle that ultimately yields
           hydrogen gas and iodine.  So you have two sets of
           chemical reactions in the reactor.  
                       The key thing about all of these cycles
           that the people have looked at that look reasonably
           practical is there's this 800 to 1,000 degrees Celsius
           temperature, and they're coupled to some complex
           chemistry and some fairly aggressive chemistry, such
           as the decomposition of sulfuric acid.
                       I mentioned that because what it means is
           this is your interface, and you have this chemical
           plant on this side and your nuclear plant on this
           side.  This chemical plant for, let's say, a 600
           megawatt reactor would be producing about 100 million
           cubic feet of hydrogen a day.
                       You know, there are going to be a few
           1,000 or tens of thousands of tons of reagents in
           these systems.  And if you think of a couple of
           thousand tons of sulfuric dioxide or a couple of
           thousand tons of iodine, you recognize there's some
           non-trivial hazard issues associated with the right
           side of the plant.
                       In fact, you might have a debate on
           whether or not your primary safety concern is the left
           side or the right side.  It's not intrinsically
           obvious to me that you can make a blanket statement
           that safety problems are on the nuclear side if you're
           into this kind of game.
                       I would now like to describe one reactor
           concept that we have been examining that might meet
           these requirements, and they're very special
           requirements.  That's an advanced high temperature
           reactor, a reactor concept for hydrogen production.
                       The main point, however, I want to
           emphasize with this example is not only describing the
           example, but emphasize that different products may
           require different reactors.   
                       If somebody proposes a new product from a
           nuclear reactor, it may very likely imply you have to
           think about how you're going to design the reactor,
           and it may be fundamentally different than anything
           you've built before.  
                       We've been thinking electricity,
           electricity, electricity.  That imposes one set of
           requirements on the reactor, one set of requirements
           on the regulator, one set of requirements on the
                       If you change the product, you may need to
           change the reactor, the regulatory structure, and how
           the operator thinks about things.  That's a very
           important message I'd like to leave with you today,
           that there really are some large changes if you think
           about changing products.  
                       We've only begun to examine this issue. 
           I'm sure it's not an issue that's received much
           examination anywhere else, but it's important to
           recognize, you can't apply old rules if you change the
           product.  Some things are easier; some things are more
                       Could I have the next picture or the next
                       There's a very simple description cartoon
           of this concept.  What we're proposing in this case is
           a graphite reactor, similar to a MHTGR with graphite
           fuel.  The molten salt goes up in the molten salt
           coolant.  We're using as an example a lithium
           fluoride, beryllium fluoride salt, although there are
           several other salts that are potential candidates.
                       The heat is transferred in the heat
           exchanger to the chemical plant and the molten salt
           goes back to the reactor, but the basic reactor core
           would be similar to an MHTGR modular high temperature
           gas filled reactor, except that the coolant is a
           molten salt.
                       Heat would be transferred in a special
           heat transfer device to the chemical plant.  It takes
           water in, produces hydrogen and oxygen.  
                       Important point to be noted about this
           interface.  High temperature, but it's also a chemical
           plant.  Inside this side of the heat exchanger we're
           talking about the catalytic decomposition of sulfuric
                       So this has a solid catalyst bed in tubes,
           has a variety of other design features that can impact
           the design of the nuclear side of the plant.  This is
           not a water interface or a helium interface or a gas
           turbine interface.  It's a chemical plant interface,
           with all the constraints and issues that you have to
           address in operating a chemical reactor.
                       And that of course includes the regulatory
           issues of that interface.  There are some very serious
           regulatory issues that you don't normally think about.
                       Could I have the next slide?
                       Let's think about what we might want if
           we're going to make a high temperature reactor. 
           What's -- what are our requirements?  What would we
           prefer to have, especially if we're going to have one
           that is blazingly hot?
                       Well, the first requirement is we really
           want low pressure operation.  We want low pressure
           operation for a couple of reasons.  First, medals
           become weaker at higher temperatures.  If we're going
           to higher temperatures we'd rather avoid the situation
           of high temperatures and high pressures.  That's a
           double difficulty.
                       And at 1000 C., strength of materials
           becomes and endurance of materials becomes a major
           issue.  So we need the low pressures to minimize
                       We also would like to match the chemical
           plant pressures.  The chemical plant pressures in this
           system will be near atmospheric.
                       We would rather not have a high pressure
           primary system feeding to a low pressure chemical
           plant because in that case we have to worry about what
           happens if you have a leak in the high pressure
           nuclear system and it pressurizes a low pressure
           chemical plant with a high inventory of hazardous
                       So we have to worry about the nuclear
           plant doing bad things to the chemical plant, and as
           I say, that's not a trivial detail if you have
           thousands of tons of nasty materials.  So this is a
           situation where the nuclear plant could be a threat to
           the chemical plant or vice versa, and you have to
           think about both and design to avoid those issues.
                       It's a different mindset.  We think about
           a particular nuclear plant.  In this case we've got to
           protect both plants.  
                       Second, we want very efficient heat
           transfer.  We need to minimize the temperature drops
           between the nuclear fuel and the application to
           deliver the highest possible temperatures, and for
           that reason we have chosen a liquid coolant.
                       Can I have the next slide?
                       I'm showing here a picture of the Japanese
           high temperature engineering test reactor fuel that's
           designed for 950 C. helium exit temperature.  This
           reactor is currently operating.  It's in its first
           year of operation.  They are not yet to 950 C.  If I
           remember right, they are somewhere around 850 C., and
           after a couple of years they're going to run the
           temperature up to 950 C.
                       And it's a coated particle fuel like the
           fuel we would use.  It's slightly different type of
           fuel element because they run into much higher
                       Now, the reason I point this out is
           they're running at 950 C.  We'd like to run 1000 C,
           maybe a little warmer than that, but this is 950 C in
           helium.  And if you use a much better heat transfer
           material, like a molten salt, you reduce the
           temperature -- the temperature drops the required to
           transfer heat inside the fuel element, and thus a 950
           C. exit temperature for helium is probably
           substantially over 1000 degrees C. for molten salt
           because it's a better coolant.
                       So you can have higher temperatures with
           the same fundamental fuel limits which are associated
           with that coated particle fuel.  So if we can improve
           the heat transfer we can knock down the temperature
           drops elsewhere in the system to reduce the stress or
           reduce the difficulty of making a fuel element.
                       If you're pushing to high temperatures,
           the goal is to minimize the stretch that's required.
                       Could I have the next slide?
                       The other important item is the coolants. 
           Why do we want molten salt coolants?
                       Well, they allow low pressure operation at
           high temperatures compared to traditional reactor
           coolants.  The particular salt we've mentioned here
           we'd operate around 1000 C.  It has a boiling point of
           about 1,400 C, which gives us 400 degrees C. between
           the operating point and the boiling point.  And of
           course, that means we're a very low pressure system.
                       To give you a comparison, sodium
           unfortunately boils at a low boiling point of 883
           degrees C.  Hot machine if you're going to make
           hydrogen.  It's unavoidable.  And of course water and
           helium are further on down the loop.  
                       Can I have the next slide?
                       Needless to say as a new concept we've
           only begun to examine the safety issues of this kind
           of reactor.  There are many, many uncertainties, but
           we'll identify those that look potentially attractive,
           but please recognize we're a very, very early in the
                       Of course, one of the key requirements for
           both the chem. plant and for nuclear safety we believe
           is low pressure coolants, subatmospheric coolant. 
           Escaping pressurized fluids provide a mechanism for
           radioactivity escaped from a reactor during an
                       A low pressure salt coolant minimizes 
           accident potential for a radioactive transport to the
                       It also minimizes chemical plant
           pressurization issues.  So for this kind of
           application one would like to have very low pressure.
                       Second, molten salt has a good coolant
           characteristic to provide high safety margins for many
           upset conditions.  
                       We believe with a molten salt that we
           could have significant natural circulation, which
           would help in certain kinds of abnormal conditions. 
           It has a high heat capacity.  
                       And last, although we don't fully
           understand the chemistry of it and are only beginning
           to think about it, molten salts have the unusual
           features that most fission products dissolve in molten
           salts, such as cesium and iodine.  And hence, the salt
           itself becomes a --
                       DR. POWERS:  And those particular salts
           that you've got there, just about everything
           dissolves, even the things we think are nominally
                       DR. FORSBERG:  I know.  This is an unusual
           coolant.  But it's a different approach to safety
           also, and that's why I mention it because we normally
           don't think of coolants as fission product absorbers. 
           And in this case the coolant is a fission product
                       DR. POWERS:  Yeah.  I mean, we saw this in
           TMI, that you blow efficient products through water. 
           They stay in the water.  
                       DR. FORSBERG:  Yes.
                       DR. POWERS:  Okay.  And here all you're
           doing is magnifying that with a coolant that has a
           higher dynamic range than water does.  
                       DR. FORSBERG:  Yeah.  I think it's an
           important issue though because there are different
           approaches to safety also that you can think about
           when you go to these high temperatures and when you go
           to other coolants.  
                       We're using molten salt, but there may be
           other cases where you can think about fundamentally
           different approaches to safety than the traditional
           approaches that we have historically used.  When you
           go to different systems you need to think beyond the
           box, outside the box.
                       As I say, we're not far enough into this
           to give you any answers, but there some interesting
           potentials.  In this particular concept the passive
           decay-heat removal system is similar of that of other
           proposed reactors.  That is, heat conducts outward
           from the fuel to the pressure vessel, to the passive
           decay-heat cooling system, and our conceptual design
           limits the power to about 600 megawatts, the same as
           the HTGR, because the worst design condition for this
           reactor is you lose the coolant, and then you have
           essentially an HTGR, a depressurized HTGR.  So it has
           essentially the same temperature units.  
                       I would emphasize very early in our
           conceptual thinking about this, but what comes out of
           this kind of thinking is it's a very different kind of
           system.  It has potentially some different approaches
           to safety that we have not historically used, some
           chemical approaches. 
                       DR. POWERS:  I think it has some
           interesting safety issues that are peculiar to itself.
                       DR. FORSBERG:  Oh, yes.
                       DR. POWERS:  I mean, this is the classic
           problem of over-cooling accidents.  Start-up is kind
           of an interesting --
                       DR. FORSBERG:  Yes.
                       DR. POWERS:  -- challenge in this reactor. 
           Start-up and shutdown, both are interesting events in
           this reactor. 
                       DR. FORSBERG:  What he means by start-up
           is that this material thaws, becomes a liquid at about
           400 C., molten salt.  So you have a system that is, on
           start-up when it turns to liquid, is already
           moderately warm.  In fact, it's hotter than any light
           water reactor on start-up, which is not your normal
           way of thinking about things.
                       DR. POWERS:  There are salts that one can
           imagine that have much wider --
                       DR. FORSBERG:  Yes.
                       DR. POWERS:  -- liquidous boiling ranges
           than this fluoride system.  Have you looked at any of
                       DR. FORSBERG:  Not in any detail.  So far
           we've only begun to look at the fluoride systems, and
           we're looking at this salt and a salt that has
           zirconium potassium sodium fluoride.
                       DR. POWERS:  Yeah.
                       DR. FORSBERG:  Which of course gets rid of
           the beryllium issue.  So that's why that one's being
           looked at.  There are a variety of other options.  
                       DR. POWERS:  Going down -- going to the
           more complicated ternary systems does get you a
           broader --
                       DR. FORSBERG:  Yes.
                       DR. POWERS:  -- liquidous range.  That
           particular salt's not a good one for a broad liquidous
                       DR. FORSBERG:  Yes.
                       DR. POWERS:  But you can get fairly broad
           liquidous ranges so that at least you're start-up
           might be -- I mean, you've got to worry about how to
           preheat this stuff.
                       DR. FORSBERG:  Yes.  Yes.
                       DR. POWERS:  And if you wanted to use a
           water-base preheater technology, which I think you
           would, you want something that melts within the range
           you can get with water.  
                       DR. FORSBERG:  Unusual set of issues.  I
           should mention here, which I didn't mention earlier,
           one of the desirable features of fluoride salts is
           they're fully compatible with graphite.  Most of you
           probably are used to aluminum tin cans.  Well,
           aluminum is made by the hull process where you
           dissolve the aluminum oxides in a fluoride salt that's
           in a graphite bath.
                       And the aluminum industry has been using
           fluoride salts and graphite for a little over a
           century now.  And they're thrown everything, including
           the kitchen sink, in their graphite baths over a
           century of experience.  
                       So there's at least a century of
           experience of running a very wide set of fluoride
           salts and graphite baths with an extraordinarily wide
           level of impurities, not intentionally, but
           accidentally over 100 years of operational experience.
                       MR. SIEBER:  I presume you pumped this
           molten salt around the surface.
                       DR. FORSBERG:  Yes.  
                       MR. SIEBER:  Are there pumps that can
           actually do that at these temperatures?
                       DR. FORSBERG:  Yes.  Well, we haven't done
           anything at this temperature.  The molten salt reactor
           experiment at Oak Ridge operated at 700 C.  Now, the
           difference is in that reactor the uranium was
           dissolved in the salt.  There was not a solid fuel
           element.  But that operated about a much lower
           temperature of 700 C., and of course, nobody has
           operated a salt system at these temperatures.  
                       MR. SIEBER:  You start this reactor with
           no flow at all.
                       DR. FORSBERG:  That's right.  
                       DR. GARRICK:  Are you going to say
           anything about performance characteristics other than
           temperature and pressure?
                       DR. FORSBERG:  We're very early in the
           game, and I wouldn't make any promises that we have
           any information that would be considered credible. 
           It's very, very early in the game.  
                       DR. GARRICK:  Just cycle times?
                       DR. FORSBERG:  That's right.  We started
           this effort about six or eight months ago, so we're
           very early in the game.  Starting with the observation
           that there some -- maybe some demands for a very high
           temperature reactors, and if you have very high
           temperatures, how do you get there with the materials
           that may exist, and obviously you throw out water; you
           throw out sodium.
                       DR. GARRICK:  Right.
                       DR. FORSBERG:  And by elimination you're
           sort of left with graphites and molten salts if you
           want to really run the temperature up.  
                       The same problem -- it's somewhat similar
           to the issue of the aircraft nuclear propulsion
           program in the '50s.  They investigated many coolants
           for an aircraft nuclear propulsion system that had a
           solid fuel and a heat transfer loop, and the original
           nuclear work on molten salt transfer was done as part
           of the aircraft nuclear propulsion system because at
           high temperatures with low pressures molten salts were
           the only game in town.  There just weren't any other
                       MR. SIEBER:  And it operates under a solid
           coolant condition, no pressurizer or anything.  You
           just pump in --
                       DR. FORSBERG:  That's right. 
                       MR. SIEBER:  -- to maintain the pressure. 
           How does it accommodate power swings?
                       You know, it expands and contracts.
                       DR. FORSBERG:  Yes, it's regular expansion
           and contraction of the coolant, plus the doppler
           coefficient of the --
                       MR. SIEBER:  But that could be pretty
           sever in some accident situations.
                       DR. FORSBERG:  Yes.  We're not at the
           point where we've investigated the details of how
           you're going to handle these types of events.
                       MR. SIEBER:  All right.  Thank you.
                       DR. FORSBERG:  We're at the issue of
           materials and what materials can you actually build
           the thing out of that you have a reasonable chance of
           operating at these temperatures.  A 1,000 C. is a very
           severe operating environment. 
                       MR. SIEBER:  It's hotter than a super
           critical coal boiler.
                       DR. FORSBERG:  That's right.  
                       MR. SIEBER:  You get up to those
           temperatures and the tubes just melt.
                       DR. FORSBERG:  That's right.  
                       DR. POWERS:  Have you thought about what
           your primary pressure boundary is going to be?
                       DR. FORSBERG:  There are three obvious
           choices.  One is a molybdenum alloy.  Then there is
           some oxide dispersion stainless steels that may have
           the capability, and then there are also graphites. 
           But we're very, very early.  And all of those things
           are cases where people have shown in the laboratory
           that the materials are capable of doing something, but
           nobody knows whether or not they could be made on a
           large scale or whether you could fabricate them or
           whether you could convert this into a practical
           reactor design.
                       So what we have is materials that are used
           -- we have -- there are a number of high temperature
           materials that are used in research applications that
           operate at these conditions normally, in a research
           environment, but have not been used in a production
           environment.  So what you have is materials that, yes,
           some of them have been used for 40 years, but only in
           a research environment.  There's a big difference
           between research and production.
                       DR. POWERS:  There's a big difference
           between research environments and flowing, high
           velocity flows and things like that.
                       DR. FORSBERG:  Yes. 
                       DR. POWERS:  In particular, on any kind
           alloy.  The problem here is kind of interesting.  It's
           not carbon extraction, it's alloying-agent extraction.
                       DR. FORSBERG:  That's right.  That's
           exactly right.  There is a fair amount of experience
           based up to about seven, 800 C.  Above 800 C., the
           databases begin to get very sparse.  
                       Could I have the next slide?
                       If one can produce a high temperature
           reactor, obviously the options for the production of
           electricity, that one can use a high efficiency helium
           gas turbine cycles, conversion efficiency greater than
           50 percent, provide isolation of the power plant from
           a reactor using low temperature drop heat exchangers,
           and advanced gas turbine technology. 
                       In the longer term there's the option of
           direct thermal through electric production.  That is,
           no moving parts, methods to produce electricity from
           high temperature heat.  It would radically simplify
           the power plant design.  It has the potential for
           major cost reductions.
                       However, it must be emphasized this is a
           longer term option.  Current solid state technology
           results in thermal electric conversion efficiencies
           between 20 and 25 percent, and the technology is
           clearly not ready to be considered as an industrial
           technology with those low efficiencies.
                       If they continue to make progress, one
           could hope for the possibility in ten to 15 years of
           a radically simplified power plant.  
                       May I have the next slide?
                       This shows an advanced Brayton cycle.  You
           have the reactor.  You have the turbine cycle, and of
           course, you have an intermediate heat exchanger loop. 
           In this particular case, the intermediate loop is to
           separate the high pressure helium system from the low
           pressure reactor and protect the reactor from
                       Could I have the next slide?
                       This shows that the possible use of direct
           conversion systems, where you'd have a molten salt go
           through a heat exchanger and produce electricity
           directly.  That is, you have electricity, the molten
           salt going through a tube.  You'd have a solid state
           converter on the outside of the tube, water cooling on
           the outside of the solid state converter, with direct
           production of electric current.  
                       As I mentioned, this potentially is very
           attractive in the long term, but the technology does
           not currently exist to get the efficiency high enough
           to be of commercial interest.  It's only 20 to 25
                       But if they make sufficient progress, it
           has major implications in terms of a radical
           simplification of nuclear power plants.  
                       Of course that technology would probably
           also apply to sodium cooled reactors and a variety of
           other high temperature reactors.  And it's a long term
           option, not a short term option, but something to keep
           in mind because in 20 years we may have the conversion
           devices capable of doing it, which would be a true
           radical simplification.  
                       These molten salt coolants have extremely
           low activity levels compared to sodium or water.
                       DR. POWERS:  You were talking about sodium
           just now, so --
                       DR. FORSBERG:  Sodium you would have
           activity.  But molten salts themselves are extremely
           low activity, far, far less that water or sodium. 
           That's one of the really nice things.  That's one of
           the nice things about molten salts.  
                       MR. SIEBER:  The physical size of the
           converters must be huge to get the commercial levels
           of power out of them.
                       DR. FORSBERG:  You have to predict what
           it's going to be in 20 years, and they've been
           shrinking dramatically and the efficiency has been
           going up dramatically, but the question is will that
           continue for another 20 years.  And I don't know.  
                       DR. POWERS:  And they produce a direct
           current; don't they?
                       DR. FORSBERG:  Yes, they produce a direct
                       DR. POWERS:  So we get long term direct
           current transfer with no loss.
                       DR. FORSBERG:  Well, I'm not sure about
           the no loss part.
                       DR. POWERS:  No, well, you don't have the
           radiation loss.  That's what -- I mean that's the
           biggest loss you have in --
                       DR. FORSBERG:  Yep.  
                       DR. POWERS:  -- transmission.  We go back
           and Thomas Alva Edison may have been right after all,
                       DR. FORSBERG:  That's entirely possible.
                       Could I have the next slide?
                       Obviously high temperature creates
           development challenges.  That's the understatement of
           the year probably.  The AHTGR uses some demonstrated
           technologies.  The fuel technology is demonstrated. 
           The coolant technology is demonstrated.  Both require
           more development work.  But the base technologies are
           in existence.
                       Of course at AHTGR it requires advanced
           technology.  The most important one is the high
           temperature materials of construction where there are
           plenty of laboratory materials capable of doing it, as
           measured in the laboratory, but have not had the kinds
           of tests required for long term operation.  
                       And they are not industrial materials at
           the current time.  Lots of issues in terms of system
           optimization, heat exchangers and particularly the
           heat exchanger that couples with the chemical plant,
           and of course lots of work on hydrogen and energy
                       Could I have the next viewgraph?
                       Radio chart implications of hydrogen
           production.  If we talk about an alternative use of
           nuclear power, there are some very large regulatory
           implications.  The first, most important probably in
           many respects is that we're talking about different
           owners, the oil and the chemical industries.  Pluses
           and minuses.  
                       The key item, first item to be noted is
           they are much larger than traditional utilities. 
           ExxonMobil last quarter earned $5 billion.  They're
           approaching 300 billion in sales.  Shell is a little
           bit behind, but not far.  Very, very large
           organizations, which means buying a reactor is not a
           serious capital outlay.  
                       It's a strange way to put it, but in that
           large of an organization it's not a major -- you know,
           a CAT cracker in a large refinery costs four billion. 
           Hibernia offshore platform costs seven billion.  These
           are the kinds of things your boards of directors see
           normally.  Oh, it's only like four billion, seven
           billion, three billion --
                       MR. SIEBER:  Pretty soon you're talking
           big money.
                       DR. FORSBERG:  You're talking serious
           money.  But it's a different mindset.  They're very
           concerned about, obviously, the cost per unit product
           delivered, like the cost per million cubic feet of
           hydrogen.  But the capital cost issue would not be a
           major issue for a chemical company or an oil company,
           because it's just not that kind of dollars. 
                       The other thing that's important though is
           they have very different perspectives about risk and
           how they do business, and I'm not sure how that would
           interact with the Nuclear Regulatory Commission, but
           it's a different philosophy and different ways of
           thinking about it.  
                       They are, of course, used to handling
           large quantities of very nasty materials.  So in that
           sense there's a commonality, but there's a different
           culture.  It's a very different culture, and I have no
           good feel of what that kind of interaction applies,
           except there would be a lot of grinding of teeth.
                       DR. POWERS:  Yeah.  I mean, they deal with
           a different set of regulatory --
                       DR. FORSBERG:  That's right.
                       DR. POWERS:  -- body, but time scales tend
           to be a little more shorter term.
                       DR. FORSBERG:  Yes.  The second item I'd
           like to emphasize is both chemical and nuclear safety
           must be considered, and in my mind it's not clear
           where the primary hazard is.   
                       The chemical plant must not impact the
           nuclear plant.  Equally important, the nuclear plant
           must not impact the chemical plant.  When you think
           about boundaries between facilities, you must think
           about both directions.
                       And that's something we don't normally do
           in a nuclear facility.  A nuclear facility, well, we
           can trash a turbine and we don't worry about it.  We
           can trash a steam generator; we worry about the
           economic costs.  But we don't worry about the nuclear
           plant in terms of safety, damaging secondary
                       In a chemical plant interface one has to
           be -- this gets to be a major regulatory issue.  
                       Last, if we're talking about alternative
           uses of nuclear power we're going to have to do some
           serious thinking about non-traditional reactors that
           don't have water, do not have liquid metal and do not
           have gas.
                       And that just flows from the different
           requirements, different applications.  We just have to
           rethink what you want based on requirements.  
                       Can I have the last slide?
                       Some conclusions.  Economic methods to
           produce hydrogen from nuclear power may provide
           multiple benefits.  Increased gasoline and diesel fuel
           yields per barrel of crude oil will reduce dependence
           on foreign oil.  It's a long term pathway to the
           hydrogen economy.
                       Higher temperature heat allows new, more
           efficient methods to produce electricity.  
                       Last, reactors with different
           characteristics may be preferred for such very
           different uses.  In particular, if you're dealing with
           very high temperatures and you need low pressures, it
           may require a fundamental rethinking of how you
           approach reactor design, and also the regulatory
           issues associated with those plants because they will
           be very, very different than the traditional utility
           type thinking.      
                       That completes it.  
                       CHAIRMAN KRESS:  Charles, back in the
           distant past when I worked on molten salt reactors, we
           have a saying about talking about hazards.  We said --
           the saying was "No wing, no sting."  
                       DR. FORSBERG:  Yes.
                       CHAIRMAN KRESS:  There wasn't any way to
           get the fission products out to the atmosphere or
           there didn't seem to be.  The reason I say that is why
           wouldn't this be an attractive concept for just
           electricity generation?  Because you don't have these
           extra hazards then of the chemical plant and so forth. 
           And just by itself it looks like would be a pretty dog
           gone safe, inherently safe concept.
                       DR. FORSBERG:  I think it has many
           potential attractivenesses.  And that's worth
           considering, but I think an important other
           consideration is that in this particular case you may
           also have multiple markets.  And it's those multiple
           markets that may make it much more attractive for a
           serious consideration as an advanced reactor concept.
                       But clearly if you develop this, one will
           take a very hard look at it as a electric power
           producing reactor because those safety benefits apply
           to any other application as long as it doesn't have
           interface issues.
                       So, yes, you're right.  There are
           tremendous advantages if you can make it work and then
           particularly both in the electrical context and in the
           chemical context.
                       CHAIRMAN KRESS:  And the electrical
           context you could back off a little on the
                       DR. FORSBERG:  Oh, yes.  Electrical
           context you can drop probably 200 C. in the
           temperature and not be too concerned about it.  
                       CHAIRMAN KRESS:  You'd still have some
           sort of interface with --
                       DR. FORSBERG:  That's right. 
                       CHAIRMAN KRESS:  -- gas, helium or --
                       DR. FORSBERG:  Yes.  
                       CHAIRMAN KRESS:  -- water, one or the
                       DR. FORSBERG:  Yes.
                       CHAIRMAN KRESS:  I would think helium with
           the direct cycle, but --
                       PARTICIPANT:  Tom, there's somebody behind
           you there.
                       CHAIRMAN KRESS:  Okay.
                       MR. CARLSON:  Don Carlson, NRC staff.  
                       I have a couple of questions about your
           use of a lithium based salt as your coolant.
                       DR. FORSBERG:  Yes.
                       MR. CARLSON:  Lithium 6 is a strong
           neutron absorber and produces copious amounts of
                       DR. FORSBERG:  It's isotopically separated
                       MR. CARLSON:  Lithium 7?
                       DR. FORSBERG:  Lithium 7.  If we -- we're
           looking at several coolants, some with lithium and
           some without lithium.  The ones that include lithium
           have Lithium 7 because otherwise the neutronics
           doesn't work.  
                       MR. CARLSON:  Well, even impurity levels
           of Lithium 6 would give you lots of tritium.  
                       DR. FORSBERG:  Yes.
                       MR. CARLSON:  In fact, in the pebble bed
           reactor work in Germany, where they were considering
           processed heat applications, the very small amounts of
           tritium on the order of 1,000 Curies per year were a
           concern in terms of getting the tritium into the
           product gas.  
                       DR. FORSBERG:  Yes.  That's why we're --
           one of the reasons why we consider multiple coolants. 
           Each coolant has particular advantages and
           disadvantages.  Neutronically the lithium beryllium
           fluoride is a tremendous advantage.  But the
           disadvantages include tritium and a couple of other
                       The sodium potassium, sodium potassium
           zirconium fluoride avoids that problem.  It has a
           little more activity in the coolant, has some other
           issues.  So one of the issues in a molten salt reactor
           is which coolant you want.  They all have the same
           general characteristics, but that's where the tradeoff
           comes on, coolant A versus coolant B.
                       You're absolutely right.  That's why the
           coolant decision has not been made and why several
           coolants are being considered.  All fluoride salts,
           but they have different benefits.  
                       CHAIRMAN KRESS:  Other questions,
                       It's hard for me to see behind me.  I have
           been accused of having eyes in the back of my head. 
                       DR. POWERS:  I guess I can't say too --
           emphasize too much what Charles' point is, that when
           we think about new applications, we need to be -- we
           need to think creatively and innovatively on these
                       Have you looked at some of the silicon
           nitride, silicon carbide type refractories for your --
           as a material?
                       DR. FORSBERG:  We haven't done any serious
           looking yet. 
                       DR. POWERS:  I'm really ignorant in that
           area, but I know that they have done a lot of things
           in connection with molten salts --
                       DR. FORSBERG:  Yes. 
                       DR. POWERS:  -- with those kinds of
           materials.  And the nice thing about them is at these
           temperatures they're ductile.  
                       DR. FORSBERG:  Yes, I know.  
                       DR. POWERS:  They're no longer behaving
           like ceramics.  
                       DR. FORSBERG:  Dana points out the very
           funny thing.  With materials you have to start
           rethinking.  These temperatures, all sorts of
           materials that you normally think as brittle become
           wonderfully ductile.  So there's a plus and there's a
           minus.  You have to worry about their tensile
           strength, but the ductility -- well, gee, like
           graphite itself.  You know, graphite gets stronger and
           more ductile.  It begins to look like a construction
           material at these temperatures.  
                       DR. WALLIS:  Silicon carbide becomes a
           very good conductor of heat too.
                       DR. FORSBERG:  Yes, yes.  One has to be
           very careful about taking preconceived notions when
           you move into these systems because if you do you will
           be surprised.  They don't apply.
                       DR. GARRICK:  Have any early looks at this
           indicated real problems with respect to the
           interaction of the chemical part of the plant and the
           nuclear part of the plant?
                       And if so, does that suggest other
           concepts that might be attractive with increasing
           efficiencies and furnaces and electrical systems of
           going maybe electrical first and then to hydrogen
                       DR. FORSBERG:  People have looked at
           making hydrogen from electrolysis.  The problem with
           hydrogen from electrolysis is that if you include the
           nuclear plant efficiency and the electrolysis
           efficiency, you're down to a range of about 25 to 30
           percent total efficiency, whereas the direct cycles
           have about 50 to 60 percent efficiency.  
                       And the general feeling among most people
           who have looked at this issue is that that factor of
           two in efficiency drop makes electrolysis very
           difficult to ever become competitive in production of
                       DR. GARRICK:  That's unless that
           technology --
                       DR. FORSBERG:  That's right.  
                       DR. GARRICK:  -- improves.  And there's
           real safety problems between the --
                       DR. FORSBERG:  That's right.
                       DR. GARRICK:  -- direct cycle.
                       DR. FORSBERG:  That's right.
                       DR. GARRICK:  Yeah.
                       DR. FORSBERG:  These direct systems have
           not really been explored in any detail.  Now, we have
           looked at some very unique type of heat exchangers
           between the chemical plant and the nuclear plant.  In
           particular, we've been doing some examination of using
           radiation heat transfer from the primary system salt
           coolant to cold pipes that contain the actual chemical
           reagents.  Instead of a mechanical heat transfer,
           literally have the salt tubes radiate heat in infrared
           to absorber tubes that contain the chemical reactors
           so that you essentially have no physical contact
           between the reactor pipes and the chemical plant
           pipes, and that begins to look potentially applicable
           above about 900 degrees C.
                       Below 900 degrees C. the heat transfer
           rates are not very attractive.  But the heat transfer
           rate goes up as T to the 4th, and somewhere around 900
           C. you get heat transfer rates that begin to look
           attractive for radiation heat transfer rather than
           conduction heat transfer.
                       CHAIRMAN KRESS:  Have you looked at that
           marvelous material, graphite foam, that's being worked
           on at Oak Ridge?
                       DR. FORSBERG:  We've thought about it.
                       CHAIRMAN KRESS:  It seems to have an
           extremely high thermal conductivity.
                       DR. FORSBERG:  Yes.  We've thought about
           it.  It's a possibility.  We're still very early in
           the understanding the requirements for the chemical
           plant.  Remember the chemical plant, we not only have
           to transfer heat, but those tubes in the chemical
           plant have catalysts in them and chemical reactions,
           and so they have their own set of design constraints
           independent of the reactor.  
                       But we have been looking at alternative
           ways to couple the plants, and we've looked at the
           conventional heat exchangers and also this issue of
           radiation heat transfer, which sounds like a very
           unusual heat exchanger, but when you run through the
           numbers it begins to look like, gee, that's rather
           amazing.  It may be viable.  
                       CHAIRMAN KRESS:  Back to the subject of
           this particular Subcommittee meeting.  What do you see
           as regulatory challenges or implications of -- if such
           a plant ever came before NRC?
                       DR. FORSBERG:  Well, the first
           institutional one, which would be probably the most
           difficult one to deal with, is relationships between
           the Environmental Protection Agency, OSHA, and the
           NRC, because the chemical plant comes under a
           different regulatory structure than the nuclear plant,
           and there's been some history to indicate that it is
           sometimes difficult to work between different federal
           agencies with different philosophies.
                       So that's clearly the first thing that
           shows up.  
                       The second one, which is related, would be
           the need for the technical staffs of EPA and the state
           regulator that deals with hazardous materials to work
           with the NRC in whatever type of analysis, safety
           analysis, would be required to assure that all the
           safety issues are properly addressed, both in the
           nuclear and chemical side and on the interface.  
                       So I see that the initial problems as both
           institutional and technical because we have a separate
           structure for regulation of nuclear versus chemical.
                       Now, that's not true in some other
           countries.  The Brits have a unified structure, in
           which case no problem.  But for the United States
           where we have, for one reason or another, have got two
           different organizations to deal with hazardous
           materials, this would be a significant interface
                       CHAIRMAN KRESS:  Are there other
           questions, comments?
                       Seeing none, thank you very much, Charles.
                       And we'll move on to the next item on the
           agenda, which is, I think, an NEI presentation, I
           believe.  Yes.  
                       DR. WALLIS:  Are you the next speaker? 
           All yours.  Do you want this seat?
                       MR. HEYMER:  Can you hear me?
                       Good afternoon.  My name is Adrian Heymer. 
           I'm a pro jet manager at NEI in the risk informed
           regulatory group.  
                       We deal with Option 2, Option 3, which is
           risk informing the SSCs governed by NRC's special
           treatment requirements, risk informing NRC technical
           requirements, a few other risk informed activities,
           and we've been matrixed across to the new plant group
           within NEI dealing with the new plant regulatory
                       Since we're in the risk informed group,
           one of the things that we've come up with is that we
           feel that we should start with a fresh sheet of paper
           as we deal with the regulatory framework for new
           plants, especially since we're not dealing with
           necessary light water reactors with different --
           dealing with different types of reactors.  
                       And that really comes about because we
           don't want to be too burdened with current
           interpretations and current philosophies or ingrained
           or established thought processes necessarily.  
                       We have run into some cultural issues as
           you go through any change process, and these have been
           difficult to overcome. 
                       So starting with a clean sheet of paper we
           hope that we start off with fresh minds, but build on
           our experiences of the past so we don't actually lose
           those, but don't become ingrained with them.
                       Establishing new wired thinking or a new
           framework provides some form of measure against which
           we can set our requirements, requirements being in the
           regulations and the general design criteria and what
           we believe are general operating criteria.
                       And I think it provides a platform for a
           better understanding between the people who are trying
           to get a license or a certification and the regulators
                       Next slide.
                       So not only does it provide a basis for
           the regulatory positions, but it helps the industry
           establish its own positions as we work through the
           development of the framework so that we can come up
           with, as we said, a generic framework to cover all
           types of plant, and some people think we can achieve
           that goal and other people think we can't.
                       And I think it depends upon the degree of
           specificity that you get down into, whether or not you
           put the real details in the regulations or do you put
           the details in the regulatory guide.  
                       We think there's a need as you go through
           looking at where we are today in the current plants. 
           We've got an oversight process which is risk informed. 
           And we have regulations which are very much
           deterministic.  There are some that are moving towards
           a risk informed world, but we haven't quite got there,
           and in fact we are struggling in some of those areas.
                       And so it would bring some degree of
           consistency between an oversight process and the
           regulations, the reg. guides and the way we run and
           regulate out plants.
                       And so what we're looking at is to start
           with, and again, it's a starting point for discussion,
           is to use the framework that was being developed for
           the oversight process, to start not only in the
           industry-regulatory interactions, but sort of the
           intra-interactions between the industry and we hope
           for the discussions within the NRC staff as we move
                       Why do we want to start there?
                       Well, quite simply it's out there today. 
           It is a risk informed type of framework.  
                       Does it cover everything?   No.  And I'll
           get to that in a minute.  
                       But it has, if you like, broken the ice as
           regards the changing the cultural mentality that
           exists within the industry and the regulatory
           establishments, and I think that's only a natural
           resistance.  There's a natural resistance to change
           that you see anywhere that must be overcome.  
                       Next slide.
                       So we want to be generic to all types of
           reactor.  We think it's good if you start from the top
           and slowly work down and cascade out.  And many of our
           concepts, I think, are reflected in some of the
           presentations I heard this morning.  I wouldn't
           necessarily say we're going down the same path as
           everyone.  I heard this morning all those paths, but
           certainly there is a common flavor that if you take it
           at a high level, that there is a convergence of
           thought as we move down towards establishing the basis
           for the licensing a new reactor in the United States.
                       And so we start with the adequate
           protection of public health and safety, and there are
           some safety goals that are associated with that.  
                       Are they the same safety goals as we have
           today?  And we believe at the moment they are.  It may
           be more towards a radionuclide release criteria rather
           than a core damage frequency, but it's along those
           lines, and those goals have been established.  
                       We do believe you need a new set of
           general design criteria, although I do agree with I
           think Mike Golay this morning, who said the general
           design criteria, if you read them, they are very
           motherhood statements.
                       And we've got an example towards the back
           end of the presentation of where we might go in that. 
           And I think one of the items that we're going to
           struggle with as we move through this is how specific
           do we get in the regulations as opposed to trying to
           keep it general because the more specific you get, the
           more difficult it is to say, "Well, is this going to
           be applicable to all regulations, all types of plants,
           or not all plants?"  And then how do you work that one
                       There isn't really much or until recently
           been much in the regulations regards general operating
           criteria or operating regulations.  The regulations
           were really set in place to deal with design and
           construction of plants, and we try to sort of adjust
           and bend the regulations into an operating mode.  
                       And I think there needs to be some element
           in there.  I think when you look at the maintenance
           role and you look at 56(a)(4), the maintenance rule,
           which is if you lack a configuration control element,
           we've begun to put those measures in place.
                       Whether we need some more or not, I don't
           know.  But I think we do need to look at the operating
           side as well as the design and construction.  
                       It should be a risk informed and
           performance based.  We've struggled with what does
           that mean in the regulatory world.  But I think
           building on the experiences that we've had with Option
           2 and Option 3, with the oversight process, I think we
           can come up with a good set of regulations.
                       And then beneath that, you're going to get
           a series or reg. guides or implementation guides that
           would be, first of all, regulatory specific.
                       So how to implement this regulation, and
           that's where you may get down into the various
           different design characteristics.  So you might have
           one regulation, but it may have two or three reg.
           guides depending upon the type of reactor that you are
           talking about.  And then you'd have design specific
           applications dealing with that, that design element.
                       So that way the regulations are general. 
           They're generic.  They cover everything.  It's a set
           standard, but it is fairly high level, and I guess
           there is an issue out there as regards finality and
           certainty, is the more general you get, the more
           reliance you're putting on reg. guides, and is that
           regulations and is there a finality in the legal
                       And we leave the lawyers to deal with
           that.  That is an issue that has been mentioned on
                       I just want to touch a few moments now
           that I've said what the concept is and we're moving
           forward.  We are in the process of establishing a task
           force made up of industry participants to take a look
           at what the framework would be, how detailed it should
           be, and give us some input so that we can provide
           something as regards an input to the regulatory
           process and the development process either at the end
           of this year or the early part of next year.
                       But is that the end of the game?
                       No, it's not.  It's only really the start
           because in order to move forward, I think, you really
           need some active project.  Otherwise, you'll, as you
           move into the regulatory discussion, you're dealing
           with somewhat of the theoretical hypothetical type of
           interactions that have gone on.  And I think if you
           have a specific program to lean towards, to join with,
           that you force yourself to come up with -- you force
           yourself to a decision point, and you have to make
                       And we can always get smarter as day goes
           on, but at least you come up with a decision.  You
           come up to a starting point.  So what we see as a
           proof of concept type of application, whereby very
           similar to what happened in license renewal and Option
           2 for South Texas, that we hope is a little bit more
           expeditious than Option 2 or the license renewal
           approach, whereby you come up with an idea and you
           come up with a framework or you come up with a
           regulation.  And then you move forward with a specific
                       And the lessons learned from that specific
           project and those specific interactions between that
           licensee or designer and the NRC get fed back into the
           framework, and you adjust as you move forward.
                       CHAIRMAN KRESS:  When you say use license
           renewal and Option 2 models, you don't mean the
           specifics in there, do you?
                       MR. HEYMER:  No, I mean --
                       CHAIRMAN KRESS:  You mean as a process.
                       MR. HEYMER:  As a process.
                       CHAIRMAN KRESS:  As a process.
                       DR. APOSTOLAKIS:  I think what you
           described, Adrian, is really the idea of a pilot.  Is
           that --
                       MR. HEYMER:  You can call it a pilot. 
           Pilot's probably too strong a term.  We're looking
           more or less at proving the concept, proving of the
           framework, proving that the regulatory process as the
           process is being developed.  
                       And so that's why we think it's important
           to have representation into the development of the
           industry thought process on the framework from Exelon,
           from Westinghouse to cover IRIS, to cover the AP 1000,
           to cover the pebble bed from General Atomics, et
                       So that you get those thought processes in
           and there's the concept; that's the framework.  Then
           you go and perhaps test it with a few applications and
           see how it actually works out.  
                       When we've used the term pilot in the past
           internally, some people have thought that was perhaps
           a too definitive term as you are definitely testing
           the regulation.  
                       Here you are testing more the concept, and
           then the regulations would be developed from the
           pilots or the proof of concept projects moving
           forward, and what you've come up with is a draft
                       And I think if you see or the way we see
           it going forward is that there -- we have the
           regulatory interaction. We provide input to the
           regulatory process.  They come forward with an
           advanced notice of proposed rulemaking.  That goes out
           of the street, has public involvement.  It comes back;
           there'll be more discussions and sessions like this.
                       In the meantime, the pebble bed and others
           are moving forward, and they're talking about
           specifics, and that gets fed back into the process,
           and by that time, some point in time, you come forward
           with a notice, if you like a mega-notice to proposed
                       Now, whether it's on specific regulations
           or a new part to the regulations, I don't know.  But
           I think at the moment we're thinking about a new part
           to the Code of Federal Regulations to deal with these
           new types of reactor designs.
                       CHAIRMAN KRESS:  For advanced reactors.
                       MR. HEYMER:  Yes.  Advanced reactors.
                       CHAIRMAN KRESS:  Part 6(e) something or
                       MR. HEYMER:  Yeah, 63.53 or whatever, yes.
                       MR. SIEBER:  It seems to me that licensed
           renewal never struck me as particularly risk informed
           or performance based.  How does that act of a proof of
                       MR. HEYMER:  Well, in licensed renewal
           there was a draft regulation, and then some plants
           came forward, and one or two dropped out, and then
           Constellation and Duke took up the ball, and there
           were active interactions going on on renewing a
           license, a specific license at the same time as we
           were trying to work out the implementation details
           associated with the regulation, and in fact, while the
           regulation in some cases was being changed.  
                       And so that's how I see it's more of a
           process issue.  I agree with you, it's --
                       MR. SIEBER:  It's not risk informed.
                       MR. HEYMER:  It's not risk informed, but
           it's -- we're trying to look at the regulatory process
           as well as the specific regulations dealing with that.
                       DR. APOSTOLAKIS:  Adrian. 
                       MR. SIEBER:  Thank you.
                       DR. APOSTOLAKIS:  Everybody keeps saying
           risk informed performance based, but can licensing
           really be performance based?
                       MR. HEYMER:  I think in the context of
           purely the licensing action, no, but what follows on
           afterwards is. 
                       DR. APOSTOLAKIS:  Oh, the regulatory. 
                       MR. HEYMER:  Yes.
                       DR. APOSTOLAKIS:  The oversight, sure.  We
           are not dealing with that now.  You are dealing with
           licensing, aren't you?
                       MR. HEYMER:  Well, we think that if you
           put a new Part 63 in place that there should be some
           element dealing with operational aspects, and so
           that's where we see that coming in, and there's also
           a probability that if you look at the Part 52 process
           in ITAAC, that is akin to a performance based element
           to a certain extent.  
                       I mean, you have the ITAAC which are
                       Okay, next slide.
                       This is a pictorial representation of the
           process that we've -- I've just discussed.  I spoke
           about coming down from the top, but equally you've got
           the reg. guides and the specific design, specific
           guides from the bottom and it's -- if you like, we
           could have drawn it as a pyramid, but it was easier to
           put all these words in place.
                       What are the safety areas and what is the
                       And we think they are the same as the
           oversight process, and if you go to the next slide,
           this is what the regulatory oversight process is as of
           today.  Does it cover everything in a regulatory
                       And the answer is, no, it doesn't.  There
           are some things missing, and I think if you start
           looking at some of the advanced reactor types that we
           have today, are we talking about mitigation systems or
           mitigation processes?
                       And by that I mean perhaps there isn't a
           system to mitigate the initiating event.  Perhaps it's
           designed into the plant.  
                       There's also an admin. element that's
           missing that would cover some of the reporting
           requirements, configuration and change control, cover
           quality assurance.  
                       And so if you go to the next slide,
           please, this is what one might look like, and we
           haven't had very much discussions totally within the
           industry.  There are rather a lot of boxes and it's a
           very complex slide.  
                       Some things I want to point out is I don't
           think it's mitigation systems.  It's mitigation in
           general, and we need to perhaps define what that is.
                       And then under the administrative area,
           you have a whole section of issues here, some of which
           could be risk informed.  Others, which will probably
           just almost be lifted carte blanche out of a Part 50
           space, and whether or not we do that is still to be
                       And one of the other issues is how would
           we deal with the Part 52 interface.  And I think there
           is a way to deal with that as you go through the
           rulemaking process with the conforming change.  
                       But some of these, like the reporting
           elements, tech spec amendments, and things like that,
           I think there is an opportunity to risk inform those
                       I believe there is some internal work done
           that showed that 40 percent of all tech. spec.
           amendments aren't really associated with safety, and
           something like 70 percent of all LERs and reporting
           requirements from 50.72 and 50.73 aren't associated
           with safety significant issues.  
                       So I think that's something that we should
           take a look at from an administrative burden that
           perhaps we need to place the emphasis of our resources
                       As you go down here one other point is
           that on radiation safety, we are looking at an
           activity to take a look at Part 20 and see if we can
           improve on that regulation, and perhaps make it
           performance based, building on what we've learned over
           the last 35, 40 years of implementing those
           regulations within the industry.  
                       So that is an addition to what we have
                       How long is this going to take?
                       Well, as I said, we're hoping to have some
           recommendations or proposals into the NRC staff
           towards the end of this year, early part of next year.
                       CHAIRMAN KRESS:  Whenever I've seen this
           slide or the previous equivalent, without the added
           parts, I've always thought between that top box and
           the three boxes below it, and now you have four, that
           there's a missing set of boxes.  And that is what is
           the regulatory objective of reactor safety.
                       Is that the safety goals, for example, or
           is it something else?
                       So what's the regulatory objective for
           radiation safety?  Is that 10 CFR 100 or is it -- and
           similarly for the safeguards.  
                       I've always thought that it's that missing
           line in there that gives us a lot of trouble.  And I
           wonder if you guys had planned on adding something in
           there to define what we mean by those three boxes, or
           the four.
                       MR. HEYMER:  Well, when you look at the --
           when you look at the oversight process, there was an
           attempt to define what is associated with those -- it
           was three boxes, but those -- that second layer, and
           associated with the attributes and an attempt to
           define what they are within those areas, and as they
           come down into the next box, which is the cornerstone.
                       We can take a look at that and see, but
           that's a good input.
                       DR. APOSTOLAKIS:  I had a similar comment,
           maybe expressed in a different way.  The fundamental
           difference between what you're trying to do and what
           the oversight process does is that the oversight
           process starts with an existing system that has been
           licensed and works with changes from that.  
                       As such, the need for these goals that Tom
           mentioned is not there because now, you know, I look
           at the particular plant, look at the initiating
           events.  There is a certain rate.  Although the system
           is not plant specific yet, they're going there with
           design specific thresholds.
                       But if you think about this framework
           being used to license a new concept, then all the
           questions that came up this morning during Mike
           Golay's presentation come back here to haunt you.  
                       In his presentation, Tom asked what is the
           allocation to LOCA's of, you know, the goal and so on. 
           Well, here because you are starting with a new sheet
           of paper, you have the same questions.  How much
           should I tolerate of the frequency to go to the
           initiating events, to the mitigating systems, to the
           barrier integrity?  
                       So it's really something that's -- I mean,
           I think you have very good intentions, Adrian, but the
           really tough questions have not been addressed yet.  
                       There is a fundamental difference between
           overseeing something that's already there and has been
           licensed and starting with something that's coming out
           of the blue, and I don't know.  I don't know what the
           initiating events are for the pebble bed, you know.
                       MR. HEYMER:  You make a very good point,
           but it's not literally coming out of the blue.  We
           have --
                       DR. APOSTOLAKIS:  Well, it's maybe blue
           and red.
                       MR. HEYMER:  -- experience that we can
           build on, and we can start establishing some of those.
                       DR. APOSTOLAKIS:  I am sure we can, but
           I --
                       MR. HEYMER:  I mean, I think if you sat a
           group of people around a table you could come up with
           those type --
                       DR. APOSTOLAKIS:  I think what I'm saying
           is that you are a little -- overplaying it a little
           bit, unintentionally, the significance of the fact
           that this framework has been used in the oversight
           process.  The fundamental issues are there.  
                       If you look at the report the staff
           developed on Option 3, essentially they follow the
           same approach, but they dare go beyond that, and I
           think you guys are a little cool towards the other
           stuff they did.  
                       If you look at what Golay did, well, it's
           buried in there.  I mean, it's the same idea.  So I
           think this is a good starting point, but I wouldn't
           overplay the connection to oversight.  It's a very
           different regulatory problem.  I guess, that's my
                       MR. HEYMER:  That's good insight.  It's
           good input.  I'm going to take that.  
                       DR. APOSTOLAKIS:  I came on too strong,
           Adrian.  I'm sorry.
                       MR. HEYMER:  No, no, no.  Please, please. 
                       DR. APOSTOLAKIS:  It's just that I don't
           like it.  
                       DR. APOSTOLAKIS:  No, I'm sorry.  No, I
           didn't mean that.  Take it back.  Take it back.
                       MR. HEYMER:  But from the cornerstones we
           would develop specific criteria and specific
           regulations, which would feed off the cornerstones in
           those areas.  And we did a -- what we just to see how
           it would pan out, we looked at -- we took the current
           regulations, of which there is about 160 general
           design criteria regulations.  
                       DR. APOSTOLAKIS:  One other question. 
                       MR. HEYMER:  Yeah?
                       DR. APOSTOLAKIS:  What we're seeing on the
           board now on the screen is the NRC oversight.  Now,
           when you go to yours, you are adding a fourth element
           in the second tier, but how about the bottom?
                       What happened to human performance, safety
           conscious work environment, and problem identification
           or resolution?  Are you going to handle those in a
           different way?
                       MR. HEYMER:  Problem identification and
           resolution is in the quality assurance element.
                       DR. APOSTOLAKIS:  Oh, it's --
                       MR. HEYMER:  Yes.
                       DR. APOSTOLAKIS:  Oh, okay.
                       MR. HEYMER:  And we see training would be
           down in there as well.  And so --
                       DR. APOSTOLAKIS:  I see.  So you are
           covering those with the new boxes?
                       MR. HEYMER:  Yes.  
                       DR. APOSTOLAKIS:  Okay.  
                       MR. HEYMER:  What we did is we took the
           cornerstones, and we added a few areas to them, such
           as administrative, financial and operational, and we
           took the current regulations, and we attempted to say
           which box would they fit into.
                       And we soon realized that some of them
           actually fit into more than one box.  That's why if
           you add up the number it does actually come out to
           more than 160.  
                       But it's interesting to see where the
           regulations are focused at the present time, and
           perhaps that's quite proper because it's a legalistic
                       DR. APOSTOLAKIS:  But again, why is that? 
           I mean, I appreciate the point you're making, but why
           should I be surprised?
                       I mean, here is a technology that, you
           know, the safety issues are really very low
           probability, high consequence events.  Very low
           probability means that I really don't have a
           statistical record, right?
                       So it makes sense for me to have lots of
           administrative controls, doesn't it?  Unless
           administrative means something else that I don't
                       MR. HEYMER:  Well --
                       DR. APOSTOLAKIS:  Doesn't it?
                       MR. HEYMER:  Administrative controls
           dealing with reporting, dealing with how to make
           out --
                       DR. APOSTOLAKIS:  Those I understand.
                       MR. HEYMER:  -- dealing with how to update
           the FSAR.
                       DR. APOSTOLAKIS:  So what you're saying is
           we are -- we got them carried away?
                       MR. HEYMER:  I think we may have done in
           some areas.  Now, on the other hand, if there's some
           administrative requirements to keep the regulator
           informed, I think the regulator should be informed of
           those matters that have safety significance for the
                       DR. APOSTOLAKIS:  Sure.
                       MR. HEYMER:  And I think that's -- I mean,
           when you look at some of the regulations and they're
           ten pages in length and very complex and difficult to
           read, it's certainly not nighttime reading.  Then I
           think we can do a job of streamlining those
           regulations and still being able to focus on those
           matters that really do present a risk to the public.
                       DR. GARRICK:  And there are those
           precursor events for which there is information and a
           relatively high frequency. 
                       MR. HEYMER:  sure.
                       DR. GARRICK:  And of course, the risk
           informed is making the connection between those and
           the events of interest.
                       DR. APOSTOLAKIS:  No, I understand that,
           but all I'm saying is that I'm not really surprised
           that the highest number is down there in the
           administrative thing, because you are dealing with
           rare events.  
                       Now, I do agree that instead of 68
           probably it should be 43.  But I still think it's
           going to be a high number. 
                       MR. HEYMER:  Yes, but hopefully not as
           high as proportionally as what we've got here, and
           plus also we recognize, as I'm sure you do, that the
           current regulatory framework is not really that risk
                       DR. APOSTOLAKIS:  No, no.
                       MR. HEYMER:  And so it's fine.  But it was
           just to show you -- show us where it comes in and the
           fact that we thought that it does fit.  
                       On the next slide what we've attempted to
           do, just as a point of discussion, is just to chalk
           out, and we've done this for a couple of regulations,
           is to calk out what might a regulation look like and
           is some associated with configuration management?
                       And a lot of people in the past 20 years
           or so have got into some problems about losing
           configuration control and what that means in the
                       DR. APOSTOLAKIS:  I must say --
                       MR. HEYMER:  And that includes risk
           configuration management.
                       DR. APOSTOLAKIS:  I though your -- the
           emphasis of your talk was going to be on licensing of
           the new concepts.  But yours seems to be attacking the
           whole thing.
                       MR. HEYMER:  It's a regulatory --
                       DR. APOSTOLAKIS:  Does Exelon really worry
           about how the NRC will regulate the pebble bed after
           they get the license?
                       They worry about it right now?
                       MR. HEYMER:  They worry about it right
           now, but if you're dealing with -- and that's why I
           said when you develop the framework, you have people
           like Exelon moving out and testing the process on a
           pebble bed, and there's a feedback process that comes
           in and you can adjust.  
                       Now, once you start operating those
           plants, perhaps there's some additional -- just as
           there is today.  We get smarter as we go on.
                       DR. APOSTOLAKIS:  So how is this different
           from the current maintenance rule?  Isn't that what it
                       MR. HEYMER:  It's very little different. 
           I mean.
                       DR. APOSTOLAKIS:  Okay.
                       MR. HEYMER:  I mean, it's just an example
           of we're already there in some of these areas.  Okay. 
           Now, some of the areas we're going to do some more
           work, but it would be -- the purpose of this slide is
           to say that it is not ten pages.  It's a bit more than
           ten words, but it's not going to be a detailed, very
           specific regulation, like Appendix R, like 50.55(a)
           for codes and standards.  
                       We think it should be a fairly general,
           high level sort of regulation that we're talking about
                       MR. SIEBER:  Would this take the place of
                       MR. HEYMER:  This could take the place of
                       MR. SIEBER:  Well, this is pretty general.
                       MR. HEYMER:  I mean, this is general.  We
           hadn't really thought that point all the way through,
           but we thought if you're dealing with configuration
           control, configuration management and change process,
           if you're dealing with something akin to what we've
           got in (a)(4) with the maintenance role, perhaps this
           is all that you need.  
                       Now, we probably need a few more bullets
           than what we've got here, but as a starting point,
           just to oil the brain up and get it moving, so to
                       MR. SIEBER:  I would imagine that once the
           lawyers got through that, it would look pretty much
           like 50.59.
                       MR. HEYMER:  That's why we want a risk
           informed and clean sheet approach, because we want to
           be able to say, "Okay, is it risk management?  Are you
           managing the risk profile of the plant?"
                       And if you are, perhaps it's just
           something like this in a reporting element.  So it's
           a question.
                       DR. POWERS:  Can you tell me what exactly
           your intention is?  Assess and manage, what -- how do
           you view those?
                       I mean, assess could be, yeah, it's a
                       MR. SIEBER:  Tells you what desk drawer to
           put it in.  
                       MR. HEYMER:  Underneath this there would
           be a regulatory guide that actually defines the
           specific process and would put the change control
           criteria down in there.  So it wouldn't necessarily be
           in the regulation.  It would be in the regulatory
                       DR. POWERS:  The regulatory guides of
           course are just advice to the staff.  I mean, advice
           to the licensee.  
                       MR. HEYMER:  And the licensee would make
           a commitment.  
                       DR. POWERS:  He would make a commitment
           upon that.
                       MR. HEYMER:  To have a process that
           satisfies that reg. guide.
                       DR. POWERS:  What I'm trying to understand
           is what do you see him committing to do?
                       MR. HEYMER:  Committing to meet the
           regulatory guide, and as I said at the start, there is
           a debate about how specific we get to, and I think
           that point was made by Mike Golay, and I think it was
           this morning about how specific do you get in items
           such as the general design criteria, because when you
           look at the general design criteria, they are very
           motherhood statements and you could say, "Well, yeah,
           this can fit any type of reactor."  
                       Now, if you start getting the next step
           below that, you begin to get more specific, and then
           you begin to run into the different types of designs
           and perhaps different facets of what is covered by the
           regulations in those designs.  
                       And so that's the reason why I put this
           slide and the slide after it up, is to really
           emphasize the point of what we're going to struggle
           with, I think, as we go through this, is how much
           detail you get into as you develop the new regulation.
                       DR. APOSTOLAKIS:  The major challenge
           right now, it seems to me, is licensing a new concept. 
           And you are really ahead of the game because -- not
           ahead of the game, but you are looking after licensing
           perhaps because it's easier to start with, because
           it's very close to what we're doing now.
                       I mean as you said, this is very close to
           what the maintenance rule is.  So this is the easy
           part and, you know, I also like to start with easy
                       MR. HEYMER:  You go through and one guy
           goes through and he has a license, but then you want
           a standard by which other people coming forward can be
           judged against, and this is what we're trying to put
           in place.  
                       DR. APOSTOLAKIS:  But I think -- I
           thought, at least, that you were going to place more
           emphasis on the actual licensing process.  How do you
           risk inform that?
                       MR. HEYMER:  Well, the licensing -- you
           mean the Part 52 process or the Part 50 --
                       DR. APOSTOLAKIS:  Yeah, if you want to go
           part -- 
                       PARTICIPANT:  The design certification.
                       DR. APOSTOLAKIS:  Okay, the design
           certification process.  
                       MR. HEYMER:  And just as Part 52
           references Part 50, I think Part 52 would reference
           this new process.  I mean there's going to be a
           comparison of -- as you come in, there's going to be
           a comparison of the proof of concept project coming in
           with what they believe should be the framework. 
           You've got the existing requirements, and you've got
           the development of this new regulatory framework set
           of regulations.
                       It's like a three cornered input, and the
           initial comparison is going to be the new guy coming
           in with the new framework, which is developed
           predominately by that licensee, and which that
           license's input would also feed into the general
           industry view.  
                       And you've got the NRC with their current
           regulations, and you want us to say you meet the
           current regulations or take an exemption from them, or
           you come up with another set of regulations.  And what
           we're looking at here is what do we come up with as
           regards another set of regulations.
                       DR. APOSTOLAKIS:  Again, if I look at --
           I mean, if I look at the figure with the expanded
           framework of the oversight process --
                       MR. HEYMER:  Yeah.
                       DR. APOSTOLAKIS:  -- I mean, all the
           questions that came up this morning and yesterday,
           again, you will need to a major effort to address
           them.  If I look at initiating events and mitigation
           and barrier integrity and emergency preparedness, now
           I'm told that in a new concept I really don't need to
           worry too much about the containment, additional
                       I mean, I will need guidance to be able to
           evaluate that in a risk informed way.
                       MR. HEYMER:  I think the containment issue
           is not necessarily linked to the containment.  It's
           linked to the -- it's linked to the barrier. 
                       DR. APOSTOLAKIS:  Yeah.  The barrier.  So,
           you know, that's what I'm saying that I said earlier. 
           For an existing plant, I already have an allocation if
           I were to use that way.  We know from the existing
           PRAs, 103 units and so on, roughly how much of the
           risk is due to initiating event frequency, roughly how
           much due to the mitigating systems, the containment,
           and so on.
                       Now, in a new design somebody tells me,
           "I'm going to keep the core damage frequency to ten to
           minus five," which is, you know, maybe better than
           some of your plants now.  But all the ten to the minus
           five comes from the initiating events.  I'm going to
           make sure that those don't happen.
                       Now I'm having a problem with defense in
           depth, you know, which I didn't have in the oversight
           process because the plant already existed.
                       Now, that's the fundamental problems that
           will take time, I think as these, resolving those, and
           some guidance from you guys would be great actually.
                       MR. HEYMER:  As regards defense in depth,
           you have -- I mean, that's linked to uncertainty in
           the consequences, and you k now, the higher the
           uncertainty and the larger the consequences, the
           poor --
                       DR. APOSTOLAKIS:  Right.
                       MR. HEYMER:  And what we see is probably
           more of a risk based and then a deterministic being
           laid on top of that from a defense in depth
           perspective as opposed to the other way around that
           we've got it at the moment.  We have a deterministic
           set of regulatory requirements, and we're trying to
           layer or at least impose a risk informed set on top of
                       DR. APOSTOLAKIS:  I understand that.  I
           guess my point is that at this stage you have not
           really attacked the most difficult questions of --
                       MR. HEYMER:  Well, I think it comes
           back --
                       DR. APOSTOLAKIS:  -- and that's fine, I
           mean, as long as you agree that you have not.
                       MR. HEYMER:  It comes back to the point
           you made on the box diagram about defining what
           reactor --
                       DR. APOSTOLAKIS:  I'm sorry.  Comes back
           to where?
                       MR. HEYMER:  To the point you made on the
           framework diagram that's got the admin. box in it
           where you talked about reactor safety, radiation
           safety --
                       DR. APOSTOLAKIS:  Yeah.
                       MR. HEYMER:  -- is defining, better
           defining what those are.
                       DR. APOSTOLAKIS:  Okay.  So you will do
                       MR. HEYMER:  Yes.  I mean, we can do that.
                       DR. BONACA:  Although I must say that I
           still am confused about what's different in this from
           the previous system.  I mean I could take the previous
           -- the existing system and then put it on --
                       MR. HEYMER:  From a framework perspective,
           not much.  It's when you get down to specific
           regulations you begin to see --
                       DR. BONACA:  Okay.  Well, I can understand
           that.  Yeah, all right.  I don't quite understand from
           the examples where the differences may be, and I
           really couldn't figure it out.  But I understand your
           intent.  I mean, clearly you said before that it has
           to be risk informed and you're looking.
                       The reason why I bring it up is that we
           saw a number of innovative processes this morning, and
           the concern I have is that you can put in pricing
           framework now that may stifle, in fact, the
           credibility of some of the innovative cultures as much
           as the old system stifles.
                       If you step ahead and make, you know, a
           framework too articulated here.  I don't know.  It
           seems to me --
                       MR. HEYMER:  Well, when you look at the
           framework and you see the current regulations and
           requirements, I would agree with you.
                       If you look at the frame work and say
           there are alternative regulations or a different set
           of regulations, a different set of design criteria, I
           think that gives you the flexibility.
                       If you go to the last slide, this is one
           we came up with protection against natural phenomena. 
           I mean, it really brings home Mike Golay's point. 
           It's how specific do you get because this is almost
           identical to what's in the general design criteria
                       But do you break it down into separate
           elements or do you stay with a simple general
           statement like this?  
                       And that's one of the things I think we're
           going to struggle with, but when you look at you're
           going to protect against natural phenomena, I mean, I
           think that's what you're going to have to do.
                       DR. POWERS:  But it's the historically
           reported.  I mean, this is --
                       MR. HEYMER:  Well, that's the reason why
           initially we were going to stop at halfway through it
           where it says capability to perform the safety
           functions, and then we added on the last of it to say,
           you know, do you go back to the historical or is it
           just probabilistic or what, and that's the reason why
           we put the last bit in.
                       DR. POWERS:  What it means is that sites
           where there hasn't been anybody living or reporting
           for have much less severe criteria than where I have
           a long history.
                       MR. HEYMER:  It depends on how far back
           you go.  I mean, a lot of those histories go back
           before a nuclear plant was actually put in place.
                       DR. POWERS:  Sure.  I mean, I'm think of
           earthquake.  We go back farther than that.
                       MR. HEYMER:  Oh, a lot farther, yeah.
                       DR. POWERS:  And so why now are we going
           to drop it down to just the historical record on
           earthquakes?  There's not enough history to get any
           kind of statistics on just earthquakes.
                       MR. HEYMER:  Well, I mean, that's a debate
           that I think we're going to have, but it's just to try
           and highlight.  The reason why we wrote it this way is
           just to try and make the point of are we going to go
                       DR. APOSTOLAKIS:  I can't remember right
           now, but how is this different in a fundamental way
           from the existing practice regarding earthquakes?
                       MR. HEYMER:  We didn't say it would be
           that much different.
                       DR. APOSTOLAKIS:  This is almost the same,
           is it not?
                       MR. HEYMER:  Yes.
                       DR. POWERS:  No, no.  If I have to adjust
           to use the historical record on earthquakes?
                       DR. APOSTOLAKIS:  They define the safe
           shutdown earthquake using the history of the site,
           using the history.  That doesn't mean you go strictly
           by what happened, and they say, you know, you're going
           to have what, a margin for uncertainty and so on?
                       It's really no different.
                       DR. POWERS:  I think it's a big
                       DR. APOSTOLAKIS:  Oh, no.
                       MR. SIEBER:  The flood area --
                       DR. POWERS:  If I have to live on what's
           historically reported rather than the history of the
           site, that's a big difference.
                       DR. APOSTOLAKIS:  Oh, oh, oh, I see.
                       MR. SIEBER:  The flood area is quite
           different.  For example, I know of one plant where
           they postulated the breakage of a major upstream dam
           to define what the flood level would be, and of
           course, there's no historical record that that dam
           ever broke.  
                       So, you know, that prevents you from
           postulating that might occur, but have not yet
           occurred as part of the protection of the plant.
                       DR. APOSTOLAKIS:  And what safety
           significant -- do you mean risk significant --
                       MR. HEYMER:  Yeah.
                       DR. APOSTOLAKIS:  -- in the sense of
           Option 2?
                       MR. HEYMER:  And the reason why I put that
           down is because when we told -- we mentioned about
           safety related or safety --
                       DR. APOSTOLAKIS:  Significant.
                       MR. HEYMER:  I know.  We were just -- we
           put safety significance trying to emphasize that
           that's in tune with the Option 2/Option 3 type of
                       Now, you could say risk significant in
           terms of the maintenance rule.  It would come up.
                       DR. APOSTOLAKIS:  No, there is a slight
           problem here, I think, in the sense that I cannot
           determine what is risk significant or safety
           significant until I have a PRA which will tell me when
           the PRA will be based on the actual design, but now
           I'm supposed to use the results of that PRA, in fact,
           to create the knowledge base for the PRA.
                       MR. HEYMER:  Well, it's an iterative
                       DR. APOSTOLAKIS:  So you start with one
           and do it and do it again?
                       MR. HEYMER:  Yeah, and there is
           experience.  I mean, when you do -- you know.
                       DR. APOSTOLAKIS:  Well, yeah.
                       MR. HEYMER:  You just don't say, "Well,
           I'm starting with a new design.  What have I got?"  I
           mean, there's --
                       DR. APOSTOLAKIS:  I must say overall
           though, Adrian, maybe it's too early in the process,
           but I, frankly, thought you were going to come up with
           something that's a little more daring.  You are really
           sticking to the existing regulations which you have
           blasted in the past.  We must be doing something
                       DR. APOSTOLAKIS:  You really like it.
                       MR. HEYMER:  But there is specific
           language in the regulations.
                       DR. GARRICK:  There is one big difference,
           George --
                       DR. APOSTOLAKIS:  What is?
                       DR. GARRICK:  -- that I am detecting, and
           I think it's one of the things that bothers you, and
           that's the issue of allocation.  I get the impression
           that they're talking more in terms of general
           performance goals and not so much in terms of
           allocation down to levels that partition those or
           apportion those to lower levels of the plant.
                       DR. APOSTOLAKIS:  I think whether they're
           doing --
                       DR. GARRICK:  And that's a big difference.
                       DR. APOSTOLAKIS:  No.  I think what they
           are doing is they are not facing it.  The issue will
           come up, eventually will come up.  You don't have to
           allocate, but de facto by doing the things that
           presumably they will propose, you will have an
           allocation, and the question will be a petition, if
           you want.  Is that good enough?
                       Because if I go back to the boxes, again,
           if they come back and tell me that all my eggs are in
           the initiating event basket, why?  Because this is
           what the various criteria produce.  What am I going to
           do as a regulator?  Am I going to accept that because
           that's how it turned out, or what?
                       I know that you have an aversion, John, to
           allocating risk from top down.
                       DR. GARRICK:  Right.
                       DR. APOSTOLAKIS:  And I appreciate that,
           but I think at some point you have to -- I mean, let's
           say you go purely by engineering and you build
           something because it's feasible.  You have to decide
           whether the design is acceptable, which in some sense
           brings that issue back into the forefront of --
                       DR. GARRICK:  I'm not saying you shouldn't
           strive for a balanced design.  I'm just saying that
           there are two ways of looking at this.  One is if you
           really are trying to implement a risk informed and
           performance based approach, then you can take that at
           an overall performance and an overall risk level.
                       You're got a risk standard and a
           performance level, and you go after it, and another
           way is to give it more of a bottoms up treatment.
                       And it's more difficult, especially when
           you're talking about different designs, to think in
           terms of an allocation process.
                       DR. APOSTOLAKIS:  And I agree with you. 
           I fully agree.
                       DR. GARRICK:  It just will not make sense,
           and --
                       DR. APOSTOLAKIS:  Exactly.
                       DR. GARRICK:  -- it won't work.
                       DR. APOSTOLAKIS:  I think it should be a
           check at the end whether you really -- allocation
           really means difference in depth if you want to think
           about it that way.
                       DR. GARRICK:  Okay.  
                       DR. APOSTOLAKIS:  It's not something that
           should drive you.  It should be a check of, you know,
           the design, whether you like what you see.
                       But I must say I'm really surprised at how
           little the current proposals differ from what we're
           doing now.
                       DR. GARRICK:  Maybe this will stimulate
           them now to go back and be more daring.
                       MR. HEYMER:  On that point, you know,
           we've given you today just what our very first initial
           thought is.
                       DR. APOSTOLAKIS:  And I fully appreciate
           that.  Maybe some of my comments are unfair.
                       MR. HEYMER:  Oh, no.
                       DR. APOSTOLAKIS:  But they're more fun
           that way.
                       MR. HEYMER:  It's good input, you know? 
           And we've got to get the input from a lot of other
           people in the industry, and once we've got that, you
           know, I'm sure we're going to have the opportunity to
           come back and discuss it with you again.
                       DR. APOSTOLAKIS:  It's probably pretty
           much a reality, but you got the first reaction though
           to this.
                       MR. HEYMER:  And really and truly, you
           know, if we take a look, we've often said, at the
           regulations at a high level, there's a lot of good
           words in the existing regulation.  There's also a lot
           of words in there that give us heart burn, and what we
           think is that we need to go in there and streamline
           and sort them out.
                       MR. SIEBER:  I think though that part of
           the reason the regulations are written the way they
           are today is that they're supposed to be enforceable. 
           You know, this is really the law, and when you get too
           fuzzy and wishy-washy about things, you can't enforce
           it, and if you can't enforce it, there's no point in
           having the regulation.  You might as well just call
           them suggestions at that point.
                       MR. HEYMER:  That's an idea.
                       DR. APOSTOLAKIS:   Just a general
           suggestion criteria.
                       DR. POWERS:  And there is a --
                       CHAIRMAN KRESS:  We have a comment from
           back here.
                       DR. POWERS:  -- a discrepancy in the way
           engineers treat quantitative views and the way the
           legal group treats quantitative definitions, and quite
           frankly, we have to accommodate them.  They don't have
           to accommodate us.
                       MR. SIEBER:  That's the way it goes.
                       DR. POWERS:  Yeah.
                       MR. SIEBER:  That's just the way the world
                       DR. POWERS:  And they accommodate it by
           not, by avoiding the quantitative and using case law
           to get precision in the definitions.
                       MR. SIEBER:  That's right.
                       DR. POWERS:  We seek precision through
           numbers, and they seek it through cases and live with
                       DR. KADAK:  Let me suggest -- this is Andy
                       Let me suggest something a little more
           daring, and it's reestablishing the regulatory compact
           between what the regulator's job is, what the
           licensee's job is in terms of how they deal in terms
           of the future protection of public health and safety
           from a system that is quite prescriptive in terms of
           its requirements to something that more fully puts the
           burden on the operator to meet some what you might
           call high level goals.
                       And I'm not sure what that new
           relationship is, but clearly if we go to 1,000 plants,
           let's just say, in trying to build on George's ten
           times whatever the probability is and it gets to be a
           large number, that you can't continue doing it the
           same way, and what new regime might be appropriate to
           protect the public health and safety in the sense of
           a risk informed and performance based system.
                       So that addresses the inspection and
           addresses the enforcement action, as well as the
           standards that you apply to new technology.  So that's
           kind of the comment to the NEI people as well as to
           the rest of us, and that is how can we improve the
           overall process not only for design and construction
           and operation, but also regulation.
                       So a though.  If there was a question on
           that, you can try to answer it, but it's a new
           regulatory paradigm.
                       DR. APOSTOLAKIS:  But you are going the
           other way.  I mean I get the impression from NEI that
           they really don't want to move too much -- to far away
           from the existing system.  Perhaps it's the fear of
           the unknown.
                       Another Option 2 review of the times
           three, you know, and you are going about -- you're
           talking about revising the whole structure and doing
           all sorts of wonderful things.  There must be a golden
           optimum in the middle somewhere there.
                       MR. HEYMER:  Yeah.  It's thinking ahead
           and saying, like just challenging the NRC relative to
           how are they going to do license renewals for 80
           plants in the next five years or ten years.  They
           can't something has to change, some trust, some new
           relationship, and we have to figure out how that will
           work in a legal way.
                       DR. POWERS:  Well, I mean, I think they
           came up with a fairly effective solution.
                       DR. APOSTOLAKIS:  Which is?
                       DR. POWERS:  I mean, they've gone through
           the catalog to a variety of data on the agent
           degradation, a huge number of topic reports that run
           four or five pilots, established a template, and
           people were following the template, and based on what
           we saw from A&O, you follow the template and you put
           out a pretty good product, and it goes very quickly.
                       DR. APOSTOLAKIS:  The problem is that for
           licensing new concepts, we don't have a template. 
           That's the --
                       DR. POWERS:  Well, you're also not going
           to have 80 new concepts in five years.  We haven't got
           the same problem.
                       CHAIRMAN KRESS:  We could almost review
           every one of them as a special case.
                       DR. POWERS:  I mean we do each one of the
           certifications in this special case because they are
           special cases.  Just a thought.
                       Now, if you had these 500 modular units,
           then templates work very well.
                       DR. APOSTOLAKIS:  Then I would have a
           problem with the goals.  The moment you get above 600,
           I'd have a problem with it because the goals are posed
           in terms of rates, and the rate inherently depends on
           how many of those things you have.  Okay?
                       So if somebody says, "Boy, this is the
           dawn of the new nuclear era.  We're going to build
           another 1,000 reactors," we'd have to go back to the
           Commission and ask them to think again about the goals
           they have set.
                       DR. POWERS:  Again, they'll tell us no.
                       CHAIRMAN KRESS:  How does the prompt
           fatality have anything to do with the number of
                       DR. APOSTOLAKIS:  Oh, don't ask me
                       DR. POWERS:  George, I think Tom hits upon
                       DR. APOSTOLAKIS:  I think the societal
           risk changes.
                       CHAIRMAN KRESS:  Of course it does, but we
           have no societal risk goals.  That was my point.
                       DR. POWERS:  The guy at the boundary, with
           few exceptions, is only susceptible to one plan.
                       CHAIRMAN KRESS:  That's right.  We need
           some societal risk though, which would change with the
           number of plants.
                       DR. APOSTOLAKIS:  That's right.
                       CHAIRMAN KRESS:  We don't have them.
                       DR. POWERS:  I don't know that.  It's not
           transparently obvious to me that you need a societal
                       CHAIRMAN KRESS:  Well, I think if you had
           1,000 plants --
                       DR. POWERS:  I think we'd be much happier
           if we had one to land contamination and injuries.
                       CHAIRMAN KRESS:  Well, those goals in my
           mind are societal type goals.
                       DR. APOSTOLAKIS:  Those are societal. 
           They're societal.
                       CHAIRMAN KRESS:  Those and total deaths I
           would call societal goals.
                       DR. APOSTOLAKIS:  Yeah, yeah.  Anyway, are
           we done with Adrian?
                       CHAIRMAN KRESS:  Yeah.  Thank you very
                       At this point I'm going to declare a 15
           minute break, and then we'll start a very interesting
           panel discussion at four o'clock.
                                   (Whereupon, the foregoing matter went off
                       the record at 3:43 p.m. and went back on
                       the record at 4:02 p.m.)
                       CHAIRMAN KRESS:  Let's get back to order,
                       This should be very interesting.  I
           haven't worked out any particular protocol of how to
           proceed with this.  What I think I'll do is just say
           if any of you members of the panel wish to make some
           comments before we entertain questions, why, you're
           welcome to do so.  You don't have to.
                       I don't think I like the idea of going
           you, you, you, you make your comments.  So I'll
           actually open the floor.  If any of you guys want to
           make a few comments, just go ahead and volunteer and
           we'll hear them and we'll through the floor open for
           questions while you're commenting and after you
                       So if that's agreeable to you guys, we'll
           do it that way.  So with that I'll say who wants to
           make some comments.  Anybody?
                       Rich, go ahead and start.
                       MR. BARRETT:  Let me just say -- is this
           on? -- that in the material that we got in preparation
           for the workshop, I think all of us were sent
           questions that we were to deal with, and we were asked
           to make a few points about the question that reads as
                       DR. APOSTOLAKIS:  I can't hear you.  Can
           you move the microphone closer?
                       MR. BARRETT:  The question that we were
           faced with was this one.  What are the most important
           regulatory challenges for the licensing of future
           nuclear power plants?
                       And I think the guidance we were given was
           that we should try to keep it to a list of three or
           four, and I see everyone shaking their heads that you
           all got the same question; is that right?
                       PARTICIPANTS:  Yes.
                       PARTICIPANT:  We may not have done our
                       MR. BARRETT:  All right.  Well, at some
           point I would like to answer the question.  Maybe I
           ought to go first and that would get everybody else
           thinking.  How's that?
                       CHAIRMAN KRESS:  Sounds like a good way to
           do it.
                       MR. BARRETT:  Okay.  Well, you know, from
           the staff's point of view I think you've heard on a
           number of occasions how the staff defines success, and
           we define success whether it's in licensing or in
           operating reactors in terms of the four pillars that
           we have defined for operating reactors.
                       And when you're talking about the
           licensing of a future reactor, I think you're dealing
           with the same four pillars, except that you probably
           want to state them a little differently.
                       So let me simply state those four pillars. 
           First of all, I think what we want to do is make sure
           that we assure safety as opposed to maintaining safety
           for the operating plants.
                       And, secondly, that we want to do that in
           a way that is effective and efficient.
                       And, thirdly, we want to do this without
           imposing unnecessary regulatory burden upon the
                       And finally, the fourth of these pillars
           is to do this all in a way that instills public
           confidence in the licensing process.
                       So those are the four pillars that we use
           for judging success of anything we do, and so keeping
           in mind those four pillars, I'd like to just say a few
           words about what I think are the most important
           regulatory challenges for licensing of future nuclear
           power plants.
                       First of all, to maintain safety or to
           assure safety, we're going to have to take a
           comprehensive look at every aspect of safe design and
           operation, including the risk implications of these
           new designs.
                       Now, we're going to have to do that, and
           in order to do that, and I think this is a very
           important point, we must assure that the NRC has all
           of the requisite skills to do a complete review, and
           that's a big challenge for us because this is going to
           require a significant effort on the part of the NRC to
           retain our current experts and to recruit and to train
           new staff.
                       So I think that's the first thing that's
           required from the NRC's side.
                       Secondly, to assure efficiency and
           effectiveness, we're going to have to streamline our
           review of siting and licensing applications, and we're
           going to have to take a careful look at the time and
           the resources that are required for those reviews.
                       And I think that that's a management
           challenge.  I think we've seen that challenge being
           met in the management of the license renewal
           applications, and our challenge is to do that also in
           our management of the applications for review of
           future applications.
                       On the other hand, applicants for site
           permits, design certifications and combined licenses
           must submit complete applications of high quality. 
           That's an absolute must if we're going to be effective
           and efficient, and the applicant furthermore has to
           assign the resources necessary to respond promptly and
           completely to staff questions.
                       So to assure effectiveness and efficiency
           in licensing, there's a burden on the staff, and we're
           prepared to go forward and meet that, but there's also
           a burden on the applicant to assure that you bring in
           that application, make a complete, high quality, and
           support it from start to finish.
                       The third bullet is avoiding unnecessary
           regulatory burden, and in order to do that, I think
           that we must bring out early resolution of a lot of
           the issues related to our regulatory process.  In
           these last two days, you heard a lot of examples of
           these types of issues.  Some of them are financial. 
           Some of them have to do with ITAAC.  Some of them have
           to do with the processes that we use.  Some are
           specific to modular reactors and merchant power, and
           some are bought up because we have new designs.
                       We're going to have to get early
           resolution of these questions in order to avoid
           unnecessary regulatory burden on applicants.
                       And, finally, to instill public
           confidence, we must assure that all of our
           stakeholders have access to the licensing process and
           input to the licensing process, and this is a
           commitment that has to start at the very beginning and
           has to be carried on throughout the process.
                       I think yesterday and today this workshop
           is a very good start along those lines.  I want to
           point out that the staff is going to sponsor a
           workshop at the end of July in which we are going to
           be looking for stakeholder comments on a wide variety
           of regulatory issues that will be important as we go
           forward as well, and we're committed to instilling
           public confidence by giving people access to the
                       So those are the four areas that I think
           are important for licensing of future nuclear plants.
                       DR. WALLIS:  Well, Rich, the only one
           comment I'd have is it's not good enough just to have
           access to a process.  What they find there has to
           instill the confidence that you're trying to instill.
                       MR. BARRETT:  Right.  One of the things
           that we wanted to do at the workshop is very early on
           we want to identify where specifically, to the extent
           possible, where people's concerns are about the future
           licensing so that we can factor those concerns in at
           every stage along the way and make sure that we
           address those questions and concerns.
                       CHAIRMAN KRESS:  I think what I'll do is
           after a given panelist makes his talk, I'll open the
           floor for questions if anybody wishes to question that
           particular panelist while it's fresh in your mind, and
           when we exhaust those questions, which we may have
           already, we'll move on to another, I guess, volunteer.
                       I don't want to put anybody on the spot,
           but does anybody want to speak next?  Mr. Lyman, are
           you --
                       MR. LYMAN:  I actually prepared slides.
                       CHAIRMAN KRESS:  Well, that's certainly
                       MR. LYMAN:  And that's probably more
           than --
                       CHAIRMAN KRESS:  No.
                       MR. LYMAN:  -- you need, but --
                       CHAIRMAN KRESS:  No, that's fine.
                       MR. LYMAN:  -- I can go through them
                       DR. TODREAS:  Don't worry because I did,
                       CHAIRMAN KRESS:  That's fine.  That's
           fine.  I think that's probably a good way to do it.
                       MR. LYMAN:  Are you going to go first?
                       DR. TODREAS:  No, no.  You spoke up first. 
           You get the floor.
                       PARTICIPANT:  Well, let me change these.
                       DR. TODREAS:  Well, let me go first since
           she's --
                       CHAIRMAN KRESS:  Well, since there's a
           palpable reason, we'll let --
                       DR. TODREAS:  She's got the order.  That's
           fine.  Just flip it up.
                       CHAIRMAN KRESS:  Why don't we go in the
           order of the agenda then?  How does it read?
                       PARTICIPANT:  That will help Jenny.
                       CHAIRMAN KRESS:  Yeah, it'll help her. 
           We'll do it that way.  We'll go in the order that the
           agenda has those listed.
                       DR. TODREAS:  I'm first.
                       CHAIRMAN KRESS:  Okay.  This is the second
           speaker then.
                       DR. TODREAS:  Okay.  Just go to the first
                       What I did since you want to constrict it,
           I picked out an area, which is basically fuels and
           materials, and actually the theme is somewhat similar
           to what you just mentioned.  I'm going to wind up
           getting back to the NRC is going to have to have a
           confirmatory research base and is going to have to
           have people who know the material, can deal with
           material, can ask the questions.
                       It's going to come from the fact, and I'm
           building on what I did this morning, that we're
           dealing with fuel cycles, and I'm talking about these
           Generation IV plants now.  I'm in the 2010 to 2030
           period.  I'm not talking about the near term
           deployment water plants based on the one through
           cycle, but I will get into the gas plant.
                       CHAIRMAN KRESS:  Who should do these
           research, Neil?
                       DR. TODREAS:  Well, obviously industry has
           got to do the research as a base, and then the NRC to
           a certain degree has got to do enough confirmatory
           research to insure that they've got a complete
           database for their education and to confirm to the
           level necessary.
                       We've been through, you know, a lot of
           that with the research program.
                       DR. POWERS:  But that's the rub, is
           knowing how much and when to do confirmatory research
           because, I mean, there's finite resources here, and
           there are constraints on the system.
                       DR. TODREAS:  What I'm telling you is to
           get on fuels and materials.  Make it a good part of
           the mix.
                       DR. POWERS:  We never had any materials
                       DR. TODREAS:  And what I heard Chuck --
           I'm glad that under number two here I mentioned
           coolants because we can get off into coolants, but
           we're going to go to longer cycles.  We're going to go
           to higher temperatures, and since I was limited to
           actually two to three challenges, I just stuck four
           down here as a -- this is kind of an outcome.
                       DR. POWERS:  That provokes the question: 
           is it because you're from MIT and can't read?
                       DR. TODREAS:  Can't count.  Yeah, that's
           the supermarket checkout joke, but I'm only going to
           talk about the two that are starred, but you know, if
           we go to nuclear power in a significant way, we're
           going to have to deal with waste volume, and we're
           going to have to reduce the toxicity.  
                       I'm not really talking about accelerator
           trends, mutation relative to toxicity going all the
           way, but you've got to start to think about somehow
           separating out certain isotopes and going more toward
           the French direction of a dedicated program on volume
           reduction and focused on toxicity.
                       We're also going to have to get into
           coolant corrosion aspects.  I never met formally Peter
           Ford, but I know through my colleagues he's really
           been into white water coolant corrosion issues, and
           these other coolants, no matter what we say about
           them, are going to have impurities in them.  We're
           going to learn things.  We're going to have to go
           through the whole coolant corrosion business.
                       But what I wanted to get to was three and
           four.  We're going to deal with new fuels, and the
           first new fuel effectively that we're dealing with is
           particle fuel, and particle fuel for me, I can see
           applications not just with gas reactors, but particle
           fuels in different matrices can be applied in broader
                       So I'm very positive on potential for
           particle fuel, but with core loads of billions of
           these particles, how are you going to deal with them?
                       Well, if you go to the next figure, the
           next figure shows my problem.  What I've got here is
           basically a sample list of questions that I drew up
           about a year and a half ago and have been talking from
                       The first list, these are the types of
           things I'd go into relative to particle fuel.  The
           first set of questions basically deal with the source
           term in terms of circulating, possible circulating
                       The second two sets of questions are
           focused on whether our fuel particle is going to be
           qualified by a product or a process specification, and
           I don't know the answer to that yet, but if it's a
           product specification, we've got to do a hell of a lot
           of work because we've got to identify those attributes
           and those combinations of attributes that have to be
           controlled to certain levels, and we have to do it
           relative to the fuel design that we're up to.
                       CHAIRMAN KRESS:  Are you just saying you
           can't know that the particle has been failed until
           after you stick it in the reactor and irradiate it so
           that you've got some signal that says you have failed
           particles.  Is that --
                       DR. TODREAS:  No, what I'm saying is it
           may be the same, but we're going to run a core filled
           with these particles, and we're going to say always
           that it can sustain a depressurization accident.
                       Well, what are the attributes and what's
           the tolerance around those attributes of particles
           that can be in the core that with burn-up that can
           sustain that transient?  Ask that question and see
           what answers you get.
                       That's what you're going to have to know
           to go on a product spec.
                       If you go on a process spec, then you've
           got to be sure that the fuel that you're going to put
           in that reactor has been thoroughly enough tested, and
           the fuel that has been put in the reactor, how it's
           been fabricated is the same process that the tests
           were all done on on the fuel.
                       So that imposes or requires quite a long
           test program.  So, say, on the pebble bed reactor,
           you're going to have to go back to that German fuel
           really to know what the process was and make sure you
           duplicate that process because presumably that's what
           the test base is on.
                       If you go to the third figure, I think
           we're moving toward a process spec, and if we do, what
           I see is we have replaced or at least made the fuel
           fabrication facility operator analogous to the current
           control room operator, and you're going to really have
           to have the fuel fabrication facility locked into the
           whole operation process, which is quite different than
           what we do now with the product spec on light water
           reactor fuel.
                       And also, if we go to a process spec, once
           we freeze the process it's going to be difficult to
           make changes, really costly to make changes, maybe not
           so difficult, because every time you deal with the
           process, you're going to have to go back and requalify
           the fuel.
                       CHAIRMAN KRESS:  This is somewhat
           analogous to the dilemma we face with digital INC
           controls where we don't determine the reliability of
           the product, but we control the process at which the
           software, for example, is put together.
                       DR. TODREAS:  And my anecdote here is I
           took the relevant people to Gillette about nine months
           ago.  Gillette has been making razor blades for 100
           years.  They make billions a year.  They do it through
           a process spec.
                       They wrote a paper about a year, year and
           a half ago.  They had a problem in one of the
           processes.  It was the washing process where they
           washed the blades before they put on a coating, which
           is the coating right on the tip of the blade that
           gives it hardness, the ability to cut.
                       And so they had a problem and they lost
           the process control.  They didn't know why.  It turned
           out the reason they did, being Boston, they left the
           soap out on the loading dock.  The temperature
           dropped.  They didn't know it froze.  They pulled it
           out, put it in the process, and the process didn't
                       So that's indicative of the real control
           and scope you've got to have if you've got a process
           control scheme.
                       The other point I want to make -- I see
           I'm running a little long, but the next slide.
                       If we go with this fuel, this long cycle,
           implicit with that is we're going to try to match the
           maintenance cycle with the operating cycle, and when
           we do that, we're going to really reexamine the
           maintenance approach, extend those aspects where we
           can after a good technical look.  If you can't extend
           the interval between maintenance, you try to do it on
           line, and if you can't do it on line, you try to
           change the practice by design and bringing in new
           component design, new systems.
                       And I've basically got an example of
           relief valve testing that we've developed associated
           with IRIS because IRIS would try to go to a long
           cycle, and relief valve testing, very difficult now to
           do it on line.  It's going to have to go through a
           code case, but we've come up with a relief valve
           system that I think could possibly do it.
                       But the point I wanted to make when you
           can finally come down to adjustments in the practice.
                       So finally, last slide.  Why are these
           items challenges?  And then I come back to the point
           that was made.  In the fuels and materials and coolant
           corrosion area, you're going to need to develop the
           NRC staff expertise.  Develop it, hold it.  The real
           strength of this place is that smart people can ask
           the right questions, and we really get off base if
           people don't ask the right questions in terms of
           getting technically focused on what's important, and
           you need this confirmatory research base.
                       And then finally, the last bullet at the
           bottom just goes back to what we talked about on this
           risk based regulatory framework, and I really look
           forward to NEI picking that ball up, leading, and
           giving us something relative to these new reactors
           because we're going to have new coolants, new systems,
           new fuels, and we're going to have to take advantage
           -- I look at that -- take advantage of the
           opportunities when we go to new systems to open this
                       But you guys are going to have to take the
           lead with a structure that goes through these guys and
           satisfies them and has a good dialogue.
                       CHAIRMAN KRESS:  Thank you.
                       Questions?  Comments?
                       DR. GARRICK:  One of the things that
           bothers me about these challenges is the resource
           base, the talent, because we are talking about fuels
           quite different from anything we have been dealing
           with.  We're talking about thermodynamic conditions
           quite different than anything we've been dealing with
           very seriously.
                       The government is not known for its
           ability to change people in and out efficiently and
           effectively, and yet the whole regulatory process is
           founded on technical expertise because it can't be
           automated, except up to a certain point.
                       So isn't that a real problem in coming to
           grips with these new technologies?
                       DR. TODREAS:  Well, that's why I raised
           it, because I'm hopeful that the ACRS will find
           reverberations through it, but I mean, that hasn't
           gone unrecognized at all in this building.  I'm just
           looking behind Graham Wallis and Ken Rogers is there. 
           When I was involved with the research oversight, that
           was one of the whole points that he raised, the
           competence or the requirement to maintain and enhance
           the competence of NRC.
                       I don't exactly know where it's gone over
           the last two or three years and whether it's a
           problem, but I know in fuels, fuels in particular, we
           got so much -- you know, we weren't pushing the burn-
           ups very much.  We had a fixed fuel system.  There
           weren't many issues in the research side.  The number
           of people really knowledgeable and working in fuels
           was reduced just because there wasn't a demand.
                       Now not only are we pushing light water
           reactor fuels up, but we're going to bring in SURMETS,
           METMETS, et cetera.
                       DR. POWERS:  Let me take a devil's
           advocate position on that and just reason a little bit
           from analogy.
                       DR. TODREAS:  Go ahead.
                       DR. POWERS:  When we look at reactivity
           excursion accidents in the current generation of
           plants, we typically find them to be a very localized
           phenomenon.  It's fairly challenging, in fact, to
           imagine any of the probable reactivity excursion
           events like a control rod ejection.
                       And when I say "probable," something
           greater than ten to the minus sixth, say, probability
           leading to a core-wide event that results in any
           public hazard.
                       When I look at these modern reactors,
           maybe there are more adventurous things, but by and
           large, I would say reactivity events are going to be
           relatively small sorts of things compared to loss of
           coolant, loss of heat sync accident.
                       I guess I'm asking the question:  why
           should we get involved in fuel?  Why don't we just let
           that be the licensee's problem?  He's the one that's
           got to take care of his work force.  He's the one
           that's got to take care of this plant and his fuel and

           really draw our boundary and say what we're really
           interested in is fission product release that goes
           outside the plant.
                       DR. TODREAS:  Yeah, but don't just start
           off with reactivity accidents.  Start off with
           operational reactor behavior and failed fuel and --
                       DR. POWERS:  Let that be his problem. 
           Coolant activities, start-up problems, things like
           that, it doesn't impact the public health and safety. 
           So let him worry about that for his purposes.
                       DR. TODREAS:  Okay.  The only answer to
           that when you come back, that is his problem. 
           Fundamentally the licensee is responsible.  He's
           responsible for everything, but if you've got a
           regulatory agency or you're got a development agency
           in DOE, the best regulator and the best developer in
           DOE is a smart customer because they don't waste your
           time on putting you on the wrong questions, and they
           don't waste dollars going out and developing the wrong
                       So it's just a question that I have the
           belief that government ought to have the best people
           they can, and they need competence to interact with
           the guy who owns the problem.
                       DR. APOSTOLAKIS:  I also think, Dana, as
           you know very well, if we start regulating that way,
           we're not satisfying or meeting the fourth pillar that
           Rich Barrett mentioned, public confidence.  If you
           start having incidents that affect the core but do not
           end up releasing anything, I don't think the public is
           going to trust us very much, and that's why you have
           the cornerstones in the oversight process that include
           initiating events.
                       I mean you can argue there it's none of
           our business as long as there is no core damage or as
           long as there is no release, it's not our business,
           and yet the agency says, no, it is our business.
                       DR. POWERS:  And what I'm saying is why. 
           You're saying it's a public confidence issue?
                       DR. APOSTOLAKIS:  Yeah, it's a public
           confidence issue.
                       CHAIRMAN KRESS:  I would think there's a
           strong reason than that.
                       DR. APOSTOLAKIS:  I don't think it's weak.
                       CHAIRMAN KRESS:  I would think there's a
           stronger reason than that, Dana, and that is you want
           to -- one of the principal performance indicators, for
           example, is that you want them to be something that
           tells you that things are wrong, but they're not
           approaching a catastrophic condition yet, and then
           similarly, if you put the regulations here, you want
           to regulate to a level that, for example,
           radioactivity in the primary system, if it's a gas
                       You want to say, okay, this is indicative
           of some level of failed fuel, and even though if I
           release that, it may not hurt the public, but I'm not
           sure that if I ever undergo an depressurization
           accident it may not have something equivalent to the
           iodine spike, and it may be too much.  Maybe I should
           regulate to some level that's short of hurting the
           public if it gets release.
                       That would be my --
                       DR. POWERS:  I mean, I can -- all right. 
           Suppose you came along and said, "Okay.  You run your
           -- just make sure you coolant level is such that you
           never come within ten percent of the 10 CFR 100
                       CHAIRMAN KRESS:  I would buy that if they
           also included some factor of safety to take care of
           the spike like concept.
                       DR. POWERS:  The fact of the matter is
           we've never found any relationship between coolant
           activity and risk to the public health and safety.
                       CHAIRMAN KRESS:  But you might if you
           didn't have a containment.
                       PARTICIPANT:  Exactly.
                       DR. POWERS:  We'll always have a
                       CHAIRMAN KRESS:  Oh, okay.
                       DR. POWERS:  Remember Moses with the 11th
                       CHAIRMAN KRESS:  Yeah.
                       DR. APOSTOLAKIS:  This is not a Committee
           position.  This is a personal view.
                       MR. HOCKRITTER:  I was going to ask Neil
           something, but let me just also respond to Dana.
                       I was going to say the same thing.  Some
           of these designs are looking at not having a
           containment, and then I think you have issues.
                       Today in the light water area, really
           failed fuel is a utility or an operator concern, and
           it's a vendor concern, and you're very, very careful
           about it because obviously if you want to sell fuel,
           you don't want it to fail.  So it's a problem that
           solves itself.
                       But you've got a containment around the
           plant.  In some of these designs you don't have a
           containment, and I think it could be more of a
                       DR. POWERS:  Made an awful good argument
           for having a containment, didn't you?
                       MR. HOCKRITTER:  Back to Neil, on your
           process control, are you envisioning a control process
           where you can try to control each, on these particles,
           each layer in this thickness within a specified amount
           or the total product as it comes out?
                       Because I don't see how you control each
           layer, and if you control on the total product that
           comes out, if it doesn't come out right, and you won't
           find that out probably until you operate, then you've
           got a problem.
                       DR. TODREAS:  Okay.  First, let me answer
           I'm not promoting either a process or a product.  What
           I am doing is asking whether it is going to be a
           process or a product, and then developing a line of
           questioning along each.
                       MR. HOCKRITTER:  Either way.
                       DR. TODREAS:  However, now, in addition
           though the way you ask the words, a process spec means
           that you control the process of every manufacturing
           step.  So you may have a process where you're doing
           the coating, but you don't go and measure the coating
           or sample the coating.  What you do is you control the
           attributes of the fabrication process.
                       MR. HOCKRITTER:  Well, how do you know you
           meet your criteria if you don't go and measure?
                       DR. TODREAS:  No, no, because what you do
           in the qualification stage, you take the product that
           comes out; you put it in the reactor; and you'd better
           make damn well sure it can take the burn-up with a
           failure criteria over whatever your design length is.
                       MR. HOCKRITTER:  Yeah, but at some point
           you're going to have to have gone through and verified
           that whatever your process is gave you the product
           that you wanted.
                       DR. TODREAS:  Absolutely.
                       DR. APOSTOLAKIS:  There is indication or
           evidence that the process is working well.  That's
           different from having a product based method for
                       And it's the same thing with software as
           Tom said.  I mean we are largely controlling the
           process now, but then we know if we're going to put it
           there in the field and it starts failing that
           something was wrong with the process.
                       DR. TODREAS:  Larry, there's a tremendous
           amount of radiation data on this particle fuel.  If
           you can pin down the process that it was made to and
           link it to the data, then you can say you identified
           the process, and then you can basically duplicate it
           and keep going.  That's the burden the applicant is
           going to have.
                       DR. APOSTOLAKIS:  Yeah, I agree with you
           it's late, but it's not a matter of choice really,
           process versus product.  You're forced to go to the
           process because you don't have the tools to do the
           other one.  So it's -- you know.
                       DR. TODREAS:  Why do you say you don't
           have the tools?
                       DR. APOSTOLAKIS:  Well, take INC, for
           example.  They know a little better than fuels.  Right
           now nobody knows what kinds of tests you should do to
           a new digital system to assure that they will perform
           out there.  So it's a combination of controlling the
           process of producing the software, and of course, you 
           do some tests, as well.  But this envelope --
                       DR. TODREAS:  Okay.  I might not be
           surprised if an applicant comes in and says, "I know
           what the thickness of the various layers have got to
           be within a certain spec.  I know what the impurity
           levels are that need to be controlled."
                       You may be a case on fuel that way.
                       PARTICIPANT:  You're going to need that to
           get an analysis.  You're going to need that
           information to do the analysis.
                       DR. TODREAS:  What was asked for is the
                       DR. APOSTOLAKIS:  Right, right.
                       DR. TODREAS:  Okay?  That area is --
                       DR. APOSTOLAKIS:  It is certainly a
                       CHAIRMAN KRESS:  Okay.  With that, let's
           move on to the next speaker, which according to the
           list here would be Mr. Lyman.  Are you prepared or are
           you over there tying your shoe or what?
                       MR. LYMAN:  No, I was looking for more
           evidence to demonstrate the previous discussion.
                       CHAIRMAN KRESS:  You're welcome to go
           ahead and look.
                       MR. LYMAN:  No, that's okay.
                       DR. POWERS:  I'll pull out.  I see you
           guys can't see directly.
                       CHAIRMAN KRESS:  Okay.
                       MR. LYMAN:  Actually, like Bill Magwood
           yesterday, I'm not quite sure what's in these
           viewgraphs, but unlike him, I did write them myself.
                       MR. LYMAN:  I think it's interesting that
           the fuel issue has come up because I definitely had
           that on my list as one of the challenges, and I'll go
           into that in more detail.
                       Can I have the next slide, please?
                       I think the overarching context, I'm the
           first member of the public and not the industry or DOE
           or NSC to address this workshop.  So I am going to
           speak generally as a member of the public.
                       I see the fundamental dilemma of nuclear
           power expansion right now is that without massive
           subsidy, there are not going to be any nuclear plants
           built unless they can really compete with cheaper
           fossil fuel sources, and that means perhaps mimicking
           these characteristics like low capital costs, short
           construction time, modularities of distribution that
           we've all heard about, and the question is:  are these
           really appropriate criteria for nuclear power plants
           or is there something fundamental about nuclear
           technology which will make that difficult?
                       Can I have the next slide, please?
                       DR. POWERS:  Well, let me go into just a
           question of philosophy a little bit with you here. 
           Since, I guess, some time in the early '50s, the
           government has felt some sense that it should foster
           a peaceful use of atomic power, and is there any
           reason that that general government feeling should be
           viewed as having changed?
                       MR. LYMAN:  Well, in my view there's been
           enormous public support of nuclear technology here and
           all over the world since the dawn of the Nuclear Age. 
           I forget what the exact figure is, but it's certainly
           in the -- if you include fusion, it's in the hundreds
           of billions of dollars at least.
                       And the question is maybe it's time for
           the government to stop weaning nuclear power and let
           it go out on its own and see if it can compete.DR.
           POWERS:  Well, I mean, that's a decision we leave to
           the politicians to make.  I guess I'm asking have they
           made that decision.
                       MR. LYMAN:  Well, if you look at the Bush
           policy, you'd have to say no sine it seems to suggest
           rekindling a large domestic nuclear research program
           and does make reference to technologies which right
           now are uneconomic likely processing or accelerated
           transmutation, which would require large government
           subsidy to actually complete R&D development of this
                       So if you take that policy on its face,
           there may be a change at least in the administration's
           thinking.  I'm not sure they appreciated that when
           they put out the document because I understand they
           were stung by some of the criticism by conservative
           think tanks of what looked like an endorsement of
           government picking winners and losers.
                       CHAIRMAN KRESS:  That's a sign, I think,
           of a low battery in there.  Have you guys got it? 
                       Pardon me for interrupting you.
                       DR. POWERS:  Okay.  I mean, so right now
           the inherent assumption in your first bullet is not
           necessarily one that has to be made.
                       MR. LYMAN:  Well, I'm saying in the
           absence of a policy decision that the public and
           taxpayers do not support subsidization of construction 
           in nuclear power plants, then the rest follows.  If
           they are, and if that's a decision in the public, then
           it's a different ball game.
                       DR. GARRICK:  Would you accept as a
           substitute for those three items, low capital cost,
           short constructions time, modularity, and ease of
           distribution low power costs?  I mean, why would you
           pick on a component of something that's much more
                       MR. LYMAN:  Well, because these are the
           features as distinguished from going to larger and
           larger reactors, which is the other way to reduce
           power costs through economies of scale.
                       At least some of the feeling as a member
           of the public reading literature, that there is this
           feeling in the nuclear industry that by imitating
           these characteristics, that is the best way to benefit
           from the favorable economics of gas turbines.
                       There's no more market for large, you
           know, very large base load plants, and especially if
           you consider the export market to less developed areas
           of the world.
                       You know, this isn't my own conclusion,
           but this is what I've heard.  If you can come up with
           another way of doing it, cutting costs, fine, and we
           just heard the gentleman from Westinghouse emphasizing
           reduction of capital costs and payback time is so
                       DR. GARRICK:  Yeah.  Well, I think the
           alternative is power cost because I think that's what
           the public wants.
                       DR. POWERS:  Well, I think you've got an
           inherent schizophrenia here on the arguments.  You've
           got arguments that get advanced to us that say, "My
           God, there's a crisis.  We're going to need tens of
           thousands of additional kilowatts," and at the same
           time we've got to keep the costs very low.
                       The two don't match.  There's a crisis. 
           We'll pay what it takes to get the kilowatts.
                       DR. APOSTOLAKIS:  But the subject of the
           workshop is regulatory challenges, not national policy
           regarding nuclear power.  So perhaps we can -- if we
           want to finish tonight.
                       MR. LYMAN:  But there is a link actually
           because part of the new driver for accelerated
           licensing new plant designs is this perceived crisis. 
           So they're really linked, and one of my concerns as a
           member of the public is that there's going to be
           momentum toward expediting, streamlining, licensing of
           nuclear plants without the kind of deliberation that
           I think was probably necessary for the previous
                       Can I have the next slide?
                       So the challenge is given these advanced
           designs that have the features that I described on the
           previous page, how do you maintain issues like without
           having a negative impact on safety, on risk of
           radiological sabotage on waste management, on
           nonproliferation, and on opportunity for public
           participation.  So these are some of the top level
           challenges, and I talk about a few of them.
                       Next slide, please.
                       Okay.  So the example  I'll fix on is a
           PBMR, not because I want to pick on it necessarily,
           but it is what's coming down the pike, and there's
           more detailed information about the approach that
           developers want to take.
                       DR. APOSTOLAKIS:  I think you're going to
           be more comfortable with this, Lyman.
                       MR. LYMAN:  Right.
                       DR. APOSTOLAKIS:  Where you don't have to
           come back and forth.
                       MR. LYMAN:  But I want to see you, too.
                       DR. APOSTOLAKIS:  Oh, okay.
                       MR. LYMAN:  So the PBMR, you know, we've
           heard a lot about it.  So it's something everyone
           understands, but there are fundamental characteristics
           which are at odds with conventional balances, defense
           in depth elements like the lack of a pressure
           containment, significant reduction and safety related
           SSCs, a proposed reduction in the emergency planning
           zone radius by a factor of 40, and a greatly increased
           reliance on fuel integrity to compensate for mitigated
           measures to protect public health.
                       And going back, this is not a new reactor
           and neither are any of these issues, and in fact,
           neither is the discussion because you go back to the
           mid and late '80s, you find the ACRS has already
           commented extensively, and I think they wisely stated
           in 1988 that it would require unusually persuasive
           arguments to justify what they characterized as a
           major safety tradeoff.
                       In other words, emphasis on preventive
           rather than mitigative measures.
                       Next slide, please.
                       And so with the PBMR, I agree with
           Professor Todreas that fuel performance is the big
           challenge, and when I started looking at the data
           after hearing the pitches made by the PBMR promoters
           about how this is meltdown proof fuel, how it's
           indestructible, how you have to heat it to 2,200
           degrees Celsius to get the fuel to melt, well, it
           turns out, of course, that the data that's been
           accumulated is a lot spottier than that, a lot less
           definitive, and the first interesting thing about the
           data for pebble bed fuels, they really don't
           understand its performance in relation to changes in
           the initial conditions.
                       And until that understanding is acquired,
           it's going to be very hard to implement the kind of
           process or product controls that we just heard about
           with confidence.
                       Also, the robustness of this fuel is being
           widely oversold right now, and you do not have to get
           to the temperature where there's fuel degradation to
           have significant fission product diffusion through the
           silicone carbide barrier.
                       And could we have the first, the one with
           just one graph on it?  Thanks.
                       Okay.  So I started looking at the data,
           and this is not the kind of pretty picture we saw
           yesterday, and like someone just told me, anyone who
           knows anything about pebble bed or gas cold reactor
           fuel is aware of this data, but how come we didn't see
           it in the last two days?
                       So I'm going to show it to you.  This is
           a summary of German data.  Sorry it's so out of focus. 
           This is actual fission product of Cesium 137 release
           from TRISO, from actual graphite pebbles with TRISO
           fuel in them, and there are a variety of different
           burn-ups here, but it gives you the flavor.
                       This band is 1,600 degrees.  This is
           release fraction versus heating time, and you can't
           really read it, but the upper band is 1,800 degrees,
           and you see that you get into quantitative cesium
           release on the order of several to ten percent after
           50 to 100 hours of heating time at 1,800 degrees.
                       Can we have the next slide, please?  The
           next graph.
                       And this is substantiated by recent
           Japanese data.  This is from a journal last year. 
           Also TRISO fuel irradiating the Japanese gas cooled
           reactor, and you see you have the same behavior
           roughly after 50, 75 hours of heating time.  You get
           a rapid increase in fractional release of cesium up
           until about ten percent, and this is 1,700 degrees. 
           That's 1,800.  You see you go almost to 100 percent on
           silver.  You go beyond ten percent at 1,800.
                       Can we have the next -- actually the
           previous computer slide, please, no, the Power Point
                       Okay.  So, you know, here's the gritty
           reality about pebble bed fuel, is that the margin to
           significant cesium release is not nearly as great as
           it is to massive fuel degradation.  So I'd like to
           hear less about how the fuel is meltdown proof and
           more about how the cesium releases are going to be
           mitigated in the event of, let's say, a 100 degree
           over shoot in the predicated maximum temperature after
                       Now, so clearly quality control is
           paramount since we're being told that the fuel is the
           containment in this case, and that raises the issues
           about British Nuclear Fuels involvement as one of the
           designers of the South African -- of the SCOM pebble
           bed fuel manufacturing facility.
                       And just for a little background, BNFL
           almost single handedly killed the Japanese nuclear
           industry by exporting mixed oxide fuel to Japan that
           had fabricated quality control data, and the reason
           why the quality control data was fabricated was
           because the people who were working on the production
           line got so bored with doing manual checks on this
           fuel they decided they're rather just copy sheets of
           data, you know, whole bore.
                       And i think it affects the credibility of
           BNFL, as well as raises general issues about how
           reliable, how much emphasis you can put on fuel
           reliability and quality control in affirming reactor
           safety, and that's why I would throw out that the
           fabrication plant really is part of the reactor system
           and, therefore, there's going to have to be greater
           involvement in fuel fabrication by NRC even if it's
           done overseas, I think, than is customarily the case,
           according to Appendix B criteria.
                       And so I'd suggest that there has to be an
           ITAAC on quality assurance for fuel manufacture in
           this case, a programmatic ITAAC.
                       Next slide, please.
                       MR. SIEBER:  Maybe I could interrupt.  The
           first graph that you put up, could you tell me where
           it came from?
                       MR. LYMAN:  Yeah.
                       MR. SIEBER:  I want to read the whole
                       MR. LYMAN:  From the reference that's in
           IEA Tech. Doc. on fuel, pebble bed or gas cooled
           reactor performance, and I don't think I have the
           number with me, but I'll get it to you afterwards. 
           It's within the last three years or so.
                       MR. SIEBER:  Okay.
                       MR. LYMAN:  It may be 978, but I'll have
           to check.
                       Okay.  So --
                       DR. POWERS:  I think I can find it for
           you, Jack.
                       MR. SIEBER:  Thank you.
                       MR. LYMAN:  Now, on the issue of safety
           goals, which we've heard something about, I think that
           the safety goals do need to be reexamined  for
           advanced reactors, and I don't think the current goals
           are conservative enough.
                       And a little thought experiment is that if
           you actually remove the containments from most light
           water reactors operating today, would they still meet
           the safety goals?  I think at least according to the
           existing calculations, they would, and that's because
           anyone in the industry will tell you they were already
           a factor of ten or more below the safety goals in
           existing plants.
                       And since containment performance is
           predicated on a ten percent -- less than ten percent
           conditional containment filler probability, I think
           this is an example of why the existing safety goals
           should not be the target for advanced plants.
                       We also need to define --
                       DR. APOSTOLAKIS:  Excuse me.  I think this
           is going to be challenged a little bit.  You are
           evaluating the usefulness of the goals by going
           through the plant and say, "Well, gee, the plant is
           really much better than the goal.  Therefore, the goal
           is not conservative enough."
                       I can pick the other line and say, "Well,
           gee, the goal will be set independently of the plant
           by using some societal measure.  So one tenth of one
           percent of other risks, I don't know that that's not
                       MR. LYMAN:  I agree, but I'm not sure
           that's the history of the development of those goals. 
           I mean, it is kind of convenient that they were chosen
           at a level where the fleet of plants does meet them 
           with a large margin.  Maybe it's just a suspicion, but
           you know, that number was picked out of a hat as far
           as I can tell.
                       Okay, but fair enough.
                       DR. WALLIS:  But you could remove the
           statement "not conservative enough."  It might still
           be valid to say that the goals could be met with
           containments removed, if that's a true statement.
                       That's an interesting statement to make.
                       MR. LYMAN:  Well, if that is true, it
           makes one think.  I'm not, of course, recommending
                       DR. APOSTOLAKIS:  That was my next
                       MR. LYMAN:  No, I'm not recommending it. 
           I'm just wondering if the existing safety goals do
           capture what needs to be captured in the public
           concept of reactor safety.
                       And in the industry in the West, it really
           dug its own hole in this regard.  After Chernobyl, the
           chief response from the Western nuclear industry is
           that can't happen here because our plants have
                       So you have to think a little bit about
           how the public response is going to be when you try to
           introduce graphite moderated reactors in the
           containments in this country.
                       One issue is what do you do with the
           concept of a large early release, especially if you
           have a reduced evacuation zone.  I think you need to
           think in terms of a large release in the case of the
           pebble bed.  Since there's going to be a large number
           of people who no longer have instructions to evacuate,
           and given the type of cesium releases that I think the
           fuel is capable of, this is something that also I'd
           like to think about.
                       CHAIRMAN KRESS:  If you're not going to
           have evaluation, the E ought to go out of the ERF.
                       MR. LYMAN:  Right.  There's no meaning to
           "early" anymore.
                       CHAIRMAN KRESS:  Yeah.
                       MR. LYMAN:  And since a lot of these
           released don't occur until 50 hours into the accident,
           then, you know, that also has to be figured into it.
                       And so one issue, you know, is is it going
           to be necessary to add additional requirements to the
           pebble bed to make it safe enough, and the IEA pointed
           out or it was actually an IEA document where I saw the
           statement that if a whole lot of additional
           requirements had to be imposed, it would really
           threaten its economic viability.
                       Yet there are some characteristics we're
           thinking about.  One is the fact that there is no
           secondary coolant loop in the SCOM design.  Yet the
           MIT design proposed by Kadak does have one for the
           reason that it reduces the risk of water ingress.
                       So the SCOM design isn't the last word in
           the pebble bed, and there has been discussion
           apparently in the literature about coatings which are
           better or more refractory in silicon carbide than
           zirconium carbide, and maybe the whole issue of
           whether the fuel, the traditional TRISO fuel is
                       These all have to be opened up, and I
           don't think in the schedule that's been laid out
           there's going to be enough time to do that.
                       Next slide, please.
                       My next major concern is the issue of
           radiological sabotage, which I think could be a show
           stopper for certain features of advanced plants that
           have been suggested.
                       Just to beat a dead horse, 50 percent of
           U.S. nuclear plants today have failed their OSRE
           exercises, meaning that mock terrorists can simulate
           enough damage to cause the core in a force/unforce
           simulated attack.
                       Exelon's Quad Cities was an example of a
           failure in early 2000.  To quote from the inspection
           report, deficiencies in the licensee's protective
           strategy enabled the mock adversaries to challenge the
           ability to maintain core cooling containment.
                       So I'd like to see Exelon concentrate a
           little more on defending their existing fleet of
           plants before starting to site new ones.
                       Next slide, please.
                       And the basic point here is that no matter
           how inherently safe a plant is from accidents, there's
           always going to be a scenario, I believe, that someone
           clever enough can cause fuel damage, and this was
           touched on actually in this morning's discussion.
                       And that means to me that you're not going
           to be able to justify drastic reductions in the
           security force requirements for pebble beds, and also
           that the issue of additional defense in depth measures
           like containment may be warranted for that reason even
           if probabilistically they're not warranted from an
           accident standpoint.
                       And, third, plants that have in situ
           reprocessing modules like the PRISM we heard about are
           going to be unusually attractive because you already
           have fuel that's in process in a disbursable form.
                       It turns out that the very wise ACRS in
           1988 recommended that sabotage resistance be a design
           feature, general design requirement for advanced
           plants, and I don't think I see that in the current
           generation that's been proposed.  In needs to be
           thought about, and there needs to be involvement now
           with the NRC safeguard staff in trying to challenge
           the pebble bed from the point of view of sabotage.
                       Next slide, please.
                       Waste disposal is the third challenge. 
           Obviously the issue of waste disposal is going to be
           a driver in whether we can sustain an expansion
           nuclear power in this country, and the other issue
           that the pebble bed people don't like to talk about is
           their waste.  And rather than minimize waste as was
           one of the Generation IV requirements, the pebble bed
           generates a volume of waste, ten times as much,
           something I verified myself by calculation, meaning
           that storage and transport requirements per kilowatt
           hour generated are going to be ten times greater, and
           you'll need ten times as many packages in a repository
           if you ever get to that point.
                       Thinking about the problems that are
           already going to be encountered in transport, it seems
           that ten times as many shipments from the same amount
           of electricity might raise a red flag.
                       The other issue is Carbon 14, specially in
           the context of the repository.  You're going to get
           quite a lot more Carbon 14 in a gas cooled reactor
           design, and because of gaseous emissions, the gaseous
           emission issue in an unsaturated repository, that
           could be a dose problem.
                       Next slide, please.
                       So just from a public acceptance
           standpoint, getting back to my original point, I think
           that a better approach for new plants, if the industry
           really wants public acceptance, is not to try to cut
           margin where it can, even if it claims it has a safer
                       The goal should be to increase safety, the
           next step, and that would in my mind suggest a limited
           number of sites that are well protected rather than
           small scale reactors which are widely disbursed, and
           might require gold plating instead of trying to shave
           margin where you can find it, and that approach would
           be inconsistent with these performance based
           tendencies that we've heard about earlier today.
                       Next slide, please.
                       And the aggressive licensing schedules
           that have been proposed, I think, are also going to
           aggravate and generate public opposition, and it's
           really better to proceed cautiously to make sure
           there's full resolution instead of trying to expedite
           and streamline.
                       That's all.  Thanks.
                       CHAIRMAN KRESS:  Questions or comments?
                       MR. SIEBER:  Do we have copies of these
                       DR. POWERS:  Did you want to say anything
           about resistance in connection with the PBMR?
                       MR. LYMAN:  Well, there are two issues. 
           One is the fact that it's on line fuel, which I think
           will increase the safeguards' inspection requirements. 
           Of course, it's not an issue in the U.S. since we
           don't -- you know, we have voluntary safeguards at
           nuclear plants, but overseas it could be a problem.
                       It's going to take more work to inspect,
           you  know, system discharges.  What is it?  Tens of
           thousands of balls a year, I think, or more as opposed
           to a system where you only have to be present, an
           inspector only has to be present once every year and
           a half or two years to observe core loading.
                       Now, the tradeoff is that the fuel is
           quite dilute.  It would take a lot of it, as we heard
           this morning, to divert a significant quantity of
                       But, on the other hand, if you have a
           large utility that operates a large number of these
           plants, if let's say there were some malevolent desire
           on the part of the operating company to divert small
           numbers of fuel from each one of these modules, then
           you could have protracted diversion as an issue.
                       So the safeguards requirements are really
           going to require some evaluation.
                       DR. GARRICK:  There is one part of your
           message that I like very much, and I think the NRC is
           quite sensitive to it, and that is that the industry
           has to be very cautious about overselling the PBMR,
           for example.  That kind of activity has been a result
           in the past and has been an example of the industry
           shooting itself in the foot.
                       And I would agree that there seems to be
           a wave of confidence and enthusiasm towards the
           concept that from a scientific and technical
           standpoint certainly has not been demonstrated on any
           kind of systematic, evidentiary basis at least yet.
                       So I think that's a good comment.
                       DR. TODREAS:  Can I make just two comments
           on things that you mentioned?  
                       I was not here yesterday and, therefore,
           don't know exactly what you've heard, but my
           understanding on two points is the following.
                       On the secondary system difference, my
           understanding is that Kadak has gone to the secondary
           system because of development times and requirements
           on the helium power cycle.  He has not gone there
           because of a feeling that water ingress is a problem
           that can't be beat on a direct cycle.
                       So I would suggest you discuss that
           further with him on that.
                       And, second, on the depressurization
           transient and the temperature that the fuel is allowed
           to go to, I thought 1,800 or even less was the maximum
           limit that it had always been designed to.  
                       I got the implication from what you put up
           that the target was up at 2,000 or so.
                       MR. LYMAN:  No.  I mean, I don't know what
           the target actually is, what the number that's used,
           you know.  When Exelon or whoever is presenting this
           data to the public, they use the figure 2,000.  It
           appears in a whole lot of literature, and so that
           gives the impression that there's a bigger margin than
           there may actually be to fission product release.
                       That's my only point.
                       DR. TODREAS:  If the number 2000 is being
           used, but the design calculations and the criteria
           from analysis on the depressurization, at least in the
           context I'm familiar with, has always been lower than
           that.  Eighteen hundred may be a little bit lower, but
           since I don't remember exactly, I don't want to say
                       MR. HOCKRITTER:  I was going to say I
           think it's around 1,600 C.
                       DR. TODREAS:  Yeah, okay.  I've got 1,600
           to 1,800.  I wasn't sure of the exact number.
                       MR. SIEBER:  He said 1,600.
                       DR. TODREAS:  But the point is that number
           encompasses some awareness of -- I think a great deal
           of awareness -- of the data that you show.  So I think
           you might take some comfort and actually talk to the
           analysts about that.
                       MR. LYMAN:  But, you know, one needs to
           see what the uncertainty is in these calculations and
           what the actual error bars are and the maximum
           temperature.  What are the factors that could
           conceivably cause the final temperature to be
                       You know, that's the kind of systematic
           thing that hasn't been presented to the public yet,
           and my concern is, you know, the numerous articles,
           and there's an enormous amount of press interest in
           this reactor, but the claim is it's meltdown proof no
           matter what happens to it.  You can't get
           radioactivity out of it, so you don't need a
           containment, et cetera.
                       And I think that kind of talk  is
                       DR. WALLIS:  I think there ought to be
           more reassuring.  If Exelon had presented the kind of
           curves that you presented and the worst curve which
           they presented was one which was not on a log scale;
           so everything sort of disappeared down to the
           reactors, then appeared to come up at 2,000.
                       That doesn't tell you anything about this
           kind of stuff that you presented.
                       MR. LYMAN:  Right.
                       DR. WALLIS:  So it may well be that the
           scheme is all right.  It's just that it will be more
           convincing to the technical community.  They presented
           this stuff, and we didn't have to hear it from you,
           and I think that's a good point.
                       CHAIRMAN KRESS:  All right.  Why don't we
           move on to the next speaker, which according to my
           list is you, Ron Simard.  You're welcome to make any
           sort of presentation that you wish.
                       MR. SIMARD:  No slides.  Just a comment.
                       My focus would be on the near term
           challenges facing NRC, and I go back to my
           presentation of this morning, but I would very
           strongly endorse what Rich Barrett said.
                       I think we need to keep in mind this fact
           that the credibility of the regulator and the process
           is essential to the industry to be able to meet our
           objectives.  So I would roger everything that Rich
           said -- Roger Rich -- I would roger, Rich, everything
           that you said.
                       With respect to the need for a tangible
           and clear demonstration of safety, involvement of the
           public, I would certainly pick up on your suggestion
           that we do need this early resolution of some of the
           open issues because as I said this morning, the
           potential licensees of the future are looking for much
           more certainty and knowledge of the licensing costs
           and schedules than they've had in the past.
                       And certainly I would roger his points on
           efficiency.  With respect to the work force, one of
           the things that we're doing in terms of trying to
           assure that we have the work force we need for the
           future is we're working with this group of young
           professionals now called Young Generation North
           America, and the definition of young in this case is
           35 years old.
                       And as Rich was talking about the
           importance of the work force to the NRC, I looked
           around the room at some of the NRC staff in the room,
           and I wouldn't ask for a show of hands, but look
           around and you guess how many of the NRC staff in this
           room would be eligible to join the Young Generation.
                       So I would certainly agree that there is
           a challenge to the NRC in terms of maintaining not
           only the number of people, but the level of skills. 
           I think Dr. Garrick mentioned the level of skills and
           so forth, but I think one of the points I see us keep
           returning to in the last couple of days is the
           importance of this risk informed approach to meeting
           some of these objectives that we've been talking
           about, for example, being able to demonstrate to the
           public what is significant in terms of safety and
           being able to assure the NRC, the licensees and the
           public that we are, in fact, focusing our attention on
           what is significant.
                       We've heard a lot of discussion about the
           need to draw even more on some of the successes we've
           had so far in implementing this risk informed approach
           and being able to take advantage of the new insights
           we've gained.
                       But I would suggest that maybe one of the
           biggest challenges of all is the culture change that
           the NRC is going to have to implement to be able to
           get acceptance of that across the agency at the levels
           that are going to be needed to handle the licensing
           challenges in the near future.
                       And that comes from the top.  That
           requires leadership.
                       CHAIRMAN KRESS:  Why don't we move on to
           Ms. Hauter?  You're the anchor today.
                       MS. HAUTER:  Well, I always enjoy coming
           to the NRC to meetings because I never have to wait in
           the ladies room.
                       MS. HAUTER:  And I hope that I'm not going
           to add to any gender stereotyping, but I don't have a
           Power Point presentation, and I didn't get the
           questions beforehand.  I've based my comments on what
           I've heard at this meeting.
                       And I don't think that I would have used
           a Power Point presentation anyway because I think it's
           my role as coming from public citizen to speak plainly
           as a member of the public.
                       So even if you don't like what I have to
           say, I promise there will be no techno. talk, no
           incomprehensible jargon, and no indecipherable
                       PARTICIPANT:  Thank you.
                       MS. HAUTER:  We've heard a very rosy
           picture painted this morning.  I think that it was Ron
           who talked about the poll in California, that public
           now supports nuclear power, and I'd like to say that
           we've done a lot of polling, been involved in a lot of
           polling through the years, and that the public always
           supports renewable energy and energy efficiency first,
           and that that is a very deep support.
                       And in fact, the Post had an article today
           showing that President Bush is losing support, and
           that 58 percent of the American public now disapprove
           of his energy plan.
                       So I think that when the numbers of
           nuclear power plants go in two days from 200 to 1,000,
           that that's your biggest challenge, is when you're
           talking about these large numbers, and you have almost
           no public participation in a meeting like this, that
           our telephone is beginning to ring off the hook, and
           you're helping us mobilize a new anti-nuclear
                       So, you know, I would consider that in
           these kind of large promises that are being made.
                       Now, I think that we all know that through
           the years, that the cooperation of the industry and
           the agency has led to a weakening of the democratic
           process both of licensing and siting new plants, and
           I suspect that people in the room feel that that will
           certainly help this new generation of plants, but I
           think the biggest challenge is going to be about some
           of the issues that Ed spoke of, especially the issues
           of subsidies.
                       As I sat here throughout this meeting, I
           heard a lot of words that really mean taxpayer money. 
           Let's see.  We heard cost sharing, government R&D,
           talk about the Price-Anderson Act or even the license
           by test with the government picking up the cost for
           the test facility and the liability.
                       And you have to have political support to
           get that kind of level of subsidies, especially for
           the number of years that you're talking about, and I
           think that it's a real problem when at the same time
           we hear an analysis of the electric industry in 24
           states have deregulated and we hear that we've now
           moved into this deregulated, competitive marketplace,
           and we could argue about whether that is true or not,
           and I would say that it's not true, but that is
           certainly what the public is hearing.
                       And we also know that the reason that
           nuclear power is so cheap now in these deregulated
           markets is that O&M is cheap because of the huge bail-
           out that's occurred at the nuclear industry, over $200
           million for all of the stranded costs, and so
           basically the mortgage has been taken care of, and
           that's why the issue of capital cost is so very, very
                       But this puts you in a very vulnerable
           position because, on the one hand, people are talking
           about this competitive market, and on the other hand,
           this plan that you've laid out is going to take
           massive subsidies, and we're going to see a fight over
           the reauthorization of Price-Anderson.
                       Now, I recently had a very interesting
           speaking engagement, and I probably won't be asked
           back to speak at this for a number of these gatherings
           either.  It was the Institute for Infrastructure
           Finance, and I'd never heard of this organization.  I
           had to look it up on the Internet.
                       It's a group of, an association of the
           financial institutions that build power plants and
           water projects and so forth.  And I sat through two
           days of this meeting.  In the last session I debated
           somebody from Cato about energy policy.
                       The whole tone of the meeting was getting
           the public to accept paying higher power costs, but
           these investors expect to get a 35 percent rate of
           return on profit after just a couple of years of
           investment.  They're going to get in and get out
           quickly.  I mean it was enormous profits that they
           were talking about.
                       And I asked a number of the bankers and
           investment institution representatives there in
           conversations and publicly whether they were going to
           invest in nuclear power, and not one person said that
           they were.  In fact, I was laughed at.
                       So I think that there are some major
           challenges around subsidies and costs.
                       The third point that I'd like to make is
           that the theme of this meeting has been how to further
           deregulate the regulatory authority of the NRC, and
           I'll have to tell you I am always appalled when I hear
           things like the regulatory process described as a
           negotiation because negotiations take place between
           partners of equal power and ability, and in my mind,
           regulation, especially what the NRC is supposed to do,
           is a government function with the goal of protecting
           the public's health and safety, not protecting the
           profits of the nuclear industry or the future of the
           nuclear industry.
                       So the idea that the mission -- and I know
           that this negotiation talk has been going on for some
           time -- but it just to me demonstrates the abysmal
           state of regulation, and unfortunately, I think the
           truth is closer to has become a negotiation process,
           and that's because of our political situation and our
           system that we believe is a system of legalized
           bribery, where public policy is led by campaign
           contributions and lobbying.
                       And we believe that the Nuclear Energy
           Institute and their ability to give campaign
           contributions and to influence Congress has grown
                       Now, whether this will continue and we'll
           be able to get the amount of subsidization that is
           required, we don't know, but I think that all of this
           conversation that's taken place here has taken place
           without any political context, and that that's another
           thing that's very disturbing to me, is that there are
           a number of other things going on politically besides
           this new generation of plants, and I'd like to just
           mention a couple of them because I think they all play
           into the health and safety concerns that we have.
                       One thing is IAEA's attempt to harmonize
           radiation standards across the world and to increase
           the amount of radiation that the public can be exposed
                       The other is the National Academy of
           Sciences' BEER 7 (phonetic) Committee, which we
           believe the deck has been stacked with scientists who
           support exposing the public to higher levels of
                       There are the DOE studies that are going
           on, the radiation studies, which we don't believe will
           be done fairly.
                       And then there's the NRC's process to
           deregulate a category of low level nuclear waste.
                       So the thrust of all of this is that the
           public can and should be exposed to more radiation,
           and then when I come to a meeting about a new
           generation of plants, and I hear almost no real
           discussion of how many radiation releases, what the
           amount of the radiation releases are, and it's all
           really shrouded in technical talk and not real talk
           that people can understand, I think that that's a real
                       My next point is related to the political
           context, and that's the discussion of regulation, and
           I think most of the presentations here talking about
           licensing and so forth used code words for
           deregulation, and we're concerned about the
           deregulation of safety records.  I'm concerned when I
           hear jokes being made and the ACRS Committee
           suggesting that NEI isn't going far enough in
           rewriting regulations, even though I believe that was
           tongue in cheek.
                       And I think that we've heard a lot of code
           words that really mean deregulation and letting the
           industry regulate itself, and those code words are
           risk informed, probabilistic risk assessment, common
           regulatory framework, cost-benefit analysis, new
           regulatory paradigms.
                       You know, the theme of this meeting is how
           can the industry work with the NRC to rewrite safety
           regulations so that this new plant, new generation of
           plants can come on line, appear to be safe, get public
           support, and be economic.  And we're not supportive of
           those kinds of deregulatory efforts.
                       I'm always very concerned when I hear
           about merchant plants as well, because we've seen what
           has happened, what is happening with merchant plants,
           for instance, the natural gas plants.
                       I live in rural Virginia.  We're now about
           to get our third natural gas merchant plant, which is
           coming in under the Clean Air Act because of a
                       We know that there are thousands and
           thousands of megawatts of merchant plants planned, and
           there are a lot of questions about the experience of
           the operators and their financial viability, and I
           think that it will be of grave concern to the public
           that there will be merchant nuclear plants.
                       And I guess lastly, I'll just briefly
           mention the democratic process because I am a great
           believer in democracy, and I don't see the process
           that's been described as having any room for public
           participation because I don't really believe that the
           industry thinks that the public supports nuclear
           power, even if we quote polls.
                       And so, you know, it's damaging to our
           democracy when we take away the public's right to
           engage in discussions about siting and licensing, and
           we need to have as much public participation as
                       CHAIRMAN KRESS:  Do you have a suggestion
           on how that could be done?
                       MS. HAUTER:  Well, I think that these
           meetings, a meeting like this, if it's held on a work
           day and the content is incomprehensible to most of the
           public, that the public is not -- you know, you have
           to go out of your way to get the public to
           participate, and I think there should be hearings
           around the country, and that there should be much more
           of an outreach effort to engage the public.  
                       Because just referring to Mr. Power's
           comment about, well, it's the government's policy to
           support nuclear power, our government is made up of --
           you know, it's a democratic government, and it's what
           the people support, and so, you know, the people
           should be involved in making these decisions as much
           as possible.
                       And I see people shaking their heads.  So
           I think that's the fundamental problem.
                       DR. POWERS:  Just to correct you, it's a
           federal government.
                       MS. HAUTER:  Yeah.
                       DR. POWERS:  I mean it's a federal.  It's
           not a democratic republic.
                       CHAIRMAN KRESS:  Questions, comments?
                       DR. WALLIS:  Well, we have, I think,
           several times in this Committee mentioned that public
           meetings should involve the public, and we are
           concerned that they tend to involve people who have
           some particular interest, which is not perhaps
           representative of the public, and we've struggled with
           how to do that.
                       Whether, in fact, the NRC should somehow
           -- how do you get public input?  How do you get sort
           of informed technical people who are not part of the
           nuclear empire, whatever you want to call it, to go
           there and actually give their attention to it?
                       I don't know, but we have talked it a fair
           amount, I think.
                       CHAIRMAN KRESS:  In fact, I think the ACRS
           considers itself as a public -- taking care of public
           interests in this whole institution actually.  That's
           the way we view ourselves.  So we want to do it in a
           responsible, technically defensible way.
                       And you  know, if this is a technical
           issue, it's not always possible to resolve it without
           using technical jargon or technical arguments.  I
           mean, it is a technical issue.
                       MS. HAUTER:  Yeah, and can I just answer
           that?  I don't think that it's not a technical issue. 
           I think if you want public participation, you hold
           meetings where the public can come to them.
                       I mean, you know, you hold meetings during
           the time that the public is available.  Most people
           aren't going to take off from work, and probably they
           can't come, you know, to a two-day meeting, not that
           you shouldn't have two-day meetings, but you could
           plan special meetings in different locations that the
           public could get to.
                       DR. POWERS:  I think in fairness it's
           important to understand that this particular Committee
           meeting was done to educate us.  I mean, it wasn't
           really intended to be a public, though we invite the
           public to participate, and sometimes we actually get
           some participation.  But this was for educating us.
                       DR. WALLIS:  This meeting is actually
           being recorded, too.  So the transcript is available
           on the Internet.  Anybody who wants to who has the
           access to the Internet.
                       CHAIRMAN KRESS:  Well, I think --
                       DR. TODREAS:  Could I ask --
                       CHAIRMAN KRESS:  Yes, you may ask.
                       DR. TODREAS:  -- a question?
                       I wanted to just drag out a little bit
           more on this.  This terminology being used here, "risk
           based," my whole image of this is that's an approach
           to try to get everybody to focus on the biggest
           issues, the biggest regulatory issues associated with
           plants, the biggest potential hazards associated with
           nuclear power.
                       So my whole perception was that that was
           a move in the right direction relative to putting
           people's attention on the key things, and what I
           gather from your reaction is that whole thrust not
           only misses you, but actually raises suspicions.
                       So what is the right -- well, first, I
           mean, do you have any sense as to why or the positive
           effect that's trying to be accomplished by this
           thrust, and do you have better words or is there a
           better way we should project this?
                       MS. HAUTER:  Well, I think risk based
           analysis had its roots in the late '70s and especially
           then after the Reagan administration, and it was part
           of the deregulatory effort.  It was to make regulation
           cheaper and less costly for industry.  So I'm going on
           the roots of where risk based analysis comes from.
                       So it's not the words that I'm objecting
           to.  It's the idea that agencies are not going to
           regulate, but that we're going to set up this regime
           where you're looking at, you know, what is supposed to
           be the largest risks.
                       And I think that what it ends up doing is
           making it appear as if there are fewer risks and, you
           know, that it's been basically a way to deregulate and
           make the regulatory regime cheaper.
                       DR. TODREAS:  Yeah, past political
                       MR. BARRETT:  Can I address that?  I'd
           like to say a word about that.
                       I think that the experience of the NRC
           with regard to risk based or risk informed regulation
           may not be the same as what you've experienced in
           other regulatory agencies.  We got into risk informed
           regulation or risk based regulation in that time
           frame, in the late '70s, throughout the '80s, and up
           to today.
                       And I would say that in the '80s,
           following the Three Mile Island accident, for
           instance, it would be possible to list a number of
           very, very important new requirements that were placed
           on the regulated industry as a result of our risk
                       And so I don't know that for this
           particular agency it's fair to say that risk informed
           or risk based regulation has been a deregulatory
           trend, and I would have to second what Neil said.  I
           think that when we see the proposals from the industry
           to take a risk informed look at our regulations for
           these new types of reactors, we know that there are
           some of our regulations that are specific to water
           reactors, and really it would be just wasteful of
           resources to try to apply them to these new types of
                       And we also know that there are challenges
           to these new types of reactors, such as the fuel,
           which we've never faced before for a reactor, trying
           to think of the fuel as part of the licensing process
           that we're going to have to address.
                       And so we feel that we need a systematic
           and technical way that we can lay all of these issues
           out on a level playing field and say which ones are
           important and which ones are less important, which
           ones do we concentrate our resources on.
                       So our general tendency is to welcome a
           risk informed approach and to go forward to use that
           risk informed approach to come up with an optimum
           approach though.
                       MR. SIEBER:  Maybe I could add to that a
           little bit.  My impression, having once worked in the
           industry, was that risk based approaches cost us
           money.  One thing that was identified through the
           reactor safety study was event fee, which intersystem
           LOCAs.  We had to change our plant for that.  IPEs
           generated design changes for us, and that improved
                       And I think that risk based approaches go
           in two directions.  You may find when you apply this
           technique to a plant that you have to modify the
           plant, modify the way you operate the plant to make
           the plant as safe as you can.
                       And, on the other hand, there are things
           that are in the regulations that are in the plant that
           when you study them have no risk basis at all and
           probably represent a cost burden to the licensee for
           no safety gain.
                       So I think it goes both ways, and that's
           the way I perceive what has gone on in applying risk
           based techniques in the industry over the last 50
           years or so.
                       DR. WALLIS:  I see risk based regulation
           as being or risk informed as being a way of being
           honest with the public.  I mean, the whole idea of
           regulation is to hold the public risk to some
           acceptable level, which is acceptable to the public,
           not something that's acceptable with an agency.
                       And that communication has to be there on
           the basis of what risks are you exposed to and what
           risks will you tolerate.
                       So it has to be in the language of risk,
           and it has to be measured in some way.  It can't be
           vague and waffley.  So it seems to me that measures of
           risk and explaining how we make those measures of risk
           and how we interpret them and how we decide presumably
           by some political process about what risk is
           acceptable is the honest way to do business rather
           than talking about a lot of technology and loss of
           coolant accidents and design based accidents and all
           of these kinds of things, which are technical things.
                       The common language really ought to be
           language of risk.  So I don't quite see why there's a
           problem with doing it that way.
                       MR. LYMAN:  Can I just share my
                       I think the concern the public has is that
           industry is only interested in risk informed
           regulation when it perceives that the existing
           regulations are too conservative, and then making the
           changes would only go in one direction.
                       And one good example is the attempt to
           risk inform the 50.46, which is the combustible gas
           control regulations is something industry sought
           because they wanted to get rid of a whole lot of
           systems like hydrogen recombiners and hydrogen
           monitoring that they didn't want.
                       But when it turned out that there may have
           been a couple of aspects, for instance, having a back-
           up power supply for hydrogen igniters in the case of
           the station blackout in ice condenser plants, that
           would have introduced -- that was a risk measure that
           would, by the same token, have to lead to increased
           requirements, and so then the proposal from NEI was we
           want selected implementation, which is we can choose
           whichever we want and forget about the others.
                       So that gives the impression that they are
           really only interested in those that reduce cost and
                       If it's applied systematically, then I
           agree with you.  But then the issue is brought up of
           how accurate are the risk assessments to begin with.
                       CHAIRMAN KRESS:  That's why NRC's job is
           difficult.  They're there to make those judgments, I
           think, and to help make them, and I, for one, think
           they are very diligent about that sort of thing.
                       DR. WALLIS:  Well, part of the problem may
           be that NRC is perhaps set up, and maybe it has to be
           by law, to respond to industry, and if industry does
           only ask the things which appear to benefit them, then
           that may be not a very good system.  Maybe that's the
           way -- I'm a bit concerned about that, that the NRC is
           responding to things.
                       Well, maybe it has to respond to other
           forces or maybe your influence, too.  That's another
                       CHAIRMAN KRESS:  It does have to respond
           to petitions.  That should be the other route.
                       MR. SIEBER:  Well, it's responding now
           with the development of performance indicators.  It's
           responding to industry trends and plant trends.  It
           responds to its own inspection program.  So that
           actually goes both ways, too.
                       DR. APOSTOLAKIS:  What's wrong with the
           industry being interested in cutting costs, Mr. Lyman? 
           It's the job of the agency to make sure that they
           don't do anything that creates undue public health
           risk, but the fact that industry is interested in
           reducing the operating cost, I mean, that's not a
                       I mean everybody has an agenda.
                       MR. LYMAN:  Sure.
                       DR. APOSTOLAKIS:  It's the agency's job to
           make sure, you know, that the requests that are
           granted are really legitimate, and they don't really
           threaten anything.
                       And the other thing is I'm always, you
           know, amazed, not amazed, but maybe puzzled that we
           always talk about public interest groups, public
           interest groups.  What's wrong with considering the
           Nuclear Regulatory Commission as the number one public
           interest group when it comes to nuclear affairs?
                       Now, you have five Commissioners that have
           been appointed by the Senate, I mean the President
           with the approval of the Senate.  You know, every
           year, you know, we have a new one, and they represent
           different parties.
                       Then you have the staff, professional
           people.  Aren't they the number one protectors?
                       I don't hear anybody giving them enough
           credit.  So we have to go out and have evening
           sessions to meet with the public?  The public will get
           very bored when we get into technical matters, and
           this Committee is supposed to advise the Commission on
           technical matters.  Why?  Because the Commission is a
           group of political appointees.  They're not expected
           to have the technical expertise that's required.  They
           represent the people.
                       Don't they represent the people?  I'm
                       MS. HAUTER:  The problem is in our
           political system, the industry is able to influence
           Congress, the appropriations process, the executive
           branch of government through campaign contributions,
           through lobbying, through a revolving door, and so
           that type of influence -- the NRC has to be responsive
           to industry in a way that we believe is not always
           representing the public interest.
                       And in a democracy you have tensions
           between different constituencies, and that's what I
           think we're discussing here.
                       MR. SIEBER:  But if public opinion is as
           you say, and I've heard the same stories you did on
           the recent California polls, the politicians, I think,
           would respond on the side of where the votes are going
           to come from, hopefully, and that should be a check
           and balance on the whole system, which is what I think
                       MR. BARRETT:  I'd like to change the
           subject a little bit because I want to get to this
           question about public participation.  That's an item
           that's always challenged this agency, and over the
           past four or five years we've made a concerted effort
           to try to improve our performance in that area.
                       We have tried to have meetings that do
           make it easier for people to participate at least in
           terms of trying to knock down the amount of technical
           jargon, trying to have facilitators who can make sure
           that everybody is up to speed on what's going on.
                       But it's still an area that's a challenge
           for us, and I can tell you we're going to have this
           workshop in July.  It's two days, and it's during the
           work week, but we will try very hard to make sure that
           it's a discussion that's open to everyone because at
           that session we are going to be talking more about how
           we make decisions and this whole question of risk
                       But I think the issue of how we get out
           and make the process even more accessible is something
           that I think we need to think more about.
                       CHAIRMAN KRESS:  Well, with that note, I
           think I'm about ready to declare this Subcommittee
           meeting over with, unless someone has some burning
                       DR. APOSTOLAKIS:  Did you give the public
           an opportunity to --
                       CHAIRMAN KRESS:  Well, I'll tell you what. 
           I would -- you know, I don't want to put anybody on
           the spot, but we do have ex-Commissioner Rogers here,
           and I would love to hear any words he would like to
           give us, any words of wisdom and thoughts on the whole
                       MR. ROGERS:  Well, thank you very much.
                       There's a lot of things I could say, but
           I think one of the things that I really would like to
           say in response to this criticism of risk as a basis
           for anything, that I've been very enthusiastic about
           the use of risk analysis by everybody, and the reason
           is that it is a systematic way of looking at the whole
           system, not piece by piece, isolated pieces, but at
           the whole system.
                       And that's one of the biggest problems in
           any large, complex, technical operation, which
           normally gets broken down into individual management
           pieces -- manageable pieces that can be dealt with,
           and then they're all assembled, and people say, "Now
           it's all done.  It's fine."
                       And yet you know that when you put them
           together, you've got a system that has new features,
           new ways of expressing itself that you hadn't seen
           before, and that risk analysis, probabilistic risk
           analysis is a disciplined approach, a technically
           disciplined approach to looking at the interactions of
           all the different parts of a complex system, how they
           influence the behavior of the whole thing, and each
                       And what the bottom line number is that
           comes out of that may not even be that important, but
           the process of looking at the entire system of how the
           parts interact with each other and using probabilistic
           analysis to quantify this process and begin to allow
           you to  pinpoint where the really serious aspects of
           the system are from a safety point of view is an
           enormous advance in the protection of public health
           and safety.
                       It is not a dodge.  It is not a subterfuge
           to avoid doing the right thing.  It is a powerful
           technical analysis that has not yet come totally to
           maturity.  There are things that we don't know how to
           include in it.  We really don't know how to include
           human performance in it very well, and we know when al
           is said and done, many times that is the controlling
                       But nevertheless, I think it is really a
           shame to consider risk analysis as simply some kind of
           a political tool.  It is a technically sound
           discipline that is maturing.  It is not totally
           mature, but it is maturing and has already revealed
           many, many important issues in nuclear power plants
           that were somewhat I  won't say undiscovered, but not
           thought to be very important.
                       So that, in fact, it does cut both ways,
           that there are aspects of what we have put in place as
           regulations that were done early on in the history of
           the business because we didn't know any better.  So we
           thought, well, that's at least some way of dealing
           with this problem.
                       And as time has gone on and we've been
           able to learn more and more about the total system and
           risk analysis, the discipline of risk analysis has
           been brought to bear on the safety of a total nuclear
           plant.  Enormous strides have been made in
           understanding their behavior.
                       And I think that the much improved
           performance of nuclear power plants not only in the
           United States, but throughout the world is, in part,
           a result of the application of risk analysis to being
           able to pinpoint where the weaknesses are and correct
                       So I really hope that you could take away
           from this meeting at least a sense that this is a
           technical tool that, in fact, has great power and can
           produce and has produced significant improvements in
           plant safety not only here, but throughout the world.
                       CHAIRMAN KRESS:  George, you may have the
           last word.
                       DR. APOSTOLAKIS:  This reminds me of a
           debate we had last week as the symposium that John
           Garrick hosted under the auspices of the Society for
           Risk Analysis, and I objected then, and I will object
                       It seems to me that it is a
           miscommunication to talk about risk analysis in
           general because I understand your complaint about the
           '80s, risk analysis being used as a political tool,
           which to a large extent it was.
                       Risk analysis as used by this agency is
           not the same risk analysis as used by EPA or chemical
           oriented kinds of analysis.  We're dealing here with
           a very complex system.
                       I think the other federal agency that
           comes close is NASA with the international space
           station, and so on, very complex, technical systems,
           and I really think it's miscommunication to call what
           we do risk analysis and then call what the EPA does
           risk analysis.
                       That's why we're using PSA, probabilistic
           safety assessment.  I think what the Commissioner
           referred to is this systematic approach to a very
           complex, technical system that really brings out the
           weaknesses and so on.
                       And I think in the chemical world the use
           of risk analysis is different, although the
           philosophical approach might be the same.  The actual
           tools for implementing it are different, and a lot of
           the criticism regarding risk analysis from public
           interest groups really has in mind the EPA, and
           generalizing, I think, is not, in my view, appropriate
           because there are a lot of technical benefits from the
           probabilistic safety assessment we're doing here.
                       Unfortunately we have to use jargon and so
           on, but anyway, I really think risk analysis is too
           broad a term.  It doesn't really cover what we are
                       CHAIRMAN KRESS:  Wonderful.  Well, I would
           like to thank all of the participants in this two-day
           meeting.  I'd like to especially thank this panel who
           I think have done a very good job.
                       And with that, I'm going to declare this
           Subcommittee adjourned.
                       (Whereupon, at 5:49 p.m., the meeting in
           the above-entitled matter was concluded.)

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