Reactor Fuels - Mixed Oxide (MOX) Fuel Fabrication Facility - November 16, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Reactor Safeguards
Reactor Fuels Subcommittee
MOX Fuel Fabrication Facility
Docket Number: (not applicable)
Location: Rockville, Maryland
Date: Friday, November 16, 2001
Work Order No.: NRC-113 Pages 1-202
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005
(202) 234-4433 UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
REACTOR FUELS SUBCOMMITTEE
MIXED OXIDE (MOX) FUEL FABRICATION FACILITY (FFF)
+ + + + +
NOVEMBER 16, 2001
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The subcommittee met at the Nuclear
Regulatory Commission, Two White Flint North,
Room T2B3, 11545 Rockville Pike, at 8:30 a.m., Dana A.
Powers, Chairman, presiding.
COMMITTEE MEMBERS PRESENT:
DANA A. POWERS Chairman
MARIO V. BONACA Member
THOMAS S. KRESS Member
GRAHAM M. LEITCH Member
WILLIAM J. SHACK Member
JOHN D. SIEBER Member ACRS STAFF PRESENT:
MAGGALEAN W. WESTON, ACRS Staff Engineer
I N D E X
AGENDA ITEM PAGE
Introductory Remarks 4
MOX FFF Presentation
Safety Analysis 23
Radiological Consequences 51
Chemical Process and Products 66
Nuclear Criticality Safety 82
Fire Safety 99
Confinement Ventilation 115
Material Control and Accountability 164
Physical Security 172
Presentation by Ed Lyman, Nuclear Control 187
Discussion and Adjournment 197
CHAIRMAN POWERS: Let's bring the meeting
to order. I apologize for delaying people. We have
little administrative matters that have to be taken
care of while we have a chance here.
This is a meeting of the ACRS Subcommittee
on Reactor Fuels. I'm Dana Powers, Chairman of the
The ACRS members in attendance are: Dr.
Bonaca, Dr. Kress will be with us after he does his
little administrative chore this morning, Graham
Leitch, Jack Sieber, and Bill Shack.
The purpose of the meeting is to discuss
the mixed oxide fuel fabrication facility construction
authorization. The subcommittee will be gathering
information, analyzing relative end issues and facts,
and formulating proposed positions and actions as
appropriate for deliberation by the full committee.
Maggalean Weston is the cognizant staff
engineer for this meeting and the person whose office
will be overflowing with paper generated by this
The rules for participation in today's
meeting have been announced as part of the notice for
the meeting previously published in the Federal
Register on November 2, 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 readily heard. And I assure
you our reporter, in her charming way, will let you
know when you fail to comply with those requirements.
We have received a request from Mr. Ed
Lyman from the Nuclear Control Institute to make an
oral statement at today's meeting. We have also
received written comments from Georgians Against
Nuclear Energy, Atlanta, Georgia. These comments have
been distributed to the ACRS members here today, and
I encourage the members to examine it. They raise 13
issues. It's a fairly quick and interesting read.
If members look at the agenda, the
statement by Mr. Lyman is not culled out on the
agenda. My intention is to call a break at 3:00 and
do his statement at the conclusion of that break. Mr.
Lyman has spoken to us before, and I think we'll all
agree he usually has interesting things to say.
We're embarking on looking at a plutonium
process facility. This is not the first process
facility that's ever been constructed in this country.
My own involvement has been with three of them --
Rocky Flats, PUREX, and the plutonium finishing plant.
I wish I could assure the members that the smooth,
non-controversial functioning of these facilities
should give us confidence in the ability to prepare a
There are some differences that we do need
to recognize. This is going to be a new facility.
Whereas the older facilities were designed with short
lifetimes and the technology was evolving as they were
being operated, this new facility is going to be
designed with a 50-year lifetime and a fairly well-
Members are going to find that the safety
analyses for facilities are substantially different
than what we're familiar with in the reactor world.
Members may want to reexamine Part 70 of Chapter 10 in
the Code of Federal Regulations. They also might find
it of interest to look at the Parts 800 and above that
are the codification of some of the DOE orders that
give you some insight on how facilities within the DOE
world are operated.
The committee historically has been very
comfortable with the quantification of risk -- going
to enter into a less familiar world of safety analyses
that are done for process facilities. And these are
process facilities that are fairly unusual. It's
located on a large government-controlled reservation.
That means that risks to the public, as we
generally define them, are going to be low because --
just because of the distance. On the other hand,
there are large populations of people on these
government reservations. The last time I looked at
the Savannah River site there were 25,000 people
working on that site, most of whom will have only the
vaguest familiarity with any hazards posed by the
mixed oxide fuel fabrication facility.
And, consequently, the definition of what
we mean by "public" in looking at this facility
Well, with that brief introduction, I
think we can proceed with the meeting, unless other
members have opening comments they'd like to make. I
will begin, and I believe Drew Persinko is going to
start us off on this?
MR. PERSINKO: Yes.
CHAIRMAN POWERS: Drew, the floor is
MR. PERSINKO: Thank you. My name is Drew
Persinko. I am the MOX Project Manager at NRC. I
will try -- I will give a brief introduction and will
try to move through it quickly, so we can get on to
more technical matters.
Today we will be speaking about many
different topics as we were requested to do -- a
little bit about many areas. We will not be speaking
about any classified information, nor will we be
speaking about any proprietary information. If a
question is asked that contains proprietary
information as an answer, we will decline to answer.
So we have a tight schedule today. We've
tried to pack in a lot of information into this
schedule. So if we extend in one area, we're going to
steal from another area.
CHAIRMAN POWERS: Yes. I think you use
your judgment on this. This is -- I mean, we're
looking at this mostly as an introduction to the
subject. One of the things that the committee is
going to have to do at the end of the meeting is try
to decide when we bring the -- what and how much
material when we bring to the full committee.
You've got a substantial fraction of us
here, so you can tell there's a lot of interest in
this new activity.
MR. PERSINKO: Okay. Next slide, please.
Start off with a brief history. I'll go
through it quickly. You've heard some of this before
in an earlier presentation that we made, I think it
was last February.
The reason for the facility is a U.S.
agreement with Russia, whereby each party, each
country has agreed to dispose of 34 metric tons of
plutonium. The policy is being implemented through
the Department of Energy. The Department of Energy
has decided to convert some of the excess plutonium to
MOX fuel; 25 metric tons will be converted to MOX
The DOE has contracted with Duke Cogema,
Stone & Webster, whom we will -- we use the acronym
DCS -- to build and construct and operate the facility
located at the Savannah River site in Aiken.
I'd also like to state that at the current
time the Bush administration is currently reviewing
all of the plutonium disposition programs within the
Department of Energy. And it's possible at the
conclusion that some elements of the program may
change. But at the current time, staff -- the NRC
staff is continuing to review the project at the
Next slide, please.
This is an overview, high-level depiction
of the flow of material, weapons-grade plutonium
coming into the Savannah River site, first coming to
a pit disassembly and conversion facility, which will
be under the jurisdiction of the Department of Energy
and not NRC.
From there, the plutonium oxide powder
goes to the MOX fuel fabrication facility, and then to
the reactors. The plan is that the MOX fuel fab
facility will process approximately -- assuming staff
approval, will process approximately 70 metric tons of
heavy metal per year.
Next slide, please.
This is an artist's depiction of the
proposed facility from the applicant's construction
authorization request. The main building is
approximately -- the footprint is about 400 by 400 by
about 65 feet above grade. The main building
comprises of three areas within the building, one
being the aqueous polishing area, one is the
shipping/receiving area, and one is the MOX processing
area, which we'll get into a little bit here.
CHAIRMAN POWERS: And this is all in F
MR. PERSINKO: All in F area. Next slide,
This is a map of the Savannah River site.
You can see that the MOX fuel fabrication facility is
shown in F area. This is the -- the red line around
the outside is what the applicant has proposed to be
the controlled area boundary. You mentioned earlier
about there is a significant amount of Department of
Energy personnel on site, which there are.
The Part 70 regulation allows the
applicant to choose the controlled area boundary at a
location between the restricted area and the site
boundary, and the applicant in this case has chosen
Savannah River site boundary as its controlled area.
The Part 70 regulation does have provisions in it you
may have read about how the Department of Energy
personnel should be treated with respect to the
performance requirements in 70.61.
It has to do with training, so that they
do become aware of the hazards associated with the MOX
facility. But we can go into that in much more detail
if you'd like at --
CHAIRMAN POWERS: It's quite a question to
my mind how much this committee really wants to get
into that argument. I have endured those arguments
within the Department of Energy itself for worker
protection. There's a real question in my mind,
though, whether that's a useful use of this
committee's time. I think it's an interpretation of
I have my interpretation. It's
undoubtedly different than the applicant's. But I'm
not sure I have -- I'm not sure the Commission is
looking to me to get advice in that area.
What you might want to point out is
there's a public road going through this.
MR. PERSINKO: Yes. There are public
roads running in that area, and I believe that area
right there is a public road. There are public roads
that transverse the site.
I guess I'll have to point out, too, that
the MOX fuel fab facility is approximately five to six
miles to the nearest controlled area boundary site.
Next slide, please.
This is a high-level view of the process.
Alex Murray will get into the chemical process in more
detail when he speaks, but this is a high-level view
of it. This is the part known as the aqueous
polishing part of the process. It's based on various
processes that are in place at the LaHague facility in
France. It's similar to the PUREX process in many
It consists of a dissolution phase where
the plutonium oxide is dissolved in nitric acid, a
purification stage whereby Americium and gallium and
other impurities are removed via pulse columns and
solvent extraction. And then it's converted back to
a plutonium oxide and transferred to the next phase of
Next slide, please.
CHAIRMAN POWERS: I'll learn lots about
red oil here.
MR. PERSINKO: And Alex will be happy to
talk to you about that.
Okay. The next phase is the actual -- the
fuel fabrication process. This is based on the
process that's currently in use at the MELOX facility
in Marcoule, France. Both, like I said, the aqueous
polishing and this are based on processes in France.
Some of the components will be exactly the same, some
will be different, but the basic processes are
involved -- are similar.
The applicant is doing what it has called
Americanization, which means trying to take the
designs that are in France and showing that it meets
U.S. codes and standards.
CHAIRMAN POWERS: Excuse me. A couple of
things here that pop immediately to mind is that there
is an accumulation, it seems to me, at some point in
the 20 percent blend here before we get into the
blending to form the pellets. So there is -- I mean,
there is more complexity in this step here.
The other thing is that some of the
technology that's just recently come to the fore is
being applied in this. It's the ultramicronization
and things like that to get a little -- a better
distribution in the fuel.
MR. PERSINKO: Yes. As you were saying,
the first process is a blending. It's a two-step
blending process. After each phase there is ball
milling, homogenization of the material, and it uses
what's known as -- you referred to the MIMAS process
It's pressed into pellets, sintered in
ovens, and assembled into rods and assemblies, similar
to -- the process is -- that part of it is similar to
the uranium processing facilities.
Next slide, please.
This is just an overview of all of the
regulations that apply to the facility, just to let
you know that there's more than just Part 70. But
today we'll be speaking primarily about Part 70.
We'll get into some others when we talk about
safeguards and security, but --
CHAIRMAN POWERS: You've left Part 20 off.
MR. PERSINKO: You're absolutely right.
Part 20 should be added. It's a very
Okay. Next slide, please.
Yes, we put a lot of pictures onto the
slides. They didn't quite fit onto one floppy, so we
had to split it up.
Okay. So the primary regulation that we
will be discussing today is 10 CFR Part 70. Part 70
allows a two-step process to be -- a two-step
licensing process, one for construction and one for
operation. We are currently reviewing the
construction application that was provided to us that
was submitted by Duke Cogema, Stone & Webster, the
Concerning construction, Part 70 requires
that the design -- that in order for the applicant to
move forward with construction, the NRC must approve
the design bases of the principal structures, systems,
and components, the quality assurance plan, and also
complete an environmental impact statement.
We are in the process of working on the
environmental impact statement. We have issued a
quality assurance -- a safety evaluation report
concerning the quality assurance plan.
Next slide, please.
We are using the definition of design
bases from 50.2, which consists of functions and
With respect to operation, you had quite
a presentation on this on Wednesday. But, once again,
with respect to operation, the applicant will be
required to submit an integrated safety analysis.
Part 70 requires that an ISA be submitted, that the
NRC approve the ISA summaries. It also has provisions
to identify the items relied on for safety, and I
think you're familiar with that term, commonly
referred to as IROFS, and then management measures to
assure that the IROFS are available and reliable.
Those are the three main ones, but there
is a host of other items that must be also submitted
with the operational application, such things as
physical protection plan, material accounting plan.
One thing I'd like to say at this point,
though, is for the construction phase the regulations
talk about principal structures, systems, and
components, and safety analysis. At the operations
stage, it talks about integrated safety analysis and
the IROFS, items relied on for safety.
There's an analogy there, but there are
different terms that apply to it. We sometimes forget
ourselves and use the terms interchangeably. But I
would like to state that when we talk about
construction we are really meaning principal
structures, systems, and components.
CHAIRMAN POWERS: We will be equally
MR. PERSINKO: Next slide, please.
This is a depiction of the performance
requirements, which is the -- in 70.61. You heard
about them on Wednesday. This is shown -- the
performance requirements are shown in matrix form.
Basically, if you have unmitigated doses to the public
or the workers that fall into different consequence
bins, you have to have associated likelihoods with it.
These areas -- for example, if an
unmitigated consequence and a certain likelihood fall
in this bin, you either have to provide -- the
applicant must provide -- must identify items,
principal SSCs or items relied on for safety,
preventive IROFS, which would take it into this
direction, or mitigative IROFS, which would lower it
into this direction. But, basically, the regulations
require that you -- after application of the IROFS,
you do not exist in those bins.
CHAIRMAN POWERS: One of the challenges
I'm sure we're going to come up with is understanding
the role or the application of defense-in-depth
philosophies to this, which may well be interpreted by
at least some as a balance between preventive and
mitigative activities. Can you comment on that?
MR. PERSINKO: Well, the applicant, for
certain scenarios such as criticality, has committed
to prevention rather -- as opposed to mitigation. In
other cases, it has relied on mitigative features.
Rex Wescott, when he speaks about the safety analysis
part, will get into more of this.
What I'd just like to say also -- the
performance requirements that are shown up here really
apply to the operations phase. When Part 70 was
formulated, it was -- we were thinking operations
phase at this point. So they really applied to
operations. However, they are also being used by the
applicant in identifying principal structures,
systems, and components at the construction phase,
although the regulations do not require that.
At the construction phase, the applicant
is identifying the principal SSCs at a systems level,
and then at the operations phase the applicant intends
to identify IROFS at a component level.
Next slide, please.
This is a quick overview of the activities
that the staff has done to date, has completed to
date, or is in progress. Has completed to date -- we
issued a standard review plan, NUREG-1718. We've
established a website, although I don't think it is
currently -- because of the -- I don't think it's
currently usable right now, but it was a very good
And hopefully we'll have it back online at
We've had numerous technical meetings on
the subject, some of which were in Aiken, in South
Carolina near the site. We have had also public
meetings with members of the public, especially in the
EIS -- in the environmental area, both in South
Carolina and North Carolina. We had environmental
scoping meetings down there in Charlotte as well as
the Aiken area.
CHAIRMAN POWERS: None in Georgia.
MR. PERSINKO: We had them in -- well, we
had them near Aiken, North Augusta, South Carolina,
which is just across the border from Georgia.
MR. GIITTER: And one in Savannah.
MR. PERSINKO: Oh, one in Savannah.
That's right. That's right. Thank you. We did have
one in Savannah. That's right. Savannah being
downstream of the plant along the Savannah River.
And we have issued a request for
additional information. We issued that last June.
The applicant has responded to our 239-question RAI,
a very interesting number.
CHAIRMAN POWERS: That's why Mag is
applying for a bigger office.
MR. PERSINKO: And the applicant has
responded to that -- to those 239 questions. We are
currently discussing some of those responses with the
applicant because of additional or clarifications as
well. We are currently in that process right now.
We've had public meetings on this -- on
certain RAIs, and we have visited the offices to
review certain in-house -- in-office supporting
documents that the applicant has. That's where we
Next slide, please.
A high-level view of our schedule up
through -- near-term schedule, I should say. The
environmental report was received in December of 2000.
The application for construction -- the construction
authorization request -- was submitted in February of
'01. We intend to issue a draft EIS in February of
'02 and a draft construction SER in April of '02.
The applicant has indicated that it will
submit an application for operation of the fuel fab
facility in July of '02, and our plans are to issue a
final EIS and construction SER in October of '02.
Next slide, please.
These are just some of the considerations
that we are currently dealing with within the staff.
We're using 10 CFR Part 70. It was revised fairly
recently, about a year ago. And it's the first time
it's being applied in total from start to finish for
our new facility.
We also have -- since this is a two-step
licensing process, we are working on design bases. So
we have many interesting discussions concerning what
is the appropriate level of detail with respect to
Another issue -- another consideration is
that this is a plutonium facility. It's been quite
some time, maybe about 25 years, since the staff has
reviewed such an application. We are also -- let's
not -- in addition to the technical safety analyses
being performed, we are also in the process of writing
an environmental impact statement. And there are also
public hearing -- requests for public hearing, and the
technical staff is supporting the Office of General
Counsel in that respect.
And that completes my presentation. With
that, I would like to turn it over to Rex Wescott, who
will talk about the safety analysis portions.
CHAIRMAN POWERS: Well, I'll just
interject we'll -- I think we could have an
interesting discussion on this issue of design bases
and design alternatives, because it's a -- it's
remarkable how many of these processes I've actually
seen before. I mean, these are fairly geriatric
approaches to mark what little progress has been made
in the last 20 years.
MR. WESCOTT: Good morning. My name is
Rex Wescott, and I'm the safety analysis reviewer, and
I'll be describing the safety analysis review which is
primarily the review of Chapter 5 of the construction
authorization request for the MOX fuel fabrication
The purpose of this slide is to give you
an idea of the scope and organization of my
presentation. I want to note that the applicant
refers to the safety analysis provided in Chapter 5 as
the safety assessment of the design basis, which is
also the terminology from our SRP. And this is the
terminology which I will use in referring to the
I wish to note that the objectives of the
safety assessment and the tasks listed to meet those
objectives were developed by the applicant and are
presented here to better describe what is being
reviewed by the staff.
I will also talk about the NRC's safety
analysis review responsibilities, which include a
little bit more than just Chapter 5 review, an
overview of the MOX safety assessment, a little bit of
quantitative information about what it all entails,
and the status of the MOX safety assessment review to
The major objectives of the safety
assessment are as follows: to identify the hazards
and events associated with the MOX fuel fabrication
facility design and operations. That's the first step
to figure out what the hazard and events are. The
second objective is to identify the principal SSCs
required to mitigate or prevent these events and their
specific design bases.
MEMBER KRESS: Are those the same as
MR. WESCOTT: At this point, no. This is
at the systems level, and I'll get into IROFS a little
bit later. Right now we're primarily dealing with
principal structures, systems, and components. I
guess that's consistent with Drew's explanation.
And the third objective is to provide
reasonable assurance that the identified principal
structures, systems, and components can reduce the
risk to a level consistent with 10 CFR 70.61, through
the adoption of a general design philosophy, design
bases, system designs, and a commitment to appropriate
The significance of that is that the need
to consider the design philosophy and commitment to
management measures is a reflection of the early state
of the design at the construction authorization stage.
At this point, we really don't have the quantitative
reliabilities or the procedures to assure them that
could allow us to be more quantitative.
MEMBER SHACK: On 70.61, this matrix that
we were shown earlier is from 70.61?
MR. WESCOTT: That is correct. That
reflects the requirements of 70.61.
MEMBER SHACK: So that is the codified --
MR. PERSINKO: You won't see the matrix
itself in 10 CFR --
MEMBER SHACK: No. But I will see the --
these numbers --
MR. PERSINKO: Yes.
MEMBER SHACK: -- the low consequence
doses is --
MR. PERSINKO: Yes.
MEMBER SHACK: -- 25 rem for the worker.
CHAIRMAN POWERS: Yes. You can construct
the matrix from that.
MR. PERSINKO: Right.
MEMBER SHACK: Is there a numerical value
associated with highly unlikely and likely?
MR. WESCOTT: At this point, what the
applicant has done, basically, in response to one of
our RAIs, has committed to an index as we've described
indexes in Appendix A of the SRP, an index of minus
five, which we -- and this is, incidentally, just for
the public and the site workers. It is not for the
He has committed to an index of minus
five, which we take as approximately a probability of
10-5 per year, not exactly, you know, in a sharp
regulatory sense, but kind of a neighborhood
MR. PERSINKO: The regulations themselves,
though, Part 70, do not specify a numerical number
with the likelihoods.
MR. WESCOTT: For the facility worker, the
licensee has committed to more or less qualitative
descriptions that should ensure a likelihood of -- we
would estimate in that neighborhood, such as defense-
in-depth and a commitment to quality assurance. I
can't remember all the commitments, but they are
basically qualitative commitments that followed in the
nuclear industry that should provide for a very high
level of protection.
MEMBER SHACK: It just seems like a worker
dose of 25 rem is not being unlikely is acceptable
If I walked into a national lab and told
them that I was going to, you know, give my hot cell
worker a 25 rem dose --
CHAIRMAN POWERS: You'd walk right back
MR. WESCOTT: Well, certainly, it's
attempting to make it very -- you know, highly
MEMBER SHACK: But it says not unlikely is
MR. WESCOTT: Not unlikely is acceptable.
MEMBER SHACK: Yes. It says low
consequence, worker dose --
MR. WESCOTT: Oh.
MEMBER SHACK: -- I guess he can have
MR. WESCOTT: I see what you're talking
about. Well --
MR. PERSINKO: One thing to remember I
think is that those doses are with respect to the
performance requirements in 70.61. They're not with
respect to Part 20. The applicant still must meet the
Part 20 dose requirements.
MR. WESCOTT: Right. But you're
absolutely right. From the performance requirements
that is the regulation. But Part 20 and ALARA we feel
will come in to kind of make that particular --
MEMBER SHACK: Less acceptable.
MR. WESCOTT: Yes, less likely.
CHAIRMAN POWERS: There may be a question
that has no answer right now, because of timing, but
I'll ask it anyway just because it pops into my mind.
Suppose the NRC indeed grants both the applicant's
request for construction and operation. What kind of
monitoring and enforcement regime would the NRC
anticipate at this facility? Episodic or continuous?
MR. PERSINKO: That decision has not been
made yet. It's very possible we would have a resident
inspector on site, but that decision has not been
MR. WESCOTT: Okay. Slide 4, next slide.
Okay. Now here are the tasks which have
been developed to meet these objectives. First is the
identification of hazards and events which was
accomplished in the applicant's primary hazard
analysis, which is kept at his office. It wasn't
supplied to this.
And in this he's gone through procedures
like what-if checklists, hazard interaction, matrices,
and similar basic tools to determine what the events
The determination of unmitigated
consequences, of course, identifies events which will
have to be prevented or mitigated. The identification
of bounding events is part of our SRP guidance. In
other words, we don't require that every event be
dealt with in terms of principal SSCs, but the
bounding events at this point.
And the formulation of a safety strategy
and identification of principal SSCs and their
associated design bases -- the last two elements there
-- is directed toward getting the event to be in
compliance with 10 CFR 70.61 performance requirements.
We will --
CHAIRMAN POWERS: Looking and reviewing
these things, how much access has the staff had to the
historical record of the DOE facilities that in many
cases have used similar SSCs to mitigate events?
MR. WESCOTT: Well, we have looked at some
facilities. I mean, we were out at Los Alamos a
couple of --
CHAIRMAN POWERS: EA-55.
MR. WESCOTT: -- ago and looking at their
experience and what they did, and so on. Primarily,
at this point, we are looking at trying to make sure
we've got all of the events covered. And as I'll
mention later, of course, in determining the
strategies we are looking at the basic nuclear
experience, including reactors.
If something is normally done to prevent
an accident or prevent a dose in a reactor as a
strategy, say, as a -- let's say, an entry control or
interlock, you know, we -- we tend to accept that as
probably an acceptable strategy here. And, yes, we
are trying to base our review, to the extent possible,
on historical precedent.
CHAIRMAN POWERS: Okay.
MEMBER KRESS: How will you decide what an
SSC is? If they're not IROFS, what are they?
MR. WESCOTT: Well, right now, principal
SSCs -- I'm trying to be consistent with Drew, because
I think that is generally the way we're going -- is
primarily systems, the principal SSCs. We're up at
the system level.
Now, in some places, a component can, of
course, be a system. And that would be a principal
SSC. But right now, we're at the systems level. The
strategy is still in the conceptual design stage, I
guess would be a proper way to characterize the
design, and we're looking at systems as opposed to the
actual design of these systems themselves.
Where we get into the IROFS, the
components, would be -- be -- some components maybe
IROFS, some components may not be, depending on the
design of the system.
MEMBER KRESS: But you don't have the
equivalent of an importance measure that you'd have
with the PRA. So I'm not quite sure what the criteria
is going to be for saying this is an SSC.
MR. WESCOTT: Do you mean this is a proper
MEMBER KRESS: Yes.
MR. WESCOTT: I'll get into that a little
MEMBER KRESS: Okay.
MR. WESCOTT: But I guess maybe to answer
your question right now, as I said before to Dr.
Powers, one of the criteria is, is it being used in
the industry? I mean, is it a normally applied
The other thing we're using is we have a
table in Appendix A, Table A-5, which is a description
of various types of measures -- in other words, robust
passive control or active control, that type of thing,
and it assigns an approximate probability of
And so we're kind of doing a semi-
qualitative/quantitative approach at this stage to get
an idea of whether this appears to be an appropriate
strategy, whether it's going to work at the OL stage.
That's what we're trying to do right now. We're
trying to have reasonable assurance that they're going
to have a design that when they actually design the
components and determine the surveillance requirements
and go into all of these different measures that
narrow down what the exact reliability is, they are
starting with something that will work, that they can
get there from where they're starting. That's our
concern at this point.
MR. GIITTER: Just to make it clear that
the approach they're taking is deterministic at this
MR. WESCOTT: I'm sorry. I guess slide 5,
Okay. Determining the mitigated
consequences checks for the actual quantitative
compliance with the performance requirements. In
other words, doing a calculation with mitigative
measures; that is, for those that are not -- those
events that are not prevented, we determine whether
the dose to the public, the dose to the site worker,
or the dose to the facility worker, and so on, has
dropped below the threshold value and then is in
compliance. You've got to do that check or you don't
really know if your mitigative measure is proper yet.
Support systems, such as power supplies
and other supporting systems have to be identified
when you're looking at these principal SSCs. Natural
phenomena hazards were treated as events whose
consequences are normally prevented through the use of
proper design of SSCs. Natural phenomena, of course,
include things like tornadoes, earthquakes, floods,
that type of thing.
And one of their last tasks here was
provide a general description of the principal SSCs,
and that's required so the reviewers can -- the other
reviewers, the discipline reviewers, can determine
whether the design bases for these principal SSCs has
been properly reflected.
Now, to kind of show you where they are
going, I thought it was also a good idea to show what
is required at the operating license stage, so you can
see how what's being done at this stage goes into what
we'll be reviewing next.
First is the identification of items
relied upon for safety will drop down from the systems
level to the components level. That's when we start
being concerned about pumps and valves and circuits
and that type of thing in certain --
CHAIRMAN POWERS: HEPA filters.
MR. WESCOTT: -- yes, in certain systems.
There will have to be a demonstration that those
IROFS, items relied upon for safety, have the right
characteristics to meet the regulatory performance
requirements. In other words, do they have the right
reliability, right pedigree, QA, that type of thing.
And often this is accomplished through a
preparation of likelihood analyses, criticality
analyses, shielding analyses, structural analyses,
fire hazard analyses, etcetera. In other words, this
is where we expect to be a lot more quantitative, to
have a lot more quantitative information to base our
And specific operating requirements will
be identified with many of these operating
requirements supporting the demonstration of
regulatory compliance, such as, as I mentioned before,
surveillance frequencies, testing frequencies, that
type of thing, which really can't be developed at this
MEMBER BONACA: So at this stage, you
would expect to have a more quantitative assessment of
all these issues.
MR. WESCOTT: That is correct.
MEMBER BONACA: Do you expect those to
have -- you know, the question that Dr. Shack posed
before, a better or a quantitative classification of
the categories here, what is acceptable, unacceptable,
and so on, insofar as the categories of accidents?
MR. WESCOTT: I'm not sure exactly --
MR. PERSINKO: You're talking about the
likelihoods, I guess? Is that what you're referring
MEMBER BONACA: Yes.
MR. PERSINKO: Yes. Well, I --
MEMBER BONACA: I'm trying to understand
how you go from --
MR. PERSINKO: Yes.
MEMBER BONACA: I mean, for the
construction, clearly, you cannot be overly
MR. PERSINKO: Right.
MEMBER BONACA: Because -- but at some
point you will have to become more quantitative. And
I guess my point is, you know, what flexibility you
have during the operation, the phase from construction
to operation to adjust and modify, because you may
discover that some systems that you now classify it as
safety-related become safety-related or vice versa
MR. PERSINKO: Let me -- well, first of
all, there is if you go look at the standard review
plan -- to answer your last question, there is a
flowchart in there about how the construction phase
interfaces with the operations stage, and there are
feedback loops in there so that if you learn something
later you can feed it back into the process and
properly characterize the SSCs.
As far as the quantitative/qualitative
aspects on the highly -- on the likelihoods, the
applicant has currently proposed qualitative terms for
its likelihoods, which it intends to follow, and it
still intends to follow that in a qualitative manner.
I'd like to point out that during the
Part 70 rulemaking, too, the Commission did say that
qualitative analyses were acceptable. PRAs are
But, so anyway, but in our -- one of the
responses to our request for additional information,
it was response number 39, as Rex had said, the
applicant has committed to doing an index approach as
we propose in our standard review plan, and I think
also the Part 70 standard review plan has the same
So in our -- in response to our question
number 39, at the OL stage the applicant has committed
to showing that for the site workers and the public
that they will meet a certain index.
MR. WESCOTT: Next slide, please?
Okay. This slide --
MEMBER BONACA: I just would like to
MR. WESCOTT: I'm sorry.
MEMBER BONACA: -- to you just one more
question, just for clarification. You don't have to
have a PRA to be somewhat quantitative. I mean, core
powerplants had ranges which were based on projections
even when, you know, at the beginning it was somewhat
MR. PERSINKO: That's correct.
MEMBER BONACA: If you go back to the ANSI
standards, you know, that's -- if you look at the
1970s, the 1960s, and so -- so, you know, that's not
requiring such an effort. I mean, that's more like
giving some ranges of classification. Would you
MR. WESCOTT: Well, I think we expect
whatever is required to give us a good idea of what
the reliability or availability is. If it really
takes a PRA, then I guess we would expect a PRA. But
we would expect this to be maybe for very few -- maybe
the ventilation system, the C4 confinement system, for
example, may be the only thing requiring a PRA. And
maybe not. But we wouldn't expect to see a lot of
PRAs, if any, I guess would be the best way to answer
MR. PERSINKO: I think you will get some
quantification when the index approach is performed at
the next stage.
MR. WESCOTT: This slide is to show the
NRC review responsibilities at the construction
authorization stage. The first one I think we've
already gone through -- the necessity of evaluating
completeness of the hazard evaluation. We're doing
this as a team approach. We're doing this by going
down and looking at their preliminary hazard
evaluation onsite. We're doing onsite reviews.
We're reviewing the methodology that was
actually used. And, of course, the detailed review of
the CAR in-house we expect to have some questions
regarding actual completeness of the hazard
The appropriateness of the selected safety
strategies is, in my opinion, primarily a safety
analysis responsibility, along with team input. And
that's where our evaluation is based on standard
nuclear practices, an awareness and knowledge of
what's gone on in similar facilities, and our somewhat
of a reliance on the qualitative criteria from
Appendix A of the SRP. That's where we're trying to
make sure at least they're starting with the right
Evaluation of the design basis. And the
question here is: do the design bases support the
strategy in terms of assuring compliance with the
regulation? Some design bases at this point consists
of commitments to standards. Some design bases
actually will require numerical design bases. It
depends on the SSC, and it depends on the standard.
If it's a standard commitment -- if it's a commitment
to a standard, how specific it is, that type of thing,
as to what's an acceptable design bases.
And the final -- well, I shouldn't say the
final, maybe one of the most important aspects of the
safety analysis review is to coordinate the resolution
of multidisciplinary conflicts. In other words,
that's the integrated part of the integrated safety
analysis, and that's when we'd look to -- the classic
conflict is fire and criticality.
But we're also finding other conflicts in
this particular project that also require a
multidisciplinary approach, and the SA responsibility
is to try to oversee this and make sure that it's
being coordinated properly.
MEMBER BONACA: Now, one question I have
again. I guess just coming from qualitative, one of
the issues that you have when you look at defense-in-
depth, you look at not excessive reliance on
MR. WESCOTT: Right.
MEMBER BONACA: But if you have a
qualitative -- you know, a heavily qualitative
application, you know, like we saw in the early
designs of powerplants, there is a lot of reliance on
the operator action, who will take care of it at some
MR. WESCOTT: Well, right now, in the CAR,
the licensee has an area entitled their hierarchy of
controls, and that's where basically they've made a
commitment to, wherever possible, use a robust passive
engineered control first and then an active engineered
control second, and then maybe enhanced administrative
controls, and finally a simple administrative control.
So even though they haven't told us in all
cases what the control might be, there is a commitment
to start with the higher level of control.
Now, we have found some cases where
there's a commitment to a standard and the standard
maybe says, "Well, you can use almost any type of
control," and then we might want, you know, a little
more of a commitment there. But, yes, the applicant
has provided a hierarchy, and our understanding is he
is committed to that hierarchy and we expect it will
MEMBER BONACA: Would you want to set, for
your review, a set of defense-in-depth criteria that
you are going to consistently apply to your review?
I think it would be appropriate.
MR. WESCOTT: Well, we've tried.
Unfortunately, there are so many different types of
events that what seems to work well in one event can't
-- I think a facility worker's safety is an area -- is
a problematic area right now, because, first of all,
there's not a lot of history there, or, you know,
other examples where we're actually designed to try to
keep facility worker safety to within a certain
probability and within a certain -- below a certain
threshold. So --
MEMBER BONACA: But wouldn't that be a way
to bring the, you know, 40 or 50 years of experience
in operating reactors to better experience on what in
defense-in-depth really paid off and what it didn't,
into the review of a new application. That would
help, I think. That would also help the review on
your part and on our part.
MR. WESCOTT: Oh, yes. We are certainly
not ignoring, you know, regular nuclear engineering
practice. That weighs very highly in our review.
MR. PERSINKO: I'd like to say, while
we're on this subject, it's a Part 70 regulation.
When it talks about items relied on for safety, the
item itself can be an operator action, because it does
-- human action is defined as also an item relied on
So an admin procedure, an admin control --
human action would be the item relied on for safety.
The admin control or the procedure would be the
management measure that supports the reliability of
the human action. So it's analogous to a component
and a procedure.
Also, the regulation does specify a
preference for engineered controls over admin controls
right in the regulation for new facilities.
MEMBER BONACA: Yes. The reason why I
insisted on this point was because there is quite an
amount of qualitative bases to this application
evidently. And, you know, in the context, at least
the experience of the past has been, you know, when we
had early PSARs and FSARs there was heavy overreliance
on operator actions without definition of what that
will be and what it will accomplish.
And then later over time we found that we
had to refine them or substitute, you know, equipment
for those. So that was the reason why I brought up
MR. WESCOTT: One thing I'd like to
mention is some places where we're really having
doubts as to whether actions or administrative
controls are sufficient -- at the strategy level, we
are asking for calculations, so we'll have some
numeric -- these are primarily in one aspect. Like in
the load drop, we're asking for some dose calculations
to see -- just to give us kind of a baseline or a --
let's say a data point so we can determine with some
degree of confidence whether this is a -- whether this
is a viable strategy or not.
MEMBER BONACA: Okay. Thank you.
MR. PERSINKO: One thing also, the
process, if you've seen the MELOX process, it's a
highly automated process. So it -- not to say there
are no admin controls or operator actions, but it is
a highly automated process.
The admin control is one of the areas they
do come into play, like Rex has been saying, is -- is
with respect to the worker safety and worker actions
and that kind of thing.
MR. WESCOTT: Next slide?
Okay. I'm not going to go through these
slides in detail. I just prepared them more or less
for information for the committee and to give you an
insight into the extent of the safety assessment at
And I'd like to mention that the
applicants valuated natural phenomena, external
manmade events, loss of confinement events, fire
events, load handling events, explosion events,
chemical events, and criticality events. And these
seem to be pretty much similar to events that are the
types of events evaluated at other --
MEMBER SHACK: When it says 19 hazards
evaluated out of 32 considered, it means the others
were somehow ruled out as being too unlikely or --
MR. WESCOTT: Yes, that's correct. In
other words, you know, the -- yes, too unlikely. That
would be -- actually, I think almost more in terms of
credibility. I don't -- I think the ones that were
ruled out were really considered incredible rather
than just highly unlikely.
MEMBER KRESS: Was there a criterion for
what was meant by "incredible"?
MR. WESCOTT: Well, the criteria for
credible in our SRP is 10-6. And from my review of
what they did, that seemed to be quite similar to --
MEMBER KRESS: So they had some sort of a
SIMAC quantitative --
MR. WESCOTT: Yes, they didn't state their
MEMBER KRESS: Yes.
MR. WESCOTT: -- for credible. But they
did use a lot of existing NRC Reg. Guide criteria,
which is in that neighborhood. So I would say --
MEMBER KRESS: Yes. You know, for
example, in the past I have seen things like if you
have two independent highly unlikely things that have
to go wrong to get you any kind of consequence, that's
-- that was sometimes viewed as incredible. I
wondered if they did something like that or --
MR. WESCOTT: For the external events, I
don't believe -- I'm not absolutely sure, but I don't
recall any in that category.
MEMBER KRESS: Oh, the external -- seismic
would be easy. You just pick the frequency above
which you don't -- the 10-6 and above, you just forget
about them I guess.
MR. WESCOTT: Well, it's -- I'm going to
CHAIRMAN POWERS: Seismic is not easy at
MEMBER KRESS: I know. The selection of
which ones not to worry about is --
CHAIRMAN POWERS: I mean, I think you see
-- I think the speakers characterize it correctly.
What I see is a lot of things get screened out just on
plausibility. For instance, you don't really have to
worry about seepage as an external event, because
there is no lake or body of water there.
And, interestingly enough, I think they're
wrong about the tsunamis, because there is -- an
authority has looked at the Sea Mount collapse at the
Medeira Islands and concluded that once every 5,000
years there is a possibility of a tsunami that reaches
I don't fault him for ruling it out,
because I think a tsunami created by a Sea Mount
collapse in the Medeira Islands would give us things
to worry about other than the MOX facility.
MR. PERSINKO: The applicant's qualitative
definitions of highly unlikely are essentially a
single failure criterion.
CHAIRMAN POWERS: Yes. I think -- but, I
mean, he's been encyclopedic in listing what are the
possibilities, and most of them get ruled out just on
MR. PERSINKO: Yes.
CHAIRMAN POWERS: He includes meteorites
in his external events list.
I'm going to apologize to you. Three of
our members have had to go off and help former
Commissioner Rogers with an activity, and they will be
back as quickly as they can.
MR. WESCOTT: Okay. I think this is
coming up to the last slide?
Okay. The status of the MOX review at
this point, the safety analysis review. The staff is
still reviewing the hazards analysis for completeness.
I really can't give you a status on that -- in other
words, how many potential open items there are. There
is a couple of potentials, but we want to get more of
a consensus in-house before we go down --
CHAIRMAN POWERS: Just for your
information, I have already sent a note to our Fire
Protection Subcommittee that we're going to ask for
their assistance in reviewing this material. So as we
progress forward, we'll probably have some focus on
the fire protection issues here.
MR. WESCOTT: Okay.
CHAIRMAN POWERS: With people expert in
that facility, in that area. Fortunately, you have
most of the members of the Fire Protection
Subcommittee already here, just not the chairman.
MR. WESCOTT: Right. Okay. We are going
to be talking about fire protection later. We've got
requests for additional information pending in areas
of fire protection, load handling, confinement to
define adequacy of proposed safety strategies.
I think I mentioned the load handling
information request. We've also got some in fire
protection where we're trying to determine whether
combustible loading controls by themselves will be a
sufficient strategy for preventing some type of fire
events, and we're looking for some quantitative
CHAIRMAN POWERS: The problem at the
Savannah River site, as a whole, in the area of fire
protection analyses has always been transient
MR. WESCOTT: Right. That's exactly what
we're concerned about.
CHAIRMAN POWERS: Yes.
MR. WESCOTT: But we think that other
areas -- but certain areas we feel are going to have
different transient combustibles than others. So
rather than just having them pile up the combustibles
until we know, you know, that there is going to be --
I think we'd want to have them to take a look at just
exactly what they might possibly bring into a certain
area, say with fuel rods or something, where there's
no type of suppression, and, you know, what might
likely be left there, try to get an idea just how good
a combustible loading control by itself is.
CHAIRMAN POWERS: How do you -- well, this
may be jumping ahead of even where you are in your
review right now. But I think we're going to be real
interested in electrical circuit damage in fire
events. Have you given any thought to that?
MR. WESCOTT: Well, no, not specifically.
I know there's a possibility of chloride damage, and
so on, from, you know, burning of cable trays type of
thing. Sharon may have. I think I'm going to pass on
this. Incidentally, I'm a fire protection engineer,
but Sharon is our expert on --
-- so I'm going to keep my mouth shut on
fire protection stuff.
CHAIRMAN POWERS: I think we'll also be
very interested in filtration strategies, because
there is an awful lot of reliance on filters in this
MR. WESCOTT: Yes, there definitely is.
And we are very concerned about aspects of the
CHAIRMAN POWERS: And we're going to be
interested in discussing knock along and knock
through, and things like that.
MR. WESCOTT: Well, and, of course, design
basis concerns are still being evaluated and may
result in additional questions. So that's primarily
-- that's my presentation.
CHAIRMAN POWERS: Sure.
MR. BROWN: Good morning. My name is
David Brown. I'm the health physics or radiation
safety reviewer for the MOX project. I'm going to
talk specifically this morning about how the applicant
derived radiological consequences for specific events.
Next slide, please.
And specifically, I'll talk about how
source terms were derived, the major pathways for
release from a plutonium facility, and specifically,
once the material reaches its receptor, how we
calculated doses or concentrations in the environment.
Next slide, please.
The approaches, you know, of what has come
to be known as the five factor formula, it's described
in the nuclear fuel cycle facility accident analysis
handbook. It's a product of the five independent
factors I've shown here. On the next slide I'll get
into that a little more.
Next slide, please.
The first factor, of course, being the
material at risk, the applicant has looked at the
amount of material they may have in I think something
more than 200 individual process units throughout the
plant. That gives you a feel for the resolution of
the safety assessment at this point.
The damage ratio or the fraction of that
material at risk for any given process unit is
generally one, just conservatively. They're assuming
it all gets involved in the event. Both the
atmospheric release fractions and respirable fraction,
which are, of course, additional reduction factors on
the material at risk, are from the handbook 6410.
And the final, of course, factor, another
reduction factor, is the leak path factor, generally
that which would be used for two HEPA filters in
series. I'll talk about that a little bit more on the
With regard to that approach, the staff
just has two issues. There is the -- what we call the
intermediate consequence performance requirement to
keep concentrations at the restricted area boundary
below 5,000 times the values that appear in Appendix B
to Part 20.
It's release of material to the
environment, not intended to be a human dose, so the
application of the respirable fraction to reduce
emissions would not have been appropriate. We've
pointed that out, and that will be resolved.
We've also questioned the use of 99
percent efficiency for two consecutive stages of HEPA
filter for all events. I was particularly interested
in how that might be degraded during a fire event or,
say, an explosion event, that type of thing.
CHAIRMAN POWERS: It seems to me the issue
of HEPA filters is on whether you can stack -- I mean,
they are advertised as being 99 percent efficient
devices, or sometimes 98 efficient devices. But the
second stage is filtering material that was not
filtered, and it's difficult -- it's challenging to
believe that they retain that high level of efficiency
for material that has already passed through.
The second one is that you have presumably
some accumulation on these filtration devices during
normal operation, and you have a phenomena
colloquially known as knock along and knock through
from the particles that in an accident maybe it makes
more material available on the back side of the first
stage than you thought.
MR. BROWN: I think in the Department of
Energy, for example, I've heard that 99.9 percent may
be credited for the first stage, 99.8 -- marginally
lower efficiency -- for the second stage, perhaps to
account for the phenomena you described first.
With regard to the second phenomena, I
don't think that's a consideration at this point. You
know, but the applicant has pointed out 99 percent,
you know, is the efficiency they choose to use rather
than 99.9, for example.
Tim Johnson will provide a presentation on
the confinement system, including the ventilation
system, later. And he may shed some more light on
some of those questions.
CHAIRMAN POWERS: It's interesting, it
seems to me, that some of the facilities at Savannah
River have chosen to use sand filters rather than
HEPAs for their operations.
MR. BROWN: Yes.
CHAIRMAN POWERS: And it's interesting
they go back to the HEPAs here. Same filters, though.
MR. BROWN: It is something we have
discussed with the applicant. It's a consideration in
our current draft EIS as an alternative.
CHAIRMAN POWERS: Oh, okay.
MR. BROWN: Or what we call a technical
option. My understanding is it's both a fire
protection issue and, of course, a confinement
ventilation issue. I think, again, Tim Johnson and
Sharon may touch on that in their presentations.
CHAIRMAN POWERS: Good.
MR. BROWN: Next slide, please.
Again, as may be expected for a plutonium
facility, the pathway of most concern to the in-
facility worker would be the inhalation of plutonium
oxide or other plutonium compounds resulting from a
breach of confinement. Of course, the notable
exception to that would be a criticality event
involving direct radiation dose.
The strategy is to assume that the -- an
event affecting a facility worker is unacceptable. We
don't have, for example, quantitative unmitigated
doses in the construction authorization request for
facility workers. The safety strategies assume that
they will be unacceptably exposed and that we'll apply
principal SSCs to either prevent or mitigate the
The pathways are similar for SRS employees
immediately offsite and members of the public off the
Savannah River site. Inhalation is the predominant
pathway for accidents, and immersion becomes the
pathway for criticality. The staff will also take a
quick look at whatever marginal increase may be
attributable to Groundshine. We would expect that to
be pretty small.
Listed up there are the two codes we've
used for estimating the atmospheric dispersion of
contaminants moving downwind -- MACCS2 for members of
the public and ARCON96 for the worker.
Next slide, please.
Issues that were identified with respect
to pathway analysis were the so-called intermediate
consequence environmental performance requirement that
-- 5,000 times the Appendix B values is intended to be
calculated at the restricted area boundary, which for
this plant is just a little over 100 meters away.
The applicant calculated it at the
controlled area boundary, which they assume is five
miles away, and they will correct that. The
implication of that is that, as one might expect, that
this -- really, this is the bounding intermediate
consequence performance requirement. This is the
toughest one to meet. And I'll give you the results
at the end of my presentation for where they are in
meeting that performance requirement.
The second issue is one you touched on
earlier, and it's our resolution of the problem here.
Certainly, Part 70 has provisions for allowing members
of the public within the controlled area to be treated
as workers for the purposes of meeting their
The applicant has decided to meet the
provisions of the -- you know, the requirements of
those provisions in the rule. But it doesn't change
the status of these individuals with respect to
Part 20, and that was a point we needed to clarify
with the applicant. So --
CHAIRMAN POWERS: That's cute. Finesse
that one right there. Nice.
MR. BROWN: Moving on to the final stage
of the assessment, there are just some general, you
know, what I'll call issues specific to the plutonium
facility. We didn't identify any issues with the
applicant's calculation. Just that we may -- when
you're doing something like this, we will be looking
at both soluble and insoluble forms of the plutonium
compounds. That will have some bearing on how you
would calculate inhalation doses.
We'll also be looking at material that's
been purified and material that has not yet been
purified, the impure material having a slightly higher
dose consequence per gram.
CHAIRMAN POWERS: I am confused about the
status of our database on dose effectiveness for the
239 Plutonium isotope and completely ignorant as far
as the dose effectiveness for the Americium isotopes.
Can you give me -- I mean, what is it that we know?
What is it we don't know? And what is it we think we
MR. BROWN: Well, I think --
CHAIRMAN POWERS: A lot of the data comes
from -- a lot of the data comes, it seems to me, comes
from 238, which I wouldn't think would be directly
applicable but maybe it works okay for like what the
soluble fraction is. I don't know.
MR. BROWN: You're touching on an issue we
looked at very early on, which had to do with, you
know -- well, to do with some proposed research to
study could there be, for example, a super Class Y
plutonium compound, that type of thing. But for the
most part, for the purpose of this application, we're
using dose conversion factors that are provided in the
Federal Guidance Report Number 11.
And, for example, a Plutonium 239 nitrate
compound would be a Class W compound, and that is the
dose conversion factor we would use.
I think I understand what you mean. Many
of the earlier -- some of the studies were involving
Plutonium 238 oxide, which has a tendency to fragment
within the tissue of the lung and can actually lead to
I'll say unpredictable dose consequences, plus you're
doing bioassay and actually tracking how much is being
CHAIRMAN POWERS: You got highly variable
results as I recall.
MR. BROWN: Yes.
CHAIRMAN POWERS: I mean, in some cases no
effect. I mean, literally no effect. And in some
cases very severe effects.
MR. BROWN: I think we'll be dealing with
oxides that are created and temperatures that are
routinely encountered at other -- at similar plants
worldwide and even in the history of the U.S. Nothing
that should be really exceptional.
Next slide, please.
These are the applicant's calculations of
mitigated doses to both the Savannah River site
employee who is assumed to be 100 meters downwind and
a member of the public who is five miles downwind. If
you compare the -- this employee doses to the 25
millirem intermediate consequence criteria, you'll see
that they've met that with some considerable margin.
And the same is true for the public.
Next slide, please.
The other -- you know, and again, I've
mentioned it a couple of times -- the intermediate
consequence criterion of meeting the 5,000 times the
Appendix B concentrations, these are their
I should point out that there's a footnote
at the bottom of the screen. I hope most of you can
see it. Once we've resolved the issue of making sure
they've done this calculation at the correct
compliance point, which is not at the Savannah River
site boundary but at the -- essentially the protected
area fence of the facility, that they've not used the
respirable fraction to further reduce the source term.
Once we've resolved issues pertaining to
the actual rated removal efficiency of HEPAs, it may
be challenged by certain events. These numbers could
go up considerably. It wouldn't be a stretch to say
they could go up a factor of 1,000. So --
CHAIRMAN POWERS: The change in -- from
respirable fraction to actual release fraction will be
a big one.
MR. BROWN: It's typically about, I would
say, a factor of 10, perhaps a factor of 100. Moving
the boundary is about a factor of 100. Therein you
have anywhere from 1,000 to 10,000. So the meaning of
that, then, is that the -- they may come right up
against this particular performance requirement,
which, again, is an intermediate consequence event.
They need only show that this event is unlikely or
further mitigated. We're working on that now.
Last slide, please.
Now, this is just a summary of the issues
that are identified in deriving radiological
consequences. We talked about the fact that they use
a respirable fraction when perhaps they shouldn't
have. We may need to consider a leak path factor for
degraded HEPA filters, the fact that the environmental
performance requirement was calculated at the boundary
and not the restricted area boundary, and that the so-
called issue of the co-located worker I think we've
Are there any other questions?
CHAIRMAN POWERS: I come to the -- also to
the airborne release fractions and took them out of
6410 -- I think they came from.
MR. BROWN: That's right.
CHAIRMAN POWERS: Is that the Meshima
MR. BROWN: Essentially, yes.
CHAIRMAN POWERS: So the applicability is
always going to be a question on that, isn't it?
MR. BROWN: Yes. I mean, given the P
value may not specifically match the experiment.
CHAIRMAN POWERS: Yes. Yes. He put in
that collection what he had, and he may not have the
exact thing that -- that's really wanted there. It's
like Perry's Handbook of Chemical Engineering. It
will give you an answer. Doesn't tell you whether
it's a good answer or not; it will give you an answer.
And so are we looking at -- with any care
at the applicability of the airborne release
MR. BROWN: We will. At this time, we
have not studied that in detail.
CHAIRMAN POWERS: I mean, I -- there may
not be much you can do, but you can certainly see how
bounding they were on those.
MR. BROWN: Certainly, we will look at --
you know, if it was for dropping an oxide powder, then
we want to be sure that that was properly used for an
event in which there is an oxide powder.
CHAIRMAN POWERS: Yes. I think you're not
going to have too much trouble with that one. I think
where it more likely is when you have the combustion
events, aerosolizing things that just by the
difficulty of doing the experiment they probably
didn't do the kind of event you really would have
liked to have seen. And that's the one where you've
got to look and say carefully what -- how bounding of
a value do they really pick.
MR. BROWN: I might just suggest, I
suppose that in the event that we simply can't agree
on a bounding consequence, the applicant has the
option to simply show that the accident is prevented.
CHAIRMAN POWERS: Sure.
MR. BROWN: Which is unique to Part 70.
MEMBER LEITCH: Schematically, the aqueous
processing unit that was shown I guess at the very
first slide is at the front end of this whole process,
and that portion of the activity is regulated by DOE.
Is that --
MR. BROWN: No. The entire facility is
regulated by the NRC.
MEMBER LEITCH: The entire facility is.
MR. BROWN: If I may just clarify that the
-- the feedstock, the plutonium powder, will be
prepared in a different DOE facility.
MEMBER LEITCH: Okay. And it comes in in
the form of powder, then, is that --
MR. BROWN: Plutonium oxide powder.
CHAIRMAN POWERS: One would just really
love to see the trade study that resulted in taking a
metal tray into an oxide and redissolving the oxide to
polish it and make it back into an oxide. Why that
was chosen as the route, I would just love to see the
trade study that gave that. That's not these
MEMBER LEITCH: That process takes place
elsewhere at Savannah River or elsewhere?
MR. BROWN: As it has been described, say,
most recently in the DOE EIS for the project, it would
be right next door.
MEMBER LEITCH: But the aqueous polishing
process is an integral part of this facility. In
other words, in the plot plan where you showed the 400
by 400 --
MR. BROWN: It was barely visible as is
somewhat -- to a different square in that top plan.
MEMBER LEITCH: I guess I misunderstood
perhaps at the very beginning. I thought there was a
portion of this that was DOE regulated and a portion
that was NRC regulated.
MR. BROWN: That's right. And it is --
the DOE activity will be at a physically separate
plant, not -- and this will -- everything within the
protected area fence here will -- you know, to the
extent that it's licensed material, will be NRC
CHAIRMAN POWERS: The waste stream coming
out of the facility will go back into the DOE complex?
MR. BROWN: Yes.
CHAIRMAN POWERS: And presumably in one of
their tanks, and then eventually to the DWPF and
things like that?
MR. BROWN: That's the plan. That's
MEMBER LEITCH: Okay. Thanks. I
MR. BROWN: Thank you.
CHAIRMAN POWERS: So we don't have an
issue of a long-term accumulation of a waste stream
MR. BROWN: We should not. No, the plan
is to --
MEMBER LEITCH: We can discuss that a
MR. BROWN: Right. We can always talk
MR. MURRAY: Okay. Good morning
everybody. My name is Alex Murray. I am the chemical
safety reviewer for the proposed MOX facility. I am
also a supporting reviewer for ISA on issues related
to chemical safety.
Next slide, please.
This is just a quick overview of my
presentation. I'm going to just give you a very brief
discussion of the main chemical process areas in this
facility. Some of the details are considered
proprietary by the applicant, so if you have questions
which require detailed answers, we may have to get
back to you in a different forum.
I'm also going to discuss some of the
proposed design bases from the applicant. I'm going
to give a quick overview of where the review stands
right now. It is very much a work in progress, and
I'll give you some idea about current issues that we
Next slide, please.
Just to -- as we have discussed, there are
several main chemical process areas in this facility.
There's the AP area, aqueous polishing. Its principal
function/objective is to purify the plutonium and
basically separate out gallium, uranium, and some
There also is the MOX process, which is
essentially a powder processing route that actually
makes the fuel rods and assemblies. To support these
areas there are some chemical reagents, storage, and
mixing areas. Some are outside the actual MOX
handling building and would be regulated under OSHA.
Some are within the building and would be regulated by
the NRC because of their potential effects upon the
handling of licensed radioactive material.
And as we have with the chemical area,
there are both chemical and radioactive radiochemical
Next slide, please.
Now, discussing aqueous polishing, it's
important to note that there are some modifications to
the standard PUREX process routes which have presented
some hazards which might require some controls or
principal SSCs in this facility.
First off, the plutonium dioxide which
comes from DOE, a separate DOE facility proposed at
Savannah River, is actually dissolved using an
electrochemical process. And there are some issues
The PUREX process itself is actually
tweaked, adjusted, optimized, to improve the
separation factors. Okay. There are some very fine
oxidation state adjustments which I'll mention on the
-- one of the next slides, and so forth.
I should add that at the very early stages
of this project there were some discussions about,
"Oh, why can't we use a dry process to purify the
weapons grade plutonium?" And the reason is it didn't
work. Okay. There are many other issues in addition
to the fact that it was basically ineffective for
Once the plutonium has been purified, the
proposed facility would precipitate it as an oxalate,
a very standard step. And I should add that in the
aqueous polishing area many of these operations are
very similar to operations that are performed in some
portions of the LaHague facility in France. They also
have been performed at some of the DOE facilities in
Next slide, please.
Okay. Computers are wonderful. That is
actually PuO2. Okay. For the dissolution step, okay,
the plutonium dioxide powder would come from a DOE
regulated facility. It was on one of Drew's slides.
It is referred to as the pit disassembly and
conversion facility. Okay. That is regulated by DOE.
The dissolution uses nitric acid
principally as the dissolving medium. However,
because of concerns about processing rates, kinetics
if you will, they use -- the proposed process uses a
silver(II) ion, a very strong oxidizing agent, to
assist with the dissolution.
Because silver(II) is also extremely
corrosive and has some other issues, the applicant has
proposed means to reduce, in effect eliminate, the
potential hazard associated with that reagent once the
plutonium has been dissolved. Of course, the
electrochemistry -- you have both heat, gases, and,
you know, sort of like an interesting combination of
potential hazards from the electrochemical operations.
And also in the dissolution step the
applicant proposes to initiate isotopic dissolution of
uranium 235. Now, you may wonder, gee, why if we're
discussing weapons grade plutonium is there
uranium 235. It turns out that there -- that about
one percent of the heavy metal U235 from the alpha
decay of plutonium 239.
Next slide, please.
Okay. In the actual purification step, it
is a PUREX process. The PUREX process is optimized.
There are some very fine valence adjustments to
improve the extraction coefficients of plutonium.
Most notably, most of the plutonium is reduced from
the plus six state to the plus four state. This
improves the separation factor.
After it has been separated, there is some
other oxidation adjustments which basically allow the
plutonium to recover by going to the plus three state.
Then, there are some other adjustments made, so it
precipitates better with oxalic acid, the oxalate
precipitation steps. They take it back to the plus
All of the reagents used for these
operations do present some potential hazards which we
are reviewing to see if any potential PSSCs are
Finally, there are some solvent washing
and purification steps. These are actually done in
mixer settlers, not the columns which are used for the
actual plutonium purification. And this is primarily
-- this is a PUREX process, but it is primarily in a
Dodecane diluent as the actual solvent.
Next slide, please.
Okay. Once the plutonium has been
purified, it is just recovered by an oxalic acid
precipitation. There are some fine pH adjustments,
again, to improve the recovery, get some additional
decontamination factors from some of the potential
The oxalate is filtered and then fired in
a calcined and oxygen atmosphere, and then this
purified material is sent on to the actual MOX powder
Next slide, please.
As part of aqueous polishing, you do
generate some liquid streams which require some
processing for recovery of useful reagents before they
are sent to waste management at the Savannah River
site. It should be noted that the majority of these
recovery operations for things such as silver, some of
what they call the oxalic mother liquors in the
These have all performed on -- all of
these operations are performed on high alpha
contaminated streams. Okay? So we're looking at some
of the potential issues and hazards associated with
those to see if any principal SSCs are needed.
Nitric acid is recovered by evaporators
and subsequently rectified, distilled, to get it back
up to strength to be recycled within the process, and
that step also has some potential hazards which we'll
Next slide, please.
Okay. Just very quickly, the MOX powder
area -- this is simply a powder processing line. It
is based upon the advance MIMAS process from France,
a lot of micronization of the powders. Ultimately,
the powders are formed into pellets, sintered, and
then placed into the fuel rods and the rods into
From the chemical safety perspective in
this area, the main areas of potential concern have to
do with a lot of inert gas use and also around the
sintering furnaces where there are hydrogen/oxygen --
I mean, hydrogen/argon mixtures used. And I should
note for this area, this -- the processing steps are
very similar to those at the operating MELOX facility
Next slide, please.
CHAIRMAN POWERS: Do they do the sintering
with just forming gas, or do they --
MR. MURRAY: I'm sorry?
CHAIRMAN POWERS: Do they do the sintering
under an atmosphere of argon/hydrogen that --
MR. MURRAY: At MELOX?
CHAIRMAN POWERS: At four percent like
hydrogen or something like that?
MR. MURRAY: In the proposed facility,
there is actually a range.
CHAIRMAN POWERS: A range.
MR. MURRAY: Okay. And some of the
details on the range are proprietary.
Okay. Just to give you a quick overview
of some of the applicant's proposed principal
structures, systems, and components, and their design
bases and potential controls, for the public, a
receptor in the chem safety area, the consequences
were judged to be low and no PSSCs were proposed.
Similarly, for the Savannah River site
worker, no PSSCs are proposed. For the facility
worker, in the area of chemical safety, the applicant
has proposed that the emergency control room HVAC
system would be a PSSC, and the applicant has stated
that they believe most of the radiological-related
PSSCs will provide adequate protection for chemical
safety type events. And, hence, no additional chem
safety PSSCs are necessary.
Having said that, if you could go to the
next slide, please.
Within the text of the construction
authorization request, there are actually PSSCs
proposed for chem safety, and I've listed these here.
There are a lot of proposed administrative type
controls for chemical makeup, for reagent
concentrations, and so forth, the proposed controls,
PSSCs, on some of the vents and offgases. Some of
these are interrelated with radiological-related
Also, the applicant has proposed PSSCs to
ensure that there are non-explosive mixtures, and I've
listed some here. However, as our review is
continuing, we are finding that the specificity might
need more definition.
MEMBER LEITCH: Just a question for
understanding on the previous slide.
MR. MURRAY: Sure.
MEMBER LEITCH: It says emergency control
room AC system. Is that for an emergency control
room? Or should that say control room emergency AC
MR. MURRAY: That is actually for an
emergency control room.
MEMBER LEITCH: Okay. That was my point.
MR. MURRAY: Yes.
MEMBER LEITCH: In other words, there is
an emergency control room.
MR. MURRAY: Yes.
MEMBER LEITCH: And the thing that would
be a PSSC is the air conditioning system for that
MR. MURRAY: That's correct.
MEMBER LEITCH: Okay. I understand.
MR. MURRAY: That's correct. That's
MEMBER LEITCH: But not for the main
control room apparently?
MR. MURRAY: With the documentation and
the discussions that we have had so far, not at this
time, no. The review is still continuing. Okay?
MEMBER LEITCH: Thank you.
MR. MURRAY: Okay. Just to give you a
quick overview of the status of the review and some of
the activities, we are -- the review is continuing.
It is a work in progress. We have looked at the
construction authorization request, the RAI responses.
We are looking at independent sources of information
in the literature, including DOE peer reviewed
documents and what have you.
We are having discussions with the
applicant. Some of these are in public meetings.
Some of these are documented phone calls. And also we
plan additional meetings and reviews. We currently
are working on a very preliminary -- very, very rough
draft of the chem safety sections of the evaluation
Next slide, please.
Okay. Our main findings to date are, as
I previously mentioned, we find a general lack of
specificity for some of the chemical principal
structures, systems, and components, and their
associated design bases. As we read the documents,
the responses from the applicant, and as we review the
literature, we are finding that there are many implied
or potentially implied PSSCs and design bases.
We also notice there is, particularly in
the chemical area, a heavy reliance on operators and
Next slide, please.
Okay. I've just listed some of the areas
where we have some current issues under review and
discussions. Once again, admin controls, how do you
get to the highly unlikely regime and minimize the
consequences, the high alpha waste streams, how they
are controlled to basically do the recovery functions
safely and appropriately, and then ultimately the
waste going on to the Savannah River site.
The electrolyzers, the proposed facility
has three electrolyzers. Right now, two are for
dissolution, one is for recovery of the silver which
is used in dissolution.
Evaporators, this is the red oil concern,
the nitrated tributyl phosphate esters. The proposed
facility has at least three areas where evaporators
are used for reagent recovery, concentration, recycle,
etcetera. And also, we have an issue we are reviewing
in the area of the uranium 235 -- where it goes in the
process, how it is diluted, where it is diluted, what
the intermediate assay levels are, and so forth.
CHAIRMAN POWERS: In the issue of red oil,
I got the impression that the principal safety control
on that was to control the temperature.
MR. MURRAY: That is what the applicant
has proposed, yes.
CHAIRMAN POWERS: And my initial reaction
to that was -- I've probably gotten out of date on
where we stand on oil, red oil issues. But my
recollection is --
MR. MURRAY: I'm sure you're quite
CHAIRMAN POWERS: My recollection is that
we had a poor understanding of the formation of this
material, that when we have tried to form it it's a
hit and miss sort of thing, that we have never been
able to convince everyone that what we form in the
laboratory is exactly what we seem to form in the
accidents, and that we couldn't say that there was a
temperature threshold for the formation of red oil.
MR. MURRAY: Well, this is an area that we
are reviewing and discussing with the applicant.
There are concerns that we have in this area. There
have been at least five events within the DOE complex
over the years, some as recently as the 1970s. Okay?
In the late 1980s, DOE did issue a summary report
which basically was based upon the temperature
However, there have been a couple of
incidents since then, most notably overseas, the
Tomsk-Sevin area in the former Soviet Union. That
appears to involve some other factors beyond
temperature. DOE has done a lot of work in the mid
and late 1990s looking into this issue some more. And
all I can say is right now we are continuing,
obviously, to --
CHAIRMAN POWERS: Stay tuned, huh?
MR. MURRAY: Stay tuned, yes.
CHAIRMAN POWERS: Good.
MR. MURRAY: Yes.
MEMBER LEITCH: Has there been any
discussion at this point of staffing levels or
operator qualifications or training, or is that all
premature to ask those kinds of questions?
MR. MURRAY: At this stage, yes. Okay.
In the area of admin controls, we have been in
discussions with the applicant about how -- how do you
show independence, how do you show redundancy, how do
you ultimately attain the highly unlikely threshold
for, if you will, chem safety events which could have
MEMBER LEITCH: Does this generally tend
to be a batch process or a stream process? In other
words, is this the kind of thing that once this
process is up and running it runs for -- on a
continuous basis around the clock, or is it a batch
kind of an operation?
MR. MURRAY: The majority of the plant, of
the proposed design, would run in what I would call a
more continuous manner. Some steps within it, notably
the dissolution area, is a batch, a semi-batch sort of
processing area. Some of the evaporators function in
what I would call a semi-batch mode. But it is
predominantly a continuous process.
MEMBER LEITCH: Okay.
MR. MURRAY: And the applicant, in their
description of the process, have proposed sort of like
idle modes, particularly in the solvent extraction
area, where it can sort of keep running but it doesn't
have to be fed fresh materials.
MEMBER LEITCH: Thank you.
MR. MURRAY: You're welcome.
Any other questions? I know earlier on
you had a question on the waste streams. In the
proposed design, the applicant is proposing to batch
the waste, the high alpha waste, to the Savannah River
site via a double-contained underground pipeline.
And the batches would be, oh, about a
weekly sort of operation with on the order of a few
thousand gallons. They think it'll be between one and
two thousand gallons.
MEMBER LEITCH: And in order of magnitude,
how long is this pipeline?
MR. MURRAY: We do not have any specifics
on that at this time. We are discussing this with the
CHAIRMAN POWERS: Okay. Well, at this
point, we're scheduled to take a break, which is a
little longer because members have to do some
interviewing I think.
MR. MURRAY: Okay.
CHAIRMAN POWERS: So we will recess until
a quarter of the hour.
(Whereupon, the proceedings in the
foregoing matter went off the record at
10:17 a.m. and went back on the record at
CHAIRMAN POWERS: I think we can come into
My agenda says that Margaret Chatterton is
going to talk to us next. Maybe I'm in error. Nope?
Well, in that case, here's Margaret.
MR. TRIPP: How are you doing? My name is
Chris Tripp, and I'll be talking about the criticality
safety design for the MOX facility for the
Next slide, please?
Criticality safety is one of the dominant
risks at the facility, along with fire safety. And
part of the reason for that is because of the type of
processes and types and forms of materials that are
going on -- are going to be used at the facility.
The criticality risk associated with this
plant is similar, in our view, to several other NRC-
regulated facilities; specifically, the high enriched
uranium facilities, NFS and BWXT. Those facilities
involve high enriched uranium. Here we're dealing
And the reason for that is out of the 22
criticality accidents that have occurred at processing
plants in the United States, Russia, Japan, and the
United Kingdom, all but three have involved either
plutonium or iron-enriched uranium, and they have all
involved solution forms because of the small critical
masses, the difficulty in controlling these types of
material configurations, and so forth. And we have
similar types of processes here.
The MOX plant is, as has been stated
previously, based on the MELOX and LaHague facilities.
And from the standpoint of criticality safety, the
LaHague type processes, the aqueous polishing process,
has the majority of the criticality risk because we're
dealing with solutions.
There are some differences between the
French plants and the proposed American plant, and
some of the equipment dimensions are different and has
criticality implications, because of two things,
because of Americanization where they have to make the
plant conform to American standards, and also the more
significant factor is that this plant is using weapons
grade as opposed to reactor grade plutonium as is in
the French plant.
The areas of greatest risk are where you
have material configurations that are difficult to
control, particularly Plutonium 239 solution, but also
in the MOX process where you're dealing with
uncontained powder. And that is -- the majority of
the criticality issues are at the front end before the
material is isotopically diluted with depleted
At this point, specific controls, items
relied on for safety, have not been defined for
criticality hazards, being a worker safety issue --
and we'll go into that in more detail. But the basic
parameters of interest are the aqueous polishing phase
would rely mostly on favorable geometry for plutonium
nitrate solutions as well as spacing between the
CHAIRMAN POWERS: I guess I am surprised
that you don't also cite acidity control and avoiding
the plutonium hydroxide precipitations.
MR. TRIPP: Well, the concentration is not
credited for criticality purposes.
CHAIRMAN POWERS: No. What I'm talking
about is the tendency of plutonium nitrate, if you
drop too low in acidity, to drop out this amorphous
precipitate. That's an oxydroxide material. It's
been responsible for at least one criticality event.
MR. TRIPP: Yes, that's true. But in this
case, the -- they're not taking credit for the
concentration, so it's being assumed it's at an
optimal concentration. So, therefore, if it would
precipitate out, you'd tend to have an undermoderated
solution. It would probably be less reactive than the
optimally moderated case.
Now, the chemical form is credited because
the nitrate acts as a neutron poison, a mild neutron
CHAIRMAN POWERS: Well, I'm going to have
to think about that a little bit, because I get very
nervous when we don't have good acidity control on
MR. TRIPP: Yes. Well, that's certainly
a concern, and the chemical balancing of the process
is important to keeping the solution out of -- keeping
the uranium -- plutonium in this case -- out of the
raffinate stream, which is another criticality hazard
that I should mention.
In the MOX process, we have -- the main
controls/modes are the isotopic control, where you're
mixing it with depleted uranium after the blending
stage. That's being credited for criticality safety
-- and also moderation, keeping the powder dry.
The master blend is to take the plutonium
oxide powder and to blend it down to about 20 weight
percent in Pu, with the depleted uranium, and then
later on it's further diluted to between two and six
weight percent plutonium. And the blending, as I
said, is crucial to ensuring the right isotopic mix.
So that's some information about the
inherent risk of the facility. It should be pointed
out that the majority of the facility is going to rely
on passive engineered controls, particularly safe
geometry, and probably to a greater extent than being
based on a more modern design -- a greater extent
relying on favorable geometry than a lot of U.S.
plants. So that will -- should significantly reduce
the risk associated with the facility.
CHAIRMAN POWERS: I'm just surprised my
distinguished colleague from Tennessee didn't salute
the advice to keep your powder dry.
MR. TRIPP: Very important for
criticality and --
CHAIRMAN POWERS: Not going to volunteer
MR. TRIPP: Now, I'm just going to quickly
summarize the regulatory requirements from Part 70.
As for most of the safety disciplines, it's very non-
prescriptive. They are free to choose pretty much any
high dose relied on for safety as long as they meet
the performance requirements of the rule. In fact,
the only specific SSC that's mentioned for safety is
the criticality alarm.
They have to make high consequence events
highly unlikely, and that's -- typically, criticality
is considered highly unlikely by default. At least in
this case, it is, so when we're talking about the risk
we're talking basically about likelihood associated
with preventing criticality.
They're required to maintain
subcriticality, and that includes using an approved
margin of subcriticality, which is based on code
validations that we'll talk about in a little bit.
And, finally, in 70.64, they're required
to adhere to the double contingency principle, such
that two -- at least two unlikely and independent
changes have to occur before criticality is possible.
And that is really only applicable for new plants or
new processes at existing plants. The reason for that
is a lot of -- some of the older plants have
historically not been able to meet double contingency,
because you're dealing with bulk quantities of powder
and other things. And then, of course, the SRP goes
into a lot more detail on this.
Next slide, please?
Required to ensure that the design basis
of the principal SSCs provide reasonable assurance of
safety. I'll quickly go over this, since I know you
heard this in more detail on the 14th.
At this point, there have really been no
principal SSCs or IROFS identified for criticality
safety. That will come more during the review of the
ISA summary, along with the license application. So
what do we have to rely on for safety?
Most of the assurance is based on having
an adequate NCS program, and that follows the typical
DOE model and also the model we adopted for the
gaseous diffusion plants, where most of the details
referred to the program, and the regulator is mainly
overseeing the structure of the program.
And that will be relied on in the
construction stage, and then the component-level
review, as with the other Part 70 facilities, will be
more in the operating phase.
So I'd like now to turn to the open
issues, of which there are three. There were several
RAI questions asked. About 40 in all I think pertain
to criticality issues. And we've reached resolution
on all but three issues, and they are the NCS staff
qualifications, the -- what's an acceptable
subcritical margin, and an issue related to how we
meet the performance requirements.
And on these two issues on this slide we
have provided them with a summary of industry
experience, industry licensing precedent I should say,
on what we've accepted for other plants, understanding
that this plant has some unique issues associated with
For the staff qualifications, we are only
interested in the construction phase, because part of
having a reasonable assurance that the plant could be
designed safely is our assurance in the qualifications
of the people doing the safety design. So we're only
interested in the roles and responsibilities
associated with design activities, not operation. And
primarily we're looking at the education and
experience levels associated with these individuals.
And what has been accepted at the
different plants varies across the spectrum. But in
this case, a couple of the unique issues are that this
is a brand-new facility. There really is no facility-
specific experience, which is often credited in
saying, for instance, you have to have two years of
industry or facility experience.
The other is the fact that most of the
industry experience is drawn from uranium plants, and
criticality safety depends a lot on the judgment of
the analyst. And so the staff has -- believes that
it's necessary that NCS staff have some specific
plutonium or MOX experience.
So it's a question of, what would be the
-- how transferable would be experience at other
plants? And some of that experience they can get.
There is experience on the DOE side, of course, with
plutonium. But that's one thing that we are in the
process of discussing.
The other secondary issue is, what's an
acceptable subcritical margin? And I'll quickly go
through this. This is the standard equation for
calculated multiplication factor plus uncertainties --
has to be less than what's known as the upper
subcritical limit, which is one minus the
calculational bias minus the uncertainty in the bias
minus -- delta Km is an arbitrary or administrative
And the bias is the difference between the
experimental value, typically 1.0 for K effective of
a critical experiment and the calculated value. And
all the statistical effects are taken up in the bias
and the uncertainty in the bias. And this
administrative margin is meant to account for
unquantified or unknown uncertainties, such as the
fact that what you're actually modeling differs from
any of the benchmarks. Well, how important is that
kind of effect?
And so what the applicant has proposed is
-- and this actually goes beyond what most of our
licensees do in practice -- is to split the types of
processes at the plant into five main areas and
perform a separate validation, which could result in
a separate bias and administrative margin for each
And whereas the techniques for determining
the bias are well understood, the techniques -- there
is no real applicable guidance on the administrative
margin and what is acceptable. So, again, we provided
them with precedent on what was accepted at other
facilities, with the understanding that there are some
differences because you have -- plutonium physics is
slightly different, significantly different in some
The administrative margin of .05 has
typically been accepted at most uranium plants.
That's based on a rule of thumb, but there has still
always been a requirement that the licensee or
applicant justify it on a case-by-case basis. And
that's particularly true in -- for a plutonium or MOX
plant where we have different neutron physics.
The other complicating factor in the
validation, which we're looking at as a significant
part of the design basis, because it tells to what
maximum K effective you can design the plant to, is
the fact that for a lot of these systems, particularly
the three types of systems listed in Part 2, there is
not really a lot of critical benchmark experiment data
So a typical statistical technique may
need to be augmented, and there are some techniques
such as sensitivity uncertainty methodology, which is
currently being developed at Oak Ridge National
Laboratory, that may be applicable. It's just
different from what the staff has had to review in the
Finally, I turn to the -- what's probably
the most significant of the open issues, and that is,
what's the relationship between the two regulatory
requirements to be doubly contingent and to assure
that high consequence events are highly unlikely?
Well, I know you heard some of this the
other day on the index likelihood method. So I won't
go into the details of what that is associated with.
The MOX SRP, standard review plan, Appendix A, is
based on the Part 70 standard review plan and has a
safe technique proposed.
Since the SRP has come out, we have
approved ISA plans for BWXT and NFS on the Part 70
side, and so there are plants that have proposed
methods that are acceptable to the staff that have
Now, for hazards other than criticality,
DCS has proposed meeting the index likelihood method.
The reason for excluding criticality, as we understand
it, is criticality is viewed as a facility worker
hazard. So, therefore, there are many -- the approach
is one of prevention.
There are many different -- sometimes
dozens of accident sequences that have to be prevented
against. Unlike a site worker or a public type of
consequence, you can't simply mitigate the bounding
accident. So there's a great deal of analysis
And I believe on the ISAs that we've seen,
about probably more than half of the accident
sequences involve criticality hazards for that reason.
And so what DCS has proposed was to meet -- use the
commitment to double contingency and say that was
sufficient to ensure that criticality is highly
The industry has traditionally used a
deterministic approach that relies on the judgment of
the analyst, rather than any kind of quantitative or
qualitative assessment of reliability of the barriers
relied on. So, therefore, there's a lot of
subjectivity associated with that kind of approach.
And the other thing that has been proposed
is what DCS calls robust double contingency, and that
would be a commitment to meet double contingency plus
a generic commitment to meet management measures and
the applicable criticality ANSI standards, of which
there are probably about 20 in total.
And, again, on an accident sequence basis,
that does -- it simply is too vague to give assurance
that in all cases they will beat the standard of being
highly unlikely. The wording of the double
contingency principle is taken from an ANSI standard,
and it's not defined in terms of a performance
And the last bullet, let me say that what
the staff has determined is that the robust double
contingency defined above as double contingency
principle plus management measures and ANSI standards
is what we have said is not sufficient. We are still
discussing what would a possible form of a robust
double contingency be that would be sufficient to meet
the performance requirements of the rule. And those
discussions are ongoing.
So that is basically where the status of
the review is now. If you have any further
MEMBER BONACA: I have a question.
MEMBER LEITCH: I have a question. It
seems to me that criticality prevention is -- if I
understand what you said correctly, is primarily the
geometry. There are passive things in the way the
facility is built, particularly the geometry for
prevention of criticality, supplemented perhaps by
operator actions and administrative procedures.
But are there no engineered systems to
mitigate criticality? In other words, it seems like
everything is geared towards preventing the initiating
event. But what about mitigative strategies?
MR. TRIPP: Okay. And you're quite right
in that the fact they're relying on geometry and other
passive controls, that all comes out of this hierarchy
of controls that was talked about during the ISA
But the approach taken at -- by the NRC is
that criticality is something that is to be prevented.
It's undesirable to have a criticality, regardless of
the actual dose consequences. At a minimum, it
involves a lot of cleanup activities, and so forth.
The only real mitigation is from 70.23,
which is requirement to have a criticality alarm
system. And, of course, that won't mitigate the dose
to the person that's there when the initial burst of
the criticality goes off, but it could mitigate dose
to further individuals. And also, there is -- there
are requirements to have emergency procedures and
protocols in place.
In DOE, there are some -- DOE facilities,
some of them are shielded, and they do take credit for
that in allowing criticality to be less than highly
unlikely. But the NRC has never taken the approach
that you can substitute mitigation for prevention for
a criticality accident.
MEMBER BONACA: Okay. I had --
MEMBER LEITCH: Go ahead.
MEMBER BONACA: I had a question on the --
you made a reference to 22 process accidents that have
occurred worldwide, and at the highly enriched uranium
facilities. And I was curious to know, first of all,
is there a dominant sequence that has occurred? I
mean, what is the dominant cause for these accidents?
And, second, could you comment on the consequences?
MR. TRIPP: Certainly, yes. As I've said,
all of these have occurred in process tanks or vessels
of some type. Typically, columns relied on for
favorable geometry, and so the typical sequence a lot
of the time is you have something that has an
inadvertent transfer to unfavorable geometry, such as
to a wastewater tank or some other large geometry
vessel. There are variations on that, but I think
several fall under that category.
MEMBER BONACA: Right.
MR. TRIPP: As far as the consequences
have been, there have been -- most of them have not
involved fatalities. Some of them have. I think two
or three is the maximum number, and that's just --
that's from the worker that's in the immediate area.
MEMBER BONACA: So to the personnel.
MR. TRIPP: Right.
MEMBER BONACA: The release is outside the
-- it's at the site.
MR. TRIPP: Right. And that's typically
because it's usually operators involved in the
MEMBER BONACA: Okay. Thank you.
MR. TRIPP: Okay. I'd like --
MEMBER LEITCH: I asked the question of an
earlier presenter about operator training, and I guess
the answer I got was we were a little too far
premature to discuss that. But you alluded to the
fact that you have given at least some thought to how
these operators might be qualified.
MR. TRIPP: Yes. We were -- actually, I
was talking about the criticality safety staff who
were involved in the design of the facility and what
their experience and qualifications are. I would
agree it's a little early to be talking about the
operator training, although that would be one of the
management measures that we would expect to be --
MEMBER LEITCH: Yes.
MR. TRIPP: -- applied in the next stage.
MEMBER LEITCH: And there again, as you
indicate here, that there's precious little experience
to draw on. I guess the same would be the case with
MR. TRIPP: That would probably be the
case, unless you go to the DOE complex.
MEMBER LEITCH: Yes. Okay. But, again,
I'm hearing that it's just premature to talk about
that, but it's a topic that I'm very interested in.
MR. TRIPP: Yes. That was something that
will be very important later on.
MEMBER LEITCH: Yes, right. Thank you.
MR. PERSINKO: I'd like to make a comment.
You asked about engineered features with respect to
criticality control. As I mentioned earlier, the
system is a highly automated system. There is an
instrumentation and control system referred to as the
MMIS system, which material is not allowed to move
from one station to another station unless the
permissive is given by the MMIS system.
The system keeps track of material
inventory at various posts, and then before material
can move from post A to post B the computer system --
the instrumentation and control system checks to see
whether it's permissive, whether the material can move
to this area or not, with respect to criticality
We will get into that particular system
more when John Calvert talks about the digital I&C
MEMBER LEITCH: Thank you.
CHAIRMAN POWERS: Any other questions
about the criticality safety? I think we can move on.
MS. STEELE: Good morning. Can you hear
My name is Sharon Steele, and I'll be
presenting the fire safety portion of the briefing.
I will begin with a brief discussion of guidance in
the standard review plan and the applicant's proposals
for the facility couched in terms of the major aspects
of fire safety. I will discuss some of the open items
and then follow up with a summary.
In developing the standard review plan, we
relied on NRC guidance for fuel cycle facilities and
reactors, where appropriate. We also drew heavily
from DOE standards, particularly the one -- the fire
protection criteria, and also required conformance to
National Fire Protection Association codes and
Based on the elements of a standard review
plan and on accepted engineering practice, there are
some major aspects of fire safety that I'd like to
briefly touch on, and they are administrative controls
or -- and development of a fire protection program
which helps to prevent a fire from occurring. Also,
automatic detection and suppression systems provide
the capacity to extinguish a fire if they occur.
Manual firefighting capabilities are
important as well as --
CHAIRMAN POWERS: Do you really give
credit for automatic systems extinguishing a fire?
MS. STEELE: Sometimes -- in some places,
automatic suppression systems are considered principal
structures, systems, and components. But for the most
part, they're used as defense-in-depth strategy.
CHAIRMAN POWERS: The suppression -- you
know, I can imagine giving credit, but giving credit
for an automatic system to actually extinguish the
MS. STEELE: You're referring to the
detection, then, automatic detection concerning --
CHAIRMAN POWERS: Detection you can do and
suppression from an automatic system. But to
extinguish the fire with an automatic system seems to
MS. STEELE: Right. Normally, when you
use fire -- water-based sprinkler systems, I think the
probability of success is 96 percent. Other systems
are a little bit lower.
Also, one of the major aspects of fire
safety is compartmentation, which would help prevent
the spread of fires to other parts of the building.
And, finally, the fire hazards analysis is an
important part because it's a common thread throughout
the various aspects of fire safety. So I'll discuss
The fire hazards analysis, or FHA, isa
systematic analysis of the fire hazards inside and
outside of the facility, and it is used to determine
the adequacy of plant fire safety. When performing a
fire hazards analysis, the facility is divided into
discrete fire areas, and the risk or the consequences
of ignition and combustion scenarios are evaluated.
The fire hazards analysis is used to
develop design basis fire scenarios from which
principal structures, systems, and components are
developed. The applicant has provided a preliminary
fire hazards analysis, which we were able to review
onsite, and they are continuing to develop the fire
hazards analysis in conjunction with the integrated
The applicant has committed to develop
administrative controls in the license possession
stage, and these controls will include procedures for
the storage and control of ignition sources and
combustible items. It will include periodic
surveillances of the physical fire protection features
to ensure that these systems are operational, and also
periodic surveillances of the transient combustibles
to ensure that limits are not exceeded.
The applicant has proposed administrative
controls as a principal structure, system, and
component in some cases. They have also committed to
develop a fire protection program which will describe
the policy with regard to protecting items relied on
The fire protection program will also
describe personnel and lines of management for the
development of procedures for training for combustion
controls and procedures for maintenance, testing, and
inspection of fire protection features. It will also
address the development of controls for design
changes, recordkeeping, and fire prevention activities
such as fire emergency planning.
The applicant --
MEMBER LEITCH: Can you talk about --
MS. STEELE: Sorry.
MEMBER LEITCH: -- the transient
combustibles? I'm used to thinking of transient
combustibles as trash, basically, that could be stored
in the facility. Are some of these process streams
MS. STEELE: Yes.
MEMBER LEITCH: In other words --
MS. STEELE: Yes, they are. But in some
MEMBER LEITCH: So is that what you mean
by transient combustibles, stuff that's flowing
through the process or --
MS. STEELE: I think in some cases that
could be the combustible, the transient combustible.
But largely within the process rooms there might be
cases where it is assumed that there could be leftover
pieces of polycarbonate window materials left over
from maintenance activities as well.
CHAIRMAN POWERS: It's moving drums of
MS. STEELE: The applicant has provided a
strategy for automatic detection and alarm systems,
and these include smoke and heat detectors and manual
pull stations throughout the facility. The systems
will be able to provide audible and visual alarm in
the affected areas, and it will indicate and transmit
these alarms to central alarm panels which would be
located in the polish and control room and at the
Savannah River site fire department.
They have also proposed various types of
CHAIRMAN POWERS: Not to the control room?
MS. STEELE: I'm sorry? Polish and
CHAIRMAN POWERS: Oh, to the control room.
MS. STEELE: Yes. They have also provided
various suppression agents. For example, sprinklers
will be provided in the hallways and offices, and
basically in areas where an inadvertent actuation of
the sprinkler system does not affect -- cannot affect
Also, clean agent suppression will be used
where fissile materials are present, and in those
areas the suppression systems will be considered a
principal structure, system, and component.
They are also proposing the use of
standpipe and hose systems and portable extinguishers
for manual firefighting.
A baseline needs assessment for the manual
firefighting and the license to possess stage will be
provided. This assessment will evaluate the minimum
staffing needs of the firefighting force. It will
describe organization and coordination of onsite and
offsite firefighting resources. It will describe
personnel protective and firefighting equipment, also
training of the fire brigade, and fire emergency
The FHA will determine a need for a
separate emergency response team.
CHAIRMAN POWERS: Remind me what FHA
MS. STEELE: The fire hazards analysis.
CHAIRMAN POWERS: Okay.
MS. STEELE: Will determine the need for
a separate emergency response team which -- in
addition to what's already provided at the Savannah
River site fire department.
MEMBER BONACA: So this is the Savannah
River site fire department.
MS. STEELE: Yes. They will look at
MEMBER BONACA: Because you mentioned
before that you will have alarms in the Savannah fire
department that --
MS. STEELE: There will be a -- there's a
plan to send an alarm to the Savannah River site fire
department as well, and in the baseline needs
assessment they will, during that stage, analyze the
firefighting forces to determine whether the Savannah
River site fire department would be sufficient to meet
the needs at the MOX facility or whether they would
need a separate emergency response team.
CHAIRMAN POWERS: It would stun me if they
MS. STEELE: I'm sorry?
CHAIRMAN POWERS: It would surprise me if
they weren't adequate.
MS. STEELE: Right. Exactly. But yes.
MEMBER SIEBER: Well, part of this is the
MS. STEELE: Right.
CHAIRMAN POWERS: Well, considering where
they are, that's not going to be a real problem.
MEMBER SIEBER: Right.
MEMBER BONACA: I guess my question was
more in the sense that, are they trained to deal with
a facility where you may have a fire situation and,
you know, radioactive release at the same time?
MS. STEELE: That should be part of the --
MEMBER BONACA: That's part of it. Okay.
I mean, I'm not talking about the fire brigade there.
I'm talking about the one in Savannah.
MS. STEELE: Yes.
CHAIRMAN POWERS: Well, I mean, at
Savannah River site they have lots of places where you
can have fires and radioactive material at the same
time. No question that they would have to have
training for the particular site.
MEMBER BONACA: Okay. And then, how you
integrate these forces I guess.
MS. STEELE: Right. Integration and the
training for specific hazards that could be
encountered at the MOX facility.
For operational purposes and as provided
by the fire hazards analysis, the MOX facility -- the
buildings at the MOX facilities are subdivided into
several fire areas. The fire area boundaries are
typically provided to separate manufacturing
operations, radioactive material storage, control
rooms, electrical equipment rooms, offices, and
redundant TRANEs of principal structures, systems, and
The primary structural members surrounding
each fire area will have a minimum of two-hour fire
rating. The openings in the barriers, including fire
doors and dampers and penetration seals, would be
There was a question earlier regarding
electrical circuits and cable trays. Right now, what
I've been able to establish is that for the most part
qualified cable would be used in the facility, and
they could be contained in non-metallic cable trays.
CHAIRMAN POWERS: Qualified cable --
MS. STEELE: Right.
CHAIRMAN POWERS: -- just a little harder
to ignite than --
MS. STEELE: Right.
CHAIRMAN POWERS: -- unqualified cable.
I mean --
MS. STEELE: That's right.
CHAIRMAN POWERS: -- it's not going to
MS. STEELE: That's right.
CHAIRMAN POWERS: I mean, I'm a little
surprised, and maybe it's premature. But it seems to
me that you've got people coming in here saying,
"Okay. We're going to have this facility. It's going
to have this elaborate electronic computerized system
to make sure we don't have a lot of inadvertent
transfers," which has been the bane of most chemical
processes involving plutonium.
MS. STEELE: Right.
CHAIRMAN POWERS: They're going to try to
get around this with a computerized quasi-automatic
system. It seems to me that if I was defining the
fire strategy, I would say, "Okay. You must have a
TRANE that allows you to shut this system down and is
protected against fire."
MS. STEELE: Yes. Right.
CHAIRMAN POWERS: And that doesn't seem to
be emerging from this.
MS. STEELE: I believe that could be
addressed later in the electrical portion. But there
would be redundant TRANEs of -- I'm sorry.
MR. GIITTER: As you'll see in the I&C
presentation, there are redundant systems that could
shut the system down.
CHAIRMAN POWERS: Well, you know, I just
don't think you can separate that from the fire. I
mean, I think you have to sit here and say, "Well,
you've got to have enough separation here and enough
protection, so that you always have one of those
TRANEs available." You're protected from -- I mean,
it's a lot like Appendix R. You have a shutdown TRANE
that you protect from fire.
And so there is some sort of a design. I
mean, most of this stuff is kind of routine fire
protection for a car body company. And, I mean, it
seems like there should be a strategy here that I'm
not seeing emerging.
MS. STEELE: Okay. You are not seeing the
integrated effort that perhaps we should -- well, that
we are currently doing in our review. And that will
be addressed. Also --
CHAIRMAN POWERS: I had also noticed -- I
jumped and noticed that you -- they are going to have
separate electrical equipment rooms, but you did not
cite sprinklers for the electrical equipment rooms.
MS. STEELE: I believe clean agent
suppression systems will be employed there.
CHAIRMAN POWERS: Oh, yes?
MS. STEELE: And it's --
CHAIRMAN POWERS: We're just never going
to learn that you've got to put these fires out with
water, are we?
MS. STEELE: In addition, fire barriers
are considered to be principal structures, systems,
and components. I will cover a couple of open items
that remain, and then I will summarize.
But, again, DCS is proposing the use of
polycarbonate material for the windows and the
gloveboxes. This is against or -- against what
National Fire Protection Association Code 801
requires, because it prohibits the use of non-
combustible material in the glovebox construction.
And even though polycarbonate is not non-
combustible, DCS has tried to demonstrate that an
equivalent level of fire safety could be still
achieved, and they've done so by using -- providing
various test results that indicate that the
polycarbonate is difficult to ignite and difficult to
Also, where gloveboxes are used, they will
be providing additional administrative and physical
fire protective features. However, we feel that the
scenarios that DCS provided does not adequately
address areas where polycarbonate could be -- could be
combusted or could be involved in the combustion, and
we're asking them to develop or provide analyses to
indicate a better -- that the margin of safety is
And we're requesting additional analyses,
such as determination of when flashover would occur if
these gloveboxes were involved.
An additional open item is that of the
combustible loading controls. The applicant is
proposing combustible loading controls only as items
relied on for safety to protect various forms of
plutonium that are not in fire qualified containers,
and some of these containers would be canisters, fuel
rods, and the final HEPA filter.
We have requested details on additional
surveillances to augment the controls, and we are
asking them to provide a fire safety analysis to look
at critical transient loads beyond the imposed or
established limits. We are also trying to get more
information on what the role of detectors would be,
the role of detectors which are not credited in the
ISA would be.
Finally, to summarize, I'd like to say
that DCS has addressed the major aspects of fire
safety. They have provided the commitments to develop
administrative controls, a fire protection program,
and a baseline needs assessment for manual
They have described the planned
suppression and detection features and currently have
a preliminary fire hazards analysis. I identified a
few of the open items in the fire safety, and NRC will
continue to review additional information in order to
complete the safety evaluation report.
CHAIRMAN POWERS: One question that pops
immediately into mind is in a facility everything gets
through and eventually they put these pellets down
into some zircaloid-clad tubes. Do they do any work
with the zirconium that would result in the
accumulation of scrap zirconium and turnings and
things like that?
MS. STEELE: Yes, that's a potential
hazard that has been identified, and I believe they
have ways to remove the scarse, and they are providing
-- the principal SSC there would be combustible --
would be controls, staff training, administrative
controls I should say, and the use of manual
extinguishers, Class D portable extinguishers, in
Those areas -- currently there is no
suppression -- no automatic suppression provided in
those areas because of -- because the space is so
large, and they're not sure whether they could achieve
the desired atmosphere using a clean agent.
CHAIRMAN POWERS: Do you have any
familiarity with the available base of incidents that
have occurred on spontaneous combustion of zirconium
MS. STEELE: Yes. There is some
information that's available that I will be looking
CHAIRMAN POWERS: I'm aware of two
MS. STEELE: Right.
CHAIRMAN POWERS: -- myself.
MS. STEELE: One occurred at MELOX in
France where I believe they use a vacuum, for example,
to remove some of the scarse, and there was a fire
that occurred. I believe they were able to extinguish
that with a Class D extinguisher.
CHAIRMAN POWERS: Okay. Looks like the
Fire Protection Committee has got a lot here.
MEMBER SIEBER: I think so.
CHAIRMAN POWERS: Yes.
MS. STEELE: Uh-oh. Thank you.
CHAIRMAN POWERS: We'll tell Mr. Rosen his
work is cut out for him here. Lots to read.
MR. JOHNSON: The next presentation will
be on confinement systems. My name is Tim Johnson,
and I'll discuss with you some of our issues that
we've identified in this system.
The objectives of this presentation is to
briefly discuss the proposed confinement system that
Duke Cogema, Stone & Webster presented in their
construction application. I'd like also to discuss an
issue that we've raised regarding the high efficiency
particulate air filter removal efficiencies, and also
discuss an issue involving whether HEPAs or sand
filters should be used.
Our review is in process. We have raised
some issues with DCS on these, but we're not at the
point where we've made any decisions on the
acceptability of the proposed system.
Ultimately, when we make our decision on
the acceptability of the system, we're going to have
to evaluate whether or not the safety features
presented can adequately protect public health and
safety. And in DCS's proposed design, the ventilation
and confinement systems are important features for
As part of the construction authorization,
DCS needs to provide a safety assessment of the design
bases to demonstrate that the safety features can
perform their safety function under anticipated
accident conditions and conditions of natural
phenomena hazards. And since DCS is relying on the
confinement system as one of the safety features, it's
an important area for our review.
Another aspect of this is we are looking
to -- at the defense-in-depth features of the proposed
MEMBER KRESS: Tim, what exactly does that
MR. JOHNSON: Defense-in-depth would be
the use of as proposed -- what they refer to as static
and dynamic systems. Confinement would be by things
like gloveboxes, room walls, as well as a ventilation
system. So these are diverse systems that help to
confine the material and prevent releases.
MEMBER KRESS: So the defense-in-depth is
-- relates to how diversities are or --
MR. JOHNSON: Diversity and redundancy.
MEMBER KRESS: In this instance, you're
talking about diversity and redundancy as being --
MR. JOHNSON: Right.
MEMBER KRESS: -- defense-in-depth.
MR. JOHNSON: Yes.
MEMBER KRESS: Okay.
CHAIRMAN POWERS: It sounds like multiple
barriers as well.
MR. JOHNSON: Yes. We have some guidance
that we've published dealing with confinement systems,
the standard review plan. We have the fuel cycle
facility accident analysis handbook, and there is also
a regulatory guide on design of ventilation facilities
for plutonium processes.
And, of course, these guidance documents
provide acceptable methods for meeting our regulatory
requirements. They don't restrict DCS. DCS can
propose alternatives, but those alternative approaches
would need to be provided with adequate justification.
The proposed confinement system of DCS
involves what they refer to as both static and dynamic
barriers. A static barrier would be a thing like a
glovebox, a process cell, process piping, process
tanks. A dynamic barrier would be the ventilation
And I have a very simplified figure that
may help to explain the approach that's used.
Is that okay?
The confinement system is basically
oriented by the formation of four confinement zones.
These zones are oriented where leakage would go from
a zone of lesser hazard to a zone of higher hazard,
and the most hazardous zone is what they refer to as
C4. These would be the gloveboxes containing the
plutonium pellets or powder, etcetera.
The confinement system is the glovebox,
and it also has a separate ventilation system. The
ventilation system has HEPA filters right at the
glovebox, on the inside and outside of the glovebox.
There's another HEPA filter. This is -- this would be
located at the boundary of the room, and there is also
a separate final filtration assembly.
This is a very simplified figure. It only
shows the HEPA filters, but there are also spark
arresters and a set of pre-filters here as well.
The next zone is what is referred to as a
C3 zone, and this is in the process room and airlocks.
It has -- its static confinement is the room boundary
itself, the walls. There's an airlock system. It has
its own ventilation system that has a HEPA filter
right at the boundary and a separate filter assembly
that has spark arresters, a set of pre-filters, and
HEPA filters here.
The areas surrounding the C3 process rooms
also have a separate ventilation system. It has,
again, spark arresters, a pre-filter, two sets of HEPA
filters that run to the stack.
Another example of a confinement system
would be the control rod itself. After it's finished,
it's been sealed and appropriately tested, it comes
out of the glovebox arrangement. That also provides
a confinement boundary.
This figure here is for the mixed oxide
processing areas. There's a similar figure here for
the aqueous polishing areas, and it has some of the --
a lot of the same concepts -- you know, the glovebox
confinement, the process room confinement, and so on.
But in addition to that, DCS also has areas called
process cells where there are welded tanks that
contain aqueous polishing liquids, and so on, and
This would be equivalent to a C4 zone. It
has an offgas system with filtration as part of that,
and the process cells also have their own separate
ventilation system, again with double HEPA filters,
pre-filter, and spark arresters.
CHAIRMAN POWERS: I keep coming back to
the fire protection. It seems to me that in the
events of glovebox fires you cannot credit the first
filters, HEPA filters.
MR. JOHNSON: Right.
CHAIRMAN POWERS: Do you have problems
crediting the second batch of filters in the event of
MR. JOHNSON: DCS is not taking credit for
the HEPA filters right at the glovebox. There is one
inside and outside immediately on the glovebox. There
is also another one at the room boundary that they're
not taking credit for. The only ones they're taking
credit for are the final filtration assembly ones.
MEMBER KRESS: What is the criteria for
whether you take credit for it or not?
MR. JOHNSON: Well, I think it has a lot
to do with the fire hazard itself. In the immediate
vicinity of the fire, the HEPA filter could degrade
and be ineffective.
MEMBER KRESS: Temperature or pressure or
loading, excess loading or excess temperature or
excess pressure? What is the --
MR. JOHNSON: Right. Right.
MEMBER KRESS: Are all those --
CHAIRMAN POWERS: I think the answer is
yes on those.
MEMBER KRESS: Okay. And where in that
line do you draw the line and say, "Okay. Now the
loading or the temperature or the pressure is down far
enough that my HEPA filter can survive"? Do you have
criteria for that?
MR. JOHNSON: Well, that's kind of the key
question that we have. What DCS's approach is is
they've set up specific fire areas, basically their
process rooms or -- individual process rooms would be
considered a separate fire area. And they're saying
that they can confine the fire to one fire area, and
the effluent exhaust from that fire area would be
basically diluted in temperature, and so on, by
exhaust from other areas as it goes into the final
So they are taking credit for dilution
from areas where the fire has not spread to. And
that's, of course, one of the things that we're --
where we're looking at. And it goes back to one of
the things that Sharon indicated was, you know, what's
the margin of safety of their fire barriers? And, you
know, will the fire spread to other areas?
What I'd like to talk kind of briefly
about is some of the key design features of the
ventilation system. This indicates here the design
base pressure areas and vacuums for each of the zones.
You can see there is a gradient here where leakage
would go from lower pressure areas to higher -- to
higher vacuum areas as the hazard increases.
There's also a supply air system. The
supply air into the C4 and C3 zones do get filtered by
HEPA filters. There is also redundant fans in that
system. The C4 confinement system includes
gloveboxes. Also, the exhaust system has redundant
final filter assemblies. Each of the filter
assemblies has two banks of HEPA filters.
There are four redundant fans as part of
this exhaust system, and other parts of the system are
gloveboxes and the C3 boundary wall.
MEMBER SIEBER: I presume there are
dampers in the ductwork.
MR. JOHNSON: There are fire dampers in
each of the fire areas just to confine it.
MEMBER SIEBER: Would the action of a
glovebox fire be accompanied by shutting down the
MR. JOHNSON: Yes, into that zone.
MEMBER SIEBER: And closing the damper.
MR. JOHNSON: Into that zone, yes.
MEMBER SIEBER: All right.
MR. JOHNSON: The C3 confinement system --
this would include process rooms and cells. It has
redundant filter assemblies. Each of the filter
assemblies has two banks of HEPA filters and two
redundant fans for each of those systems.
One of the issues that we've identified in
our review is the amount of credit that DCS is taking
for the release fraction for their accident analyses.
And as Dave Brown mentioned, they were basically
crediting each bank of the final HEPA filters -- of
the HEPA filters in the final filter assembly at 99
percent for basically a release fraction of 10-4. And
we have some concern with that.
There have been fires in a number of
facilities which have resulted in filter damage.
We're very concerned about that. There are
uncertainties in the fire analysis, and we requested
further justification for those removal fractions.
Our guidance says we will accept a 99
percent removal efficiency for a ventilation assembly,
and we asked DCS to provide additional justification
for their removal efficiencies. Their response to us
was basically to use a calculational approach to
calculate what the efficiency might be, and their
approach addressed soot analysis and projected
temperatures, but it didn't include other aging
effects, you know, chemical effects, and so on, that
left us still concerned.
And after some discussion with them, they
have decided that they will try to refine their
environmental conditions and send us additional
information on that. Again, this is an issue that we
have not made a decision on.
The other issue I wanted to talk about is
an issue that fell out of our environmental impact
statement scoping meetings where a number of people
talked about the Savannah River site and the fact that
historically they've used sand filters in their
plutonium processing areas. And there are other
facilities. At DOE Hanford, they use some sand
filters as well, but it's not universal within the DOE
And what we decided to do in our EIS was
to include this as an option in terms of our impact
analysis. And we had a preliminary analysis performed
for us, and, you know, what we found is that both
systems have advantages and disadvantages. Both of
them have similar particulate removal efficiencies.
They have similar life cycle costs.
And by life cycle costs we included the
installation costs, maintenance, replacement of
filters, in-place testing. Waste disposal and
decommissioning costs are in there, and our analysis
was that overall they are pretty similar.
There are some advantages to the HEPA
filters in terms of lower installation costs, lower
decommissioning costs. Sand filters -- we're talking
about a system here that may be, you know, a couple
hundred feet by a couple hundred feet by, you know,
eight to 10 feet deep. We're talking -- this is a
fairly large piece of equipment. It would have some
significant decommissioning costs if it was required
eventually to totally dismantle that facility and
dispose of the sand in a waste disposal area.
The sand filters do have lower maintenance
costs because the sand filter is there for the life of
the plant. You don't need to keep replacing and
testing the individual filter units. And sand filters
can withstand severe events like fires.
MEMBER KRESS: The particulate removal
efficiency, does that apply to the most respirable
size of the particulates?
MR. JOHNSON: There have been -- yes,
there have been some tests on sand filters with the
dioctyl phalate, DOP, tests. And they come out 99.8
percent in a sand filter. A HEPA filter bank, when
it's DOP tested in the field, would generate 99.95
MEMBER KRESS: Yes. But my understanding
was that for sand filters the part that went through
was the respirable size, whereas the HEPA filters took
out the relative percentage of all of the sizes. Is
that not true?
MR. JOHNSON: Well, I think the bottom
line is is that there -- the differences are slight
between them in terms of, you know, all sizes of
MEMBER KRESS: Okay.
CHAIRMAN POWERS: Yes. These are big sand
-- these are serious sand filters.
MEMBER KRESS: Huge.
CHAIRMAN POWERS: And so you just -- just
the interception component gets rid of that respirable
fraction pretty well. I mean, I've always been
impressed by them. And having endured the headaches
of misaligned --
MEMBER KRESS: HEPAs?
CHAIRMAN POWERS: -- HEPA filters and
testing and things like that --
MEMBER KRESS: It's hard to misalign a
CHAIRMAN POWERS: Once you've got her
built, she's good forever.
MR. JOHNSON: So as part of our
environmental impact analysis, we are including a
discussion of the use of sand filters as an
In summary, I've talked about the proposed
confinement design. I talked about the issue
regarding HEPA filter removal efficiency and also
about how we're considering in the EIS the sand filter
use. If you have any questions, I'll be happy to try
to answer them.
CHAIRMAN POWERS: One of the questions
that comes up is we have a lot of redundancy on the
fans for maintaining the pressure differentials.
Redundancy and diversity are two different things, and
so what -- I mean, how do we view this?
MR. JOHNSON: Well, I think we -- we view
it in terms of the confinement systems as a whole,
that it includes both physical barriers like
gloveboxes, cell walls, confinement zones, as well as
ventilation filtration. And, you know, the redundancy
built into the ventilation system, you know, is a part
of that. But diversity I think is achieved through
the use of both static and dynamic confinement areas.
CHAIRMAN POWERS: So you're really putting
ventilation and barriers on an equal footing here and
saying, "Yes, there's diversity."
MR. JOHNSON: Right.
CHAIRMAN POWERS: Okay. Thank you.
MEMBER KRESS: The other issue that
usually comes up about barriers is, how independent
are they and how independent do they need to be? And
the independence depends on the -- on things like
bypass and loads and how well the fire can spread from
one to the other. Have you looked at that part of it?
MR. JOHNSON: Well, I think the fire
spread is a key area of the fire analysis, and it is
something that Sharon is focusing on. And that's a
basic assumption in the use of the HEPA filters here,
and its overall integrity in the event of a fire
event, because they are making the assumption that
they can confine a fire to a specific fire area.
MEMBER BONACA: You characterize the four
ventilation zones as independent. But it seems to me
that the C4 and the C3, for example, were depending on
the same intakes and exhausts. Are there still
independences maintained there somehow?
MR. JOHNSON: Well, I guess I would look
at them as somewhat independent in that they can be
segregated, they can -- through damper systems, so
that the -- the design goal here is that they will
have fire dampers that would activate and seal off a
So in that situation, the rest of the
system would still remain operational in the other
areas where the fire doesn't spread to. But, again,
the question of, can you adequately contain the fire
into a fire area is a question that we're still
MEMBER BONACA: Yes.
CHAIRMAN POWERS: Any other questions?
Well, thank you.
MR. JOHNSON: Okay. Thank you very much.
CHAIRMAN POWERS: We are scheduled to take
a lunch break and to resume at 1:15, and I can't
change that resumption schedule.
I'd like to, at this intermediate stage,
congratulate all the presenters on what I think have
been so far outstanding presentations and hope that
those after lunch can maintain this high standard
And with that, I'll recess this until
(Whereupon, at 11:53 a.m., the
proceedings in the foregoing matter went
off the record for a lunch break.)
CHAIRMAN POWERS: Let's go back into
session and continue our discussions of the MOX fuel
fabrication facility. And I guess we're moving on to
the electrical stuff.
MR. BURROWS: I'm Fred Burrows. I'm the
electrical reviewer for MOX. I'm going to give a
general overview of the electrical systems. It'll be
using the viewgraph and also the slide projector, so
bear with me.
CHAIRMAN POWERS: A multimedia
MR. BURROWS: Yes, that's true.
This is a simplified one-line diagram of
the MOX facility. It has two feeds from the Savannah
River site. They are 13.8KV feeds. There are two
transformers, one for each feed. They're 100 percent
capacity. That is, they are capable of carrying all
of the loads in the facility.
There are two 4KV buses. There are two
4KV emergency buses. There are also 480-volt load
center buses. There are more than one; I've only
shown one to make this slide simple. There is an
automatic transfer scheme. If an offsite source
should be lost, all of the loads or this bus will
shift over to the opposite source following a time
Also, the 480-volt buses here have cross-
ties. They are manually controlled. They are used
If I could go back to the overhead.
MEMBER LEITCH: Just before you leave
that, we have talked about the diesels a little bit.
The standby diesels --
MR. BURROWS: Yes.
MEMBER LEITCH: -- normally supply the
standby bus. In other words, can you tie the
emergency diesel to the standby bus?
MR. BURROWS: No. I'll be working my way
down to --
MEMBER LEITCH: Okay. Okay. I'll just
hang on --
MR. BURROWS: I'm starting at the top.
MEMBER LEITCH: -- for a second. Okay.
MR. BURROWS: All right. All right. I'm
down to the last bullet. The normal AC system that I
describe is designed to IEEE Standard 785 -- or 765.
And it is a non-principal structure system component.
And I should say this is similar to what you'd find in
a nuclear powerplant.
MEMBER KRESS: Is non-principal a
MR. BURROWS: Yes.
MEMBER KRESS: Or is that just a word?
MR. BURROWS: No, it's non-principal SSC.
MEMBER KRESS: There's different kinds of
SSCs, principal and non-principal? Did I miss that
MR. BURROWS: Yes. If it's not a
principal, it's a non-principal.
MEMBER KRESS: But it's still an SSC.
MR. BURROWS: No, it is --
MEMBER SHACK: I think it's like saying
it's non-safety-related, if we were going to put it in
-- you know, in reactor terms.
MR. BURROWS: It's non-Class 1E.
MEMBER SHACK: Yes, it's non-Class 1.
MEMBER KRESS: Non -- okay. That's the
MEMBER SHACK: Okay. And principal is
just what you think it is.
MEMBER KRESS: Okay.
MR. BURROWS: Okay. The next -- and I
want to talk about the standby AC system. It has two
diesel generators. These each have redundant
batteries for starting. Also, they are not shown in
this diagram, but there are two 120-volt, 208-volt
uninterruptable power supplies, which provide power
for the control of the process.
These generators will start on the loss of
a feed and the failure of the transfer to the other
offsite source. And their purpose is to provide for
safe shutdown of the facility and also a quick restart
of production. And they are sized to carry one
emergency bus that corresponds to their switch gear
bus, and they are also sized to carry the shutdown
loads associated with this bus. Not all of the loads;
some of the loads are shed.
MEMBER SIEBER: What's the kilowatt output
of the diesels?
MR. BURROWS: I'm not sure of that yet.
I don't think that's been established. But I believe
they are the same size as the emergency diesel
generators, but that doesn't answer your question.
MEMBER SIEBER: No, it didn't.
It can't be too big if you use batteries
to start it.
MR. BURROWS: Yes. Okay. Let's see, I'm
now down to the last bullet on this slide. The
standby AC system is designed to IEEE Standard 446,
and, again, it is not a principal SSC. It is not
Now, moving on to the important stuff, the
emergency AC system. That's this area down here.
There are two separate redundant diesel generators.
They also have redundant batteries for starting. They
are, if I can use the term, Class 1E.
And there are also two 480-volt
uninterruptable power supplies. Those are for the
glovebox extraction fans. You saw a little bit of
that with the ventilation system. There are two 120-
volt uninterruptable power supplies, and they provide
power for the principal SSCs in the I&C area. That is
instrumentation and controls.
Now the diesel generators and these power
supplies are there for the loss of all other sources.
And they power -- the diesel generators provide power
mainly to the principal SSCs, such as the
depressurization exhaust fans. That's part of the
ventilation system also.
As I said, they are Class 1E, so the whole
emergency AC system is designed to Class 1E IEEE
standards such as 308, 387, and they are a principal
Are there any questions?
Okay. Next slide.
Now we have the normal DC power system,
two separate 125-volt batteries. Each has a charger.
They provide breaker control and some DC loads in the
plant. As a normal system, it's designed to 485 for
battery sizing and 484 for the installation of the
batteries. And they are designed as non-principal
SSCs. That is, they are not Class 1E.
Then we get to the emergency DC system.
This also has two separate redundant 125-volt
batteries. They each have a charger, and they provide
power for the emergency breakers. That is, the
breakers that are needed for the emergency buses.
They also provide emergency lighting, and they are
also principal SSCs. They provide power to the loads
that are principal SSCs.
They are designed as Class 1E DC systems
to such standards as 946, 450, and 485. And they are
designed as principal SSCs. That is, they are
Now, in summary, the whole electrical
system is a robust design, as I showed. They have
multiple AC sources, multiple systems. I believe that
provides defense-in-depth -- multiple layers.
Specifically, the emergency AC and DC
power systems are designed for redundancy and
independence. No single failure vulnerability, have
sufficient capacity and capability to carry the
emergency loads. They will have quality assurance
applied. Also, some of the IEEE standards provide for
maintenance, and there will be an environmental
qualification program to ensure they perform their
function when required.
Now, the only issues I have are related to
the specific standards and the associated Division I
reg guides. As you know, the staff endorses IEEE
standards. It's usually specific versions, a specific
year. So DCS, the applicant, has used the latest
standards, and the staff is somewhat behind in their
So I am reviewing the differences with the
help of DCS. We are having ongoing dialogue. They
have also agreed to look at the Division I reg guides,
and in some cases they are committing to the
Division I reg guides.
Are there any questions?
MEMBER LEITCH: Could you get back to your
single line again, please, Fred? I was just --
MR. BURROWS: Yes.
MEMBER LEITCH: I was just a little
confused about the answer to the diesels. The
emergency diesels can't backfeed through and pick up
the main -- the normal bus?
MR. BURROWS: Oh, no. That's going to be
separated from the switchgear, just carry the
MEMBER LEITCH: All right. So, in other
words, if the emergency diesel breaker is closed, you
won't be able to close one of those tiebreakers to the
MR. BURROWS: No. I mean, just these
MEMBER LEITCH: I'm just curious how that
-- and maybe you don't have the details yet on how
that interlock works.
MR. BURROWS: Yes. You wouldn't want to
do that. There was a question when I was out of the
room this morning about separation, electrical
separation. You don't want to tie your emergency
Class 1E stuff back to the non-1E stuff.
MEMBER LEITCH: Yes, I agree. I was just
wondering how -- how that interlock is achieved. I
guess you can't have those two breakers closed at the
same time is about what it amounts to.
MR. BURROWS: Yes. I don't -- I don't
know if they want -- they could do that, but I don't
think they want to do that. I'm not sure they'll have
interlocks to prevent it, but there may -- they may be
designed with interlocks. I haven't seen that level
of detail at this point. It's just --
MEMBER LEITCH: Yes. I mean, I think it
should be interlocked so that it's impossible to do
that, really. Otherwise, you compromise the
independence of the two systems.
MR. BURROWS: Well, you know, yes. You
know, sometimes, you know, for testing you have to
parallel them to the offsite sources, and so there
might be occasions when you want to do that to develop
load and --
MEMBER LEITCH: But at any rate, that
level of detail is not worked out yet.
MR. BURROWS: Yes. At this point, the
review is focusing on the standards that they're
using, not -- the applicant graciously used the IEEE
standards from nuclear powerplants, which made my
review very simple, somewhat simple. But, so it's
pedigreed as -- similar to what you find in a nuclear
Actually, I personally believe it's better
than the powerplant, but -- than a nuclear powerplant,
with certain features like standby diesel generators
that start automatically and -- before you end up on
your emergency diesels.
MEMBER LEITCH: Okay. Do you know
anything about the nature of those two 13KV lines?
Are they aerial? How long are they? Those kinds of
MR. BURROWS: No. I don't know that at
this point. I do know they are committing to be
somewhat independent of each other, but I don't -- the
independence is, you know, not to the point that
they're going to commit to using separate right-of-
ways. They're going to make sure one line, if it
falls over, doesn't fall into the other. So you're
going to get that type of limited separation.
MEMBER LEITCH: So it would not be on the
same pole set.
MR. BURROWS: No. That's all discussed in
IEEE 765. I won't go into GDC 17, but it's in that
I believe this morning there was a
question about separation. Somebody had a question.
CHAIRMAN POWERS: Right.
MR. BURROWS: One of the standards they
are committed to was 384, along with we're looking at
Reg. Guide 175. That's part of the ongoing dialogue,
to home in on, what are the issues? Where do they get
closer? Where do the cables get closer than what's
permitted by the version of 384 that's endorsed by
Reg. Guide 175?
Are there other questions?
MEMBER SIEBER: Could you give us examples
of some of the emergency loads that might be carried
by the emergency bus? What is the equipment that
MR. BURROWS: Yes. From this morning's
presentation by Tim Johnson, it's mostly the
ventilation system, the fans.
MEMBER SIEBER: What about the pumps and
things like that? Nothing?
MR. BURROWS: No, just mostly fans for the
MEMBER SIEBER: And what are the
consequences if the fans don't operate?
MR. BURROWS: Well --
MEMBER SIEBER: A release? It looks like
MR. JOHNSON: Do you want me to try to
answer that? If the fans don't operate, there's a
chance the confinement systems won't work properly and
you could get a release.
MEMBER SIEBER: Okay.
MR. BURROWS: You're going to lose that
vacuum in your gloveboxes or your different
MR. GIITTER: Something that was kind of
interesting, we were out at -- a group of us were out
at Los Alamos last week, and about a year ago when
they had the fire that threatened the facility they
actually walked away. They shut the entire facility
down, no power to the facility, and they walked away
from it for two weeks.
They came back into it expecting, you
know, some at least minor contamination, but they
really didn't see any. So in that particular instance
of just shutting down the facility, walking away from
it, did not lead to widespread contamination at all.
MR. BURROWS: But, of course, this is --
this is designed for spills, you know, event-type
scenarios, upsets of things, you know, activities that
could cause problems, releases, not just normal
operation but emergency situations where you need that
filtration system to work.
MEMBER SIEBER: Thank you.
CHAIRMAN POWERS: And the throughput
through TA-55 is substantially smaller than this
facility, I think.
MR. GIITTER: Yes, that's true.
CHAIRMAN POWERS: John, you're going to
discuss I&C, huh?
MR. CALVERT: Yes, sir. My name is John
Calvert. Fred and I work together actually on
instrumentation and controls.
Next slide, please?
Today I want to give you an overview of
the I&C systems and talk about the principal
structures, systems, and components that we've been
calling the PSSCs. They are the -- if you will, the
safety-related systems. A little bit about the system
architecture, the design bases, and then a summary.
Next slide, please?
This is -- shows you in a nutshell the
four major systems in the MOX facility. MOX or --
yes, MOX process control, AP control, utility control,
and emergency control. Each one of those has a
subsystem that's entitled normal, protective, and
safe. And then the Xs show which is allocated to
The PSSC is shown here as the -- in these
two systems here, but there is also -- in the
nomenclature that's used presently by the applicant,
there are safety controllers that aren't necessarily
PSSCs. The emergency control is a hard-wired system.
It's all PSSC. And then I showed the various control
rooms, which are manned according to the process.
There are six control rooms associated
with MOX, one major control room associated with AP,
and then there is -- utility control normally is in
this control room in AP, and then there's an alternate
Then, emergency control has two control
rooms separate and redundant. And then there is one
more control room for reagent processing, which I
don't show. But the important thing here is that
we've identified the PSSCs.
Next slide, please.
This is an overview of the system
architecture for both the process -- it could be in
the AP or MOX, but it will have this architecture.
What it centers around is there is a normal controller
that's programmed with the modular processing
algorithm, and it is -- this is the main controller
for that production step if you will.
Then, separate and independent is a safety
controller that's looking at limits, and then we'll
take action to mitigate any safety problem, or these
In addition, there is a protection --
personnel and equipment protection that's inside this
MCC that is used for equipment, motors, and so forth,
and for industrial safety of personnel.
CHAIRMAN POWERS: And what is an MCC
MR. CALVERT: Motor control center.
CHAIRMAN POWERS: Motor control center.
MR. CALVERT: The normal process has its
normal complement of sensors. Then, the normal
controller controls to -- the motor control center
controls the process actuator. This could be, you
know, a motor, a valve, or whatever.
In addition, connected across this bus
called the immediate control network are work
stations. These work stations at this time are
usually in the associated control room that this step
-- this production step is associated with.
And this monitors the action of what's
happening down here, and the normal control center
also sends and receives messages from the MMIS
computer, which is the manufacturing, management, and
information system. So that in some cases, for
example, you -- they want to start a particular
product module. The normal controller can't stand
until it receives permissive information from MMIS.
Then, when it stops, it sends messages
back to MMIS which says, "I'm done. You can proceed
to the next step." The MMIS keeps track of the
material inventory and the steps in performance. This
little section in here in the MMIS concerns one part
of the safety controller, and that is we are trying to
find out from the licensee in detail how this will fit
in with the IEEE standards that he has chosen. And we
are -- so that's why that's there.
The manufacturing status computer is
actually a mirror image of the MMIS, and this is where
production sorts and production information and
everything are taken out of. The MMIS, like I say, is
taking information from the normal controllers, and it
serves as a server for the terminals that are spaced
at the various control rooms.
This is a diagnostic computer that
receives information over the local -- local
industrial network this is called. And it has an
independent program that figures out that the normal
controller is in trouble or it's not performing the
way it should.
And it's used as a diagnostic aid only for
the operation staff. And this was added from the --
the foreign facilities added this, which was an
So what happens is for each production
step you can have a normal controller by itself or a
normal safety controller by itself, depending on the
-- what the process engineers desire. So these little
dots here indicate different configurations, and this
is one of the configurations showing just a normal
controller by itself.
So this is designed such that these
ethernet buses here -- ICN, LEN, and XTN -- are really
not needed. This can control by itself. It's
independent and almost autonomous. The safety
controller is autonomous. Nobody touches it.
So that's the idea. Each production step,
then, is broken up. And if one section fails, it will
only be that one section, not the whole -- like
sometimes they put in a whole massive computer, it
fails, everything goes. So this is -- is designed for
CHAIRMAN POWERS: You indicated that the
manufacturing status device and the manufacturing --
the MMIS were mirror images of each other. Can they
send conflicting signals?
MR. CALVERT: At this time, we don't know
that because we don't know the details. But if it's
a non-primary or non-principal SSC, we'll ask those
questions. But if they come up with conflicting
answers, we'll have to solve it. It's not a safety
situation. That's why we tried to identify the PSSCs.
But there are the interactions where the
normal controlling -- there are interactions there
which will -- that we look for that may cause a safety
action to occur.
MEMBER SIEBER: Will the depth of your
review include a line-by-line review of the software?
MR. CALVERT: For the primary -- for the
MEMBER SIEBER: Okay.
MR. CALVERT: And the rest of the --
MEMBER SIEBER: Are they all the same?
You know, all of these controllers and computers.
MR. CALVERT: Yes. Well, I'm not sure of
the entire details. But the design is that the normal
controllers are PLCs. They have a history of
operation in the plants overseas. And also, the
software -- the requirements for the software will
have a background of actual operation.
And safety controllers will get a pretty
thorough review. Normal controllers we'll be looking
for -- that they satisfy the algorithms, that there's
no chemical safety problems, and so forth, and that a
normal failure will not cause one of these things to
come into existence.
MEMBER SIEBER: Okay.
MR. CALVERT: Any other questions?
MEMBER LEITCH: Is there some kind of a
manual override on the safety controller? Or once it
intervenes, you can't do anything about it? I was a
little confused. You said it was autonomous and I --
MR. CALVERT: It's autonomous in that it's
-- it's looking at a set of parameters all by itself.
When it senses the condition to take action, it
overrides anything that's coming from the normal
controller down to the process actuator and actually
causes the process to stop.
If that doesn't work, the administrative
control -- they go to -- the operators go to the
emergency control center and actually shut off the
power either to that module or whatever, like what
happened in what Joe was talking about. You shutdown
MEMBER LEITCH: All right.
MEMBER SIEBER: Are the process sensors
and the protection sensors two different sensors, or
do you have --
MR. CALVERT: At this time, I --
MEMBER SIEBER: -- cases where one sensor
would serve both functions?
MR. CALVERT: No. They are supposed to be
separate and independent. Everything here that's
cross-hatched, with the exception of MMIS, which we're
investigating, is supposed to be separate and
MEMBER SIEBER: Okay.
MR. CALVERT: Any other questions?
Okay. So that's the main architecture
that will be used.
The second architecture is for utility
Next slide. Oh, there we are.
It has the same structure, except this one
has two data communication networks. Here again, we
have the normal safety controller arrangement. But
now the safety controller, which is also independent,
has independent, manual, and actually from safety work
station. This is in a control room, and this is in a
different location than this.
But, again, this is a non-principal SSC.
But it has a redundant design. And so this is for
utilities, you know, the gas, and so forth.
Next slide, please.
The emergency control is actually what
we're used to looking at -- is separate, redundant,
control centers, actually in separate rooms. And this
has no -- these have no software involved at all. And
their main -- this is where the operators will go to
manually control the process, essentially to turn it
off. So it has the same kind of structure, but it is
separate and redundant.
Okay. The design bases at this time --
the function of -- these are the safety control
subsystems. These are the PSSCs. Again, here is the
safety limits, can't be exceeded, and they are used to
prevent or mitigate the undesirable conditions or
The design is -- what they've done since
they've modularized everything -- this is the
applicant -- they've chosen standards for the system
design, the programmable electronic system, and then,
for software -- these are usually all the things for
software. They've chosen IEEE specs. These are IEEE
specs, the set points, independent separation,
isolation, EMI, follow pretty much what we have in the
reactor arena. The only tricky part in this is we
have to check their application as applied to this
kind of facility.
Again, here's the safety controller,
single, separate, independent. And all of its
interfaces with non-SSCs are isolated.
Here is the emergency control center or
system. Again, its function -- and its design, again,
is redundant, primarily manual control. This we have
to work out with the applicant what that means. I
think it comes in in the design phase where they might
find something different.
And, again, they use appropriate standards
from the reactor arena that are applied to this type
CHAIRMAN POWERS: They don't have
standards of an appropriate nature coming out of the
chemical process industry?
MR. CALVERT: The applicant has chosen to
apply reactors. There are some in the chemical
industry, yes, and I'm familiar with them and so is
the applicant. But they've chosen the route of
reactor -- actually, for us it's a better deal because
we're quite familiar with those.
CHAIRMAN POWERS: Sure. Sure. But I'm
just anxious that we're not missing something.
MR. CALVERT: That's been discussed, but,
as I say, I and some of the other fellows have a
little bit of background in that. We don't apply them
in our industry, of course. But I have looked at them
for -- part of my job is to look at other industries
and see what's good.
CHAIRMAN POWERS: We have -- I mean, we
have -- I think what you said, looking at the
applicability issues, because you've got other -- a
different environment here.
MR. CALVERT: Yes.
CHAIRMAN POWERS: You have a lot more
chemical vapors that you have to worry about, and
things like that.
MR. CALVERT: And that's -- I didn't
mention that part of the -- in the I&C review, I have
to work with the chemical process, the ventilation,
everybody. And this comes in in the design stage,
because actually the requirements that will hopefully
be firmed up in the ISA actually become requirements
of the design for those controllers.
So I have to make sure that those hazards
and the mitigation of those hazards are actually in
the software requirements and actually get done.
In summary, again, the appropriate
standards are used. It's really the application
trickiness of it. We have discussed this with the
licensee and we're working that out.
The design basis commitments -- at this
time, they are appropriate for a construction
application. And then the allocation of safety
controllers to the process modules for the PSSCs, what
we would like -- and discussing it now -- is what PSSC
goes with what process module, or what module of the
process. So we can -- you know, we've got eight of
these or four of them, or whatever. And then we can
check back through the various other reviewers to see
that that's correct.
So that ends my presentation. Are there
CHAIRMAN POWERS: Questions from the
members? My off-hand reaction to this system is it's
sufficiently complex that we may need some consulting
help on this, examining this system. And I am writing
a note to that effect to the able cognizant engineer.
MR. CALVERT: Yes, sir.
CHAIRMAN POWERS: I guess we're moving now
to the seismic discussion, a non-controversial area on
the southern -- South Carolina area. We'll all become
familiar with sand vents, and I think we ought to have
a subcommittee meeting in Charleston, just so we get
familiarity with the seismic issue.
MEMBER KRESS: I second that. I second
MR. STAMATOKOS: What's the easiest for
me? Do you want me to sit and talk or --
CHAIRMAN POWERS: Whatever is easiest with
you. You have the option of sitting or standing.
It's just you have to be next to a microphone. That's
the one requirement or our extremely competent and
charming reporter will be on your case. And you don't
want that to happen to you.
MR. STAMATOKOS: Well, my name is John
Stamatokos. I work at the Center for Nuclear Waste
Regulatory Analysis in San Antonio. And our task is
to evaluate the seismic hazards among other parts of
this particular project.
The bottom line I think of the applicant's
approach to the seismic, as you'll see, is that they
have chosen to use Reg. Guide 160 design spectrum
anchored at .2G, which is similar to a nearby nuclear
facility. And their whole analysis in their
construction authorization request is developed to try
to support that as an appropriate and safe level
So what we're evaluating is sort of their
technical basis for choosing the design spectrum that
they have. So what I'm going to walk you through in
this talk is just some of the things that they've done
in support of that and some of the things that we've
talked about with them in our preliminary part of the
Go to the next slide.
So the history of the seismic evaluation
at Savannah River has gone on for a long time.
There's a long history of the evaluation. The
approach that was taken by the applicant was to first
develop a probabilistic seismic hazard assessment,
generic for the entire Savannah River site.
The way that that was done was by using
existing probabilistic seismic hazard results from
Lawrence Livermore and EPRI. They've averaged those
two to develop a better hazard spectrum. They
established, then, a design basis earthquake, and in
doing so they were implementing Standard -- DOE
Standard 1023, which is quite similar to NRC guidance
Reg. Guide 1.165.
DOE uses -- also uses a standard now in
their probabilistic seismic assessments of DOE
Standard 1020, which sets -- it's a graded approach.
It sets five performance goals, PC0 through PC4, and
in this particular instance we are -- they are most
interested in the highest levels, PC3 and PC4.
PC3 standards are essentially for nuclear
fuel-type storage facilities, those kinds of
facilities. PC4, which is the highest, are
established for reactor-type facilities. And the
input return periods for those are 2,000 and 10,000
Okay. Next slide.
MEMBER KRESS: Did you say you averaged
the LL -- the Lawrence Livermore and the EPRI?
MR. STAMATOKOS: Yes, they averaged them
together to get a composite.
MEMBER KRESS: To come up with a new
MR. STAMATOKOS: Right. Yes. It's sort
of intermediate between the end member --
MEMBER KRESS: That was very interesting.
MR. STAMATOKOS: Diplomatic. The other
thing they did, and they've -- they performed a lot of
checks along the way. One of the things they did was
what they called their historical earthquake check.
In this case, they are using the Charleston 1886
earthquake, which is a magnitude 7.2 earthquake, at a
distance of approximately 120 kilometers from the
So there was the -- the approximate
location of the Charleston earthquake, an approximate
surface magnitude of 7.2. We don't, obviously, know
the exact magnitude of that.
So they then filtered this information in
to make sure that the design spectrum they were going
to ultimately use will envelope that ground motion
from the Charleston earthquake.
The other half, once they've developed
these input rock ground motion, probabilistic seismic
ground motions, is that they did a study of the site
response. And, again, like the other one, this is
sort of a two-part approach.
They used the ground motion attenuation
models to generate what they call the site-specific
PSHA, and then they used the extensive soil data they
had to develop the soil profiles in order to bring
those ground motions from the bedrock up to the soil
And the way that they did that was to
develop some amplification functions which would scale
the uniform hazard spectrum bedrock to the soil
surface. But they also developed an alternative
methodology, looking at amplification functions as a
way to test to make sure that their approach was
conservative. This is an approach developed by
Cornell, and I can't remember the other author's
names, but it's basically to perform a check of the
scaling they used for the amplifications.
And then they said in their soil stability
analysis what they're going to do is use their bedrock
PC3 ground motions and scale those to the surface, so
that the PGA is at .2G.
Next slide, please.
MEMBER SIEBER: Do you use actual borings
from the actual location of the plant?
MR. STAMATOKOS: Yes, they have both a
site-wide soil response model, and they have some
site-specific information which they used to show that
the site-wide model is appropriate.
MEMBER SIEBER: So you are comfortable
that there won't be a soil liquification --
MR. STAMATOKOS: Well, I haven't talked
about liquefaction in this particular topic. Yes, but
we're pretty confident that that is also handled in
So this is the -- this diagram, which
didn't come out as clear as I had hoped on the slide,
but anyway, this is the design spectrum that they're
going to use. What they're showing you here is that
PC4 and PC3 spectrum, so this would be the 10,000
year, this is the 2,000 year. Theirs is -- this is
the 160 spectrum anchored at .2G.
And as I said, they tied this to Reg.
Guide 160. The resulting spectrum that they're using
they say is quite comparable to what's used at the
nearby nuclear powerplant. The only differences are
at the -- there are some very low frequencies. The
frequencies of interest in the facility are probably
in this range, but I'll let the engineers address
And then the final point is that the --
these were all done for the horizontal spectrum, and
for the vertical spectrum they originally started with
using the sort of traditional two-thirds horizontal,
but they decided that wasn't conservative enough, and
so they went back and they're using the vertical
spectrum also from Reg. Guide 160 anchored at .2G PGA.
CHAIRMAN POWERS: That's interesting.
MR. STAMATOKOS: Next slide.
So our evaluations, which have been talked
about with -- in our preliminary RAI and in the
meeting with them in South Carolina -- have to do with
the use simply of the Lawrence Livermore and EPRI
hazards and whether or not there is any need to
consider updating those or modifying those slightly to
consider a closer source for the Charleston
There are some differences between what
has been produced for this site and what the USGS --
that's the national earthquake hazard reduction
program has predicted, and that -- those differences,
the USGS -- the NEHRP results are a little bit higher
has to do with just how some of the attenuation models
are scaled. And that was a question that was raised
at that meeting, and we're looking forward to seeing
how they might modify to incorporate the additional
And, of course, we're looking at the site
response information and, in particular, the sort of
interesting way that they're checking their site
response with the alternative method that was proposed
So that's a very quick summary of the
seismic assessment, and I'll be glad to take some
CHAIRMAN POWERS: Any other questions on
this particular area? I bet we get to visit this
MR. STAMATOKOS: I think so, too. Yes.
CHAIRMAN POWERS: I mean, this issue of
closer sources is one that's been around for as long
as I've been going to Savannah River. And it would be
interesting to see how that gets resolved. The other
question, of course, is the bedrock to soil transfers
and how they do that.
Fine. Fair enough.
MEMBER SIEBER: Just are there differences
when they do the two amplification models?
MR. STAMATOKOS: There are some slight
differences, and they show that the one that they're
using is a higher motion than the --
MEMBER SIEBER: The Cornell model.
MR. STAMATOKOS: That's right. So they
justify it by saying, "We did this check, and we still
feel that by anchoring at .2 and using the 160 that we
essentially envelope what a specific hazard would tell
MEMBER SIEBER: Did they compute the
G-forces using separately EPRI and Lawrence Livermore
MR. STAMATOKOS: No.
MEMBER SIEBER: Okay. So this means that
that choice of averaging is -- makes it non-bounding.
MR. STAMATOKOS: In that sense, yes. If
you would just use -- certainly, if you'd use the
Lawrence Livermore, you'd get higher values.
MEMBER SIEBER: That's right.
MR. STAMATOKOS: But I --
MEMBER SIEBER: I'm just wondering if
that's significant or not because --
MR. STAMATOKOS: I don't think so. I
think that -- I think that the choice of giving them
equal weight actually is -- is -- you know, at least
it gives deference to all of the information that's
MEMBER SIEBER: Both of them are just
MR. STAMATOKOS: That's right. That's
right. I think that the proof comes in this
historical check. I mean, you know, if you take --
you know, and that's where this controversy about
where you place the Charleston earthquake is
MEMBER SIEBER: Okay. Thank you.
CHAIRMAN POWERS: On my agenda, I have
physical security. Is -- oh, no, I'm sorry. Material
control and accountability.
MR. PHAM: Good afternoon. My name is Tom
Pham. I am the reviewer in the material control and
accounting, MC&A, area. As you know, complementary to
the physical protection aspect, MC&A is a part of the
overall safeguard program for the applicant.
The basic regulatory requirements for the
MOX MC&A program consists of the MC&A regulation
contained in 10 CFR Part 74, subpart A, paragraphs 51
through 59. This put the applicant into what we call
a Category 1 facility, which requires the most
stringent requirements in MC&A.
Along with the regulations, the applicant
needs to submit a so-called fundamental nuclear
material control plan, FNMCP, following the guideline
for how NUREG guidance document 1280. And this plan
is being prepared by DCS following our NUREG
guideline, and it will be submitted to us with the
operation license application stage.
In the construction authorization
application, and also in two different meetings in
December 1999 and March 2001, DCS staff presented to
the NRC and -- in the CAR application DCS committed to
provide to us the FNMC plan consistent with the NUREG-
1280 and also provide us the overall approach and
different physical aspects of various MC&A elements,
including the process monitoring, the program item
monitoring, the receipt measurement, measurement
system, and how to control the measurement, and also
about the annual inventory, physical inventory.
And the overall aspect is it depends on
the current expected highly automated control process
and manufacturing features.
CHAIRMAN POWERS: Do they give you a
feeling for the kind of MOF that they're going to
have, the materials that they just miss in this -- in
their monitoring process? I mean, do they have a
target for that or anything that --
MR. PHAM: Yes. They -- it's -- I can
give you an overall description. I cannot give you
into detail a description they provide to us. For the
process monitoring, the program is designed to detect
some material in case they -- if that happened.
That's the main idea for the NRC to ask to require
that process monitoring.
And in two different stages, process
stages, the first one, the aqueous polishing, they
want to divide that process in some subdivisions, some
subunit. And in those subunits, they are going to set
up a certain control limit and monitor that through
different material control tests to detect any
potential material lost during three-day or seven-day
tests, depending on the characteristic of the time of
the material getting involved.
And after that process goes through the
material -- the MOX process, the fuel process, they
also divide, depending on the type of material and the
stages, into more subdivisions. And its subunits that
-- they have to set up also the same thing, different
control, material control limits and material control
tests, three-day or seven-day, and also those things
combine to trigger in case they have some kind of
alarm or material loss. So it's in there.
MEMBER SHACK: Well, I think Dana was
asking whether it was some sort of specific kind of
tolerance that they would -- you know, they would
track the -- to plus or minus X grams.
MR. PHAM: Right now, they do not provide
to us those specific numbers. Like, for example, we
don't know exactly right now the applicant wants to
put in one batch -- for example, a batch of material,
10 kilograms or five kilograms or 20 kilograms. It
depends on -- later on, during the operations stage,
depending on that quantity of material, that's what
you need to use your statistical calculation to come
up with the control limit.
At that stage, the staff had to look at
that -- how much is the input and what is -- if the
control limit is appropriate for that material
quantity. And what is the input? What is the output?
What is the process different to calculate it to see
that it is okay?
And even after setting those control
limits, the applicant is still allowed to -- to do
that for a certain period of time to get some
experience and modify their control limit to make sure
everything is running smoothly, how many alarms, how
many -- yes, how many alarms has happened during a
certain period of time. And you have to adjust that
and control that.
But right now, at this stage, they come up
with some information about the design basis to do
that, but not a specific number or even more detail
how they do that in the future.
MEMBER KRESS: Is this different than the
way it's been done in the past?
MR. PHAM: No. This is the normal
operation process the other NRC licensed facilities
are doing, like we have -- right now, we have two
Category 1 facilities, nuclear fuel -- BWXT down in
Lynchburg doing that. And my understanding is the
contractor for writing the fundamental nuclear
material control for the DCS, they are using the
licensee, the NRC licensee people from NFS and other
consultants working in the past have experience in
Cat. 1 facilities.
So we feel like they use the right people,
they use the knowledgeable people, experienced people,
to do that. And how Cat. 2 facilities -- they run
that for many years in 1980s when we first proposed or
when we first put into the regulations for a Cat. 1
facility like the process monitoring program. We put
that back in 1985, and those people have experience to
MEMBER KRESS: Yes. But I thought that
part of that experience was that the plus or minus
that Dana is talking about, if you integrated it over
a number of years, it would come out to be a
substantial quantity. And that's what I think Dana
was getting at.
I don't know what that quantity is, but I
just wondered if they are doing better here or not.
Just a comment for you to think about.
CHAIRMAN POWERS: I mean, it's -- this is
a highly visible program internationally. And losing,
you know, 80 kilograms of material is probably not a
real good idea.
MEMBER KRESS: Not a good idea.
And your system has to be set up to be
sensitive at that level.
CHAIRMAN POWERS: I mean, it seems like
it's a particularly challenging design element, that
you'd want some -- I mean, it seems to me that you'd
want some pretty specific considerations of it at the
design stage, because it's -- it's been a problem in
all of our facilities.
MEMBER KRESS: It's basically a
measurement error and statistics problem that can be
CHAIRMAN POWERS: Well, there is also the
-- I mean, most of the wayward material is actually
just holed up in the system.
MEMBER KRESS: Yes, that's the other part
of it. Where does it get --
CHAIRMAN POWERS: You've got to convince
people that that's the case, and trying to do it after
the fact, after the system has been designed and what
not, is a chore.
MEMBER KRESS: Yes, particularly when
you're dealing with powder and liquified systems you
get that problem.
CHAIRMAN POWERS: And these, of course,
are powders that are particularly obnoxious because
they tend to distribute themselves uniformly over any
surface that they encounter.
MEMBER KRESS: They get electrified.
CHAIRMAN POWERS: Yes.
MEMBER KRESS: Anyway, that's --
MEMBER SHACK: The good news is you can
make the measurements of what goes in and what comes
MEMBER KRESS: Yes. You can do that --
CHAIRMAN POWERS: Yes. But the trouble
is, they're not going to be the same number.
MEMBER KRESS: You can do that for --
CHAIRMAN POWERS: Well, you don't want to
be too glib about that. It becomes increasingly
difficult as you move down this processing line. What
comes in you'll know pretty well.
MR. PHAM: At this stage, the staff found
that the overall approach and the physical aspects of
the DCS MC&A design basis, that they are adequate.
And we have no outstanding issue in this stage, and we
expect to conduct further review when DCS submits the
MC&A plan at the operations stage.
And that concludes my presentation on the
CHAIRMAN POWERS: Any other questions on
this? Okay. I think now we can move to physical
MEMBER KRESS: Is this in closed session
CHAIRMAN POWERS: No. I think this is
Are they different from these?
MS. FRAGOYANNIS: Yes.
CHAIRMAN POWERS: Now, this is Mike
Warren, who has metamorphosed some.
MS. FRAGOYANNIS: You've got new slides
that are coming around.
MEMBER KRESS: These are different than
the ones we have?
MS. FRAGOYANNIS: Yes. Disregard the one
that you have in your packet, since we have one coming
CHAIRMAN POWERS: We've got lots of
MS. FRAGOYANNIS: Okay.
CHAIRMAN POWERS: We're up to date here.
MS. FRAGOYANNIS: Okay. You're up to
date. All right.
CHAIRMAN POWERS: You can't get ahead of
MEMBER KRESS: One package has not arrived
MS. FRAGOYANNIS: Oh, okay. Well, we'll
start. My name is Nancy Fragoyannis. I'm a physical
protection specialist here at the NRC, and I do want
to mention before I get into my presentation that
discussions and reviews of physical protection were
made prior to September 11th.
As a result of the events of
September 11th, the NRC is conducting a top to bottom
review of physical protection regulations, including
the design basis threat. That is an ongoing process,
and we're communicating frequently with other agencies
throughout the government.
So what we'll be discussing today is pre-
9/11, and many of these may change. So what I'm going
to do is I'm just going to give you a quick overview
of the process that we went through and just some of
the security measures that we would have implemented
at the time.
What we're doing in the physical
protection is -- the goal is to protect nuclear
material or facilities from unauthorized removal of
nuclear material and sabotage. The safeguards
approach that we use in order to protect our
facilities is, first, a graded approach, and that's
dependent on the type of material, the significance of
Then we incorporate a defense-in-depth
strategy, which will include multiple barriers which
could be physical barriers such as fences, reinforced
walls, or even protective forces. Various alarms,
whether they're internal or external.
Can you hear me okay when I back up?
Communications, onsite and offsite, and
response. And regarding response, you will have
immediate response by your licensees and then
reinforced response through local law enforcement and
the Federal Bureau of Investigations.
NRC provided DCS with a detailed SRP and
other documents to help in their -- to assist, excuse
me, in the physical protection design. DCS, in turn,
provided us a comprehensive briefing on protection
strategies and designs that they would incorporate in
the facility. That included defensive strategies,
location of their guards, wall structure, types of
walls, thicknesses of their MMAs in vault areas, and
they also discuss the modeling tools they use for
vulnerability assessment, which will help in worst-
case scenario and as well as response force.
The NRC will review a physical protection
training and qualifications and contingency plan --
will review that to make sure that they do meet the
intent of our regulations, as well as do an onsite
MEMBER KRESS: Will these measures be
tested routinely by --
MS. FRAGOYANNIS: Well, there are
requirements to test measures, yes. Your protective
force will be tested routinely through various force-
on-force exercises throughout the course of the year.
There are a certain number that you have to do, yes.
I'm just going to go over a number of
measures. This is not all inclusive. And this first
group is more physical protection measures that you
would incorporate at the site. First, is your dual
perimeter fences that have an isolation zone. And
there is where our PIDAS -- our perimeter intrusion
detection and assessment system is incorporated, where
we will have alarms, CCTV coverage, adequate
illumination to provide detection and assessment for
the protective force.
MEMBER KRESS: Are there specifications on
what the fence has to be?
MS. FRAGOYANNIS: There are certain
specifications at this time, and we don't know if that
will change. But there are specifications, and the
type of alarm system that has to be tested, routinely
tested for operational and effectiveness testing. So
there are a number of those that will be incorporated.
We have a hardened central alarm station
that will be manned 24 hours a day with another
independent, secondary alarm station in the event of
an emergency. Volumetric alarms in unoccupied areas
for quick type of detection and then an assessment.
On the next --
MEMBER SIEBER: I presume the CAS will
have its own emergency diesel generator?
MS. FRAGOYANNIS: It will have -- if I'm
correct, I believe it does. Yes, it does. It will be
independent, yes. So it will be a stand-alone
redundant system at the SAS also.
MEMBER SIEBER: All right.
MS. FRAGOYANNIS: These are some other
measures, not physical in itself, but more operational
measures. There will be access control points in
which contraband will be screened, firearms,
explosives, and other contraband deemed at the site.
There will be also exit searches for
special nuclear material coming out of the facility.
The MAAs will be locked and alarmed, and there will be
access control in those areas, limited control areas
also, so they won't allow anybody into the material
access area. HEU and PU will be stored in vaults.
Here we talk quickly about protective
local police response force, but on the next page I
get into a little more about the armed response.
There will be armed security force onsite provided by
the Savannah River site. They will have
qualifications and training for site members. They're
going to have a special tactical response team,
special response team for DOE, who are more like their
SWAT members, and they will have special training and
There will be performance evaluations
conducted on the protective force. It could be in
writing. It could be test-taking as well as firearms
training and other response training. And then we'll
have multiple offsite communications, actually onsite
and offsite, but in that case --
And then these are some other measures
that we're going to also incorporate, and we want to
protect against internal conspiracies, possibly put
CCTVs at locations, two-man rule, MC&A controls,
additional searches, maybe a -- I believe it was a
two-guard search or two searches going out, so no
nuclear material will be removed.
They will have a personal screening
program, the fitness for duty and access
authorization, and full-field background
investigations will be conducted if the government --
MEMBER KRESS: Does that include drug
MS. FRAGOYANNIS: I'm sorry. Drug testing
-- I believe fitness for duty is drug testing.
And just a quick overall summary. It is
on the Savannah River site, the DOE reservation, the
MOX facility will be located. They will be protected
by the Savannah River site guard force.
In January of this year, NRC traveled to
Savannah River site to meet with DOE security
management and discuss onsite security. At that time,
they had the opportunity to observe two force-on-force
exercises conducted by the protective force. NRC
staff was very pleased with the results, which help
reinforce that we think that the Savannah River site
and DCS will be able to provide the level of
protection needed for the MOX facility. And as we
indicated, they had two force-on-force exercises
I must add that the MOX facility, in
addition to meeting NRC regulations, will also have to
meet certain DOE landlord requirements. Thus, it may
go over the NRC regulations and requirements.
And we feel that the security prior to
9/11 and the discussions we had and some of the
documents we reviewed will protect the public health
and safety. And, again, after 9/11, that will all
have to be reviewed again.
CHAIRMAN POWERS: Stay tuned.
MS. FRAGOYANNIS: Yes.
CHAIRMAN POWERS: None of us know exactly
what that one will be.
MS. FRAGOYANNIS: Well, time will tell on
MEMBER SIEBER: Your personnel screening
program, I presume that the screening that's done will
be at a higher level than it would be for powerplant
MS. FRAGOYANNIS: Well, it would be for
the Category 1 facilities.
MEMBER SIEBER: Okay.
MS. FRAGOYANNIS: Yes. Yes.
MEMBER SIEBER: So it's equivalent to
MS. FRAGOYANNIS: It's different than your
power reactors, yes. They will get background
investigations where they have access to classified
MEMBER KRESS: What do you do about
offsite contractors that come in occasionally to do
maintenance and things? Are they --
MS. FRAGOYANNIS: We haven't really gotten
to that point yet where we've discussed -- do you mean
MEMBER KRESS: Yes.
MS. FRAGOYANNIS: I don't think we've
gotten to that point where there's like one to five or
one to three. I don't know. We haven't gotten there
yet. I can't answer that.
MEMBER SIEBER: But they will be escorted
just like in a powerplant.
MEMBER KRESS: Oh, yes.
MS. FRAGOYANNIS: They will be escorted,
but I can't tell you the number of escorts per onsite
contractor, independent --
MEMBER SIEBER: I take it there is not yet
a physical security plan by the applicant nor a TQ
MS. FRAGOYANNIS: I can't answer that.
I'm sorry. I don't know that.
MEMBER SIEBER: Oh, okay.
MS. FRAGOYANNIS: We had a very thorough
briefing provided to us because it's a classified
briefing, and they went through what they plan on
doing for physical protection. And that was provided
to us. I apologize. I'm not the main person on the
MOX project, so I -- I've been involved in it, but I
don't know if there's a specific plan that has come
MEMBER SIEBER: But NRC approval is
usually based on --
MS. FRAGOYANNIS: Oh, yes, I'm sorry. It
will be based on a plan, and we will review that plan
and then do an onsite verification, yes.
MEMBER SIEBER: Okay.
MS. FRAGOYANNIS: Sorry.
Any other questions? I'm sure you'll have
more for me --
CHAIRMAN POWERS: Well, I guess -- you
know, I sit here saying -- I'm picturing the site.
MS. FRAGOYANNIS: Okay.
CHAIRMAN POWERS: And I'm saying, okay,
I've got Savannah River, and then I have this new
operational entity operating in there. And at the
gates, and what not, it has its own people. And then
-- but then there's this other layer out there, and
I'm saying, what goes wrong in the interface between
MS. FRAGOYANNIS: Well, the goal -- it's
going to be the -- are you talking about the
protective force itself? The protective force will be
from Savannah River. They will augment their current
forces in order to be able to protect the new
facility, and there will definitely be coordination
between the sites out there, because you've got the --
it's a very large reservation. I don't know the exact
size of the reservation, but they've got a number of
buildings. This will be a separate protected area.
MEMBER KRESS: It had design basis threats
that you've already identified prior to --
MS. FRAGOYANNIS: Pre-9/11, yes. We had
the design basis threat pre-9/11, and -- but we don't
know what changes will be made. And, of course, we'll
have to incorporate that in the security plan. But
those were discussed prior to.
MEMBER SIEBER: If you want a description
of that, that's in the first set of slides you got.
MS. FRAGOYANNIS: I wanted to avoid that.
That's an unclassified version which --
what you have there, it just gives you a -- just a
quick synopsis of what the DBT was prior to 9/11.
CHAIRMAN POWERS: Okay. Any other
questions? Thank you.
MS. FRAGOYANNIS: Thank you.
CHAIRMAN POWERS: We'll come now to a
MR. PERSINKO: Thank you. At the outset,
we said we were here to tell you a little bit of
information about a lot of areas, and I think we did
that. And, in fact, in some areas we --
CHAIRMAN POWERS: You did very well, too,
by the way. I am very --
MR. PERSINKO: Well, thank you.
CHAIRMAN POWERS: -- impressed with the
amount of information you were able to pack in.
MR. PERSINKO: And I was going to say, and
maybe in some cases we gave you a lot of information.
But even though we did that, there are still areas we
did not discuss with you, for example, quality
assurance, human factors, wind and tornadoes,
structural criteria, heavy load, control of heavy
loads, material handling, fluid systems.
So there are still a number of areas that
we have not discussed, primarily due to time
limitations. We'd be happy to discuss any of these
areas with the committee. We'd also be happy to come
back and talk to you about any of the areas we spoke
today about in more detail.
And one thing we would seek from the
committee is feedback. We are in the process of doing
our review. We're well along in our review, and we
would appreciate feedback from the committee,
preferably in the form of a letter, so that we know
whether we are moving in the right direction or
whether there are areas that we should be doing
differently or items we should be considering
But this is a good stage that we get the
feedback, because our schedule, as I showed you at the
outset, was to issue a draft SER in April. So we can
make mid-course corrections right now.
And with that, that concludes the staff's
CHAIRMAN POWERS: Now, your schedule is
for April. What I want to do is try to schedule
things with the full committee. I know right now that
they will shoot me dead if I try to get something in
on the February meeting. So it strikes me as March is
the earliest we can.
What I would propose doing, then, is
sometime after the first of the year getting together
with you and discussing the areas that I think you
should bring up in a meeting to the full committee,
because it's only the full committee that can produce
a letter. And it will be the areas -- it's going to
I'm going to pick the areas that I think
we have the most questions about, so that you're not
going to get to put your best foot forward. Okay?
Because I want to concentrate on that,
because I want to get feedback on the areas that --
where we might have comments about what you're doing.
And I will do that with you sometime after the first
of the year, once I can get us a slot on the schedule,
which is a bit jammed right now with power uprates and
license renewals coming in at prodigious rates. We're
just getting booked. That's the problem.
But I -- we'll have to strategize exactly
how we want to present that. And some of the
materials I think can be presented in a summary
fashion, and some areas we will want to go into
detail. In the meantime, I am going to ask that the
Fire Protection Subcommittee take over looking at the
fire protection aspects of this rather than the Fuel
Subcommittee. I think that's just efficient and it's
-- it's an area that can be broken out fairly
efficiently on that.
And I'm sure fire protection will be one
of the issues that we'll want to bring up with the
full committee, and what not. And so I propose we'll
just get back after the first of the year on those
things. And before then, I can assure you that you
put on an impressive show here. This was --
MR. PERSINKO: Thank you very much.
CHAIRMAN POWERS: -- extremely well done
presentations, extremely well organized, and if
nothing else you persuaded at least the Chairman of
this committee that you guys have got your act
together. So, but I think we will try to get you
before the committee, but I think it -- I think the
earliest we can do that is the first week of March.
MR. PERSINKO: Okay. Thank you very much.
Any feedback we can have would be appreciated.
CHAIRMAN POWERS: Okay. Well, and, of
course, the comments that came around here, you have
MR. PERSINKO: We've taken note of those.
CHAIRMAN POWERS: And if you -- and I
think the members are always willing to follow up with
you if you just want some elaboration on, you know,
what were you talking about, and what not. In the
meantime, the members are getting this several pounds
of documentation to get themselves all up to speed on
this, and more is coming. I know that, indeed. Thank
you very much.
MR. PERSINKO: Thank you.
CHAIRMAN POWERS: Let's see, the next
scheduled -- we're a little ahead of schedule. I
wondered if -- Dr. Lyman, are you prepared to make
your presentation? Why don't you go ahead and do
that. I think most of the members are -- have met Dr.
Lyman. If you have a written copy of your
presentation, can we get one for the record, or --
MR. LYMAN: I actually don't. But I can
maybe supply one afterwards.
CHAIRMAN POWERS: Oh, sure. Whatever is
easiest. Well --
MR. LYMAN: I'm going by the seat of my
pants here. Things are changing very rapidly. And I
don't have much time today, but since, Dana, you've
anticipated a lot of what I was going to say, as
usual, it makes my job easier.
The Nuclear Control Institute has had a
long-standing concern with the U.S. MOX program, in
particular issues of safeguards and physical
protection. And to cut to the chase, I think in this
context the question we have to ask right now -- is
the approach that the staff and DCS are taking for
safeguards and physical protection at this facility --
the question is: are those approaches adequate to the
We had concerns about that pre-September
11th, and now that it's post-September 11th our
concerns are even greater. For that reason, I did
assist Georgians Against Nuclear Energy, or GANE, in
preparing a couple of the contentions which they've
submitted in the current licensing proceeding on the
construction authorization request. And I guess I'd
just like to summarize some of my concerns in that
I think the overarching concern we have is
that the inertia of NRC and its whole regulatory
bureaucracy may interfere with the ability to make
changes swiftly enough so that this proceeding can be
more credible in light of post-September 11th events.
And to illustrate that, I'd just like to point out
that The Washington Post, in a front-page story on
November 3rd, used an NRC staff legal brief in this
proceeding to illustrate the sluggishness of the
It was a brief dated September 12th, and
it was responding to GANE's contention that sabotage
issues should be considered in the MOX plan
environmental impact assessment. The staff's response
on September 12th was, "That's not necessary because
it doesn't meet the legal tests that a terrorist act
is a reasonably foreseeable occurrence."
Now, I think NRC has to be extremely
careful now about avoiding stories like that in the
future, because I think it may affect its credibility
and public confidence that it's dealing with these
issues in a timely way.
And I'd just like to recap some of the
issues that GANE has raised in this proceeding. I
think the -- one of the overarching concerns we have
is the fact that the license application under Part 70
has been bifurcated effectively into two pieces. One
is the construction authorization request, which is
not a document defined in Part 70 in any way. It's an
invention of DCS and the staff.
And the impact of this is that the CAR
itself contains a fairly limited amount of
information, and, in fact, does not contain
significant bodies or significant categories of
information which one may argue is something that
should be available at the design stage and be part of
The fact that a number of issues have been
segregated and deferred to the actual application for
the license to possess and use SNM means that there is
certain information not available now to the staff
that may actually be very relevant at the design
stage. And in my mind, one of the primary areas where
this is true is what was just discussed before in the
material control and accounting area.
It seems to be accepted wisdom in other
quarters that -- that material control and accounting
should be an important feature at the design stage,
and that issues of making sure that the systems are
adequate to the task at hand is something that should
be built into the design. Both the International
Atomic Energy Agency has emphasized that, and so has
In fact, a report from 1997 with co-
authors from Los Alamos and Sandia made exactly this
point, that there are design considerations that have
to be taken into account at the design stage to make
sure that the material control and accountancy and
physical protection systems will work as billed when
the plant is built.
And if those aren't considered at the
design stage in enough detail, there's a risk that
there may have to be expensive backfitting to modify
those systems to make sure that they actually can meet
the regulations. One good example -- I'm sorry.
CHAIRMAN POWERS: Let me interject here.
You know, you could argue that NRC's job is to set the
standard, and it's the licensee's job to meet that
standard. And if he wants to blow this off at the
design stage, that's his business. NRC just says when
the thing is up and running, it's got to meet the
Certainly, the designers might be foolish
not to recognize what IAEA has said about this. But
if they want to ignore that, shouldn't they have --
shouldn't it be left up to them?
MR. LYMAN: Well, that actually was the
argument that DCS made in responding to this
contention. They said, "Well, we're willing to assume
the risk." You know, you say, "Well, we may have to
backfit later. We're willing to take that risk." But
the fact is DCS is doing the public's job and, in
fact, they're not assuming any risk at all. The
public is going to end up with the bill.
So I think it's really the public's -- it
should be in the public interest to determine whether
or not DCS should be allowed to risk their money or
not. So that was a pretty disingenuous comment on the
part of DCS.
A second part is that this is a program of
larger implications, as Dr. Powers mentioned. The
International Atomic Energy Agency theoretically
should play a role or even apply verification to this
facility, because this program is not in isolation.
It is a bilateral program, hopefully with an
international component. And we have to lead the way
And to that end, I still haven't seen --
I know -- if there is a response to a letter sent to
DOE in December 1999 by NRC saying it is their
operating assumption that IA safeguards would be
applied to this facility, and if they could get an
answer, a clarification of that as soon as possible,
it would assist in their review of the design.
And I have not found a response to that.
Maybe Pat Rhodes would be able to supply that
response. But to my knowledge, DOE ignored this
request. So it right now is not known to the extent
to which IAEA will be allowed access to this facility.
And that would be an important component, especially
at the design stage, because it -- for instance, the
Los Alamos report in 1997 indicates that if
international safeguards are going to be applied there
are space considerations and other things which may be
important in the design.
So I do think that the inappropriate
limitation of what we should look at at the design
stage and what information is necessary to make the --
to approve construction, that limitation is
inappropriate, especially now. I think that the
applicant should be willing, well, to exceed what may
be the appropriate requirements.
After September 11th, I think they should
step to the plate and say, "Well, we're going to take
this issue -- issues of both safeguard and physical
protection as seriously as possible. And we're not
going to be bound by this very strict legal -- what
we're required to do and no further." I think that
doesn't show good faith on their part in this threat
I just wanted to get in one more
illustration of the importance of design
considerations in safeguarding, and that's the
experience of the plutonium fuel fabrication facility
in Japan or plutonium fuel production facility, PFPF,
where this plant operated for a few years, accumulated
at least 70 kilograms of plutonium in the ductwork,
necessitating a shutdown for many years, including a
cleanout and a complete redesign of the internal
measurement systems, redesign of the gloveboxes to
improve the ability to measure in-process materials,
all to the tune of over $100 million.
So this issue of backfitting is a
significant cost, and, really, I think there has to be
additional attention now and additional information
about details of the material control and accounting
system and how problems like holdup will be mitigated
by the design.
The second issue I'd like to raise is,
again, in the post-September 11th context. I am
encouraged by the letter that NRC sent to DCS only a
few days ago reminding DCS that the design basis
threat, as well as all other physical protection
regulations, are under review.
But this letter wasn't very helpful. It
said that NRC couldn't say right now what was going to
happen, if anything, but DCS should be aware of it.
But certainly there needs to be a better sense right
now of whether there's going to be a major change in
the design basis threat and other aspects that might
affect the design of the facility.
And to that end, GANE and NCI did file, on
October 13th, a motion to postpone the existing
proceeding pending the results of the top to bottom
security review, and we maintain that that's prudent
because staff resources are being wasted right now in
a review of the design which may be obsolete in the
post-September 11th era.
And one aspect which I think deserves
particular attention is the aspect of resistance of a
plant to a deliberate air crash. The facility, as
designed now, screened out even accidental air crashes
as part of the design basis on the basis of low
probability. So there is no -- not even any
consideration of an air crash as an external event
threatening the plant.
Therefore, the design basis missiles used
to establish the missile resistance of the building
are those generated by tornados and high winds, which
are considerably less penetrating than the jet engine
of a 767 plowing into the facility at full speed. I
calculate the penetration of the design basis missile
to be something like a factor of 10 lower than what
the jet engine in the 767 would be at full speed.
So whether the appropriate new design
basis threat should include an intentional plane crash
I think has to be considered. And for all we know,
the whole way that nuclear facilities are going to be
built in this country or elsewhere is going to have to
be rethought in the context of this kind of threat.
It may be that facilities will have to go
underground in the future. That may be a significant
constraint that would lead to a substantial redesign
of this facility. So these questions have to be
asked, and obviously they are appropriate for the
So, you know, we do feel that there needs
to be a pause in the review until questions are
clarified. And, again, this is because the public is
paying the bill for this facility.
One last issue is something we're
concerned about, and that's the control area boundary
definition, which is cross-cutting and impacts the
whole safety basis for the facility. I missed the
discussion this morning, but I'd just like to
reiterate our position that it only makes sense to
define the controlled area boundary as one which is
reasonably -- reasonably includes only the facility
that we're talking about and not the entire Savannah
I think that such a definition simply does
not pass the red face test, and to imply that the
licensee, DCS, can by any definition have authority,
sole authority to exclude anyone from the entire
Savannah River site, which is what the regulations
require, that kind of authority should not be granted
to a private entity. And it clearly seems to violate
the intent of Part 70 as written to have such an
extensive definition for the controlled area. And we
believe that a legal review will show that our
position is right.
So I think I'll stop there. Thank you.
CHAIRMAN POWERS: Will you entertain
questions if members have any?
MR. LYMAN: I'll try.
CHAIRMAN POWERS: Any people have
Mr. Lyman, I will recall for you that I
think in one of your packages you have a recently
published paper on use of MOX as a disposal means.
And it's -- I can attest to be a good read. So I'd
recommend it to the members to read.
Any questions for Mr. Lyman?
MR. LYMAN: Thank you. Appreciate the
CHAIRMAN POWERS: Let's chat just a minute
or two before we adjourn about strategy. I suggest
that we have something of an oral summary on this
meeting and acquaint the full membership with this
coming along the pike at our December meeting, just
mostly to say that -- to summarize the fact that we
have met and the kinds of things that we forecast.
I see some challenges for us in the
instrumentation area, just because of the dilution of
membership. Mr. Persinko mentioned to us several
areas we have not gone into which includes flow
systems, and what not. I am sure that if I bring up
flow systems for our Thermal Hydraulics Committee they
will throw large, heavy objects at me. So we may have
some challenges there.
I think we should ask the Fire Protection
Subcommittee to look at this in addition to us,
because it's an issue up their alley, and it -- it can
be split out kind of easily, I think.
Are there any other suggestions on
MEMBER KRESS: I think your thought of
narrowing the presentations down to items where we may
have additional questions or concerns is a good one.
We'll have to define what those area, so --
CHAIRMAN POWERS: Yes. If members could
send me notes on the areas that they think those
presentations should be concentrated in for the -- it
will probably be the March meeting.
My thinking is if we're going to prepare
a letter that has feedback, we've got to bring up
those items where we're going to have feedback. And
this covers a host of things, and I don't see any
convenient way to cut it down, because they were
pretty synoptic presentations they made to begin with.
So it's a little hard to tell them what to leave out
on any one of them. So I'd like to focus on those
areas where I think we'll have comments on.
I am -- I have a sense that we'll have
comments on the fire protection area for sure, the
MC&A area for sure. I think --
MEMBER KRESS: And there may be some
CHAIRMAN POWERS: We're going to have some
questions about the philosophical approach overall
here, including the bifurcations issues.
MEMBER KRESS: And I suspect we may have
some safeguards issues.
CHAIRMAN POWERS: Well, you know, I'm
reluctant to bring that one up because I think it's --
I think it's still too much up in the air, and I'd
rather do it as part of our more integrated view. You
know, we're going to have -- we're going to have to go
back and understand better what the results are of
what the NRC is doing now. There is no point in going
back immediately on that because they are still fixing
to do it.
And then, I mean, once they're in a
position there, then I think this is one of several
areas that this comes up in. And I wouldn't leave
them out of this.
I do see a distinction between this
facility and commercial facilities. I mean, you know,
commercial nuclear powerplants and a facility doing a
government job on a government reservation. I see
MEMBER KRESS: It's two completely
separate missions, too.
CHAIRMAN POWERS: Yes.
MEMBER KRESS: And that needs to be
CHAIRMAN POWERS: Right.
MEMBER SIEBER: Well, the philosophical
approach to safety is different, too. Our plants use
PRAs, and these kinds of plants are integrated safety
assessments, and I think people need to understand
what that really means and how they're done.
CHAIRMAN POWERS: Yes. That's the other
thing we should think about. In the presentation to
the full committee, they really need our Wednesday
morning presentation as well as this presentation. I
mean, they have to have both of them. We'll have to
figure out how to do that exactly. So I think I'm
going to --
MEMBER KRESS: Just more time on the
MEMBER SIEBER: I think we ought to
CHAIRMAN POWERS: Yes, that's --
MEMBER SIEBER: -- to the meeting. That
CHAIRMAN POWERS: That would make people
real happy with me, wouldn't it?
Okay. So we've got some challenges to
deal with the planning and procedures folks. Any
Well, again, I want to thank the speakers
and presenters. I think seldom have I seen such
terrifically organized and well-presented material for
a one-day meeting. It was an outstanding job. I
think it does reflect well on the kind of work that's
being done at this stage, and it was very useful to
the subcommittee. I think it will be useful to the
MEMBER KRESS: And I think we should thank
Mr. Lyman for his input.
CHAIRMAN POWERS: He always has something
useful to tell us, and I encourage the members, if
they have a chance, to take time to look at the GANE
submission here. They didn't have a chance to
present, but I found it interesting reading.
And with that, I will adjourn the meeting.
(Whereupon, at 2:56 p.m., the proceedings
in the foregoing matter were adjourned.)
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