Reactor Fuels - Mixed Oxide (MOX) Fuel Fabrication Facility - November 16, 2001

                 Official Transcript of Proceedings


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
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                          (202) 234-4433             UNITED STATES OF AMERICA
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                 NOVEMBER 16, 2001
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                ROCKVILLE, MARYLAND
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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.
                 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
           ALSO PRESENT:
                 DAVID BROWN
                 FRED BURROWS
                 JOHN CALVERT
                 NANCY FRAGOYANNIS
                 JOSEPH GIITTER
                 TIM JOHNSON
                 ED LYMAN
                 ALEX MURRAY
                 ANDREW PERSINKO
                 TOM PHAM
                 JOHN STAMATOKOS
                 SHARON STEELE
                 CHRISTOPHER TRIPP
                 REX WESCOTT
                                            I N D E X
                         AGENDA ITEM                       PAGE
           Introductory Remarks                               4
           MOX FFF Presentation
              Introduction                                    8
              Safety Analysis                                23
              Radiological Consequences                      51
              Chemical Process and Products                  66
              Nuclear Criticality Safety                     82
              Fire Safety                                    99
              Confinement Ventilation                       115
              Electrical                                    131
              I&C                                           143
              Seismic                                       155
              Material Control and Accountability           164
              Physical Security                             172
              Summary                                       183
           Presentation by Ed Lyman, Nuclear Control        187
           Discussion and Adjournment                       197
                                                    (8:38 a.m.)
                       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
           new facility.
                       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-
           established technology.
                       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
           becomes interesting.
                       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
           current schedule.
                       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
           the regulations.
                       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
           the process.
                       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
           in France.
                       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
           important one. 
                       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
                       Next slide.
                       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
           values primarily.
                       Next slide.
                       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
           some point.
                       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
           currently are.
                       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
           design bases.  
                       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
                       Next slide?
                       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
           applicant's analysis.
                       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
                       Next slide?
                       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
           management measures.
                       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
           facility workers.  
                       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
           approximate goal.
                       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
           just --
                       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
           out again.
                       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
           24.9 --
                       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,
           next slide.
                       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.
                       Next slide?
                       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
           review on.
                       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
           or --
                       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
           pose --
                       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
           expect that?
                       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
           that question.
                       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
           procedural requirements.
                       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
           be followed.
                       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
           for safety.  
                       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
           this issue.
                       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
           this stage.  
                       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
           criteria --
                       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
           let --
                       CHAIRMAN POWERS:  Seismic is not easy at
           this --
                       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
           that part.
                       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
           plausibility grounds.
                       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
           analyses there.
                       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
           filtration system.
                       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
           next slide.
                       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
           performance requirements.
                       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
           satisfactorily resolved.
                       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
           database essentially?
                       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
           gentlemen's problem.
                       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
           correct.  Yes.
                       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
           little bit.  
                       MR. BROWN:  Right.  We can always talk
           about that.
                       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
           are discussing.
                       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
           other impurities.
                       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
           with that.
                       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
           this country.
                       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
           four state.
                       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
           processing step.
                       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
           proposed facility.  
                       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
           discuss shortly.
                       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
           in France.
                       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
           control room.
                       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
           admin controls.
                       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
           current, Dana.
                       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
           high consequences.
                       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
                       10:45 a.m.)
                       CHAIRMAN POWERS:  I think we can come into
           session now.
                       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
           construction application.
                       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
           with plutonium.
                       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
                       Next slide?
                       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
           nitrate solutions.
                       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
           anything, huh?
                       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
           been approved. 
                       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
           questions --
                       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
           initiating event.
                       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
           the operators.
                       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
           control systems.
                       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
           me clearly?
                       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
           be optimistic.
                       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
           that next.
                       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
           safety analysis.
                       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
           for safety.
                       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
           cases --
                       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
           Dodecane around.
                       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
           suppression --
                       CHAIRMAN POWERS:  Not to the control room?
                       MS. STEELE:  I'm sorry?  Polish and
           control room.
                       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
           the operation.
                       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
           stands for.
                       MS. STEELE:  The fire hazards analysis. 
           I apologize.
                       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
           the --
                       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
           response time.
                       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
           appropriately rated.  
                       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
           stop anything.
                       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
           sustain combustion.  
                       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.
                       Any questions?
                       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.  
                       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
           incidents --
                       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
           doing this.
                       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
           a fire?
                       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
           ventilation system?
                       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
           sand filter.
                       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
           fire area.  
                       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
           looking at.
                       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.)
                                A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (1:16 p.m.)
                       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
           presentation here.
                       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
           for maintenance.
                       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
           basic analog.
                       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
           Class 1E.
                       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
           Class 1E.
                       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
           emergency loads.
                       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
           other bus?
                       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
           you're operating?
                       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
           ventilation system.
                       MEMBER SIEBER:  And what are the
           consequences if the fans don't operate?
                       MR. BURROWS:  Well --
                       MEMBER SIEBER:  A release?  It looks like
           everything --
                       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
           confinement zones.
                       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
           those systems.
                       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
           control room.
                       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
           safety problems.
                       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
           interesting choice.
                       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
           principal SSCs.
                       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
           and leave.
                       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
           of facility.
                       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
           any questions?
                       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.
                       Thanks, John.
                       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
           ground motion.  
                       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.
                       Next slide?
                       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
           the application.
                       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
           attenuation models.
                       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
           by Cornell.  
                       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
           out there.
                       MEMBER SIEBER:  Both of them are just
           opinions anyway.
                       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
           do that.
                       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
           dealt with.
                       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
           out precisely.
                       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
           or not?
                       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
           I guess.
                       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
           the material.
                       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
           the TQ?
                       MS. FRAGOYANNIS:  It's different than your
           power reactors, yes.  They will get background
           investigations where they have access to classified
           material, yes.
                       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
           escort requirements?
                       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
           the two?
                       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
           be difficult.  
                       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
           heard those.
                       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 review.
                       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
           by example.
                       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
           design phase.
                       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
           River site.
                       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?  
                       Thanks, Ed.
                       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
           strategy here?
                       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
           defense-in-depth questions.
                       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
           distinctions here.
                       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
           have --
                       CHAIRMAN POWERS:  Yes, that's --
                       MEMBER SIEBER:  -- to the meeting.  That
           would do.
                       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
           other comments?
                       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
           full committee.
                       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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