ML20135E646

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Transcript of ACRS 437th Meeting on 961205 in Rockville,Md. Pp 1-253
ML20135E646
Person / Time
Issue date: 12/05/1996
From:
Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-2086, NUDOCS 9612110388
Download: ML20135E646 (347)


Text

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i Officitl Trcnscript of Prsce dings

NUCLEAR REGULATORY COMMISSION O

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Title:

Advisory Committee on Reactor Safeguards j 437th Meeting TRO4 (ACRS)

RETURN ORIGINAL TO BJWHITE Docket Number: (not applicable) 7(sg2g2s THANKS!

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! Location: Rockville, Maryland i

h Date: Thursday, December 5,1996 Work Order No.: NRC-926 Pages 1-253 21 8 961205 T-2006 PDR , _ _ , , , , , ,

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DI8 CLAIMER PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS DECEMBER 5, 1996 The contents of this transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards on DECEMBER 5,

) 1996, as reported herein, is a record of the discussions recorded at the meeting held on the above date.

This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.

1 1 UNITED STATES OF AMERICA

,-~ 2 NUCLEAR REGULATORY COMMISSION ,

\_.

3 +++++

l 4 437TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 6 +++++

7 THURSDAY 8 DECEMBER 5, 1996 9 +++++ l 10 ROCKVILLE, MARYLAND 11 +++++

12 The Advisory Committee met at the Nuclear 13 Regulatory Commission, Two White Flint North, Room T2B3, 14 11545 Rockville Pike, at 8:30 a.m., Thomas S. Kress, 15 Chairman, presiding.

16 COMMITTEE MEMBERS: J 17 THOMAS S. KRESS, Chairman 18 ROBERT L. SEALE, Vice Chairman 19 GEORGE E. APOSTOLAKIS, Member 20 IVAN CATTON, Member l 21 MARIO H. FONTANA, Member l 22 DON W. MILLER, Member j 23 DANA A. POWERS, Member 24 WILLIAM J. SHACK, Member O

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2 l

1 ACRS STAFF PRESENT:

2 JOHN T. LARKINS, Executive Director

'" 3 MICHELE KELTON, Technical Secretary 4 SAM DURAISWAMY 5 CAROL A. HARRIS 6 RICHARD P. SAVIO 7 PAUL BOEHNERT 8 NOEL DUDLEY 9 MEDHAT M. EL-ZEFTAWY 10 MICHAEL T. MARKLEY l

11 AMARJIT SINGH l 12 13 ALSO PRESENT: l f~s

'v) t 14 GARY HOLAHAN 15 MARK CUNNINGHAM 16 WAYNE HODGES 1

17 ANN RAMEY-SMITH 18 FRANK COFFMAN 19 JARED WERMIEL 20 CHRISTINA ANTONESCU 21 JOEL KRAMER 22 MICHAEL E. MAYFIELD 23 JACK STROSNIDER 24 DICK WESSMAN O

i ) 25 GERRY WEIDENHAMER NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

3 1 ALSO PRESENT (Continued):

-s 2 JITENDRA VORA

~

3 ANDY MURPHY 4 CECIL O. THOMAS 5 FRANK COLLINS 6 DENNIS SERIG 7 JACK ROSENTHAL 8 ERNIE ROSSI 9 BRUCE BOGER 10 11 12 13 (m

14 15 16 17 18 19 20 21 22 23 24 m

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( 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

4 1 A-G-E-N-D-A

- 2 Acenda Item Pace w

3 Opening Remarks by the ACRS Chairman 5 4 Proposed Standard Review Plan Sections and 5 Regulatory Guides Associated with Risk 6 Informed, Performance Based Regulation 12 7 NRC Research Program on Instrumentation and 8 Control Systems 48 9 Plant Aging Research Program 109 10 Human Performance Program Plan 184 11 12 13 p

14 l 15 16 17 18 19 20 21 22 23 l

l 24

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5 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:34 a.m.)

G 3 CHAIRMAN KRESS: Will the meeting please come 4 to order now.

l 5 This is the first day of the 437th meting of 6 the Advisory Committee on Reactor Safegruards. During 7 today's meeting, the committee will consider these items 8 in this order: I I

9 1. We are going to go over first some items for i

10 our meeting with the commissioners tomorrow.

11 2. We will hear about the proposed standard 12 review plan sections and regulatory guides associated with 13 risk-informed performance-based regulation. l I

/T 14 3. We hear about the NRC research program on I&C l

15 systems.

16 4. Then we will hear about the plant aging j l

17 program.

18 5. We will have presentations on the human 19 performance program plan.

20 6. And then we will work on our reports. l 21 I would like to point out to members in the t

22 audience that this agenda has some minor schedule changes l

l 23 in it. The discussion of the item regarding the prcposed 24 standard review plan sections and a regulatory guide

'O 25 associated with risk-informed, performance-based 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j 1323 RHODE ISLAND AVE., N W.

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6 l

1 regulation will begin at 9:30 this morning instead of 8:45 1

, _s 2 as it had on an earlier agenda which you may have had.

t i

~ 3 So, if you are here to hear about that part, ,

I 4 you may want to take a coffee break until 9:30 a.m.

5 because we are going to talk about some dull, internal )

6 items before then.

7 This meeting is being conducted in accordance 8 with the provisions of the Federal Advisory Committee Act.

9 Dr. John T. Larking is the designated federal 10 official for the initial part of the meeting.

11 We have received no written "tatements or i

12 request for time to make oral statements from members of 13 the public regarding today's session. A transcript of

/3 k/ 14 portions of the meeting is being kept, and it is requested 15 that the speakers use one of the microphones, identify 16 themselves and speak with sufficient clarity and volume so 17 that they can be readily heard.

18 I will begin with some items of current 19 interest to members. You have a little handout on this in .

I 20 front of you. All I want to do is flag a couple of things 21 in here.  !

22 It outlines the recently announced changes in 1

l 23 the NRC organization that were recently announced by l 24 Chairman Jackson and you will be interested to know.

(3 g ,/ 25 I won't go over them; but you can read the s

~

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l 7

1 information in this handout. l

,_ 2 The other thing I want to flag is a recent l l )

\# 3 speech by Chairman Jackson to an OECD CSNI workshop on j l

4 thermal hydraulics and neutronics code requirements. That  !

l l

5 is an interesting speech you may want to read also.

6 MEMBER POWERS: Tom, have you given any 7 thought to this reorganization which appears to me to 8 introduce a new layer of management into the NRC structure 9 which seems curious since the rest of the world seems to 10 be going in the other direction in management structure.

11 CHAIRMAN KRESS: That did occur to me also, 12 but I figured it is not my business to talk about 13 organization charts, so I didn't.

(~h 1 k m 14 MEMBER POWERS: Didn't care to speculate on 15 that? ,

l 16 CHAIRMAN KRESS: Didn't speculate on why or l

17 the reasons for it.

18 But it is interesting.

19 The other announcement I wanted to make to 20 remind members that we do have a Christmas luncheon in the 21 adjacent conference room at 12:15 p.m. So don't go down 22 and buy your lunch.

23 MEMBER SHACK: That is tomorrow.

24 CHAIRMAN KRESS: That is tomorrow,

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I 8

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1 today. )

,_ 2 CHAIRMAN KRESS: For those that I have invited 3 to the Christmas luncheon today, that's tomorrow.

4 We do have a possibility of four letters 5 today, tomorrow, this meeting. Dana, you don't know yet 6 whether you are going to have a letter on aging?

7 MEMBER POWERS: I rather think we won't. But 8 my suspicion is that we need to file away the information 9 presented to us in this discussion, the aging research 10 program, for a general discussion letter discussion the 11 research program, as a whole.

12 CHAIRMAN KRESS: Well, if we intended to have 13 this as part of our report to Congress, we would have to m

ss 14 have a letter first.

15 MEMBER POWERS: That is certainly your 16 opinion.

17 CHAIRMAN FRESS: No , it is not my opinion; it 18 is somebody else's.

19 MEMBER POWERS: Somebody else's opinion.

20 CHAIRMAN KRESS: I am passing it off.

21 I guess the same thing applies to the item C 22 . search programs. You don't know whether there will be a l 23 letter or not.

24 MEMBER. MILLER: I think we will have to play O

'q,) 25 that by ear.

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9 l

1 CHAIRMAN KRESS: Okay.

2 George Apostolakis is not here yet; he will to

/

3 show up later this morning. I am pretty sure he plans on 4 having a letter on the human performance program plan.

5 VICE CHAIRMAN SEALE: I believe that is 6 correct.

7 CHAIRMAN KRESS: You are planning --

8 VICE CHAIRMAN SEALE: Yes, I'11 have at least 9 another chance for us to take a hack at the report to 10 Congress.

11 CHAIRMAN KRESS: Well, that is all the items 12 that I wanted to talk about before we start.

13 MEMBER MILLER: I have a question.

14 CHAIRMAN KRESS: Yes.

15 MEMBER MILLER: On the research. The report 16 to Congress is on research, right?

17 CHAIRMAN KRESS: Yes.

18 MEMBER MILLER: And, in my case, we already 19 have I&C in there. Are you implying that we should have a 20 sepa ate letter on research for I&C?

21 CHAIRMAN KRESS: If you think there is a need 22 to.

23 MEMBER MILLER: It seems to me it is redundant 24 with what we have already put in the letter that Bob put l /~N

!V 1

25 together.

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10 1 Based on what we hear here today we might add

,q 2 to that letter.

a V'

3 VICE CHAIRMAN SEALE: Well, I think we already 4 have enough material in the I&C area over the past year to 5 provide backdrop for any comments we finally wish to 6 include about I&C in the letter that I am writing or I am 7 trying to prepare for consideration by the committee.

8 I think the intent, though, of that letter is 9 a more general one. Namely, to regenerate some interest 10 in general research areas or to try to define the research 11 areas that are in need of some attention in light of the 12 way in which the regulatory process seems to be going.

13 MEMBER MILLER: Okay. So, in other words, a (b) 14 letter that I would write or George or whoever is going to 15 write one would be more directed?

16 VICE CHAIRMAN SEALE: Yes.

17 CHAIRMAN KRESS: Yes, more specific.

18 MEMBER MILLER: Then I also raise the other 19 question. Of course we wrote a fairly lengthy comment on 20 DSI 22, I think it was, and that is on research.

21 VICE CHAIRMAN SEALE: Yes, that's right; very 22 specifically on research.

23 However, that was in response to an identified 24 query from the commissioners on input.  ;

25 MEMBER MILLER: Right.

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11 1 VICE CHAIRMAN SEALE: On the general topic of 7s 2 research.

( )

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3 MEMBER MILLER: But that doesn't go to 4 Congress, though.

5 VICE CHAIRMAN SEALE: No.

6 MEMBER MILLER: Okay. I am just trying to get 7 straightened out.

8 VICE CHAIRMAN SEALE: Yes.

9 MEMBER MILLER: It seems that we are writing a 10 lot of letters on research.

11 VICE CHAIRMAN SEALE: But basically, we are 12 going to wait until after what we hear.

13 CHAIRMAN KRESS: Until you make a decision.

14 MR. DURAISWAMY: Don, I think that the letter 15 that you wrote on the DSI, that is your individual letter.

16 That is not a committee letter.

17 MEMBER MILLER: DSI 22 I thought was a 18 committee letter.

19 MR. DURAISWAMY: The one that Dana wrote. But  !

20 not the last one.

21 MEMBER MILLER: Yes, the last one I wrote was 22 individual. We wrote a committee letter on issue 22.

l 23 CHAIRMAN KRESS: Are there other comments from ,

l 24 members or clarifications on the issues? 1 25 Hearing none.

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12 1 (Whereupon, the proceedings recessed at 8:45 2 am. until 9:41 a.m.).

(

3 CHAIRMAN KRESS: I think we can now resume OUR 1

l l 4 meeting.

1 5 The agenda item we are up to now is the l

6 proposed standard review plan and regulatory guides 7 associated with risk-informed, performance-based 8 regulation.

9 Our subcommittee chairman on this is George l

10 Apostolakis, so I will turn the floor over to George.

11 MEMBER APOSTOLAKIS: Thank you.

12 Normally, what we would do is have the staff 13 give a presentation to the full committee on the issues b] 14 that were discussed with the subcommittee. But this is in 15 a kind of unusual meeting.

16 First of all, at the subcommittee meeting the 17 whole committee was present, so we don't really need to 18 brief anybody who was absent.

19 And second, we understand there have been some 20 developments very recently, so maybe we can take advantage 21 of this time for you to brief us as to what has happened.

22 MR. HOLOHAN: This is Gary Holohan of the 23 staff.

24 Since the last subcommittee meeting, I guess l

25 there are two significant things that the committee should NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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13 i 1 be aware of, one scheduler and one an issue that is still i

,3 2 being worked on.

l t )

\._/

3 In terms of schedule, I think, George, last 4 time you said you had met with the chairman to discuss at 5 what point the ACRS should write a letter.

6 MEMBER APOSTOLAKIS: Yes.

7 MR. HOLOHAN: Whether it should be December or 8 something like February.

9 MEMBER APOSTOLAKIS: February.

10 MR. HOLOHAN: There was a meeting among staff 11 managers about a week after that. And then a meeting and 12 discussion with the chairman relating to the schedule.

13 At that point, a decision was made to delay

'As 14 the issuance and reg guides and SRPs for comment for three I

15 months. We are documenting that in a memo to the i 16 Commission that lays out the steps between now and --

17 I think the public comment period would be l 18 March as opposed to end of December. And that, I think, 19 in part would accommodate the ACRS wanting a little more 20 time to think about it.

21 But there are also some internal issues within 22 the staff that we think need to be sorted out before we go 23 for public comment.

24 MEMBER APOSTOLAKIS: Now, you get three months

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l (,,T/ 25 and we get six weeks after the three months?

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14 l 1 MR. HOLOHAN: No, no. What we are doing is i

t es 2 laying out a schedule where --

' \ ')

3 I don't have the details yet because it is 4 still in concurrence. But what I would say is we would, 5 at the early March ACRS meeting we would ask for a letter, 6 having given the committee what we would consider a final 7 document or close to a final document during February.

8 MEMBER APOSTOLAKIS: During February meaning, 9 when in February.

10 MR. HOLOHAN: We were talking yesterday of 11 perhaps at the end of January or very early February was 12 the idea. I 13 MEMBER APOSTOLAKIS: Okay. So it would be  ;

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\2 14 roughly a month.

15 MR. HOLOHAN: Yes. That would be our wish.

16 MEMBER APOSTOLAKIS: And these documents are 17 expected to be significantly different from what we have 18 seen?

19 MR. HOLOHAN: Well, I think there is one issue 20 that could be significantly different, but I think only 21 one. I will get to that as the issue.

22 The other item with respect to the schedule is 23 we are hoping that even though the draft for public 24 comment would be March instead of December, that we would x_,/ 25 still meet the December, 1997 final issuance date.

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15 1 In other words, the period of public comment i

rs \ 2 and the six or so months of resolution of public comments I V 3 and finalization and coming back to the committee, we hope i 4 that that won't really take a year.

5 If we spend our time up front, really ironing 6 out the issues, we should be able to shorten the comment 1

7 period because we have done most of the work up front, i l

l 8 MEMBER APOSTOLAKIS: And tentative l l

l 9 subcommittee meeting for January is off? '

10 MR. HOLOHAN: I think we should discuss the 11 committee's desires.

12 To have a subcommittee meeting in January, I I 13 think you would again be in the position of reviewing or O

('J 14 discussing interim documents or interim thinking.

15 It seems to me a February subcommittee meeting 16 with an early March full committee meeting would be 17 consistent with looking at a more final document.

18 MEMBER APOSTOLAKIS: Oh, so you envision a 19 subcommittee meeting in February?

20 MR. HOLOHAN: I think we should have a 21 subcommittee meeting, but January might just be too early, 22 I think.

23 MEMBER APOSTOLAKIS: Okay.

24 MR. HOLOHAN: I think the subcommittee 25 meetings have been valuable and there are some substantive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE-, N W.

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16 1 issues.

-. 2 MEMBER APOSTOLAKIS: My only concern is that 3 we aren't presented with something that is so new or 4 revolutionary with a capital 'R' that we have difficulty 5 among ourselves deciding what kind of letter to write.

6 So, as long as things are just being worked 7 out on the details, that is just fine.

8 VICE CHAIRMAN SEALE: Well, the answer to that 9 may depend on what you are yet to say, to identify as the 10 crucial issue.

11 MR. HOLOHAN: Well, let me identify the issue 12 and maybe that will clarify the discussion some.

13 We had a meeting, in the process of taking our o

-- 14 drafts of the reg guides and the SRPs and moving them 15 another step through the management process, within the 16 offices, we had a meeting with the staff and each of the 17 office directors or their representatives from NRR, 18 Research, AEOD and NMSS. I l

i 19 At the meeting there was a concern expressed j 1

20 about the way the documents presented the allowable risk 21 increases. The staff also had a similar concern about 22 such an issue. I think this is one of the first issues we 23 raised with NEI when they put their figure on the table.

24 Triere was at least a perception, if not the j O)

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17 1 from where they are all the way up to the safety goals and 2 that might not be the right thing to do.

i 3 So, the concern is about how should you deal 4 with risk increases.

5 MEMBER APOSTOLAKIS: It's not whether, then, 6 it is how.

7 MR. HOLOHAN: Well, that is part of the issue.

8 This is also slightly complicate because if you remember, 9 back in the summer, we discussed this issue with the 10 subcommittee and we forwarded to the Commission a policy 11 matter as to whether risk increases should not be allowed; 12 a generally risk-neutral policy. Or whether small 13 increases should be allowed.

,y i r

(_) 14 We have developed a guidance document based on 15 small increases.

16 I think what has resulted from that, --

17 In fact, we don't have a Commission vote about 18 whether the commmission is in favor of a risk-neutral or 19 small increases or whether they have another alternative 20 or they might agree with us with some suggestions as to 21 how to do it. So that is still up in the air.

22 I think the message we are getting from NRR 23 senior managers is the way we have presented it, the small l

l 24 increase approach that we have presented is sending the

()

(_y 25 wrong message. It looks like it is opening the door for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

18 1 utilities to increase risk in a sort of uncontrolled 2 manner, 7s j

< \

U 3 At a minimum, we have to structure the thing j 4 in such a way that it doesn't send that message.

I 5 Exactly how to do that, whether we should l l

l 6 revise one of our principles to say, 'should monitor risk 1

7 increases and they should be neutral', or 'there should be 1 8 no cumulative significant changes', or whether this can be  ;

9 done, worked in in some other alternatives.

10 I think the principal reason why we need --

1 11 When we say three months what we are really 12 saying is take one month to sort out the issues and then 13 everything else sort of gets back on the review track.

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x- 14 So, we are caught up in, what is in many ways, 15 the fundamental issue that we have discussed with the 16 subcommittee many times. That is how to do you deal with 17 the potential for changes in risk?

18 MEMBER APOSTOLAKIS: So, I am curious now.

19 Those four policy issues that you raised for us, as you l 20 say, in early summer and then we wrote the letter which 21 was sent to the Commission in August, is the Commission 22 going to decide anything on these?

23 MR. HOLOHAN: My understanding is that the 24 Commission's staff has been developing semething for the

()

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25 Commission to vote on. The Commission has not yet voted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.

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19 l

1 on it but they are working on sending direction to the i

n 2 staff, shortly.

U 3 VICE CHAIRMAN SEALE: Well, then the question l

l 4 of when we should have a subcommittee meeting turns on the i

5 issue of when you expect to have an alternative that 6 addresses issue of modified risk neutrality and when you 7 would like our input into the acceptability or perhaps the 8 fine-tuning of that resolution.

9 MEMBER APOSTOLAKIS: In March, I am going to 10 be in Japan.

11 VICE CHAIRMAN SEALE: Well, that is a little 12 late.

13 MEMBER APOSTOLAKIS: I don't know about the A

~ 14 letter.

15 MEMBER SHACK: That meeting conflicts with the 16 meeting?

17 VICE CHAIRMAN SEALE: Teleconferencing.

18 MEMBER APOSTOLAKIS: Or we can go by past 19 history and say the March deadline is not really a 20 deadline.

21 MR. HOLOHAN: If it helps, the :af f has been j l

22 over here having a side conversation.

23 MEMBER APOSTOLAKIS: We noticed that. l 24 VICE CHAIRMAN SEALE: We were hurt by it. Go 25 ahead.

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20 ;

l 1 MR. HOLOHAN: We want to share with you 2 everything we just discussed.

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\_-)S \

3 What we are trying to do is figure out at what 4 point were really trying to either identify alternatives 5 or solidify a position. It is not March and it is not i l

6 February. So, the committee can start thinking about 7 whether you agree with us or not.  :

8 It seems to me we are currently developing 9 views on the subject and we are going to meet with the 10 office directors again before Christmas. Hopefully, later l

11 in December, we will have both a Commission view and staff i

12 position on this issue. Maybe not written in some final 13 document, but a position for the committee to think about. ,

/\  !

U 14 So, I would think later December or early '

15 January at the latest, I think this issue will settle out.

16 At least from the staff's point of view.

17 MEMBER APOSTOLAKIS: So, it is really out of 18 the question to have a subcommittee meeting the last week 19 of January?

20 MR. HOLOHAN: Uh, well, let me say what is 1

21 possible. I think by the later part of January, our 1

22 thoughts would be refinalized or however you want to put 23 it. I don't think that would meet with your expressed 1

24 desire to be dealing with more finalized documents.

f

(_ - 25 MEMBER APOSTOLAKIS: Okay.

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21 1 So, we could have additional discussions on

{

,_s 2 the merits of the matter, but I don't think you will be in k_'\) 3 the position of reviewing the final documents.

4 So, if you do a January meeting you might end 5 up doing a February meeting anyway or something to that 6 effect.

7 MEMBER APOSTOLAKIS: Do we need a subcommittee 8 meeting after we have the final documents you think? Or 9 while things are being developed. What is the purpose of 10 the subcommittee meeting?

l 11 MEMBER MILLER: I think the purpose is to at l i

12 least reach agreement on some basic principles as we did 13 before.

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\~ # 14 MEMBER APOSTOLAKIS: And --

15 MEMBER MILLER: It sounds like there is a 16 chance that the basic principles may be changed.

17 MEMBER APOSTOLAKIS: And have an opportunity 18 to influence the process.

19 VICE CHAIRMAN SEALE: That's right.

20 MEMBER APOSTOLAKIS: So, maybe we should bee 21 in January.

22 VICE CHAIRMAN SEALE: But that is different l

23 from what we were originally talking about, namely a j l

1 24 situation where the principles, as stated in the present

() 25 version of the documents and what we were talking about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. 1 (202) 234-4433 WASHINGTON. D C 20005-3701 (202) 234-4433  ;

1 22

, l 1 was writing the letter.

-, 2 So, what we are looking at here may be two

/

( '\)

3 things. One, to influence the modified position and then 4 to prepare our letter so that we can get it out in a 5 timely way.

i 6 If you are going to be in Japan in March, then 7 a February meeting looks particularly important if we are i

8 going to meet that deadline.

9 MEMBER MILLER: You are going to be in Japan l

10 for the March meeting?

11 MEMBER APOSTOLltKIS: Well, not the whole 12 meeting; the early part of the meeting.

13 But if this letter is due --

(~N i w- 14 MR. HOLOHAN: The staff would be willing to I

15 meet in Japan with you. i 16 LAUGHTER 17 MEMBER MILLER: You are too anxious.

I 18 CHAIRMAN KRESS: Well, will you be at the 19 March ACRS meeting?

20 MEMBER APOSTOLAKIS: Well, the meeting in 21 Japan is Monday through Thursday, I think.

22 CHAIRMAN KRESS: Of the same week?

23 CHAIRMAN KRESS: Yes.

24 MEMBER MILLER: You gain a day coming back.

O)

( 25 MEMBER APOSTOLAKIS: What?

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l 23 l 1 MEMBER MILLER: A night flight.

j n 2 MEMBER APOSTOLAKIS: Well, the other thing is

! / i N_) 3 I am not sure I have to be there the full four days.

l i

4 CHAIRMAN KRESS: So, my feeling is that if we 5 wanted to write a letter in March, we better have it 6 written before you leave.

7 MEMBER APOSTOLAKIS: Probably.

8 VICE CHAIRMAN SEALE: So, that's the February 9 meeting.

10 CHAIRMAN KRESS: Yes. So, we better use the 11 February meeting to write the letter which means we need  !

I 1

12 the documents.

13 VICE CHAIRMAN SEALE: Yes.

/'N

! )

(s' 14 MEMBER APOSTOLAKIS: Yes.

15 CHAIRMAN KRESS: So, it might be useful to 16 have a January meeting, but it might be more useful to 17 have them to use that time to be sure we get documents l l

18 early February.

19 MEMBER APOSTOLAKIS: No, I don't want to have l 20 two meetings. It was just a question of whether January  !

21 is better than February.

22 CHAIRMAN KRESS: The best time is when we get 23 the documents.

24 MEMBER SHACK: We could have a discussion of

(~

( ,)/ 25 the principle at the February full committee meeting.

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24 1 MEMBER APOSTOLAKIS: That's also possible, 2 MEMBER SHACK: The position would be finalized in\

(~/

3 then, so we could discuss the position then.

4 CHAIRMAJ KRESS: We could have a pretty good 5 start on a letter by then.

6 MEMBER APOSTOLAKIS: That's a good idea.

7 MEMBER SHACK: And then in February we will 8 have the final documents.

9 MEMBER APOSTOLAKIS: So, we should have a 10 briefing at the February meeting, anyway.

11 VICE CHAIRMAN SEALE: Well, particularly on 12 the revised --

13 CHAIRMAN KRESS: Whatever the revisions and p

i D) 14 their --

15 VICE CHAIRMAN SEALE: Policies.

16 CHAIRMAN KRESS: Approaches.

17 MEMBER APOSTOLAKIS: And when the documents 18 would come out and so on.

19 MEMBER MILLER: Are we then canceling the 20 January meeting?

4 21 MEMBER APOSTOLAKIS: Yes.

22 EXECUTIVE DIRECTOR LARKINS: If you have a 23 February subcommittee meeting and most of the members are 24 there, you can probably outline the main parts of your h

(Q 25 letter and then finalize it at the full committee meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234 4433

25 1 in March.

g~g 2 MEMBER MILLER: Are we then having a February 3

(

3 subcommittee meeting before the February meeting?

4 MEMBER APOSTOLAKIS: We will have a February 5 subcommittee meeting which will involve the full 6 committee.

7 MEMBER SHACK: Late February.

8 MEMBER APOSTOLAKIS: Late February and it will 9 be the full committee like it did last time.

10 MEMBER FONTANA: You are going to have a 11 position on the issue by when?

12 MR. HOLOHAN: Hopefully, later in December,

_ 13 definitely by early January.

t

' ') 14 MEMBER MILLER: Can I -- I'm trying to grasp 15 the global as well as the micro issue here.

16 Is the micro issue which may be a global issue i l

17 that we want risk neutrality on a plant-by-plant basis?

18 Is that the issue?

19 MR. HOLORAN: Yes. Or something. Risk 20 neutrality implies a precision of no change. But, in a 21 little bit fuzzier sense, that no significant deviation 22 from what we perceive the risk of the plants to be.

23 MEMBER MILLER: So, if we had a plant with l

j 24 some core damage of say, 10 4 and the plant says we want to

/ h

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26 1 more, that would not be permitted. l

- 2 MR. HOLOHAN: Well, we haven't defined what is

/s\

3 significant. But under the assumption that 20 per cent is 4 significant, the answer is that would not be permitted.

5 MEMBER MILLER: Well, let's say 10 per cent. I 6 NR. HOLOHAN: Let's just say a factor of two, 7 to make it easy on me.

8 MEMBER MILLER: From my point ( - view --

9 MR. HOLOHAN: It would say that a plant that 10 had 10-' should never, in it's lifetime, be allowed to 11 increase to 2 x 10-' . I think that is basically what it 12 says.

13 MEMBER MILLER: My point of view, if we are I

k/ 14 going to go plant-by-plant risk neutrality, why go into 15 this whole business?

16 MEMBER APOSTOLAKIS: Yes, exactly. That is my 17 problem, too.

18 MEMBER MILLER: I heard you say that and it 19 struck me between the eyes; why even bother?

20 MEMBER APOSTOLAKIS: Why?

21 MEMBER MILLER: Maybe we should tell the 22 Commission that.

23 MEMBER APOSTOLAKIS: And not only that, if it 24 appears --

f3

(,) 25 MEMBER MILLER: Now, globally, the 109 plants NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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27 1

1 were going to reduce the risk by risk-informed regulation  :

2 that is fine. That is what we want to do. But if a plant

\

3 is doing very well, and can't increase their risk by 4 making some changes which increases their effectiveness in l

1 5 using resources, I don't want to even bother with it.

6 MEMBER APOSTOLAKIS: The problem with a global I i

1 7 neutrality is of course we are not looking at the plants i

8 that violate the goal right now.

9 VICE CHAIRMAN SEALE: Yes.

10 MEM APOSTOLAKIS: Because, we are not 1

11 moving to truly risk-informed regulatory practices. We l l

12 are just evaluating changes. '

13 MR. HOLOHAN: However --

/'

C 14 MEMBER APOSTOLAKIS: I am not going request a 15 change. ,

l l

l 16 MR. HOLOHAN: But in order to be consistent, I 17 each time you say that I feel obliged to say we do have 18 another program following up on the IPE insights, among l

19 other things, looking at the plants that appear to be i

20 above the safety goal and have specific concerns and we l

21 are putting a program in place to do that. It doesn't i

l i 22 happen to be this program; but we are not ignoring that 23 issue. ,

i 24 MEMBER APOSTOLAKIS: So, one of the questions I

/h

, (j 25 is how does one define risk-neutrality?

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28 1 MR. CUNNINGHAM: Or small increases.

- 2 MEMBER APOSTOLAKIS: Yes. But I think risk-3 neutrality is a bigger issue. Because if you define it in 4 terms of the whole population of plants, then --

5 VICE CHAIRMAN SEALE: Does this imply a 6 response to the expected consequence of the present pilot 7 studies?

8 MR. HOLOHAN: Well, I think, depending on how 9 decide on this issue, it affects the pilots.

10 VICE CHAIRMAN SEALE: That is what I mean.

11 So, they may be wasting their time, also.

12 MR. HOLORAN: Well, I wouldn't want to send 13 them that signal at the moment.

/

_ 14 VICE CHAIRMAN SEALE: I wouldn't either.

15 MR. HOLOHAN: I don't want to argue with some 16 of the things I have heard today, because I agree with 17 most of them. But I think it is fair to say that there is 18 a legitimate concern which is if this in actuality or in 19 perception turns into all the plants that are 10 4 deciding 20 tomorrow that they would really like to be a 10", that is 21 neither what we want to do, nor the perception that we 22 want people to have.

23 MEMBER APOSTOLAKIS: We agree.

24 MR. HOLOHAN: So, I think the concern is real;

,es

(,) 25 the question is how to deal with it.

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29 l

1 MEMBER APOSTOLAKIS: Now, there is another 73 2 element here. It has to do with the definition of risk-f i

'J 3 neutrality.

4 Which risk are we referring to? Are we 5 referring to the risk that was there pre-WASH 1400, right 6 after WASH 1400 or yesterday?

7 Because it seems to me that the plants have 8 made already changes based on results of risk assessment.

9 MR. HOLOHAN: Yes.

10 MEMBER APOSTOLAKIS: To reduce the risk.

11 MR. HOLOHAN: Yes.

12 MEMBER APOSTOLAKIS: So, now you tell them 13 that now that you have reduced it, neutral now. You are

/,_ %

5- 14 not all'wedo anything else.

15 So, it seems to me that there is an element of 16 unfairness there, as well.

17 MR. HOLOHAN: That is possible.

18 MEMBER APOSTOLAKIS: So, it depends -- Has the 19 use of PRA been oeneficial or not, from the safety point 20 of view?

21 MR. HOLOHAN: Yes.

22 MR. CUNNINGHAM: Yes.

23 MEMBER APOSTOLAKIS: So, now we decided we 24 want to be neutral. We have to appeal to logic at some

( j'

'(~~N 25 point.

I NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1

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30 1 MR. HOLOHAN: Yes.

n., 2 MEMBER APOSTOLAKIS: Not you, but as a

[V t 3 community.

4 MR. HOLOHAN: Yes.

5 MR. HODGES: He doesn't have to appeal to 6 logic.

7 MR. HOLOHAN: Or at least we have three months 8 to do it.

9 MEMBER MILLER: Is the issue not of risk-10 neutrality but the message we are sending of moving the 11 possibility of moving that 10-6 plant they can move back to 12 10'4 Are those two issue coupled?

13 MR. HOLOHAN: Well, it is a little difficult

/

1 i

1 N' 14 to be talking about an alternative that is not precisely 15 defined. That is what are we talking about in terms of 16 risk?

17 If you are talking about accumulation, when 18 did you start, where is it fair to start?

19 Are you talking about your current estimation 20 of what the risk was on that day or what you thought it 21 was that day?

22 There are all sorta of --

l 23 MEMBER APOSTOLAKIS: Or 20 years ago.

24 MR. HOLOHAN: All sorts of issues.

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1

f 31 1

1 that is important.

2 Let's say you have one really dominant

,)

l 3 accident sequence; seismic. So, for that particular plan l

l 4 the core damage frequency is 3 x 10-5 and most of it comes l 5 from seismic events.

l 6 MEMBER MILLER: Which aren't included in some 7 --

1 8 MEMBER APOSTOLAKIS: Now, I can go and change 9 everything else if I want to because it would be risk-10 neutral. Right?

11 I can change my quality assurance, I can 12 change ISI and everything because everything is below the 13 seismic; seismic dominates.

\- 14 MR. HOLOHAN: Remembering, of course, that we 15 have other principles.

16 MEMBER APOSTOLAKIS: You will have other 17 principles but that also is kind of illogical. That 18 because this thing dominates I can do whatever I want here 19 because I am risk-neutral.

20 CHAIRMAN KRESS: The Commission has a policy 25 of allowing risk increases. They allow increases in 22 power, exemptions to various rules.

! 23 MR. HOLOHAN: Yes.

l i

( 24 CHAIRMAN KRESS: We are not talking about a 25 different policy. It seems to me we are talking about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i 32 l

l 1 appearance of some sort of allowing willy nilly changes l

l 2 without a control or without appropriate review and 7s

(

' ') 3 approval.

4 It seems to me like we ought to deal with what 5 our review, approval and control process is on this and in l

l 6 terms of re-evaluating what we are saying, as opposed to 7 whether or now we are allowing risk increases.

8 MEMBER FONTANA: I think what they are saying, 9 Tom, is that some of the managers is concerned with the 10 public perception.

11 MR. HOLOHAN: That's why we would deal with 12 the control, review and approval process.

13 MEMBER APOSTOLAKIS: Is it also a little bit -

\~/ 14 - One of the reasons for this concern is now we really 15 know what we are doing.

16 You make a change now and you see a number 17 change.

18 MR. HOLOHAN: Yes.

19 MEMBER APOSTOLAKIS: It's not in our 20 judgement. We are protecting public health and safety.

21 CHAIRMAN KRESS: That was the advantage of 22 having this adequate level of protection. You never knew 23 what that meant.

I 24 MEMBER APOSTOLAKIS: That's right. So I think c

pm

) 25 --

t NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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33l 1 MEMBER MILLER: Or, we have a number and we

_ 2 believe we know what we are doing.

3 VICE CHAIRMAN SEALE: Ignorance is bliss.

4 MS. RAMEY-SMITH: Ann Ramey-Smith.

5 I want tc make a comment on that, Dr. Kress.

6 I don't know, in general, that I would agree 7 that the Agency allows risk to increase.

8 If you calculated it, it may increase by some 9 amount, but my interpretation, and others can share their 10 views, is that the changes that we make, the enforcement 11 discretion and so forth, are made with the assumption 12 that that change results in no significant increase in 13 risk given the defense and depth and compensatory actions

<x l I

\/ 14 and so on.

15 CHAIRMAN KRESS: Yes, but I maintain that what 16 we do is when you say run a five per cent power increase, 17 what you do is you require a re-analysis of the design 18 basis to be sure you stay within the design envelops.

19 That has a very, very loose connection to 20 risk. But I maintain that it is almost transparent 21 because if you increase the power by tive per cent you 22 have increased the risk whether or not you stay within the 23 design basis envelope. We just haven't done an 24 appropriate connection between those two and haven't done n

( ,) 25 the appropriate risk analysis.

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34 1 So, it is not --

73 2 MEMBER MILLER: Or now we believe that we can (w)' 3 measure it where ten years ago --

4 CHAIRMAN KRESS: We just don't acknowledge 5 that it is a risk increase.

6 MR. HODGES: This is Wayne Hodges. There is 7 at least a perception that over the last 15 or 20 years, 8 plants are safer now than they were previously. We have 9 improved risk.

10 That perception says that what we have done 11 over the past 20 years has been a cumulative effect of 12 decreased risk.

13 CHAIRMAN KRESS: I think that is true.

m

~- 14 MR. HODGES: The perception is we want to )

1 15 continue with that trend, not reverse. And the perception 16 was that the way our reg guides and SRP were phrased it 17 would tend to invite the reversal of that trend.

18 MR. HOLOHAN: Okay, let me make a few comments i

I 19 since Ann invited other staff members to air their views.

20 There are places in the regulations, for  !

21 example one of the bases for an exemption would be an 22 equivalent level of safety. But that is only one of the 23 tests. There are other bases which could well be 24 interpreted to allow an increase in risk.

(~m ,) When you ask why is it that licensees request

\ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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l j 35 1 more than a 1,000 license amendments a year, it is l

fx 2 generally because they are not allowed to do those things s

V 3 now'and they couldn't make those changes and pass a 50.59 4 test.

5 Having failed a 50.59 you either increase the i

6 probability or consequences or something, which to me 7 implies a risk increase.

8 So, in general, our approval of exemptions or 9 license amendment requests or power upgrades is not based i 10 on the size of the change, but the conclusion that after  ;

11 the change you still have adequate protection, no undue 1

12 risk to public health and safety.

l 13 So, it is not so much on the delta than on the j

<p,') ,

'-- 14 end point. j i

15 CHAIRMAN KRESS: Which is why we are still  ;

16 talking.

17 MEMBER APOSTOLAKIS: As you know, I always to 18 take these principles from the traditional way of doing 19 business'and translate them into probabilistic terms.

20 So, an equivalent statement here is you meet 21 the QHOs, isn't it?

22 MR. HOLOHAN: That is the equivalent 23 statement, yes.

24 MEMBER APOSTOLAKIS: If you are below the

, D \

s ) 25 quantitative health objectives, and the subsidiary i

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36 1 objectives, then the public is adequately protected.

2 MR. HOLOHAN: Yes. That's the same thing.

3 MEMBER APOSTOLAKIS: But now there is a number 4 staring at us.

5 VICE CHAIRMAN SEALE: The problem though is, 6 that I think we all in a leap of faith or a leap of 7 confidence in each other or whatever, assume that 8 continuing the meet the QHOs was implicit in the 10" 9 number or whatever, and we got wrapped up in adjusting the 10 size of the changes that would be associated with a 4

11 particular action by the licensee.

12 And that kind of attention to detail is 13 perhaps what gives the impression then that we are talking

.O 1 k/ 14 about everyone willy nilly running up to the safety goal 15 limit.

16 MR. HOLOHAN: I am hoping that these are not 17 two different thoughts that are in conflict.

18 VICE CHAIRMAN SEALE: Yes.

19 MR. HOLOHAN: It is perhaps possible to have a 20 principle that allows either risk reductions or small 21 increases and also have some principle or expectation that 22 we expect licensees to be responsible risk managers and 23 not to be presenting us with an unending chain of risk 24 increases.

C)i

(_ 25 CHAIRMAN KRESS: Those are not mutually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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37 1 exclusive.

2 MR. HOLOHAN: But I think those are not

(_)

\.

3 mutually exclusive. So, it is going to take some time to 4 sort out what is the right way to do this.

5 Personally, I don't know that we should remove 6 the other principle and put a risk-neutral or no 7 significant change principle in its place. Some people 8 have suggested that.

9 MEMBER APOSTOLAKIS: Which principle are you 10 referring to?

11 MR. HOLOHAN: Principle number five, which 12 basically says small changes. You could remove that one 13 and put a different principle in its place. Or you could

/~'N

(_) 14 leave that principle and add another principle which 15 addresses directly that we expect good risk management.

16 An individual license amendment is not the 17 only change in risk that is going on. How the plant is 18 being operated and whether it has reactor scrans all the 19 time and reliability of equipment and implementation of 20 the Maintenance Rule and all these things may be very 21 relevant to whether we think the plant is being managed

(

22 well.

23 MEMBER APOSTOLAKIS: I wouldn't make it that 24 principle, but somehow I would make the message very A

( ,) 25 clear, somewhere.

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38 l

1 Because what you are saying again is somebody  ;

- 2 is asking for a change now and it is declared small. Then 3 ten years from now, they have good performance, we know 4 more and so on, and they ask for more. At that time you 5 might grant it, right?

l 6 So, you don't want to commit yourself now to  ;

7 saying this is what I am going to do in the future.

8 As we know more we will do more. But don't I

9 make it a principle. j 10 MS. RAMEY-SMITH: Perhaps that is a staff l

11 expectation.

l 12 MEMBER APOSTOLAKIS: Sure. 1 l

13 MS. RAMEY-SMITH: Remember how we had the 1

,f~%s i

\_-) 14 principles and the expectations? ,

I 15 MEMBER APOSTOLAKIS: Yes.. You can bury it in 16 the text, maybe in a figure.

l 17 MR. HOLOHAN: Maybe bury it in two figures.

18 MEMBER APOSTOLAKIS: In the text it would be 19 better.

i 20 So, things are not as bad as I thought. I I

21 So, what else do we want to learn from the 22 staff?

23 MR. HOLOHAN: Well, I think one of the things 24 that Mark and Wayne were mentioning to me was one of the

[ 25

(_

things that we are considering is to develop alternatives.

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39 l

1 Maybe even put alternatives out for public comment.

g3 2 But don't be surprised if we don't converge on N- l 3 one alternative.

l 4 CHAIRMAN KRESS: But you would put in there i l

5 along with that that we recommend alternative --

6 MR. HOLOHAN: Well, I don't know.

7 MEMBER APOSTOLAKIS: You don't know?

8 MR. HOLOHAN: No. I doubt that because if 9 there is, in fact, a consensus on one of the 10 recomraendations I think that is what we would present.

11 If we present alternatives, it is probably i 12 because there is not a consensus on one of them.

13 MEMBER APOSTOLAKIS: Now, the Commission is f%

14 aware of all these issues?

15 MR. HOLOHAN: Well, the chairman is aware.

16 Because all of the commissioners weren't involved we 1

17 decided to write it in a memo to the Commission so that l

18 the schedule and the issue become known and we expect that l l

19 to go to the Commission soon, this week, next week?

20 MS. RAMEY-SMITH: I think the schedule for 21 that two or three pager -- That's not the paper we are 22 talking about?

23 MR. HOLOHAN: No, there are two papers. One 24 is basically identifying to the Commission the three month f~%,

(_) 25 schedule change with some details of the steps in between NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i -

\

j 40 l 1 1 and what issue is being resolved in that period of time.

l l

l

p 2 That one should be out very shortly. l i

3 I think we are going to w: rite a paper just on l l 4 this issue, to come to closure on thia issue rather than 5 to keep re-writing the draft documents. That will l

6 probably take a couple of weeks.  ;

l 7 MS. RAMEY-SMITH: That is the one that we 8 expect to go forward consistent with the PRA l 1

9 implementation plan --  ;

10 MR. CUNNINGHAM: Schedule. l 11 MS. RAMEY-SMITH: But not together with it. ,

i i

12 MR. HOLOHAN: Just before Christmas.  !

I 13 MR. MARKLEY. Gary, these are the things that ld

\

14 we would expect to be discussed at the February full 15 committee meeting then?

16 MR. HOLOHAN: Well, sure. j l

17 MR. MARKLEY: And any Commission decisions l

18 that it might have yielded at that point?  !

19 MR. HOLOHAN: Yes.

20 MEMBER APOSTOLAKIS: Well, I get the 21 impression that a lot of these concerns are driven by 22 perceptions, both within the staff and what the 23 perceptions of the public will be. Of course, you cannot l

l

24 really dismiss the issue of perception, but on the other

(~\

l V 25 hand, you have to ask yourself do you really have to run a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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~~

l 41 1 technical enterprise based on perceptions rather than

! s 2 technical arguments? Where do you draw the line?

3 I think a lot of people are scared by l j 4 performance-based regulation and flexibility and all that 5 stuff and that should not be surprising because that is 6 not how we have been doing business.

i l

7 On the other hand, we should recognize that 8 that is maybe part of the problem and maybe granting some 9 flexibility is not such a great, I don't want to use the 10 word crime.

11 We state our goals and a certain number of I 12 principles, but it seem to me that people who then comply 13 should be left alone. Trying to deal with derivatives is

(

N-- 14 not easy; cumulative numbers are easier to deal with.

15 Shall we talk about dates? l 16 MR. HOLOHAN: I guess that's okay.

17 MEMBER APOSTOLAKIS: How about February 20 and  !

l 18 21, Thursday and Friday. I assume we need two days. I 19 MR. HOLOHAN: I presume at that point you will 20 be preparing to write letters on all of the documents.

21 MEMBER APOSTOLAKIS: Yes, what we have done is 22 made some assignments.

23 MR. HOLOHAN: Good.

24 MEMBER APOSTOLAKIS: so there will be some t

l

(~h s ) 25 detailed reviews by some members who will report to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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42 1 full committee.

-s 2 Should we go ahead and read the documents we f

3 have? No.

4 MR. HOLOHAN: Yes.

5 MEMBER APOSTOLAKIS: Yes? Okay. That is good l

6 to know.

l 7 MR. HOLOHAN: I think so.

8 MR. HODGES: We are making some editorial 9 changes to try to make it clearer and if we go through the 10 options they will be in there.

11 MEMBER APOSTOLAKIS: Okay. Great.

I I

12 MR. HOLORAN: As a matter of fact, in those 13 application-specific documents, it may be that nothing but G

\ 14 --

15 VICE CHAIRMAN SEALE: The date.

16 MR. HOLOHAN: Theoretically nothing should ,

l 17 change except that those documents do tend to restate the 18 principles.

19 MR. CUNNINGHAM: There will be changes being 20 made to those documents because of CRGR comments and 21 things like that. But by and large the principles are 22 incorporated almost by reference.

23 MEMBER APOSTOLAKIS: So, people will not be 24 wasting their time reviewing it.

'(7_,)

25 MR. HOLOHAN: Right.

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43 1 MEMBER APOSTOLAKIS: So, I don't know whether g 2 the members are available. Are you available February 20 3 and 21? Anybody objects?

4 MEMBER MILLER: I may not be able to be here 5 February 20. I may be able to change a meeting.

6 MEMBER APOSTOLAKIS: Okay, because the 7 following weekend is too late and the previous week is too 8 soon. And we cannot meet Monday, Tuesday or Wednesday.

9 So, this is the SRP review.

10 MEMBER MILLER: So, we've now scheduled 11 Thursday and Friday, February 20 and 21?

12 MEMBER APOSTOLAKIS: That is right and we are 13 canceling the January meetings on January 8, 9 and 3 0 . No

,in t i b' 14 actually, the meeting on January 30 was supposed to be 15 Steam Generator Rule. We can discuss that some other 16 time.

17 VICE CHAIRMAN SEALE: Yes, don't worry about 18 that.

19 MEMBER APOSTOLAKIS: If there is nothing else, 20 I will turn it over --

21 MR. FONTANA: No, that's all right; different 22 subject.

23 MEMBER APOSTOLAKIS: Back to you, Mr.

24 Chairman.

(%

Q 25 MEMBER MILLER: One question of you George, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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44 1 last time, each of us were assigned one of these documents 2 to review. Should we feed you comments as we go on this?

/ -}/

\'~'

3 MEMBER APOSTOLAKIS: I would like that because 1 4 it helps me a lot.

5 MR. HOLOHAN: Would the committee care those 6 comments with the staff as they are being developed?

7 MEMBER APOSTOLAKIS: At the February meeting 8 we might tell you a few things.

9 MR. HOLOHAN: That wasn't my question.

10 MEMBER APOSTOLAKIS: AS they are being 11 developed?

l 12 MR. HOLOHAN: Yes.

13 MEMBER APOSTOLAKIS: How do we do it.

4

[~h

-# 14 MR. HODGES: E-mail them to us and we will try 15 to factor them into the document.

16 MEMBER MILLER: That was my next question.

17 MEMBER APOSTOLAKIS: We can do that?

18 MEMBER MILLER: Would it be valuable of 19 feeding them to the staff because I have concerns about 20 quality assurance.

21 CHAIRMAN KRESS: They may be the nature of 22 individual member comments. l 23 MR. HOLOHAN: But I think it is good to 24 understand people's concerns and viewpoints as soon as O s_/ 25 possible; why not?

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i 1 45 i

! l 1 MEMBER APOSTOLAKIS: I don't have any problem.

g- 2 MEMBER MILLER: Who should be the receiver of O] 3 these comments?

MEMBER APOSTOLAKIS:

4 You send them to me and 5 I'll send them to Mike.

6 MR. MARKLEY: In any case, we have done this l

7 type of thing in the past to help staff prepare for the 8 meetings and reviews.

9 MEMBER APOSTOLAKIS: And I don't think it )

10 should be automatic. It should be up to the people who 11 write and me to decided whether it is worthwhile 12 forwarding them or not.

, 13 CHAIRMAN KRESS: Okay, well, at this point I i )

\' 14 guess we are through with this part of the agenda and we 15 are scheduled for a break at 10:30. I propose that we 16 take that break now.

17 MEMBER APOSTOLAKIS: Sure. I 18 EXECUTIVE DIRECTOR LARKINS: Right. i 19 CHAIRMAN KRESS: And we are not scheduled for ,

i 20 the next part of the agenda, to start on the I&C until 21 11:30, so we have some time in there, John, where we could 22 either go back and talk about the Commission meeting.

23 EXECUTIVE DIRECTOR LARKINS: Go back and pick i

24 up the discussion.

t O)

(s ,/ 25 CHAIRMAN KRESS: We can take that up again.

l l

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46 l l 1 So, let's take a 15 minute break; be back at f- 2 20 'til.

l (3) 3 (Whereupon, the proceedings recessed from 4 10:25 a.m. and resumed at 11:22 a.m.)

i 5 CHAIRMAN KRESS: Why don't we go ahead and get 6 started? So Don, I'll turn the microphone and the floor 7 over to you to introduce this subject matter.

8 MEMBER MILLER: Okay. The topic is the 9 research program undertaken by the research staff to meet 10 the needs and objectives of I&C -- or J' lubly most 11 specifically, digital I&C -- in the regulatory framework.

12 And I would presume that we as a committee will be most 13 interested in those research topics that may relate to 7

(s' )

14 some of the concerns we've raised in our letters, as well 15 as the overall research program.

16 MEMBER APOSTOLAKIS: May I ask you a question?

17 When is this committee report coming out?

18 MEMBER MILLER: Well, that's a --

19 MEMBER APOSTOLAKIS: Any clue? l l

20 MEMBER MILLER: I can answer that question --

l 21 of course that's not, I guess the research is not really 1 22 necessarily in control of that by any means.

23 MEMBER APOSTOLAKIS: No, I didn't ask for 24 control.

I q f 25 MR. COFFMAN: Best guess is December 16th at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l l

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47 l

l 1 this point, but that has been a moving target.

2 MEMBER MILLER: A rapidly moving target, yes.

',7_ )

\'

3 But that's a reasonable question because I'm certain that 4 what comes out of a National Academy study may have some 5 effect on our thinking.

6 MEMBER APOSTOLAKIS: Yes. Also I saw l

7 somewhere that there was a subcommittee meeting on this 8 subject? From the research on I&C? Is that true?

9 CHAIRMAN KRESS: I don't think so. l 10 MEMBER APOSTOLAKIS: You don't think so.  !

l 11 CHAIRMAN KRESS: I don't recall having one in I

12 quite a while.

13 MEMBER MILLER: Now, my understanding is, a b')

(_/ 14 member of the research advisory committee who is on that 15 sub -- may be here, is that -- Paul, is Christine here?

16 MR. BOEHNERT: I don't know. Is Christine 17 Mitchell here in the room?

18 MEMBER MILLER: Because there's two members of 19 that subcommittee who might have been here. Charlie May 20 from NC State informed me by e-mail he would not be here.

21 Paul thought Christine, who's from --

22 MR. BOEHNERT: It's early yet.

23 CHAIRMAN KRESS: It's early, and in fact, I 24 think we probably ought to delay the start of this O

( j 25 particular meeting until 11:30. Now, no reflection -- so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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48 i

1 why don't we just take a 10-minute break?

l

,._ 2 (Whereupon, the foregoing matter went off the l I

)

l 3 record at 11:23 a.m. and went back on the 4 record at 11:34 a.m.)

5 CHAIRMAN KRESS: Let's start again, and I was 6 going to say, this is the discussion of the I&C research 7 programs, and Don Miller has the gavel and the floor.

8 MEMBER MILLER: Well, let's see, should I 9 repeat what we started with then?

10 CHAIRMAN KRESS: Yes.

11 MEMBER MILLER: This is to review the I&C 12 Research program which Frank Coffman is going to take the 13 lead on here. And of course we would hope that we as a g

k s/ 14 committee, would ask questions and the questions we've 15 asked in the letters addressed specifically by the 16 Research program, and those are the areas that we're 17 probably the most interested in. Digital I&C would be the

- 18 areas we'd be most interested in looking at here today.

19 And Frank has some slides and I assume that 20 will take a few moments, and then we'll have questions and 21 you have staff members here with you that can help us out?

22 MR. COFFMAN: Yes sir. The staff working on 23 the Research program is about six I&C engineers and l 24 analysts. And just to characterize who may be supporting

! /N l

l

( ,) 25 in the answers to specific questions, they have about 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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49 l

l 1 years of experience on the average, each; I mean, that's a l e~s 2 total of 150 staff years.

l )

\_J 3 And the average is that they've experienced 4 seven years at the NRC, and about half of that time has l

l l 5 been in a regulatory role, regulatory function. So they

, 6 come with that perspective.

1 i

7 This.overall program runs about three million 8 dollars a year -- has been running about three million l

l 9 dollars a year.

10 MEMBER MILLER: You're specifically -- in j 11 addition to reviewing those overviews -- target some of I2 the questions that have been raised in our letters, right?

1 13 Some of the issues we've raised in our letters?

7'T

-- 14 MR. COFFMAN: Which letter are we referring 15 to? I mean, we -- the program addresses substantive 16 issues; that was the intent, to provide an overview on --

17 MEMBER MILLER: Right.

18 MR. COFFMAN: That was my understanding.

19 MEMBER MILLER: But the issues we've -- like 20 in the October letter we raised a few issues we thought 21 we'd need further clarification on. I can read those.

22 MR. COFFMAN: If you don't mind, just to 23 refresh my memory. I think I'm covered, but it might be i

1 1 24 safer to --

((~h,)

I 25 MEMBER MILLER: Ones on blalance - well, of l

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50 1 course, we finished our review of the Standard Review Plan 7S 2 Chapter 7, but in that we raised a concern about the

( )

3 balance between process and product as far as the approach 4 to software quality assurance.

5 We raised, not the issue, but the question 6 about the linkage between the various aspect of Standard 7 Review Plan Chapter 7 and other chapters, and also level 8 of detail, and then the graded approaches based on 9 importance to safety. Those are things we put in that 10 letter; in the last letter we wrote to Mr. Taylor. Now, 11 the question will be, is research looking at those kinds 12 of issues, have they looked at those kinds of issues, and 13 of course, researchers responsible for the Regulatory p_

i )

\ 14 Guide development.

15 MR. COFFMAN: The only item I was going to 16 cover specifically that addresses one of those issues is a 17 product versus process, by way of a research project that 18 we're considering, but I think the others are regulatory 19 issues. So I had not planned to explicitly address those. .

l 20 CHAIRMAN KRESS: Well, we were also looking I

21 for a broad overview of the I&C --

22 MEMBER MILLER: Yes, we want that broad l

23 overview --

l 24 MR. COFFMAN: That was my understanding. And

,O

(_j) 25 the format I was expecting to use is to just go through l

l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.  !

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51 1 the items -- and I'll show you how I've got it organized -

s 2 - and then, as we touch on a topic, if there's an item of

( ) '

3 interest for the committee that they could address it.

4 MEMBER MILLER: One that did come up -- of 5 course, it was an outcome of the Research program -- was )

1 6 environmental stressors, in which you have an ongoing .

l 7 program looking at the committee's concern over smoke. In 1

8 addition to that you had the Research program in which it )

l l

9 turned out that lightening was also a stressor we needed 10 to be concerned about.

11 MR. COFFMAN: Yes sir, and I --

12 MEMBER MILLER: And I know that's on your 13 agenda.

A 14 MR. COFFMAN: Yes, those I'll cover. But by I 1

15 way of an overview to start off with, I was just going to j l

16 state the goals that -- it's primarily focused on 17 regulatory guidance, and the technical basis for that 18 regulatory guidance -- the branch program covers the areas

19 of I&C, including software quality, hardware 20 qualifications and human system interface -- system 21 interactions at the interface.

22 And the branch program also includes some 23 human factors aspects, but that's not the focus of this 24 meeting so I was not going to cover that.

25 We also assess and develop methods that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.

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l i

52 1 primarily geared toward facilitating the regulatory review 2 tools for the regulatory reviewers. And we stimulate and l 7_)

'(

3 collaborate in internatic research, primarily through 4 maintaining key contacts internationally; not only in the 5 nuclear industry but with other industries.

6 MEMBER POWERS: The agency is moving toward a 7 risk-informed performance-based regulatory system. When 8 you say you're involved in, assess and develop methods for 9 safety evaluation, does that include methods for assessing lv the risk significance of digital I&C systems?

11 MR. COFFMAN: Yes, primarily to determine 12 measures for establishing the quality of the product, 13 reliability of the I&C systems. But as far as putting n

f I

\s / 14 failure rates -- and if that develops into putting failure 15 rates into PRAs and risk assessments, then it will guide 16 how close of an interface we have with the PRA branch.

17 But we don't have anything specifically geared toward 18 building up the way I&C is modeled in PRA.

I 19 MR. HODGES: This is Wayne Hodges with Office l l

20 of Research. I think more explicitly, what we're doing is l l

21 looking at ways of trying to characterize the reliability 22 of the components, and the risk significance would depend 23 upon a particular application.

24 MEMBER MILLER: Reliability of analog -- or l /~N

( ,) 25 components. How about reliability of software?

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53 1 MR. HODGES: We'll talk about reliability of

,_ 2 software, yes.

U 3 MEMBER POWERS: And who, Wayne, in your 4 organization then, worries about how it's modeled in the 5 PRA?

6 MR. HODGES: Mark Cunningham's branch would 7 handle the actual modeling in the PRA itself, and input to 8 that would be the reliability of the software.

9 MR. COFFMAN: And we interact more closely 10 with them as that gets to be the application for the 11 method, and I'll be looking to see, as we go through this, 12 how that might relate. And this is just how it's 13 organized; how the presentation is organized.

(%

-- 14 Going to characterize the program by some 15 recent products and then talk about the ongoing projects.

16 We have some projects that are actively being planned, and 1

17 then have some considerations. And the reason I inserted l 18 this was to give you a feel for what we have our eyes on, 19 on the horizon, and what we have under consideration. So I

20 I'll touch on them in that order.

21 To go down to recent products, we've come to i

22 you and discussed some of the six regulatory guides on the l 23 software quality and the public comment period was 24 scheduled -- was completed October 31st. We received five (O) 25 sets of comments. It was a mix of responses in the l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 comments, although they all generally supported the idea 7s 2 of establishing standards.

('~') 3 Some of the specific comments dealt with the 1

4 need for a safety system model for relating process and l 1

5 product; and I'll come back to that.

6 There were some comments that some of the standards 1

7 contained too many shalls, so they might be too specific. j 8 There were some good comments on some potential l

9 inconsistencies dealing with commercial off-the-shelf 10 software between some of the reg guides and --

l 11 MEMBER MILLER: Now, that question, we don't 12 yet have a guidance on commercial off-the-shelf software.

13 How did those comments factor into the reg guides we now l

'/ 14 have?

15 MR. COFFMAN: We don't have that --

16 MEMBER MILLER: We do not have any guidance on 17 commercial off-the-shelf software; we're still waiting for 18 that SER, right? For commercial off-the-shelf software?

19 MR. COFFMAN: Yes, but the comments were, I 20 think, anticipating the possible use of commercial off-21 the-shelf --

22 MEMBER MILLER: Okay.

23 MR. COFFMAN: There was some concerns about 24 the degree of independence of the V&V. But where we are

(

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55 l l

1 and making -- dispositioning those comments, and then we n 2 will be coming back to the ACRS.

3 The schedule was to come back to the ACRS with 4 the Standard Review Plan since they're closely tied in 5 together. Possibly, we might be able to come back ahead ,

6 of that if it appears that it's a good use of resources to 7 do that. ,

8 These software standards endorse -- the  !

l 9 software reg guides endorse the consensus standards from l l

l 10 the industry. And the conse sus standards are based upon l 11 experience rather than experimental analysis of first  :

l J

12 principles. 1 13 And they are focused on process and they are -

( )

V 14 - the reason to focus on a process first is to bring some  ;

l 1

l 15 repeatability to the process; that is, it's used. Using 16 consensus standards means that the considerations, the j i

17 elements concidered are probably more complete than using 18 experimental bases -- although we don't have the option of 1

19 using experimental bases with software, because -- well, 20 to some degree because software is an abstract entity, not i 21 a physical entity.

22 But relying upon experience makes it difficult 23 to analyze some of the experience to -- where experiments 24 can be more easily analyzed. But the standards, these C(% 25 consensus standards are developed -- what you're doing is, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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56 1 you're relying upon a system of feedback of practical f_3 2 experience.

/ 4 V 3 MEMBER MILLER: And this experience, because 4 they are consensus standards for the software industry, 5 really then you would say you get feedback from all 6 segments of the software engineering community. NASA 7 would be involved in there, aircraft and so forth. I 8 mean, they were not nuclear standards?

9 MR. COFFMAN: That's right. They were not 10 nuclear standards, plus these experiences by the system, 11 the system also includes upgrading, generally on a 5-year 12 period. So you know, you don't let the experience 13 stagnate.

(~\

'w l 14 But that's one effort closely tied to the i

15 regulatory process that we've got underway -- or, we're at 16 that stage; that's where we are on the software reg 17 guides.

18 We recently issued a report under review 19 guidelines for software languages. And these are review 20 guidelines for the regulatory reviewers, because there are j l

21 some characteristics in the different languages that are j i

22 used in programming, that are practices that have the 23 potential to have adverse safety impacts.

l .

l 24 An example might be dynamic allocation of

(~s

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57 l

1 in working through the code in actual application, and you l ,_ 2 could store and then recall values from memory that had

(

~

3 not been planned in the design or tested.

4 So we put out this guidance on six languages.

5 And it's not a style guide; it's not a consumer's report 6 type of assessment of languages -- of trying to get people 7 to select them - but it's a reviewer's guide for the 8 purpose of flagging to the reviewer, what characteristics 9 of these languages -- when the reviewer finds it used in a 10 safety system -- he should be aware of.

11 The CASE tool, computer-aided software l

12 engineering tool that we developed to look for common 13 code, uses a control flow analysis where it basically l

(~h  !

k sl 14 identifies what parts of the program being looked at is l l

15 relevant to selected output. So it identifies that slice l l

16 of program.

17 The program can then be -- which is the string 18 of dependent statements through the program that the 19 output depends upon -- those different slices can be 20 combined if the output -- you're looking to see if output  !

l 21 1 is to be independent from output 2.

22 And you can combine those clices and identify 23 where there are common instructions in the code, and it 24 raises the potential -- it identifies for the reviewer, r'N

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1 58 1 mode failure, common cause failure.

2 We were thinking about -- in the CASE tool we 7_

U 3 were thinking about trying to modify it to be able to 4 identify the language characteristics, the undesirable 5 programming practices. But in doing a survey we were able 6 to discover that most of those undesirable programming 7 practices -- that there are CASE tools available already, 8 so that information was helpful coming out of that study.

9 Another product is the human factors 10 engineering guidelines, review guidelines. This is NUREG-11 0700, Revision 1, which provides review guidance to the 12 staff for both reviewing submittals, inspecting designs 13 and investigating events.

/~

t K 14 Then the last item on this viewgraph is an 15 evaluation of computerized procedures. We did that to 16 gain some firsthand knowledge with computerized 17 procedures. This was a computerized procedures system 18 developed at the Halden Reactor, and we tested it out at i

19 North Carolina State University scaled PWR facility.

20 MEMBER MILLER: These are I&C procedures? j l

21 MR. COFFMAN: These are emergency procedures. l l

l 22 MEMBER MILLER: Emergency operating i 23 procedures?

24 MR. COFFMAN: Yes. And they were computerized 25 by this system. It's a computerized procedures manual

{)N NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W. I (202) 234 4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 l l

! 59 i

! 1 called COPMA. But part of what I've included in here is i

n 2 work on the intetface. And this is --

/ i LJ 3 MEMBER MILLER: The last two items really 4 don't have direct impact on digital I&C.

5 MR. COFFMAN: Not digital I&C, but they do --

6 we consider them to be involved in the total system --

7 which I'm going to come back to the total system here in a 8 minute.

9 Just to continue on some of the products --

10 dynamic flowgraph methodology is an analysis tool to be --

11 we put that out as NUREG-6465. Right now it just covers 12 software and hardware, and analyzes the hardware and 13 software system -- either the design or implementation in p)

\

V 14 the context of its use.

l 15 It's an amplification, it's an expansion from 16 fault tree methodology -- I'm not saying it was built upon 17 it, but it expands upon it because it includes both 18 success and failure events. Prime implicants is what it 19 uses.

20 And it also goes beyond the binary, the 21 fail /no fail. There are different states, so it includes 22 the different states. We're exploring it as a tool for 23 analyzing software and hardware.

24 MEMBER MILLER: Analyzing -- what do you mean f%

(,)

t 25 by -- analyzing what aspect of software?

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60 i

l 1 MR. COFFMAN: Looking for combinations -- the l

l fy 2 output is such that you're looking for combinations of r

i U/ 3 conditions of basic events that could lead to an adverse l

4 effect -- lead to top event and fault tree type of effect.

5 But you're looking for undesired failure modes and what 6 combinations could occur -- would give me that.

7 MEMBER MILLER: No , I mean, I did look at that 8 before. That came out last summer, right?

9 MR. COFFMAN: Yes.

10 MEMBER MILLER: It wasn't clear to me -- the 11 overall goal was that Research program.

12 MR. COFFMAN: Yes.

_ 13 MEMBER MILLER: This is going to give us a

( )

14 better way of assessing the reliability of the product, or 15 the --

16 MR. COFFMAN: It's an alternative --

17 MEMBER MILLER: -- another way we're 18 discussing the way we're doing the process --

19 MR. COFFMAN: It's an alternative way of 20 looking at the reliability of the -- at this point, the 21 software and the hardware. So it's an analysis method to 22 generate those combinations of events -- you know, like a 23 fault tree generates combinations of faults, this 24 generates combinations of failurcs and successes.

1 (3_j/ 25 MEMBER MILLER: George, did you look at that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

61 1 report?

2 (No audible response.)

7-s.

> )

~

3 MEMBER MILLER: Go ahead.

4 MR. COFFMAN: We made some measurements of the 5 ambient EMI and RFI at nuclear power plants. The purpose 6 of this was to confirm the operating envelopes, EMI/RFI 7 characteristics at nuclear power plants.

8 So measurements were made at eight sites over 9 a 14-month period, and on the average -- these were 10 continuous measurements, so on the average it was two 11 weeks. Some sites were five weeks, and millions of 12 readings were taken.

13 To do this we had to develop a spectral f'T

\' 14 receiver that could be operated unattended, continuously.

15 And that was developed by Oakridge, and these measurements 16 were made and reported in NUREG-6436, which is a good, 17 rather extensive characterization of the EMI/RFI 18 environment in power plants.

19 MEMBER MILLER: Now you're also in process of 20 developing a Reg Guide on EMI/RFI, right?

21 MR. COFFMAN: Yes sir.

22 MEMBER MILLER: Now how is that going to --

23 we've already endorsed an SER on EMI/RFI which was 24 developed as a guideline by EPRI. How are these two going

(~m

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62 1 or are these measurements consistent with the EPRI 7s 2 guidelines?

k ') 3 MR. COFFMAN: Yes, the measurements -- ,

l 4 MEMBER MILLER: It's hard to picture here in 5 this area how this all fits together.

6 MR. COFFMAN: The measurements are consistent i

7 and the development of the reg guide would consider the 8 measurements also made by EPRI -- the development of their 9 guidance. They used a different system, they took l 10 snapshots.

11 So considering both the EPRI measurements and 12 these measurements, and the EPRI guidelines, and the )

13 military standards that relate to EMI/RFI, then we put n

- 14 them all together and prepare a draft reg guide. l l

15 MEMBER MILLER: So would the goal of this reg ,

l J

16 guide be to supersede the SER, or the guideline, or -- I'm i 17 trying -- what's the goals here of the two different j 18 guidances on the same issue?

19 MR. COFFMAN: Jerry Wermiel --

20 MEMBER MILLER: Yes, Jerry.

21 MR. WERMIEL: Jerry Wermiel from the NRR 22 staff. Dr. Miller, the decision on the need to pursue a 23 reg guide is being considered -- we considered because of 24 the very question that you're raising, 25 If we go forward with a reg guide it will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBE %S 1323 RHODE ISLAND AVE., N.W.

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63 1 based on a perception that while the EPRI guidance n 2 provides the industry a way of demonstrating qualification

( ) l 3 for digital systems to EMI/RFI environments, it's not the {

l 4 only way. l 5 The staff recognizes that, just as Frank ,

1 1

6 mentioned, there are other ways of providing )

7 qualification. This could be done through testing against 8 the military standards; it can be done through the kind of -

l 9 methodology pursued by Oakridge. And the reg guide would )

10 put together in one place, all the potential options for j 11 demonstrating qualification to EMI/RFI. ,

t 12 It will not in any way, supersede the staff's 13 acceptance of the EPRI guidance document on the subject -- I l

l

(~%

U 14 that's TR-102323 -- but it would put together other 15 potential approaches. The reason for that is because 1

j 16 we've been told by a number of vendors in particular, that j 17 they may want to do other things; things different from i

18 what is in the EPRI guidance document, in order to 19 demonstrate that their particular products are qualified.

l 20 And we've said, that's fine; we're not going 21 to preclude you from doing that. But what that means is, l

l 22 perhaps the broader guidance in a reg guide is 23 appropriate. We're still looking at that ,d we haven't 24 maae a final decision about whether or not there will be a f"

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i 64 1 there will be.

g3 2 VICE CHAIRMAN SEALE: Well, are you telling us O 3 that the issuance of the reg guide would perhaps encourage 4 diversity in the way in which different vendors might go 5 about meeting this requirement?

6 MR. WERMIEL: It not only would perhaps 7 encourage it, we already know that there is already going 8 to be diversity, Dr. Seale. The --

9 VICE CHAIRMAN SEALE: So in that --

10 MR. WERMIEL: Certain vendors are not going to 11 do exactly the kinds of things that the EPRI guidance say.

12 VICE CHAIRMAN SEALE: Sure.

13 MR. WERMIEL: They've said that already.

O

'- 14 VICE CHAIRMAN SEALE: Okay. So in that sense, 15 publication of the reg guide would, in a sense, encourage 16 --

17 MR. WERMIEL: Yes.

18 VICE CHAIRMAN SEALE: -- going forward. So it 19 seems to me like --

20 MR. WERMIEL: Yes, it v.ould.

21 VICE CHAIRMAN SEALE: -- I'd have a hard time 22 figuring out why you wouldn't want to follow the reg 23 guide.

l t

j 24 MR. WERMIEL: Well, only in that, in past

[

(m l

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65 1 already. I think -- as I was saying, I think it's likely

-s 2 a reg guide would go forward.

3 Certainly the industry itself, the licensees 4 themselves, are quite happy with the EPRI guidance, and 5 they believe that that is what they would want to impose; 6 even though some dunders are telling them that's not what 7 they're going to do, and if they want to utilize their 8 products, they'll have to take exception to certain parts 9 of the EPRI guidance and get our approval on that.

10 VICE CHAIRMAN SEALE: Yes, but there is an 11 implications of the standards of performance that you 12 would expect from these alternative methods that's sort of 13 embodied in the reg guide.

()

14 MR. WERMIEL: Yes, no question.

15 VICE CHAIRMAN SEALE: That might be helpful, '

16 even if you don't use that particular alternative, at 17 least it kind of tells you what kind of -- what your goal 18 is.

19 MR. WERMIEL: I think you're right, although 20 the GDC themselves are pretty clear already. Whatever 21 digital technology you employ must be qualified for the 22 environment it will see, and if it sees electromagnetic 23 interference to certain levels, then it must be qualified 24 to perform its function to those levels.

m

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l i

66 l

l l

1 guide no matter what we did, because each reg guide states l 2 the basic regulatory requirements, put requirements right (m\

s <

3 up front before it even begins to provide supplemental 4 guidance.

5 MEMBER MILLER: So the premise in the reg l

6 guide will be consistent with the premise in the guideline 7 which is endorsed --

8 MR. WERMIEL: Yes.

1 i

9 MEMBER MILLER: -- and this would give you -- l l

10 just broaden your ways of meeting that basic premise?

l 11 MR. WERMIEL: Absolutely; that's right.

l 1

12 MEMBER MILLER: And the research that Frank '

l l 13 has just mentioned here is supporting the development of l ,O r ;

C) 14 that reg guide?  !

15 MR. WERMIEL: Yes, it was. All the work that 16 was done at Oakridge was compared against the EPRI 17 guidance before it was endorsed, to ensure that there was 18 a correlation, or that there wasn't anything --

i 19 MR. COFFMAN: Inconsistencies.

l 20 MR. WERMIEL: Yes, inconsistent in the tube.

l 21 MEMBER MILLER: I guess the next one which you l

l 22 haven't gotten to is stressors -- that report has EMI/RFI l

23 also, right?

24 MR. WERMIEL: That's correct.

25 MEMBER MILLER: That report is just issued I l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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l

67 1 believe, right?

,_ 2 MR. COFFMAN: Yes.

!' 'l 3 MR. WERMIEL: I have to say, I have not read 4 it yet, but I do have it.

5 MR. COFFMAN: Yes, the purpose of that report 6 was to determine the failure modes and weaknesses in the 7 type of technology that's in use.

I 1

8 MEMBER POWERS: Can I go back to your database 9 on the EMI/RFI? l l

10 MR. COFFMAN: Sure. I 11 MEMBER POWERS: You said you looked at eight 12 plants for an average two weeks each? l 13 MR. COFFMAN: Yes.

l'3 ss l 14 MEMBER POWERS: And that was always at power 15 operation?

16 MR. COFFMAN: It was primarily at power 17 operation.

18 MEMBER POWERS: I guess what I'm --

19 MEMBER MILLER: I was waiting for your 20 question, Dana. I was trying to anticipate it here.

21 MEMBER POWERS: I guess what I'm interested 22 in, is that what you're interested in was not just the 23 average but the statistical fluctuations in the EMI power.

24 And I'm wondering is, is a 2-week period in one mode of 25 operation enough to give you the statistical fluctuations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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68 1 over a year?

7- 2 MR. COFFMAN: Yes, the report contains an

! )

~#

3 estimate, the likelihood of capturing limiting events.

4 And I forget the specifics, but -- it's high but not 5 overwhelming. It was like on the order of -- given the 6 measurements that are -- it's like a 90 percent confidence 7 that captured -- on a random basis of the events 8 occurring, that we would have captured the limiting EMI 9 event for the year.

10 MEMBER POWERS: In that particular mode of 11 operation, though?

12 MS. ANTONESCU: This is Christina Antonescu 13 from -- I'm working in Frank Coffman's group. We looked s 14 at the range of operating conditions, both our start-up.

15 We also captured some transients, so we looked at the 16 range of different conditions. l 17 VICE CHAIRMAN SEALE: I recall hearing 18 something in the junk news that one inevitably is 19 assaulted with when you drive around in your car, about a 20 period of intense sunspot activity coming up and that this 21 may have some adverse effects on PCs and other things like 22 that.

23 First of all, are you satisfied that the 24 EMI/RFI environment that you're concerned with, is largely

/N

(_) 25 internally generated?

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1 69 1 MR. COFFMAN: No. I mean, we're considering 2 lightening.

7-w Y 3 VICE CHAIRMAN SEALE: Okay, fine. All right.

4 And then there's also this sunspot thing, so it may be 5 that you didn't pick the right two months in the 11-year 6 cycle or whatever it is, too, so.

7 MR. COFFMAN: Yes, this was over 14 months, 8 but --

9 VICE CHAIRMAN SEALE: Well, whatever.

1 10 MR. COFFMAN: Whenever you sample, there's l 11 always the question of representative, or capturing the --

12 VICE CHAIRMAN SEALE: Dana's point is very )

13 much the case. That this is a cyclic process that obeys a

. A

1 ,

\/ 14 rhythm that is a little disturbing. l 15 MR. COFFMAN: It is a concern. And the 16 sampling by this process used by Oakridge over --

17 continuous for weeks, gives you one picture. The EPRI l

18 effort, they staged some events, other fields, and looking 19 at the collection of data gives you some confidence, but 20 it won't give you a full guarantee that you've captured 21 the limit either.

22 MEMBER MILLER: Well, Dr. Seale raised the 23 question about the sunspots. I also heard the same junk 24 mail and I have experience with sunspot effects on

( / 25 communications, not necessarily on PCs though.

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70 1 Is that something that is being considered by l

r~g 2 the staff, or even aware? I was surprised that they were t i V

3 going to say sunspots affects PCs; if they're going to 1

4 affect digital I&C I'd be surprised. We should maybe look j 5 at it.

6 MR. COFEMAN: To my knowledge, we're not 7 addressing it directly, but the measurements were made at 8 locations that were considered representative of where 9 digital systems might be installed.

10 MEMBER MILLER: My point is sunspots. They go 11 through a cycle; I believe it's 10 or 11 years.

12 VICE CHAIRMAN SEALE: Yes.

13 MEMBER MILLER: They've had dramatic effects

\/"s')

'~'/

14 on communication by shortwaves and so forth. And I was 15 surprised they were raising the issue of sunspots 16 affecting digital systems like PCs, but maybe it's 17 something to look at.

18 I don't know -- Christina do you have any 19 idea on those things?

20 MS. ANTONESCU: We haven't looked at that, but 21 we're happy to look.

22 MEMBER MILLER: I'm not certain -- don't spend 23 a lot of time on it, but I was just surprised -- I heard 24 that thing, it bothered me. Like I say, I've had O

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71 1 it affects the ionosphere quite strongly. l 1

2 MR. COFFMAN: Well, we haven't looked at the {

\"/ 3 EMI/RFI issue from the standpoint of sources; other than l

4 the risk assessment which I'll mention. But the idea even 5 of the risk sensitivities is to determine which ones could 6 be the most important ones to address.

7 MEMBER MILLER: And of course, lightning came 8 out of the one study with Brookhaven.

l 9 MR. COFFMAN: Right. So we're in the process 10 of considering what to do -- addressing lightning. This -

11 -

12 MEMBER MILLER: Excuse me. Since I've not 13 read the report yet on the stressors -- on the effects of n

i 4

(>' 14 stressors -- that's the Oakridge study, right?

15 MR. COFFMAN: Yes.

16 MEMBER MILLER: Is there anything in there 17 that the committee should know about, or should we just 18 all read the report and --

19 MR. COFFMAN: Well, basic --

20 MEMBER MILLER: Anything dramatic --

21 MR. COFFMAN: Nothing dramatic --

22 MEMBER MILLER: -- surprise -- showstoppers I 23 guess, is the most recent word we use.

24 MR. COFFMAN: No, nothing dramatic; in fact

/%

f

) 25 the results are consistent with the risk sensitivity NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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72 1 studies from Brookhaven. The EMI/RFI -- it's to be the

,_ 2 leading contributor. Smoke can be a contributor, and then i

("'l 3 the synergistic effects of high temperatures and humidity.

4 MEMBER MILLER: Now, of course lightning was 5 not part of that study.

6 MR. COFFMAN: No, in fact, in the risk 7 sensitivity study the lightning was used as a substitute 8 for -- because we didn't have data on the other, 9 And the other thing coming out of that that 10 the committee might be interested in is the fact that it's 11 at the interfaces where most of the -- appears to be the 12 most sensitive part.

13 Online calibration monitoring w6m a small t

rx) x- 14 business, innovative research project that explored how 15 effective automated monitoring of the calibration of 16 instrumentation was compared to manual monitoring. And 17 there's interest in the potential reduction of calibration 18 intervals.

19 MEMBER MILLER: Again, I'll ask the question.

20 That was separate from -- obviously separate from the 21 EPRI. I believe EPRI has an SER of coming through the 22 system, is that right, Jerry?

23 MR. WERMIEL: Yes, they owe -- EPRI owes us a 24 topical report on the guidance document for doing online I 25 monitoring. We have not seen it yet and we are continuing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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73 1 interactions with them on that.

2 MEMBER MILLER: Oh, I thought they'd submitted

, c 1 3 that?

l l

i 4 MR. WERMIEL: No, no the top -- they submitted l

l 5 a draft document quite some time ago that was very high l

6 level, very, very sketchy. And we've interacted with them 1

7 on several occasions since then, providing comments and 8 input, and the document itself is being developed, but 9 it's being developed on a relatively deliberate and --

10 I'll say not particularly fast track.

11 They have promised us a -- very shortly, as a 12 matter of fact -- a second version of that document, and 13 we're going to be meeting with them -- I believe it's next

\(')s v 14 week, Dr. Miller -- to go over their plans and where they 15 are with that document. But an official topical hasn't 16 been submitted yet.

i 17 MEMBER MILLER: So my question is, is this 18 research effort here in some way connected in any way? Or i l

19 are these two separate, standalone efforts that are 20 consistent --

21 MR. COFFMAN: They're generally a standalone 22 effort -- was, like I said, a small business innovative 23 research, l

24 MR. WERMIEL: That's right.

l p/

(

25 MEMBER MILLER: So what are we going to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i l 74 l

l 1 with the results? Are they going to help us evaluate what i es 2 EPRI'c doing? I'm trying, again, to put the pieces f

LJ 3 together here.

4 MR. WERMIEL: I haven't seen the results of 5 that work yet, if it's available -- at least in my branch, 6 Dr. Miller -- but I would say this. I would expect there 1

7 might be some insight from what they did that will help us 8 in our understanding of this topic.

l 9 This is an extremely controversial topic and a l 10 lot of work needs to be done. So I would say any help at j l

l 11 all from another set of eyes would be of benefit to us in 12 this area.

13 MR. COFFMAN: Yes, I think we might find O

\/ - 14 particularly useful the results, the measurements made at 15 a couple of power plants.

16 MEMBER MILLER: What contractor did this work?

17 MR. COFFMAN: AMS.

18 MS. ANTONESCU: Analysis Measurements. And 19 the work was coordinated with EPRI, and other members --

20 MEMBER MILLER: Oh, so it was? Okay. And you 21 said AMS --

22 MEMBER SHACK: Is this one of the small 50,000 23 or is this the follow-up --

24 MEMBER MILLER: No , it was the bigger one.

i

(~)

25 MR. COFFMAN: This was phase 2.

q,/

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75 1 MEMBER MILLER: Oh, this is phase 2. But AMS I

rx 2 did this one, right?

l )

\_/

3 MR. COFFMAN: AMS.

4 MEMBER MILLER: They're pretty well familiar 5 with EPRI --

6 MR. COFFMAN: Yes.

7 MEMBER MILLER: Not officially maybe, but 8 unofficially.

9 MR. COFFMAN: Just by way of continuing an 10 overview, talk about the current projects. We've got a 11 project on hybrid control rooms. This is a user need and 12 it also what we referred to as a gap in NUREG-0700, Rev.

, 13 1.

(' ') 14 And the user need in the project is focused on 15 looking for potential effects on performance on the 16 operators, and if so, then provide review guidelines.

17 And it's focused on some topics - I'm not 18 sure I'd call them issues, but they are topics -- looking 19 at design and implementation, looking at the topic of 20 computer-based procedures, then information design or --

21 like navigation -- to do some soft controls and the 22 effects of mode changes, and looking at the maintenance of 23 digital equipment.

24 MEMBER MILLER: Is that part of the Halden

! /\

l C/ 25 project?

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l l 76 1 MR. COFFMAN: No.

l lI l

s

)

2 3

MEMBER MILLER:

MR. COFFMAN:

Who did you say did that one?

That's Brookhaven.

4 MEMBER MILLER: Brookhaven.

5 MR. COFFMAN: These are now current, ongoing l

6 projects.

7 MEMBER MILLER: Okay. And are they going to 8 look at what's going on here nationally in those areas?

l 9 MR. COFFMAN: Yes. Yes, John O'Hara is the 10 guy on that.

11 MEMBER MILLER: I know it's in your 12 information you provided us. What's the target date on l 13 that one to get a report?

l n i I x/ 14 MR. COFFMAN: Well, the next step I think is l

15 in March or April. Joel?

I 16 MR. KRAMER: Actually, we decided on, based l 17 upon an evaluation and prioritization scheme to develop 18 the guidance for these five topical areas and go through a 19 peer review process, an external peer review process, by 20 the end of FY98. Actually, some of the topics will be 21 actually completed the end of FY97. But what we envision 22 is packaging the five in a module for a future revision to i 23 NUREG-0700 Rev. 1.

24 MR. BOEHNERT: Could you identify yourself,

'O 25 Joel, for the record?

()

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77 1 MR. KRAMER: Joel Kramer, Office of Research.

7-2 MR. BOEHNERT: Thank you.

3 MR. COFFMAN: The approach then, is what I I

4 guess is the tie to the March date.

5 MEMBER MILLER: Joel, have you -- or I should 6 say, has Brookhaven then looked at the international 7 control rooms designs with you?

8 MR. KRAMER: Yes. As a matter of fact, the 9 first phase of the project was a comprehensive literature 10 review and site visits, and incorporates most of what's 11 going on in Japan, for example, and other countries in the 12 Halden project. Other industries in our country -- so i

13 it's fairly comprehensive. It's about a 100-page j

- (_ >; 14 literature review and issues on a report that we already I

15 have.

16 MEMBER MILLER: Has that report been issued, 17 you say?

18 MR. KRAMER: It's a letter report --

19 MEMBER MILLER: Is there a way --

20 MR. KRAMER: -- that we have and we can 21 provide it.

22 MEMBER MILLER: Yes, I'd like to see that one.

23 MR. KRAMER: Very good.

24 MR. COFFMAN: The alarm system effort is to

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l 78 1 operator performance. This also is a gap in NUREG-0700, 2 and this is being done in the Halden project.

/,"N l

I i) 3 MEMBER MILLER: That's on alarm priority 4 setting and that type of thing?

5 MR. COFFMAN: That's one of the aspects, yes; l;

6 screening and prioritization, presentation.

).

7 Then the total system review guidelines is an l l

8 effort to develop guidelines or a template for the reviews l l

9 that ensure completeness of the total system requirement 10 specification. And this would be done through the 11 development of a systematic framework.

12 Framework is built based upon a decomposition 13 from the big picture to the specifics, keeping in mind two l CT

\- / 14 aspects: the safety functions that are necessary, and  ;

15 then the ability -- the integrity of the safety systems to 16 better performing those safety functions.

17 And the focus is on the requirement 18 specification because experience at a couple of different 19 places shows that most of the faults are introduced at the 20 requirement specification stage and picked up later. So 21 if we can bring the process under control, there would be 22 a potential reduction in the number of errors introduced.

23 MEMBER APOSTOLAKIS: Now, during the review of 24 the reg guides, the issue of expressing the specifications i,Iwy D 25 in terms of some sort of formal mathematical language was l

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79 1 raised. Are you going to have a project to look into l -

2 these kinds of possibilities? I mean, this is not an (s' ') 3 academic issue anymore. Ontario Hydro has done it. Are 4 there any plans to look into that?

5 MR. COFFMAN: Ontario Hydro -- I don't know 6 all the details of what they've done, but my understanding 7 is, it's more like formal notation --

8 MEMBER APOSTOLAKIS: Yes, yes. That's what I 9 mean.

10 MR. COFFMAN: -- than formal specifications --

11 MEMBER APOSTOLAKIS: No, it's not a formal 12 language in the sense that it's used in this field. But i

i 13 the question is whether -- I mean, you just mentioned that j 14 that's where most of the errors are, and that's consistent l I

15 with what the literature is saying. So I was wondering 16 whether you were planning to investigate it, at least.

17 MR. COFFMAN: We're following closely what 18 Halden -- and participating in what the Halden project is 19 doing on formal specification.

20 MEMBER APOSTOLAKIS: Oh, they are reviewing 21 it?

22 MR. COFFMAN: Yes. Plus what others have 23 done, experience others are having with the implementation 24 of formal method.

i

'O

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l 80 1 about Halden in the next slide, so --

2 MR. COFFMAN: Yes.

l f3 (v) 3 MEMBER MILLER: I'm looking at your title 4 there. So the title says, " Total System Review 5 Guidelines" Really, the emphasis is going to be on 6 specifications for a software system, right? Is that what 7 you're saying?

8 MR. COFFMAN: Yes sir. Yes, the --

9 MEMBER MILLER: You'll be looking at the 10 method --

11 MR. COFFMAN: -- focus --

12 MEMBER MILLER: -- methodologies, including 13 formal that George raises, but also some graphical methods

\- 14 and that type of thing. Is that the thrust of it? This 15 is a fairly new project, right? l 16 MR. COFFMAN: It's a fairly new project. Now I 17 in this project I don't think we're going to look at 18 graphical methods, but elsewhere we're looking at --

19 MEMBER APOSTOLAKIS: Who is doing this? The 20 last of the field work?

21 MR. COFFMAN: This is intended to be -- right 22 now -- well, we're in the negotiation stages, two national 23 labs with experience.

1 l 24 MEMBER MILLER: The timeline on that one, when O

\s,/ 25 you're going to select a national lab and then when you're

(

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81 1 going to move forward with it, and what's the timeline in  !

,s 2 getting at something?

/ \

3 Because I think that's a very important issue, 4 learning how to better, I guess, do the software 5 requirement specification in the design. Because that's 6 obvious from our review of the reg guides, that's one of 7 the weak spots in the overall software development 8 process.

9 MR. COFFMAN: The intent is to have the first 10 step to be for one of the contractors to develop the 11 framework, and the other contractor to review it. And the 12 two project managers involved are out for different 13 reasons, but if I recall correctly, we plan to complete p) i

\> 14 that before the end of fiscal '97.

15 MEMBER MILLER: Okay, good.

16 MR. COFFMAN: And then that would determine 17 where we go from there by way of developing review 18 guidance.

19 MEMBER MILLER: And since George mentioned the 20 Canadians, I would have to say there's great controversy 21 on the method they've used ao being any contribution at 22 all. So I'll just make that comment. I've talked to 23 Canadians since t. hat came up recently, and you would get 24 very differing opinions on that approach. As well as your

/^T 25 own staff of differing opinions.

( ,/

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82 I

l 1 MR. COFFMAN: We've talked to the ACRS about 1

i

,_. 2 the risk sensitivity studies of selected stressors. We 3 have just received -- haven't even had time to digest it -

4 - the final manuscript from the contractor on the 1

5 sensitivity studies. l 6 There were some -- when we talked to the 7 committee we mentioned some pretty bounding assumptions 8 that drove the results and the contractor has addressed l l

9 those assumptions. I'm not too sure that we haven't still l

10 got just a sensitivity study.

i 11 I mean, we need to consider -- the output of 12 the sensitivity study was what was interesting in that it 13 focused on lightning as the leading contributor. And part n.

\ .I I

14 of considering what to do with lightning is to review this 15 report. But it's at that stage, the report is at that 16 stage now -- the project is at that stage.

17- MEMBER MILLER: As far as what the final 18 report says, is there any change versus what we already 19 know?

20 MR. COFFMAN: No change --

21 MEMBER MILLER: And we reviewed that report.

22 MR. COFFMAN: No change in the relative 23 ranking.

24 MEMBER MILLER: Is that then, going to lead to l

l

('3j 25 another research program written more specifically at t

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83 1 lightning?

2 MR. COFFMAN: That we have under consideration f

and I've -- see if I've listed it -- and yes, we need to -

3 4 - it's a matter of characterizing the threat and 5 determining whether that merits putting limited resources 6 into it.

7 The next item on the effects of smoke, is also 8 a user need and there it was to determine the failure 9 modes and to develop guidelines for safety applications.

10 Part of that work done just recently issued report -- or 11 actually, it's at the stage of being at the printers.

12 It's a NUREG/CR-6476 on the circuit bridging of components 13 by smoke.

\p) k- 14 And then the follow-on effort, the rest of the 15 project is to address the longer-term effects -- you know, 16 the metal loss, the wastage consideration -- and then the 17 effects on the functional circuits. That's where we are 18 on that one.

19 There is a long-standing user need on 20 developing regulatory guidance for overall environmental 21 qualification of digital I&c. And there, the stressors 22 are still those that were focused on EMI/RFI:

23 temperature, humidity, smoke, perhaps vibration.

24 MEMBER MILLER: So that regulatory guide, now (h 25 That would put together all the

(_) what would that do?

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84 1 stressors --

-s 2 MR. COFFMAN: Right. For total environmental 3 -- for considering all the stress.

4 I was going to spend some time --

5 MEMBER MILLER: Might that also include the 6 traditional, environmental pressure and temperature, 7 things like we currently worry about for analog systems? ,

1 l

8 All this put together into one package would be kind of I l

9 like a summary of the -- Reg Guide No. IEEE 323 is the l l

l 10 environmental standard for I&C. Would that --

11 MR. COFFMAN: Yes, this would --

12 MEMBER MILLER: -- put that as a subset then? l l

13 MR. COFFMAN: I don't know whether it would i

(~

> 14 be a subset. l 15 MEMBER MILLER: I mean, 323 be a subset of 16 this regulatory guide? i 1

1 17 MS. ANTONESCU: Yes, 323 will be a subset of 18 this one.

l MEMBER MILLER: Okay.

19 What's the schedule on 20 this reg guide? Or have you decided to do it? I 21 guess,let me ask the question.

22 MR. COFFMAN: No --

23 MS. ANTONESCU: All these projects are closely 24 interrelated, so --

A

( ,) 25 MEMBER MILLER: I see that.

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85 1 MS. ANTONESCU: We have a target date, but we

,-w

, 2 are still working all these other projects, making sure O 3 that we've come out with a good criteria for EMI/RFI and 4 for smoke. So probably in '98, have a reg guide 5 available.

6 MEMBER MILLER: Is there a reason to have a 7 reg guide on EMI/RFI specifically, than one on 8 environmental overly global, or why not just put them all 9 on one reg guide?

10 MS. ANTONESCU: EMI was not treated originally 11 as a separate environmental stressor, and at that 12 particular time we considered as a separate stressor.

_ 13 MEMBER MILLER: Okay, so you would not --

14 MS. ANTONESCU: It's very hard to include test 15 methodology, test criteria under the existing 323, the 16 standard. We have not considered that, but something we 17 can keep in mind.

18 MEMBER MILLER: Okay, I see. Okay.

19 MR. COFFMAN: Okay, I understand that the 20 committee is interested in a little more discussion on the 21 Halden Reactor project. To orient those not familiar with 22 it, it's an OECD consortium. It involves 14 signatory 23 members and seten associate members from 19 countries.

24 Basically all the major nuclear-owning, nuclear power g~w

( ,/ 25 plant-owning countries are involved except Canada.

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86 1 And we've just renewed our agreement for the

-~ 2 next three years. We've participated since '58. But what

() 3 we get out of the Halden project is, we get technical 4 products: reports, data, even some software -- that gets 5 folded into the rest of the program to become part of the 6 technical basis for regulatory guidance. So that's one of 7 the major benefits we've gained from it.

8 Also, we gain access to the Halden man-machine 9 laboratory, the HAMLAB, which is in the process of being  ;

10 considered for upgrading. Right now, its primary l 11 ingredient to the upgrade is it's right now based upon a l 12 simulation of the Loviisa plant and it would try to I l

l 13 include a simulation of a more western style, western

, C) 14 design.

1 l 15 But we also gain access to test subjects and 16 to the staff necessary to conduct man-machine interface l

17 research, and just the whole aspect of an experimental 18 facility and the benefits that come with that, including i

19 testing of computer-driven interfaces.

20 It also provides us early information on test 21 and development, because Halden does test and development.

l 22 We get insight that we would not otherwise get as a 23 regulatory agency. So we get some advanced information or 24 insights into some of the emerging issues on I&C.

(h

(_) 25 Provides us qualified data in some other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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87 1 areas: fuels, radiation materials. But it also generally 2 provides a forum for international cooperation and 7-3 information exchange, and then leverage on the funding.

4 Just recently they've completed the lessons-5 learned reports. There were five lessons-learned reports 6 on the topics such as software OA, software reliability, 7 testing evaluation methods for the interfaces, and 8 advanced control rooms and the issue of function 9 allocation between automation and manual.

10 So these lessons-learned reports are 11 collections of what they've paid -- tuition -- the 12 benefits from paying the tuition on the research over the 1

13 past 15 years. And those, like the other technical  ;

(.

\/ 14 reports, data and information will be folded into the 15 ongoing projects and eventually find its way into 16 technical -- some of it finds its way into technical bases 17 for regulatory guidance.

18 Now, the plans. We have an ongoing effort to 19 use discreet event simulation task network modeling as a 20 means of integrating all the factors that shape the 21 outcome of the process involved in the utilizing or 22 operating with any I&C, but primarily digital I&c.

23 Every time we have opportunity we use 24 simulation to address the interaction of the different p

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! 88 1 interface side of the effort, in contrast with the dynamic I

2 flowgraph methodology, which is focused on the software

(;7s) t

%J 3 and the hardware.

4 We have used this for modeling process control l

l 5 -- control of processes -- but there was a possibility we l

l 6 could use this for the development process, and thereby i

7 bridge the gap between the process product reliability.

l 8 But that's not where I want to focus the discussion on 9 process and product reliability. I'm going to come back 10 to that in a minute.

11 Another aspect is that -- another effort is an 12 in-house effort where programmable logic controllers are - j 13 - they appear to be being used more frequently, and a CASE f'~N l k- 14 tool like Unravel, that would allow for bering checks l 15 looking for common code, those types of review tools, is i l

16 language dependent. So what we're doing is to develop a 17 CASE tool that would be for PLC languages since they tend 18 to be more symbolic. I I

19 MEMBER MILLER: How is that effort going to -

20 - you're aware the DOE-EPRI has established three areas of 21 research -- not research -- areas for I&C upgrade 22 emphasis? And one of them is PLC, programmable logic 23 controllers.

24 How does this effort dovetail with what DOE i

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i 89 I

1 a topical report of some type?

g- 2 MR. COFFMAN: Yes. We are just --

\ms/ l 3 MEMBER MILLER: Are you in the pipeline yet, 4 or -- I'm certain, I know the NRR is looking at it.

5 MR. COFFMAN: Just in -- Jerry may want to i i

6 address that -- we're just -- j l

7 MR. WERMIEL: What we'd expect, Dr. Miller, is 8 if we had this kind of a tool, when we actually see PLCs -

9 - specific PLCs proposed against the guidance document 1

10 that EPRI is currently developing, we could use thic kind l l

11 of tool as an assessment mechanism for approval.

I 12 EPRI's guidance is intended for general use l 13 for any manufacturer of a PLC, and they're all -- l l

{

."\ t k/ 14 manufacturers use different languages and different 15 approaches to their development of the software. Such a 16 tool, if practical or if it could be made practical, would 17 help us in our audit of the software when specific PLCs 18 are proposed.

19 MEMBER MILLER: Okay, yes. That's the EPRI 20 guideline on PLC --

21 MR. WERMIEL: The EPRI program on PLCs is 22 actually several phases. The first phase is to develop an 23 overall guideline that any manufacturer of a PLC could use 24 for assuring application of that PLC in a nuclear power

~

x_) 25 plant -- safety application.

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90 1 A second phase is for specific vendors to then 7- g 2 be contacted, to actually propose products for the staff i V 3 to accept against those guidelines. That phase is 4 somewhat down the road yet. Although, the industry is 5 already working with at least two vendors that we know of,

]

1 1

6 to solicit interest in developing a generic platform for 7 use in nuclear power plant upgrades.

8 MEMBER MILLER: And a utility is buying in so l

9 -- a utility may be our test (indiscernible), is that i 10 right?

l 11 MR. WERMIEL: There are some utilities that )

12 are already pursuing potential PLC platforms with specific i l

I 13 vendors, yes, that's true. 1 f ~__,r.

"' MEMBER MILLER- So this all fits together?

14 l

15 MR. WERMIEL: It all fits together -- well, )

16 I'm not -- because this is in the planning phase, I can't 17 necessarily say that this is something that we're going to 18 be able to use specifically in our review efforts. That's 19 our intent; we hope to be able to take something like this 20 and actually audit the PLC platform software when we start 21 to see specific PLCs proposed.

22 MEMBER MILLER: Well, I would assume that if 23 Research is going into it, the goal is to be able to use 24 it, as you say.

/'N ,

km) 25 MR. WERMIEL: Oh, yes, that's the goal.

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91 1 MEMBER MILLER: You have the need --

- 2 MR. WERMIEL: The need is clear.  !

\ >

3 MEMBER MILLER: I'm just trying to fit all the 4 pieces that I'm aware of, all together here.

5 MR. HERMIEL: Fortunately, we think we have  ;

1 6 time to develop this because the, as I say, the guidance  :

1 1

7 document has yet to be approved, and then once that is 4 1

8 approved then the application-specific vendor work has yet l l

9 to go, has yet to be done. So there is time, we think. I 10 MR. COFFMAN: I was going to give you some j 1

11 insight into what we see on the horizon. I was going to 12 go over some of these items which I titled considering -- ,

1 1

13 or, those items which were projects we're in different

(~~ j

('

14 stages of considering but we haven't actually committed 15 ourselves to.

16 The first being a CASE tool for failure modes 17 and effects analysis on software, and this is primarily 18 in-house effort to, you know, basically seeding faults 19 into source code and determining the effects, and looking 20 at existing CASE tools for their capabilities and 21 limitation, and for possible consideration by possible use 22 by the regulatory office.

23 MEMBER MILLER: Now, there's a study actually i

24 taking place -- isn't that what Smidts is doing at

/'N j ( ,) 25 Maryland? Is that what she's doing?

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92 l,

1 MR. COFFMAN: Well, no, Smidts -- well, I l

2 don't know what all she's doing but --

(,, )

\  !

3 MEMBER MILLER: Well, she has a paper I looked 4 at.

5 MR. COFFMAN: Yes, the paper -- well --

6 MEMBER MILLER: I just -- I have my notes; I'm 7 looking at it right now in front of me here. I'm trying 8 to figure out how these fit together. George, you've 9 looked at this paper too, I know. Wasn't she one of your 10 students?

11 MEMBER APOSTOLAKIS: I'm not sure it's 12 appropriate to discuss specific investigator's projects, 13 is it?

k) 14 MEMBER MILLER: Well, I'm only looking at a 15 paper she published. I don't know about her projects.

16 MEMBER APOSTOLAKIS: Well, even --

17 MEMBER MILLER: I'm just wondering if we're 18 interfacing.

19 MR. COFFMAN: Are you looking at her paper 20 that relates to predicting reliability of software based 21 upon --

22 MEMBER MILLER: Right --

23 MR. COFFMAN: -- failures of their --

24 MEMBER MILLER: " Systematic Generation of s

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l 93 l l

1 Tolerant System Software." l

-s 2 MR. COFFMAN: Yes. Actually --

( /

3 MEMBER MILLER: I'm not certain how these fit 4 together.

5 MR. COFFMAN: Yes. That -- if you look at the 6 bottom bullet, that's what I was going to maybe touch on 7 that. This is just to evaluate case tools for doing FMEAs 8 on software and gaining some firsthand experience with 9 them, but it could facilitate, particularly the review of 10 object-oriented codes where techniques like information 11 hiding are used.

12 And it's difficult to do a more typical FMEA, 13 so if you have the CASE tools to help you do the FMEA you o

~- 14 can more readily flag failure effects and seeded faults.

15 MEMBER APOSTOLAKIS: Now, does FMEA cover I

16 HAZOP? Is that the same thing? Because I've seen a bunch l i

l 17 of papers also, that use the term HAZOP, hazard and I I

18 availability analysis. Not on FMEA, but -- l I

19 MR. COFFMAN: No, I -- l 20 MEMBER APOSTOLAKIS: They're probably the same 21 thing.

22 MEMBER FONTANA: They're supposed to be 23 different.

24 MEMBER APOSTOLAKIS: Are they? Well HizoP is

(%. But I'm not sure it's that

(_) 25 used by the chemical industry.

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1 i

94 l l

f 1 different from FMEA.

,f3 2 MR. COFFMAN: Well, I'm not an expert in the j

( )

\_/

3 hazard analysis, but I understand that it's more toward --

4 what we would do by way of determining vulnerabilities o'f  ;

5 a system, in a system where FMEAs are more looking for the 6 importance -- you take an inventory of failures, you i

I 7 propagate them to their effects, and then by looking at i

8 the relative important effects, you can determine if there l l

9 are some failures that merit more attention than others.

10 MEMBER MILLER: Then you can develop a way to 11 compensate for the failure, right? )

1 12 MR. COFFMAN: Right.  !

1 13 MEMBER MILLER: And I think that's the l

/ i

'~ 14 ultimate goal. i 15 MR. COFFMAN: Yes, it could be, right. l 16 MEMBER MILLER: Sometimes I think we worry 17 about reliability almost -- we might more want to worry 18 about the failures and compensate for the failures. )

19 Develop fault tolerant systems and not worry about 20 reliability. That may be a better approach here.

21 So the goal here is to develop, at least get a 22 start on that approach?

23 MR. COFFMAN: Yes.

l 24 MEMBER MILLER: And you say that's in-house?

r~%

k ,) 25 MR. COFFMAN: It's in-house. Again, like on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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1 95 l 1 the languages, we're not trying to endorse any particular )

I l q 2 language or any particular CASE tools, but we're trying to l t s

%J 3 gain some firsthand experience with it.

I 4 I think I mentioned already that we're l

5 consider:.ng the review guidelines for lightning effects, 6 looking at the Brookhaven report.

7 Then the study on ". non-safety system 8 development product. The thesis there is that the 1

9 mechanisms that generate the faults in non-safety systems 10 are the same mechanisms that generate faults in safety 11 systems -- could generate faults in tne safety system.

12 So given that, we were going to do some --

13 considering doing some research on non-safety systems and i  ;

I k/ 14 development of non-safety systems in nuclear power plants 15 and that would involve first identifying a target system 1

16 at a plant, and then monitoring the development process. l 17 Monitoring the development process in the way that Smidts 18 writes about on her paper.

19 So that you then have a means, using her 1

20 technique, then have a means of predicting reliability of j 21 the outcoming system. Then -- okay, that takes you to one 22 point, which gives you some results which you could then 23 compare against independent evaluation of the software.

I 1

! 24 And we would do that perhaps, in-house also.

l

(/m\ -- the

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l 96 1 resulting software primari3y, even though it was on a

,s 2 total system -- to evaluate and determine what residual l 3 faults might still be in the software, and then compare 4 the two.

i 5 And that might give you some feel for the l

1 6 relationship between the development process and the 7 prediction hat you would get of the reliability out of 8 that process, and an independent evaluation of a separate 9 product.

10 There's even a third ingredient to the 11 comparison, and that's operating experience. After you 12 collect data on the operating experience of the developed 13 system and then you can compare that to the predicted

(

\- 14 reliability or the results of the evaluation.

15 MEMBER MILLER: So the idea would be to pick a 16 non-safety system which we have -- a digital system which 17 you have some long-term experience with? Do we have 18 digital systems on plants -- non-safety parts of plants 19 which have been there for quite a while? Your feedwater 20 is the one that comes to mind real quick.

21 MR. COFFMAN: Yes, if you picked a, for 22 example, a feedwater system, you'd want to pick one that 23 was being upgraded --

24 MEMBER MILLER: From an analog to a digital?

fh

()

25 MR. COFFMAN: Analog to digital, or even the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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4 1

97 i l

digital being upgraded itself. And then looking at that l 2 development process is where you would monitor it and

(,,)

3 collect the data that would be necessary to put into j i

l 4 Smidts' technique.

5 MEMBER MILLER: How far along are you in this 6 one?

7 MR. COFFMAN: These are just being considered.

I 8 We're exploring possibility, feasibility, the approach. l 9 But it's something -- we're trying to look beyond the  :

I 10 present, and that was the intent for describing these 11 items called " considered".

12 MEMBER MILLER: I'd certainly look at the --

13 well, I picked digital feedwater because it's a fairly p,

k- 14 complicated one; it's had some success, too, as one to 15 look at. Those have been taking place over a number of l 16 years, and they're still further upgrades going on.

17 MR. COFFMAN: Then this final viewgraph and 18 just three more items on the list. I need to record, or 19 clarify the wording on the second one, so I'll get to that 20 in a minute if you're reading ahead.

21 But on the software numerical reliability l

22 measures, we're just exploring, considering how to explore i

i 23 the feasibility of numerical reliability of software, and 24 by such techniques as one that -- SoHaRs published some

/

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98 l 1 upon, but it's one where it's kind of key to monitoring l

-s 2 development processes and controlling and evaluating final l O 3 product. oo we've got some of those under consideration.

l 4 If I were editing the viewgraph, I would 5 rewrite, instead of evaluations of the effects of combined 6 hardware and software failures, what we have in mind is 7 really more to evaluate the effects of injected faults on 8 hardware and software.

9 So this extends failure modes in effects 10 beyond just paper studies, but take some actual hardware, 11 which we think we're going to have access to, in 12 combination with its software, and then do an actual --

13 inject faults and measure the effects.

O k/ 14 You could do this in a -- we think it might be 15 possible to do this in addition to the paper studies, to 16 confirm the adequacy of paper failure modes and effects 17 analysis. So that's under consideration.

18 And then, obviously, it comes to the last 19 item, the ACRS will hear from the National Academy, 20 although you'll have the report beforehand. Right now I 21 understand it's scheduled for February 6th.

22 MEMBER MILLER: When is the report scheduled 23 for?

24 VICE CHAIRMAN SEALE: February 6th.

() 25 MEMBER MILLER: Well, I heard December 16th

()

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l 99 j l

l 1 earlier today. )

I r~s 2 MR. COFFMAN: Yes sir. What we'd do is, we'll

( ) l 3 get a preprint and right now we're hoping it will be in I

4 December 16th. We'd make distribution, including the  !

5 ACRS.

l 6 MEMBER MILLER: You'll distribute it in l 7 December to us, if it come in?

l l 8 MR. COFFMAN: Right. As soon as it comes in l 9 we'll make the distribution. It would be for internal use l 10 only until we get the final report, which will come out of  ;

11 an NAS printer. But the briefing is now scheduled.

12 MEMBER MILLER: Okay, that's what I thought 13 you meant. Okay, assuming it comes in in December, we'll 3

( 1

\/ 14 have the briefing on the report in February?

15 MR. COFFMAN: Yes.

1 16 MEMBER MILLER: Because we have no January 17 meeting.

18 MR. COFFMAN: Right. So the basic message that I was trying to deliver is that the program is doing i 19 20 two things: trying to improve the technical bases for 21 regulating advanced I&C by focusing on substantive issues, 22 and it's also trying to produce some tools to improve the 23 capabilities of the regulatory reviewers.

i l

l 24 MEMBER MILLER: We have a few more minutes.

25 What I'm trying to do is put everything together, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE,. N W (202) 234 4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

100 1 somehow I don't see the big -- I see a lot of pieces but I

,y

- 2 don't see them coming together. Maybe I'm looking at them b 3 differently, and other committee members may want to 4 interject here.

5 Do you have kind of an overall strategic plan 6 for research? It says, in I&C, here are the major issues 7 we need to address and here are the projects and how we're 8 going to address those issues. I don't see that coming 9 through clearly to me.

10 MR. COFFMAN: It's difficult to come through 11 because we are focused in regulatory support, and so we're 12 addressing substantive issues as they can be identified at 13 the time. But we have taken an initiative to try and 14 confirm that we've captured all the issue, and we did that 15 initially with the MITRE report -- NUREG-6263. But there 16 is -- was focused on software, but wc were trying to 17 determine, have we captured all the issues?

18 MEMBER MILLER: Well, let's take the MITRE 19 report. Would it reasonable to list the major issues 20 brought up in the MITRE report to see, are we addressing 21 the issues that we need to address in the MITRE report, as 22 an example?

23 MR. COFFMAN: Yes, the primary issue in the 24 MITRE report that was beyond the scope of its ability to t

O 4

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101 l

1 issue was the total system effort. l 73 2 And as I mentioned, we got a couple of efforts

('^' ) 1' 3 trying to address the total system and the total system 4 framework, or the design requirement specification 1

5 framework. And then this modeling, trying to look at 6 whether there are any simultaneously interacting -- let's 7 see, I'm not explaining it clearly.

8 In the combination of human system and ,

l 1

9 software faults, do you get any previously unidentified 10 adverse consequences? There are two efforts: the task 11 network modeling and then the possibility of including 12 this dynamic flowgraph methodology. Once we've added the 13 human to that, part of that ongoing effort is to add the

,G I

.k/ 14 human to the dynamic flowgraph --

15 MEMBER MILLER: And that addresses the system 16 issue brought up in the MITRE report? All those do?

17 MR. COFFMAN: Right. Yes.

18 MEMBER MILLER: So that's one of the major l 19 issues. What are the other major, kind of high-level 20 issues that we need to address? We've got environmental 21 stressors I guess, is obvious.

22 MR. COFFMAN: Yes. Coming out of --

23 MEMBER MILLER: Well, the MITRE report -- did 24 the MITRE report --

(- )

(, 25 MR. COFFMAN: No, it didn't --

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102 1 MEMBER MILLER: Didn't have environmental

- 2 stressors. I'm just looking at --

l

~' 3 MR. COFFMAN: It talked about domain l

4 engineering --

5 MEMBER MILLER: I'm trying to look at a global l

1 6 picture of all the issues we think we're facing at I&C,  !

i 7 and as research from a regulatory perspective, and is )

1 8 research addressing those issues that need to be j I

9 addressed? And it's not all fit together to me. I don't i

10 see the big picture yet. l l

11 MR. COFFMAN: Yes, it's something that we 12 worry about and try to keep our eyes and ears open to 13 monitor issues that are occurring, but we don't have -- do

/"N  !

4

! )

\/ 14 a lot of these efforts on -- you know, we're participating l 15 -- it's like the question, what are you doing to stay 16 current? ,

l 17 MEMBER MILLER: Well, let's take the software 18 areas. You have the MITRE report, you have several other 19 areas going on, the Halden project has been going on 20 forever, since 1958 -- that's forever for most of us --

21 and that's addressing software issues. Are they all 22 fitting together into trying to address a common set of 23 issues. Or are they just bits and pieces that aren't 24 coming together? I don't see them coming together.

,-~

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103 1 you mean by a common issue. We're addressing --

MEMBER MILLER: Well, let's say --

g)

(

2 3 MR. COFFMAN: -- the issues that are occurring 4 --

5 MEMBER MILLER: Let's take the common issue of 6 software reliability. And that's an issue that the 7 commission currently says, or their policy says, we do not 8 believe there's a way to quantify the reliability of 9 software.

10 MEMBER APOSTOLAKIS: Did we take that out? I 11 thought we took that out. I remember --

12 MEMBER MILLER: When we endorsed the Reg Guide 13 1.152 --

rx 14 MEMBER APOSTOLAKIS: I don't remember now how 15 it's stated, but I remember we moved something.

16 MR. COFFMAN: Yes, Reg Guide 1.152 says that 17 software -- numerical estimates of software are not to be 18 relied upon as the sole basis for regulatory --

19 MEMBER APOSTOLAKIS: The sole basis, yes.

20 MEMBER MILLER: Right.

21 MR. COFFMAN: But we're -- you know, that's an 22 issue that can be addressed by itself. We've got some --

23 you know, it isn't being prompted, it's a NAS, National 24 Academy of Sciences issue --

/3 Q 25 MEMBER MILLER: Right.

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104 l

1 MR. COFFMAN: -- but we're addressing it.

l s 2 This effort that considers how to use the SoHaR work, the

/ \

3 Smidts approach is another way to look at -- tends to 4 predict software reliability. So we're addressing the 5 issue. Whether there is a common issue and a way to 6 integrate the research program into something that has a 7 single objective --

i 8 MR. HODGES: Maybe what we should try to do 9 for you here is put together a matrix that says across the 10 top there, here are all the I&C issues we think need to be 11 looked at or have been looked at, and been taken care of l

12 through research products.

13 And then on the other side it says, this is

.Q

$ 1

\/ 14 what we need to have done, are doing, or plan to do. And 15 see where the gaps are.

16 MEMBER MILLER: Well, I think that's really a  !

17 very good beginning, and I realize that research is in a ,

I 18 sense, you're a responsive organization, not necessarily a 19 leading organization.

20 MR. HODGES: Well, we're trying to do some of 21 both.

22 MEMBER MILLER: You have to respond to what 23 the NRR wants you to do; I understand that. Maybe really 24 what I'm asking for is, NRR and research to come together

/"'

(_,N) 25 in one room and sit down and say okay, these are major NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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105 1 issues and how is research going to do these issues, how j fS 2 is NRR going to do these issues, and how is industry-t 1 O'

3 interfacing with EPRI, and DOE taking a lead in some 4 issues?

5 How are all these fitting together? And right i 6 now I see like a big puzzle and the pieces aren't together 7 to me. I hope everybody's working together on common 8 goals here. I'm not necessari..y 1 saying research should be I

9 the only one. I'm trying to see where the NRC is, I guess 10 is the big picture.

11 MR. COFFMAN: The basic goal is to develop the 12 guidance, which means working on issues, specific issues  !

l 13 that are under regulatory considerations, and they can be l

/, ~T j

\- 14 in different stages -- can be identified early in formal l 15 user needs, or they could be anticipated, which is what we 16 do in research.

17 But regardless of what we anticipate or what 18 we work on, we don't work on anything we'd like to 19 address; it's what we anticipate as becoming a regulatory 20 issue. So that's the one goal.

21 And the other goal is to make the regulatory 22 reviewers -- regulatory review more effective and i

l 23 efficient by developing tools. So those two things, those 24 two overall objectives tie together. But you're right. I l

() mean, when you get into the different issues it's a (ms/ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

106 1 kaleidoscope of specific issues. It's something we've

,3 2 wrestled with and the MITRE report was our first attempt l )

3 to address it.

4 MEMBER MILLER: As I look at the bigger 5 picture, we have -- advanced technology is being developed 6 for other industries like neural networks and expert 7 systems and AI and those type things. I know we had a 8 major effort in your research program to look at V&V of 9 expert systems.

10 And we have on the horizon, DOE EPRI has 11 identified three major technologies they think are going -

, 12 - could make a big impact on current operating plants.

13 And those are ASICs and PLC and dynamic safety systems.

c f~s k- 14 And of course, we have spent hours in this 15 committee discussing the software issues that were 16 identified as part of the standard replan update. and I'm 17 trying to put all these together and is there one plan 18 that's going to try to address all those issues as they 19 evolve. And I see the bits and pieces but I don't see a 20 total integrated approach here.

21 MR. COFFMAN: Currently, we don't have even an 22 updated program plan because of the --

23 (Off record discussion.)

24 We typically prepare program plans which tend

()

rN 25 to tie things together. This year, because of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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107 1 strategic planning effort, we don't have that. But even i

-- 2 that would not be much different from what I've -- has not

\_J 3 been in the past, much different # rom what I've described.

4 And I thought there was another point to be 5 made, but I forget what it is.

6 MEMBER MILLER: Well, the -- of course this 7 year we have a, from the viewpoint of NRC, we've developed 8 a standard review plan, it's out for comment, it codifies 9 what current practice is and what the ALWR program came up 10 with; that's all out there being reviewed. And you 11 already have comments back on the reg guide component all 12 that.

13 That part I see clearly as a targeted effort.

/'~T I -- 14 And I'm looking at the other pieces of the puzzle here.

15 MR. COFFMAN: Yes, well the missing pieces at 16 this point, at least from our planning or kind of group l

17 consideration, dynamic safety systems and ASIC, sometimes 18 we're aware of some of the things that are going on, but l 19 we don't have anything coordinated or any effort underway.

1 I 20 It will be a continual problem, and in fact, l

l 21 we're hoping the NAS .eport will give us some guidance on 22 it because of the rate at which the technology changes.

23 We'll probably continually have technological developments 24 that come up that could generate new issue.

A

(_) 25 MEMBER MILLER: George, a reminder our time is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l

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108 1 coming to an end here. Any other committee members have 2 comments here that could be of value or helpful?

g/

(s 3 VICE CHAIRMAN SEALE: Are there any industry 4 comments?

5 MEMBER MILLER: Okay, I'll turn it back to the 6 chairman.

J 7 CHAIRMAN KRESS: Well, with that, I'm willing 8 to declare a break until 1:45.

9 VICE CHAIRMAN SEALE: One-forty-five?

10 CHAIRMAN KRESS: That's what it says on the 11 agenda. For lunch, 1:45.

12 (Whereupon, at 1:05 p.m., a luncheon recess 13 was taken.)

,r'\

(

  • b' 14  ;

l s

15 16 17 18 1 19 20 21 22 23 24 (y 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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109 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 (1:4 9 p.m. )

V 3 CHAIRMAN KRESS: Okay, we're back in session 4 now. The next item on the agenda is the plant aging 5 research program. And Dr. Powers is our cognizant acting 6 subcommittee chairman on this, so I'll turn it over to 7 Dana.

8 MEMBER POWERS: Thank you. The members will 9 note that this is an area that we have not had a 10 subcommittee meeting on. But we're going to get an 11 explanation of some fraction of the aging research program 12 that's going on at the NRC. It looks to be a fairly 13 detailed overview of what the research programs are.

/~N

\

'--) 14 I'm sure that the members will find the 15 individual research topics of a great deal of interest. I 16 think we also ought to look at why these particular 17 research programs and not others were selected, and that 18 we ought to understand why -- where the research program 19 is headed, what the state of nirvana in the area of aging 20 research is going to look like in the future.

21 With that, I turn it over to Mike Mayfield 22 who's guaranteed to keep us awake.

23 MR. MAYFIELD: I'll talk fast and loud.

24 MEMBER POWERS: It definitely looks like (q) 25 you're going to talk fast.

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110 1 MR. MAYFIELD: We will talk fast. Thank you.

fN 2 Before I got into this, and just as we're l

3 getting on the record, I would like to acknowledge the 4 efforts of the ACRS staff, Theron Brown, in helping us put 5 together this " gee whizzy" approach. If it's successful, 6 it's Theron's accomplishment; if it fails miserably, well, 7 it's Theron's accomplishment.

8 (Laughter.)

9 MEMBER POWERS: That aside.

10 MR. MAYFIELD: We did want to acknowledge his 11 effort in making this thing go together. This 12 presentation is a follow up to Dr. Morrison's briefing of 13 the committee on the overall research program last 7_.

i 1

' 14 September. You may recall from his presentation that i j

15 under the heading of the reactor aging program, we have l

16 three major objectives. '

17 First, to provide the data and analysis tools 18 necessary to identify -- and by that, we're really meaning 19 to anticipate aging effects on major systems, structures, l

20 and components. To quantify the effects of that aging --

21 how would we go about inspecting for it and what i l

22 procedures would be necessary to validate those 23 inspections.

24 How do we go about managing aging, I

\_/ 25 particularly to mitigate its effects; and to establish NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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111 1 appropriate margins for continued operations. What do we 2 need to do in the world of regulations and regulatory 7~.)

i

\~_/ guidance to assure that plants can continue to operate 3

4 safety through their current license period, as well as 5 any license renewal periods.

6 The second anjor objective is in the area of 7 stimulating research both in the national and 8 international community to provide leadership in those 9 research areas and to collaborate on international 10 research projects. As you well know, and as you'll see a j 11 little more as we go, our budget's going down.

12 We're needing to find ways to leverage that 13 budget. International collaboration is plainly one way to ex

, ( )

kd' 14 make that happen.

15 The third major objective is to maintain the 16 essential competence that the staff will need in the l 17 future to -- by maintaining a highly qualified technical 18 staff and a few analytical and experimental contractors to 1

19 support the staff.

20 Our aging research program addresses these ten 21 areas. This is looking a little different than it's 22 supposed to, so I'm hoping this is not going to fall apart 1

23 on me, but the subject matter is correct. We have these 24 ten major areas, and we'll touch on these as we go through

(_j}

/

25 the presentation this afternoon.

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112 '

1 MEMBER POWERS: I notice in your ten major 2 areas I don't see something labeled containment.

7_3

( ) You don't see something labeled 3 MR. MAYFIELD:

4 containment explicitly. It's part of this activity.

5 MEMBER POWERS: Structure and components.

6 MR. MAYFIELD: Structures and components. And 7 we will talk about that a little bit as we go this 8 afternoon. Dr. Murphy is here with me, and he's the 9 branch chief for that activity.

10 In terms of the budget, Dr. Morrison's 11 presentation he showed you, I believe, over the last 25 or 12 so years the trends in the Research Office budget. I've 13 broken out the aging program budget since 1990. Well, the I

(-) 14 office budget has gone through some rather significant 15 swings over time.

16 At least over the last seven years, the aging 17 budget has sort of tracked the trend in the office budget, 18 but with much smaller proportional swings. This is i

19 something that we've been quite pleased with, the support  !

I 20 that we've gotten both from the office, as well as from 21 the agency management.

22 The budget for the ten areas -- two of the l

23 areas do not have explicit budget support in 1997. A 24 third area, the piping integrity, is an area that we're (M

() 25 closing down, and I'll talk more about that as we go.

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1 113 I

1 These are the fiscal '97 budgets. Presoure vessel

, 2 integrity is plainly the big actor in our program.

3 Environmentally assisted cracking, 4 nondestructive evaluation -- steam generator tube 5 integrity is another significant contributor. Degradation 6 of mechanical components and environmental qualification 7 -- if you happen to have our budget details -- I'm sure 1

8 the committee can gain access to them if you don't --

9 you'll see that in the budget details, these two come 10 under the same budget subactivity.

11 But for this presentation, we've broken them 12 out. l 13 CHAIRMAN KRESS: Where do cable -- electrical

[h #

\/ 14 cables -- l 1

15 MR. MAYFIELD: That's in the environmental 16 qualifications, and we'll talk a little more about that as 17 well.

18 I mentioned the leverage through the 19 international community. One of the guys suggested this 20 was a geography lesson, and that's not what it's intended 21 to be. Rather, it is a convenient way to illustrate that 22 we leverage our budget a couple of different ways in the 23 international community.

I l

24 One is through cooperative programs. And by p) j (_, 25 cooperative, I'm implying that there is an exchange of t

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1 114 l l

I i

1 funds in the program. In an international piping )

1

,g 2 3 tegrity research group program, we have Canada, a number i l

! i '

%/

3 of the European countries, as well as Japan, Taiwan, and j 4 South Korea.

5 There are similarly jointly funded programs in 6 the seismic area and earths sciences area that involve 7 Japan, Taiwan, France, and the U.S.

8 In terms of collaborative programs -- and by 9 collaborative, I mean we -- the good old boys and girls 10 get together; we talk about what work needs to be done; 11 who is best equipped to do that work; and move forward 12 meeting oh, on anywhere from nine to 18 month intervals.

13 There's a variety of these programs. Some are bilateral, i

k 14 some are multilateral.

15 We include in this activity the CSNI 16 activities as well as some of the IAEA activities.

37 Through those two international -- two types of  ;

18 international activities, we are able to significantly l 19 leverage our research budget.

20 So even though it's declining, we're not 21 incurring as big a decrease as we might otherwise see.

22 We're hoping to also build on that in the future.

23 As our budget has declined, we have had to 24 focus the research in a few key DOE laboratories and

(~%

( ,

) 25 universities and some commercial contractors. We have l

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115 1 been working to not fall into the trap of doing everything f

- s. 2 with the DOE labs. I suspect the DOE labs would like it

( i q ,1 3 better if we did; but the fact is, we feel like we get a 4 different perspective from the three types of contractors.

5 And we think that's important to make sure 6 that stays in the program.

7 The research efforts that we undertake -- you 8 were asking how did we get to some of these things -- come 9 from user needs, as well as some office initiatives. Most 10 of the aging research program is supported by user need.

11 This is the information that Dr. Morrison showed you. For 12 the major hardware related activities, we have 100% user 13 office support for our programs.

(' 14 There's some 80% support for the containment 15 program. There is no explicit support for the aging 16 effects on the balance of plant components or the buried 17 components. These are things we have proposed to the 18 office, and we -- once we can gain some financial support 19 for them, they will be undertaken as exploratory 20 activities.

21 If it looks like there's something there to be 22 pursued, we would go back to the user office with those 23 results and try and gain their support. Failing that, we 24 could always propose it to the office as an RES

,a

(_) 25 initiative.

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116 1 Projects are closed as warranted. Researchers 2 are sort of notorious for making careers out of

,f s

( '

/

3 activities. And I suspect that our program is not the 4 exception. However, we have been paying attention to 5 this, particularly as the budget declines.

6 We close programs based on technical judgement 7 primarily. We do use expert outside consultants to help 8 provide us some insight to give us an independent l 9 assessment when has the value of additional research 10 reached the point of diminishing return. Similarly, when 11 has the question being addressed been adequately answered.

12 We'll talk about the piping fracture work 13 being closed, and that's actually coming down as a

! t

'- 14 consequence of both of these. The key questions have been

! 15 adequately answered. There's always something else you 16 could do. However, the cost of doing those uer things l

17 has simply reached the point that it's not justified.

18 Some key examples of the kinds of programs 19 that we've closed in the last few years: the NPAR l

I l 20 program, which stood for the Nuclear Plant Aging Research 21 Program. It was a multi-year, multi-million dollar 22 activity, but it had reached the point where it had 23 answered the key questions.

24 That's certainly not to say they had all been f%

( ,) 25 answered. But it had answered the key ones. And we felt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 2344433 WASHINGTON D C. 20005-3701 (202) 234 4433

1 117 1 like again the cost of doing more and finishing off those

~_ 2 remaining issues exceeded the value.

('~' /

3 Pipe fracture research program -- the aging of 4 cast stainless steel was an activity that looked like it f 5 was a very big deal early on as we did the research. We 6 decided that well, while it was important, we had probably 7 reached the point where we had answered the major  ;

l 8 question.

9 The aging research program we believe to be a 1

10 vital part of the NRC's overall regulatory program. We j e

11 believe we're providing the technical bases for many of l l

i 12 the current day regulatory decisions. We work at -- go to )

13 some lengths, in fact, to stay involved with the user g s.

k- s 14 office to make sure we're on top of what's going on in the 15 regulatory world, and to try and make sure that our 16 research is addressing those issues.

17 We also are providing longer term confirmation 18 of broader policies and regulations. We have exploratory 19 elements in our program, and we'll talk a little bit about 20 some of those as we go this afternoon. We do use 21 exploratery research when we need to better evaluate the 22 safety significance of an issue that's been put on the 23 table or to increase our understanding of areas where 24 maybe there's something there and we just need to poke at

(~s

(,-)

> 25 it a bit more.

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118 l

1 This presentation this afternoon will address 1

0

[7s 2 the issues that are in white. Since we don't have any

' (' ') 3 budget for these other two activities and I knew I was j 4 going to be time constrained, I didn't include them in the l

5 package.

6 MEMBER POWERS: Those are your exploratory 7 components?

8 MR. MAYFIELD: They are two of the exploratory 9 components -- two major activities that -- we think 10 there's something there, but it's more intuitive than 11 based on hard information. We had put forward a proposal 12 to the office to support this to some limited degree. Dr.

13 Morrison is looking at it, and depending on where the (D

\~) 14 budget goes, at least the buried components is a 15 possibility.

16 The balance of plant is something that will 17 probably have to go to '98 or beyond. But that's -- those j 1 18 are two that we don't have user office support for. I'd 19 like to try and draw a distinction between having user l

20 office support versus it being exploratory, because we do 21 have user office support for some of our exploratory 22 research, mechanisms of neutron embrittlement being a case 23 in point.

l l 24 That's very much exploratory in its nature, l

\ (3 l

(_) 25 but we have good user office support for that activity. ]

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1

[ 119 l

1 MEMBER FONTANA: It seems that unless the 1 l

li \

,_s

\

'~'/

2 argument is made that buried components are not 3 significant, it seems to me like it's pretty important to l

4 know what's going on.

l 5 MR. MAYFIELD: The issue is whether or not 6 there's something there that the research program needs to I l

1 7 address. There's no argument that they are important.

8 They've become a significant issue in license renewal as 9 plants have done some of their evaluations for license 1

10 renewal. l l

1 11 The question is whether there's some piece of 12 that that the research program needs to address. And it's 13 that part that we need to poke at. Or at least we feel

(-

(~)h 14 like we need to poke at a bit.

15 MEMBER SHACK: This would be beyond MIC or 16 something like that?

17 MR. MAYFIELD: Yes, sir; yes.

18 Regulatory -- I'd like to turn now to some of 19 the specific research areas -- research issues. Reactor 20 pressure vessel integrity program, regulatory issues, 21 pressurized thermal shock -- this is something that in 22 fact we've been to brief this committee a number of times.

23 It is certainly an area that periodically raises its head 24 and creates all manner of mischief.

r~

(T) 25 In our regulations, we have screening criteria NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W, (202) 234-4433 WASHINGTON, D C- 20005-3701 (202) 234-4433

120 1 that effectively limit the level of embrittlement of

,_ 2 reactor pressure vessels. If it looks like you're going

('-') 3 to go over that level of embrittlement, this regulatory 4 guide, 1.154, ostensibly provides guidance on how you go 5 about doing an analysis to determine if it's safe for you 6 to continue to operate the plant.

l 7 As we saw with Yankee Rowe, pressurized 8 thermal shock can certainly be the kind of issue that i

9 becomes life limiting for nuclear power plants. One of l

10 the other things we saw from Yankee is that this '

11 regulatory guide is nearly useless. It was a nice piece l

12 of work when it was done; however, it turned out to not be l 13 very practical to use the document. I p\

p

(_/ 14 So, we have activities under way to look at 15 the regulatory guide. At the same time, some of the 16 activities that have come out of the NRR assessments of 17 some of the operating plants raise issues that cause us to 18 question the level of conservatism that are in the generic 19 screening criteria in the rule.

20 So our activity is two-fold to look at the 21 screening criteria as, at the same time, we're looking at 22 what needs to be done to this regulatory guide. So it L 23 turns out that as we got into the guide, coupling with 24 some of the work that NRR's been doing, we're now starting r

()h 25 to ask questions about the screening criteria.

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121 l

1 PTS has always been one of those issues that s 2 as soon as you take the top off the can, the worms start I \

\~'/ 3 to climb out; and then it's a bit cumbersome to kind of 4 bring it all back together in a way that satisfies all of 5 the technical concerns.

6 I'd like to talk -- jump down to the charpy 7 upper shelf energy just to deal with the issue fairly 8 quickly. We briefed the committee and put forward a 9 regulatory guide on what are called equivalent margins 10 analyses. It turns out the regulations say if you're 11 going to drop below a 50 foot pound upper shelf energy, 12 you have to do an analysis to demonstrate margins of 13 safety equivalent to those in Section III of the ASME

,j '%.\

N / 14 code, Appendix G.

15 There's a lot of Appendix G's we'll talk 16 about: Appendix G to 10 CFR 50, Appendix G to Section 17 III of the ASME code, and Appendix G to Section XI of the 18 ASME code. It gets a little bit confusing. I'll try and 19 draw the distinction.

20 Appendix G to 10 CFR 50 has the 50 foot pound 21 upper shelf energy requirement. That regulation says if 22 you're going to drop below 50 foot pounds charpy upper 23 shelf energy, you have to do an equivalent -- an analysis 24 to demonstrate margins equivalent to those in Appendix G

(~%.

(_ ,/ 25 to Section III and also Section XI of the ASME code.

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122 1 We have a regulatory guide that we put in l

l f3 2 place a year and a half or so ago that tells you how to do

,\ )

' v 3 this equivalent margins analysis. The question becomes l

4 how far can you go. How low in charpy upper shelf energy 5 can you go and that analysis still be credible?

6 This is not a high priority issue for the 7 staff, but it is something that we've identified as an 8 area that needs to be probed a bit as we go.

9 Pressure temperature limits and low 10 temperature over pressure protection -- these are two 11 issues that, while they are separate issues that the 12 staff's dealing with, they come from the same basic 13 technical problem. What we're showing here is pressure in)

Y-- 14 versus temperature and at least a view of the pressure 15 temperature limit issue.

16 As plants operate, there are -- it becomes an 17 operating window that you have to live within. It's 18 bounded by the saturation pressure for the coolant. You 19 need some margin -- some sublevel of subcooling to avoid 20 cavitation on the pump. You also have to have some delta 21 P across pump seals.

22 There has to be some margin added to that to 23 account for factors such as gauge error. This is the t 24 pressure temperature limit that is determined from the

[ a

(_) 25 Appendix G to Section III, or also Section XI. Those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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l l 123 I

l 1 things turn out to be identical. But this is an

, 2 administrative limit imposed through the regulations.

3 What we've fcund is that plants were tending 4 to violate, particularly at low temperatures -- sort of an 5 old issue -- plants were tending to violate this 6 administrative limit. So we imposed requirements to have 7 a low temperature over pressure protection system. Those 8 set points for that system derive from system 9 considerations and from this sc called Appendix G curve.

10 So you have the set points. But then you 11 effectively have to reduce those for the margin against 12 lifting the valve and for gauge error. So the operator 13 has on start up a fairly narrow window through which he

\> 14 must navigate. These margins give you the lower pressure.

15 The enable temperature which comes out of the analysis is 16 tied to a level of embrittlement.

17 When you're above this temperature, you can go 18 to full system pressure. Below this temperature, you have 19 to have pressure relief protection. For plants that use 20 fixed set point relief valves for their LTOP system, they 21 get this right angle that they have to navigate through.

22 Some of the plants have PORV's that are 23 programmable so they can stair step up along the Appendix 24 G curves. Less of an issue for them than for many of the O)

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l 124 l

1 levels of embrittlement, this comes down and this shifts l l

2 over.

(~s; l I

%J 3 You can reach a point where you begin to 4 significantly impact the heat up temperatures or heat up 5 rates that the plants can follow. You're finding some of 6 the plants that are making changes in system line up -- 1 7 racking out and locking out some of the safety injection 8 pumps so that they can -- it's not possible to have some 9 of the mass addition events that can get them into a 10 situation where they're lifting the LTOP valves.

11 So the questions that we're dealing with in 12 terms of the P-T limits and the Appendix G issues have to 13 do with the embrittlement estimates, the level of r'N i )

(_/ 14 conservatism in the Appendix G analyses, as well as some l

15 of the flaw size issues that we'll come to in a moment. ,

i 16 Flaw size assumptions are another key issue 17 that we're having to come to grips with. I mentioned the 18 flaw size assumed in the P-T limits. Currently the 19 licensees have to assume a 1/4 thickness flaw with a 20 particular length tied to that thickness in doing these 21 analyses. l l

22 The question is whether or not a reduced size l l

23 can be justified. The 1/4 T was a committee size flaw. A l 24 group of people got together and they concluded that a 1/4 l (_)

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125 1 of their interest, whether it was demonstrating leak i

2 before break in the vessel, or this larger -- you know, Ih

\ ',)

3 such a large size that ISI couldn't possibly have missed 4 it.

5 For whatever reason, this was the size i 6 selected. The question is, can it be credibly reduced?

7 If it's going to be reduced, what kind of inspection do we 8 need to do? How rigorous must it be? What probability of 9 detection and with what reliability would we have to 10 inspect the vessel to justify a change in this, referenced 11 flaw size?

12 One of the other questions that comes up --

13 right now, the licensees are required to postulate axial

/"'i k> 14 flaws. The question is, for the vessels that are limited 15 by circumferential welds, why shouldn't they postulate a 16 circumferential flaw? Do we really need the added level 17 of conservatism imposed by this axial flaw constraint?

18 Where can ISI results be used in the 19 regulatory analysis is another issue that keeps coming up.

20 In particular for pressurized thermal shock, there is a 21 flaw distribution assumed in the analyses, and the 22 question is whether or not you can use ISI results to 23 justify a change in that flaw distribution.

24 If so, how -- again, how good does the l rh I

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126 1 detection you need, and with what reliability.

7- 2 Thermal annealing is an issue that we N~S] 3 promulgated a regulation early this year -- a regulation i

4 and a regulatory guide identified here. Thermal annealing 5 is the only known method for mitigating the effects of 6 neutron embrittlement. ASME has promulgated a code case l 7 that fills in some of the blanks -- some of the issues  ;

8 raised by the regulatory guide.

9 DOE has performed an engineering demonstration .

I 10 to show that thermal annealing can be successfully 11 performed on U.S. designs. However, there are still some 12 open issues. In particular, the degree of recovery you l 13 get by performing a thermal annealing. Are the models t

( \ 1 l

i

\/ 14 that we have in our regulatory guide sufficiently 15 conservative; or more correctly, sufficiently accurate to 16 justify thermal annealing?

17 And then the reembrittlement rate one gets 18 upon -- after thermal annealing and upon further 19 operation.

20 So those are the issues that we have to deal 21 with in -- under the heading of thermal annealing. They 22 really tie back to the neutron irradiation effects issue.

23 Our technical program --

24 MEMBER POWERS: Is the --

(O

, s,/ 25 MR. MAYFIELD: Sir?

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l 127 1 MEMBER POWERS: Is the Department of Energy's l <x 2 annealing demonstration concluded now?

/

3 MR. MAYFIELD: They completed the annealing --

4 it's actually an easy question, but the answer is going to 5 be a little cumbersome. They completed the thermal l

6 annealing at the Marble Hill plant. There are some 7 financial difficulties and some delays in completing the 8 final report.

9 The independent assessment that the staff did, 10 we are satisfied that the -- that annealings can be l

l 11 performed successfully without damaging other portions of  ;

i 12 the plant. We also identified some areas that we think 13 warrant some further evaluation, and particularly by a i

[,_h

\- 14 licensee that would propose to do a thermal annealing.

l 15 So there's some things that we now know to go '

16 focus on at an individual plant. But there's been enough 17 work done and enough progress made on the DOE program that 18 we're satisfied that the demonstration was successful.

19 Okay?

I 20 Technical program addressing the reactor 21 vessel integrity -- three technical issues, it turns out, ,

1 22 all of those regulatory issues, hinge on the same three 23 technical issues: fracture mechanics analysis method, 1

l 24 embrittlement estimates, and inspection capabilities. Our l

f~)

\_s/ 25 program does address all three of those activities.

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l 128 1 I'll try and step through those. Fracture I

g- 2 analysis work -- objectives to evaluate and develop as j t

\

3 warranted advanced methods for predicting the integrity of 4 the reactor pressure vessels during normal and accident 5 conditions; to experimentally validate those analysis ,

6 methods; and to provide appropriate baseline material )

7 property data.

l 8 We have activities under way trying to l

9 validate and improve analysis methods that are already on l l

10 the books and being used in the ASME code and some of our l 1

1 11 regulatory analyses. We also have under way some l

12 developmental work looking at how you make use of advance l 13 fracture mechanics to take account of, for example, j kl 14 smaller flaw sizes.

15 As you go to smaller and smaller flaw sizes, j i

l 16 you can't use linear elastic fracture mechanics )

17 methodology the way we do when we fuss with 1/4 T flaws.

I 18 As you get nearer and nearer the surface, other factors l l

19 come into play such as the loss of crack tip constraint. I l

)

20 So the activity under analysis method development looks at 21 these advanced fracture analysis tools.

22 We have activities under way looking at l 23 developing material property data. And more particularly, l

24 looking at new specimen types, specimen sizes, how you

,3

(,) 25 correlate data developed using those specimen types and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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129 1 sizes to the existing data base of material property data 2 for a vessel.

(y) 3 One of the things you're going to hear fairly 4 often during this presentation is on validation. We've 5 reached the point in our activities where we think it's 6 increasingly important to test the analysis methods, test 7 the material property evaluation methods against realistic 8 bench marks.

9 We have in the past, at Oak Ridge and 10 elsewhere, performed large scale validation experiments in 11 the pressure vessel program. As our budget has declined, 12 we have moved to work with the international community in 13 looking at validation experiments performed around the v' 14 world.

15 Current emphasis -- as I mentioned, evaluating 16 the improved fracture analyses, developing through 17 collaboration with national and international researchers 18 some of the advanced analysis methods. A lot of nice work 19 done around the world in these areas. Work that we're 20 able to build on and that works very nicely with some of 21 the developmental work done in this country.

22 Experimentally and analytically evaluating 23 crack tip constraint effects, looking now at shallow 1

24 cracks. As you go to shallow cracks, effects of cladding,

(~m

(_) 25 bi-axial loading effects. So making the analyses more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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130 1 rigorous is a necessary consequence of considering more 73 2 realistic flaw sizes.

6

'% '/

3 You can't use the same old brute force 4 fracture mechanics that you used in the days when you had 5 these huge flaw sizes you were considering. Validation of 6 the analysis methods through comparison to bench mark 7 experiments -- there is a nice program that's been going 8 on through the CSNI called the FALSIRE program. Fracture 9 assessment of large scale international reference is what i 10 FALSIRE stands for.

11 There is a new program -- new: it's been i l

12 under way a couple of years now out of the European 13 community, the network for evaluating steel components.

,rh k-) 14 They're using a spinning cylinder facility that's in the 15 U.K. Once they finally get around to running this 16 experiment, it should prove fairly interesting.

17 We have been very heavily involved in that 18 NESC program.

19 MEMBER POWERS: Especially --

20 MR. MAYFIELD: Sir?

21 MEMBER POWERS: -- with regard to material l 22 property data, but all of the program elements that you l l

23 have there, it looks to me like you're pushing the state l 24 of the art in this area.

/'s

(_) 25 MR. MAYFIELD: Yes.

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l 131 l

l 1 MEMBER POWERS: And I was wondering why you gS 2 want to push the state of the art here?

I )

\_/ ,

l 3 MR. MAYFIELD: For two reasons. The one is 4 that we believe that that's generally the direction the 5 industry is going to head. And so we -- it's not so much 6 that we intend to develop the tools, as we believe we need 7 to have an independent assessment of those tools so that 8 as they're brought to the regulatory table, we've got a 9 way of saying yes, no; well, maybe if you do something 10 different.

11 That's the primary reason. The secondary 12 reason -- the Commission has told us in a number of areas, 13 pressurized thermal shock being a case in point, to use

- 14 best estimate analyses. And it gets a little cumbersome 15 what that means. In this sense, it means use the best 16 technology you can get your hands on. So don't use brute j 17 force conservative analyses when you're trying to do some 18 of these more rigorous analyses.

19 Pressurized thermal shock is a case in point.

20 You're using technology that's only appropriate for deep 21 flaws when you're trying to analyze some of these more 22 shallow flaws. We know that's conservative. In some 1

23 cases, it's grossly conservative. So there's that piece l

24 of it.

(_j 25 So we're pushing -- we agree, we are pushing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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132 l

1 back the state of the art as part of a collaborative l p 2 program. We couldn't possibly afford to do this on our  ;

V l 3 own.

4 Okay?

5 MEMBER POWERS: You expect the industry to 6 start bringing things like this before you and you have to ,

1 7 look at them.

8 MR. MAYFIELD: Where industry's probably 9 pushing the most is through some of the code committees l

10 and starting to look at some of those areas, j l

11 Additional areas of emphasis in the vessel:

12 the fracture analysis, characterization of variability and

,, 13 chemical composition, and the initial properties. This is

/' ]\ 14 something that came out of some of the work we were doing 15 on the Midland vessel, as well as some of the activities 16 that NRR's had undergoing -- had ongoing looking at 17 pressure vessels and variability in properties.

18 Evaluation of thermal embrittlement for 19 typical U.S. reactor pressure vessel welds -- and it's not 20 really the welds; it's the material adjacent to the welds.

21 This is something that traditionally we haven't believed 22 was a significant issue for U.S. plants. It's a big issue 23 for some of the Russian -- particularly the VVER 1000's.

24 It's somewhat of an issue for the -- some of the European C 25 plants or vessels and steels.

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133 l 1 However, when we start looking at thermal l

73 2 annealing in the temperatures for a week or some, issues j N ,)

l 3 have been raised about whether or not we are going to see r

4 a significant degree of thermal embrittlement. Just 5 enough data out there that suggests this could be an 1

I 6 issue. We have been fooling with it now for some years at 7 a lower priority level just more out of academic interest 8 than is a big deal.

9 Some of the recent work that we've seen out of l 10 the U.K., the questions have been put on the table, have 11 caused us to put a little more emphasis on this. We still 12 don't think it's an issue, but we agree it's something 13 that needs to be looked at more rigorously and more I

w

)

k/ 14 quickly than we had originally planned.

15 Development and evaluation of subsize test 16 specimens particularly for evaluating embrittlement --

17 this is an activity that there's a lot of interest in )

i 18 using subsize charpy specimens or pre-cracked charpy 19 specimens as a way of determining the fracture toughness 20 of the material in a rigorous fashion.

21 And there's a lot of question about whether i 22 that's legitimate, what limits need to be placed on those l

23 specimens or the test methods. And we've had an activity l

24 ongoing for some time looking at this -- again, as almost

, r~

j I

( 25 an exploratory nature. We've reached the point now where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

i 134 l 1 we're putting more emphasis on this and looking at how it 7- 2 can be reduced practice.

\

3 MEMBER FONTANA: Haven't you looked at 4 different size charpy specimens over the years quite a 5 bit?

6 MR. MAYFIELD: Yes, yes. And now what we're 7 looking at is what does that really mean to pre-crack the 8 charpys. I think the work over the years has looked at

)

9 just using subsize charpy specimens without pre-cracking. I 10 So now the question is okay, can we use subsized charpy l 11 specimens; how do we relate that to the fracture 12 toughness, particularly if those specimens have been pre-13 cracked?

i N/ 14 And the constraint issues come into that 15 question as well.  ;

1 i

16 MEMBER SHACK: Are you doing any evaluation of 17 the really small specimens that EPRI was playing with?

18 MR. MAYFIELD: What do you mean by really 19 small?

20 MEMBER SHACK: They had those micro-mechanical 21 --

22 MR. MAYFIELD: We have looked at and continue 23 to look at some of the indentation schemes and how that 24 can be related to fracture toughness, can it be done as i e-( 25 rigorously as is advertised by the promoters. So we look NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i 135 1 at that. We've bought some of them.

7- 2 But you're talking about the shear punch

(-)

3 scheme that EPRI has come up with? That one we didn't see l l

4 a lot of potential for. We've looked at some of the --

5 MEMBER SHACK: Okay, so you have been.

i 6 MR. MAYFIELD: So we have been looking at 7 those things. The Chairman sent us on an initiative, 8 what, last year, or I guess this year -- she raised the 9 question of why do you have to break specimens. Is there 10 not a nondestructive way that can be used to infer 11 embrittlement. That's a good question.

12 It has been something that people have been 13 fooling with for a long time particularly in the area of

\ <

r~N\

, \m / 14 fatigue. However, with the emphasis the Chairman gave  ;

1 15 this activity, a lot of the national and international ,

l l

16 community got a lot more excited and a lot more i

! 17 interested. l l

1 18 The Chairman's initiative to look at 19 nondestructive evaluation techniques for material l 20 properties -- we have a small activity under way this year I

21 to invite into the international people that have been 22 working in this area to come. I think we've now selected 23 the contractor. Is that right, Carolyn?

24 So I can say it's now the University of t'y (wJ $

25 Michigan that will be hosting this activity. We have sent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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1 136 l

1 some of our irradiated samples from Oak Ridge to the r3 2 university, or will be sending them soon. Various t

(N )

'~

3 organizations around the world that have been working on 4 this are being invited to come to the university and bring 5 their hardware and make their measurements.

6 And when they're all done, we'll put together 7 some sort of international conference to let people put 8 their results on the table and compare them to the 9 fracture toughness that we have determined from past 10 research.

11 It should prove interesting as a way to foster 12 some further activity in this area. But that was really 13 the work that the Chairman had in mind when she challenged i.

'- 14 the technical community to look at nondestructive 15 techniques. i l

16 One of the other things that came along with 17 that was interest in the sheer punch scheme and the 18 indenter scheme. We've been -- again, we've looked at 19 both of those, and we don't believe that they offer a lot 20 of promise in a practical application. And that really 21 had brought me to this -- no, I'm sorry.

22 This last one is looking at a thing called the 23 master curve. This is a scheme for estimating fracture 24 toughness based on results from some small size samples.

(,,

O) 25 Pre-cracked charpys is one way to index this master curve.

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~

137 1 A lot of interest in this as an alternative to 2 the approach that's currently embodied in the regulations

!o  ;

'd 3 and embodied in the ASME code where you use a linear 4 elastic fracture mechanics, K1 arc, or a reference 5 fracture toughness curve; and then you index that using a 6 parameter called RTNDT which is derived from charpy 7 samples.

8 The embrittlement research -- again, key 9 objectives: provide information and analysis methods for 10 high confidence estimates of pressure vessel 11 embrittlement. This continues to be a problem. We can 12 always conservatively estimate embrittlement. We're 13 pretty confident of that.

, a 14 How conservative are they? We would like to 15 improve our confidence in those embrittlement estimates.

16 We would like to improve the current methods and explore 17 new methods for estimating embrittlement. This is really 18 the Chairman's initiative. And to provide data and 19 analysis methods for thermal annealing.

20 Key activities under this area are the 21 annealing studies, test reactor irradiation program --

22 this has been a big activity for us for a number of years.

23 The level of effort in the test reactor or radiation 24 program is going down in the future. We have an activity V 25 under way and have had for some time looking at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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138 1 embrittlement mechanisms. j 2 To estimate embrittlement, you obviously need 7-V 3 to understand the neutron environment, so we have had a 4 fairly large program in the past looking at neutron 5 do.,ime t ry . That program is still at a modest level. We 6 will probably always have some program, albeit at a small 7 level, looking at neutron dosimetry just to keep our hand 8 in.

9 Embrittlement correlations -- this is an l

10 activity -- Regulatory Guide 1.99 is the basic regulatory )

i 11 device we have for predicting level of embrittlement. As j 12 we started to evaluate -- and that -- I should say that 13 regulatory guide is based on the reactor surveillance data

,.m

\/ )

I 14 test specimens that come from the test -- from the l 15 reactors.

16 We're looking at evaluating that data. But 17 this time, we are using some pattern recognition 18 statistical tools, and we've brought the mechanisms people 19 in. So we have the physical metallurgist sitting with the 20 statisticians looking at the data. And it's been an 21 interesting interplay.

22 The statistician says ah, well, here's an 23 effect; and the physical metallurgist says that's utter 24 nonsense, it can't possibly be. Conversely, the physical (O

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i i

139 1 effect; and the statistician says uh-huh, it's not there,

! -s 2 sorry.

l (ms/ 3 So again, it's been an interesting interplay 4 letting them work with one another bringing this together.

l 5 And we feel like we're ending up with a better product in 6 the long run. This is something that in the next year or 7 so I suspect we'll be getting on the committee's agenda to 8 come brief you on on what's coming out of that activity.

9 Validation is a key part of this. I mentioned 10 that the test reactor irradiation work -- the budget for 11 that is going down. We're starting to increase the level 12 of work we're doing under the heading of validation. By 13 validation here, what we're talking about are getting (N

_- 14 samples from decommissioned reactor pressure vessels and 15 doing detailed assessments of those samples.

16 We currently have some samples from the Japan 17 Power Demonstration Reactor which was an old BWR that the 18 JAERI folks had at the Tokyo facility. When they cut that 1

19 vessel apart, we were able to, as a collaborative program l 20 with the Japanese, gain access to some samples. So we --

21 the Japanese are doing part of this. We're doing part of 22 it.

23 It should provide some interesting results.

24 The problem is that vessel didn't have a lot of fluence on

/~S 25 it, so there's not a lot of embrittlement. But there's

(_)

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l t

i 140 1 some there, and we'll get a look at some effects.

l l 2 We're talking with the Trojan people. Looks v 3 like there's at least a realistic expectation we can get 4 samples out of the Trojan vessel once it's been 5 transported to its burial site. So it probably isn't 6 practical to get on the critical path while they're trying i

7 to get the vessel out of the plant.

8 Will be an opportunity to get samples out of  !

l l

9 the vessel once it's been put in the ditch.

10 MEMBER POWERS: Seems to me that ten years ago 11 or maybe less there was within the Department of Energy an 12 interest in not just the fluence -- embrittlement as a 13 function of fluence, but there was a suspicion that there (V 14 was an effect of the flux as well. Has that been 15 resolved?

16 MR. MAYFIELD: Well, I suspect it depends on 17 who you talk to to some degree. I think there are still 18 great proponents of a flux effecc. For power reactors, in 19 the ranges we're talking about, there is not a great flux 20 effect. For some of the test reactor data that were at 21 very high fluxes, yes; there's a flux effect.

22 There's no question there's a flux effect.

23 It's just over what range can you ignore it. So for 24 typical power reactor applications when you're out at the y/ 25 vessel wall, it's not a big deal. Some of the test i

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141 1 reactor data are suspect becauce they were at such high gs 2 fluxes.

t v) 3 Some of the surveillance data may similarly be 4 suspect because they were at very high fluxes. And it's 5 that transition that's still -- you know, where does it i

6 cut off? How high in flux can you go before you have to 7 start worrying about it?

8 VICE CHAIRMAN SEALE: When you say transition, 9 how about internals?

10 MR. MAYFIELD: Well, the internals fortunately 1

11 aren't the same steel. So you're talking about -- 1 12 VICE CHAIRMAN SEALE: Okay.

l 13 MR. MAYFIELD: -- the stainless steel. so it's r

(3 i V 14 a different thing there. But yeah, I would -- frankly, 15 you're at high enough fluxes there. I would suspect you 16 have to take a look at it. We're just starting to --

17 VICE CHAIRMAN SEALE: Okay.

18 MR. MAYFIELD: -- scratch that surface.

19 VICE CHAIRMAN SEALE: So you're sensitive to 20 the possibility --

21 MR. MAYFIELD: Oh , absolutely.

22 VICE CHAIRMAN SEALE: -- of a flux effect in 23 the stainless internals?

24 MR. MAYFIELD: Absolutely. Not quite sure

/~} 25 where it's going to go, but it's something that has to be

, /

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142 1 looked at.

,g 2 MEMBER SHACK: Just on this same topic, have

(,)

3 you looked at all at the advanced reactors to see if there 4 are enough spectrum changes that, you know, you would get 5 some effect? You guys do seem to be still living with 6 fluence rather than any other --

7 MR. MAYFIELD: We are still living with 8 fluence rather than going to DPA. Yes, I was wondering 9 who would raise that issue; but thank you.

10 Yes, we are still looking -- our correlations 11 are still based on fluence rather than DPA or any ther 12 parameter. For the applications that we deal with, 13 fluence for E greater than 1 MEV is still like credible

,q

(~~'I 14 correlating parameter. Plainly, as you go to other 15 applications, you need a different correlating parameter.

16 Whether that's DPA, E greater than a half MEV 17 -- who knows what it might be. Plainly, as you move to 18 other applications, you have to be sensitive to that.

19 Plainly, as the spectrum changes significantly, you'd have 20 to be sensitive to it.

21 I don't -- for our program, we have not looked 22 at changes in spectrum for advanced reactors to see if all 23 still holds together. That's just not something we've 24 gotten into. We sort of have our hands full with what we O

25 have --

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143 1 MEMBER SHACK: It's not an immediate problem.

, 2 MR. MAYFIELD: It's not an immediate problem.

]

(_ / 3 But it's something that shouldn't be ignored. And we are I

4 aware of the issue. Just haven't had to come to grips 5 with it yet.

6 MEMBER FONTANA: What are some example l 7 concepts for estimating embrittlement nondestructively?

I 8 Just some examples.

9 MR. MAYFIELD: Ultrasonic attenuation; 10 positron annihilation is one that's been put forward that 11 we don't think holds a lot of promise. Michael, jump in 12 and help me here. Magnetic parameter. And that's one, in 13 fact, that we will probably have some smallish activity at

\~/ 14 a university looking at the magnetics.

15 Does that answer your question?

16 MEMBER FONTANA: Yes, yes, sure.

17 MR. MAYFIELD: Current areas of emphasis in 18 the embrittlement research -- test reactor irradiations.  ;

i 19 As I mentioned, that program is beginning to wind down. l l

20 We're currently looking primarily at the Linde 80 welds 1 21 that we got out of the Midland reactor pressure vessel.

22 And we're starting to look at some of the welds that we 23 got from the Shoreham vessel.

24 Test reactor irradiations to evaluation plate O 25 embrittlement. Turns out that the plate materials are not

( j/ ,

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144 1 something that's been looked at in any significant degree l

7-2 in our program; or by anybody else, for that matter. So 3 while we think we're on firm ground based on correlations 4 with surveillance data, we felt like it was an area that 5 needed a bit more of a look.

6 Test reactor irradiations to evaluate thermal 7 annealing and reembrittlement trends -- particularly for 8 reembrittlement, that's the only practical way to get at 9 it. Otherwise, you start having on line experiments, 10 which we think probably doesn't make a lot of sense. So 11 we do continue to look at reembrittlement trends.

12 And this also is an area that we have been 13 working with the Russians on a collaborative activity K/ 14 looking at reembrittlement where we've been doing test 15 reactor irradiations. They've been doing some 16 irradiations in the Nova Ronish Unit 5.

17 MEMBER SHACK: Just sort of -- you brought it 18 up again. How well do you know, for example, the 19 phosphorous levels in the vessels that are out there?

20 MR. MAYFIELD: It's one of the elements that 21 comes out of the --

22 MEMBER SHACK: I mean that's all tracked and 23 that's in the data base that NRR or you or somebody 24 maintains.

O (j

25 MR. MAYFIELD: I mean, it's known as well as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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145 1 any of these things. The variability in it's not well j-- 2 documented. You're talking about MIL search, so you get a 3 number. It is -- but when we have done chemical 4 composition variability studies, it's one of the elements 5 that we have analyzed.

6 So we do have data on that variability.

7 MEMBER SHACK: Even in the upper ranges that 8 you still feel reasonably confident that's well enough 9 that that's not a problem for --

10 MR. MAYFIELD: For thermal --

11 MEMBER SHACK: Yes.

12 MR. MAYFIELD: Well, I think that it's an 13 issue that -- as I mentioned, the British -- these recent G

t

\

% ) 14 British results have caused us to take a step back and say I 15 we better go look at this more carefully than we were and 16 on a little faster scale or schedule.

l 17 I'm not prepared to stand here today and tell 18 you not an issue. I'll tell you that we don't think it's 19 a particularly driving issue. But it's enough of a 20 concern that we've put more emphasis on that activity.

21 Does that answer your question?

22 MEMBER SHACK: Yes.

23 MR. MAYFIELD
Mechanisms of embrittlement --

24 this is something that does have a significant

(_j 25 international involvement. One of the multi-partner NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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146 1 groups that I mentioned earlier is a way we're leveraging

\

l 73 2 the research -- supports the mechanisms activity.

l ('j 3 We do continue to work on dosimetry and l

4 neutron transport calculations. Current interest in the 5 Monte Carlo schemes that are being put forward today for 6 estimating neutron fluence, evaluation of the trends from 7 the surveillance data -- I mentioned the collaboration we 8 have going with the statistician and the physical i

9 metallurgist. l 10 We've been participating in the annealing 4 1

11 demonstration program and the validation activities. ,

l 12 MEMBER POWERS: As we move to license renewal l

13 for a plant, have you run out of surveillance specimens?

( s D) 14 MR. MAYFIELD: No, they can reconstitute the 15 surveillance specimens. And in fact, some years ago --

16 Jack may remember how long ago -- there was a letter went 17 Out that reminded licensees to hand onto their 18 surveillance specimens for reconstitution.

19 One of the activities -- there's a ,

20 modification pending to E-185, the ASTM standard, that 21 talks, among other things, about making sure that your 22 withdrawal schedule makes sense for license renewal. I 23 mean, there's a whole host of things addressed. But of l

l 24 these activities, people are sensitive to the notion that l

C')

\.s 25 you need a surveillance program that takes you out through i

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147 1 our renewal period.

l g- 2 The inspection program -- the major objectives l N))

3 provide basis for evaluating reliability and capability of l

4 inspection tools; provide data to support the initial flaw l

5 distributions for use in regulatory analyses; and to be 6 involved with the ASME code.

7 We have had ongoing for many years this kind 8 of activity. It is also an activity that we would 9 anticipate continuing at some level in the future just to 10 provide a capability the staff can draw on. This initial 11 flaw distribution work gets a bit more involved and a bit 12 more interesting, as we'll talk about.

7-13 Current emphasis in this flaw distribution

( )

14 work -- detailed inspections to determine the initial flaw 15 distribution, and then some destructive examinations to 16 follow up on that. Some years ago, we looked at a nozzle 17 drop out from the Hope Creek plant. We have done detailed 18 evaluations of the Midland welds.

19 And some of those welds -- some pieces were 20 destructively evaluated. There's a thing called the PVRUF 21 vessel -- the Pressure Vessel Research User Facility 22 that's at Oak Ridge. It was one of the -- one of the last 23 vessels fabricated by combustion engineering. Oak Ridge 24 acquired that vessel some years ago, had it shipped down C)\

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148 1 since then.

~~s 2 We had the contractor go in and do some I i

%J 3 detailed ultrasonic evaluations of that. And as they 4 section the vessel for its final disposal, we will get 5 some pieces out of that vessel and do destructive 6 evaluations to validate those ultrasonic examinations.

7 MEMBER POWERS: Can you explain to me what a 8 Hope Creek nozzle drop out is?

9 MR. MAYFIELD: When they fabricate the vessel, 10 they -- once they fabricate it, they come in, cut a hole 11 to put the vessel in. It's that chunk of steel that 12 includes welds that literally drops out when they cut it.

13 We did examinations on that from the Hope Creek vessel.

A l 0 k/ 14 We have acquired welds from the Shoreham 15 pressure vessel and from a canceled River Bend plant.

16 That material will be moved to PNL where we wiil do the 17 detailed evaluation. And as budget permits, we'll cut up 18 the vessel -- cut up those welds for destructive 19 evaluation.

20 We also have some mathematical modeling work 21 that -- we've worked with the Rolls Royce people and have 22 acquired their computer code for predicting flaw i

i 23 distribution through thickness as the welds are 24 fabricated. One of the things we're doing with the

/~s

(,) 25 inspection results here and the destructive evaluation is f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

l j (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 l

149 1 testing that computer code.

7, 2 If the code can be validated, then it becomes

( )

'~' 3 one more tool we can use to update the flaw distributions 4 that are used in the PTS analysis.

5 Anticipated products and schedule -- I don't 6 propose to stand here and read this. It's in your 7 handout. Activities run out through the year 2000. This 8 -- the pressure vessel activity is something we anticipate 9 as a long term activity. Pretty much as long as vessels 10 are operating, we believe there will be some level of need 11 for evaluating what kinds of things could come up as they 12 continue to operate.

13 Any questions?

(~3 s 14 MEMBER CATTON: On the PTS regulatory guide, 15 --

16 MR. MAYFIELD: Yes, sir?

17 MEMBER CATTON: -- will the thermal hydraulics 18 side be reevaluated?

19 MR. MAYFIELD: Yes, sir.

20 MEMBER CATTON: Good.

21 MR. MAYFIELD: That is something that Dr.

22 Eltawila and his colleagues are involved with. This is a 23 coordinated activity that involves Mark Cunningham and his 24 people looking at how events are binned, as well as the r

( ,, 25 uncertainty analyses and how that's done.

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150 l 1 It involves Farouk and his staff looking at I i

l l - 2 the thermal hydraulics analyses and what needs to do in l /s Y,.)i ,

3 those, and it involves the materials and fracture 4 mechanics.

1 5 MEMBER CATTON: Now on the materials and 6 fracture mechanics side of it, you treat it often in a i

7 probablistic sense?

8 MR. MAYFIELD: I'm sorry, sir; say it again.

i 1

9 MEMBER CATTON: You treat it in a probablistic  !

l 10 sense.

11 MR. MAYFIELD: Yes, sir.

I 12 MEMBER CATTON: Are you going to do that on l l

13 the thermal hydraulics side in order to have balance?

-s 14 MR. MAYFIELD: You're raising an interesting 15 question. It's one we are still struggling with.

16 The analysis that's in the regulatory guide 17 today is some hybrid mix of a probablistic setting and 18 deterministic analyses. And then we go off and talk about 19 probability of through wall cracking. I'm not sure what 20 you calculate using that analysis method. What I'm sure 21 it isn't is the probability of through wall cracking.

22 It's some other number. We have been talking 23 about the level of rigor needed in those analyses and the 24 methodology. I can't quite answer your question because l /%

l () 25 that's something the staff hasn't settled.

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151 l 1 MEMBER CATTON: The reason that I raised the 2 question is because when the steam generator tube problem N.] 3 came up, they were not.

l l 4 MR. MAYFIELD: Yes.

l l

5 MEMBER CATTON: And I think that if you're 6 going to do something probablistic on the one hand, you 7 ought to do it on the other.

8 MR. MAYFIELD: Yes.

9 MEMBER CATTON: And I think it's very doable.

10 But you're going to have to push a little.

11 MR. MAYFIELD: Yes. And the question then 12 becomes the level of rigor you need to introduce.

13 MEMBER CATTON: Sure, and the more -- you can (O

V 4

substitute uncertainty in given parameters for rigor.

14 15 MR. MAYFIELD: Yes.

16 MEMBER CATTON: If you can stand it, okay; if 17 you can't, you fix it.

18 MR. MAYFIELD: And those are some of the 19 questions that we are trying to answer today. And 20 frankly, this turned out to be a much more difficult 21 problem to address that type of analysis. Not just the 22 thermal hydraulics, but the overall PTS analysis -- to 23 address that in a context that would satisfy I guess 24 levels of rigor that are expected from regulatory analyses f~ ~

'( 25 today.

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152 1 This hybrid thing we did in the early '80s

,m s 2 plainly isn't going to fly today.

t )

%./

3 MEMBER CATTON: Well, when it was done, it 4 wasn't a bad job.

5 MR. MAYFIELD: When it was done, it wasn't a 6 bad job. We're 16, 17 years downstream. We ought to be 7 doing a better job.

8 MEMBER CATTON: I agree.

9 MR. MAYFIELD: And that's -- then comes the 10 question of what does "a better job" mean, and what really 11 has to be imposed, and what's an appropriate level of 12 rigor given that these things are expensive to do. What 13 do you really need to satisfy the public health and safety i

( 14 issue, to satisfy Commission initiatives and direction, 15 and so that it is a tractable analysis to perform?

16 MEMBER CATTON: Tom, did you hear all that?

l 17 Good. l 18 MR. MAYFIELD: Before I move to the next 19 issue, are there any questions on vessels?

20 MEMBER POWERS: Is there an active licensee 21 program or industry program in this pressurized or .

l 22 pressure vessel integrity?

23 MR. MAYFIELD: Yes, yes.

24 I think we would urge the industry to do more.

j \

25 But they absolutely have a program in this area. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.

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153 1 Department of Energy has had a program in this area.

,s 2 Again, I think our urging would be for them to do more.

( ~)

~'

3 But they have budget constraints just like we do.

4 MEMBER CATTON: Yeah, I don't know how you get l

5 the industry to do anything, Dana, when there were a 6 number of programs in place to address things on the 7 thermal hydraulics side. And as soon as NRC said the I

8 issue is resolved, they canceled everything midstride. )

9 Never even finished the work.

10 So I don't know how you can resuscitate that 11 at this point. I don't know what your --

12 MR. MAYFIELD: One of the concerns that gets 13 voiced, and it's something that we're trying to be O

k/ 14 sensitive to as we evaluate this guide -- it does not good 15 for us to invest the resources in revising the PTS guide 16 if the product we're left with is so onerous and so l

17 expensive nobody's ever going to use it. i 18 So why invest that resource? If nobody's ever 19 going to use this thing, why do that? So that's one of 20 the questions we're trying to answer. Does this even make 21 sense to pursue? And again, what level of rigor -- how 22 big a deal does this really need to be?

23 MEMBER CATTON: Yeah, well there's a lot of 24 things you can do that are not resource intensive. But

()

(_j 25 you know, one of the key parameters was the heat transfer NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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154 1 coefficient between the cold water and the downcomer and

~s 2 the wall. And when I read through that recent review V 3 that was -- I forget what plant it was -- the one they 4 shut down -- there's statements in it well, that really 5 doesn't matter because this is conservative.

6 And it turns out the assumption of the person 7 who said that was 180 degrees out of phase. The heat 3 transfer coefficient actually should be higher, not lower.

9 And a lot of those things could be cleaned up if you 10 revisited the rule. And none of them are very difficult.

11 It's just bringing the right expertise to bear on the 12 problem.

13 MR. MAYFIELD: We agree.

/%

\ -)

I 14 MEMBER CATTON: Good.

1 15 MR. MAYFIELD: Okay.

16 MEMBER SHACK: Well, there's still a very 17 limited number of plants that --

18 MR. MAYFIELD: That's correct.

19 MEMBER SHACK: -- will face that.

20 MR. MAYFIELD: That's correct. And that 21 number might change if we change Regulatory Guide 1.99, 22 but it's not going to go up to be half the fleet, we don't 23 think. I mean, there's no reason to suspect that. So 24 it's still going to be a smallish number. What level of

(

(~~)h 25 resources does -- can the staff afford to invest in a NEAL R. GROSS  ;

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155 1 generic activity that really only affects a small number 2 of plants?

7~ I

~'

3 I'd like to turn to the pipe fracture 4 research. The regulatory issues that we have been  ;

5 addressing: validation of leak before break evaluation 6 procedures, validation of the flaw analysis procedures 1 7 that are in the ASME code, and promulgation of regulatory I

8 guides on leak before break and leak detection.

9 Piping integrity research program -- the l 10 objectives were to provide the analysis methods, material l

1 11 properties to support leak before break; and fitness for 12 duty evaluations for flaws detected during ISI's; and to 13 provide experimental validation. Not surprisingly,

/~~N t 1

\/ 14 fracture analysis methods was a major activity, material 15 properties, leak rate analysis methods, and experimental 16 validation.

17 This is an area that we're closing out. We 1 l

18 don't have budget in fiscal year 1997. It is an area that 19 we will be talking with Dr. Morrison about how it is we 20 can support this regulatory guide to get it started this 21 year. However, the research was initiated in 1981. So 22 we've been at this a good long while.

23 There were four major projects performed 24 during that time, as well as a number of smaller

,O

() 25 activities: the degraded piping program, phases one and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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156 1 two; the first international piping integrity research fs 2 group; short cracks in piping and piping welds. These two I \

L_)

3 were solely NRC funded.

4 The two IPIRG programs involved a consortium 5 of national and international organizations, industry, as 6 well as government. Each program was -- this one ended up 7 being funded at about $7 million dollars over five years.

8 This one's at about $6 million dollars over five years.

9 Overall, out of these programs, as well as 10 some of the other things that we have funded in the U.S.,

11 the NRC and the international community have spent over 12 $25 million dollars since this 1981 time studying ways to 13 predict the behavior -- failure behavior of cracked pipe.

t 14 What?

15 MEMBER FONTANA: Is there -- since the program 16 is being closed out, is there any big, bottom line answers 17 that it answered? For example, in the leak before break -

18 -

I 19 MR. MAYFIELD: Leak before break? Yes. Leak 20 before break is valid. We have the analysis tools and the 1

21 ways to determine material properties both generically and 22 for specific pipes to implement those analysis tools. So 23 it is a valid concept. It can be implemented. It must be 24 -- you must implement it carefully. l

,0

() 25 You can't just go off willy-nilly applying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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l 157 1 this to every piece of pipe you ever saw. But it can be i

l r- 2 imp]emented and it can be implemented successfully.

(v) 3 MEMBER FONTANA: And can one argue, for 4 example, to have less seismic supports on piping or l

5 something like that basis?

6 MR. MAYFIELD: Well, they have -- typically 7 the use of it in this country has been to remove the pipe 8 whip restraints and the jet impingement barriers. And 9 that really has been the use in this country. After we 10 promulgated the regulation in '87, I think it was -- the 11 change to general design criteria in four -- we went out 12 and asked the community whether or not there were other

_ 13 applications of leak before break that they would propose.

\--] 14 Interestingly, they came back -- we thought 15 people would pick up on environmental qualification 16 profiles. As a case in point: oh, gee, now you don't 17 have to postulate the big break. Interestingly, the 18 industry came back and said no, don't do that; don't do 19 that. Because there are too many other things we'd have 20 to go look at.

21 We're sure we're bounded by the big break, and 22 we've already done those analyses. Taking that out now, 23 we're going to have to spend a lot of money trying to find 24 the next limiting analysis. So people were comfortable i (h 25 staying with that non-mechanistic big pipe break as a i

(_/

l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

158 1 device.

,s 2 In terms of reducing snubbers and things like

( )

\' '/

3 that, typically they haven't wanted to use leak before 4 break for that application,- although there's been some 5 interest in -- there's been some application of that.

6 MEMBER FONTANA: Or any other -- you know, any 7 other application as a result of this program.

8 MR. MAYFIELD: Jack, there was what, change in 9 -- I may call on Jack Strosnider from NRR. There was 10 something about seals. I've forgotten now.

11 MR. STROSNIDER: This is Jack Strosnider from 12 the Division of Engineering in NRR. I'm not sure what 13 you're referring to with the seals, Mike. But I guess I

,.m

- 14 would point out that in addition to removal of pipe whip 15 restraints and impingement shields, this program developed 16 a lot of work in just basic fracture mechanics for piping 17 which is -- has found its way into flaw evaluation l 18 criteria in that we use extensively in assessing in 19 service inspection results on piping.

20 So there's a lot of basic fracture mechanics 21 or pipe analysis that came out of this program. So that's 22 been another very beneficial use of it.

23 There are some proposals to extend leak before 24 break into other systems on some of the advance reactors (x

( ,) 25 that are currently under review. And we'll be using NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

159 1 results from this program to assess those proposals as

- 2 well.

'~

3 MR. MAYFIELD: Okay, I'm going to rapidly run 4 out of time here.

5 So let me say we completed over 150 pipe 6 fracture experiments with a fair range in diameters and 7 wall thicknesses. We've characterized 75 different base 8 materials in welds. The final reports on the IPIRG 9 program are in preparation. Because we're closing out 1

10 this activity, we were looking for ways to document and j 11 archive the research results.  ;

1 l

12 We've contracted Battelle to put together a 13 CD-rom pipe fracture encyclopedia. This will be a

/3 (s sl 14 collection of somewhere between six and ten CD's that 15 you'll be able to access. It's going to include some l 16 30,000 pages of text, a lot of data base, some video clips i

17 from some of the pipe fracture experiments, as well as the l l

18 associated computer codes.

q 19 Current emphasis -- NRR has requested 4

20 development of regulatory guide on leak before break 21 evaluation procedures. This will really look at advanced 22 reactors, but it's -- the primary focus is to document the 23 technology and to put that together in the format of a 24 regulatory guide.

/-

( ,f 25 We've also recuested revision to Regulatory

, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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160 1 Guide 1.45 on leak detection methods. We already have an f~s 2 ongoing activity to update that. These two guides will be l

\ r i

3 -- the one will be developed. The other will be updated.

4 And we'll be talking to the committee in the future on how 5 we're going to promulgate those.

6 The work on the -- the research will be 7 completed in '97. Anticipate publishing in final these 8 two guides by the year 2000.

9 Environmentally assisted cracking, regulatory 10 issues, cracking of primary pressure boundary components, 11 the PWR head cracking, BWR safe-ends are examples --

12 cracking and degradation of reactor internals, cracked 13 growth predictions looking at crack growth in the shroud, p

k/ 14 as well as cracks that might propagate into the vessel --

15 final resolution of the fatigue life issues.

16 We were before the committee talking about the i

17 resolution of a generic safety issue having to do with i 18 fatigue. There are some final few fatigue tests that we 19 were performing to wrap up that piece of work.

l 20 Key objectives: evaluate susceptibility to 21 cracking; evaluate factors that contribute to the 1

22 susceptibility; environmental loading and the materials; 23 evaluate methods to mitigate cracking; and evaluate new 24 materials. Four major areas: crack growth, fatigue life,

(~

(_)) 25 cracking in high nickel, and irradiation assisted stress NEAL R. CROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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161 1 corrosion cracking.

-~ 2 MEMBER POWERS: What new materials?

Q 3 MR. MAYFIELD: As new materials are put 4 forward. One of the resolutions to the -- proposed 5 resolutions to the irradiation assisted was a high purity 6 -- took a look at those materials. And so it's things 7 that are put forward, not to develop new material.

8 Current emphasis -- crack growth and high 9 nickel alloys used for CRDM housings and safe-ends, 10 irradiation assisted stress corrosion cracking.

11 Particularly for the boilers, but we think the PWR's will 12 start to show this in a more significant way than they 13 have already.

1 <

N/ 14 Looking at crack initiation and growth, 15 cracking susceptibility, and behavior of crack structures.

16 One of the -- this gets to be an interesting issue. One 17 of the user requests we have was from NRR looking at 18 synergism between cracks in the core shroud and cracks in 19 other internal structures such as the top guide -- looking 20 at synergism.

21 What happens if you fail the shroud? Does 22 that then lead to failure of something in the top guide or 23 some other structure that could make it a more onerous 24 accident than had been assessed earlier? That's an fN

(_), 25 activity that Dr. Murphy's branch is actually leading in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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162 1 terms of the structural analysis.

r~3 2 They're looking at some collaboration with the V)

(

3 . Taiwanese in performing those calculations.

4 Crack growth predictions for both stainless 5 steel and low alloy steels is an area. Anticipated 6 products and schedule -- we'd look to update the report on 7 fatigue codes probably in '97. Report on the effects of 8 microstructure on irradiation assisted stress corrosion 9 cracking also in '97.

10 Evaluation of crack growth models for the 11 BWR's by '99. This again is an activity that we 12 anticipate continuing at some level in the long term. We 13 believe this is a core kind of activity. Steam generator O

O 14 tube integrity -- I think the committee's been briefed on l 1

15 the work we were doing on the severe accidents.

l 16 And I know you were recently briefed on the 17 rule, so we won't dwell on those issues. Issues that we 18 are interested in: data analysis methods pertinent to 19 emerging forms of degradation -- we'll talk a little more 20 about that; quantification of inspection capabilities.

2.1 Why do we need to do more steam generator 22 research? We sponsored a major international program in 23 the '70s and early '80s looking at steam generator 24 degradation. We got the surry steam generator. We did a O(m/ 25 lot of work in that area. With time, however, degradation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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163 1 types and modes have been changing.

g- 2 Out of the Surry generator, we saw a lot of

( /

'~'

3 denting, cracking of the support plates. We saw cracking 4 -- stress corrosion cracking in some of the U-bends. We 5 see pitting and general wastage in these. However, with 6 time, what's evolving is more of the intergranular 7 cellular attack, intergranular OD and some ID stress 8 corrosion cracking.

9 More recently, problems with circumferential 10 stress corrosion cracking. We got this chart -- I should 11 note that it came from EPRI and from their contractor --

12 looking at the types of degradation and how they have 13 evolved over time. One of the points the EPRI guys make

/"'T l

\- / 14 is that this chart is in percent of degradation detected,  !

l 15 and so it can be a little misleading to just look at that l 16 percentage. l l

1 17 They point out, quite orrectly, that in )

18 general, things are better than they used to be. However, 19 the types of degradation are changing with time. As we 20 get wastage and denting under control, stress corrosion 21 cracking gets to be an issue. What's next is part of the 22 issue we're trying to come to grips with in our program.

23 MEMBER FONTANA: What was SCC / IGA?

l 1 24 MR. MAYFIELD: It's IGA, intergranular attack.

/'T

( ,) 25 MEMBER FONTANA: I got it.

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164 1 MR. MAYFIELD: It looks a lot better on thie 7_ 2 screen than it does there. You know, it's great over (O 3 here.

4 Why do we need more steam generator research?

5 The previous research determined that the maximum 6 probability of detection was on the order of .8 for a 7 steam generator tube inspection of wastage, and between .6 8 and .7 for laboratory induced stress corrosion cracking.

9 New forms of degradation and new inspection 10 techniques have been evolving. The question is, how good 11 are the hardware and data analysis method for today's 12 flaws? Previous leak rate and leak rupture models were 13 based on a single dominant crack because that's really

("~') \

kJ 14 what we'd thought we were going to deal with.

15 However, with the types of cracking we're 16 seeing today, questions come up. How good are the burst 17 pressure prediction models and the leak rate models? Then 18 the question is, how does the degradation initiate and 19 progress to try and put some rigor to those analyses.

20 Our program deals with looking at the 21 degradation progression, looking at inspection 22 capabilities, validation using tubes removed from service, 23 as well as leak rate estimations, leak rate analyses, and 24 then this failure under severe accident conditions which

/^

(,N) 25 was a -- that's the only piece of the program that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i 165 i i

1 intended in direct support of NR.R's rule making activity. l l

1 I

7. 2 The rest of this would support implementation

'l V) 3 of the rule and the regulatory guide.

4 MEMBER POWERS: When people talk about induced 5 steam generator tube rupture in a severe accident, they 6 usually speak in terms of a race between rupturing those j 7 tubes, rupturing a surge line, rupturing a hot leg line.

8 Do you have work going on to support the analysis of that 9 race as far as the material behavior?

I i

10 MR. MAYFIELD: Not today.

11 It is an area that we've been talking with 12 Charlie Ader and his people in the severe accidents group.  !

13 There is some work in Japan at JAERI in particular looking

(/

V'~)

l 14 at creep failure of piping. It~L an area that we've I 1

15 talked about a little bit with NRR. We haven't quite 16 reached a consensus that that is something we need to do 17 to support the rule. ,

l 18 But it's a nagging question. We're talking l 19 about it. We have not yet put that on the table as

) 20 something that needs to be done. l 21 MEMBER POWERS: It seems to me we continue to 22 use a Larson-Miller parameter in these analyses in a 23 regime whether neither Larson nor Miller thought it was 24 applicable.

d(m 25 MR. MAYFIELD: Right.

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l 166 l 1 MEMBER POWERS: And for configurations of 2 materials where we just don't have the parameter. So it I (e s.\ 1 k s/

m 3 does seem like a problem.

l l

4 MR. MAYFIELD: Yes. Again, it's something --

i 5 there are competing priorities and competing budget i l

1 6 interests. If I had more budget, absolutely; this is j 7 something we'd take on as an initiative. But there's a 8 lot of things to do.

9 MEMBER POWERS: It's a long ways down on your 10 list I take it because it doesn't show up in your -- ,

l 11 MR. MAYFIELD: It's a long ways down on the l

12 list right now. If NRR comes back and says no, we really 13 want to pursue this, it would change -- for us, today, l 1

(~%,

/

\~/ 14 it's a long ways down on the list. Requests from the user l 15 office -- some other consideration that comes up could 16 cause us to reconsider.

17 Because we don't think it's a non-issue. It's 1

18 just in the relative ranking of things. '

19 MEMBER POWERS: It would be interesting to see 20 your complete list, not just the ones that you put up.

21 MR. MAYFIELD: My list would choke the 22 computer.

23 (Laughter.)

24 One of the things that the office -- Dr.

/^s

! ,) 25 Morrison in particular has been very supportive of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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167 1 staff identifying areas for research. And we plainly have gS 2 a lot more good ideas than we've got budget to support.

4 V

3 So it would be a very lengthy list of what are good ideas.

4 And it's difficult then to rank them.

5 MEMBER POWERS: Just as a point of personal 6 view, I don't think it hurts to acquaint this committee 7 with things that you would like to do that you don't have 8 budget to do. And one of the reason for saying I don't 9 think it hurts is one of the reasons you don't have budget 10 is that you don't have -- you haven't been able to 11 acquaint the people that disperse the budget with what 12 your needs are.

l 13 If you don't have a good reason, it's hard to 7_s i )

14 get money in this world.

15 MR. MAYFIELD: Well, we do put forward more i

1 l 16 ideas than get funded. That is true. And I am happy to i

l 17 not be one of the people that has to make those tough l

18 calls. I still am in the enviable position of putting  ;

i 19 forward the ideas, l

20 Products and schedule again -- I don't -- I

! 21 think in the interest of time to not read that unless l

l 22 there's a question.

23 Degradation of mechanical components, motor I 24 operated valve performance under design basis conditions -

(~h

(-) 25 - this has been a long standing issue. The staff has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

168 1 issued Generic Letter 89-10 with -- I don't know how many  ;

i 2 supplements -- seven supplements to it. We also have some (7-

)

i I

3 more recent generic letters addressing general issues on 4 motor operated valves.

5 Questions of long term degradation of motor i i

6 operated valve performance, pressure locking and thermal 7 binding of gate valves -- extension of test and inspection 8 internals for check valves, motor operated valves and 9 pumps is an issue. This program is not as tightly focused ,

i 1

10 as it used to be. There was a time when we were very 11 focused on MOV's.

12 We have broadened the scope of the activity to I l

13 look -- continue our activities looking at motor operated

(^N w- 14 valves. We've done some work looking at check valves.

15 And we're looking at whether or not we ought to be doing 16 something with regard to pumps.

17 Current areas of emphasis: perform 18 experiments to determine effects of internal corrosion on 19 motor operated valve thrust requirements. That's really 20 the key aging issue for the valve itself, whether or not 21 there's a change in the friction factor based on long term 22 corrosion. l 23 Experimentally determining the susceptibility 24 of gate valves to pressure locking and thermal binding --

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4 169 1 Laboratory, and it's providing some information for the 7s 2 licensing staff to use in their assessments of responses I \

3 to the generic letter.

4 Evaluating MOV performance under design basis 5 conditions -- this is an activity that's winding down 6 fairly quickly. Although, there will probably always be 7 some need for us to be plugged in to what's going on so 8 that we can bring our contractors to bear on issues as 9 they evolve.

10 MEMBER CATTON: So just out of curiosity, what 11 is the probability of failure to seat the valve on demand 12 -- motor operated valve?

13 MR. MAYFIELD: It's not zero, but I -- it's 14 about the best answer I can give you. And I don't mean to 15 be flip about it. I don't know.

16 MEMBER CATTON: Because I remember when the 17 program started, it was on the order of 20%. The Germans 18 said you could never get it below seven or eight percent, i

19 and I'm just wondering where you are. Because both those 1

20 numbers are significantly higher than -- l 21 MR. MAYFIELD: I'll call on Dick Wessman from 22 NRR to see if he's got a --

l 23 MR. WESSMAN: I'm Dick Wessman from Mechanical 24 Engineering Branch.

('h 1

( ,) 25 No, I don't have an answer. I think our l

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170 1 confidence is that the valves are much more likely to

, 2 perform as design upon demand now than they were five

' \'~s) 3 years ago and based upon all the work of the Generic l 4 Letter 89-10 program. But to try to develop a probability i I

5 number, I just don't have one.

6 MEMBER CATTON: See, only part of the problem 7 is resolved by the program. You still had the -- some 8 questions that were raised by the Germans about distortion i

9 of the housing and that sort of thing. And they felt that I

10 you couldn't lower it below some number. It was still l l

11 significantly higher than what's used in the PRA's.

12 And I was just wondering if this has been 13 addressed, or has it been forgotten?

fg

( )

N/ 14 MR. MAYFIELD: Gerry, do you have anything to j

\

l 15 add to it? You have to use one of the microphones.  !

16 MR. WEIDENHAMER: Pardon?

17 MR. MAYFIELD: You have to use one of the 18 microphones.

19 MR. WEIDENHAMER: Gerry Weidenhamer from the ,

I 20 Office of Research.

21 To answer your question, Ivan, no; we haven't 22 investigated that any more with regard to valve body j l 23 distortion and all of that. What we have looked at with l

24 regard to valve bodies is the erosion of the material due O)

(, 25 to some throttling of the fluid as it goes through the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER 3 1323 RHODE ISLAND AVE., N W.

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171 1 valve.

a

,- 2 But as far as distortion goes, no; I haven't V 3 seen much of the -- I haven't seen much of the --

4 MEMBER CATTON: Let's see. I just threw 5 distortion out because I happen to remember what they said 6 about it.

7 MR. WEIDENHAMER: I don't ever remember seeing 8 any problems --

9 MEMBER CATTON: Praffic Union came in here and 10 made a presentation and come to a conclusion at their 11 presentation to us that there was some bottom line number.

12 And you wouldn't get below it because it was sort of -- it 13 was the structural design of the valve that led you to

/'N k-) 14 that point.

15 You could clean up a lot of your other i 16 problems like the electrical systems or correlate that 17 limit switches don't do the right thing. That kind of 18 thing, there was no question about that it could be 19 significantly changed. And I was -- you know, one of the 20 unsettling things was the number that's used in the PRA 21 was so small and the numbers that people were quoting were 22 so large.

l 23 And I think that if you're headed towards risk 24 based regulation, somehow your PRA ought to get fixed with (3

(,) 25 what you know. And really, the question I'm asking --

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i l

172 1 l 1 it's you guys' program. Have those numbers made it into l

l l

,x 2 the PRA, the larger ones? Or , are the PRA's still based i

(G 3 on this -- I think it's .04 on reliability?

4 MR. MAYFIELD: I cannot answer your question 5 today. It's something we can look at. The one thing I can 6 tell you is that there was a CSNI activity two years ago 7 looking at internationally what are the areas of interest 8 under the heading of aging. MOV performance was one of 9 the areas where there was some consistent interest in the 10 international community.

11 Gerry, in fact, has a trip scheduled for I 12 guess the next quarter to Europe looking at what's the 13 area of interest in general to try and flush out this CSNI

() ,

14 result that says there is interest in MOV performance. So i

15 this is something that we need to go back and revisit i 16 obviously. l 17 MEMBER CATTON: I mean, I think the --

18 MR. MAYFIELD: It sounds like it's dropped, 19 and we have to pick it back up. l 20 MEMBER CATTON: -- common practice in the l

21 PRA's ought to reflect the results of your program.

22 MR. MAYFIELD: I agree, I agree. It's 23 something we will obviously have to pick up as we go.

24 MEMBER FONTANA: This MOV degradation, is this

(~%

(._) 25 coordinate with the work on diagnostics that's going on in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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173 1 places like motor current signature analysis --

-w 2 MR. MAYFIELD: Yes.

3 MEMBER FONTANA: -- and stuff like that?

4 MR. MAYFIELD: Yes.

5 In fact, we have an activity tracking what's 6 going on there, looking at some -- there was a small l 7 business program -- small business innovative research 8 program that looked at some of that, and it's an area 9 we've stayed cognizant of.

10 MEMBER FONTANA: That would be good because 11 you've got the answers here.

1 12 MR. MAYFIELD: Yes.

i 13 MEMBER FONTANA: Compare them with what they C\

s

' ') 14 were predicting.

15 MR. MAYFIELD: And there are some substantive 16 questions about whether those diagnostics really tell you 17 about whether the valve will perform its intended function 18 under full flow condition.

19 MEMBER CATTON: Well, there's no way to do the 20 testing at full flow conditions and apply it. So you 21 never really know that.

l 22 MR. MAYFIELD: But it makes no senGe if what 23 you're really concerned about is full flow performance and 24 the thing you test -- the thing you're relying on won't

(~h q_) 25 tell you that, you need some other device.

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174 l

1 I agree. You can't practically do full flow 2 testing on many of the vah e". But what do you need to l [s) i LJ 3 do? And the question is w.iet her the motor signature work i

4 and some of the other things tr.at have gone along with 5 that are the right answer.

6 MEMBER CATTON: Well, I mean, I think that 7 they did do -- did help. Because it cleaned up a lot of 8 the other kinds of problems. It just doesn't tell you 9 whether or not you're going to be able to shove that disk 1

10 in.

l 11 MR. MAYFIELD: Right.

12 Going back to Dr. Fontana's question -- yes, 13 we're staying plugged into that. I wouldn't say we're k -) 14 aggressive in it, but we are plugged into what's going on.

15 MEMBER CATTON: Whoever's responsible for 16 PRA's ought to be a little more aggressive about what they 17 use.

18 MR. MAYFIELD: I will pass that on to Mr.

19 Cunningham.

20 MEMBER CATTON: Good. If I see him again, 21 I'll remind him.

22 MR. MAYFIELD: Anticipated products and j 23 schedules -- right now, this activity is fairly short 24 ra.3e. It is an activity, however, like the rest of these p)

(, 25 we would anticipate maintaining at some level in the 1

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175 1 longer term.

73 2 EQ of electric cables -- regulatory issues, k) 3 why is it a concern? It stemmed from a license renewal 4 evaluation looking at differences in the qualification 5 requirements for the older plants and the newer plants and 6 a determination that that needed to be reassessed for the 7 currently operating plants.

8 There are some Sandia test results that raised 9 questions with respect to accident and performance 10 capability of certain cables after they had been 11 artificially aged. A preliminary scoping assessment 12 indicated inadequate environmental qualification could be 13 a significant contributor to core damage frequency.

A

> 14 Finally, the fire protection reassessment 15 report concluded that EQ should be reviewed to identify l

l 16 and correct any programmatic weaknesses. NRR developed a 1

17 task action plan to address the general area of 18 environmental qualification.

l l

19 The RES program is providing direct support to 20 the resolution of that task action plan. Our work is 21 focused on the environmental qualification of electric 22 cables, and in particular the I&C cables at least 23 initially. It's not to say power cables aren't important, 24 power cables shouldn't be considered.

( ,) 25 No, it's we had to choose something first. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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176 1 chose I&C cables. So we had to limit it because of budget l

p 2 constraints. We chose I&C.

i U

3 The program involves a detailed literature l

4 survey. The initial cut at that literature survey has ,

1 5 been completed. We originally had some 19 issues. We had 6 a public meeting in August. Based on some of the 7 additional information and some of the feedback we got at 8 that meeting, we're down now to six remaining issues.

i 9 We have been -- we have some new cables. We 10 have been acquiring cables from plants to do a LOCA 11 testing program looking at LOCA withstand capability of 12 aged cables, both naturally aged and artificially aged.

13 We also have a very active program looking at condition

/O

\

--) 14 monitoring as a way of determining LOCA survivability for 15 cables.

1 l

16 MEMBER POWERS: When you're worrying about l l

17 cables, your concern is over connectors and insulation?

18 MR. MAYFIELD: Yes.

19 MEMBER POWERS: It's not the conductor itself?

20 MR. MAYFIELD: No, it's not the conductor.

21 It's the insulation.

22 MEMBER POWERS: And the type of insulation I

i 23 that's used in these I&C cables?

24 MR. MAYFIELD: There's a number of different

,e

() 25 types.

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177 1 Jit?

gg 2 MR. VORA: Jit Vora from Office of Research.

N.) 3 And that's propylene and ethylene are the 4 predominant insulating types of material which are used 5 for the cable systems.

6 MEMBER POWERS: You don't have any 1

7 chlorosulphenated cable insulation?

l 8 MR. VORA: Not much, no. I think EPR and 1

9 hypalon and those materials constitute about 60 or 70% of i 10 insulating material. We also use --

11 MEMBER POWERS: You do have hypalon on the I&C 12 cables?

13 MR. VORA: Correct. I (D l 14 MEMBER POWERS: Wouldn't that -- that is a i

15 chlorosulphenated polymeric material.

16 MR. VORA: Yeah, that's the -- it's very 17 limited.

18 MR. MAYFIELD: Okay. In terms of anticipated 19 products and schedule, the literature survey is 20 essentially complete. There are some few remaining 21 documents -- I think 25 or so left to look at that we got 22 as a result of the August meeting. Complete the LOCA 23 testing and evaluation of condition monitoring methods, 24 basically complete the research activities in '99.

rm l (V 25 If we identify changes that we believe are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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178 1 warranted to the IEEE standards, to raise those in '99.

2 And if warranted, to initiate revision of the rule by the O 3 year 2000.

4 MEMBER POWERS: When you look at these cables 5 for I&C components, do you look at them differently for 6 analog versus digital equipment?

7 MR. MAYFIELD: No, right now it's focused on 8 degradation of the insulation and the cable's ability to -

9 - well, the insulation's ability to pass this test.

10 MEMBER POWERS: Okay, so it's strictly 11 performance of the conductor itself and not the receiving 12 device.

13 MR. MAYFIELD: That's correct. l 4

U) 14 When you get into the qualification test, if 15 you're seeing degradation, then you have to ask whether or i

16 not that cable is still suitable for its intended purpose.

17 So pass / fail gets to be application specific. But in 18 general, it is without regard to the application.

19 I'd like to turn finally to the assessment of 20 aged and degraded structures and components. This is the 21 piece that includes degradation of containment. And to 22 date -- just looking at the regulatory issues, to date 23 we've seen 65 instances of containment degradation.

24 Thirty-one of those in steel and steel containments and

()

g 25 steel liners; thirty-four in concrete structures.

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179 1 More are expected to be found with the 2 implementation of ASME code Section XI IWE/IWL. The 3 significance of instances will have to be assessed by the 4 NRC. So just because you detect the degradation, you have 1

5 to take a look at what that really means.

6 MEMBER FONTANA: That's over and above pre-7 stressing cables and things like that?

8 MR. MAYFIELD: Andy?

9 MR. MURPHY: The instances for concrete 10 containments due include the pre-stressing tendons.

11 MR. MAYFIELD: Third issue, reliable methods 12 for predicting capacity of these degraded structures are 13 not available today to assess the capacity of these O

> 14 containments in their degraded conditions.

15 The program has five major activities:

16 inspection and nondestructive evaluation, looking at a 17 data base of degradation, mitigation and repair methods, 18 response of degraled structures and components to seismic 19 loads, and response to the operating load.

20 The technical program is being conducted by 21 Oak Ridge and Sandia. The Oak Ridge program looks at 22 developing the degradation data base, but the inspection, 23 repair, and mitigation techniques and a data base on those 24 and expansion of a statistically based method for A

() 25 performing -- or to predict, excuse me -- predict NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

180 l

l 1 remaining capacity of the degraded containment.

l -

l -- 2 The Sandia program is looking at deterministic

\~A 3 methods to predict and assess remaining capacity.

4 Current area of emphasis -- data collection 5 and evaluation on the instances of degradation, 6 development and calibration of statistical and 7 deterministic methods to assess containment capacity, and 8 limited investigation of specific topics looking at the 9 effects of any -- of tendon grease leakage on the i 10 containment concrete.

11 Anticipated products and schedule --

12 degradation data base in the '98-99 time frame.

13 Statistically based remaining capacity by the end of '98.

I \~O The deterministic assessment of remaining capacity -- that

! 14 I

15 prediction tool also by the end of '98. And preliminary I 16 assessment of the grease leakage effects would be by mid l

l l 17 '97.

18 I'd like to wrap this up by sort of 19 reiterating. The program is broad based and it includes 20 both analytical and experimental research. We do enjoy l 21 strong user office support including some of our 22 exploratory activities. The program is designed to 23 address both operating plant and license renewal issues.

24 The program's structure and focus are

^

/) 25 addressing key regulatory issues today.

(_

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181 1 I've got ten minutes left for questions and

,S 2 abuse.

t i

\ )

3 MEMBER FONTANA: I notice everything goes to 4 the year 2000. What's your real planning horizon?

5 (Laughter?)

6 3000, okay.

7 MR. MAYFIELD: You recall I talked about the 8 engineers -- the researchers are great about career 9 opportunities. It's going to be around for a while.

10 Most of these activities -- our planning cycle 11 runs sort of through 2000, 2003 or so looking at long ,

i 12 range. The things that we came to talk to you about today 13 are things that we're reasonably comfortable with assuming

( ';

'd 14 that we don't get major budget swings. To start talking I

15 to you about where we would go much beyond 2000 gets 16 pretty speculative.

17 MEMBER FONTANA: Well, you know there's going 18 to be something.

I 19 MR. MAYFIELD: The activities --

20 MEMBER FONTANA: They've got decommission and 21 all that.

22 MR. MAYFIELD: That's correct. The activities 23 we have on the book today and that we talked about today 24 we believe will be long standing. Again, depending on O

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182 1 almost all of these areas. At least to keep our fingers ex 2 in.

I I RJ 3 Anything else?

4 MEMBER POWERS: Any other questions from )

5 anybody?

I 6 VICE CHAIRMAN SEALE: I'd like to compliment  !

7 him on the presentation. I thought it was very --

8 MEMBER POWERS: Superb presentation.

9 VICE CHAIRMAN SEALE: -- very much to the 10 point.

31 MR. MAYFIELD: Thank you.

12 VICE CHAIRMAN SEALE: And very well done.

,_ 13 Thank you very much.

/ )

'# 14 MEMBER SHACK: You need a spell checker.

15 MR. MAYFIELD: Don't start with me.

16 (Laughter.)

17 I don't need this.

18 MEMBER POWERS: Mr. Chairman, I'll turn it 19 back over to you. I'll point out two points on this that 20 I think we may need to follow up on. I, myself, would be 21 very interested in seeing Mr. Mayfield's computer choking 22 list of research wants. And I think we should have that 23 in hand if our -- one et our obligations by statute is to 24 report to Congress on research needs.

/~~N

(_) 25 I sure would like to know what some of his NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

183 1 needs are. Even if it chokes computers.

2 CHAIRMAN KRESS: If he's willing to share ps

\'~~ 1 3 this.

4 MEMBER POWERS: If he's willing to share it 5 with us.

6 The other thing I think we need to follow up 7 with is the point Ivan made. If indeed we are using 8 incorrect reliability numbers in our PRA's for motor l

I 9 operated valves that do not square well with deterministic 10 assessments, we've got a problem and I think we ought to i

11 chase that down a little bit.

I 12 CHAIRMAN KRESS: These are follow up items for i 13 us to -- ,

/)

~) 14 MEMBER POWERS: For us to follow up on.

1 15 CHAIRMAN KRESS: This was just a briefing i

16 today.

i 17 MEMBER POWERS: Yeah, I -- there was no 18 anticipation that we would need a letter. I have to admit 19 that I did not hear anything in this presentation that 20 suggested --

21 CHAIRMAN KRESS: That would call for a letter.

22 MEMBER POWERS: -- call for a letter. Unless 23 Mr. Mayfield feels like he needs a letter from us, and he 24 apparently doesn't not.

(D 25 CHAIRMAN KRESS: Okay. Once again, we thank

(_,/

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184 1 you for the presentation. It wasn't just the electronics 2 and the -- it's the organization and the content. So we

\ )

3 thank you.

4 And at this time, I've been given excess time, 5 but I don't really know what to do when I -- it's a new 6 situation for me. It's never happened before, and I don't 7 know what to do with free time. So I'll just give us an 8 extra time for break.

9 We're supposed to be back at 3:45 from our j 10 break. l 11 (Whereupon, the foregoing matter went off the l l

12 record at 3:27 p.m. and went back on the 13 record at 3:45 p.m.)

.A ,

l t i '

V 14 CHAIRMAN KRESS: I think we'11 get started 15 again. The next agenda item is human performance program 16 plan. This will be under the cognizance of Bob Seale.

17 So I'll turn it over to you, Bob.

l 18 VICE CHAIRMAN SEALE: First of all, I would 19 like to pass along the apologies of Dr. Apostolakis. He 20 has a bug that is bugging him, whatever that is. I just 21 hope he stayed far enough away long enough so that the 22 rest of us won't have a bug bugging us.

23 Today we're going to hear a shorter version of 24 a presentation we heard earlier in the week from staff on fg 25 the human pertormance program plan. That presentation was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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185 1 primarily structured around a group of about 18 questions

,_s 2 that were formulated out of the -- or as a result of the

\

~'

3 presentations we heard earlier in September.

4 The staff has responded to most of those or to 5 all of them. In the presentation we had earlier this 6 week, the response generally covered the waterfront.

7 There were about five questions in particular that we felt 8 might warrant specific elaboration here at this meeting.

9 The staff is prepared to do that. Of course all of the j 10 questions, and they are in your handout which is under tab i l

11 five or six, whatever it is, five, in your booklet. Those l l

12 questions are all listed on pages five and six in that 13 handout.

\/# 14 Now in particular also, while we had the 15 advantage of having Jay Carroll at the subcommittee 16 meeting we had, we did not have one of the persons who had 17 been most helpful in putting together the questions 18 earlier, namely Dr. Powero.

19 So Dana, any comments or any questions you may 20 have been particularly interested in, you will want to be 21 sure that you get satisfaction, if you will, from what we 22 hear. Of course the staff was appraised of that request.

23 With that, I guess I'll turn the microphone 24 over to Cecil Thomas. You can put your group to work

~x qj 25 here. I understand you are going to use the panel format.

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186 1 We'll see how it works.

,3 2 MR. THOMAS: Thank you, Dr. Seale. With the t )

3 committee's permission, we would like to proceed as 4 follows. I would like to begin the presentation with a 5 brief recap of where the Human Factors Coordinating 6 Committee stands and the status of the Human Performance 7 Program plan. Then we would like to proceed through the 8 topics that were identified by the subcommittee last 9 Tuesday and also include a presentation by AEOD on their lo human performance event data base, as identified.

11 I would like to begin by introducing the i

12 people at the table. To begin with, on my far left is 13 Jack Rosenthal of AEOD. Dennis Serig of NMSS, Frank

(~N i ) 14 r offman of Research. To my right is Frank Collins of the l'

i 15 Operator Licensing Branch in NRR. We will be addressing l l

16 the respective topics that were identified at the l 17 subcommittee meeting.

18 I would like to begin by taking just a couple 19 of minutes to update you on the status of the Human 20 Factors Coordinating Committee and the Human Performance 21 Program Plan. I last addressed the full committee in 22 February in the capacity of chairman of the Human Factors 23 Coordinating Committee. Since that time, a number of 24 things have happened that I would like to share with you,

( 'i

( ,/

25 just to put into perspective where we are today and some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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187 1 of the answers to our questions.

,~ 2 To refresh your memories, the Human Factors V 3 Coordinating Conmittee was chartered in 1994 in response 4 to Mr. Milhoan's Event Review Task Force recommendation, 5 that a committee, an ad hoc committee be developed that 6 has the responsibilities of coordinating human performance 7 activities and developing a Human Performance Program 8 Plan.

9 The committee was to consist of 10 representatives of the program offices, AEOD and the 11 regions. The coordinating committee was to meet as 12 necessary, to develop a program plan early in 1995 and

_s 13 semi-annually thereafter, to consider the need to update

' 14 the program plan.

15 The initial program plan was indeed developed l

l 16 by the coordinating committee. It was issued in August 17 1995. The program plan consisted of the following 18 structure. A mission statement, goals and objectives.

I 19 Under the objectives were ongoing, planned, and 20 recommended activities. It identified the lead offices 21 that were responsible for each of the activities, target 22 schedules, and priorities for each of the activities.

23 As a result of issuance of the initial program 24 plan, the committee received quite a bit of feedback and O

(_) 25 comments as to its usefulness and suggestions for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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188 1 improvement. As a result, the committee began meeting l

,- 2 approximately six months later toward the development of l

( \

('/ 3 revision one to the program plan. Revision one was issued 1 I

4 in July of 1996. 1 l

5 Its format was similar to the initial program 6 plan, but it updated the activities. It expanded the 7 descriptions of the activities so they pretty much stood 8 on their own. It included references to commitments that i 9 were made elsewhere. It expanded and updated the lo schedules to include intermediate milestones where 11 appropriate, so we can measure progress. And it reflected i 12 the status of the activities. These changes were made l 13 largely in response to comments and experience with the t

r% ;

t

\/ 14 original plan.

t l

l 15 The issuance of -- well, two of the major i

16 considerations that arose with the plan had to do first of l

17 all with the Coordinating Committee's relationship to the 18 line organization. The members of the Coordinating 19 Committee are essentially the people that are at the table 20 here. We also had historically met quarterly to 21 coordinate human performance activities for our offices l 22 and among our offices anyway. So the relationship of the 23 particular hats that we wore or allegiance or what it 24 meant to the line organizations and all, was confusing at (Q,/

25 best. Who we reported to, it was questionable. What the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W.

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l 189 '

1 line organization's oversight, management, and review

! - 2 capacity was, a question.

b- 3 So there was the question of line organization 4 involvement. There was a question of duplication and 5 overlap of our continuing quarterly meetings and that of 6 the committee. So the issuance of Revision One to the 7 program plan gave us the opportunity to go back and 8 revisit some of those questions to see if we really needed 9 to continue the work of the Coordinating Committee, or 10 could it really most effectively and most efficiently be 11 conducted with the ongoing line organization quarterly 12 meetings.

13 When we issued the revision one to the program k-)s' 14 plan, we posed that question to Mr. Milhoan and 15 recommended that the most effective and efficient use of 16 resources would be to abolish the Coordinating Committee.

17 Now that the program plan was established and was being 18 used by each of the offices, it was more a matter of 19 maintaining it, periodically reviewing it, considering its 20 need to update it, but certainly to maintain it.

21 Mr. Milhoan replied back that he agreed with 22 the recommendations of the offices, and agreed to abolish 23 the coordinating Committee, with the commitment from each 24 of the offices that we would continue to meet quarterly, (Qj t

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190 1 to update the program plan, to maintain it as a living

,_s 2 document because it had proven its usefulness and it was

( )

3 considered a valuable document.

4 Mr. Milhoan also had an additional request.

5 That was that we prepare a memorandum to the Commission.

6 Heretofore, the Commission had not been involved in the 7 activities of the Coordinating Committee. The memorandum 8 was to describe the coordinating Committee, its 9 background, accomplishments and future actions.

10 For the Committee's information, we have 11 prepared that memorandum. It is currently with the EDO in 12 the EDO's office now for his consideration.

13 That concludes my introductory remarks to let m

I )

\/ 14 you know the status of the Coordinating Committee. The 15 program plan will be reconsidered again early this spring 16 for update and for revision as appropriate, considering 17 feedback from its users, including feedback from the 18 Committee, 19 Any questions?

20 VICE CHAIRMAN SEALE: At this point? Go l 21 ahead.

22 MR. THOMAS: Okay. Thank you. What I would l

l 23 like to do now is to move into item one on the agenda 24 which was question number one, which had to do with the

-)

(_) 25 staff's intention of developing a road map that would f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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191 1 relate to various elements of the Human Performance  !

14 surprised that they weren't more advanced in their 15 planning for human factors program, since it seems to be l

16 99 and 44/100s percent of the problem that they face.

17 MR. SERIG: Even though NMSS is sometimes 18 thought of as a small tail on a large dog, doesn't mean we 19 don't have fleas. The handout that you got today is some 20 indication that we do have a human factors program and 21 that it's been active over the last eight years. That l l

22 does place it some 10 to 15 years behind activities 23 directed at reactors.

24 The community we regulate is farther behind

/~T

(,) 25 yet. They frequently say a three-word phrase instead of a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE _, N W.

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209 1 two-word phrase. They say random human error as in what

,s

- 2 can I do about it. I has taken some time to get past that 1 N ,]

3 with one of our major groups of licensees. That's the 4 medical community. But there is clear evidence that they l

5 are starting to respond to public pressure, as well as to i 6 research that indicates that no, it's not random, and that 7 you can do something about it, and that adverse 8 consequences as a result can be avoided.

9 MEMBER POWERS: Just to interrupt you. You 10 are striking a nerve chord in the way you have begun your 11 talk. So let me ask you. Within the community you deal 12 with, is there anything equivalent to the understanding of 13 conduct of operations that we have in nuclear plants or in O 14 submarine?

15 MR. SERIG: The industries we look at do not 16 have the type of controls in place to prevent, detect, 17 correct mitigate human errors that we're used to in 18 nuclear power plants. They do not have safety systems, 19 redundant and diverse, defense-in-defense are simply for i

20 the most part, not concepts that are consistent with most 21 of our 6,000 to 7,000 licensees. l 22 When you get into fuel cycle facilities, yes.

23 You start to have the kinds of considerations that we 24 think of being in place in nuclear power plants. When you (r x) 25 get into medical facilities, you have very trained, very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234 4433

210 l

l 1 disciplined, very conscientious folks who still don't have gg 2 that overall level of control and thoughts about defense-l

! ( '

)

3 in-depth, et cetera, that we have. That's an education 4 process that is certainly necessary. ,

l 5 I asked Cecil to put up the roadmap because we 6 have been doing some things over the last eight years. I l 7 would like to point out where that has gotten us. We're 8 between that big green square and the blue diamond below f 9 it. That's TBD.

10 We don't know, in fact, whether we are going 11 to do anything in that blue diamond, partly because of 12 Commission redirection or the systematic assessment,  !

i 13 partly because other actions go on while human factors

'- 14 folks are dithering. In industrial radiography, for 15 instance, we did have a human factors engineering 16 evaluation that was performed to some level of detail and 17 then terminated because we weren't satisfied with it. But 18 in parallel to that, we had acceptance of some industry 19 standards for devices that may in fact have meant that we 20 didn't need to go any further. We are simply looking at 21 the evidence to determine whether that's where we are.

22 VICE CHAIRMAN SEALE: So you are answering 23 that yes/no question right now?

24 MR. SERIG: Correct. Or we may answer it. In

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211 1 let's continue, then we're going to answer the yes/no gs3 2 question.

3 VICE CHAIRMAN SEALE: You may have a " don't 4 care" instead.

5 MR. SERIG: That's true.

6 MEMBER SHACK: Does not apply.

7 VICE CHAIRMAN SEALE: Okay. I'm sorry.

8 MR. THOMAS: Is that the answer? We left 9 Tuesday not knowing the question you asked or the answer 10 you wanted.

11 MEMBER POWERS: Well, I have got some insight 12 into why you have TBD in the program plan. I guess 13 somewhat aside, and it may be sufficiently aside that you

(' ') 14 may want to tell me to be quiet, Bob. When I think about 15 defense-in-depth, and the things that you regulate in 16 NMSS, I say gee, I'm not sure defense-in-depth is the 17 right strategy for these people. I think a standards base 18 program is much better for them. What do you think?

19 MR. SERIG: Well, I'm not -- I'm strettbing 20 defense-in-depth. Frequently a single individual performs 21 X and is required to be the checker of X as well. That 22 person is the sole barrier between good things happening 23 and bad things happening, or the intended action happening 24 or unintended action happening.

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212 1 opportunities where redundant and diverse checks might be 7-g 2 appropriate. Again, we're hung in that box between. But

(,)

3 if we continue down that path, we may see that 4 reallocation of licensee resources, shifting things away 5 from individuals to devices, that kind of thing, may in 6 fact give them the same thing as defense-in-depth.

7 MEMBER POWERS: So you really are on the cusp 8 of making decisions. You just don't know how those 9 decisions are going to come out.

10 MR. SERIG: That's correct.

11 MEMBER POWERS: It's a labor / capital trade-12 off, fairly basic decisions here.

- 13 VICE CHAIRMAN SEALE: Yes. I think that's a 14 very good point. I'm glad you made it, Dana. There is a 15 quantification of effort sometimes that we need to 16 recognize. This may be a very good example. l 17 MR. THOMAS: Is that all, Dr. Powers, j l

18 on NMSS?

19 MEMBER POWERS: It seems to have covered my 20 questions, and I see there is a lot of stuff in the 21 viewgraphs that maybe I should look at.

22 MR. THOMAS: Okay. Number 11. Frank?

23 MR. COFFMAN: The question was, how are 24 standards adopted by the staff formulated? How does the O(_/ 25 staff assure that the standards are necessary and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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213 1 sufficient to meet the regulatory needs?

g, 2 Well, the staff, because we're dealing with i

N_/ 3 human performance processes -- I guess you could call it a 4 process -- for using consensus standards that are based 5 upon the accrual of experiential evidence, and they're 6 used in lieu of the resources that would be necessary to 7 develop experimental bases frequently. Thus, there are 8 limitations in -- because the limitations and experimental 9 evidence -- let me read my notes here.

10 The point is, because we're limited in 11 experimental evidence, but that doesn't mean that we're 12 limited in technical bases, technical bases for the use in 13 the standards because the feedback of experience should O \- / 14 not be ignored. And that feedback has a time limit -- has 15 ,.a time constant with it in the standards committees, like 16 five years typically. So it remains somewhat current.

17 So the process is to adopt consensus 18 standards, and we're encouraged to -- because of resource 19 considerations, to rely upon industry knowledge and 20 experience and -- well, just leave it at that, knowledge 21 and experience. There is no guarantee of sufficiency when 22 using consensus standards, so that the -- so one 23 constraint is that the scope of the standards should not 24 exceed the scope of the experience base.

r~N

(_). 25 I think that addresses the elements of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433

214 1 question.

2 MEMBER POWERS: I mean, that's -- I think he's

/-N

.Y 3 right, that a consensus standard doesn't guarantee 4 cufficiency.

5 VICE CHAIRMAN SEALE: That's certainly true.

6 MEMBER POWERS: That it's a necessity perhaps, 7 but definitely not a sufficiency, not necessarily a 8 sufficiency.

9 VICE CHAIRMAN SEALE: Yes. The real question 10 here is, are there experience -- and now I recognize 11 you're saying I'm going to live and die by my experience.

12 Okay. Are there experienced-based needs that you have not 13 yet been able to articulate, or to address I guess is a es

- 14 better way, to address in a standard? That is, you know 15 there is a problem.

16 You haven't been able to put together a 17 standard yet that addresses that problem, and so now 18 presumably the next step would be to ask yourself, am I 19 ever going to get that on the -- you know, first of all, 1

20 how bad is the problem? And then if I can't ever get it 21 by experience, do I need to put together some sort of 22 research effort, in essence, to respond to that particular f 23 question?

I a

24 Clearly, there are gaps, as you have j O

( ,) 25 eloquently stated, in the experience base. Are we doing i

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215 1 anything to try to identify those gaps, and then to come 2 up with something to begin to fill them in?

e-) '

%.-) MR. COFFMAN: I think there are three  !

3 4 ingredients to the response I'd like to make. First of j 5 all, I have a little bit of a problem with the premise 6 that we live and die by the standards. The standards are 7 usually endorsed by regulatory guide as an acceptable 8 means and reflect a wealth of experience, to the point 9 that we're confident that by continuing to rely upon the f 10 good parts of the experience, by drawing upon that 11 experience in a wise way we are going to come out okay.

12 But I think you've got, from my perspective, 13 what I can recall at this point, is that you've got a good (D

\ '# 14 point that we only rely upon evaluating experience. We 15 primarily rely upon evaluating experience --

1 16 VICE CHAIRMAN SEALE: Yes. l 17 MR. COFFMAN: -- in human performance, and we 18 don't look to new issues based upon some experimental 19 study. We generally look at the limitatione of that 20 experimental study in contrast with the factors that are 21 involved in real experience. So --

22 VICE CHAIRMAN SEALE: Well, even before that, 23 though, there is the question of the identification of a l 24 new issue, before you ever decide whether you're going to N

, ~) 25 do any research or anything to resolve it.

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216 1 MR. COFFMAN: I think we only look at

- 2 experience, but by that it's a broad application, or a V 3 broad experience across many applications, other 4 industries and other countries, other organizations. But 5 I think that's -- and somebody correct me if I'm wrong, 6 but I think we only look at experience as the source of 7 identifying human performance issues.

8 VICE CHAIRMAN SEALE: But let me say again 9 what I am -- and, you know, I recognize that there is more 10 to it than -- the live and die was perhaps a hyperbole.

11 But my question is, I can see where there would be things 12 where experience tells you you have a human factors 13 concern. But experience is not detailed enough, broad (k-} 14 enough, or perhaps specific enough to the nuclear issue to 15 allow you to address that concern just on the basis of the 16 experience. Now, how do you handle that?

17 MR. COFFMAN: I guess I would -- if I try to 18 address it at two levels -- if I could just make a quick 19 response. There might be more wisdom around the room than 20 I can give you.

21 But on the very high level we don't. I don't 22 think we do. But when we do simulation, or when exploring 23 new features like computer-based procedures or some things 24 like that where we do some simulations or get people l'\

! ,) 25 involved, then in those activities on some specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

217 1 erformance issues, if they came up with - came to our

- 2 uttention, we'd start questioning them. And so that would Q' So we don't exclude 3 come out of an experimental basis.

4 them, but the dominance is based upon experience.

5 MR. THOMAS: If I might take a crack at it, 6 it's a little bit off of the question, but we don't always 7 have to go all of the way to consensus standards. We have We interact constantly with  !

8 many tools available to us.

9 people in the industry, with our peers, with our 10 counterparts, with licensees, with professional 11 organizations, where we relate problems that don't rise to 12 the point of making it all the way to a consensus

- 13 standard, or whatever.

t

' We have generic communications as tools to f 14 15 articulate problems and call attention to them, and to try 16 to make people aware of them and to rectify them. There's

(

17 a whole spectrum of tools available to us, all the way 18 from talking to people, to the other end of the spectrum, 19 to consensus standards.

20 VICE CHAIRMAN SEALE: But how do you use those 21 to screen for issues?

22 MR. THOMAS: Well, we actually -- again, going 23 back to Frank and our road map, it is based on experience.

24 My group spends a lot of time in the field, and so does O(_/ 25 the other groups and we see problems -- working hours, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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218 1 overtime, fatigue. There are three quick examples that

,7-2 we' re in betwee.' having a : standard on how to deal with

'V) 3 that and a problem that we know is lurking out there.

4 VICE CHAIRMAN SEA:7: And if there is a lesson 5 of Dilbert, it is that engineers are sometimes quite 6 insensitive to human factors problems.

7 MR. THOMAS: But there are some we are aware 8 of.

9 VICE CHAIRMAN SEALE: Except for the ones that 10 involve them.

11 (Laughter.)

12 MEMBER POWERS: This is the velocity according 13 to Professor Seale here.

/O b 14 (Laughter.)

15 MR. ROSSI: Well, let me just intervene with a l

16 couple of things. We do have a number of people, some of l 17 which are sitting up here right now, in the agency that 18 dwell on human factors issues a significant amount of 19 their time at work. So, you know, you could -- they are i 20 engineers, but they are engineers, I guess, who are i l

21 focusing on human factors issues that are occurring. l

[ l i )

l 22 And the other thing, of course, that we have j l

23 is we have a very extensive program for review of events 24 and operational experience to look for frequent recurring 25 problems and the lessons that can be learned. And as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.

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219 1 Cecil indicated, we have mechanisms for just feeding back

- 2 those kinds of things and the lessons learned to the

\

'"') 3 industry, and then, of course, they have programs for 4 reviewing them and trying to address them as best they 5 can. So we have all of those things.

6 MR. HODGES: We also have some people who are 7 not engineers but are psychologists and management 8 specialists on staff who are looking at these problems, 9 too, so it's not just engineers looking at the problems.

10 VICE CHAIRMAN SEALE: Okay. Well, I guess we j I

11 ought to move along.  ;

i 12 Frank, do you want to --

i I

13 MR. COLLINS: Good afternoon. Let me

(~' j k--)/ 14 introduce myself again. I'm Frank Collins from the 15 Operator Licensing Branch, and I'd like to return to '

I 16 question 16 that we discussed the other day. It was three 17 parts. It was, how does the staff assure simulator 18 fidelity? The second part was, how important is good 19 fidelity to emergency operating procedure training? And 20 the third part is, what does the staff expect an operator 21 to do if unexpected plant behavior occurs during a severe 22 accident? And really, the bulk of the discussion I think 23 was in the first part.

24 And, again, I'd like to return to this graphic p)

(, 25 because this is the world we live in with the licensees.

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220 1 It's a complex interrelationship. It's constantly being 7s 2 interpreted on both sides of the equation -- by the e

i O 3 licensees, by the staff -- and questions come up 4 repeatedly.

5 Fidelity, as we discussed the other day, is an 6 undefined term, really. It's the aggregate of software 7 design verification and validation process that is built 8 to an industry standard.

9 MEMBER CATTON: In that I initiated the 10 question, I think --

11 MR. COLLINS: Yes, you did.

12 MEMBER CATTON: -- let me expand a little bit 13 and give you my definition and then see if you have the 14 answer to my question.

15 Both at the MIST facility, which is -- I don't 16 remember where it is anymore -- and at University of 17 Maryland, during certain -- during the small break LOCA 18 they have observed erratic behavior, cyclic behavior, 19 large amounts of water moving from one part of the system 20 to another, and there is no code around that can predict 21 it. If this behavior occurs, you won't see it on your 22 simulator.

23 And what my question was, from the point of i

24 view of drying out the core, it may not be an issue. But  !

) 25 the operator is certainly going to see this behavior. Is I

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1 l

221 j i'

1 he going to do something stupid because of it? Have you 2 considered it? Is it important?

p]

L Or do you just forget 3 it? And if you want to consider it, what can you do about 4 it?

5 That's a bit different than the question that 6 you were about to answer, I think.

7 MR. COLLINS: Well, no, it fits in here. It 8 fits in here.

9 MEMBER CATTON: This is not just sort of 10 overall behavior like, gee, the pressure change with time 11 is slower than you observe or slight differences. This is ,

!I 12 major.

13 MR. COLLINS: Well, this fits in exactly with

(')

~

14 this process.

15 MEMBER CATTON: Okay.

16 MR. COLLINS: The process that the licensee is 17 doing is an iterative process. After going through and 18 establishing fidelity one time and putting the simulator 19 to work --

20 MEMBER CATTON: But how does he --

21 MR. COLLINS: He is constantly reevaluating 22 plant modifications, which would include new data which 23 would be these data that -- which could be these data that 24 you're seeing --

b

\_ / 25 MEMBER CATTON: I will bet you --

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222 1 MR. COLLINS: -- from the University of p, 2 Maryland.

U 3 MEMBER CATTON: -- and give you odds that they 4 don't even know about it.

5 MR. COLLINS: I agree. I read this data the 6 other day in the 1988 test by Dr. diMarzo.

l 7 MEMBER CATTON: Yes.

8 MR. COLLINS: And the chances are they i 9 probably don't have this data incorporated at this point, l 10 because what that data represents is some phenomena that l 11 have been observed on a small test loop that have not yet 12 been scaled up and correlated to the design codes, as you 13 say.

(

I 14 The plant is working from a design database to l l

15 build their simulator. That design database specified in l l

16 the standard goes to the safety analysis report, the 17 transients that have been run. It goes to -- the best 18 estimate --

19 MEMBER CATTON: Is the small break LOCA one of 20 the DBAs?

l l

21 MR. COLLINS: A small break LOCA is, and small 22 break LOCA is required by the standard as one of the 23 vents that the simulator needs to be able to simulate.

24 Will it, in fact, include these phenomena? I don't know.

) 25 MEMBER CATTON: When the standard says that it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE-, N W.

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223 l 1 needs to be simulated, how well does it need to be

,_s 2 simulated?

3 MR. COLLINS: It needs to be simulated to the 4 extent that the operator will be able to follow his 5 control procedures or similar procedures in the simulator 6 that the phenomena that the design data -- now, the design 7 data that's used up here in scope and design may not 8 include --

9 MEMBER CATTON: I don't believe there's any 10 design data available.

11 MR. COLLINS: That's what I'm saying. It will 12 probably not include this research data that you're 13 talking about.

CT k-) 14 MEMBER CATTON: It's very interesting also l

15 that this was first observed at MIST, which is, what, 10 1 16 years ago?

17 MR. COLLINS: Roughly. It was a 1988 document j l

18 that I read, and that was after a few years of data l 19 analysis.

20 MEMBER CATTON: That's right. And they gave 21 up trying to predict it because it didn't matter as far as  ;

22 uncovering the core.

l 23 MR. COLLINS: But if we look at what was -- if l 24 we look at the phenomena that was being addressed here, p)x

( ,

25 that phenomena was a condensation that's occurring on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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1

224 1 walls as you go into a drying out condition. It appeared f- 2 to be fairly significant at first glance. But when you

() 3 take a look at it it was running something on the order of 4 29 psi on a system that was running around 80 psi, and 5 that was for a very short time. There were five small 6 pressure spikes that were detained with each spike. The 7 general trend continued positively.

8 MEMBER CATTON: I guess my question has to do 9 with the codes can't predict these things today. I don't 10 believe the simulators can. Is it iuportant, as far as 11 what the operator will do -- and this is a human factors 12 question based on the fact that you're not going to 13 predict the behavior. What is he going to do? Is it r

\~ # 14 important, or is it not important?

15 MR. COLLINS: It's important in that the 16 display that comes to the operator will be a best estimate i 17 representation of the phenomena that's expected. The 18 driving force behind this phenomena is included in the 19 models.

20 MEMBER CATTON: I don't understand your 21 answer. The question is, given that there's behavior that 22 our codes won't predict -- and it was a surprise to people 23 like diMarzo at the University of Maryland. It was also a 24 surprise to the people at MIST. If the operator is 25 surprised, what is he going to do? Is he going to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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225 1 something damaging? Or do you know, or don't know, or

- 2 don't care?

\ /

3 MR. COLLINS: No , it's not a case that you 4 don't care. It's you're making a prediction now, what 5 will the operator do. This --

6 MEMBER CATTON: I'm not making a prediction.

7 I'm asking a question.

8 MR. COLLINS: Well, you're asking a question, 9 and it is a transient behavior that the operator is 10 watching over a longer term than instantaneous response.

11 My best estimate of what an operator would do -- and 12 having been a licensed operator -- is just take that into 13 consideration, that as far as the overall status goes you

(

A) k- 14 see an instability but you don't necessarily launch off 15 into a completely different direction. He will balance 16 that against other data that he has available and against l 17 his understanding of the phenomena that are occurring at 18 the time.

19 The phenomena that are occurring at the time 20 are phenomena that are modeled within what his simulator 21 has trained him for. Condensation on the walls and the 22 differences in pressures and closeness on --

l 23 MEMBER CATTON: This is not condensation on l i

24 the wall. But nevertheless, okay.

r3

( ,) 25 I'm not very happy with your answer, but I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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226 1 not a human factors person, so I don't know whether your gg 2 answer in good, bad, or indifferent. I just wanted to r t V

3 raise it so others could hear it.

4 MR. COLLINS: Well, with respect to simulator 5 fidelity, as these phenomena are being analyzed by the 6 licensees to see whether it needs to go into the scope and 7 design process, their engineering departments would factor 8 that data into their best estimate designs. And from 9 there the simulators are modified and go into this 10 continual process of assuring fidelity and testing to make 11 sure that fidelity has ot been degraded by the 12 modifications that they made.

13 MEMBER CATTON: When you say " fidelity," what O '

14 do you mean?

15 MR. COLLINS: What we mean is the extent to 16 which the simulator replicates the reference data.  !

17 MEMBER CATTON: Okay. And if the reference 18 data -- where does the reference data for the small break )

19 LOCA come from?

20 MR. COLLINS: The reference data from the 21 small --

22 MEMBER CATTON: I'm sorry?

23 VICE CHAIRMAN SEALE: RELAP.

24 MEMBER CATTON: And if it comes from RELAP, O%

'N,_,/ 25 then your reference data maybe needs another look. Okay.

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I 227 l 1 I understand what you mean by --

l 2 MR. COLLINS: 'Perhaps --

(f-)

U 3 MEMBER CATTON: -- fidelity, and you're not i

)

4 the guy I should be talking to, because what you mean by 5 " fidelity" is that it meets -- it matches one of these big l 6 systems codes output. The systems codes don't predict 7 this.

1 8 MR. COLLINS: I agree. I 9 MEMBER CATTON: So if they don't predict it, 10 your definition of " fidelity" is still okay. But I still l l

11 have to wonder, what the hell does the operator do?

12 VICE CHAIRMAN SEALE: But the operator may 13 have been --  ;

('T l k- 14 MEMBER CATTON: When he sees all of the fluid 15 in the system move from one side to the other, or flows 16 start to reverse, or all kinds of strange things start to 17 happen, what does he do? Is this --

18 MEMBER SHACK: Well, in general, you want 19 part 3 of question 16. I mean --

20 MEMBER CATTON: Where? I don't know where it 21 is. I don't have the questions in front of me.

22 MEMBER SHACK: When does the staff expect an 23 operator to do unexpected plant behaviors? Clearly, there 24 is going to be a range of things that haven't been thought

/-

( ,T/ 25 -- you know, there's this list of 14 things that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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228 1 simulator hasn't been designed to cover.

2 MEMBER CATTON: Okay. Let's just -- first, we 7s 3 -- okay. How does the staff assure simulator fidelity?

4 You compare with a code like RELAP.

5 MR. COLLINS: Yes.

6 MEMBER CATTON: Okay. I understand that.

7 MR. COLLINS: And we enter this process that 8 the licensees --

9 MEMBER CATTON: Now, how important is fidelity 1

10 to emergency operating procedure training? You said that i 11 it is important.

12 MR. COLLINS: Yes, it is.

13 MEMBER CATTON: What does the staff expect the  ;

r~

?

\

14 operator to do if unexpected plant behavior occurs during 15 a severe accident? I mean, how about during a DBA, like a 16 small break LOCA? I didn't mean that necessarily to be 17 severe accident.

18 MR. COLLINS: Okay. We expect an operator to 19 operate in accordance with the terms and conditions of his 20 license, which are to follow his plant procedures and to 21 at all times maintain his responsibilities for the health 22 and safety of the public.

23 MEMBER CATTON: Now, let me add another 24 question down here on the bottom. Now that you know about

(~%

() 25 this, what are you going to do?

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i 229 1 MR. BOGER: This is Bruce Boger from Division

,,. , . , 2 of Reactor Controls and Human Factors. I think you're k.'_  !

3 bringing up an issue that is much greater than just i 4 simulator fidelity. I think your question --

5 MEMBER CATTON: Oh , certainly. Certainly.

I 6 MR. BOGER: -- the whole way we approach 7 severe accidents.

l 8 MEMBER CATTON: I didn't mean to do that.

9 MR. BOGER: The operators are instructed to 10 follow the emergency operating procedures which are 11 symptom based, and that's what they'll do. The symptoms i

12 are based upon -- and the reaction to those symptoms are l 13 based upon our knowledge of the plants. If we have a r~T I )

(/ 14 fundamental problem in understanding how the plant is 15 going to respond based upon this information, then I think 16 we have a different issue.

17 MEMBER CATTON: That's the issue that I tried I

18 to raise at the outset, was that from the University of  !

19 Maryland facility there were certain observations made.

20 And when you think about it, you can understand why the 21 process works. As a matter of fact, diMarzo gives a very 22 nice explanation of it.

23 None of the codes that are used to establish 24 fidelity are capable of dealing with this. How important i 25 is it? Well, diMarzo was surprised, and he has been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.

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i 230 l

1 watching this system for quite some time. He had some 1

7 2 troubles figuring out just exactly what was going on.

3 That, to me, says that you ought to really compare that 4 behavior with the symptoms and see if the symptoms-based l 5 procedures still do the job they're supposed to.

i l

6 Right now, as I sit here, I don't know that l 1

7 that is the case. First, I don't know how well they -- I 8 mean, it may be that your plant process instrumentation is 9 so slow it doesn't even see it. Then it doesn't matter.

10 Maybe it doesn't matter. I just don't know. But I think 11 that diMarzo put this on the table and it was kind of 12 unsettling.

13 And then I find that these same/similar things

/

m \

'v# 14 were observed in the MIST facility, not quite for the same 15 reasons, but they were observed there. So it's not new.

16 And I haven't looked at the data traces or anything, so I 17 can't tell you whether these are bizarre enough that 1

18 somebody will get a little bit unsettled by it. I don't i 19 know.

20 MEMBER FONTANA: Ivan, are you asking a 21 specific question that you've identified a specific 22 response to the plant which was not modeled properly, and 23 either by MAAP -- neither by RELAP, nor by the simulator?

l t

l 24 And does the question relate -- is the operator trained --

(g) 25 are the emergency operating procedures compared against NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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231 1 this, or is the question, what is the operator going to do gS 2 when he is totally confused? And it took diMarzo three or N.-]

3 four years to fignre out what the --

4 MEMBER CATTON: It didn't take him four years.

5 MEMBER FONTANA: Well, whatever it was. I 6 mean, are there -- these are good questions.

7 MEMBER CATTON: It's a mix. See, the first 8 quertion is, is the operator going to do something 9 strange? If the answer to that is yes, then what are you 10 going to do about it? You're going to have to tune up 11 your simulator in order to represent these things. If the 12 operator is going to do the right thing no matter what, 13 well, then this is another kind of problem. It's just it

[

\' 14 makes you a little bit nervous whenever you see the code 15 result.

16 I don't know where this thing falls, because I 17 don't know how bizarre the behavior is. We saw -- I mean, 18 I saw a diagram up here, but when you're a researcher 19 you're measuring things that you don't see in the control 20 room. I still don't know how tightly the process 21 instrumentation represents what is going on in the vessel 22 or in the system. But that's a separate kind of question.

23 I think you have a facility that was built and operated by 24 NRC, and you ought to take a look at it.

l

[\

\_/ 25 .And probably you, because of your operator l

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232 1 experience, it might be very helpful for you to go look at 2 it. And then you could come to a conclusion and tell me,

/T

\ l 3 " Hey, it's nonsense. Everything is fine."

4 MM. COLLINS: Well, certainly not nonsense.

5 MEMBER CATTON: Or, "I've got a major 6 headache. We'd better do something."

7 MR. COLLINS: Yes. It's certainly not 8 nonsense. When I looked the other day at the test results 9 and projected myself into the operator's role there, I saw 10 instability at a point, but within a general trend. And 11 if I projected myself into a control room environment 12 where we're already working in symptom-based procedures, 13 we're already working our way down through flowcharts, so C\

kl 14 you're not going to make a change from one flowchart to l

15 another instantaneously based on an oscillation that you j 16 start to see in one indicator.

I 17 And all of that oscillation was dampening out.

18 It had started initially and dampened out, and within five l 19 pulses it dampened out immediately. As an operator, I i

20 would -- it was very low in magnitude. As an operator, I l i

21 might note it as a curiosity. l 22 As you say, it could be within the instrument I 23 loop tolerances, and I might not see it at all.  !

l 24 MEMBER CATTON: Well, that's certainly true.

m

,) 25 When I heard his presentation, it didn't sound to me like l

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233 l l

1 it was something that was small, but I don't know. I 1

,_ 2 haven't gone to look at it.

i  !

3 MR. BOGER: But also, we're talking about, you 4 know, a true response. And at this point in time, maybe 5 even a tech. support center would be available. We should i

6 be focusing on the operator taking an action, and I don't '

7 think that operator would take an action without --

8 MEMBER CATTON: I don't think the people in 9 your tech. support center would know either, because 10 people tend to build up a belief in the predictions of 11 codes like RELAP5 or TRAC. They believe it. And now 12 there is something that's different. Is it different 13 enough you care?

O k- / 14 MR. COLLINS: But if we're projecting 15 ourselves at this point in time to where we are 16 interacting with the technical support center, and moving I l

17 into that severe accident management space, we're in an 18 area now where the studies that were in NUREG-6126 show 19 that the operator is going to be in a much more cognitive l

20 role now, and an information-sharing and an information-21 balancing mode with the technical support center than he 22 will be in a " hands on the panels" operating mode at this 23 point.

24 MEMBER CATTON: But still, if he's not seeing

(/j}

I 25 it and it's different, what is he going to do? If it's i l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

1 234 l

l 1 something that gets discussed in training, "Yes, gee, this

- 2 can happen when you get cold water in the bottom of the I

' '/

3 cold leg and it condenses the steam. You're going to see 4 all of the inventory move from one place to another, but 5 don't worry about it." Then you're absolutely right.

6 MR. COLLINS: And what he will do is he will 7 treat it as a symptom. He will put that into his symptom-8 based procedures, look for the confirmatory symptoms that 9 the procedures call out, and follow that course of action 10 and make those recommendations back to the people who were 11 in charge at the time.

12 MEMBER CATTON: And indeed, if there is 13 something in his -- that tells him to do that, then it's

/3 /

I

\_/ 14 all right. But I just have trouble --

15 MR. COLLINS: He is constantly evaluating i

l 16 symptoms and -- l l

17 MEMBER CATTON: I understand. I just have 18 trouble believing that when he sees something that nobody 19 has anticipated he is going to do what you say. I mean, 20 what is he going to think about?

21 MR. COLLINS: That's exactly what he is 22 trained to do is to say, "I have a symptom that doesn't 23 match here. My flowchart tells me to look to this l

24 confirmatory. I do not have confirmation. I don't know (O). 25 which way I'm going on my flowchart. Help, boss."

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235 ;

1 1 MEMBER CATTON: Is that a problem, when he l l

s 2 gets into that circumstance?

(J x~

)

3 MR. COLLINS: No, that's the way plants are 4 operated. And in this case what we're seeing is 5 oscillations that are going along and that symptom is 6 going to change as they analyze it. And they're going to 7 say, " Wow, you don't have that symptom anymore." As the 8 NUREG says, it will become much more a cognitive problem 9 but less of an operator taking instantaneous and rash 10 response. i i

11 The possibilities of rash response are I 12 mitigated by the fact that he is in a much more cognitive 13 mode of operation in that abnormal operating mode where

/s l 14 he's interacting with his shift supervisor and perhaps I 15 with his technical support center. And as the NUREG 16 points out, he may even be in a mode where actual command 17 and control are being exchanged back and forth between the 18 technical support center and the senior licensed operator.

19 But that's going to be depending on how severe accident l

20 management guidelines develop.

21 MEMBER CATTON: I understand. I just don't 22 know enough about your side of it to carry this any 23 further.

l l

l 24 MEMBER FONTANA: There's a case -- let me just

()' 25 add one thing.

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236 1 VICE CHAIRMAN SEALE: Sure.

f3 2 MEMBER FONTANA: In a severe accident meeting, t i V

3 the Germans brought up a situation and I don't really -- I 4 don't remember what the sequence was, but as they added 5 water the measurements did -- the signals that the 6 operators would see would indicate that things are getting 7 worse, rapidly getting worse. But they're supposed to 8 keep at it because they know that it's from their 9 experiments.

10 If this was a situation where people knew 11 about it ahead of time you could see where it would be in 12 the procedures. If this was a brand-new situation --

p, 13 well, you can't answer the question I'm going to ask.

{

'- 14 What would the operator do? You just don't know.

15 MR. COLLINS: Well, the analysis of that 16 phenomenon and what the basis of your knowledge is is the 17 answer to that question. If the phenomena has been 18 identified, and now the test results have been scaled up l 19 to make a prediction that this is what it would look like 1

20 in the plant, and you have that knowledge that things are  ;

21 going to get better, it could be as simple as 22 precautionary statements in the emergency operating 23 procedures, that the operator would hit as he comes down 24 the flow path. He would hit a caution statement that t

(_) 25 says, "When you first start adding water here, your l

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237 1 instruments will not respond instantaneously. Continue to I l

2 add."

n) i

%/

3 MEMBER FONTANA: No, it isn't that. They're ,

4 responding, but they make things look a lot worse. l 5 MEMBER POWERS: A classic example of that is 6 almost any time you add water your radiation monitors and  ;

I 7 containment will go up. Just about every time they go up, l

8 and so you're adding water and suddenly things seem to be 9 getting radioactively wise and containment worse. I have 10 always wondered how an operator is going to respond to l 11 that, because it's counterintuitive to start with.

12 MEMBER FONTANA: Yes.

13 MEMBER POWERS: He just has to hang in there.

14 MR. COLLINS: Well, that's why the procedures 15 are reviewed, and I can offer that as a way that it could 16 be dealt with as the precautionary statement is embedded 17 in the procedures -- would give the operator the times --

18 MEMBER CATTON: Once it's embedded in the 19 procedures, it's no problem anymore.

20 VICE CHAIRMAN SEALE: Well, let's --

21 MEMBER CATTON: It's when it's not.

22 VICE CHAIRMAN SEALE: We l'1, we may want to 23 make a comment or two about this.

24 Do you have anything else?

(%

\ ) 25 We had one more presentation by

, MR. THOMAS:

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l 2381 i

1 AEOD. You wanted a briefing on a summary of their

- 2 database.

( )

\ 3 VICE CHAIRMAN SEALE: Yes.

4 MR. THOMAS: Jack?

5 MR. ROSENTHAL: We made an hour and a half 6 presentation to the subcommittee, and I would hope to be 7 able to do this in maybe like 10 minutes.

8 VICE CHAIRMAN SEALE: That's fine. That's a 9 great slide.

10 MEMBER POWERS: Obviously, a human factors --

11 (Laughter.)

12 MR. ROSENTHAL: The first thing I wanted to do 13 was talk about studies that we have done before, and I was p

(.- 14 going to use a blue slide but we -- Gene suggested we l

15 might also use a green slide to just keep everybody calm l

16 and mellow.

17 (Laughter.)

18 Since '84, where there was a study of wrong 19 unit, wrong train, it's a nice temporal element to this, 20 and that is that the issues that were pointed out about 21 bad labeling and confusion, etcetera, don't pertain to a 22 model. Those problems have been fixed, so that's an old 23 study already.

24 We briefed you on many of these studies. For

! (^

(h) 25 example, there was a major briefing on NUREG-1265, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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i 239 1 Volume 8, which was the compendium of studies that we have

, - . 2 done that Jay Carroll kept referring to at the

\) 3 subcommittee meeting. We were interested in seeing what 4 NTSB -- looking at this NTSB report on what pilots and co-5 pilots do and seeing the relevance to the U.S. power 1

6 reactors. And I think that's a good example of what Dr. j I

7 Seale said, that INPO was also interested. They were also i 8 interested in that very same event.

I 9 We did a study on inappropriate bypass and l

10 defeat of engineered safety features, and many of the I 11 examples in that report are the same examples that Zach 12 Pate used in his speech. And then the last thing is that 13 the Wolf Creek blowdown event, which is both a systems

.O ksl 14 study and a human performance study, you were briefed on 15 that separately.

16 Again, I personally spent like three hours on 17 the phc m with INPO going over that report when we issued 18 it. And then they decided not to issue their own report, 19 but they did put out in their correspondence a reference 20 to the AEOD report, because they also thought there was an 21 interest. So we do work with INPO.

22 Okay. We began multidisciplinary studies in

, 23 about 1990 of events and did a number of events, decided 24 to develop a database, and with some tribulations have now r^x

(_) 25 at least the beginnings of a very good database.

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240 1 What we wanted to do was to take those events s 2 which were richest in human factor information and attempt 3 to compile them, and we put in all AITs and IITs. We put 4 in the human performance of visits that we did. AEOD has 5 stopped going on these trips, but NRR does that sort of 6 work and these are the special team investigations.

7 I also represent AEOD on marathon phone calls 8 on decisions about whether there should be an AIT and the 9 charter of that AIT, and we now contemporaneously assure 10 that human performance information is captured, or at 11 least attempt that. So we put those in.

12 We have also put in the corresponding LER, 13 because one of the things that we will look at is the p_

i i

\/ 14 richness of the information that we have from an AIT/IIT 15 special team investigation by NRR, etcetera, or AIT 16 sponsored by the region but often with NRR and sometimes 17 AEOD participation, versus the kind of information that's 18 in LERs.

19 At the subcommittee meeting, I also brought up 20 that we could use the accident sequence precursor program 21 as a measure of how important these events were from a l

22 risk perspective. And with all of the questions about how 1

23 well you do human factor modeling in ASP, it still is a '

24 measure and would move us in the direction that the agency f(~)h 25 is going.

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241 1 And then, in discussion with Dr. Rossi, who I )

I gS 2 report to this morning, he also pointed out that we can l NA 3 use the ASP program to identify events which we should i

4 ensure that were risk significant from that perspective 5 and make sure that those also get into the database. So 6 there is work to be done, but we're trying to collect l

7 those events which were dynamic, things happened, people 8 were under stress, and so --

9 MEMBER FONTANA: Jack, I wasn't at the 10 subcommittee meeting, and I may have missed it -- you may 11 have mentioned it -- but why the big drop in events after l

12 19937 What does that mean?

_ 13 MR. ROSENTHAL: Actually, Ed Jordan in part N. 14 had me look at this because -- in a very different i 15 context, and we went back and we looked at a lot of 16 immediate notification reports filed under Part 50.72.

17 Much of a decline. It's just plain the industry is 18 performing better. )

19 MEMBER FONTANA: I mean, so it's real. It's 20 not just --

21 MR. ROSENTHAL: Not all of it is explained by 22 improved performance. But a big chunk of the decline is 23 explained by just plain improved performance.

24 Now, we're also doing -- there is other j rN ,

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242 1 of events, which at the time they occur are perceived to 2 be very significant, then there's a somewhat lesser class 3 and the regions are doing special inspections. That's the 4 formal title -- special inspections.

5 And we should know which are important but 6 haven't risen to the level of an AIT. And as I said, 7 we'll have this marathon phone call where we all agree 8 that that's the case, and we should code those in also.

9 But much of it is just plain the industry performance.

10 Okay. There was an interoffice working group, 11 and we compiled NRR, RES, AEOD, and said, "What 12 information would we like to be able to decide from a 13 database?" That same interoffice group decided on 54

/~'N kl 14 fields that we would attempt to code from the information.

15 We know it's all not there, and so one of the questions is 16 just how ripe is -- how rich is the information that we 17 get. So let's look at some very, then, preliminary 18 results.

I 19 One very -- it may be obvious to some of you.

20 And it was mentioned in the subcommittee. The events that 21 you worry about are the things that go bang in the middle  ;

1 22 of the night, the 3:00 a.m. events, and yet the data says 23 that, no, you know, it's day shift events where we have --

24 well, it's because we have evolutions going on, people are

() 25 doing work, people are modifying the plan.

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243 1 So it's just an interesting observation.

~ 2 That's not to say that 3:00 a.m. isn't important. It just 3 says that of those events most of them are day shift.

4 Now, this is not a model, but simply a dicing 5 or slicing of the data into bins, and we do need to 6 develop models. The first use that I thought that we 7 would make of the database was to just plain take an ASEP-8 type human' error rate model, which gives you a peg at .01 9 or .001 depending, and then look at the performance 10 shaping factors to move that estimated human error rate 11 around. And one of the questions was, are we receiving 12 enough information to be able to empirically come up with 13 these performance shaping factors?

t A *

\_) 14 I guess we can go to models like the -- RES is 1

15 developing the ATHENA model, which Dr. Apostolakis l 16 mentioned, and yes, we're tied in with that effort. But 17 okay, here is some parsing or binning of information. It ,

1 1

18 is not at all surprising that procedures enter many l 19 events, because it's a procedural-driven operation. So I 20 was not surprised.

21 But I was surprised at --

22 MEMBER CATTON: Jack, when procedures enter, 23 and, you know, clearly you have put a check on something 24 --

(G_,) 25 MR. ROSENTHAL: Right.

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244 1 MEMBER CATTON: -- do you go back and look at g3 2 why? Is it because the procedure was written,

( ~')

3 interpretation was a little bit off, or what?

4 MR. ROSENTHAL: Yes. I think that that came 5 out of the subcommittee also. We can't make decisions on l

6 this level. We really have to disaggregate it further.

l 7 For example, how many of the times that there was a l

8 problem with the procedures was it because the procedure  ;

9 was inadequate, or the procedure was inadequate but wasn't l 10 adequately followed? And I think that we really have to 1 11 go to that level. And the rough estimate was 50/50. l 12 MEMBER CATTON: Training is also a big 13 contributor, at least in the darker lines. I would think rm f

\ >I 14 that training and procedures would be intertwined, and it 15 would be kind of difficult to sort that out.

16 MR. ROSENTHAL: Yes.

17 MEMBER CATTON: Okay. Go ahead.

18 MR. ROSENTHAL: On the --

19 MEMBER CATTON: I'm trying to fit it into our 20 earlier discussion.

21 MR. ROSENTHAL: On many of the human factors 22 we you went on, we looked to the procedures and we also 23 went to the simulator and talked to the training 24 department. And you have to get out of Washington. And

(

(h

(,) 25 if you go to the real plant and you go through that --

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I 245 1 although I totally agree that they are interwound -- you

,m 2 can at least start getting some information about how to (V) 3 parse.

4 MR. THOMAS: Jack, could I tell you --

5 interrupt just a minute. I can't let that pass.

6 MEMBER CATTON: What did I say?

7 MR. THOMAS: No, not at all.

8 In NRR, we maintain a database -- and we made 9 a presentation on it at the subcommittee -- called the 10 human factors information system. Correct me if I'm 11 wrong, but Jack's data are based on events that they've 12 done AITs and IITs on.

13 What we do in contrast to that is we have a l 4 V 14 database that's made up of all -- well, first of all, it j 15 involves inspection reports and LERs both, and it involves )

I 16 any time there is an LER involving human performance, or 17 any time there is an inspection in which a human ,

l 18 performance element is identified. We break our data down 19 and it covers -- it's nationwide. And it is not limited 20 to those events that warrant an IIT or an AIT. And we 21 break ours down into six categories, many of which line up 22 with what Jack has.

23 To answer your question, in procedures we, 24 like Jack, found that procedures are by far the dominant (3

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l I

246 1 all. It is quite low. Training is quite effective, but I l

f e~g 2 would submit for those -- for those events that Jack has l U 3 training is implicated a lot. But if you look at the 4 nationwide, the rational average, training isn't big. l l

5 For procedures, it's both problems with the  !

6 procedures and problems in following procedures, and we 7 found in our case it's about equal. There are problems 8 with procedures and sometimes operators don't follow them.  !

l 9 Sometimes they go off on their own. Sometimes they 10 misinterpret them. And so we're looking at it from a 11 slightly different angle, as far as performance goes.

i 12 But I just had to interject that. Thank you. 1 13 MEMBER CATTON: No. And I think that

(~T l

'-- 14 explanation sort of fits with where my concerns were 15 coming from, because all of a sudden there is an 16 opportunity for more misinterpretation. And what is that 17 going to do? If it's going to impact the area that is 18 already the highest, that gives it a little bit more 19 " oomph."

20 MR. ROSENTHAL: Okay. And then let me just 21 make an observation that management and organization, as a 22 broad category, is a big contributor. The agency -- RES, 23 in particular -- spent a lot of effort in M&O type issues, l 24 and we were really at decision points about how to go

(~h

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247 1 different slant than starting and looking at what the

-s 2 management organization in the plant is, but rather V 3 saying, "Do I have real events which are judged by some 4 measure to be of safety significance than involve M&o?"

5 And if that's the dominant thing, then we ought to go 6 forward.

7 Now, I need to parse this again. There is no 8 sense talking about M&O in the abstract and say, "Okay.

9 Was it a shift turnover problem? Was it a scheduling 10 problem? Are they trying to do too much at one time? Did 11 it happen during an evolution?" To list real things that 12 happened, see what's common, look at what -- and then look 13 at what one might pragmatically do. That work is yet to

/

o

)

(/ 14 be done.

15 But that's the approach that we are taking on 16 the M&O, and that is let it be event driven, and then l

17 slice and dice it into what are the real elements that the i 18 management at the plant have control over. We are not 19 doing super soft science in this area -- not to say that 20 that shouldn't be done, but we're just not doing it. I l 21 felt that the magnitude was important.

22 VICE CHAIRMAN SEALE: Jack, I'm sure you have 23 sliced and diced these every way one can, but one of the 24 things that I believe I mentioned the other day was that (n,) 25 at least in terms of the HPS assessments it looked like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.

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248 l 1 everybody got to share the blame, in the sense that the 1

- 2 percentages are higher on almost every issue and

(-) 3 reasonably high on every issue in the HPS category, 4 whereas in the AIT category the percentages are lower.

5 If you look at individual events, what the 1

6 nesting of those different actors are --

7 MR. ROSENTHAL: We have to continue to chop it 8 apart. But let me -- if you're familiar with the Wolf 9 Creek --

10 VICE CHAIRMAN SEALE: Yes.

11 MR. ROSENTHAL: -- event, clearly people 12 directed by the control room opened too many valves at the 13 same time. But also, management scheduled the quickest rh

(_ 14 shutdown / refueling ever, and management decided to start 15 testing and manipulation when they were in Mode 4 coming 16 down. So we would tend to give them ticks in both areas.

17 VICE CHAIRMAN SEALE: Sure.

18 MR. ROSENTHAL: And as I said, we have to dice 19 it apart.

20 VICE CHAIRMAN SEALE: But what I'm saying is 21 that is a procedure and a training issue -- I mean, when 22 you look at procedures, how many -- what percentage of the 23 time in that same event is training a co-conspirator if 24 you will?

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i 249 l I

1 correlation, so you can -- we have to do that work. But 5

s 2 we had to build --  !

l / ) '

3 VICE CHAIRMAN SEALE: I understand all of 4 that.

5 MR. ROSENTHAL: -- the data. But you're 6 absolutely right. There is also a -- there may be some j 7 bias in the investigators in the sense that a small team, 8 especially coming out of AEOD, is reluctant to ping on 9 management, while the AIT -- or surely an IIT led by an 10 NRC manager -- is less reluctant to make that sort of 11 association. So we have to look at also biases in our own 12 investigations.

13 MEMBER FONTANA: That's what I was going to s

/ )

\/ 14 ask, because the black line is larger than the not-so-15 black line for everything except management organization.

16 I wonder if the AIT pinged on them harder.

17 MR. ROSENTHAL: We have to do the work. But 18 there is the potential for biases in our own 19 investigations. Then, it was just pointed out that 20 although 80 to 90 percent of the time the plant is in 21 power operation, of these events, which by some measure it 22 was a qualitative judgment by the NRC that these were

, 23 important events, have happened during shutdown and i

l 24 particular attention to evolutions. So here you've got p)

( 25 43 --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

(202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433

250 1

l 1 VICE CHAIRMAN SEALE: Plus 5. )

73 2 MR. ROSENTHAL: Well, depending on how you add

('~')

3 -- 43 and F is 5 of the -- so 48 percent of the events, 4 and 80 to 90 percent of the time it's this proportion, 5 number of events, have happened during mode changes and i

6 shutting down and starting up. It's just an interesting i

i 7 thing.

l 8 VICE CHAIRMAN SEALE: Dana, would you --

9 MEMBER POWERS: PRA is only for --

10 MR. ROSENTHAL: Let me point out that the Wolf 11 Creek event in Mode 4 -- at the time we briefed the ACRS 12 we had not quantified that event. Subsequently, it has i 13 been quantified in ASP space with a time-dependent human  !

'-] 14 recovery model, not the simple ASEP model. And that's 15 likely the most important event from an ASP -- accident 16 sequence precursor -- perspective since Davis-Besse.

17 MEMBER POWERS: Really. And, of course, when 18 we --

19 MR. ROSENTHAL: A 10-3 type event as a 20 conditional core damage probability. I mean, you have to 21 look at the ASPS.

22 MEMBER POWERS: And when we did the -- when 23 the screening was done on the operational modes for 24 shutdown, Mode 4 had the lowest risk contributor, f)h

(_ 25 suggesting maybe the screening criterion is not too good.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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251 1 VICE CHAIRMAN SEALE: Well, either that or it gN 2 won't -- they did something in Mode 4 that you'd never 1 Q) 3 expect anybody to do.

4 MR. ROSENTHAL: No. I think what happened is 5 that they said that the fraction of time that they were in l 6 Mode 4 was very small, and that was the reason. And the 7 reason that Wolf Creek comes up high is when you're in 8 Mode 4 you have sensible pressures and temperatures.

9 MEMBER POWERS: Exactly. I think --

l 10 MR. ROSENTHAL: But I think that that's why it 11 came out that way was because of the fraction of time.

12 MEMBER POWERS: I believe you're right.

l ,_

13 MR. ROSENTHAL: Here is some data from just l 14 AITs, which again slices and shows that management l 15 organizations are major contributors. And so in my mind 16 it says that it's worthwhile to go on and carve that finer 17 and see what we can learn. Our mission is to communicate I 18 this lesson.

l 19 VICE CHAIRMAN SEALE: Jack, I made the comment l 20 at the subcommittee meeting, and I'll make it again. It j 21 is intriguing to me that fatigue, stress, and workload is l

22 considered a contributor in the case of cold shutdown and 23 refueling events, but not in the case of power operations.

24 And the inverse is the case on work environment.

25 MR. ROSENTHAL: They don't have the answer.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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252 1 VICE CHAIRMN; SEALE: But that's an

,, 2 interesting -- it seems the meter stick got broke 3 somewhere in making that differentiation.

4 MR. ROSENTHAL: We need to look at that.

5 VICE CHAIRMAN SEALE: Yes.

6 MR. ROSENTHAL: Okay. And then, the last 7 thing is that Dr. Apostolakis brought up and that is that 8 it may be -- yes, he got to collect and he got to slice 9 and dice data, but that we ought to have models in which 10 to assess that data. And I agree with that, and that's 11 where it could be done.

12 VICE CHAIRMAN SEALE: Any questions from any 13 members of the committee? Any other comments or questions I'T O 14 from anyone else?

15 Yes, sir? Do you want to make any final 16 comments?

17 MR. THOMAS: No. Thank you, Mr. Chairman.

18 That concludes our presentation.

1 1

19 VICE CHAIRMAN SEALE: Well, thank you very 20 much. We appreciate your patience with our questicns.

21 And, Jack, the problem if you ran ocsr 10 22 minutes was us, not your presentation.

23 But I'd make one other comment to the members l 24 of the committee. We will be drafting a letter based on

(N y) 25 this presentation, and I would like for you to be thinking l

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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253 l

1 about your comments. And hopefully, we might add an item j

,_s 2 7.3 on the schedule today to briefly go around the room I i 3 and get those comments a little bit later.

4 Thank you very much.

5 Back to you, Mr. Chairman.

6 CHAIRMAN KRESS: At this time, I'm going to 7 declare a 10-minute break.

8 (Whereupon, at 5:31 p.m., the proceedings in 9 the foregoing matter went off the record.)

10 11 12 13

(

O 14 15 16 17 )

i 18 19 20 21 22 23 )

l 24

) 25 l

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.

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O CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:

Name of Proceeding: 437TH ACRS Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court i

l reporting company, and that the transcript is a true and j l

accurate record of the foregoing proceedings.

A!/A "CORBETT RINER Official Reporter Neal R. Gross and Co., Inc.

O

l 1 j

INTRODUCTORY STATEMENT BY THE ACRS CHAIRMAN 437TH ACRS MEETING, DECEMBER 5-7, 1996 THE MEETING WILL NOW COME TO ORDER. THIS IS THE FIRST DAY OF THE 437TH MEETING OF THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS.

DURING TODAY'S MEETING, THE COMMITTEE WILL CONSIDER THE FOLLOWING:

(1) ITEMS FOR MEETING WITH THE COMMISSIONERS (2)

PROPOSED STANDARD REVIEW PLAN SECTIONS AND REGULATORY GUIDE ASSOCIATED WITH RISK-INFORMED, PERFORMANCE-BASED REGULATION (3) NRC RESEARCH PROGRAM ON INSTRUMENTATION AND CONTROL SYSTEMS (4) PLANT AGING RESEARCH PROGRAM (5) HUMAN PERFORMANCE PROGRAM PLAN (6) PROPOSED ACRS REPORTS I WOULD LIKE TO NOTE SOME SCHEDULE CHANGES FOR TODAY'S SESSIONS.

THE DISCUSSION OF THE ITEM REGARDING PROPOSED STANDARD REVIEW PLAN SECTIONS AND A REGULATORY GUIDE ASSOCIATED WITH RISK-INFORMED, PERFORMANCE-BASED REGULATION WILL BEGIN AT 9:30 INSTEAD OF 8:45 AS PREVIOUSLY ANNOUNCED. ALSO, THE DISCUSSION OF OTHER ITEMS SCHEDULED FOR TODAY'S MEETING WILL BE DELAYED FOR ABOUT 30 MINUTES. I HOPE THIS SCHEDULE CHANGE WILL NOT CAUSE MAJOR INCONVENIENCE TO THE PARTICIPANTS AND ATTENDEES.

THIS MEETING IS BEING CONDUCTED IN ACCORDANCE WITH THE PROVISIONS OF THE FEDERAL ADVISORY COMMITTEE ACT.

i DR. JOHN T. LARKINS IS THE DESIGNATED FEDERAL OFFICIAL FOR THE INITIAL PORTION OF THE MEETING.

WE HAVE RECEIVED NO WRITTEN STATEMENTS OR REQUESTS FOR TIME TO MAKE ORAL STATEMENTS FROM MEMBERS OF THE PUBLIC REGARDING TODAY'S SESSIONS. A TRANSCRIPT OF PORTIONS OF THE MEETING IS BEING KEPT, AND IT IS REQUESTED THAT THE SPEAKERS USE ONE OF THE l MICROPHONES, IDENTIFY THEMSELVES AND SPEAK WITH SUFFICIENT CLARITY AND VOLUME SO THAT THEY CAN BE READILY HEARD.

I WILL BEGIN WITH SOME ITEMS OF CURRENT INTEREST. '

. . . - -. . . . _ ~ . . - _ - - _~ . _ _.- - - -

ClHFB Goals:

s Provide regulatory guidance and Overview of RES Activities on .._ technical basis related to computer.

Advanced l&C based l&C systems including software

~ ~

quality, hardware qualification, and Franklin Coffman human-system interactions (301-415 5698) - e Assess and develop methods for us sac /ars safety evaluations a Stimulate and collaborate in international research December 5,1996 1 2 Co itent'of Presentation Recent products from l&C research a Recent products from l&C research a Six software Regulatory Guides Current Projects .-a Review guidelines for software

(

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,_.a Planing ,_

languages

_ a Considering _ m CASE tool for common code a Human factors engineering guidelines

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m Evaluation of computerized procedures system 3 4 Recent products (continued) Cu rent Projects a Dynamic Flowgraph Methodology for e Hybrid control rooms

,_ hardware & software .-a Alarms systems

,_ g Measurements of ambient EMI/RFI ,_s Total systems review guidelines

_ m Effects of stressors on an _

Experimental Digital Safety Channel

"" e Online calibration monitoring 5 6

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) e Risk Sensitivity study of selected ja integration of l&C and Human Factors j , . _ stressors ._I at the interface

_.g Effects of smoke on digital l&C _l CASE tool for P ogrammable Logic

_ a Regulatory Guide on environmental _ Controllers qualification of digital l&C 1

- e Halden Reactor Project -

1 4

7 8 Co isidering Co 1sidering (continued) e CASE tool for FMEA on software a Software numerical measures

, .-a Review guidance for lightning effects -a Evaluations of the effects of

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on digital l&C _ combined hardware and software

_ m Study non safety system development _

failures

& product a Recommendations from the NAS study 1

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PROGRAM Michael E. Mayfield, Chief Electrical, Materials, and Mechanical

Engineering Branch  !

Division of Engineering Technology (301) 415-6690 4

Presented to the Advisory Committee  ;

on Reactor Safeguards j December 5,1996

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[ j United States Nuclear Regulatory Commission REACTOR AGING RESEARCH PROGRAM OBJECTIVES l 5 Provide data and analysis tools necessary to l

9 Identify (anticipate)

G Quantify (inspect, validate)

G Manage (mitigate effects and establish margins)

S Regulate for current license period and license renewal E Stimulate, provide leadership, and collaborate in international research projects E Maintain essential competence for NRC through highly qualified technical staff and a few analytical and experimental contractors 2

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REACTOR VESSEL INTEGRITY E Regulatory issues 9 Pressurized Thermal Shock

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l 9 Flaw Size Assumptions and ISI

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G Validation of analysis methods through comparison to large-scale benchmark experiments - CSNI FALSIRE program and NESC program 18

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REACTOR VESSEL INTEGRITY E Current Emphasis (cont.)

i G Characterization of variability in chemical composition and initial l properties 4 Evaluation of thermal embrittlement for typical U.S. RPV weldments i

9 Development and evaluation of subsize test specimens, particularly for evaluating embrittlement 9 Development and evaluation of alternate fracture mechanics-based methodologies for transition fracture ,

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9 Dosimetry and neutron transport calculations 9 Evaluation of embrittlement trends from surveillance data 9 Participation in DOE Annealing Demonstration Program  !

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I BEACTOR VESSEL INTEGRITY E Current Emphasis in inspection Capabilities (related to RPV Integrity) 9 Detailed inspections to determine initial flaw distribution and destructive evaluation to confirm

+ Hope Creek nozzle dropout

+ Midland welds

+ PVRUF vessel (C-E fabricated vessel from cancelled plant)

+ Shoreham RPV welds

+ Riverbend cancelled plant l 9 Provide improved flaw distribution based on these results and mathematical model of welding process (Rolls Royce model) l 24

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REACTOR VESSEL INTEGRITY E Anticipated Products and Schedule 9 Validate Annealing Rule & R.G ------

  • Engineering demonstrations 1997
  • Recovery & reembrittlement trends 1999 9 Revise PTS Regulatory Guide 1999
  • Revise rule if warranted 2001 9 Determine if revision of R.G.1.99 is vaarranted ,

1997

  • Publish revised R.G. if warrented 1999 9 Implement improved fracture analysis methods ------
  • PTS analysis 1997
  • ASME Code and validate 1998 O Evaluate and quantify property variability 1997 9 High-confidence embrittlement estimation method 2000 25 e e e'l .

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PIPE FRACTURE RESEARCH E Regulatory issues 9 Validation of Leak-Before-Break evaluation procedures 9 Validation of flaw analysis procedures in ASMECode Section XI e Promulgation of regulatory guidance on LBB and leak detection  ;

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PIPE FRACTURE RESEARCH E Current Emphasis -- closeout 9 Research initiated in 1981 9 4 major projects since that time t

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  • First international Piping integrity Research Group
  • Short Cracks in Piping and Piping Welds
  • Second International Piping Integrity Research Group 9 NRC and international community have spent over $25M l studying ways to predict behavior of cracked pipe I

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PIPE FRACTURE RESEARCH E Current Emphasis (cont.)

O Completed apx.150 pipe fracture experiments

  • diameters ranging from 4 inch to 42 inch
  • wall thickness ranging from 0.25 inch to over 3.5 inch
  • slow loading, rapid loading, and simulated seismic loadmg 9 Performed material property characterization for over 75 different base metals and welds e Final reports are in preparation S Research products being archieved in a CD-ROM " pipe fracture encyclopedia" -- 30,000 pages of text,80 Mb material property data base, computer codes, and select video clips l

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9 NRR also has requested revision of Regulatory Guide 1.45 on j leak detection methods 9 Future work will stress development and revision of these documents i

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) United States Nuclear Regulatory Commission PIPE FRACTURE RESEARCH E Anticipated Products and Schedule 9 Publication of final reports 1997 9 Publication of CD-ROM 1997 9 Publication of RG on LBB 2000 9 Publiction of revised Leak Detection RG 2000 31 O G G .

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  • BWR core shroud
  • BWR top guide 9 Crack growth predictions
  • SS, high nickel, and low-alloy steels 9 Final resolution of fatigue life issues 1

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e Crack growth in high nickel alloys (inconel 600) used for CRDM housings and safe-ends .

O Irradiation Assisted Stress Corrosion Cracking in reactor l internals -- particularly BWRs but PWRs will be addressed l

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i E Anticipated Products and Schedule t G Updated report on fatigue curves 1997 9 Report on effects of microstructure on IASCC 1997 9 Evaluation of crack growth models for BWRs 1999

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STEAM GENERATOR TUBE INTEGRITY E Regulatory issues 9 New rule and regulatory guide on steam generator tube integrity being prepared by NRR

  • Validation of tube burst models used in severe accident analyses as part of regulatory analysis
  • Data and analysis methods to be used in support of implementing rule and guidance
  • O Data and analysis methods pertinent to emerging forms of ,

degradation '

9 Quantification ofinspection capabilities i

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STEAM GENERATOR TUBE INTEGRITY E Why do we need more SG tube research? i t

9 NRC sponsored a significant SG research program in 1970's and 1980's

  • Significant national and international involvement O With time, degradation types and modes have changed t

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j% United States Nuclear Regulatory Commission STEAM GENERATOR TUBE INTEGRITY E Why do we need more SG research?

9 Previous research determined max POD of 0.8 (90/90 LTL) for SG tube inspection of wastage and between 0.6 and 0.7 for lab SCC 9 New forms of degradation and inspection techniques --

hardware and data analysis

  • How good are today's inspections for todays flaws?

9 Previous leak rate and leak / rupture models based on single dominant crack

  • Current degradation results in many cracks
  • Higher burst pressures and lower leak rates than would be predicted
  • How does degradation progress?

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i STEAM GENERATOR TUBE INTEGRITY

. E Anticipated Products and Schedule i

G Validated models and supporting data for severe accident analyses 1997 9 Topical report on effectiveness of ISI 1997 9 Validated correlations for leak rate, failure pressure and failure mode 1999 9 Report on crack initiation and propagation 2000 9 Topical report on validated NDE POD and sizing accuracy 2001 46

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DEGRADATION OF MECHANICAL COMPONENTS E Regulatory issues O Motor-Operated valve (MOVs) performance under design basis conditions 9 Effects of long-term degradation on MOV performance G Pressure Locking and thermal binding of gate valves 9 Extension of test and inspection intervals of check valves, motor-operated valves, and pumps

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  • Limited experimental validation of EPRI performance prediction  !

methods for estimating thrust and torque requirements S Reviewing failure data and determininig aging rates for establishing pump and valve IST intervals  ;

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E Anticipated Products and Schedule e Report on effects of corrosion on friction factor 1998 9 Report on thermal binding / pressure locking 1997 9 Report on motor-actuator efficiences 1997 9 Relationship between unavali. and IST interval  ;
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) United States Nuclear Regulatory Commission EQ OF ELECTRIC CABLES E Regulatory issues -- Why is EQ a concern?

O Stemming from license renewal activities, staff determined

that differences between qualification requirements for older plants and new plants should be reassessed for current operating plants O SNL test results raised questions with respect to accident ,

performance capability of certain artificially aged equipment 9 Preliminary scoping assessment indicated that inadequate EQ could be a significant contributor to core damage frequency 9 Fire protection reassessment report concluded that EQ should be reviewed to identify and correct any programmatic weaknesses that may exist j 51 i 9 9 9  !

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EQ OF ELECTRIC CABLES E NRR Task Action Plan (TAP) developed to address EQ G RES program providing data in support of NRR TAP 9 Focussed on EQ of electric cables

  • Instrumentation and contro cables initially
  • Power cables also of interest but had to limit initial program due to budget and time constraints l

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\,...../ i EQ OF ELECTRIC CABLES i E Anticipated Products and Schedule l

O Publish EQ literature survey Completed O Complete LOCA testing and evaluation of condition monitoring methods 1999 9 Publish final technical reports 1999 S Provide guidelines on EQ to NRR 1999 9 Recommend appropriate changes to IEEE stds. 1999 9 initiate revision to Regulatory Guide and Rule, if warranted 2000 54

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ASSESSMENT OF AGED AND DEGRADED i

STRUCTURES AND COMPONENTS E Regulatory issues G To date,65 instances of containment degradation

  • 31 steel and steel hners
  • 34 concrete structures I O More are expected to be found with implementation of ASME Code Section XI, IWEllWL
  • Significance of instances will have to be assessed by NRC e Reliable methods for predicting capacity of degraded j containments are not available to assess capacity of containments in a degraded condition 55 O O O

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ASSESSMENT OF AGED AND DEGRADED STRUCTURES AND COMPONENTS E Current Emphasis 9 Data collection and evaluation of actual degradation instances 9 Development and calibration of statistical and deterministic methods to assess containment capacity 9 Limited investigation of special topics:

  • Effects, if any, of tendon grease intrusion into containment Concrete  !

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ASSESSMENT OF AGED AND DEGRADED STRUCTURES AND COMPONENTS E Anticipated Products and Schedule 9 Degradation Database 1998-99 9 Statistically-based remaining capacity pred. end 1998 9 Deterministic remaining capacity pred. end 1998 S Prelim. assessment of grease leakage effects mid-1997 59 e - - - - - _ - _ _ _ - -

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I USNRC'S AGING RESEARCH PROGRAM E Program is broad-based -- analytical and experimental research E Strong user office support --including exploratory tasks E Program designed to address both operating plant and license renewal issues E Program structure and focus addressing key regulatory issues  !

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HUMAN PERFORMANCE PROGRAM PLAN f

A Presentation to the Advisory Committee on Reactor Safeguards i

Cecil O. Thomas, Chief '

Human Factors Assessment Branch December 5,1996 t

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e Consists of representatives of NRR, RES, AEOD, NMSS and the regions e Responsibilities include:

coordination of human factors / performance activities development of human factors / performance program plan e Meet frequently beginning in January 1995 and semiannually following issuance of plan l

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HUMAN PERFORMANCE PROGRAM PLAN - REV. O I

I e Developed by HFCC; issued by HFCC chairman in August 1995 o Contents:

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i RESPONSE TO O.UESTION 1 AND NOTE CONCERNING USE OF ROADMAP AND HUMAN PERFORMANCE MODELS A Presentation to the Adv;sory Committee on Reactor Safeguards Cecil O. Thomas, Chief Human Factors Assessment Branch December 5,1996

O O O '

HUMAN PERFORMANCE PROGRAM PLAN DEVELOPMENT e Framework for plan developed at facilitated workshop using panel of human performance experts e Plan's goals and objectives developed using systematic approach

, derived from Agency's mission to protect public health and safety e Plan's activities that support goals and objectives are comprehensive and consistent with Agency's organizational functions and resources i

I

4 o o o-l HUMAN PERFORMANCE PROGRAM PLAN CONTENTS AND MAINTENANCE e Mission statement, goals and objectives

  • Ongoing, planned and recommended activities e Relative priorities, responsible offices and completion schedules e Need for update and refinement considered semiannually

t I

/p .m%. ,

( ) United States Nuclear Regulatory Commission

~*"'

/

Human Performance Program Plan MISSION:

Ensure Saf'ety of' ]

Facilities i

s ., I i

Goal 1 Goal 2 Goal 3 Assure personnel l Innpirically based Adequate NitC saf'ety pert'ornianec  !

require:nents resources Objective 1.1 Objective 2. I Objective 3. I Personnel _

Assessinent ol' _ Coordination qualitications and huanan stal' ling periorinance Objective 1.2 Objective 2.2 Objective 3.2

~

I Iurnan-systern _

Use ol' hurnan _ Qualified NitC in ter t' ace peribrinunce personnel in t'orinat ion Objective 1.3 Objective 2.3 Objective 3.3 Or ganizational _

II:npirically _ Adequate practices based 1IltAs fiscal i

resources Objective 2 4

~

Itescarch t'or technical basis l

o o o-l HUMAN PERFORMANCE PROGRAM PLAN LIMITATIONS

  • Relatively short timeframe reflects uncertainties in Agency's mission and strategic plan e Activities reflect Agency's limited regulatory authority in human performance areas e Activities reflect Agency's declining staffing and budget e Activities reflect Agency's reactive approach to events and new technology e Plan reflects limited use of human performance models--used in selected activities

i i

4 i P Inspection ~ . Exsrience frop

. IndustE... -=-:- l Experience:  ?.Other Settingsy l I .

- L1.1.2,1,1A,- 2.4.6,2.4.7,~'

~

2~2'1-2*2*5- -

=~ 1.2.10,2.1.2 13.1:5 ~-

) i_. 7 N i 7 ,__ .i T l i

i i

i s.

HPPP .

l l ,

A Roadmap l

d.h i x >

YES l um j sea -en er ; _ . NO l

' q '. ,. bl67 7,,)

' Q , ,y~ 7 '

v

YES

! YES

YES

]

f

. . . . . , v I

i g; Prepa.....re : ._ . . . .

! ifGuidancep Deve.. .lopTechnicall

!  !$5.1','2l13,\ . . . .Basist . . . . .

lig ^ 1.1.6-1.1.8,1.2A-1.2.9ll 4

.1.3.2,1.3A,2A

's T I

Y N iy 1 a .. . .

Implement 3 l . Guidance J
1.1.2,1.2.2,1.2.3,7 j 1.2.10.2.1.2 4 \ 1 1

! 5A .

3 i

O

)

) BRIEFING ON THE NMSS HUMAN FACTORS PROGRAM

TO THE ACRS i

3 i

i i

i lO 1

4 i

i l

l Dennis I. Serig, Ph.D.

' Senior Human Factors Analyst NMSS/IMNS/IMOB i

1 i

$ \> December 5. 1996 1

j .

4' HUMAN FACTORS IN NMSS iO 4

i i

1 i

l i.

4 o Prograni initiated in May 1988 i

! o Limited resources Broad responsibilities 4

Q o i o Need to prioritize activities j o Need to leverage resources where possible i I I

2 1

l l December 5. 1996 2 4

HUMAN FACTORS IN NMSS I O

o Priorities o Teletherapy misadministrations o Remote afterloading brachytherapy misadministrations O o Nuclear pharmacies and nuclear medicine misadministrations o Industrial radiography personnel overexposures o Safeguards personnel training December 5. 1996 3

HUMAN FACTORS IN NMSS o Products / achievements o AAMI/ ANSI standard on Humanfactors engineering guidelines and preferred practices for the design of  ;

medical devices \

o Reduction in misadministrations attributed to nuclear pharmacies o Flexibility in licensees training plans to assure security personnel have necessary knowledge, skills, and abilities Hum n fact rs ev lu ti ns f teletherapy and remote O afterloading brachytherapy o Database of nuclear medicine misadministrations (1989-1990) o Database of all misadministrations (1992-present) o Findings incorporated into books, inspection reports, and newsletters o Training of inspectors o SRP for fuel cycle facilities December 5. 1996 4

l

! HUMAN FACTORS IN NMSS l

O I

l

! o Ongoing activities j o Work with AAMI on revision of Human i factors engineering guidelines andpreferred practices for the design of medical devices  ;

! o Work with RES on follow-on activities related j to human factors evaluations (i.e, feasibility of i using task network modeling for regulatory i applications). ,

! l

! o Briefings to the medical community, ACMUI, j

! other regulators, and the human factors

O j

community on the method and findmgs of the human factors evaluations of teletherapy and j remote brachytherapy l o Briefings to the medical community, other regulators, and the human factors community on the use of event databases for identifying human factors problems and on the results of that use o Daily review of events o Participation in event follow-up 1

December 5. 1996 5

l- -

l HUMAN FACTORS IN NMSS O

o Conclusion l

o NMSS has an active ongoing human factors

{ program i

o That program began from a starting point well

behind the starting point for the human factors
programs associated with reactors l o The program's research and data based .

approach has succeeded in identifying,

Q prioritizing, and evaluating alternatives for l resolving the human factors problems

! experienced by NMSS licensees i

j o Pending Commission direction on the future of l the medical program, NMSS's human factors l program is in a position to assist in revision of 10 CFR 35

! o There is evidence that NMSS's efforts have l resulted in an appreciation for the need of

, human factors in medicine i

l s December 5. 1996 6 1

_..__mm._.. ..___.~~m._. ..__.m.-. - _ . .__ _ _ .. <. _ . _ -____ _ .___. ____

l- +

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i Sc & ANSI 3 5 Part 55 ES-301-3 FS-604

-+ 10 CFR 55 -

Comments RG 1.149 Scenario Design Standard Attchmt 3 Summary Checklist B.1.C  !

=- l '

l .

" ES-604-1 f Verification Scenario  !

I NRC e NUREG Checklist i

" Form 474 1262 l Simulator >

l g.

Validation Acceptance r--

f r Periodic [

l o NRC Testing ,

-, NUREG -

Simulator ,  ;

1258  :

Evaluation n i Simulator Trawwng Fidelity  :

"-Testing, & E .a n  : - t Fee e ack  : i o

i Plant Content --

Difficulty ^

Mods l( Validity Programs

. Exam .

Training i

'b L

t I

t f

i i

9

. - _ _ _ m.-________________ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ .______m____._._.m_.m__.__m__ _ _ _ _ _ . _ _ _ _ . _ _ . _ _ _ _ _ _- -

-m- --__..____vm-, -- m_,w..em____m_-___--_______-___________n + --er_ _ _ _ _ _ __

i f  %<4,-

A,

s: "El rol 3

%N4 4***

HUMAN PERFORMANCE EVENT DATABASE AEOD Staff Presentation to the ACRS December 5,1996 i

1  !

i l

1 i

o AEOD Reports on Human Factors "

V Date Title No.

03/95 Reactor Coolant System Blowdown at S95-01 Wolf Creek on September 17,1994 07/95 Operating Events With Inappropriate Bypass E95-01 or Defeat of Engineered Safety Features 10/95 Review of National Transportation Safety Board's T95-03 SL , Study, NTSB/SS-94/01, "A Review of Flightcrew-involved, Major Accidents of U.S. Air Carriers,1978 Through 1990."

05/94 Review of Mispositioned Equipment Events T94-02 02/93 Human Factors Aspects of Boiling Water Reactor E93-01 Reactivity Management Events During Power Operations 12/92 Operating Experience Feedback Report - Human NUREG-1275, j Human Performance in Operating Events Vol. 8 (C92 01) 03/88 Significant Events That involved Procedures S801 05/87 Occurrence of Events involving Wrong Unit / Wrong T705 Train / Wrong Component - Update Through 1986 05/86 Events Resulting From Deficiencies in Labeling T604 and Identification Systems 09/86 Cccurrence of Events involving Wrong Units / Wrong T607 Train / Wrong Component-Update Through June 1986 12/85 Loss of Safety System Function Events C504 01/84 Human Error in Events involving Wrong Unit or Wrong S401 Train O

O O O DEVELOPMENT OF THE HUMAN PERFORMANCE EVENT DATABASE (HPED) e 1980's: AEOD began studies of human performance during events e 1990: Began multidisciplinary team studies of human performance INEL provided technical assistance in studying the human factors On-site studies performed in accordance with a protocol Twenty event studies completed from 1990 to 1993 e 1992: Human performance database initiated Working group representatives from AEOD, NRR, and RES i'

e 1993: Specified database content and authorized INEL to construct

, database e 1995: Delayed work because of budget cuts e 1996: Resumed work and expanded scope i

3 i

O O O .

ORIGIN OF CODED INFORMATION IN HPED AITs/IITs HPS STis LERs Total Events 1990 9/1 7 -

14 31 15 1991 15/1 6 -

16 38 21 1992 11 3 -

11 25 12 1993 17 4 2 20 43 25 1994 3 0 1 3 7 4 1995 2 0 4 1 7 6 1996 5 0 0 4 9 5 62/2 20 7 69 160 88 AIT - Augmented Inspection Team report HPS - Human Performance Study report IIT - Incident Investigation Team report STI - Special Team Inspection report 4 ,

l

O O O . r HUMAN PERFORMANCE EVENT INFORMATION Contains information on the event and on human performance factors / issues that influenced performance by crews and individuals

  • Human Factors Engineering / Human-System Interface e Work Environment e System Design and Configuration l e Procedures
  • Training e Communication and Coordination e Supervision e Management and Organization  ;

e Fatigue / Stress / Workload e Individual Personnel issues (e.g., situation awareness) f 5 i

O O O .

HUMAN PERFORMANCE EVENT INFORMATION (CONT.)

Database Structure has 54 Fields to store human performance and other general event information, including, o Event Summary and Classification e Time and Date

  • Operating Mode and Power Level e Preceding or Subsequent Subevents e Numbers, Titles, and Types of Personnel e Whether Licensed and Number of Years o Personnel Training e Shift Rotation and Duration e Activity Type and Time on Shift 6

O Q, O .

Table 1 D_istn_but_io.ns. of event time __s.pe_r two-hour period for a sample of events and AITs '

i i i -

l

][_ _ ~[ _] ]_

2-Hour Time Penod ~ ~ [_l

l (24-hr clock) -~~

+

{ l I

~

All Events AITs f f i'  !

>0000 6 4 j f f

>0200 4 3

{

--_ _ _ l l I

,,,,, , , i .

>0600 3 1 i

>0800 10 5 't f r

>1200 4 3

  • I  !

>1400 6 4 I

>1600 4 2 {

! j

>1800 3 2 j

>2000 3 2 6 3

{

>2200 +

lT

~ ' ~~~~~

_ _:. :X -

f Distribution of Event Times Per 2-Hour Time Period 10 9

8

$7

$6- -

o 5 4- - i 5 3 -

2-1 -

0 + -

[5 An Events l

>0200 >0400 >0600 >0000 >1000 >1200 >1400

>0000 >1600 >1800 >2000 >2200 [ WAITS j 2-Hr Time Period I

i Table 2

. . 00 Table 2. Contnbuting Factors for a Sample of AIT and HPS Reports O Contnbuting Factors ,

AIT (of 40 Total) :HPS (of 20 Total)i  % of AITs i

l  % of HPSs Management & Organization _ 33 [13 '82.5 65 l Procedures '26 11 9 65 !95 l System Design & Configuraticn '23 9

[57.5 !45 Supervision / Command & Control 17 16 l42.5 t80 Human Factors ;16 ,14 '40 17 0 Training l16 !16 :40 :80 Individual (Personnel) Factors 15 .13 13 7.5 65 l Communications 14 41 4 135 i70 l Fatigu.e/ Stress / Workload 4 9 i

!10 45 j Work Environment !3 2 17.5

' i10 i

l j Contributing Factors for AIT and HPS Event Studies l

Work Enwonment l

Fatque/ Stress, Workload

+

1 l Communicatens f iO l

Individisal(Personnel)

Factors B

Training r

1 g Human Factors I I l Supervison/ Command a Control System Desgn &

Confguraten Procedures h

Management &

Organizaten I

l E% of HPSs 0 10 20 30 40 50 60 70 80 90 100 E% of AITs _

Percent (%) a Contributor O

, I l

hoe 5 .

l l

l l

4 Reactor Status During AIT Events  !

I  ;

! j K hot shutdown L M Maq f [

3 2%

l i

4

)

j C routme start- rMoe sta%  ;

l 5% $

i '

i i f F power operatons, load change $f ,f

5% ,

t Mi' i$/.

?- i

+

s ,

<s

. I coid shutdown

'l i 14%

14.

l inti' g:g E power operatons. steaoy-state i j

c..x 43%

i -1;M,7-%

I l ,

I

i t

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! 1 H refWM i j 24%

i l

I

. e i

i 1

.i 0

. . . . . - . - . - . - _ . - . - . . ~ . . . . _ . _ - . . . . . . ~ - - - . . - . - . - - . . . . . - . -

O O Tsv.e 5d O: i Table 5d  % of a S. a_mple of AITs (40) for wh.. ic_h_ _certain fac__ tors we_re_found_ _to b_e .co.. n_tnbutors (S.o.rted by %_F'O E_ve_nts_)__

1

. _ _ . . . _ J Contnb_uting Factors Power Operations ._ __ Cold SD and Refuel _  !

~IPO[Fia~ction ~ (CS&R) Fraction  % PO Events i~ ~~ '% CS&R Events t

~

~

Management & Organization 15/20 14'/i6 75 % 88% .

System Design & Configuration ' ~

~' ^~

15/20 6/16 75 % 38 %

Procedures _ _ 11/20-_-_-__. _ _ 11/16' .. .

55% _.. 69%

~

Individual (Personnel) Factors ~~

8/20 4/16 40% ~

~-~25*4

~ ~ ~

SupervisionTComenand & Control 8/20 8/16

' ~

40% ~50 %

~

~ ~ ~

8/20

~'

Training

~ ~

4/16 40% 25*5

~

Commuriicat' ions ~--'~~ 3/20 8/16 15% 50*A~~~~~

Work Environment 3/20 0/16 15% 0%

Fatigue / Stress / Workload ___

0/20 2/16 __ 0% _ _ _ _____13%_ _ _ j Percent AIT Events that Resulted from Certain Contributing Factors i

Fatgue/ Stress. Workload ME i

Work Environrnent Comrnuncatens j Training m supervisen/Comrnand & Control ' N j indmdual(Personnel) Factors m f Human Facters

~

Procedures l

System Desgn & Conrguraten M . mm Management & Organizatro M ,

E % CS&R Events  !

0% 10% 20 % 30 % 40 % 50% 60% 70 % 80% 90%  !

% PO Events Percent i

to i

__________.j