ML20195B610
| ML20195B610 | |
| Person / Time | |
|---|---|
| Issue date: | 05/26/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3079, NUDOCS 9906020072 | |
| Download: ML20195B610 (130) | |
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h:buut ACASI3079 h OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION
- ADVISORY. COMMITTEE ON REACTOf SAFEGUARDS
Title:
MEETING: THERMAL-HYDRAULIC.
PIIENOMENA.
TRO4 (ACRS:
RETURN ORIGINAL 1 TO BJWHITE o4 j M/S T-2E26 '#
1 415-7130 ,
THANKS! 'k; -.
- O 1
- Docket No.:-
I Work Order-No.: ASB-300-798 i
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i LOCATION: Rockville,MD 1 i
L DATE: Wednesday,May 26,1999 PAGES:1 - 127
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b DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MAY 26, 1999 The contents of this transcript of the proceeding r~
of-the United States Nuclear Regulatory Commission Advisory (j Committee on Reactor Safeguards, taken on May 26, 1999, as reported herein, is a record of the diccussions recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
(~'\
V
1 1 UNITED STATES OF AMERICA r~s
( 2 NUCLEAR REGULATORY COMMISSION
)
3 ***
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 ***
6 MEETING: THERMAL-HYDRAULIC PHENOMENA 7
8 U.S. Nuclear Regulatory Commission 9 11545 Rockville Pike 10 Room T-2B3 11 White Flint Building 2 12 Rockville, Maryland 13 14 Wednesday, May 26, 1999 t\
(,) 15 16 The subcommittee met, pursuant to notice, at 8:30 17 a.m.
1 18 MEMBERS PRESENT: ;
i 19 GRAHAM B. WALLIS, Chairman, ACRS 20 THOMAS S. KRESS, Member, ACRS 21 ROBERT L. SEALE, Member, ACRS 22 23 24 25 Im\
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1 PARTICIPANTS:
.2 JOSEPH DONOGHUE, NRR 3 R. CARUSO,-NRR 4 N. LAUBEN, RES 5 R. LANDRY, RSB/DSSA/NRR 6 J. WERMIEL, RSB 7 C. DOUBT, EEIB/NRR 8 C. ESTRADA, Caldon, Inc.
9 P. BOEHNERT, NRC 10 11 i
12 13 14 15 16 17 18
'19 20 21 22 23 24 l l
25 I i
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1 PROCEEDINGS
()
i 2
[8:30 a.m.]
-3 DR. WALLIS: The meeting _will now come to order, l
4 This is a meeting of the ACRS Subcommittee on l
5 Thermal-Hydraulic Phenomena. I am Graham Wallis, the 6 Chairman of the subcommittee. ACRS members in attendance 7 are Drs. Thomas Kress and Robert Seale. I 8 The purpose of this meeting is to review the
\
9 proposed rule to revise Appendix K of 10 CFR, Part 50 to 10 allow small cost beneficial power uprates, also to review
, 11 the status of the RETRAN-3D transient code review, and {
1
- 12 further to discuss the proposed ACRS structured discussion i
13 on development of code review guidelines.
14 The subcommittee will gather information, analyze '
() 15 relevant issues and facts, and formulate the proposed 16 positions and actions as appropriate for deliberation by the 17 full committee.
18 Paul Boehnert is the Cognizant ACRS Staff Engineer 19 for this meeting.
l 20 The rules for participation in today's meeting !
21 have been announced as part of the notice of this meeting i
22 previously published in the Federal Register on May 3, 1999.
l l
23 A transcript is being kept for a portion of the meeting and 24 will be made available as stated in the Federal Register i
25 notice.
l l
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1 It is requested that speakers first identify
!II 2 themselves and speak with sufficient clarity and volume so V
3 that they can be'readily heard. I 4 We have received no written comments or requests 5 for time to make oral statements from members of the public. j 6 I have no comments to make, so we will proceed with the 7 meeting and I call up Mr. Joseph Donoghue of NRC's Office of 8 Nuclear Reactor Regulation to begin.
9 MR. DONOGHUE: Thank you. Good morning. As you 10 heard, my name is Joe Donoghue and some of you may remember 11 me from some of the steam generator rule committee meetings 12 that were held, and you'll be relieved to know, as I am, i 13 that I am not here to talk about steam generators at all but 14 Appendix K revision.
, ) 15 We'll get into the why, a little bit of the how, 16 and some of the background of what we are doing and a little I
)
17 bit of the when we intend to do the rule change but first a 18 little bit of the why.
19 Basically we are intending to reduce the burden on 20 licensees by changing an analysis requirement -- just one i i
21: analysis requirement of Appendix K be parallel. As you i
22 know, 102 percent is what is stated in the rule.
23 We think the biggest advantage to licensees will 24 be giving them the ability to pursue a power uprate. It ;
25 will be a small power uprate obviously that they would be l'
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5 J l' able to use, but there's also other changes they could make
() 2 3
outside of a pcwer uprate and we will talk about that in a little while.
4 Another. goal.of ours is to avoid a large number of 5 exemption requests. As you will see in a few minutes, there 6 is already one exemption that has been granted, for Comanche 1
7 Pee'. and we know there's other licensees that are 8 interested in the same sort of relief, so changing the rule 9 in this small way right now is a good idea just from an 10 efficiency standpoint.
11 As I mentioned, some licensees are interested in 12 using instrumentation, instrumentation upgrades, to affect 13 the accuracy of their thermal power measurement. The first 14 thing that we have seen is a feedwater flow instrument
) 15 that's produced or marketed by Caldon, Incorporated, and 16 there's other ones I have listed at the bottom here -- ABB 17 Crossflow System, which they have talked to us about in at 18 least one meeting and we know they will be in here shortly 19 again to talk to us about it.
20 We know of at least nine licensees -- I believe 21 it's almost 20 plants -- that intend to at some point use 22 the Caldon instrument and there will be more that want to 23 use the Crossflow system I would suspect.
24 DR. WALLIS: Excuse me. Now a key issue here I 25 seems to be how accurate is this instrument. Are you going I
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6 1 to be the person we ask about that, or are representatives 2 of.Caldon going to be here?
3- MR. DONOGHUE: I believe there was going to be a 4 representative from Caldon but I don't see him.
5 MR. CARUSO: Herb is not here yet. He is the 6 technical person.
7 MR. DONOGHUE: However, I mentioned these as 8 pretty much examples --
9 DR. WALLIS: Who is prepared to answer technical 10 questions about how it works, how well-it works, how 11 accurate it is, and so on?
- 12. MR. CARUSO: We weren't prepared --
13 MR. WERMIEL: The Instrumentation and Control 14 Branch that I used to be the Branch Chief of was involved _in 15 the review of the accuracy of those instruments and they did 16 do an assessment of it, but I don't see them here.
17 If you would like, we can try to get somebody here 18 who was involved in that review to talk about the accuracy.
19 Would that be useful?
20 DR. WALLIS: Well, I suspect that we may be more
{
21 interested in that than in the history of what everybody 22 did.
23 MR. WERMIEL: Okay. What this presentation was 24 geared to was the actual rulemaking effort but I would be i 25 more than happy to try to get ahold of those people. Let me l
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() -2 DR. WALLIS: Well, I know for myself I am much 1
- 3. more interested in the technology and whether it is good l 4 enough, not the details of rulemaking.
5 MR. WERMIEL: I perfectly understand. Let me see 6 if we can find out where those people are and we will try to 7 get one of them over here. i 8- DR. WALLIS: Thank you. Does the committee agree 9 with that or is the committee very interested in all the 10 rulemaking?
11 DR. KRESS: Well, I think we are interested in 12 both.
13 DR. WALLIS: I think we are interested in both, 14 but we certainly are interested in the technical side.
() 15 DR .. KRESS: Yes, I think we are definitely 16 interested in the technical stuff, but I am just as 17 interested in the rulemaking part.
18 DR. WALLIS: I am glad you are.
19 MR. DONOGHUE: Again I apologize for not being 20 prepared for that. We knew of these two instruments. One 21 has been reviewed -- just the Caldon instrument. We are too 22 early in the process of dealing with ABB to be able to make 23 any judgments on that, but the rulemaking is not geared to 24 any particular type of instrument or any particular way of 25 reducing the power measurement uncertainty.
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- L These are just the ones, the avenues we know 2 about.
3 DR. KRESS: Does the rulemaking say anything about 4 if your instrument for measuring the flows and the 5 temperatures -- that's involved too, I guess --
6 MR. DONOGHUE: Right.
7 DR. KRESS: --
have a certain degree of accuracy?
8 Then that means you can uprate power by so much? I mean 9 does it show the relationship between the two at all?
10 MR. DONOGHUE: I will show you the proposed 11 wording, but all we are allowing right now is the 12 opportunity for licensees --
13 DR. KRESS: Then they have to come in and show 14 their case later?
() 15 MR. DONOGHUE: If they want to change their 16 technical specifications, but if they want to change their i
17 ECCS analysis they have to be able to demonstrate what the q l
18 accuracy is --
l 19 DR. KRESS: And if they want a power uprate, they 20 have to come in? i l
21 MR. DONOGHUE: Power uprate is a tech spec j 22 amendment, right, and we will get into that in a little 23 while.
24 Now I have a couple of cartoons, just to show you 25 basic, very basic, differences between the two systems, and i
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1 9 l 1 this was as technical as I intended to be, but when we have 2 another staff member over here, they can get into a lot more f~))'
3 detail.
4 This is just to show you that the Caldon j
5 instrument -- they all it a time-of-flight measurement --
6 where a component of the ultrasonic signal is in the 7- direction of flow and it's a time difference. There's a 8 signal shot in one direction and then in the other and it 9 also measures temperature, but that difference is what gives 10 you the flow rate.
11 DR. KRESS: Is that a difference between two 12 numbers to get a very small one?
13 MR. DONOGHUE: Very small compared to what? I.
14 think the other person that's going to show up hopefully J
() 15 will be able to give you a lot more information about that.
16 DR. KRESS: 'Your measure the difference between 17 the time-of-flight?
18 MR. DONOGHUE: Right.
19 DR. KRESS: And you are subtracting one from the 20 other?
21 MR. DONOGHUE: Right.
22 DR. KRESS: To get a_very small difference -- two 23 large numbers to get a small difference.
24 MR. DONOGHUE: Right.
25 DR. KRESS: I just wanted to be sure I understood
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10 1 you.
2 MR. DONOGHUE: But I don't know how small relative
(}
3 to other ultrasonic methods or --
l 4 DR. KRESS: Yes, and you know, that's important in 5 determining the uncertainty.
l 6 MR. DONOGHUE: But again, when pursuing the rule 7 change we are not trying to tie it to any particular method.
! 8 We are just discussing these as reasons why we are doing the 9 rule now.
l 10 DR. KRESS: Okay.
11 -MR. DONOGHUE: That's all I was really intending 12 to talk about. One thing to remember is that for this 13 system the transducers are mounted in a spool-piece in the 14 line. They are actually a part of the feedwater system 15 and --
16 DR. KRESS: Is this sort of a general regulatory ;
i 17 policy that if you could show you reduced the uncertainties i 18 in your evaluations you ought to have some relief somewhere?
19 MR. DONOGHUE: Well, I hope to talk about that in I 20 a little while.
21 DR. KRESS: Okay.
22 MR. DONOGHUE: Kind of the background, why we 23 think this is something -- a change that we can pursue, but 24 yes, if we have a requirement in the rule that covers some 25 uncertainty that was based on some unknowns, and as people ANN RILEY & ASSOCIATES, LTD.
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() 2 3-DR. KRESS:
MR. DONOGHUE:
It sounds like a good idea to me.
Well, so far -- we're only three or 4 four slides into it.
5 The Crossflow system, the basic differences are 6 the transducers are mounted perpendicularly to the flow and 7 it is not a time of flight measurement, but they call it a 8 cross-correlation measurement where --
9 DR. KRESS: Does it measure temperatures?
10 MR. DONOGHUE: I don't believe this measures 11 temperatures. The other system does. I don't believe this 12 one does. What it does is apparently the signal changes due 13 to flow change -- I guess turbulence that is going by one 14 set of transducers and the time difference, it's able to
() 15 compare those signals from one set of transducers to the 16 other and is able to come up with a flow rate. That is as 17 much as I know about it.
18 DR. KRESS: The fluctuations you get at this one 19 here, fluctuations in something like pressure or 20 temperature, transmit downstream and they fluctuate in a 21 correlated matter with the ones down here.
22 If you correlate them, then you can move -- you 23 get a time difference by moving the correlations together. !
l 24 MR. DONOGHUE: I have a very basic understanding 25 of it. Like I say, we have met with the licensee, but we I
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12 1 don't have a topical report on this yet. We just know that
() 2 3
they.are aggressively pursuing having exemption requests based on this technology -- I 4 DR. KRESS: It's probably more accurate than the 1
l 5 time-of-flight measurement. I I
6 MR. DONOGHUE: Well, maybe in principle but one i
l 7' thing I was' going to get to.is that this system, unlike the 8 other Caldon instrument, is a clamp-on system. It is l 9 mounted externally to the pipe. From what I understand, the 10 Instrumentation Branch has told me that that inherently 11' leads to some more accuracy, so -- l l
12 DR. KRESS: Because -- it's probably a temperature i 13 measurement or vibration measurements. It could be lots of 14 measurements -- anything that fluctuates. l
() 15 MR. DONOGHUE: Right.
-16 DR, KRESS: But if you are clamping it on, it's i
17 not looking at the stream directly, it does get diffused and 18 it's harder to use so --
19 MR. DONOGHUE: Now one basic thing that -- if j i 20 Cliff is available, I don't know -- l
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21 MR. WERMIEL: This is Jared Wermiel again. I 22 called over and we are trying to get Cliff Doubt, who spent 23 quite a great deal of time evaluating the accuracy and the 24 technology involved in both the Caldon meter and spent some 25 time already looking at the Crossflow meter, even we don't
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13 1 officially have that in the review.
()* 2 .I hope he can be found and can come over to talk 3 to you about what he has done.
4 DR. KRESS: ' Great.
5 DR, WALLIS: I guess we have two basic questions.
6 You were going to address the first one, and the first one 7 is if you.have an instrumentation system,;whatever it is, 8 which reduces the uncertainty so that you don't need 2 9 percent margin, you only need one because your uncertainty 10 is less than 1 percent, let's say, that is the principle you 11 are going to talk about. In that case you can change the 12 application of the rule.
13 The other question is do the two candidate 14 instrumentation systems have the requisite accuracy. That O(j 15 is the second question, and you are going to address the 16 first one I take it?
17 MR. DONOGHUE: That's correct. i 18 MR. WERMIEL: That's correct.
)
19 MR. DONOGHUE: And we treated the license -- I'm I 20 sorry, not the license amendment, but the exemption request 21 the same way. The reviewer dealt with the instrumentation.
22 Okay, this is a little bit of the process 23 background. We presented a rulemaking plan to the 24 Commission earlier this year. A month later we were told to 25 proceed with the rulemaking. At the same time, because of l
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14 1 the licensee interest in being able to do this, we were told
(~} 2- don't delay any exemption requests that may be presented )
v 3 because of the rulemaking. We weren't to use that as an 4 excuse, i 5 The CRGR was briefed in March on the basic 6 approach that we are using and they had no adverse comments.
7 They wanted to hear from us after the public comment period.
8 This may be somewhat of a review, but I will 9 quickly go through here. Section 50.46 requires that the 10 licensees do an ECCS evaluation either on a best estimate 11 basis or so-called best estimate basis.
12 We are using Appendix K requirements and, as you 13 know, Appendix K has several conservativisms built into it.
l 14 The one and two percent requirement is one of them.
-w l i
s,) 15 -When we looked, we didn't find other regulations 16 that specify a. power level. This is the only place that a 17 specific power level is mentioned. However, a lot of SRPs
.18 - and at least one Regulatory Guide either reference Appendix 19' K or require 102 percent or require 102 percent or some 20 other justifiable option, so if a licensee -- I'll talk 21 about this maybe.a little more later -- if a licensee wants 22 to pursue this change, they are going to have to look 23 through their licensing basis to see where else they have 24 depended on this 102 percent.
25 A little bit on Appendix K history. The reason
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15 1 why --
() 2 3
DR. WALLIS: That's strange, because the LOCA of course is after, usually after there is a power trip, so as 4 far as the history of this power and how it affects decay 5 heat and so on, it really matters during the LOCA.
6 DR. KRESS: Yes, it's almost linear. Your two 7' percent there is two percent in the decay heat.
8 DR. WALLIS: Well, if you operate for some time at 9 two percent. If you just have little spike it doesn't make 10 any difference.
11 DR. KRESS: Yes, I think the assumption is that 12 you operate fully at --
13 DR. WALLIS: For a long time.
14 DR. KRESS: -- over a long time to reach
() 15 equilibrium.
16 DR. WALLIS: It is really the effect of this on 17 decay heat, I guess.
18 DR. KRESS: Oh, definitely.
19 MR. DONOGHUE: As a matter of fact in the 20 statement of considerations for the rule, it lumps together 21 the 102 percent requirement and the decay heat discussion, l 1
22 and there is a little bit, not in the statement of 23 considerations itself but I think in some of the hearing 24 transcriptions or some of that material that talks about 25 some amount or portion of decay heat that is attributed to I
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1 the'102 percent. It is mostly an estimate from what I can
) .-
O 2 tell.
u V 3 But what we did, we wanted to look through the 4- Appendix K history to see if we could find a clear basis or i
5~ whatever the basis might be, for the 2 percent and as I said !
6 we looked through the ECCS hearings themselves, looked at 7 the statement of considerations for the rule and really 8 didn't find a clear basis laid out, although it was 9 discussed again with the heat source considerations.
10 We also looked --
11 DR. WALLIS: So there is no quantitative arguments 12 and rationale for two percent? Someone just said let's take 13 two percent and put it in our rule?
(
l 14 MR. WERMIEL: Yes.
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Yes, .that's essentially the (f 15 way it appears. If it was quantitatively done, it wasn't 16 written down anywhere you could find it.
17 DR. KRESS: Well, that is the nature of these 18 deterministic rules.
19 DR. WALLIS: Yes. I
! 20 DR. KRESS: The question is what does that have to i
21 do with risk. It's hard to say. You have to make another 22 analysis for that. I l
23 MR. WERMIEL: Also, at the time risk may not have 24 been a consideration. .
l 25 DR. KRESS: It probably wasn't. j i
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3 17 1 MR. WERMIEL: It was probably a case where --
() 2 3 minds.
DR. KRESS: It was probably in the back of their 4 MR. WERMIEL: Exactly. Remember what was going I 5 on. You know, here was a time when it was unclear what the i 6 performance of ECCS systems really was, so in order to 7 properly provide what was felt to be an appropriate 8 conservatism and additional margin as necessary to provide 9 Defense-in-Depth, a value was picked.
10 DR. KRESS: Yes. That is the nature of design 11 basis accidents. That's how you do them.
12 MR. DONOGHUE: And what we tried to do after 13 looking at the original rule --
14 DR. WALLIS: Very interesting. The rule is made
(/ 15 on the basis of someone's guess and then very rigorous, 16_ lengthy analyses are required to meet that rule.
17 MR. WERMIEL: Oh, yes, absolutely.
18 DR. WALLIS: It seems a strange balance of effort.
19 MR. WERMIEL: Yes, it was a very different time.
20 DR. SEALE: That's sort of the relationship 21 between God and Moses.
22 [ Laughter.]
23 DR. WALLIS: Which one was the engineer? Please 24 go on.
25 MR. DONOGHUE: Yes sir. We looked at some l ANN RILEY & ASSOCIATES, LTD.
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f 18 1 material that was associated with the consideration of
() 2 allowing best estimate analyses to see if the same kind of 3_ discussion about the 102 percent would pop up. Again it 4 didn't, but what was clear in the original rule material and j 5 in what we reviewed for best estimate bases, the Commission 6 understood that there were a lot of conservatisms built into 7 Appendix K to cover what we didn't know.
8 There wasn't a lot of experimental data that was 9 pertinent when the rule was first written. As that was 10 gained,-as SECY-83-472 talks about, as more data was 11 obtained, some relaxations could be considered. And we 12 think that we're in a position at least for this one small 13 change to do the same sort of thing.
14 Now for the rule revision itself, this is what we
( 15 have proposed so far. The lawyers will not let me nail them 16 down on this, so it might change somewhat, but we just want 17 to show you a small -- how small a change it is.
18 It's really just one sentence in the first 19 paragraph of the rule, and this is where the requirement's 20 laid out, in the very first words of the rule, and we want 21 to add this part here where we talk about being able to use 22 a different power level as long as it can be demonstrated 23 that the uncertainties of the instrumentation in that rule 24 are small enough. That's what it amounts to.
25 Notice there's no requirement --
submittal ,
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L 19 1 requirement -- stated in here. We're not changing any of l 2
} that in the rule at all. What the licensee is going to have 3 to do is if they want to use this, they need to have a i 4 justification available if they're changing the ECCS i 5 analysis. That's one avenue. If they change their ECCS 6 analysis under 50.46 they're going to have to tellJus about l
7 that at least annually. If a power level change is 8_ requested, as we discussed earlier,-that's going to require 9 a tech spec amendment. So they're going to have to 10 have that justification available for us to review at that 11 point.
l Also, if another change to their tech specs might i
12 '
13 be requested, such as by changing the ECCS analysis, they 14 could'maybe find relaxation in pump flow that they've had a
() 15 hard time meeting in tech specs, they could possibly change 16 that tech spec. But again that's going to be something 17 that's going to have to be submitted for review. So most 18 cases when it involves a tech spec amendment the staff's 19 going to have to look at the basis for the uncertainty claim 20 that they're making. If they want to change their ECCS 21 analysis, they will need to have the uncertainty 22 justification available, because if at some point we decide 23 that we need to look at that, they're going to have to show 24 it to us.
25 DR. KRESS: Mr. Chairman?
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b 20 1 DR. WALLIS: Yes.
2 DR. KRESS: Supposedly a licensee has gone through 3 all of the requirements to get his license in the SAR, where 4 he meets all the deterministic design basis accident 5 criteria, and involved in that of course is the power level 6 in a lot of them because it determines after heat and what i
7 temperatures you're operating at. Now this says okay, from I 8 just me. sting the ECCS criteria only, I mean, isn't Appendix l 9 K just for ECCS?
1 10 MR. DONOGHUE: That's correct.
l 11 DR. KRESS: That we will allow you to meet the 12 requirements for your ECCS by possibly reducing the power.
13 I don't see how that relates to a power uprate 14 unless they can also then go into all the other accidents --
() 15 MR. DONOGHUE: Exactly.
I 16 DR. KRESS: In the DBA and show that they still l 17 meet those. i i
18 MR. DONOGHUE: That's why I mentioned that l 19 earlier, is that if a licensee wants to use this opportunity 20 to uprate their power, they need it as a separate step.
21 This doesn't allow them to uprate --
22 DR. KRESS: And the .02 probab3y doesn't show up 23 in a lot of those other accidents. It's just like, you 24 know, any power uprate then. They just have to show they 25 could still meet the regulations.
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l
U l
21 1 MR. DONOGHUE: ' Correct. And there are some
~
2 plants, the SRPs I mentioned earlier, there's a long list of 3 .them, and it's in that SECY paper, a long list, they either 4 require 102 percent if you follow the SRP or some 5 justifiable alternative power lower than 102 percent. If 6 the licensing basis has used 102 percent elsewhere, they're 7 going to have to address that.
- 8. As a matter of fact, right now the exemption for 9 Comanche Peak has been granted, but their power uprate is 10 still under review. And that's one of the issues. We need 11 to understand that.
12 DR. KRESS: So the only automatic part of this is 13 whatever involves the ECCS --
14 MR. DONOGHUE: That's right.
() 15 DR. KRESS: Criteria.
16 MR. WERMIEL: That's correct.
17 DR. WALLIS: Now I'm looking at --
the wording i 18 here is written in somewhat vague legalistic terms.
19 MR DONOGHUE: Oh, boy.
20 DR. WALLIS: Caldon in their report were 21 analytical and they claim that with their instrumentation if 22 one operated at 1 percent of our license power level the 23 probability that due to errors in instrumentation one would 24 inadvertently step over 1.02 times is less than it is with 25 the existing system operating at 1 times the licensee power ANN RILEY & ASSOCIATES, LTD.
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Ix 22 1 = level. So there's actually an assessment of probabilities, and-they talk about one chance in 30,000 or one chance in 3
( 2 3 million and so on and various things.
'4 You could write the rule such that-it says that 5 thou shalt not increase the probability of stepping over 6- some line, but you've written it in vaguer terms and some 7- reg guide or something has to say we will interpret this in 8 some probabilistic way or something. Something has to be 9 followed up to say how you determine whether or not you 10 analytically meet some criterion or not.
11 MR. WERMIEL: I think -- Joe, I think the key to 12 what you just raised, Dr. Wallis, is the term " demonstrated 13 to account for uncertainties." I think that's where we 14 would capture it exactly right. What you've just I think
() 15 portrayed is how they would address the uncertainty-in the 16 measurement, and that's something we would end up reviewing.
17 DR. WALLIS: But you've written this in the vague l
l 18 terms so that you can review all kinds of attempts to deal 19 with uncertainty rather than being prescriptive about it.
20 MR. WERMIEL: I think that's fair. It's possible 21 that a licensee -- pardon me, another instrument 22 manufacturer may come up with a different approach to 23 addressing the uncertainty in their instrument, maybe not a l 24 probabilistic approach, maybe strictly deterministically, I l 25 strictly based on data, and in that case we would want to l
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23 1 make sure the rule accommodated.that.
() 2 DR. WALLIS: To get back to Dr. Kress' earlier 3 question, one could look at all the margins in Appendix K 4 and other regulations and say a lot of them exist because of 5 uncertainties. As we get wiser and smarter, we can reduce 6 uncertainty, therefore we should be.able to reduce margin, 7 as long as the probability of stepping over it is not 8 increased. And that could be a principle applied to many 9 rules, not just this one.
10 MR. WERMIEL: Exactly. And as a mattee of fact, I 11 believe that is part of the thinking that's going into the 12 rebaselining or the thinking we may apply probabilistic risk 13 assessment techniques to the modifications of Part 50 in 14 general. There are recognized right now many areas where
() 15 there are additional conservatisms that the use of PRA and 16 in the considerations that result from the knowledge we've 17 gained from the use of PRA can reduce those margins exactly 18 that way.
19 DR. WALLIS: I don't think this has anything to do 20 with PRA. It simply says that because we can measure more 21 accurately we know when we're getting close to a --
22 MR. WERMIEL: Yes. In this case that's true.
23 DR. WALLIS: And this would apply to other things 24 without -- again without invoking PRA this could be used as 25 a general principle. I think maybe the ACRS or maybe the O ANN RILEY & ASSOCIATES, LTD.
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l 24 1 NRC or_both of us.together can arrive at an understanding of I
() 2 3
whether or not a principle like that is applicable, and then it can be applied across the board.
4 MR. WERMIEL: Yes.
5 DR. WALLIS: I guess we're not to that level
.6 today. ,
l 7 MR. WERMIEL: No.
8 DR. WALLIS: Okay.
9 MR. WERMIEL:
~
We're still dealing with bits and 10 pieces based on what the industry tells us they can deal 11 with.
12 DR. WALLIS: My personal preference is for this 13 _ Committee to deal with matters of principle, and if we can 14 agree and say those are the principles that should be
() 15 applied, then you can go ahead and use them without having '
16 to ad hoc treat every application.
I 17 MR. WERMIEL: Um-hum. I understand what.you're I l
18- saying. i 19 MR. DONOGHUE: I'm familiar with the Caldon 20 probability argument, and I'll just mention that in the 21 exemption that was granted, the staff didn't dispute the 22 claim, but also didn't try to tie it to a conclusion 23 regarding risk of a power uprate, and what we said was there 24 were many other factors that have to be considered when 25 _ increasing the power level of a plant. That one argument on
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25 1 the probability of being where you think you are powerwise
() 2 3
is part of it, but not the whole picture.
Okay.
l What we think this will accomplish, there's 4 a large or a significant motivation, financial motivation 5 for licensees. One estimate shows us that licensees could 6 each save about $4 million a year just based on not having 7 to buy energy from other sources if they could generate it j
~8 themselves, if they can get a power uprate.
9 As I mentioned a couple times now, there's other 10 ways that licensees could benefit from this if they don't 11 want to. pursue a power uprate. With both of those, a power 12 uprate or changing tech' specs again are going to require the 13 . staff to do a review. ;
14 DR. KRESS: Is that a good rule of thumb?
' (A) 15 MR. DONOGHUE: Say again, sir?
16 DR. KRESS: One percent power uprate is good for 17 $4 million per plant. Is that a good --
18 MR. DONOGHUE: One estimate. I said it was one 19 estimate. I wouldn't call it a rule of thumb, because I've 20 already gotten flak from some of the rulemaking people 21 that --
22 DR. KRESS: Was it too high or too low?
l 23 MR. DONOGHUE: It was too high based on how much l 24 of a cost to generate that power, that this was a simple 25 guess at how much it would cost to buy that power, not i
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E 1
26 1 getting into any details about how much it would cost them l
I b
\
2 to first get the power uprate itself, it's going to cost 3 them a little bit, but every year they're going to have to 4 incur some costs for generating that power. So it's l
5 probably a little bit lower than that,. but it depends on 6 market forces and the price of electricity, et cetera, et l
! 7 cetera.
l 8 DR. SEALE: With spot markets, that can be a j 9 pretty wild number.
10 MR. DONOGHUE: Last summer. Last summer it might 11 be $40 million. I don't know. But several million a year 12 is probably what they're going to see.
13 DR. WALLIS: And if they're paying someone to take 14 their power, then there's no benefit at all.
O; 15 DR. SEALE: That's true.
\_s l 16 DR. KRESS: Somebody gets it.
17 MR. DONOGHUE: As I mentioned before, licensees l
18 could just change their LOCA analysis by adopting new 19 instrumentation without their seeking a technical 20 specification change. And one thing I wanted to make sure I 21 mentioned, I had several questions on this when we first --
l 22 DR. WALLIS: Excuse me. There isn't really a 23 change in LOCA analysis, is there, because the 102 is still 24 there based on the old power. So the actual decay heat 25 that's put into a LOCA analysis isn't going to change.
f l
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~
27 1- You're just going to allow them to get closer to the assumed 2 value.
3 MR. DONOGHUE: If a licensee -- there's two ways 4 they_could use the rule. They could change their ECCS 5 analysis and just --
6- DR. WALLIS: But with existing power.
7- MIL DONOGHUE: Right.
8 DR. WALLIS: But they don't need to do that.
9 There's no incentive to --
10 MR. DONOGHUE: Another thing they could do, which 11 is what Comanche Peak is doing, is leaving the ECCS analysis 112 alone and requesting the power uprate so in fact --
13 DR. WALLIS: That's the most obvious thing.
14 DR. SEALE: That's the way you get the money.
() 15 MR. DONOGHUE: Right. That's the way you get the 16 most money.
17 DR. SEALE: Yes.
18 MR. DONOGHUE: As I've been educated now, a 19 licensee may have a particular mix of assets to generate 20 power, coal, gas, et cetera, and it may not make sense to go
)
21 for the power uprate.
22 DR. SEALE: Yes.
23 MR. DONOGHUE: Oh, the last point was, for 24 example, the BWR power uprate programs we don't see as being l
l- '25 -affected by this significantly. Those power uprates are I l
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i t ]
28 1 larger, they're going.to require revision of ECCS analyses.
() 2 3
This.is a little bit extra that they could tack on in addition to that program. We don't see it affecting those 4 things at all.
5 .Okay. We have touched a little bit on risk 6 already, and this is my only risk-consideration slide.
7 We don't see any significant issues raised in the 8 BWR. extended power uprates. There were two examples I know 9 about, I think Hatch and Monticello --
10 DR. SEALE: Yes.
11 MR. DONOGHUE: Where the staff was on record as 12 saying we took a look at this, there were some areas that 13 everyone asked questions about, I think human factors was
- 14. one, and there may be some others, but there were no f~
15 'significant risk issues raised.
16 As a result of those deliberations, the ACRS !
17 received a letter from the EDO last year which says plainly 18 that marginal power uprates -- and it uses 1 percent as an 19 example -- shouldn't require a risk evaluation. So we're I
20 using that as much as we can in this rule revision by saying )
21 that it doesn't seem to be a lot of PRA analysis required 22 here, but again, if a licensee wants to change their power 23 level, do some other tech spec changes, there's still the 24 existing' regulation deterministic requirements they're going 25 to have to meet.
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c 29 1 And we're plainly saying that this is not a " risk
( 2 informed" revision of Part 50 as discussed under 3 SECY-98-300. This is a separate activity from that.
4 This came up in a CRGR meeting where one could 5 envision the staff eventually looking at all the
]
6 conservatisms in Appendix K and wanted to do a risk-informed 7 change of the entire. appendix, and this is not part of that.
8 This is just a small benefit that libraries can use now that 9 we think we should be able to give them. Later on if the 10 staff finds in the process of going through the 11 prioritization process parts of Part 50 that need to be 12- reviewed, they may have to look at Appendix K some more in a
- l l
13 broader sense.
14 Okay. I think it's clear at this point we don't
) 15 consider this a backfit. It's a voluntary change. The way 16 we've written the rule, the licensees can maintain their 17 current requirement, as they have it, don't have to justify 18 anything that they are now doing, only if they want to use l 19 the rule to their advantage.
20 Okay. So I've gone through the things I wanted to 21 talk about, and I just want to show you the schedule we're 22 trying to meet. The package is now in concurrence. We were 23 hoping to have had the package for you to review. It's 24 going to be until the middle of June where we think it will l 25 be sufficiently changed from where it is now to -- during
(
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30 1 the concurrence process to be presentable to you. But we
() 2 expect to;have office concurrences complete by early to 3 mid-July. But I-think we'll be far enough along again in 4 mid-June to give it to you.
And the proposed rule we've 5 been told by middle August they want it, and it looks like 6 following that we should be able to get it out for public 7 comment in October.
8 DR. WALLIS: Will the proposed rule have a 9 rationale? Will it.be pages of legalistic language that one 10 has to figure out why it's being done?
11 MR. DONOGHUE: That's the nature of rulemaking, 12 I'm afraid.
13 DR. WALLIS: It would always help if there were 14 some up-front statement of this rule -- the purpose of this
() 15 rule is A-B-C, its effect on safety is X-Y-Z, and therefore 16 we're making it.
17 MR. DONOGHUE: No , the Federal Register' notice 18 actually is a pretty good summary. That will be part of the 19 package. Right now there's three pieces to it.
20 DR. WALLIS: Part of the package. I hope it is.
21 MR. DONOGHUE: The Federal Register notice is --
22 we're told to make it concise and straightforward. The reg 23 analysis gets into a lot of the mumbo-jumbo and so forth.
24 DR. WALLIS: Right.
25 MR. DONOGHUE: It's really kind of straightforward ANN RILEY & ASSOCIATES, LTD.
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p 31 1 even from'a legalistic sense. There's only a small
- 2- change'--
3 DR. WALLIS:
It looks like a one-page rule. It 4 looks like a one-page document. The best of all possible
.5 worlds.
l 6 MR. ~ DONOGHUE: I wish. I wish it was. Even the 7 environmental assessment's five or six pages.
8 That's all I had prepared to talk to you about, l 9- unless there's other questions. I do see Cliff Doubt here.
10 MR. WERMIEL: Yes. I was going to say if you 11 would like to discuss what the staff did to satisfy itself 12 that the instrumentation presents the kind of accuracy that 13 was claimed, Cliff Doubt from the former Instrumentation l 14 Controls Branch is here, and he did do that review.
15 DR. WALLIS: I think first of all we have to ask 16 if there are further questions for --
l 17 DR. SEALE: No.
l :18 DR. WALLIS: No?
! 19 MR. DONOGHUE: I'11 add that there's a l 20 representative from Caldon here, I think, Dr. Estrada.
1 21 DR. WALLIS: Maybe that will help when we get into 22 the technical questions.
23 Well, thank you very much.
24 MR. DONOGHUE: You're welcome.
25 DR. WALLIS: Let's proceed.
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32 l
l' MR. DONOGHUE: Thank you for your-attention. !
2' DR. WALLIS:
([ Can we talk about the 3' instrumentation?
4 MR. DOUBT: Sure. That's already been covered, I 1
5 guess.
6' DR. WALLIS: I had several questions. I read that {
7 Caldon document.
8 MR. DOUBT: The ER80P? I 9 DR. WALLIS: This one. !
I 10 MR. DOUBT: Okay.
11 DR. WALLIS: It has a very simplistic analysis of !
12 how it works. It has a straight-line trajectory for sound.
'13 It has no fluctuations with time. It has no turbulence. It i 14 has no detaile'd mathematical averaging of fluctuating f (x :
() 15 velocity fields to show that the time averaging is j 16 appropriate. It slides from time averaging to velocity 17 averaging without rigor. It doesn't tell you when it gets l 18 the signal whether it's a one off signal or an average over l
1 19- time of many' signals.
20 There are obviously fluctuations with turbulence, 21 and it would seem that the average signal is a much better,
! 22 more accurate value than -- signal. And also that the time 23 fluctuations give you some idea of how uncertain it is. I 24 mean, fluctuations to within .1 percent and your average is 25 _ going to be within .01 percent and so on, that's a very good
(~)-
- (.,/ -
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33 1 instrument.
() 2 3
So those questions don't get answered for me in this document, and there are probably some other ones that I 4 and the Committee have. Are you prepared to answer those 5 sorts of questions?
6 MR -. DOUBT: I can probably start, but I'll bet i
7 Herb has a better background than I do.
8 Noise is obviously an issue, and it does average 9 obviously in feedwater noise process. I 10 DR. WALLIS: So the signal is average.
11 MR. DOUBT: Yes.
12 DR. WALLIS: It's not clear to me from --
13 MR. DOUBT: There's actually four, obviously, and 14 there's integration off that. Those are averaged. It's
()
t 15 taken over a period of time. They do set that I think per 16 application.
17 DR. WALLIS: And it would be useful if they could 18 actually have an indication of the kinds of signals and how 19 much they fluctuate.
20 MR. DOUBT: Yes.
21 DR. WALLIS: Because if there are --
22 MR. DOUBT: Can look at each path time.
23 DR. WALLIS: If there are occasional bubbles or 24 'something there would be a blip. Do you discard the blips? l l
25 Do you average --
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34 1 DR. SEALE: Why don't we ask him to sit down up 2
( here. Because we're going to hold you down for a while.
3 DR. WALLIS.: Yes.
4 MR. DOUBT: Yes. You're going to do the design 5 details.
6 DR. WALLIS: You may need to sketch some things 7 for us, too.
8 MR. BOEHNERT: Identify yourself for us.
9 MR. ESTRADA: I'm Herb Estrada of Caldon. And 10 incidentally Mr. Donaghue conferred a degree on me which I 11 don't own.
12 DR. WALLIS: You probably deserve it.
13 MR. ESTRADA: No.
14 You're correct, particularly time averaging is
() 15 required because of the turbulence. This device is a little 16 bit unique in that respect, although of course differential 17 pressure, nozzle measurements, are also subject to 18 turbulence. But this one has both spatial averaging to deal 19 with as well as time averaging.
20 DR. KRESS: Let me ask you about the spatial 21 averaging.
l 22- MR. ESTRADA: Yes. l 23' DR. KRESS: You've got four of these things at 24 different --
25 .MR. ESTRADA: That's correct.
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35 1 DR. KRESS: Positions across the diameter.
/~h V) i 2 MR. ESTRADA: Yes.
3 DR. KRESS: And basically that would be a way to 4 get a velocity distribution if it was in there.
5 MR. ESTRADA: Exactly right.
6 DR. KRESS: So you have to average it. But you l 7 have to kind of average it based on the flow area some way.
8 MR. ESTRADA: Yes. The paths are spaced according 9 to a numerical integration rule.
)
10 DR. KRESS: Okay. You spaced them.
11 MR. ESTRADA: And in effect what you do is use a 12 weighted average of the diameter perpendicular to the paths 13 times the velocity linked product measured by that path to 14 form a numerical integration.
p
( ,) 15 Now that's a device -- that's essentially the way 16 the --
i 17 DR. WALLIS: This is replacing a circle by a set 18 of steps.
19 MR. ESTRADA: By a set of steps. Now the rules l 20 that we use are Gaussian quadrature. We get them out of the 21 handbooks. They're basically designed in our particular 22 instrument for rectilinear integration. So we have a 23 circular area, and as a consequence, there is a six-tenths 24 of a percent bias in the integration simply because you're 25 integrating a circle. If the velocity were dead flat and O' ANN RILEY & ASSOCIATES, LTD.
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36 lj you.made no correction to the device, you'd be off by
[\_)\ 2 six-tenths of a percent. So there is a profile factor that 3 accounts for that bias, as well as what distortion you see 1
4 in the velocity profile. i 5 Now this integration technique is powerful. It 6- will' integrate a seventh order polynomial without error.
7 But flow profiles occasionally have greater errors than 8 that. And in addition, the instrument is subject to 9 transverse velocities that they project onto.the acoustic 10 paths as well as axial velocities. So you've got to deal 11 with all that.
12 DR. KRESS: So basically the. instrument with the 13 built-in integration is only good for turbulence then?
}
14 MR. ESTRADA: No, we do use --
) 15 DR. KRESS: The difference in the profile --
16 MR. ESTRADA: Yes, we do --
17 DR. KRESS: Isn't that a different integration?
18 MR. ESTRADA: Yes, we do use -- we do -- you 19 mentioned the profile. I'll get back to the turbulence 20 answer, because there is, as Cliff indicated, there is an 21 explicit test on commissioning to determine what the 22 turbulence is and to reduce the observational uncertainty 23 due to turbulence to an acceptable value. And let me just
- 24 quickly finish that subject.
25 In addition, we do measure the statistics on line, )
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37 1 because they are evidence that something has changed, and if
() 2 they go flat, you know that there's something wrong and the 3 instrument is alarmed and the operator told not to use it if 4 in fact the statistics go away, because they're a symptom 5 that the --
6 DR. WALLIS: I notice that there is some 7 discussion of' incidents where something has happened and --
8' MR. ESTRADA: Yes. Our programmers are good, but 9 they're not perfect, and we have in years past had 10 situations, Westinghouse, who owned this technology before 11 Caldon, had incidents where the computation would lock up 12 and you'd get a plausible but incorrect answer. You can 13 have that in this kind of a device. And so there is on line 14 by two means, actually, one independent of the system itself 15 at Comanche Peak, and one within the system, a means to look 16 at what the statistics are doing.
17- They also do tel; you something about the profile.
18 In addition, as I started to say, the velocity measurements 19 themselves tell you about the profile. You use them as a 20 means to confirm that the profile that you're seeing in the 21 plant is in fact what you measured in the calibration 22 laboratory when you calibrated, determined the profile 23 factor for this instrument.
24 DR. KRESS: Let me ask -- you may not be the right 25 person for this question, but let me ask it anyway.
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o 38 1 This instrument device used to establish the power
() 2 3
as a' function of time, is it-also used as a controller to ensure the power --
-4 MR. ESTRADA: No, no.
5 DR. KRESS': Isn't it that controller that we ought 6 to worry about.
7 MR. DOUBT: Well, there's two different questions 8 there.
9 DR. WALLIS: The controller's a neutron 10 detector --
'11 DR. KRESS: Isn't that --
12 MR. DOUBT: It's not a controller in the sense 13 that you're thinking of feedwater controller flow. That's 14 done off the venturies. This_is used, however, I think,
) 15 for -- since it's also for the NI's and whatever, so from 16 that standpoint --
17 MR. ESTRADA: Yes, you set the gauge of the 18 nuclear instruments or the neutron monitors in a BWR based
,19 on this device.
20 DR. WALLIS: It keeps on recalibrating the 21 venturies and the neutrons --
22 MR. DOUBT: That's a site-specific -- yes, it's 23 used'to validate following in the venturi or identify 24 following the venturies.
25 DR. KRESS: I want give relief on a power uprate, ANN RILEY & ASSOCIATES, LTD.
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i 39 1 I'm interested in the device that's actually measuring the
() 2 3
power and controlling it so that it actually holds it at the level.
4 MR. DOUBT: It's an interesting question and I 5 think we asked'it.
6 DR. KRESS: Um-hum.
7 MR DOUBT: And the standpoint is that you have 8 simply'a couple of dynamics here. You have the one that's 9 calculating thermal power and showing that this is where 10 we're at. You also have a controller out there that's now 11 controlling for that number but independent of it. You set 12 it independently. So the question you might went to ask is 13 the -- what's the variance on the controller over that 14 101 --
15 DR. KRESS: What's the green function there?
16 MR. DOUBT: And nothing's really changed there.
17 But also remember that from a regulatory point of view it's 18 not instantaneous, it's over a shift or time. And in that 19 particular case the end result's the same. But at any point 20 in time we have -- in essence we can have a rate that's --
21 DR. WALLIS: Well, I guess that's a regulatory 22 question, and if you have this device very accurate but 23 you're not using it to control and you're using something 24 like the. neutron detectors as a control, if the fluctuations 25 in the neutron detectors is.2 percent, then that might ANN RILEY & ASSOCIATES, LTD.
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40 1 change your whole approach to --
() 2 3
MR. DOUBT: Well' I don't know that that's where the issue.would be. That's again protection side. But from l 4 a standpoint of control and power and feedwater flow, it is l
5 independent, but you essentially do control to that number.
6 It's an over time;-I think the credit's being taken for over 7 time. But'just like it is now, actually. I mean, you're 8 not at 100, you're at 101, 99, whatever. But it's over time ,
9 you will average.
10 DR. KRESS: So you're not changing that.
11 MR. ESTRADA: That's right. The dynamic component 12 of how well the steady-state thermal power is measured using 1
13 this device. And incidentally I want to correct some 14 impressions. This device does not measure power, it
() 15 measures flow and temperature --
16 MR. DOUBT: Right.
17 MR. ESTRADA: And the licensee's software that he 18 already uses actually calculates the calorimetric power from 19 that and steam pressure.
20 MR. DOUBT: And this just replaces input to plant 21 computer for those parameters.
22 MR. ESTRADA: Yes. But that's only part of the l
23 equation. You're right, there is a dynamic having to do 24 with basically turbine throttle control, control valve j i
l 25 control, that also affects this, and also the precision with l
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rg 41 1 which one sets the neutron monitors or nuclear instruments
'2 ,to match what this device tells him the power level is.
3 Those are' issues that are not changed in this initiative, to 4 my understanding at least. If they were, if the licensees 5 were to change that procedure, that would be outside of our 6 purview.
7 DR. WALLIS: I guess the question for NRC is the 8 words that refer to instrumentation error, which of these 9 instruments is it we need to focus on.
10 MR. DOUBT: From a standpoint of thermal power 11 measurement --
I'm not sure what Comanche -- but somewhere 12 it averages between 1.3 to, you know, under 2 percent is the 13 Appendix K off a thermal power measurement. That's the 14 number, okay? The controller and all that doesn't enter 5 15 into any, you know, that's not the parameter. So you're 16 measuring thermal power whether you did it off the venturies 17 with that uncertainty for feedwater flow and off the RTD's 18 for that temperature. Whether you did it this way -- all 19 we're really doing in that equation is proving the 20 uncertainty of that equation to calculate thermal power.
21 And the question on the controller and its accuracy was 22 not --
in the 102 is not really there. That's a time 23 function -- if it's plus or minus 1 or whatever, but that's l 24 not calculated in the --
25 DR. WALLIS: I guess the rationale is what you're l
l t ,
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l 1
i 1
l 42 l' interested in'is the power level over a period of time for l
() 2 decay. heat, is that it? .So you don't care about the 3 ' fluctuations --
l 4 MR. DOUBT: .That's the initial condition.
5' DR. WALLIS: The controller may allow. The 6 controller may allow it to go up and down~3 percent, but as 7 long as the average is less than --
8 MR. DOUBT: Not in my particular spot,'but that's 9 basically, you know, yes, we're doing an average over time.
10 DR. WALLIS: We need to understand that at some 11 time. Maybe -- you're going to back with something later.
I'think we need to -- staff needs to address the question of i
12 13 which instrumentation are we talking about and why.
14 MR. DONOGHUE: This is Joe Donoghue from staff.
(O
,/ 15 In the Comanche Peak review that's still going on for the 16 power uprate, you know, we've clearly said that we're 17 worried about power measurement uncertainties, and the 18 licensee is changing set points in the protection system as 19- part of its power uprate, and it sounds like maybe what 20 you're thinking about are more the set-point methodologies 21 for the protection systems, rather than --
22 MR. ESTRADA: Right.
23 MR. DONOGHUE: What we're talking about'here, 24 which is just a measurement uncertainty that's used as the 25 basis for an analysis input.
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43 1 DR. WALLIS: Well, I think for LOCA you have to d
( -2 tie it to the LOCA analysis in Appendix K and say what 3 you're interested in is knowing what the average power level ;
4 is over some period of time'which is far longer than the 5 controllers are interested in.
6 MR. ESTRADA: That's right. There was a 7 regulatory initiative -- that's maybe too precise a word --
8 but in our search we found that -- and actually EPRI 9 found -- that there was issued back in the early eighties I 10 believe some guidance on how well an operator is expected to 11 maintain -- he thinks he's running at 100 percent. How 1
l 12 close does he have to maintain that, and if he's out, how 13 soon does he have to get back to where he belongs.
14 There is guidance. I don't want to quote it, (O
,,/ 15 because I don't know it accurately, but there is guidance.
16 MR. DONOGHUE: This is Joe Donoghue again. There 17 is inspection guidance on that, how often and how much they 18 can go over.
19 DR. WALLIS: So that is a separate issue I think.
20 DR. SEALE: Could I ask a stupid question? It !
21 maybe is stupid.
22 DR. WALLIS: Those are often the best. I 23 DR. SEALE: Well, I am building an image or model 24 of what is going on here in my head and I am trying to make-25 sure I don't start from a false premise. You have four ANN RILEY & ASSOCIATES, LTD.
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44 1- sampling probes or receptors.
() 2 3 single path.
DR. ESTRADA: Actually there are eight, two form a 4 DR. SEALE: Okay.
5 DR. ESTRADA: There is a pitcher and a catcher 6 alternating back and forth.
7 DR. SEALE: Very good. Very good. Now, those 8 pitcher / catcher pairs, do they all sample the full diameter?
9 -DR. ESTRADA: No.
10 DR. SEALE: Or one samples a. full diameter, the 11 others sample chords?
12 DR. ESTRADA: They all -- the four chords --
13 actually, none of the chords is a full diameter.
14 DR. SEALE: Okay.
() 15 DR. ESTRADA: There are two chords, they are all 16 parallel, and two chords are, if projected onto a 17- cross-section, are about a half of a diameter, about equal 18 to one radius, and the other two chords are longer, they are 19 roughly 85 percent of a diameter.
20 DR. SEALE: Okay. And this is part of the 21 weighting algorithm.
22 DR. ESTRADA: Exactly right. They are positioned 23 and the weighting are both selected according to the 24 numerical integration rule.
25 DR. SEALE: . Fine.
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.)
45 s
L1 DR. WALLIS: Could we get back to the time
()- 2 . averaging that you started with?
3 DR. ESTRADA: Yes.
'4 DR.'WALLIS: You get a' signal and it is a point 5 signal, and you get a set of signals. How often is it 6 sampled?
7 DR._ESTRADA: The sampling rate is a function of /
8 path lengths, but it will be in the range for the Comanche 9 Peak' instrument of 60 hertz.
10 DR. WALLIS: 60, hertz, okay. And how much do 11 those readings fluctuate over say a second? ;
12 DR. ESTRADA: Let me -- we find the turbulence 13 varies in feedwater systems, but we find averaged along a 14 path, a long path, for example, because they are a little
()
3 15 bit different. The turdulence is_ higher near the periphery 16 of the pipe and lower near the center, so the turbulence as 17 a percentage of the velocity is larger on the short paths 18 than it is on the long paths.
19 But let's take a long path which is more 20 representative of what you see. A single snapshot of a 21' velocity is going to be typically on the order of 3 percent, 22 that is to say the variance --
23 DR. WALLIS: Three percent.
24 DR. ESTRADA: Yes.
25 DR. WALLIS: You have-to average to -- )i ANN RILEY & ASSOCIATES, LTD. I O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p.
l l
46 1 DR. ESTRADA: You must average or you are done.
/'Ni t 2 DR. WALLIS: It doesn't appear in the report.
%) I l
3 DR. ESTRADA: It does in one of the appendices, I 4 but it does not in the -- yeah. l 5 DR. WALLIS: It is going to be a very important 6 discussion because a point reading is not good enough.
7 DR. ESTRADA: Absolutely not.
8 DR. WALLIS: Statistics, if you are averaging over 9 time, has to be good enough so that the average value is j 10 within the --
11 DR. ESTRADA: That's right. And there are two, I 12 want to make mention that are really two constraints on that l 13 average. One is that you have to take lots of samples to 14 get the variance, the uncertainty of the menu down to
/~'% i
(
s ,) 15 something within reason. But, in addition, there are low 16 frequency components to the turbulence down in the 1 hert:
17 range.
18 DR. WALLIS: You were asked about large eddys. i 19 DR. ESTRADA: Yes. And occasionally in nuclear 20 l plants you see limit cycling of the feedwater regulating l 21 valve, which also causes more than a second occasionally at 22 low power.
l 23 DR. WALLIS: If you ever get a bubble, then you 24 get a blip in the signal.
25 DR. ESTRADA: Yeah, now -- yeah, we see no -- we
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I 47
, 1 do in oil pipelines, we see gas. We have never seen that
()
/ ~,
2 kind of a problem in feedwater. We do see furrow 3 stratification of feedwater at low flows, but we don't see 4 gas.
5 But you are right, getting back to the averaging, 6 it may be three to five minutes of averaging that is 7 required to get the precision. And, again, there is a 8 statistical test done at commissioning to establish what the 9 appropriate averaging period is, and the variance that 10 produced that averaging period, so that you can check that 11 in the future and make sure that it hasn't changed.
12 DR. KRESS: Do you cross-check this device with 13 other instruments to see how -- that your averaging is 14 actually working right? l For example, you know, you could ;
) 15 have an array of flow measurements that you compare.
16 DR. ESTRADA: Not formally, but we expect, j 17 because, you know, generally speaking, this device is more 18 accurate than the devices that you are comparing it with.
19 But I am old plant operator and you would be foolish to 20 ignore things like first stage pressure or steam flow, or 21 the venturi nozzles, even though they are subject to -- you 22 do and should check those things for plausibility. I am not !
23 prescribing that that be done, but I would if it were me.
24 DR. WALLIS: Now, the analysis in this report also 25 just shows a straight line trajectory and talks about one ANN RILEY & ASSOCIATES, LTD.
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T:
48 1 velocity in the algebra and so on.
()
i 2 DR. ESTRADA: Yes.
3 DR. WALLIS: When you have sound going through a 4 medium with fluctuations in velocity and temperature and so 5_ on, it doesn't just go in a straight line.
6 DR. ESTRADA: No, it does not. This takes me back 7- a long time. I was involved in Westinghouse's use of this 8 instrument to measure reactor coolant flow at Prairie Island 9 back in the 1974 timeframe. They used it as a design 10 verification tool to understand what the true resistance was 11 to the reactor coolant loops to see -- in an effort to l
12 improve the design of pump impellers and understand the 13 headflow characteristics of their pumps.
14 And in reactor coolant systems, because of the
() 15 thermal streaming, the problem that you mentioned is big.
16 In addition to the velocities varying in time and spatially 17 along the path, particularly in reactor coolant systems, the 18 temperature varies as well.
19 DR. WALLIS: Well, I was expecting to find in the 20 report the analysis which actually said here is a trajectory j 21 of a --
22 DR. ESTRADA: Yeah, that is right.
23 DR. WALLIS: When it fluctuates, there are 24 temperature fluctuations, velocity fluctuations, we have to 25 integrate and so on. And I didn't see anything like that.
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{ 49 1 I just saw --
1 ID 2 DR. ESTRADA: It is not in there. There is, U
3 however, an assessment of that effect. What - the instrument 4 does is, in effect, it-performs a line integral of DL times 5 C plus V or DL. times C minus V, where C and V, C being sound 6 velocity and V are locally varying without -- that is really 7 what it'does, it is not measuring a --
8 We have done. assessments of what kinds of -- you 9 get when you use -- when you treat --
10 DR. WALLIS: Excuse me. It is measuring times.
11 DR. ESTRADA: Yes.
12 DR. WALLIS: So it measuring length'over --
13 DR..ESTRADA: Yes, I misspoke. You are exactly 14 right. It is the inverse of that number. It is DL over C
() 15 plus V or DL over C minus.
16 DR. WALLIS: There is a path in there where an 17 integral DT is turned into an integral DL, but it is not as 1
i 18 simple as -- l 19 DR. ESTRADA: It is not as simple as what is in j 20 .there. It is more complex. We have, however, I wanted to !
l 21 say, we did -- we have done -- there is no general way of 22 treating that, but we have made assumptions. And this is l 23 back in 1974 is why I brought that experience up, to 24 understand what the uncertainties were in that.
25 DR. WALLIS: Well, there has been various things l ANN RILEY & ASSOCIATES, LTD.
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50 1 you could throw in for your components of fluctuation, all
() 2 3
kinds of stuff to assess how big the effect might be.
DR. ESTRADA: Yes.
4 DR. WALLIS: I am not saying you have to do 5 because you have got good calibrations, but it would help 6 support the analysis, the claim of accuracy if one could 7 show that, say, 10 percent fluctuations in velocity with the 8 sorts of frequencies expected from the turbulence, 9 analytically can be shown to have .1 percent effect, or 10 something like that would be helpful. Maybe it is being 11 done.
l 12 DR. ESTRADA: It has been done, but it was not 13 submitted as part of this submittal. But it has been done.
14 DR. WALLIS: Does that mean the staff is not
() 15 sophisticated to ask for this?
16 DR. ESTRADA: I am not going to touch that 17 question.
18 DR. WALLIS: Well, it bothers me a bit because I 19 don't like the situation where it is the ACRS that asks for 20 the information, and that is the first time the question has 21 ever been raised.
22 DR. ESTRADA: Well, it is not the first time it l
23 has been raised. It has been raised by licensees actually.
24 It is a valid question and it will take some digging, but we 25 can dig up that analysis if it is appropriate.
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51 1 ~DR. KRESS: Is-the downstream transducer at a
-i
. \g l
/N 2 different angle than the upstream one?
3 DR. ESTRADA: No. -No. They look directly at each 4 other. That is to say, the nose of the well is 5 perpendicular -- this is like on a thermo-well that they --
6 DR. KRESS:- You can get away with that because C 7 is so much bigger than V?
8 DR. ESTRADA: I am not sure'I understand.
9 DR. KRESS: Well, you know, if you are going this 10 direction, the light curves this way.
11 DR. ESTRADA: Oh, yes, I see. Yes, the beam is in 12 fact swept by the velocity. Is that what you are asking?
13 Yes. The amount of sweeping is small compared to the 14 dimension of the transducer well.
() '15 DR. KRESS: The size of the transducer.
16 DR. ESTRADA: Yeah, and that basically is because 17 -
you are correct, that V is in the order of, in feedwater 18 systems, 15 feet a second axial whereas the C is in the 19 order of -- well, hot, it is 4,000 feet a second or 20 thereabouts.
21 DR. WALLIS: Do you have to adjust these things?
22 Do you build it and put the transducers in? Then does 23' someone have to do a lot of fiddling to get them lined up?
24 DR. ESTRADA: No , that is controlled dimensionally 25 in the fabrication of the spool piece. If you are saying do l
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l 52 1 you have to focus the beam, the answer is no.
() 2 3
DR. WALLIS:
DR. ESTRADA:
Like some of the laser instruments.
No. j 4 DR. WALLIS: Where you spend two days trying to 5 get the thing lined up.
l I
i 6 DR. ESTRADA: No. No. Now, in order to get that, 7 there are very stringent controls on perpendicularity of the 8 well assembly and of the run-out of the flange so that you 9 -- you know, they do shoot at each other. But the answer is 10 no. If yen don't get a signal when you put this thing in, 11 you are in trouble.
12 DR. WALLIS: So the thing is sold as a spool piece 13 with everything installed, not to be touched by licensee, is 14 that the way it is?
l
() 15 DR. ESTRADA: No. They can touch it. There is no 16 alarm required. But, for example, things do fail. The 17 transducers --
18 DR. WALLIS: It doesn't require an adjustment?
19 DR. ESTRADA: No, you just replace them in kind 20 and there are tests that the instrument runs to ensure that 21 the signal received from a new transducer meets the 22 requirements of the precision of time measurement that the 23 old one did. But that is go/no-go kind of test and it is 24 not something that you adjust.
25 DR. WALLIS: I think it would be useful to see ANN RILEY & ASSOCIATES, LTD.
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53 1 this analysis, some statistics put into the turbulence and 2 the expected temperature stratification, if any, so that we 3 can_see under what conditions this' device might have less 4 accuracy than claimed, and.when we would have to worry about 5 that. If it turns'out that temperature variations of 100 !
6 degrees are required to throw it off, then we wouldn't 7 worry. But if .1 of a degree can throw it off by .2 8 percent, we may have~to worry. I don't know.
9 DR. ESTRADA: Fair enough. We will dig that 10 analysis out.
'll DR. WALLIS: I think it would be useful to educate 12 the staff on this point, too. I don't know how much the 13 staff has got into this.
14 MR. DOUBT: We looked at it.
) 15 DR. WALLIS: Maybe you have and I just didn't --
16 MR. DOUBT: This is a different angle on the 17 question, but one is we looked at it from the standpoint of,
-18 okay; we calibrate this thing in the lab someplace, we come 19 up with a number and a meter factor, and I now going to 20 throw it in a plant-specific situation.
21 DR. WALLIS: Right.
22 MR. DOUBT: What will affect that? And so we ask 23 questions on profile, temperature realms number, the flow 24 rates are different. Downstream or upstream. In this 25 particular case, there are interesting problems at Comanche ;
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)
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r I .'
l 54 I
! 1 Peak, at least from our review point is that, generally, the
() 2 3
topic report you are reading says that we will do a hydraulic model of'the installation based on - run at a 4 test at a flow facility,-essentially, with a model of 5 whatever we are going to do plant-specifically, and to give 6 us some confidence that this. plant-specific installation 7 will match up.
8 The Comanche Peak installation isn't quite that-9 way. It does have some differences.
10 One is it does have.an elbow and almost 10 11- diameters, maybe a little bit less than that, from this 12 meter'there'is a T that comes into there to provide swirl --
13 so there are some differences in flow profiles and 14 velocities, compared to what would be tested in a test
( 15 facility.
16 - However, Caldon has -- or actually Westinghouse ,
t 17 more likely -- and again some Caldon tests to show different 18 elements upfront and what the sensitivity meter is to those 19 changes. It is relatively robust from what we could tell, 20 and also -- but you do have to orient the meter in some 1 l
21 cases and you do have to take some essentially -- they call j i
22- 'it commissioning but you do have to look at the flow '
23 ' profiles, you have to look at the velocities, and 24 compensate. ;
i 25 The other thing we did is we went and looked at-l lO ANN RILEY & ASSOCIATES, LTD.
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?
55 1 technology similar to this -- I mean just what is the 2 general meter technology out there and what are the
(
~3 capabilities. Essentially we looked at it and we thought 4 that this particular accuracy is attainable, not 5 necessary -- this just happens to be the meter that is in 6 front of us, but from a technology point of view and the 7 state-of-the-art or whatever, this is attainable and in fact 8 can be, based on some tests that we observed, significantly 9 bettered.
10 DR. WALLIS: So when the Staff considers whether 11 or not to approve an application from Comanche Peak, for 12 instance they look at the evidence of the tests and the 13 geometry of the loop in which this was tested and go through 14 all that stuff to satisfy --
() 15 MR. DOUBT: That was more of my concern. In fact, 16 we went to some calibration facilities in NIST and we looked 17 at what type of effects -- how would this meter be affected 18 by the different profiles? And obviously Venturi's the same 19- difference. I took a little different angle on this when I 20 did the review. I said if I had a Venturi and I wanted a 21 one percent uprate, what would I do?
22 I would do all the same things, except that the 23 Venturi has some uncertainty component that I can't really 1
24 eliminate here. I looked at them as time-dependent type 25 issues.
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i 56 l 1 DR. WALLIS: Is orienting the meters important?' I
_2- You said if you --
3 MR. DOUBT: You have to, depending on your 4 profile, coming off, you may -- you want to cross. You want 5 to hit it'like that.
6 DR. WALLIS: Right.
7 MR. DOUBT: So there is some -- it is sensitive to 8 that orientation, so you have to make adjustments for that.
9 DR. WALLIS: So it's not so simple as to just take 10 the meter and put it in a pipe and it will measure --
11 MR. DOUBT: Depending on the accuracy you want to 12 attain.
13 DR. ESTRADA: Absolutely not, no. Cliff's right.
14 It depends on what -- many of our applications, if you can
() 15 give somebody six, seven tenths of a percent, that kind of 16 accuracy, that's fine, and in that case this thing is 17 robust, but like. Venturi meters if you have close-coupled 18 nonplanar bends upstream, this can get in trouble just like 19 any flow measurement system that I know of can get in 20 trouble.
21 DR. WALLIS: That's where the math would be 22 useful, if you could say, well let's take an extreme case 23 where'the velocity is twice as much on this side as on that
.24 side and let's put it into the math and see how much error 25 we get.
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57 1 I think what my impression is is that this meter
[~'} 2 is pretty robust for those sorts of changes. Because it V
3 integrates the way it does fairly large changes in velocity 4 or distributions of velocity it won't make that much 5 difference, but it would be useful to see an assessment of 6 that in a mathematical way.
7 MR. DOUBT: I guess I looked at it from a 8 standpoint of sensitivities as to which element looked like 9 it would nail it the worst and that angle with it.
10 DR. WALLIS: Maybe you can show mathematically the 11 fluctuations of 100 percent in flow rate across the duct 12 averaged out over so-on only make a difference of one 13 percent in the reading. That Would be very convincing.
14 MR. DOUBT: Yes. Test run -- basically if you did
) 15 a straight pipe fully conditioned flow, threw an elbow in 16 front of it, looked at the profile factors, looked at the 17 meter factors, the effects are -- and with a flow 18 straightener -- essentially the effects are very minimal.
19 It does tolerate pretty well but it does show, at least from 20 what I have in front of me, that if you have to orient the 21 meter to get these accuracies from what I understand from 22 the Westinghouse installation when these were put in, they 23 were basically trying to quantify a fouling in a Venturi, so 24 they needed basically precision repeatability and accuracy 25 is a nice thing to have and it has it, but they did not O ANN RILEY & ASSOCIATES, LTD.
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58 1 calibrate-the spool piece, essentially installed it cold, I
() 2 3
and you could take a one percent on that, and that was their claim.
4 So what we are looking at here with this 5~ installation is how do we get the other .5 so that we can 6 satisfy the calculations to come up with the thermal power 7 and 101.
8 DR. SEALE: 'It is always interesting to put on our 9 blinders and look at our problems as if they are the only 10 ones that count, but it is even more interesting to take 11 them off sometimes.
12 You mentioned that the oil and gas industry uses a 13 version of this in pipeline --
14 DR. ESTRADA: Yes.
() 15 DR. SEALE: What kind of precision requirements do 16- they have? Actually, what kind of precision requirements do 17: the states have to measure the tax -- or to calculate the
- 18. tax revenue from the flow of that oil, which is also a very, 19 very interesting number to some people.
20 DR. ESTRADA: Yes,-they -- let me tell you, that !
21 is a --Lit is a different ballgame.
22 We have two kinds.of applications in the pipeline 23 business'for-liquids. This instrument is used on-the 24 -TransAlaska pipeline for leak detection. Now there is it is 25 .long-term repeatability-that. matters, and repeatability l
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59 1 having tas do not simply with how well the clock maintains
/'%./) 2 .its frequency but also having to do with if I put 3' drag-reducing agent in the pipeline, which flattens the 4 . profile and the profile changes, what does this instrument 5 now read relative what it was, because such changes in 6 Instrument A, upstream of a piping segment and Instrument B, 7 where the-change hasn't taken place can produce the false 8 alarm for a leak or perhaps mask a little leak that occurs.
9 So there the repeatability is the -- what they 10 call repeatability is the variable of importance, and they {
11 are looking for numbers like a tenth of a percent for 12 varying temperatures, viscosities, products, waxes, not 13 simply stability of the signal processing electronics.
14 Now going back to your first question, what is
()
15 called cosities transfer, the practice in the oil and gas 16 industry is to use something called a prover wherever 17 possible. You have an instrument, perhaps it is a pcsitive 18 displacement meter or a turbine meter are the two commonly 19 used meters in that business these days, and we are trying 20 to displace the turbine meters, they prove them by a fixed 21 volume prover where they run a prover and they fix a fixed 22 number of barrels of product, and you count of the number of 23 counts out of your instrument and you calibrate it that way.
24 Now there is a requirement on the repeatability 25 there as well. They typically will run five such proving
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r:--
60 1 tests and they expect the meter factor determined from those I 2 tests. In effect, they are calibrating anyplace to be C'J) 3 within .02 to .05 percent plus or minus, so that is tough on 4 .us because in'that short period of time the turbulence 5 statistics can kill us, but that, answering your question, 6 the absolute accuracy which is important here tends not to 7 be as important in the oil and pipeline industry.
8 On the other hand, precision and repeatability for ,
9 changing of hydraulics is extremely important, if not more 10 so.
11 DR. WALLIS: So when we have an application from a 12 given plant the Staff is going to come up with really robust 1 I
13 evidence that justifies the claim of accuracy which is being 14 made? Specific tests with specific outputs from instruments
() 15 and we can actually if we wish look at this evidence?
-16 MR. DOUBT: Well, the problem with this particular 17 proposal instrument or whatever is that from a plant point 18 of. view once -- you really need to know that for the 19 plant-specific installation, because once installed, it's 20 .like or it says basically that accuracy of that instrument I l
21 can't trace it to that accuracy either, so essentially what l 22 I have got is a standard, but I have to ensure that I am 23- getting what I --
24 DR. WALLIS: It may be relatively easy to make the j 25 rule and relatively difficult to prove the accuracy i
I l
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61 1 necessary to allow a deviation from the old rule.
2- MR. DOUBT: That was the major question-here 3 actually when we were doing the review. That is why the
]
4 instrument became, I think, a focal point or instrumentation 5 in general, but it was the. focal point when the rule was 6
originally done too, I'm sure, is that what can the industry 7 support? Two percent. The basis for that, that is the 8 other part of the debate.
1 i 9 In this particular case, what we are now basically 10 being asked is if the state of instrumentation, not only 11 -Caldon, but if we can support a power uprate of one percent 12 based on improved thermal power measurement, and yes, we 13 have to -- that is the question, can we justify that.
14 DR. WALLIS: We are not going to get into a
() 15 situation where we say, yes, this looks great, let's do it 16 and then the thoroughness with which the Staff investigates 17' the true accuracy of these devices gets relaxed?
18 MR. DOUBT: I don't think so. What we are trying 19 to do here is through a topical report provide a basis that 20 for a plant-specific installation we can confirm that.
21 DR. WALLIS: Because I think in principle it seems l
l 22 a very reasonable request, then the feasibility of being !
23 sure that your uncertainty really has gone down the amount 24 claimed may turn out to be quite an undertaking.
25 MR. DOUBT: Yes, because in this particular case O ANN RILEY & ASSOCIATES, LTD.
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1 there is significant test data, not necessarily arranged to
(~N) 2 the plant-specific installation we have, but we also have QJ 3 other data too from other meter types or other ultrasonic 4 meters that give us a feel for what the industry capability 5 is also, and there are different angles or different 6 methodologies that can be used here.
1 7 I mean in some cases with this meter, ultrasonic 8 and general chordals, you can really look at it as a 9 reference standard, and calibration is not required except 10 for orientation and you can get some significant accuracies )
11 without -- basically cold. There's no accuracy or 12 calibration requirement from the manufacturer's point of 13 view. He installs it, orients it to the flow profile to get 14 the velocities indications and he is there in some claim r
i 15 2.5, 5.5 just doing that.
L.,
16 So the question we had here was the sensitivity of 17 flow velocity profiles or flow profiles and changes and then 18 can we tolerate it.
1 19 DR. WALLIS: Do we have some other technical I
20 questions? '
21 I guess they may come back when we have some 22 specific requests.
23 MR. DOUBT: Right. I don't know if you have --
24 the way we did the topical report is essentially we looked 25 at the technology and other plant-specific issues have to be N ANN RILEY & ASSOCIATES, LTD.
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63 1 asked is if you can maintain that accuracy in a 2 plant-specific situation, and that is what that SER would
. U'~N 3 do.
4 DR. WALLIS: Are there any other pointh anyone 5 wishes to make? Do you have'any other questions we should 6 have asked and didn't?
7- DR. ESTRADA: My background, as you may know or 8 can tell, is nuclear and from my.own perspective I felt that 9 there are two fundamental questions that we had to address 10 to the supplier of this instrument.
11 ) One is is it as accurate as claimed, but second, 12 how do you know it is that accurate six years later on the 13 backshift, and that I put a lot of weight in my own 14 conscience on the fact that this instrument does tell you
] 15 that the hydraulics haven't changed, that the time 16 measurement hasn't changed, and that the geometry hasn't i 17 changed from what it was when you calibrated it, or at least ;
18 when you put it in because the geometry obviously does 19 change from a cold calibration facility to a hot operating 20 feedwater system, but the fact that you can check it and it 21 is simple to do was to me a key element in -- you know, you 22 can make the probability argument but the probability 23' argument only obtains if the distribution really looks like 24 that, and that is essentially where I felt we had to step up 25 and do something a little different than usually is done I
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64 1- with an instrument.
, 2- DR. WALLIS: Now feedwater systems are subject to-3 things like water hammers?
4 DR. ESTRADA: Yes, they are.
5 DR. WALLIS: And Venturis are fairly robust when a 6 wave goes through them, an acoustic wave. A water hammer is 7 a pretty large wave for --
8 DR. ESTRADA: Yes.
9 DR. WALLIS: --
for devices to withstand, 10 DR. ESTRADA: These are not fragile devices. I am 11 sure we'd excite the transducers with some of the water 12 hammers. I saw one at Nine Mile Point, Unit 1 some years 13 cack that moved the pipe two or three feet -- we would see 14 that but I don't believe the instrument would have a problem e~
(]s 15 with it.
16 The reactor coolant system, while it isn't subject 17 to water hammer _or better not be, is a relatively rugged 18' environment. There's lots of vibration. It's hot. The 19 transducers that Westinghouse put in at Prairie Island 20 20 years ago are still there and they still work or at least l 21 they worked the last time we checked, which is two, three
{
22 _ years ago, so it is just a piece of ceramic with some 23 springs and some leads and the thermowell is big, rugged l 24 stuff, looks like an RTD well. The pipe is extra heavy wall !
25 to make up for the holes in it. You know, it looks just j O ANN RILEY & ASSOCIATES, LTD.
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r 65 1 like hardware you would see in a reactor coolant system. It
'[\/') 2 is not -- the electronics is different but the --
3 DR. WALLIS: Well, but the mounting of a 4- transducer if it were subject to a water hammer might move 5 the transducer relatively --
6 DR. ESTRADA: Yes, you would expect it to move, 1
7 but then --
8 DR. WALLIS: Wouldn't there have to be some way 9 the system checks for that?
10 DR. ESTRADA: Yes. In fact, what might happen --
11 we are speculating obviously -- is that the transducer might l 12 use a foil bond, no grease, no stuff, because that stuff 13 will not last in the hot environment of the feedwater 14 system, so we have a roughly 1000 psi pressure. It's a
() 15 couple hundred pounds of force on the transducer, holding it 16 against a foil which in turn couples it acoustically to the 17 well. The well itself is stainless steel; window is about 18 three-eights of an inch thick.
19 If for example the shock would cause it to move, 20 part company momentarily, then come back, if in fact the new 21 coupling was inadequate, you do not receive a signal and the 22 instrument would tell you so and say ' don' t use me. "
23 DR. SEALE: Reasonable failure is catastrophic, 24 essentially -- that is, in the sense that it just doesn't 25 work anymore.
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1 DR. ESTRADA. It just doesn't work anymore, that's 2 right.
3 DR. WALLIS: That is easy to understand. The 4 worst one is the little water hammer no one pays any 5
attention to, which moved it a little bit, and that changed 6 the calibration.
7 DR. ESTRADA: But the instrument is not magnitude 8 sensitive, and that is an important point. Maybe that is 9 the question you should have asked.
10- ,
The pulse that we receive we measure time by not 11 measuring when it crosses a particular magnitude threshold, l 12 we measure a time. We start the clock when we pulse the 13 transmitting transducer and then we stop the clock on 14 typically the second half-cycle zero crossing. You get a
() 15 little packet of about five half-cycles of energy.
16 DR. WALLIS: The zero crossing -- you don't 17 measure zero. You have to measure some finite --
18 DR. ESTRADA: Well, the way the detector actually 19 works is there's a threshold that says get ready to look for 12 0 a zero, a magnitude threshold then. It comes out of sonar 21 technology is where it comes from. It's torpedo stuff, but 22 you enable the zero crossing detector when the magnitude of 23 the received signal exceeds some value, and then the next 24 zero is when the clock stops.
25 Now the pulse -- if coupling changes over time, l
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67 1 for, example the magnitude of that received pulse can change.
() 2 3
.There is a very long time' constant, automatic gain control that-maintains the pulse amplitude at specs, so that is 4 another way that_you give yourself assurance that by god you 5- are in fact.looking at the right zero crossing.
6 If you are running out of gain, if there is an 7 oxide layer or something forming on the coupling and the 8 magnitude of the signal goes down over time, and gradually 9 you run out of sensitivity in your receiver, then, again, an 10 alarm comes on, says -- actually, there is a precursor to 11 the alarm, it says, hey, you are running out of gain, stop 12 using this instrument and go replace the transducer on the 13 coupling is in effect what it says. So we endeavor to get 14 something robust.
() 15 There are also checks on the plausibility of the 16 time measurement itself. Paths are compared with each other 17 as regards the total transit time. Do they change from one 18 sample to the next by more than is plausible? There is a l
19 lot of checking of that kind that are based on the <
l 20 statistics of the system.
21 DR. WALLIS: Actually, it goes on all the time.
22 DR. ESTRADA: All the time, yeah.
! 23 DR. WALLIS: Do devices like this experience 24 waterhammers?
25 DR ., ESTRADA: I am trying to think. We probably l
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68 1 have, but not in nuclear plants, at least not that we know
/ 2 oof . This technology is used in hydroelectric facilities 3 and --
4 DR. WALLIS: They get surges.
5 DR. ESTRADA: They get surges occasionally.
6 DR. WALLIS: Well, maybe there will be some 7 evidence about that in the future, too.
8 Any further questions?
9 [No response.]
10 DR. WALLIS: Are we ready to take a break?
11 DR. SEALE: Sounds like a winner.
l l 12 DR. WALLIS: Let's do that. We will recess.
13 Thank you very much indeed.
14 DR. ESTRADA: Thank you.
' 15 (Recess.)
16- DR. WALLIS: It is now 10:15, I would like to come
' 17. back into session. The first job is to summarize where we 18 are with this proposed revision to Appendix K. What next 19 steps -- the next steps are what really the ACRS needs to do i 20 now and in the future. l 1
21 Joe, could you do that for us? Where are we going 22 with this?
23 MR. DONOGHUE: Okay. I mentioned that the l l
24 rulemaking package is in concurrence and we expect in about 25 two' weeks that we will be able to present it to the ACRS.
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- J 69 1 We were hoping that we can get your endorsement on
[ ) 2. proceeding with the proposed rule.
3 DR._WALLIS: So when is it that you want to bring 4 this to the full committee?
'S MR. DONOGHUE: Well, if you decide that you want 6 to have a full-committee meeting on it, it would be I guess 7 in July.
8 MR. BOEHNERT: Yes.
9 DR. WALLIS: Will there be anything significant 10 that changes between now and July?
11 MR. DONOGHUE: I wouldn't expect so, no. The 12 language should be pretty much what you saw today.
13 DR. WALLIS: Based on what we heard today, I think 14 you part would go pretty quickly.
() 15 MR. DONOGHUE: That is my plan.
16 DR. WALLIS: If you don't get into details of 17 turbulence'and meters. And maybe we don't need to at this 18 stage. I mean are just sort of saying is there is a meter 19 which is an accurate.as claimed, then this rule would be 20 appropriate.
21 MR. DONOGHUE: That is the approach we are taking, 22 right. Otherwise, we could be talking about several 23 different instruments come July, and it would take all day.
24 DR. WALLIS: But sometime down the road, we may 25 see more detailed questions about instruments in given I
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70 1_ plants and so on.
() '2 MR. DONOGHUE: Well, if the committee wants to j 3 review the review done for Comanche Peak or future 4 applications of this or other technologies, of course the 5 staff should prepare him -- would accommodate that request.
6 DR. SEALE: I think the lesson here -- a couple of 7 comments I would make. First of all, I think we ought to 8 give our a colleagues a high sign that it would be very 1
9 worthwhile for them to all read SECY-83-4 -- what is it?
10 MR. DONOGHUE: 472.
11 MR. BOEHNERT: 472, yeah.
12' DR. SEALE: 472. Because it tells us what the 13 staff's expectation for a best estimate calculation was as 14 of 1983 and the expectations of the ACRS now for a best
() 15 estimate calculation are somewhat different from that in the 16 context of so-called risk-informed regulation, and in 17 particular, I think the questions of uncertainty have ;
18 emerged in the last few years as significant parts of any 19 best estimate assessment.
20 I think there is a message here for the staff, 21 too, in that, from what you heard today and so on, when you 22 do have a specific request, the committee is going to be 23 interested in uncertainty questions, what :".le greens 24 functions are in the sense that when you diddle that, 25 something else is going to wiggle in a not necessarily
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71 1 sympathetic way and so on.
2 So if you are going to do a best estimate 3 assessment, which has got to be.the basis for these Appendix I 4 K kinds of changes, then'you are going to get best estimate 5 kinds of questions, which include uncertainties and so.on.
~6- MR. CARUSO: I guess I am not sure what you mean 7 by best estimate, because we are talking here about revising
'8 the Appendix K requirements.
9 DR. SEALE: Yeah. Well, what I am saying is, if 10 you are going to modify those requirements based on the 11 ability to do something better. We want to know why you 12 think you are doing it better.
13 MR. WERMIEL: Yeah, exactly.
14 DR. SEALE: And some at some point someone may O
Q -15 come in with a best estimate versus Appendix K kind of 16 question and then, certainly, you will have a concern for --
17 MR. CARUSO: We have done that already for 18 Westinghouse WCOBRA TRAC.
19 DR. SEALE: Right.
20- MR. CARUSO: And we expect that there will be more
.21 such requests coming in.
22 DR, WALLIS: Tom?
23 DR. KRESS: No, but I agree, this is a pretty good 24 principle, you know. If you have an instrument that you can 25' show has less uncertainty, then it is appropriate to relax l
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r; 72 i 1- these kind of rules. So I think I'am certainly in favor of 2 this rulemaking going forward.
! 3 DR. WALLIS: It is not just instrument, I think 4 there is a broad question.
-5 DR. KRESS: I think there is a real broader
'6 question just like that.
7 DR. WALLIS: A broader question.
8 DR. KRESS: And not just'this issue. And I 9 think --
10- DR, WALLIS: Are you going to define it now?
11 DR. KRESS: Well, I don't know if I can right now.
12 But I will let_you try if you would like.
'13 DR. WALLIS: Well, I think the question is that a 3
14 lot of margins exist _in rules, regulations because of
() 15 uncertainties.
16 DR._KRESS: Uncertainty.
17' DR. WALLIS: And as we get better knowledge, 18 better information,.better instruments, all the'above, --
19 DR. KRESS: You ought to be able to chew away at 20 those margins.
21 DR. WALLIS: The question is, should we then 22 reduce the margins because we now know better where we are.
23 MR. WERMIEL: Yes.
i 24 DR. WALLIS: And this should be a principle that I 25 applies broadly across the entire agency. If so, they it ANN RILEY & ASSOCIATES, LTD.
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73 1 maybe needs to be understood and written up in some way.
I\ 2 MR. WERMIEL: Yes. We agree.
b
-3 DR. WALLIS: Can we finish with this particular 4 topic and move on?
5 DR.-SEALE: Well, I think they were talking about 6 providing some additional information on these questions.
7 MR. WERMIEL: That's right.
8 DR. SEALE: Can you make sure Paul gets a chance?
9 DR. WALLIS: The information is about the 10 instrumentation.
11- DR. SEALE: Yes, right.
12 DR. WALLIS: That is not relevant, really, to the 13 main question of rulemaking.
14 MR. WERMIEL: No.
15 DR. SEALE: Oh, so.
16 DR. WALLIS: It is going to be sometime in the 17 future. The message is in the future.when we get 18 applications for specific plants, that we are going to look 19 very carefully at the evidence that claims to show that the 20 instrumentation really is as accurate as it is meant to be.
21 MR. WERMIEL: Yes. ,
)
22 DR. WALLIS: Okay. Anything else you need to tell 23 us?
24 MR. WERMIEL: No. I think we are finished.
25 DR. WALLIS: Well, then let's finish with this L
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r 74 1 topic. I would like to call on Ralph Landry to move us on
/ Y 2 to the question of the review of RETRAN-3D.
V I 3 MR. LANDRY: Okay. Thank you, Mr. Chairman. My 4 name is Ralph Landry from Reactor Systems Branch, NRR. And
- 5. today what I would like to do is update you on the status of s 6 the RETRAN-3D review, the usual history recount.
7 We came in -- or we received RETRAN-3D application 8 for review in September of 1998. We met with the committee i
9 twice in '98 talking about our plans for a thermal-hydraulic 10 code review, and then talking'about our review of the 11 documentation on the RETRAN-3D code. And we met with the 12 committee again in March of this year, at which time we 13 presented the status of our review, our concerns and what we 14 -saw as potential requests for additional information which
() 15 we were going to send to the applicant.
16 So today what I would like to do is update you on 17 the status, because in March, when we met with you, we made i
18 the commitment to come back more frequently than we had i 19 originally scheduled. We had said originally we were going 20- to come back in September -- August or September to talk i 21 about the draft SER, responses to the RAIs, draft SER, and L 22 we felt that there were enough concerns that were raised 23 that it would be in the best interest of the relationship 24 with the subcommittee to come back before that and i
25 periodically update you on the review status.
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l 75 1 So today I would like to go through where our
() 2 3
review is, what our concerns are and where we see the review going. -The requests for additional information were l i
4 formally sent to the applicant April 27th, 1999. The 5 applicant has forwardedm to us an electronic version of the 6 response at the same time that they sent the paper version.
7 of the. response to the document control desk. I have 8 provided the ACRS staff engineer with a printed copy of that 9 electronic version of the RAI responses which we have 10 received to date.
11 Those RAI responses reflect the RAIs which the 12 staff had prepared at the time of the March meeting when we 13 discussed where our review was going and what we were l 14 finding in the review. Since that time, the chairman of the !
() 15 subcommittee and one of the consultants of the subcommittee 16 have forwarded their concerns. In addition, we have become 17 assisted by Joe Kelly from the Office of Research. Joe is 18 looking at the slip models, the drift flux models in the 19 code, and I anticipate Joe will be coming up with some 20 additional concerns also.
21 So what we had envisioned as a one round set of 22 RAIs when we set out on this review, we now believe is going 23 to be requiring at least one more round of RAIs because i 24 we're going to take the serious concerns that the chair has 25 raised, formulate those concerns as RAIs, the concerns i
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l 76 1 raised by Professor Schrock, formulate.those as RAIs, and
'. 2 concerns which Joe Kelly may come up with, and put together 3 RAIs so that we can send out another round of RAIs with some 4 very serious concerns which you have all raised, i 5 The Chairman has raised some very serious concerns 6 regarding the. formulation of the momentum equation in the 7 code. We need to look very carefully at your comments, 8 Professor Wallis, and determine how we're going to phrase 9 those concerns as requests for additional information, and 10 we will of course have to go back to the code architect and 11 determine how they're going to respond to those concerns.
12 DR. WALLIS: I'm wondering how an RAI gets a 13 suitable response. If it turns out there's a formulation at 14 a basic level of something like a momentum equation which
() 15 16 seems odd, let's say, I'm-not sure this is amenable to the RAI procedure, unless I'm wrong.
17 MR. LANDRY: That's why I say we will have to 18 discuss with the applicant and in particular with their 19 contractor,'the code architect, and how this can be 20 addressed. You've raised a very serious concern.
21 DR. WALLIS: If there are some things that are 22 fundamental in some conservation law in the code which 23 doesn't seem to be right let's say and the code nevertheless 24 appears to predict some reactor transients, is it still 25 acceptable code?
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77 1 MR. LANDRY: That's a very difficult philosophical i
'2 question, because it makes us stop and think. Are these 3 effects in the misformulation of the momentum equation so 4 minor that they really' don't affect the response of the code 5 and the ability of the code to predict a real reactor 6 transient? These are some hard questions that we have to 7 look at. But still this calls into. question a concern that 8 we have of a code being without known errors, which I'm 9 going to get-to a few minutes later, and it's another 10 concern that we have.
11 It's a very difficult question. I don't know the E12 answer at this point.
13 DR. WALLIS: We shouldn't really be in this 14 situation, reevaluating fundamentals in a code many years
() 15 after it's been used for a lot of applications, including 16 many nuclear applications.
17 MR. LANDRY: I would agree with you. And the 18 question is, where does this misformulation come from. Is 19 it from the original RELAP 3, RELAP 4 days of what was the 20 predecessor of RETRAN, or is it from this version of RETRAN, 21 an earlier version. We don't know where at this point --
l
- 22 DR. KRESS: Or it could even be a typographical j 23 error.
24 MR. LANDRY: Some of what the Chairman has pointed l
25 out are typographical errors, which he has noted, but some l
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4 78 1 'are misformulations.
() ~2 DR. WALLIS: But not this one. The thing that i 3 bothered me up here is in so many. equations it would be hard 4 to --
5 MR. BOEHNERT: Tom, you've got Graham's comments 6 right in front of you.
7 DR. KRESS: Okay.
8 DR. SEALE: Well, I cheated, and I looked at a 9 couple of slides on further back, and I have the impression 10 that the response to the question about the model that has
'11 been used has been to start over again. Not quite, but --
12 DR. WALLIS: If they're starting over again with 13 fundamental formulations, then it's a new ball game and it 14 has to be started again. It's not going to be on your O 15~ original schedule.
l ( ,/
16 DR. SEALE: But it's clear that the RAIs that were 17 generated rattled the cage pretty vigorously.
l 18 MR. LANDRY: Dr. Seale, let me just jump up, skip 19 this slide on the neutronics, and go to the slide that l 20 you're talking about, about the five-equation flow field 21 formulation. Let me reverse those two and go right into 22 that then.
! 23 DR. SEALE: Sure.
1
( 24 MR. LANDRY: To make a plug for the way we're 25 doing business now, we. start out on this review, change the
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l !
l 79 1 way we were doing' business in code review by insisting on.
j ) 2 receiving a copy of the code so that we could look at the 3 code itself. In the process of running the code, one of our
- 4. engineers, Undine Shoop, ran a problem, the code came back 5 and said it was relaxing because of overspecification the 6 five-equation model. But it didn't tell how.
7 So she used to raise the question how do I know 8 what's being taken out? What equations are being dropped?
9 So we asked the question of the applicant, how do we know 1 10 what equations are being dropped? And then they came back 11 and said oh, well, we're revising that whole five-equation 12- model anyway because there are problems with it.
13 Well, if we had not run the code, we would have 14 never found that. Without running the code, we never would
() 15 have found that the code was doing this and not telling us 16 what was happening.
l 17 This is particularly troubling because we found in 18 looking at some papers that were presented at the ninth 19 RETRAN international conference in June of 1998, three 20 months before the code was submitted to us for review, a 1
21 paper that was given authored by the code architect in which I 22 the code architect said there are problems with the 23 five-equation model in that it has limitations in i 1
24 calculating depressurization transients. There are problems 25 in the five-equation model, in that it does not adequately l 1
l l l
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80 1 represent pressurization transients. We looked at that and
) 2 said. wait a minute, that leaves steady state. And that 3 abstract went on to say that the five-equation model was 4 being reformulated, redeveloped.
5 This gave us a great deal of concern, because this 6 says that the code was known to be in error when it was 7 given to us for review, which violates one of our very basic 8 premises on code review which we discussed with the AP600 9 reviews of NOTRUMP. We said that one of those conditions 10 for our code acceptance and approval.has to be freedom from 11 known code errors. And here's a code submitted for review 12 which has known errors. A known error is that the 13 five-equation model is wrong. So this gave us a fundamental 14 problem in doing the review.
() 15- What we have done as a result is we've suspended 16 partially the review of the code while we wait to receive 17 this reformulation or this description of the five-equation 18 model that is being substituted into RETRAN-3D. This has 19 far-reaching consequences into a lot of the thermohydraulic 20 review that's going on. But this is a very difficult 21 problem for us.
22 We weren't going to go today into a long 23 discussion of the development of the standard review plan 24 and the reg guides, but we're talking internally now about 25 based on this experience what is our approach in the reg l l
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l 81 1 guide and standard review plan as to requirements that a
() 2 code submitted for review be free of known errors, how do we 3 specify this, how do we state this, because we don't want to 4 receive a code that the person knows is wrong.
5- We start reviewing the code and say yes, we knew 6 that was wrong and wasted a lot of time and effort reviewing !
7 something that was known to be in error. This is a !
l 8 fundamental problem.for us right now.
9 DR. WALLIS: Well, I don't know if it is. Maybe 10 you simply have done the right thing in suspending review, 11 and it's up to the submitter to fix things.
12 MR. LANDRY: Well, we have received a draft copy !
13 in electronic form of replacement pages for volume 1 of the 1 14 RETRAN-3D document. We are going to start looking at that,
/~
i 15 because that should be the description of this 16 redevelopment, reformulation of the five-equation model. We 17 want to see what is in there.
4 18 DR. WALLIS: Then this has to go into a 19 reformulated computer program?
20 MR. LANDRY: Yes.
21 DR. WALLIS: Has to be revalidated, everything has 22 to happen all over again.
23 MR. LANDRY: It's going to have to be redone.
24 DR. SEALE: And there's still the question of 25 whether or not the concerns for the momentum equations that T ANN RILEY & ASSOCIATES, LTD.
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L 82 1- have been expressed earlier have been appropriately 2 addressed.
3 MR. LANDRY: That is another concern; yes.
4 DR. SEALE: It strikes me --
5 MR. LANDRY: That's a second concern, a second 6' major concern.
7 DR. SEALE: Yes.
8 MR. LANDRY: Which we have to deal with.
9, DR. SEALE: It strikes me that we hear all about 10 resource conservation, and the expenditure of resources both 11 within the industry and within the Commission as being a 12 problem, and certainly it is. We don't seem to be able to 13 afford to do certain things because we do other things. And 14 you say it's a problem. I hope this problem has been
) '15 articulated to the Commissioners, and they are aware of it, 16 so'that'when they get their serious chiding about resource 17~ limitations and so forth, they understand that false trails 18 like this sometimes cost a lot of money.
19 MR. LANDRY: We are discussing how to deal with
'20 this internally.
21 MR. WERMIEL: I'll make the point, Dr. Seale, one l 22 of the primary purposes for development of the new criteria 1
23 for code review was geared exactly to your concern about the l 24 best use and most-efficient use of staff resources.
25 DR. SEALE: That's right.
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p 83 1 MR. WERMIEL: Whether or not it's been articulated
'( ) 2 in that fashion to the Commission, I don't believe. At l 3 least I'm not aware that that has happened. But clearly we 4- are aware of that issue, and that's one of the prime movers 5 for the path that we're on that Ralph has been talking _
6 about. And we do believe that with the new guidance and 7 with this new approach to code review, we will be utilizing 8 our resources to the best of our capability.
9 DR. SEALE: Yes.
10 DR. WALLIS: Well, I think there's the other 11- question that you have fewer resources. Are you still going 12 to be able to do what the review requires?
13 MR. WERMIEL: Yes, we believe so.
14 DR. WAlLIS: Or is it just going to take longer?
O
\, ,/ 15 I mean, there's going to be pressure if there's a schedule 16 to get something done on time, one person do it, if it takes 17 three people but there's only one person available to lean 18 on that person to get it out the door, 19 MR. WERMIEL: You're absolutely right, Dr. Wallis, 20 and that is nothing new. We deal with that kind of pressure 21 and that kind of concern all the time. We have to 22 understand what our priorities are. We have to be in a 23 position to best utilize the available talent that we have.
24 That's not something that will be unique or new with this 25 new approach to code review. We've been dealing with that
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84 l
1 for a long time, and we continue to deal with it.
2 MR. LANDRY: If I may, I'd like to move into a 3 good-news side.
4 DR. WALLIS: That would be lovely.
5 MR. LANDRY: Bad news, good news. One of the good 6 points that has been coming out of this review, at the March 7 meeting we discussed a great deal of the work that Tony 8 Ulses has been doing in reviewing the neutronics within the 9 code. Since that time, Tony has been doing some more work 10 trying to isolate the neutronics package even further, and 11 examining part of a rod eject upset in a PWR using a 3D 12 transport model versus a 3D diffusion model to try to 13 determine is the 3D diffusion formulation adequate, does it 14 represent the neutronics adequately, and from that then we O
Q 15 would like to be able to isolate the 3D neutronics 16 calculation that is done in RETRAN 3D for further comparison 17 purposes.
18 Why do we want to isolate the neutronics so much?
19 Well, there's the concern that has been raised that we have 20 3D neutronics being coupled with feedback from 1D thermal 21 hydraulics, and how can you get the right answer? We're 22 concerned that first if the neutronics package is not right, 23 it doesn't matter what the thermal hydraulics package is 24 doing. You can't possibly get the right answer. The 25 neutronics has to be right or the answer cannot possibly be
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':- 1 85 1- correct or representative of a plant upset. If the
() 2 neutronics package is doing.a reasonable and an acceptable 3- job, then we have the other side of the question, is the 4 thermal-hydraulics package adequate to give the proper 5 feedback to the neutronics to get a reasonable answer.
6 So what Tony's been doing is trying to isolate the 7 neutronics capability of the code to determine is the 8 neutronic capability adequate to represent the upset 9 condition in the reactor in the-first place. If so, then 10 the next step, is the thermal hydraulics feedback and 11 coupling correct or reasonable so that you get a reasonable 12 answer.
13 Tony's'also started working with the SPERT data.
14 We obtained a copy of the SPERT report, and Tony's begun to 1
() 15 do some work using the SPERT data to try to model those 16 tests, which were suggested by-the consultant in the March l 17 meeting. ;
I 18 We've also suggested to the applicant that the 19 applicant should do some modeling and calculations with the 20 SPERT data also. This should not be done entirely by the 21 NRC staff. This is the type of comparison, modeling, 22 assessment that should be done by the applicant and should 23 have been done already by the applicant. We should not be 24 the ones that have to do this.
25 So we're stressing that we do recommend very O ANN RILEY & ASSOCIATES, LTD.
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l 86 l ~1- -strongly that the applicant begin looking at the SPERT data l \,
2 and so some similar calculations.
l 3 DR. SEALE: But I would say there are enough 4- questions having to do with what might be considered 5 second-order transport calculations, whether it's a 6 diffusion or a Boltzmann transport is beside the point. So
- 7 .that you have to have the capability to do some of these l 8 calculations. There's a spectral hardening question or.
9 softening, I guess you really should say, as you remove 10 control rods from bundles that is not a simple one to i 11 resolve, and so I don't think you're being out of line at 12 all in insisting that you have that capability.
13 MR. LANDRY: I don't mean to imply that we --
14 .R. SEALE:
D I understand. What I'm saying is I p
i() 15 defend your position to have that. I would, anyway.
16 MR. LANDRY: This review approach, again to give a ,
l 17 plug to what we're doing, has been quite good. This has
- 18. been a very strong educational' experience, a very strong i
19 experience for us in the review process, and we're very ;
1 20 pleased with the way the work is going, and what we're i 21 finding in doing this kind of review. !
22 DR. WALLIS: Well, it's surprising to me that the l
.23 code's been around for some time, EPRI's a very professional ;
24 ' organization, big organization, lots of engineers, that it l
25 isn't a more straightforward process where things are right eft i
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U l 87
.1 and they-work and you don't have to keep going back with
/~'\ 2 questions. I'm surprised that we're in this -- that you're
' \)
3 !1 earning so much. I would have-thought that you would be
- 4. convinced of-the wonder and beauty and excellence.of the 5 code:at_every state.
l 6 - MR. LANDRY: Well --
7 DR. SEALE: Well, most of these calculations or 8 . codes we developed back in a time when the reliance was on a
- 9. large central processing unit like a Cray or something like 10 that. And the ability of those machines to provide 11 computational capability for doing some of the things you're 12- interested in was in fact limited. I mean, it -- you just j '13 couldn't do all of the spectral calculations you needed and i
14 so on. Well, now.you can. And so you no longer are forced
() 15 by computational capability to rely on fudge factors to take 16 into account spectral effects and so on. So the climate's 17 changed, and before we apologize for the fact that we're 18 ' stuck like this, we ought_to recognize that we're not using 19 the same tools now that we used to use.
l 20 DR. WALLIS: Ralph, you said this was good news, i
21 and what I've learned is that Tony is working on these 22 calculations and comparisons, and so is EPRI. Are there !
i 23 results from it which are good?
l 24 MR. LANDRY: Tony is at a preliminary stage right 25 now and isn't ready to present results, and we did not plan ANN RILEY & ASSOCIATES, LTD.
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88 1 on going through a technical presentation this morning. All'
() 2 I can say at this point is that Tony's been encouraged by 3 the results he's been getting. We have to wait and see what 4 he finally comes up with when he completes the studies.
5 Changing the topic a little bit, looking at the 6 code approval process. In looking at the code, we were 7 aware that RETRAN-3D code was designed to be able to 8 substitute for RETRAN-02 when it is set up to run in a 9 RETRAN-02 mode. As part of our approval, we intend to write 10 one single safety evaluation report. If we determine in 11 that process that RETRAN-3D in the RETRAN-02 mode is indeed 12 a RETRAN-02 substitute, then we will state that and draw 13 those conclusions in the one single SER on the code. We do 14 not intend to issue separate approvals or separate safety
('
I 15 evaluation reports and statements on the capabilities of the 16 code. We will provide only one SER in this code.
17 DR. WALLIS: Now can we look at that? RETRAN-2 -- l l
18 I'm not sure what the procedures are, but RETRAN-2 has I 19 already been approved in some way?
20 MR. LANDRY: Yes. I 21 DR. WALLIS: So if there are errors in RETRAN-3 22 which are traceable to RETRAN-2, we've been through this 23 before, I think, but if there's some fundamental error in 24 formulation, it's probably in RETRAN-2 as well.
25 MR. LANDRY: It very well may be. We haven't
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89 1 traced all the problems back to see if they exist in 2 RETRAN-02 also. If they do, that will raise further
[V) 3- concerns for us.
4 DR. WALLIS: You're not going to be blind to --
5 MR. LANDRY: We're not going to be blind to --
- 6. DR. WALLIS: Just because it's been approved in 7 the past doesn't mean it's perfect.
8 MR. LANDRY: We're not going to reopen the review 9- of RETRAN-02, but we're not going to be blind to a history.
10 or an ancestry of problems. If that ancestry is there, then 11 we will have to make some statement regarding the RETRAN-02 12 approval also.
13 In that light, there are a number of limitations 14 'in the SER on RETRAN-02. Where those limitations are
) 15 addressed by RETRAN-3D, such as the limitation in RETRAN-02 16 that it does not have 3D neutronics, if we determine the 3D 17 neutronics to be acceptable, we would say that that 18 limitation is removed with respect to RETRAN-3D. It still 19 exists for RETRAN-02, but it is no longer applicable to 20 RETRAN-3D. There are limitations'in the RETRAN-02 code 21 which are not being addressed in RETRAN-3D, and thus we 22 would say those limitations still apply to RETRAN-3D because 23 this code has not addressed the limitations that were placed 'j 24 on RETRAN-02.
25 So any removal of limitations for the RETRAN-3D l 1
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90 1 would only be those that are addressed directly by 3D.
() 2 3
Now there is'a topic that has already been mentioned, schedule. >
We have not changed our schedule at 4 this time. We still have our schedule showing the draft OCR 5 in September of this year and the final SER in October. The '
6 impact of.the code revision has not been addressed. We are 7 waiting for the full revised documentation to determine how 8 much material is there, how much review has to be'dcne.
9 We have to address the additional concerns reised 10 by the members of the committee and additional concerns 11 which we would anticipate raised by Joe Kelly in Research.
4 12 Now we still show the schedule has the final SER 13 in October. It's very difficult to envision actually i 14 staying with that schedule. We have to wait and see what
() 15 the material shows and how much review work is involved.
16 DR. WALLIS: I think you made an understatement 17 there.
18 DR. SEALE: Yes. Could I ask a couple of 19 questions, please?
20 Once a_ utility has a package of codes that has a 21 . track record of acceptability, I would think there would be 22 some reluctance on their part to venture into using a new 23 code to calculate things which they perhaps believe were 24 adequately treated with the old code, okay?
25 Now what happens if in your look of 03 you find
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c 91 1 .that RETRAN-2 results'are somehow tainted? It seems to me
() 2
'3 that the utilities ought to know about this before they spend a lot of resources on another application where they 4l otherwise have reason to believe 02 is adequate.
5 'What is the information flow path that gives 6- you -- that you will use to warn these people that they have 7' a potential problem?
8 MR. LANDRY: The Chairman of the RETRAN 9 Maintenance Group is present today and I am sure Greg 10- Swindelhurst will be commenting to his colleagues on what he 11 has heard today.
12' We are aware that that is the way the world works.
13 In our discussions with the utility representatives and with 14 .the applicant we are aware that they have invested heavily 15 in RETRAN-02.
16 DR. SEALE: Sure.
l 17 MR. LANDRY: They use it extensively. We also are 18 aware that they are concerned that if RETRAN-3D operating in 19 the 02 mode is an equivalent and can replace RETRAN-02 they 20 would like to have approval for that, because that would 21 move them to the latest version of the code, and then if the 22 code _is approved for the full RETRAN-3D capabilities, it 23 would be an easy migration to 3D as 3D instead of as 02 24 lookalike and equivalent.
25 However, even though we are aware that that is a ;
I
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l 92 1 -desire that they have, because of our limitations on 2
resources we do not intend to do two reviews of this code.
3 We will do one review and issue one Safety Evaluation 4 Report, which may say in the 02 mode it is equivalent, 5 however we are not going to issue a separate approval for 6 that at this point.
7 DR. SEALE: But on the other hand, if you find out 8 there is a tainted result --
9 MR. LANDRY: And that they have ancestry in 02, 10 then that calls into question the 02 results also.
11 DR. SEALE: That's right.
12 MR. CARUSO: In that case, Dr. Seale, we would 13 pass'that information back to EPRI depending on the 14 seriousness of it, and it would be incumbent upon EPRI to
() 15 notify their customers and have those customers assess the 16 impact of those error on their calculation and on their 17- operation.
- 11B DR. SEALE: Since 02 is an EPRI property --
19 MR CARUSO: Yes.
20 DR. SEALE: -- it is pretty easy to find the 21 string to pull.
22 MR. CARUSO: Yes.
23 DR. SEALE: Okay.
24 DR. WALLIS: Now you had some other folks working 25 on running thermal-hydraulic code. Have they been coming up ANN RILEY & ASSOCIATES, LTD.
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'1 with new results?
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l \ 2: MR. LANDRY: Other thermal-hydraulic codes or 3 RETRAN-3D?
L 4- DR. WALLIS: You spoke about Ulses doing the-5 neutronics' work and he's made some progress. You had Joe 6 and I forget who -- ,
7 MR. LANDRY: Undine Shoop.
8 DR. WALLIS: Have they been coming up with new 9 results?-
l 10 MR. LANDRY: No , I said we have partially 11 suspended the review. We have stopped calculations --
12 DR. WALLIS: Doing something else --
13 MR. LANDRY: We have stopped that work because our 14 feeling was if the five equation model was wrong or it was
() 15 going to be replaced, why should we spend further resources
'16 doing calculations with a code that is going to be 17 undergoing major revision. We don't see a value in spending 18 the resources, doing calculations-with a code that is going 19 to be undergoing such a major change.
- 20. DR. SEALE: Depending on what --
21 MR. LANDRY: We progressed where we were in March 22 on those discussions.
l l 23- DR. SEALE: Depending on the details of this 24 equation set, you may or may not resolve this momentum j ..
25 concern.
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L l 94 1 MR. LANDRY: That's correct. Yes.
) 2 DR. SEALE: It is seems'to me that is the first 3 thing you are going to want to decide before you spend a lot 4 of resources evaluating that thing.
5 MR. LANDRY: That's correct. We need to go back 6 and look at Dr. Wallis's concerns, Dr. Schrock's concerns, 7 try to formulate those as REIs and we need to get together 8 now with the applicant and with their code architect, their 9 code modelers, and determine what is the result of the 10 concerns which they have raised.
11 DR. WALLIS: Well, it may be that I am completely 12 mistaken, but I felt very uncomfortable. This is the first 13 time I have opened that chapter and read those pages and 14 tried to figure out what is going on, and I have these
() 15 questions about how is it they ever get from here to there 16 and they have done some very strange things with the physics 17 at a very fundamental level and that makes me even more l
18 queasy and uncomfortable because this is just something that
- 19. should have been resolved 10 years ago, if there is an issue 20 there.
21 This code is being used -- in all sorts of ways.
22 MR. LANDRY: Yes. That's why we need to look at 23 it very carefully. We'need to talk with their modelers too, 1
24 and again.it raises the fundamental question that perhaps J 25- .even though this is wrong it doesn't matter.
O
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95 21 / I hate to say something like~that but that is 2 rather perplexing too.
3 DR. WALLIS: That's what we heard all through last 4 year.
5 MR ~. LANDRY: The momentum equation doesn't matter.
6 DR. KRESS: Is that why you have margins in there 7 too?
8 MR. BOEENERT: Could be a re'ason.
9 MR. CARUSO: As Dr. Seale mentioned earlier, it is 10' possible that it could be either a typographical error. It 11 could be a peculiarity in the modeling that came about as a 12 result of computer limitations many years ago, and {
13 simplifying assumptions may have been made which caused the 14 equations.to be cast in a form which is not physically
() 15 correct but which for computational purposes is good enough, 16 and that is why we have to communicate with the code 17 architects to understand why they have the equations cast in i
18 that form. l l
19 Following that discussion we hope we will I 20 understand better what it was that is in the documentation. l 21 DR. SEALE: But this is an example where brevity l
22 is not a virtue.
23 MR. CARUSO: Right. There is no question. l 24 DR. SEALE: And if there are determinations that 25 are done like that, and they are somehow not documented,
/
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96 1 then-every time a curious person like Professor Wallis takes
() 2 a look at this formation'and gets this queasy feeling in his 3 stomach about the whole thing and asks some questions about
'4 the issue in a fundamental way, like the momentum equation, that kind of gets decoupled in the data from the decision
~
5 6- that was made for various reasons and so on that this 7 approximate method is okay.
8 MR. CARUSO: I hate to be flip, but we don't treat 9 relativistic effects because we know we are well below the i 10 speed at which they are important, so we sort of throw them 11 out.
12 DR. SEALE: I understand that, and I didn't say 13 you should, but on the other hand, momentum is not a 14 relativistic effect.
() 15 MR. CARUSO: I understand that, but just to give 16 you -- ;
17 DR. SEALE: I understand.
18 MR. CARUSO: Simplifications show up.
19 IM1. SEALE: Newton's equations are adequate. !
20 MR. CARUSO: Adequate, not quite correct, but 21- adequate.
22 IMt. WALLIS: No , but this purports to-be more than 23 that and if --
24 DR. SEALE: Sure, it is.
25 DR. WALLIS: -- and if look at some of these
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L 97 1 things'I was pointing out there'are cases-where a term I 2 would mark " wrong" on a homework assignment for an 3 undergraduate, that sort of thing should never get past the 4 first review by-the producer of the code long ago.
5 I am very, very puzzled. Either I am going wacky 6 'in my old age or something is very wrong with the whole 7 system where people throw together some math which may have 8 big errors in it and then they spend' billions of hours 9 making a code work, and that:is the wrong way to put your 10 effort.
11 Well, you must have something more to say? No?
12 MR. WERMIEL: No. Not on this.
13 MR. LANDRY: This was to say the status of the 14 review and alert you to problems that we see.
() 15 MR. WERMIEL: And where are going.
16 MR. LANDRY: And that we are going to be having 17 some intensive discussions with the applicant over these 1 i
18 problems. We need to resolve these issues because these are l
19 such fundamental issues that we can't find a way just to l 20 ignore at this point. l l
21 DR. WALLIS: Well, my sense is that you should say {
22 the old schedule is scrapped. We are back to the beginning 23 and we are going to figure out what we do now. !
24 MR. LANDRY: The old schedule is -- ;
25 MR. CARUSO: It is likely scrapped, yes.
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i.:
98 1 MR. LANDRY: It is what is on paper at this point.
2 We haven't taken the steps to change it because we have to O("N 3- determine what is the magnitude of this problem, what is it 4- going to take to fix the problem before we change the 5 schedule.
6 We don't want to just change 'the schedule to 7 change it' .
We would like to have a reasonable idea of what B we need to change the schedule to.
9 MR. WERMIEL: We will know a lot better where we 10 are after we meet with EPRI and' understand exactly what they 11 have to tell us. They are aware of these things. They have ;
12- to input to us, you know, what the impact of these findings 13 is to them, and then we decide where we go from there.
14, DR. WALLIS: I think you may have to look hard at
( ) 15 the lessons learned on how to go about this sort of review 16 in the future.
- 17. MR. WERMIEL: Yes.
18 MR. LANDRY: Early on I said that some of this i
19 being fed back in to the staff members working on the !
20 Standard Review Plan and the Reg. Guides.
21 MR. CARUSO: Exactly. )
22 MR. LANDRY: That we have learned some things here 23 that challenge our fundamental criteria, and that is feeding l
-24 back to. '
25 MR. CARUSO: But on the other hand, reviews are 1
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99 i
1 never perfect. I mean we never get a perfect submittal
, (~') 2 where there are no questions. There are always questions, 1 \ /
3 and the more complicated the review, the more questions 4 arise, and this is a complex review.
And I mean I -- this 5 really doesn't surprise me considering what we went through 6 with all the various codes on AP600, the SBWR, the 7 WCOBRA-TRAC review for operating reactors. These code 8 reviews are very complex and in many instances, the 9 documentation is not as good as we would want it to be, and 10 we just have to work through these issues. And, 11 unfortunately, it takes time.
12 DR. SEALE: Yes, but your level of sensitivity is 13 different now.
14 MR. CARUSO: That's true. That is true.
/~%
15 DR. SEALE:
(a) And the fact that they have got a code 16 which they already knew had to be redone because there were 17 inkjequacies in the equation set that they were using --
18 MR. CARUSO: That is unfortunate, and we hope --
19 DR. SEALE: Well, it is more than that.
20 MR. CARUSO: Well, I am trying to be positive.
21 DR. SEALE: I understand that, and that is why I 22 asked the question about whether or not this message has 23 gotten to the attention of some people who can point out 24 that this is --
I 25 MR. WERMIEL: It has.
i
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100 1- DR. SEALE: This is not the kind of thing that
()
V 2 instills trust between the regulator and the regulated.
3 MR. WERMIEL: That 's true , and the message has.
4 DR. SEALE: Okay.
5 MR. WERMIEL: It is not say it couldn't happen 6 -again, but-the message is out there.
7 DR. WALLIS: Well, there is a broader part, too, 8 and that is the trust that the intelligent observer has when
{
9 he looks in on what is happening from outside, not just the 4
10 regulator and the regulatee, but some reasonably informed 11 member of the public.
12 MR. CARUSO: And this is the first code review we 13 have done with this new process. So we are learning, the 14 licensees are learning.
() 15 DR. SEALE: You are moving the bar a little bit.
16 MR. CARUSO: We have moved it. I am not sure how 17 we have moved it' but we certainly have moved it.
, And we 1 18 have some other' vendors that are coming in with other codes 19 this summer and, hopefully, they are watching what is going 20 on here and they are learning. Actually, we do know that !
l 21 because we had a presentation from one of the'other vendors 22 yesterday and it was impressive, quite impressive. They 23 seemed to have learned a lot from the mistakes of others.
24 Well, their own mistakes and the mistakes of others in the 25 past.
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E. I 101 1 DR. KRESS: Well, let me ask you a general policy (A) 2 question. You know, you have these design basis 3 requirements, and people meet them by making calculations in 4 the codes, not always codes, but sometimes codes, and in 5 order for you to approve these,.make a judgment that the 6' design basis requirements have been met, you have to kind of
- 7. review and approve the-codes.
8 MR. CARUSO: Maybe, it depends. The only codes we 9 have.to. review and approve are the ECCS codes, Okay. For 10 transients, these are transients and accidents.
11 DR. KRESS: This is not as general a question-as I 12 -thought it was going to be. My question was going to be, 13 then suppose later on after a code has been approved and by 14 . virtue of that the design basis, so to speak, has been I
g ,f 15 approved, NRC finds something wrong with the code that is 16 already approved, is there a policy that says what you do 17- then?
18 MR. WERMIEL: Oh, yeah.
19 DR. KRESS: Do you shut down the plant or do 20 you --
21 MR. WERMIEL: It works no different from a 22 computer code than from any other, say, design error that is 23 uncovered. That is communicated to the appropriate affected 24 licensees for action and their determination and their 25 assessment. The process calls for the licensee to take that
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102 1 information and make an operability determination.
() 2 3
DR. KRESS:
MR. WERMIEL:
Okay.
Using guidance that is out there in 4 Generic Letter 91-18 and other places. It is no different 5 for a computer code than it is --
6 DR. KRESS: So they go through that. And they are 7 allowed to run it until they finish --
8 MR. WERMIEL: Exactly. There are certain 9 differences that are predicated under 50.46 that we can 10 mention, but the general process is exactly the same. They l
11 are forced to take that information and to determine the 12 impact of this noncompliance, nonconformance on their 13 ability on to continue to operate. I 14 DR. KRESS: It is viewed like a noncompliance.
() 15 MR. CARUSO: Yes.
16 MR. WERMIEL: Exactly. That is exactly right.
17 DR. KRESS: Thank you, that helped.
18 DR. WALLIS: I wanted to discuss what we are 19 trying to-do today. We were going to have this update on 20 RETRAN-3D, which we hoped would have been a more positive 21 report. And then we are going to hear from Norm Lauben, I 22 believe, about the more general question of how should one 23 go about setting up guidelines for any code review.
24 MR. WERMIEL: That's right.
25 DR. WALLIS: And then this afternoon, what we
(~'
\
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103 1 wanted to do was have an executive session, but to which all U()
2 of you are invited, without a transcript, so we could have a )
3 sort of down to earth, straightforward discussion of how
- 4. _should one go -- what have we learned from this? How should 5 one in the future go about code reviews? Can we set up some i i
6 principles or anything? Just see, because I think all of us 7 are grasping for what the process should be.
8 MR. WERMIEL: That is exactly right.
9 DR. WALLIS: And I hope that will.actually be very 10 helpful.
11 MR. WERMIEL: Yes. 1 i
12 DR. WALLIS: Maybe we should move on then to, 13 first of all, what I think Norm was going to talk about.
14 And then we can have lunch and then we can come back and go 15 to work.
16 MR. LAUBEN: Discuss with you that we didn't have 17 a formal presentation.
18 DR. WALLIS: Well, you are on the schedule, Norm, 19 so you are on -- what are you going to do?
-20 MR. BOEHNERT: Ralph indicated to me that Norm 21 didn't have any comments.
22 DR. WALLIS: It says Norm Lauben.
23 MR. LAUBEN: I do not have a presentation.
24 DR. WALLIS: Well, then perhaps we should move to 25 the presentation by et al.
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i 104 1- SPEAKER: Ralph, if you had any comments about'the
, 2 guidelines.
3- SPEAKER: I don't have any comments about the 4 guidelines other than to say that the staff is continuing to l I
5 work on them. And I believe we had planned on having them I i
6 in July, late June,' early July, a draft.
l 7 SPEAKER: Norm, why don't use the mike. Over i 1
8; h' e r e , around the other side.
9 DR. WALLIS: Norm, why don't you sit up front. I 10 am going to direct you to sit up front.
l 11 DR. SEALE: We will look you in your squinty eyes. '
12 DR. WALLIS: Transparencies or no transparencies.
13 MR. LAUBEN: Actually, I do have some that I could l 14 show, just as a matter of background, but not to talk about
'15 this -- is this on?
16 DR. WALLIS: Yes. !
17 MR. LAUBEN: Oh, I am sorry. I am Norm Lauben j 18 from the Office of Research. But, yes, to answer your first 19 ' question, we said we would have, by August, after review by l 20 Research and NRR, a draft of the Regulatory Guide for the 21 committee to look at. That was our latest agreement. Okay. I 22 So that -- so we will have that.
23 _DR. WALLIS: Well, are you going to be here this 24 afternoon?
25 MR. LAUBEN: Yes, I will, i
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105 1 DR. WALLIS: I think that will be very_useful,
() 2 3
because of the sense I think of this committee was that, really, we shouldn't have to get into the details of looking 4 at equations in the codes and so on. That should be stuff 5 which is done at some other level. But where the ACRS could 6 really help would be in setting up, helping you set up some 7 of the principles to used, the guidelines, efforts of the 8 overall_ structure of how one goes about it, not the details.
9 MR. LAUBEN: Right.
10 DR. WALLIS: And that is what I hoped you would be 11 able to enlighten us on.
12 MR. LAUBEN: Right. Well, in December, the 13 presentation I made when through the basic principles, and 14 the first basic principle was that this is going to be f 15
( _
basically a top-down kind of activity that is similar in i
- s. _
i 16 nature to what was done with CSAU, that is the first basic 17 principle.
18 The second basic principle is that because, when l
19 you are dealing with a large -- well, it is even true of I i
20 LOCA, but when you are dealing with transients and 21 accidents, very frequently you are not talking about one !
22 code for a particular transient and accident, you are ,
23 talking about several codes. So we introduced the 24 evaluation model concept as defined in 50.46 and said that 25 that would be -- a similar concept would be introduced for O ANN RILEY & ASSOCIATES, LTD.
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s 106 1 call the transients and accidents.
()
2 3
And the other thing is that merging those two, that the evaluation model concept is really not at odds with 4 the ideas that are embodied in the CSAU or development and 5 assessment process.
6 The third thing, I.think, is I was listening this 7 morning -- maybe this get into this afternoon's discussion.
8 Is that the whole idea of an error-correction !
I 9 protocol? There's a rather complicated error-correction '
10 modification protocol in 50.46. Something like that I guess 11 is needed for the transient and accident codes. And so I 12 think -- I had started to write something about -- in the 13 outline I presented or in the outline we presented to you I 14 think informally we did talk about change protocol, but I
() 15 think the principles weren't discussed in any great detail.
16 So I just think the basic thing is the top-down j 17 approach which makes a review like RETRAN extremely 18 difficult, because the top-down approach says you need to I 19 first of all define your transient and define your plant. !
20 And once you've done that, then the assumption is that you 21 have a code that's frozen and error-free.
22 Well, obviously we're not meeting very many of ,
23 these criteria, these three criteria.when it comes to the ,
24 RETRAN review, so I think as you noted, Dr. Wallis, that it 25 was probably optimistic to say that we could proceed apace O ANN RILEY & ASSOCIATES, LTD.
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l 107 i i
I without making sure that some of these things happen. l 1
2 DR. WALLIS: This really concerns me -- it l(
3 concerned me with AP600, too -- is that you go through all l
4' this stuff and then it comes up to the ACRS and we're "5 already to make a decision and sign off, and this is the end 6- of the process and~everything's great, and that's the time 1
7 when someone starts to say gee, whiz, there's a fundamental i
8 error in a code. That's completely the wrong place and time I 9 for it to appear.
10 MR. LAUBEN: Presuming that we followed some of 11 the principles for the kinds.of things that you would do in )
1 12 a top-down review, one of the things you start with a code I 13 or an evaluation model description that's very accurate, and i
14 you -- it's very specifically in a CSAU document, for !
(q ,/ 15 ' instance, it talks about the adequacy of the equations and 16 -the adequacy of closure relationships. Obviously you need 17 to do that, but you can only really do that effectively in 18' the context of knowing precisely the transient and precisely 19~ the plant that you're applying these things to or the class 20 of plants.
21 So, I mean, I appreciate the idea, and maybe in 22 the area of neutrcuics you can do this to some degree, but I 23 appreciate the idea of trying to do a generic review that 24 minimizes what you have to do when you come to the transient l 25. and the specific plant. But I don't know how much you can l
l l
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f 108 1 minimize it.
2 When we -- a lot of this came from the Maine 3 Yankee activity, and when we looked at the Maine Yankee 4 activity -- in fact, it turned out that a lot'of it was 5 RETRAN that we had to review at Maine Yankee -- but what we 6 found out was that there are -- that when you do a generic 7 review and when a generic review of RETRAN-02 is done --
8 back in the '82 '83 time frame, by the way; it was quite a 9 while ago -- when you are going to do a generic review of a 10 code who by design is t1 'ing to do a lot of transients and 11 accidents, what you have to do is write about 40 or 50 12 restrictions on how you -- that's what happened back then --
13 on how you are going to use the code for a particular 14 application. So -- and whether or not these restrictions
() 15 end up getting followed in the plant-specific application or 16 not. But this is what happens, I think, just by the very 17 nature of trying to do a generic review of a code that's I 18 going to have many, many applications.
19 I'm not saying it can't be done. I'm just saying 20 you have to realize that there are likely to be certain 21 limitations. And I think, as Joe Kelly pointed out to me, 22 when you'look at the RETRAN documentation today, you find 23 out indeed there are restrictions within that documentation 24 itself, but you have to be able to pull those out and codify I 25 them in some way, I guess. But whether or not they turn out l
l l
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't 109 1_ to be adequate, given what you would do in a top-down
) 2' review, I. don't know.
3 DR..WALLIS: I thought the general idea was that 74 something.like the following, say the ASME has a boiler room
.5 ' pressure vessel, so on, and they've done all this stuff, and 6 somebody's got to make a boiler, obeys the code, follows the 7 . rules, and is okay. I was hoping that we were moving to 8' something similar with-these thermal-hydraulic codes, that 9 this code is so useful and robust and error-free that you 10 can use it, and you don't have to have 50 or so restrictions 11 for its use for just one specific purpose. That it's so l
12 all-purpose that it's been shown to be good for a certain i l
13 generic problem.
14 MR. LAUBEN: Well, that would be nice, but I guess !
( 15 I don't think --
16 DR. WALLIS: Your view is that we'll never get to 17 that.
18 MR. LAUBEN: I'm afraid not. I think -- or at i 19 least not in my lifetime. I think that the thing that --
20 one of the other things that we learned in the CSAU 21 experience and in similar applications since then, as for 22 instance AP600, is that assessment becomes extremely 23 important, how the code is assessed, both the individual 24 models in an integral sense, and if you, for something as 25 complicated as a LOCA at least, you better not wander very ANN RILEY & ASSOCIATES, LTD.
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110 1 far outside that assessment base, or you're bound to get in 2 trouble.
(~}
v And I think that that means by definition then 3 that you've done all the possible assessment that you need 4 to do for a code as general as RETRAN, and I don't think 5 that's possible to do that, and I think even the manual says 6 that they didn't really do that, and they can't possibly do l 7 that.
I 8 DR. WALLIS: Are you saying that the codes are so 9 approximate or crude or whatever that the assumptions in i 10 them require sort of tuning for applications, you put l 11 coefficients here and there, of course you can fit data with 12 any number of -- with any lousy theory if you have enough 13 coefficients in it, and therefore this is what's been -- the 14 state of the art. Therefore, that's the way the codes are (3 15 validated.
J 16 MR. LAUBEN: Well, I don't know if tuning is 17 right, but rather that you have to be sure that the models 18 and correlations and equations are appropriate.
19 DR. WALLIS: But they become, rather than having 20 the authority of proven physics and engineering, it's 21 validated with a large spectrum of tests, so that you can 22 accept them and use them. It's more like a recipe which 23 people have found to be adequate, though with many faults, 24 for certain purposes, therefore you only use it very 25 cautiously for those purposes. That seems to be -- you seem ANN RILEY & ASSOCIATES, LTD.
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111 1 .to be inclined to'the second.
2 M
.R. LAUBEN: Yes.
( Maybe I'm too colored by the 3 experience that we've had in the LOCA reviews. It may be 4 true that -- well, let me say this. ~It shouldn't be as 5- difficult for most other transients, but I wouldn't.want to 6 say that it is until it's been thoroughly explored.
7 DR. WALLIS: Well, I looked at the CSAU 8 documentation, and-it' looked to me.as if that was'a pretty 9 good effort.
10 MR. LAUBEN: Yes. As a principle, indeed.
11 DR. WALLIS: It lays out a lot.of guidelines, 12 ' steps. Anything that you guys do-has got to be an 13 improvement on that somehow. That to me is the sort of 14 baseline I'm starting from. We have CSAU. It looks like a
() 15 16 good thing. A lot of pecple put a lot of work into it.
MR. LAUBEN: Right.
17 DR. WALLIS: A lot of people approved it at the 18 time.
19 MR. LAUBEN: Right.
20 DR. WALLIS: If you're going to come up with j l
21 something to replace it, you've got to do a very good job. 1 22 MR. LAUBEN: -As a matter of fact, I don't think we 23: .w ould come up with -- it's not my intent -- in fact, I find 24 myself not replacing it, but rather trying to broaden its 25 scope for these kinds of things and to apply the lessons ANN RILEY & ASSOCIATES, LTD. !
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-i
7 112
'3J we've learned in subsequent reviews to that. And that's --
2 for instance, I think we've learned a whole lot more about (a}
3 scaling.than we did back in CSAU. So I think we need to be 4 sure that we apply those lessons as well. And I think 5 that -- well, that in particular. And I think since there 6 are, asJI said, usually more than one code involved in an 7_ accident analysis, although the trend over the years is to 8 go to fewer codes, I think that we need to be sure that the-9 whole is considered in the top-down approach that you use to 10 this.
11 MR. CARUSO: I believe Norm hit on an important 12 fact, the fact that because of the cost in teaching people 13 and maintaining the expertise to run these codes, there is a 14 natural tendency to go toward one -- a smaller number of
() 15 codes that can do many things. And I believe that the 16 ' problems that we're seeing arise because we try to make 17 these general-purpose codes have as many capabilities as 18 possible that are able to analyze different types of steam 19 generators,-BWRs and PWRs. In some cases some of these 20 codes are used for -- there are nuclear applications that 21 are very strange. And the difficulty is that when you try 22 to build in this capability to model anything, people use 23 that capability.
24' l DR. SEALE: No good turn goes unpunished. -
25 MR. CARUSO: And creative people, people who ANN RILEY & ASSOCIATES, LTD.
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113 1 are -- creative people do the damnedest things.
()
I 2 DR. SEALE: Yes.
3 MR. CARUSO: And it's extremely difficult to
'4 assess in advance how creative people can be. I just don't 5 know how to do that. And I'll tell.you it's my experience 6 that the -- it's my experience that the more experienced the 7 user is, the better they are able to justify their 8 creativity, which really.gets -- makes it hard.
9 MR. LAUBEN: Would you be interested in a couple 10 of what I would call factual background slides about 11 transient analysic?
12 DR. WALLIS: I'm still puzzled how you're going to 13 come up with a reg guide in August. I would think that --
14 MR. LAUBEN: Okay. Let me tell you what.
15 DR. WALLIS: You have to be able at this stage to 16 say I've thought about the problem, I've laid out sort of 17 some specific --
18 MR. LAUBEN: Yes.
19 DR. WALLIS: I've thought about the principles I'm 20 going to use --
21 MR. LAUBEN: Um-hum. I l
22 DR. WALLIS: I mean, there's all kinds of things, i
23 I've got some kind of outline --
24 MR. LAUBEN: Right.
I - 25 DR. WALLIS: Of --
l I
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p 114 1 MR. LAUBEN: Right.
)
2 DR. WALLIS: The thought process I'm going 3 -through.
"4 MR. LAUBEN: Okay. As I' mentioned in December,
'5' theLphilosophy that we agreed on with NRR was that we were 6 going to write a very -- a fairly top-level regulatory guide 7 that would apply in general to all the chapter 15 transients.
i 8 and-accidents. However, then we would write appendices'that j 1
9 would be very specific to the particular class of events or 10 event, and so I think that's how I can do something by ,
i 11 September is to make sure that we have a fairly good i
-12. top-level document-for which'the principles -- those 13 principles should apply to most all the. transients and 14 accidents. :And it may indeed get somewhat more difficult to i
( 15 write the accident-specific. appendices. But as I do it, I 16 think-maybe it isn't going to be as dif ficult as I thought'.
17' But --
, 18- DR. WALLIS: Is this going to help us? I mean, I 19 thought --
20 MR. LAUBEN- I think it will, because --
21 DR. WALLIS: RETRAN comes before the ACRS, and I 22 guess the ACRS is asked to make some decision about is this 23 -good.for use, or are they going to believe the results of 24 it --
25 MR. BOEHNERT: Applicants.
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p 115 1 DR. WALLIS: Applicants' use. Can we believe the
~
2
. results that it puts out? That's -- I'm not sure that what l 3 you've described is going to help us in our evaluation of -
L 14 something like RETRAN.
5 MR. LAUBEN: Well, perhaps the real task is to
- 6
- decide-when you're doing a generic' review like RETRAN --
L 7 maybe this is a difficult. task -- is to say just exactly, l
8 now you've done a generic review, what then remains for the 9 applicant or licensee when he comes to his plant-specific 10 transient and his plant-specific -- that indeed may be l 11 something that needs to be set out.
12 DR. WALLIS: That should lead to more efficiency
-13 and less unnecessary work if we know that there's a certain 14 core -- i
() 15 MR. LAUBEN: Um-hum.
16 DR. WALLIS: Of competence in the code or 17 abilities of the code which has been established and doesn't 18 have to be questioned again every time --
19 MR. LANDRY: That's been the difficulty with the 20- historical RETRAN -- RETRAN-02. And that we discussed 21 previously when we met with the subcommittee that the 22 applicant or the individual utility, individual user of the i-l 23 code, because the assessment of the code was so poor, or so
-24 limited, would'have to come in with a 150, 300-page document 25' for-every transient they were applying the code to for their l
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116 1 plant.
() 2 One hope that we had had with this code version 3 would be that the assessment would be so robust that we 4 would save our staff time in not having to review a 300-page 5 assessment document for every transient for every plant the
-6 code was used for, that they would be able to come in with a 7 very small document saying we're using the code within the 8 constraints of its assessment and generic approval and we 9 say great, go away.
)
10 MR. LAUBEN: However.
11 MR. LANDRY: However, from our comments that we 12 made last March --
13 DR. WALLIS: That really concerns me. I have seen 14 it before in my short experience here.
() 15 We get these mountains of documents with 500 pages
'16 of computer printouts of transient curves, this, that and 17 the next thing, and we look at all that and now what is the 18 message? I mean then we start looking at the code and we l 19 say well, here is an equation in the code documentation that 20 we don't think applies particularly well to these 21 situations.
22 What are we supposed to -- I would tend to say 23 that if I don't believe this equation then forget.about my 24 500 pages of curve.
25 MR. LANDRY: That's where we are right now and O
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117 1 from the discussion this morning I think it should be
() 2 evident that we -- and looking at your comments, your 3 concerns, and looking at.some of the things that we have 4 seen so far, we are going back to looking at the 5 fundamentals of the code.and saying we have to resolve some 6
of these issues on the fundamentals of the code before we 7 can even get to addressing the concerns we have already 8 expressed about the state of the assessment of the code in 9 general.
10 MR. LAUBEN: I think that RELAP is a somewhat 11 general purpose code too, and when we --
12 MR. LANDRY: Which unfortunately gets misused very 13 heavily too --
14 MR. LAUBEN: Yes.
) 15 MR. LANDRY: -- because we have had people trying 16 to use it for containment analyses.
17 MR. LAUBEN: What was that meant to be about, 18 Ralph?
19 MR. CARUSO: Licensees. It was about licensees.
20 MR. LAUBEN: Oh, okay.
21 DR. KRESS: I remember Norm using it for that.
22 [ Laughter.]
23 MR. LAUBEN: But the point that I was about to 24 make about RELAP was that for every application that we felt 25 the need to use it or for the important applications in the
} ANN RILEY & ASSOCIATES, LTD, s_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
118 1 last several years, we have gone through the top-down, 2 PERT-based assessment _ process that looks like CSAU so that 3 we can determine whether the code could be used adequately 4 that way.
5 I am just saying that it would be nice to think
.6 that RELAP was the perfect code that could be used for a lot 7 of things without such a process but I am afraid that is 8 just not possible.
9 What Ralph I think is saying is you would like to 10 minimize the amount of plant-specific and accident-specific 11 work that.you can do, but I think only by going through the 12 process can you find out how much you can eliminate or not.
13 MR. LANDRY: Yes, that is exactly it, Norm. As we 14 have said.a number of times, the difficulty with this code )
15 is to be a do-everything code it has to be complex and it 16 has to have a lot of options and a lot of models which then 17 is going to translate into a lot of restrictions. When we 18' look at the code we see a plethora of correlations and some 19 apply well under these conditions and these transients and 20 some do not, and there has to be some statement as to which 1
21 will be used for which class of transient so that the user 22 does not just pick a correlation which is totally j 23 o inappropriate for the analysis being performed.
24 That is the nature of a code that is intended to 25 ~be so broad as to cover everything.
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i r
119 1 DR. WALLIS: My view is the expertise should then
() 2 be, that the source of this expertise should be.the 3 originator of the code, that you can't rely on the user to 4 be wise enough to know all the constrictions and all the 5 choices, which are the best choices, that the code itself 6 should have some sort'of expert system in it which says that 7 it's~been established by experiment that-this correlation is 8 best over this range and this correlation is best over that 9 range and so on, therefore it itself selects the best on the 10 basis of some criteria, otherwise you have --
11 MR. CARUSO: Unfortunately, Dr. Wallis, 12 unfortunately the code developers don't have to use it, 13 okay? -- to solve real world problems.
14 DR. WALLIS: That should be their punishment.
) 15 [ Laughter.]
16 MR. CARUSO: Well, it has been strongly suggested 17 by many people that the code developers actually use the 18 code, but historically that is not the case, okay? -- and 19 what. ends up happening is that the people who have to solve 20 the problems in the real world say, hmmm, what kind of j 21 correlation can I stick in here or --
22 DR. WALLIS: Folks who put the recipe in the l 1
23 cookbook should have to eat the results. ,
24 MR. CARUSO: Well -- i i
25- MR. LAUBEN: I think that that is one reason 1
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120 1 why -- I'll just say it again -- that integral assessment 2 becomes so extremely important and integral assessment has 3~ to be.the ultimate responsibility of the user.
4 It.is never_ going to obviate the need for very 5 ~ intelligent users, I'm afraid. It just will not.
- 6. I don't think you can make a code perfect enough 7 for someone just to pick up and use without -- without 8 having a certain responsibility of assessment for his 9 particular transient and -- j 10- MR. LANDRY: Well, there was a problem, Norm, back 11 in the RELAP-4 days'and one of the concerns was you had all l 12 these dials and you could tweak these dials and get what you j 13 wanted. The idea was going to a more advanced code and 14 removing that capability, but we are not going in that 15 direction.
- 16. MR. LAUBEN: Well, let me give you some numbers as 17 a user,.okay, which you probably know as a user --
18 MR. KELLY: Norm, I would like to interject for 19 just a second, 'This is Joe Kelly from the Office of 20 Research. !
21 I have been asked to review the drift flux models 22- in the code, so I just started this and started looking at-23 the RETRAN documentation, and there is one big thing 24 missing, and that is the User. Guidelines.
25 When you look in the list of what volumes there j
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e
121 1 are, there is no User Guidelines for RETRAN-3D. There is a
,m 2 User Guideline for RETRAN-02 and the statement in the
(\ s) ,
i 3 RETRAN-3D volume is that you should use the User Guidelines 4 from 02. But if RETRAN-3D has significantly changed a j l
5 number of the models in the code, I don't see how you can }
6 say just use the old User Guidelines.
7 That means there is no user guidance on how you 8 should use the new models, and to me that is worrisome.
9 MR. LANDRY: That's a concern which we raised 10 early-on, Joe, and one of the concerns we expressed to the l
11 applicant, that though it refers to the Guideline Volume 5, 12 which doesn't exist, and then they said, well, go back to 13 the RETRAN-02 Guideline. l 14 We said, well, why don't you have one? They said
/~N Ix) 15 that is going to take a lot of experience and user 16 experience and we won't have that for two to five years, and 17 we said we are not happy.
18 DR. KRESS: So what I have been gathering so far 19 is clearly it is up to the user, which in my parlance is the 20 applicant who is using it to prove his case. It is up to 21 him to be sure the code he is using is appropriate for the 22 application he is using it for.
23 MR. LAUBEN: Absolutely.
24 MR. CARUSO: That's correct.
25 MR. LAUBEN: And for you guys to know that you l
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122 ;
i 1 need-to see something like a User's Manual and need to p) 2 specify to them that we need enough detail in this thing !
3 that we can judge also that you have made a good assessment !
4 that'this code is applicable for your use.
5 I don't see any other way to do a review, Graham, !
6~ than go through it that way.
7 MR. CARUSO: That was one of the reasons why we 8 started to ask for copies of the code itself.
9 DR. KRESS: Yes.
10 MR. CARUSO: So that we could run it in-house and 11 see --
12 DR. KRESS: That helps you make an assessment of i 13 whether they have made the right assessment or not, i 14 MR. CARUSO: Right. Exactly, j
() 15 MR. KELLY: This is Joe Kelly again.
16 Dr. Kress, you are exactly right. In some places i
17 in the RETRAN documentation they are very frank and they l 18 separate the code assessment process, if you will, into 19 three sections -- verification, which is just making sure 20 that you have coded the equations correctly; validation; and 21 qualification, l 22 From my cursory review so far of the RETRAN 23 documentation it appears that verification has been done 24 excellently. The validation, which is actually assessment 25 against separate effects and integral effects tests, is very O
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F 123 1 slim. Most of_what you see in their assessment report is
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' plant calculations th'at just show-operability of the code, not actual quantification of how good it works.
4 DR. KRESS: That is generally the hard part 5 anyway.
6 :MR. KELLY: But for qualification, which is what 7 you just touched on, which is the actual application to an 8 individual plant or transient, it.is stated very clearly in 9 the RETRAN documentation that this is a general purpose 10 thermal hydraulics code which can be used in a number of 11 different ways. The responsibility is entirely with the 12 user to demonstrate that it is being used appropriately when 13 performing an analysis for a plant.
14 DR. WALLIS: Joe, while you are there, you said
) 15 verification of the code is excellent? What is the basis of 16 that statement?
17 MR. KELLY: Well, assuming one believes what is in 18' the RETRAN documentation, verification is defined as -- I 19 will never get this quite right -- but it is basically that 20 they took the equations and coded them correctly.
21 DR. WALLIS: Oh, it is the verification of proper 22 coding.
23 MR. KELLY: Right, so there is a -- I guess it is 24 in Volume 4, there is a list of all the various models, what 25 correlations go into that model, and then they have four 1
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124 1 different ways of checking it.
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( ) 2 One is a line-by-line coding inspection by an 3 independent reviewer. That is a huge job, and that 4 apparently has been done for every model in RETRAN, and that 5 is very impressive.
6 DR. WALLIS: So you mean the equations actually 7 describe what is in the code? That is very important. But 8 there is something that is even more important than 9 verification, and that is that the equations themselves are 10 the appropriate ones.
'11 MR. WERMIEL: That's validation.
12 DR. WALLIS: Right. That's validation? Oh, so --
13 oh, I see, so -- I wasn't sure what you meant. I thought by 14 validation you meant once you have got the right equations
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1, 15 'and encoded them properly that they actually work on real 16- problems.
I 17 MR. CARUSO: Usually you say verification is did j 18 you do it the way you said you did it, and then validation 19 is did you do what you really wanted to do, does it give you 20 the right answer. I 21 MR. KELLY: When you talk about having a general 22 purpose code that people could use and would simplify the 23 review, that is a goal I would like to have as well, but 24 what you need to do then for each of those transients, you 25 need to identify what the parameter ranges are for the O ANN RILEY & ASSOCIATES, LTD.
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r 125 1 important phenomena,'and then show that the models in the rs Q
- 0 ' code are valid over those ranges.
3- .Then what the applicant would have to do is just 4 show that his plant falls within those ranges and then it 5 would-be acceptable, but we are a long ways from doing that.
6 DR. .W ALLIS: I think there should be another step 7 here. There should be a Step Zero or something called 8 " formulation."
9 DR. SEALE: Yes.
10 MR. LAUBEN: In CSAU that is exactly what it is.
11 It says that'you have to have that.
12 DR. WALLIS: Well, I guess we are going to break 13 up soon for lunch, so I am getting such a queasy feeling I 14 am not sure I even want to go to lunch.
15 I mean it seems to me that everybody at every
- 16. ' stage here, whether they are looking at formulations in the 17 code or any of the other things that have to be looked at, 18 it's beginning from the beginning. We don't have some 19 established base which is so sound that we just have to fix 20 up the details. Maybe my impression is all wrong. I would 21 hate to get on an airplane which was designed by the Wright 22 Brothers today.
23 MR. LANDRY: Dr. Wallis, I think when we started 24 the review we started at that point that we believed we were 25 starting from a good base, and it is through our use of the
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126 l'
code and through our review'that we are backing up, stepping
() 2 further back, further back. As we go through the review we 3 'are backing up even further because the problems we are 4 running into in this review and because of use of the code, 5 the problems are forcing us to go more and more fundamental 6 in our review and in our look than we had really anticipated 7 we would need to go, so I am not sure that would say it is a 8 queasy feeling.
9 It is a feeling that we need -- that because of 10 the way we are reviewing now, we are having, we are learning 11' so much that we are going far more fundamental into the 12 review than we had.
13 DR. WALLIS: I agree. I think you are doing the 14 right thing. My queasy feeling is about whether we are ever k 15 going to meet any of the objectives that I thought we had 16 set out on this journey.
17 MR. LANDRY: I am still optimistic. I believe we 18 will. We have some hurdles that we have to overcome. We 19 have some hurdles that we have to overcome. We have to deal 20 directly with the applicant and with the code architects.
21 We need to resolve some of these issues and determine how we 22 are going to take the next step, but I am still optimistic 23 that we are going to have a good result.
24 Quite frankly, in spite of all the problems, I 25 think what we are doing is coming up with a good review.
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1 127 l
1 DR. WALLIS: Bob? Tom? !
-( ) 2 DR. KRESS: No.
3 DR. WALLIS: We should have a break. I think we 4 should meet, can we meet in this Open Executive Session that I
5 is referred to here -- is that without the Reporter this '
6 afternoon?
7 MR. WERMIEL: Yes.
8 MR. BOEHNERT: Yes. l 9 DR. WALLIS: I think we sort of need to get down 10 to brass tacks and revisit all the fundamental questions and 11 say.where do we go from here.
12 MR. WERMIEL: Yes.
13 DR. WALLIS: Maybe we can sit around this table if 14 people want to participate.
15 MR. WERMIEL: That would be fine.
1 16 DR. WALLIS: Shall we say one o' clock? Is that a j l
17 good time. I 18 MR. WERMIEL: One is fine. l 19 DR. SEALE: That's fine. I 20 DR. WALLIS: So in that case, we are adjourned as 21 far as the reporting of this goes. )
22' [Whereupon, at 11:44 a.m., the recorded portion of 23 the meeting was concluded.]
24 25 t
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings
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[Gi before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: MEETING: THERMAL-HYDRAULIC PHENOMENA CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original fs
( ) 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 reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
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Mark Mahoney ()
Official Reporter Ann Riley & Associates, Ltd.
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