ML20195D463
| ML20195D463 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3081, NUDOCS 9906090174 | |
| Download: ML20195D463 (231) | |
Text
'g * . , 4
-a a f
~
lfh,\ c: ic j ,
- M' % b ' Q
@;( k# [M
,.,,% fint b !fh 6;kfk;kdM@MNkdNtb $$NOI R@h@k 'd fd@@y44@k%#9%I .
k aygyp:,.q m, o r p q q ,,gan g g gr y lIyNu dV I
-pp >f+.-
j .
7 y ;,
b . ,f-
.g.: $ ;
,g.
k,4 ' 'E .
' *u,1, $
+.
4f
, 6:E' .. .
4:
d' 4
0
'p.f.,.;;.g
, y. s.
- L
,j '
., yl}, hfl Yt)
- ,,; f o; p'
c, _'., 1 Jr
.z - .
1
- i?[:;,gri ' ii . .J , , , .
" e
- f r <>: 'l 4> '(;
8 R ~Q ,' .. V , .. . . p . .
.:. .'., w H.' - *.
bria, $
- $ v
~
- s
\t .
,a.
- 2.
- g; . ..
y.
'~ V
^' . ~
y
- g$ i <
,. . lE'
~ ' ' ^ .*
l p .i. < ?* < ' .,, .
's . Y' .:
.,1-
' ~
p
') ,, , , . , -
& y 4; ,
- f. ,,. i.. '
.j ..
fl(g"4 1+ h ' .'
.Q, ' . l .. -. .
" q, +,s 3.{!/* g' g ..-
M. .f.,. s . =
h h
+w 3
ho% gear
- _;f .~
ORIGINAL kbkdT'3o3/
S OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: 463RD ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
TRC4 t' A C R S '
RETJRN ORIGINAL -' W T~ BJWHITE ,
M/S T-2E2C 415 7:3C g THANKS .'
Docket No.:-
t Work Order No.: ASB-300-808
/
LOCATION: Rockville, MD
/
DATE: Thursday. June 3,1999 PAGES: 267 - 458 9906090174 990603 T 08 PDR 1b ANN RILEY & ASSOCIATES, LTD.
,. a 1 1025 Connecticut Ave.,NW, Suite 1014 d
W Washington, D.C. 20036
$G8~R'fiM2)fMM%,v u 3 uf100 LO?y M,.n5}n'.
loathefeoitheCming
-- r
^
W Y-(
n :.
l/
L DISCLAIMER
-UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JUNE 3, 1999 The contents'of this transcript of the proceeding of-the-United States Nuclear Regulatory Commission Advisory j ) Committee on Reactor Safeguards, taken on' June 3, 1999, as reported herein, is a record of the discussions recorded at the meeting held on the'above date.
This transcript had not'been reviewed,_ corrected and edited and it may contain inaccuracies.
t.
w O .
4 267 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 MEETING: 463RD ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7- ***
8 9 U.S. Nuclear Regulatory Commission 10 11545 Rockville Pike 11 Conference Room 2B3 12 Two White Flint North 13 Rockville, Maryland 14 Wednesday, June 2, 1999
() 15 The subcommittee met, pursuant to notice, at 8.:30 16 a.m.
17 MEMBERS PRESENT:
18 DANA A. POWERS, Chairman, ACRS
'19 ' GEORGE APOSTOLAKIS, Member, ACRS
-20 ROBERT L. SEALE, Member, ACRS 21 GRAHAM B. WALLIS, Member, ACRS 22 THOMAS S. KRESS, Member, ACRS I i
23, .MARIO V. BONACA, Member, ACRS 24 ROBERT E. UHRIG, Member, ACRS 25 WILLIAM J. SHACK, Member, ACRS i
f
~ (_-
ANN RILEY & ASSOCIATES, LTD. !
Ccurt Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 4
268 1 PROCEEDINGS
<~s
's 2 I
V [8:30 a.m.]
3 DR. POWERS: The meeting will now come to order.
4 This is the second day of the 463rd meeting of the 5 Advisory Committee on Reactor Safeguards. During today's 6 meeting the Committee will consider use of averted onsite 7 costs and voluntary initiatives in regulatory analyses; 8 development of a low-power and shutdown risk program; 9 strategies for ACRS review of license renewal activities; 10 options for crediting existing programs for license renewal; 11 proposed resolution of generic safety issue GSI-165, 12 spring-actuated safety and relief valve reliability; a 13 report on the joint ACRS/ACNW working group; proposed ACRS 14 reports.
()
,m 15 The meeting is being conducted in accordance with 16 the provisions of the Federal Advisory Committee Act. Dr.
17 Richard P. Savio is the designated Federal official for the i
18 initial portion of the meeting.
19 We have received no written statements or requests 20 for time to make oral statements from members of the public 21 regarding today's session.
22 A transcript of portions of the meeting is being 23 kept, and it is requested that speakers use one of the 24 microphones, identify themselves, and speak with sufficient 25 clarity and volume so that they can be readily heard. l ANN RILEY & ASSOCIATES, LTD. I
[")T
's Court Reporters 1025 Connecticut Avenue, NN, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 i
i 269 1 Do Members have any comments they want to make 2' during the opening part of this meeting?
3 DR. KRESS: I think our designated Federal 4 official must be different.
5 DR. POWERS: We have changed our designated l 6 Federal official from Richard P. Savio to Sam Duraiswamy, 7 and we have -- I'd like to introduce to the Members Edith 8 Barbley, who is from NMSS, a group that we have limited l
9 interactions with, so she can acquaint us with that 10 organization. She is on rotational assignment to the 11 ACRS/ACNW staff, and she's going to be here with us for two 12 months.
13 Well, Edith, approximately.
14 MS. BARBLEY: They said 45 to --
15 DR. POWERS: Forty-five to 60 days. Well, you're 16 very welcome, and we look forward working with you. And so 17 when Members see her wandering the halls, don't ask to see 18 her badge.
19 [ Laughter.]
20 Edith, you'll be working across from Sam?
21 MS. BARBLEY: Yes, and David. Thank you.
22 DR. POWERS: And David. Well, you're very 23 welcome, and I hope you enjoy your stay here with the ACRS. !
24 We're much better than the ACNW.
25- (Laughter.)
s O ANN RILEY & ASSOCIATES, LTD.
V Court Reporters l t
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
L
p.
J 270 1 With that, I think I'll turn to the first topic on 2 our agenda, which is the'use of averted onsite costs and the
)
1E issue of voluntary initiatives in regulatory analysis.
4 Averted onsite cost has been a theme of interest to the ACRS
'S for some time, I believe.
6' DR. KRESS: It has. We've' talked about it before.
7 DR. POWERS: Okay. Dr. Kress, if you'll take over 8 this portion of the meeting, I appreciate it.
9, DR. KRESS: Okay. Just a little bit of 10 background. When the Agency does backfit analyses, which it 11 has to do whenever it's imposing new requirements that are 12 not compliance issues or such, they do a backfit, and this 13 involves determining the costs to the -- the total costs of 14 the thing to both NRC and the licensee, as well as the
() 15 16 benefits, and the' costs involve -- they've traditionally included what's called averted onsite costs, and those are 17 costs that mostly accrue to the. licensee for, you know, if 18 you have a -- if you have an accident because you_didn't 19 have this rule or requirement, then you're going to crap up 20 your system and you have to clean it up and fix it, and 21 you've got lost power and lost time and down time, and all 22 those things cost. And NRC has traditionally included those 23 in their backfit analysis for the costs.
24- The benefits include man rems saved by the rule as l 25 converted into dollars, and one of the issues associated
]
i
~
/"'N ANN RILEY & ASSOCIATES, LTD.
- (s,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 l
271 l l' .with that has been what do you -- when you talk about
' 2- . calculating the change in release of fission products as a l
3 : change in man rems, do you give credit for voluntary actions 4 'that are not under NRC's regulatory control? And so we'll
.5 .also hear about that.. So it's those two parts of the 6 regulatory analysis process for backfits we're going to
-7 hear.
8 With that as an introduction, I'll turn it over --
9 DR. POWERS: Let me ask a couple of quick 10 questions, Tom.
11 Now the regulation itself speaks to societal 12 costs.
13 DR. KRESS: .Um-hum.
14 DR. POWERS: And a lot of the debate on averted
() 15 16 onsite costs has been personalized by the licensees.
really is societal costs and societal benefits.
But it 17 DR. KRESS: That's the debate. The licensee 18 claims that these are costs borne by the licensee himself 19 that are not really societal, where NRC disputes that, and l
}
20 the licensees also say that this is inappropriate meddling 21 of NRC in the management issues. These.are -- and that ;
1 22 besides that they have insurance to cover these, and --- I 23 DR. POWERS: But in a -- I mean, I guess.there are 24 a couple of issues that come to mind there. When we do the l l
25 cost of a backfit we include in that. cost the cost of ANN RILEY & ASSOCIATES, LTD.
- O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 272 I- 1 ' downtime - . replacement power that you have to make in
- ['N 2 downtime.
(-) -
3 DR. KRESS: Um-hum. j 4 DR.. POWERS: Okay. But now we don't want to 5 include it as a consideration in the benefits that you 6 derive ~here? I i
7 DR. KRESS: It is included. I mean, 8 traditionally --
9 DR. POWERS: Traditionally. /
~
10 DR. KRESS: But that's the dispute.
11 DR. POWERS: The contention, i
12 DR. KRESS: Yes, the contention. 1 13 DR. POWERS: The other thing that I guess I don't 14 understand very well is that when we compute the benefits in j
j 15 , terms of man rems saved, we monetize that by $2,000 per man 16 rem -- averted.
17 DR. KRESS: Yes.
18 DR. POWERS: And that $2,000 per man rem comes I 19 think from a consideration of fatalities.
20 DR. KRESS: It does.
21 DR. POWERS: And --
22 DR. KRESS: It's derived from the cost of a life.
23 DR. POWERS: But the societal costs of an accident 24 would include not only fatalities but the burdens imposed by 25 latent injuries.
/"~N ANN RILEY-& ASSOCIATES, LTD.
\_,f Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ;
Washington, D.C. 20036 '
(202) 842-0034
r- ,
273 1 DR. KRESS: Yes. That is a subject we.ought to
(~h 2 take up'at some time. It won't be part of this one, but 13 'that.is.a subject of interest, where does the $2,000 per man !
l 4 rem come from and does it actually cover those things as !
-5 well as -- at one time it was considered to be already 1
?6 discounted at that value.
l i
7 DR. POWERS: Um-hum.
8 DR. KRESS: For future occurrences. But that's 9 changed. They no longer consider that a discounted value.
10 But that is an issue, what does the cost actually cover.
11 DR. POWERS: The other point that comes to mind is 12 this issue of voluntary initiatives is not confined just to 13 regulatory analyses. We have considerations, a broader 14 interest in voluntary measures.
,) 15 DR. KRESS: That's an excellent point. You know, 16- anytime we do a risk-informed activity,' the question's going 17 .to come up. So this has much broader implications, that 18 part'of.it, than does just for regulatory analysis. So it's
- 19. ~well worth thinking about in those. terms.
20= DR. POWERS: Well, thank.you.
21 DR. KRESS: Those were very good comments, Dana.
22- DR. POWERS: Just trying to get myself squared 23 away here.
24 DR. KRESS: You know, my original concern about c 25 averted onsite costs was both whether or not you should
(~'
N Juni RILEY & ASSOCIATES, LTD.
Court Reporters 1025' Connecticut Avenue, NW, Suite 1014
! Washington, D.C. 20036 (202) 842-0034 t
7 L 274 1 . include them, but it was how'you included them, because
( ) :2 you're talking about if you have an accident sometime in the
- 3' future, you may~have this cost as some probability. So you 4 have 'ar future probabilistic cost that you're mixing up with h
i 5: if you pass'this rule it's sure --
6' DR. POWERS: Yes, there's some --
l 7 DR. KRESS: Have a cost of' implementing --
8 DR. POWERS: There are hard dollars and soft.
l 9 ' dollars.
10 DR. KRESS: So it's hard dollars and soft dollars,.
11 and you have to handle those correctly. And that was one of
, 12 my concerns about this at first. But with that, we'll just 1
13 turn it over to let'you educate us on this issue.
14 MR. FELD: I might just mention before I get into
() 15 the heart of my presentation that the staff had issued a 16 NUREG that. basically dealt with the reassessment.of the 17 dollars.per person rem value, and when we recalculated that l
18 value, which is now $2,000, we did take into account not 19 only fatalities but also injuries and other. health effects, 20 latent health effects. Basically the approach was to try 21 and-weight the -- to apply the conversion factors to a death 22 -might be a factor of 1, .but to a. fatality it might -- there i
23 was a decision made that it was equivalent to about some L 24 ' fraction of a death, and therefore it was weighted in'that 25 fashion.
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
-Washington, D.C. 20036 (202) 842-0034 j i
275 1 DR. POWERS: Okay. Now, I am familiar with a
.; 2 Brookhaven report that wrestles with the cost of a fatality.
3 Maybe I'm r.ct familiar with your NUREG.
4 MR. FELD: Yes. The Brookhaven report was a 5 contractor study that supported our NUREG. Unfortunately I 6 don't have the NUREG number right in front'of me, but it was 7- published about two years ago, three years ago.
8 DR. POWERS: If you could remind me of it, 9 whenever we have a change, that might be useful for me to 10 look at.
11 DR. SEALE: So what you're saying is that when you 12 .take the $2,000-per-fatality number, there's actually 13 subsumed into that some proportionate number of injuries of 14 varying severity, and the offset costs for those are also
() 15 included in the $2,000.
16 MR. FELD: Right. To be more precise, the $2,000 17 is based on the -- on a value of life, but when we looked at 18 the expected consequences of a person rem in terms of health 19 effects --
20- DR. SEALE: Yes.
21- MR. FELD: We didn't .'urt account for deaths, we 22 accounted for latent health effects as well as injuries.
23 My intent this morning is to discuss two issues, 24 both pertaining to the NRC's regulatory analysis 25 methodology.- The first relates to our treatment of averted O ANN RILEY & ASSOCIATES, LTD, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ,
(202) 842-0034 1 ..
276 1 onsite costs in regulatory analyses and the second concerns
,() 2 the treatment of voluntary initiatives.
3 I would first like to turn to the treatment of 4- averted onsite cots. The staff recently prepared a 5 Commission paper which was a response to a Nuclear Energy 6 Institute letter which requested that the Commission O 7 reassess its treatment of averted onsite costs in the 8 regulatory analysis. A copy of that Commission paper, a 9' draft was submitted to this committee about two weeks ago.
10 And, basically, the conclusion of that paper was that we did 11 not recommend any changes in this policy.
12 I think it would be helpful initially to define l 13 our terms. Averted onsite costs are basically the 14 consequences of averting an accident that typically accrued
() 15 16 directly to the licensee. There are a number of elements that go into what makes up averted onsite costs. Typically, 17 it would include replacement power, it would include 18 decontamination and cleanup costs. It might include certain 19 repairs and modifications if, in fact, the accident were not 20 sufficiently severe that there was a likelihood that the l 21 reactor could be restarted. It also could include economic 22 penalties associated with early decommissioning. And, )
1 23 lastly, it could involve certain administrative and legal l l
24 costs that might he associated with a whole series of i
\
25 litigations or lawsuits that the licensee would face as a I
)
ANN RILEY & ASSOCIATES, LTD.
y,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
277 1 result of an accident.
)
2 DR..KRESS: I notice with the decommissioning 3 costs, you put the words "early decommissioning" on there 4 because that is the point.
5 MR. FELD: You are looking at the differential 6 between what are the costs if you decommissioned --
7 DR .. KRESS: At the end of life.
8 MR. FELD: -- it under the normal -- if it had 9 operated to its completion versus what it would cost if you 10 had to' decommission it earlier.
11' DR. KRESS: And that is an essential difference.
12 MR. FELD: There is a differential there that 13 would be of some importance.
14 DR. KRESS: Is it true that these AOSCs are quite
' () 15 often the predominant costs in the regulatory analysis?
16 MR. FELD: It can very well be. Certainly the TMI 17 experience would suggest that it is. They are trying to 18 place an economic value on averted onsite costs in some 19 general sense. It is a little bit difficult, it is going to 20 depend on the severity of the accident and, even more 21 importantly, it is going to depend on the point in time at
.22 which that accident occurs. The later it occurs in the life 123 of the reactor, for. example, the smaller would be the 24 replacement power penalty, the smaller would be the early l 25 decommissioning penalty, and so forth.
l
('~ ANN RILEY & ASSOCIATES, LTD.
A Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l-1 1
l
- t. I
~
F7 l l \
j..
278
[
1 DR. SEALE:
In the case of TMI 2, how long after I
[
2- the accident was the cost of replacement power.taken off the I 3 table?
L 4 MR. FELD: In theory, it should have been taken 5 off the table -- it should be only accounted for during the 6 period of time that the TMI reactor was assumed to -- would 7 be assumed to have been operating.
8 DR. SEALE: Yes. )
9 MR. FELD: In other words, if you look at -- you 10 say if the TMI unit had 40 years of useful life to it, and 11 the accident occurred in its 30th year, for example, then l 12 the replacement power cost should be -- should capture the 13 incremental costs associated with those 10 years for which 14 the plant was not available.
DR. SEALE:
( 15 So it should, in the case of TMI 2, I 16 run for 39 years.
17 MR. FELD: Correct.
18- DR. SEALE: Wow.
19 DR. KRESS: And there is still consideration of 1
20 license renewal in that?
21 MR. FELD: And we do account for -- we have looked 22 at the effects of license renewal on that result. It turns ,
23 out that thUse additional years, because of discounting and 24 present worth considerations don't weight all that heavily. j
. 25 DR. APOSTOLAKIS: Now, why do you limit the costs 1 l (~g - ANN RILEY & ASSOCIATES, LTD.
i V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
-Washington, D.C. 20036 (202) 842-0034 l
l 1
m
1 279 1 to onsite? I mean TMI showed,that the whole --
[)
U 2 DR. KRESS: Oh , it is not limited, but this, the 3 offsites are not in dispute, it is just the onsite.
4 DR. APOSTOLAKIS: Oh, 5 MR. FELD: If you averted an accident, the staff 6 calculates the reduction in person rem, it calculates the 7 reduction in offsite property damage, and we say it should 8 also account for the averted onsite property damage costs as 9 well.
10 DR. APOSTOLAKIS: No, no, what I meant was that --
11 I mean you may have an accident in New York and San Onofre 12 is shut down. Is that part of --
13 DR. KRESS: That is not part of it.
14 DR. POWERS: No.
() 15 16 happen.
DR. APOSTOLAKIS: I mean that is what is going to 17 DR. KRESS: That is an interesting thought.
i 18 DR. AP^STOLAKIS:
That is exactly what is going to i
19' happen.
20 DR. SEALE: Well, it did happen. The B&W 21_ accident, with B&W reactors that were similar, TMI was shut 22 down for some period of time.
'23- DR. UHRIG: What about the decommissioning costs, i 24 does that take into account the money that the utility'does-l- 25 not collect into its decommissioning fund because it didn't l i
('
\
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L:
280 1 operate the last 10 or 20 years? Because they would
[}
x) 2 normally charge those, the customers the additional money 3 collected.
4 MR. FELD: As was noted earlier, the focus in a 5 regulatory analysis is to look at the societal consequences.
6 And because we are looking at societal consequences, we are 7 . not all'that interested in who is actually bearing the cost, 8 .whether it is coming from the utility or from its 9 ratepayers. The reason there is a differential is because, 10 based on present worth considerations, and perhaps based on 11 the expectation of whether these costs are going to increase !
12 in real terms or not, there is a differential, when you 13 calculate what the cost, the actual costs are to 14' decommission in 1999 versus in the year 2009, you find that (f 15 there is the difference in the present worth value of that 16 cost.
17 DR. UHRIG: But there is inflation in those years 18 probably,- and there may be additional regulatory ,
19 requirements in 2010 versus today. .
20 DR. KRESS: Yeah, but you can't anticipate those.
21 You just have to go with what you have today.
22 DR. UHRIG: I wouldn't bet against them.
23 DR. KRESS: I don't. You have to go with what you 24 have, what'you know today.
25 DR. UHRIG: What the existing rules are.
[/)
\s-ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l, 281 1 DR. WALLIS: There is this focus on person rem,
[ 2 but, in fact, at TMI the biggest societal cost was all the
! 3 disruption by evacuations and orders that changed, and
!- 4- people didn't-know whether they should leave or not, and 5 there was considerable societal cost associated with that, 6 without any radiation exposure at all.
7 MR '. FELD: Yes, and that would be captured under 8 an estimate of the offsite property damages, other offsite-9 damages, yes, that are non-radiological. And in response to 10 the question that was posed early about -- what about the 11 fact that other reactors might have to be shut down because 12 of the accident at a different reactor, that was also an 13- issue that was looked at. And the position that the staff 14 took based on an OGC comment was that that would be. viewed
( 15. as speculative and, therefore, we were directed not to 16 account for those possible secondary or tertiary effects.
17 MR. SIEBER: Would you tell us what you used for 18 cost of replacement power?
19 MR. FELD: Well, again, the cost of replacement 20 power can vary depending on the reactor in question and
'21 where it is located. But the staff has expended a great 22 deal of funds in developing estimates of replacement energy. ;
23 We have at Oak Ridge developed a very sophisticated economic
'24 dispatch model that looks at the production costs on a 25 system basis, where it is looking at what costs would be l
O ANN RILEY & ASSOCIATES, LTD.
'L) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
F l-282 1 with a particular reactor operational versus what those 2' costs would be without'it being operational.
And the 3- differential between those two cases is what would basically 4 be-the replacement energy cost, and it is based on the 5 actual fuel, the incremental fuel and operational costs that 6 are associated with all of the generating units in the 7 system, and it looks at the economic dispatch of those units 8 as they would occur logically based on economics.
9 MR SIEBER: So you do not consider the wholesale 10 power market, which is generally where replacement power 11 comes from?
12 MR. SELD: That would be factored. In fact, there l 13 may be certain uti?ity areas, power pools, for which the 14 L'uctation would be that they would have to make outside 3
15 purchases.to provide that energy or that power. In those 16 instances, those would be the basis for the cost estimate.
17 In other words, we are looking at what is going to provide l 18 the power in lieu of this nuclear unit if it lost, and it 19 depends on the amount of reserves available in that service 20 area. For some service areas, you may be expecting greater 21 reliance on outside purchases, unless you would expect less 22 efficient units to pick up the slack.
23 DR. KRESS: By the way, as part of the handout 24 package we received ahead of time, there is handbook on 25 making regulatory analysis. I forget the NUREG number, but L' <
ANN RILEY & ASSOCIATES, LTD.
V Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.20036
.(202) 842-0034
I 283 1 it has a lot of this in it. It is very interesting.
2 DR. BONACA: So also what is allowed to be in the 3 rate bases, because if you are not in the rate base, of 4 (
course you have a direct loss on the initial investment to 5 the capital.
6 DR. KRESS: It is NUREG/BR-0184.
7 DR. POWERS: I might just comment, backfit I
8 analysis is sufficiently an arcane subject-and comes up so 1 9 frequently in this committee that members may want to retain 10 that handbook.
11 DR. KRESS: Yes, that is why I brought it up.
12 DR. POWERS: It is very useful.
13 DR. UHRIG: What is the number again?
14 DR. KRESS: It is NUREG/BR-0184.
() 15 16 DR. POWERS: When you_get home you will find it.
MR. FELD: It is entitled, " Technical Evaluation" 17 -
" Technology Evaluation Handbook."
18 DR. KRESS: It is " Regulatory Analysis, Technical
-19 Evaluation Handbook."
20 DR. BONACA: The recovery from rate base, however, 21 there is plant-specific and depends on -- so you are j 22 including those, but you do not, you can't use a normal 23 computer program to figure this out?
i 24 MR. FELD: I am not quite clear on -- if by 25 looking at the effects on the rate base of the replacement ANN RILEY & ASSOCIATES, LTD.
\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
v; 284 11 power, if that is the question, I again would argue that i
\%) f~'i '2 that is not the controlling consideration in calculating
'3 this cost differential, because that, again, is focusing ou 4 who is going to bear the cost, which is not the fundamental 5 . issue from a societal perspective.
6 DR. BONACA: Okay. Thank you. I understand.
7' DR. APOSTOLAKIS: So is this a document that the 8 members' carry with them?
9 DR. SEALE: Some of them, whenever they are in a 10 bad --
11 DR. APOSTOLAKIS: Everybody seems to have a copy.
12 DR. KRESS': You got one as part of your review 13 package for this.
14 DR. APOSTOLAKIS: So we spent half an hour on this
- 15. viewgraph.
16 MR. FELD: All right. Just to finish off on this, 17 on the averted onsite costs, recognizing that it can vary 18 substantially, I think it is fair to say that in general we 19 are talking about averted onsite cost being on the order of 20 several billions of dollars.
21 With respect to the current policy, the current 22 policy concerning the treatment of averted onsite costs 23 appears in the NUREG/BR-0058, which is the NRC's -- the 24 Regulatory Analysis Guidelines of the U.S. Nuclear 25 Regulatory Commission. These guidelines were revised and L1
/~N ANN RILEY & ASSOCIATES, LTD.
T ,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
,, Washington, D.C. 20036 (202) 842-0034
285 1 updated in 1995 and in that analysis, in that document,
}
-2 basically, the position that is taken is that one should 3 include averted onsite costs in the cost-benefit 4 calculation. However, it goes on to say that the 5 inclusion of averted on-site costs were to result in a 6 significantly different overall cost benefit result than the 7 analyst is obligated to also display the cost benefit 8 results without averted on-site costs included. In this 9 way, the decision maker is made aware of the sensitivity of 10 these results to this particular attribute.
11 And, the decision maker always has the option to 12 attach whatever weight it deems appropriate to this 13 particular consequence.
14 DR. SEALE: I don't want to interrupt your train
() 15 of thought right now, but as you go along and if you even l 16 think about it, I would be interested in knowing of some
- 17 specific cases where successful - that term begs definition 18 - but successful cost benefit analyses were conducted, and 19- .also a case where, when you conducted that analysis, there 20 wasn't a significant change in the answer if you didn't i 21 include averted off-site costs. Just think about it, and I 22 maybe at the end you could, all right l 23 MR. FELD
- Okay. A fundamental question then is, 24 given this policy, what is the rationale or the basis for
- 25 the NRC having-adopted this position. I think there are r
l
/~ ANN RILEY & ASSOCIATES, LTD.
(_,N
/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 l
u
n i
286 1 .several.important considerations.
() 2 The first, and what I believe to be the most 3 im.portant, goes to the'very essence of what a cost benefit 4 analysis is supposed to be. And I feel that by excluding a 5 particular attribute, one is in direct conflict with the 6 ultimate objective of a cost benefit analysis. Cost benefit 7 analysis is designed, by its nature, to require, to bring 8 together all of the consequences of an action, regardless of 9- how disparate those consequences might be.
10 _Every effort should be made to identify all of the l
11 consequences, to' express them in commensurate units, so the J 12 decision maker can actually compare and understand what the
.13 differences are between these attributes, and to allow the ?
14 decision maker to make a decision based on cotaplete -
() 15 knowledge.
16 The thought that we would ostensibly, arbitrarily, 17 selectively exclude a specific direct consequence of an l 18 action, just, in my mind, is totally inconsistent with the l
19 essence of what a cost benefit analysis should be.
20 DR. APOSTOLAKIS: But then I don't understand what I 21 " speculative" means. I mean, the Office of General Counsel L 22 says these costs are " speculative". We are dealing with 23 " speculative" of course, here, I mean in the sense that I 24 there is uncertainty, right?
25 MR. FELD: That's-correct.
1 l
N ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 f
i
287 e 1 DR. APOSTOLAKIS: So it seems that those' societal 2' effects should be included, except those that are declared
-3 by the lawyers as not appropriate.
4 DR.. POWERS: -Well I think - I mean, I'm not 5 absolutely positive about this, but I think there's an 6 accounting rule that specifically addresses this. l 7 Collateral legal implications are not allowed in making 8 economic analyses, usually. That is, third parties affected 9 by'your decision, through no fault of your own, control of 10 your own - you just don't put them in to the accounting 11 equations.
12 DR. APOSTOLAKIS: This may apply when you are 13 responsible for what happens. But.here, we're talking about 14 societal. costs. So there's a difference. 1
.t A) 15 The NRC claims that all these costs are borne by 16 society, that it's irrelevant whether Commonwealth Edison 17 pays or the City of Chicago. So to me, shutting down a 18 hundred nuclear plants is a major societal cost.
19 DR. POWERS: But that would be a decision that the 20 local society made, not - since you have no control over 21 whether they make a rational decision or not, you can't l l
22 factor on a rational basis.
23 DR. APOSTOLAKIS: Well, I don't understand the 24 local society. I thought the NRC would be able to shut down l
25 - at least until the Agency. finds out what happened. Right?
~t
( ANN RILEY & ASSOCIATES, LTD.
Court Reporters .
1025 Connecticut Avenue, NW, Suite 1014. i Washington, D.C. 20036 (202) 842-0034
288 1 DR. POWERS: Well, I don't think that you can
[~D 2 argue that the NRC shut down all the hundred nuclear plants N) 3 in response to the TMI-incident, or the Brown's Ferry 4 incident.
5 DR. APOSTOLAKIS: But this time there will.
6 DR. POWERS: You think so?
7 DR. APOSTOLAKIS: Yeah, I think that is a good --
8 DR.. POWERS: Well you have a confidence --
9 DR. APOSTOLAKIS: -- at least for a few days.
10 DR. KRESS: So can you put a probability on it?
11 DR. POWERS: Yeah, we have to put a probability on 12 that?
13 DR. KRESS: Because that - you have to include the 14 probability.
() 15' DR. APOSTOLAKIS: So there's some sort of decision 16 somewhere that we can put probabilities on certain things 17 and not on others.
18 DR. KRESS: If you can establish the probability 19 of that, well maybe it's worthwhile.
20 DR. POWERS: We could.
21 DR. BONACA: I think it's pretty high.
22 DR. APOSTOLAKIS: If it's possible to shut down.
23 I mean, TMI cost many, many millions of dollars to the whole l 24 industry, in part in necessary backfits, but also in 25 reaction to the event.
ANN RILEY & ASSOCIATES, LTD.
(")s
(,, Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 l
Washington, D.C. 20036 l (202) 842-0034 1
L l
289 l' DR. BONACA: Sure. Exactly.
2 DR. APOSTOLAKIS:
( So there was a huge --
3 DR. BONACA: It's not just a shutdown, yeah..
4 DR. APOSTOLAKIS: Oh yeah.
5 DR. BONACA: Yeah.
6 DR. SHACK: That probability's very different from 7 the probability that an accident will occur, that comes out 8 of the PRA.
9 DR. KRESS: Yes. It's a different --
10 DR. SHACK: You know, it's a different quality of 11 a probability.
12 DR. APOSTOLAKIS: Okay, let's take what Mario just 13 said then. I think you can put some probability on NRC 14' actions and generic requirements after the accident.
() 15 16 DR. KRESS: But see, you can put a degree of belief probability.
17 DR. APOSTOLAKIS: Well, it's always a degree of 18 belief for me, so I have no problem with that.
19 DR. KRESS: Some of them aren't.
20 DR. POWERS: You Bayesians. I swear.
21 DR. APOSTOLAKIS: I just mentioned a shutdown as
- 22 an example, but I think Mario's example is very appropriate.
23 DR. KRESS: George, there is one practical
, 24 implication of what you're saying. If you did do that, the 25 backfit room-might as well not be there, because every room
/' ANN RILEY & ASSOCIATES, LTD.
I Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L ..
U 290 i
1 you ever want to pass or-every. requirement is going to pass pg O 2- it.
3 DR. APOSTOLAKIS: That would depend on --
4 DR. KRESS: Pass that part, pass the cost benefit 5 part.
l 6 DR. APOSTOLAKIS: It depends on the severity and 7 the impact.on core damage frequency, of the proposed 8 measure. See, that's what keeps it rational: the.
9 -probability that you will do, you prevent something is very 10 low. But if you start putting billions of dollars, yeah, 11 DR. KRESS: Well, you will have to put some l 12 probabilities on those, that's for sure. I don't know how 13 you put those on there.
14 DR. WALLIS: I think I'd like to get at a much 15 more basic thing. There are two players here - there's the 16 utility and society. When the society is put at risk by l 17 having a nuclear reactor, there are costs that are borne by 18 that society because the reactor is there. And the benefit 19 apparently accrues to the utilities.
20 There-are other situations where the cost are 21 borne by the utility and the benefit accrues to society. I 22 don't know how you make this balance, but when there are two l 23 players there and each side really needs to make an 24 independent cost benefit analysis -
25 DR. BONACA: But isn't it true that the genetic
- O
'( j ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 j (202) 842-0034 i L
i l 291 1 implication of an issue will also have some relevance? What
()
t 2 I mean is that TMI brought up a number of genetic issues '
3 that caused, then,- the necessary response to be so expensive '
i 4 to the whole industry. Okay? If the issue was so specific I 5 to the plant, then you would tend to think that you would 6 only look at the on-site, the regular costs.
7 But the if the issue was so clearly broadly 8 generic, broadly generic, then wouldn't you look at, you 9 know, the implication of the impact? That would make a 10 difference, it seems to me. What I mean is, again, TMI l 11 identified genetic issues and the result of the response was i
12 huge and impacted the whole industry.
13 DR. KRESS: I think his contention is right. You i 14 really want to look at all societal costs. And those are 7-s (j 15 societal costs, whether they're internalized. The tradition 16 has been, you do consider private and internalized costs. I ,
i 17 mean, it's, we've - that's been decided over and over and 18 over again, I think, by different agencies.
l 19 MR. FELD: I guess my response to that comment p 20 would be that I take exception that there are two bodies in 21 this - that there's a utility and that there's society.
22 There's really only one; it's society. And utility is a 23 component or an element of that society. When we capture 24 the societal consequences, we are accounting for 25 consequences to all parties in society: the rate payers,
- ANN RILEY & ASSOCIATES, LTD.
s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
n 292 1 the public, the utility.
n DR. WALLIS:
[G 2 1
So you're lumping it all together, 3 but someone in the utility trying to make a decision has to 4 make a cost benefit analysis from their point of view.
5- MR. FELD: That's exactly - exactly. And that, I 6 think, is really the basic, fundamental conflict between the 7 utility's position and the NRC's position.
8 The utility is right. If they say "from out 9 perspective, that's not a cost or that's not a benefit,"
10 well that's true. But the NRC is not responsible for 11 developing a decision framework that's going to decide 12 whether it makes sense for a utility to do something or not.
13 We're concerned with whether it makes sense for 14 society to do something or not. Our perspective is
/ \
i ) 15 different. And the fact that'it may not be a cost to the 16 utility is not really that relevant. The question is, is it 17 a cost to some component of society?
18 DR. WALLIS: Yeah, but the way to do that, it 19 seems to me, always, it ought to be reflected in the costs 20 to the utility. If the utility having a plant there is 12 1 imposing a risk cost on society outside, then t'.at should be 22 , charged to the utility. The way it's done now, it's not.
23 It's done through some regulatory lumping of all the costs j 24 and benefits.
25 DR. SEALE: Well, it's also rather difficult to l
[~'h ANN RILEY & ASSOCIATES, LTD,
(/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 '
l Washington, D.C. 20036 l (202) 842-0034 i
L 2
F . -- ,-
293 1 calculate the benefit,-when.you consider that the real
) '2 benefit _ occurred before, and whether or not the accident 3' ever happened.
4 DR. WALLIS: The benefit is simply the provision
-5 of power which is brought by the people.
t 6 DR. SEALE: Made the power available, that's 7 'right.
8 DR. WALLIS: That's a commercial thing; it has 9 nothing to do with risk.
10 DR. SEALE: But that's the benefit as far as 11 society is concerned. It had the power.
- 12 DR. BONACA: Well, when you do backfits on cars, 13 where you now install safety belts on all cars, you're not l' 14 looking at the - I'm just wondering. I mean, there are some
!( ) 15 parallels there. You're not looking at the implications of 16' the averted costs on a particular accident in a car; you're 17 looking at implications of the same issue in all of the 18 cars.
- 19. DR. APOSTOLAKIS: It's a generic thing.
- 20 DR. SHACK
- But this is generic, too. I mean, 21 when they look at a regulation, they're looking at the costs 22 on the whole industry. You know, if it's a BWR, you i 23 consider all BWRs, so it is generic in that sense. You 24 know, your particular case is a little different one. You 25 know, there's this shutdown. And that would certainly seem i
[~'
\ <
ANN RILEY & ASSOCIATES, LTD.
Court Reporters I
1025 Connecticut Avenue', NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034.
t L
l 294 1 -to me to be speculative. Again, you're also constrained by )
() 2 whatever the lawyers tell you you can do, 3 MR. FELD: I'd like to comment on the question of 4 ' shutdown of other reactors. You know, probably in theory, 5 one could make a case that one should look at all the 6 consequences of an action, and those consequences can be 7 direct, or they can be. indirect, secondary, tertiary 8 effects. But the complexity of the analysis really grows 9 when you start to consider all of these secondary and 10 tertiary effects.
11 And simply for the economics of doing the cost 12 benefit analysis, there has to be some cut-off. I think the 13 approach that has been taken here is to limit ourselves to 14 the direct consequences. So, for example, when I indicated
(
( 15 that I had a problem with excluding a particular consequence 16 my comment was, the difficulty of excluding a direct 17 consequence of an action is to me far more egregious than 18 ignoring tertiary or fourth effects that might occur down 19 the line.
20 DR. KRESS: You guys have to remember, all this is 21 just aimed at whether or not NRC should require a new, make 22 a new requirement. It's not like we're going to -
23 basically, that's it. And there are other things involved l
24 in that regulatory analysis. l l
25 First there has to be a substantial improvement in I i
l
~
ANN RILEY & ASSOCIATES, LTD.
k'm,N
) Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 i (202) 842-0034 l l
295
- 1. safety. It has to pass that screen. And then there's a
() 2 3
safety goal screen that it has to pass. And if - we've got this business of adequate protection goals, and if it's 4 required for adequate protection, then there's no cost i 5 benefit involved at all. They'd pass it. But if it's 6 already meeting adequate protection, you're in the range 7 where you-don't want to impose new requirements unless it's 8 cost beneficial.
9 We're in that narrow range between adequate 10 protection and safety goals and we're just making decisions 11 - this is a decision process as to whether to pass a new 12 requirement. So it's not that earth-shaking a problem as to 13 whether to include all these costs; it's now are we going to 14 have a practical system to screen out or not screen out all eN I I
). 15 these requirements. That's basically all it is. i 16 DR. WALLIS: I think it's really fundamental. If 17 you looked at the cost benefit analysis for those sounders 18 for AP-600, where it's claimed that the cost to society of 19 an AP-600 reactor is $7 a year, something is obviously 20 wacky. You know, if cost benefit analysis where, on the one 1 21 side, there are millions at stake, and the other side 22 there's a benefit of $7 to society, obviously something is 23 wrong. So something is wrong with the calculation of the l 24 ' cost,-based solely on person rem.
25 MR. FELD: Shall I continue?
l l
(
'(
ANN RILEY & ASSOCIATES, LTD.
Court Reporters i
l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l l
(202) 842-0034 l
l.
F 296 l 1 DR. KRESS: Yes.
- 2 MR. FELD
- So in spite of the fact that I feel l
i 3 it's totally inconsistent with the cost benefit analysis, we 4 do recognize that this still remains a controversial issue.
l 5 As a result of that, as a part of this exercise, this latest 6 review, the Staff contacted the Office of Management and
! 7 Budget to ask its views on this issue.
8 Basically, the OMB is the Federal agency that is, 9 has direct responsibility for developing regulatory analysis 10 guidance, and has oversight and review responsibilities with 11 respect to the development of analyses by other agencies.
12 And we basically put the question directly to:
13 what do you feel regarding averted on-site costs? Their 14 reaction basically is that, what you're really talking about
()
/
15 here are internalized or private benefits. By that, they l 16 meant that these are benefits that are accruing to the same 17 party that is effectively incurring the costs of that action 18 or that regulation.
19 In their view, there's nothing controversial about 20 including these benefits. In their view, it's standard
! 21 practice on the part of cost benefit practitioners to l 22 include them. And to be perfectly honest, I think they were 23 somewhat surprised that this was an issue that was of 24 concern to the NRC. I think the language they used was, 25 this is something that goes without saying.
/)
%,/
5 7J04 RILEY & ASSOCIATES, LTD, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
L
297 1 DR. WALLIS: So if you had perfect containment and
()
I 2 there's never any emission of radioactivity whatsoever --
l 3 DR. KRESS: It's all on-site.
I l 4 DR. WALLIS: It's all averted on-site costs, the 5 NRC would be still regulating, or to try to save the utility 6 from the disaster of on-site costs.
7 MR. FELD: Well, again, I think as the point was 8 made earlier, this agency can only impose an incremental
.9 burden, a new requirement on the licensee if it's not 10 involving adequate protection, if we can demonstrate that 11 there's a substantial improvement in public health and 12 safety.
13 That test has to be made before we can even 14 consider costs and benefit. If it does not contribute to a
() 11 5 substantial improvement in health and safety, then we say 16 the consideration of that action-ceases. We don't get into 17 costs and benefits. We look at that very early on in the 18 regulatory analysis, i
19 DR. KRESS: In this case, it would never pass that L 20 screens 21 MR. FELD: Right.
22 DR. WALLIS: But if the containment is very good 23 and the cost to society of an accident is very small - which !
! 24 it's claimed to be for AB-600 - then it seems to me that all l 25 the costs are on-site costs. I you why you bother to )
l l
I
(("'j) ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 i
I i l
298 1 regulate at that point, at all. It's all up to the
! s
!\-)\ 2 utilities.
3 MR. FELD: Well, I think I'm saying that, you 4- know, we would find that that would be a regulation that !
5 this agency could impose because it doesn't pass the l
6 substantial test.
j 7 DR. KRESS: You wouldn't regulate that.
8 MR. FELD: Right.
9 DR. KRESS: Wouldn't. Can't. The backfit -
10 regulatory analysis wouldn't let you regulate it.
11 DR. SEALE: My definition of perfect nuclear l 12 industry is one that doesn't require an NRC.
13 DR. WALLIS: Well - one which has claimed to have 14 a cost of $7 a year of risk, that's as imperfect as you can t's k,)
s 15 get.
16 DR. APOSTOLAKIS: You have FAA there. What do 17 they do if there is a generic problem somewhere? Don't they 18 order all the planes of the same vintage shut down and 19 grounded?
20 DR. KRESS: Yeah.
21 DR. APOSTOLAKIS: Is that similar to our shutting 22 down reactors?
23 DR. KRESS: Well, not exactly.
24 DR. APOSTOLAKIS: Not exactly.
25 MR. FELD: I guess the case can be made that our
) ANN RILEY & ASSOCIATES, LTD.
-' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
299 1 reactors are not --
() 2 DR, KRESS: It's more like a compliance issue.
3 MR. FELD: Each reactor is a unique entity. They 4 have been designed differently, so maybe the case can be 5 made that where airplanes are identical; that's not the case j i
6 with a power reactor.
7 But basically, we then followed up our discussions 8 with other agencies by contacting the Federal Aviation 9 Administration, because of our feeling that they were 10 dealing with a situation that was highly analogous to ours.
11 The NRC is responsible for primarily protecting 12 public health and safety; the Federal Aviation 13 Administration is essentially responsible for protecting 14 passenger-safety. And just as NRC's regulations can result
() 15 in a reduction in the damage or loss of property to the 16 licensees - in this case, a power reactor - an FAA 17 regulation can also result in a reduction of loss of damage 18 to its licensees' property - in that case, the airplanes 19 themselves.
20 So we asked the FAA, what is their position 21 regarding the loss of airplanes in their calculations of 22 costs and benefits. 'And once again, they made the case that 23- this is something that is clearly considered in their 24- regulatory analyses. It's not controversial. It's standard 25 practice.
i
N ANN RILEY & ASSOCIATES, LTD.
Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 i' Washington, D.C. 20036 (202) 842-0034
300 1 In fact, in their regulatory analysis guidance, O 2 they indicate that there are basically three principal V !
3 safety benefits that they must address in their analyses:
4' (1) death; (2)-injuries; and (3) property damage. So, it's 5 an integral part of their analysis, as well. 1 6 Lastly, we felt that one of the reasons why we ;
7 would argue for averted on-site costs is we feel that its 8 exclusion. produces what we would view as inconsistent or 9 illogical results. That can best be seen through an )
10 illustrative example.
11 Consider for the moment that the NRC is 12 considering two different regulatory fixes. One is a !
13- mitigated fix, which essentially is focusing on improving 14 the containment or emergency planning. The other is a 15 preventive fix that is focusing on reducing the probability 16 of an. accident. j 1
17 Well, the mitigated fix, by its very nature, is 18 only capable of reducing the person rem exposure or the 19 off-site property damage. It cannot effect the on-site 20 costs because it doesn't effect the probability of that 21 accident occurring. l 22 The preventive fix, on the other hand, can effect 23 the person rem exposure, the off-site property damage, and 24 .the on-site property damage. ,
25 So, if we said that the Agency were now, had a O ANN RILEY & ASSOCIATES, LTD.
'd - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 301 1 policy where it was not giving any consideration to averted 2 on-site costs, and it just happened that the costs of these
( }.
3 two fixes were identical, and the person rem saved and the 4 off-site property damaged saved were identical, then the 5 conclusion that one must draw from this comparison is that 6- this Agency.should be indifferent between these two 7 alternatives.
8 In my mind, that's clearly an illogical 9 conclusion, recognizing the fact that by adopting the 10 preventive fix, society also stands to avert billions of 11 dollars in property _ damage losses. This is also our basis 12 or rationale for our maintaining the position we have.
13 DR. WALLIS: Earlier you said that these averted 14 on-site costs were the dominant costs, so this would mean J 15 that reducing CDF is far more important on a cost benefit 16 basis than improving a containment, in the argument you just 17 gave. They have the same effect on public safety, but they 18 have an enormous effect on averted on-site costs. Reducing 19 CDF reduces averted on-site costs, where the most cost is.
20 Therefore, that's what we should do.
21 MR. FELD: Except not - it's not always the case 22 that these averted on-site costs are going to be dominant.
23 I think there is, you know --
24' DR. WALLIS: They seem to be at the moment.
25 MR. FELD: Well, again it depends on the severity
/") ANN RILEY & ASSOCIATES, LTD.
\ssl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
302 1 of the accident; it would depend on when that accident
]}- 2 3
actually occurred over the life of that reactor, as to how important those consequences would be, in fact.
4' MR. ROSENTHAL: Now let me just interject for a 5 moment please. My name is Jack Rosenthal, and I'm the 6 Branch Chief for Regulatory Effectiveness Analysis and Fact 7 Branch.
8 Sid Feld is an economist on the NRC staff, and a 9 member of that branch, and has long been involved in 10 developing regulatory guidance. When Sid and I first 11 discussed responding to the paper, we said, you know, there 12 was this danger that, that it would be a question of Sid's 13 contention versus any NEI's contention. And most of those 14 ideas are in fact Sid's.
1
) 15 The-point was - and I heard somebody use the word 16 " contention" earlier. The first point is that it's standard j 17 economic practice to consider all the costs and all the 18 benefits. And then cost benefit starts out with the 19 President's Council of Economic Advisors, which is that 20 regulation should be net beneficial. It doesn't give you 21 very much more, but stems from that.
22 So we went to OMB, we'went to FAA, and we tried to 23 develop a model. So what we're trying to convey is~that I 24 believe that we're providing standard government methodology
- 25. of how we think the analysis should be done, you know,
/N- ANN RILEY & ASSOCIATES, LTD.
(m-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
303 1 consistent with Council of Economic Advisors, OMB, etc., and
/ 2 V) not simply a question of one person's views versus 3 another's. So this slide becomes very important to me.
4 Okay, while I have interrupted, and it's the 5 -ACRS's choice - we're somewhat more than halfway done 6 time-wise and about a third of the way through the 7 presentation. The second issue is in fact, I think, more 8- contentious than the first --
9 DR. KRESS: I'm glad you mentioned that because I 10 think my preference would be to skip straight to the 11 voluntary initiative part at this point, and cover it first, 12 and maybe return to this if we have time. I think there's 13 broader implications of voluntary actions 14 MR. ROSENTHAL: Perhaps we could - Sid, did you
() 15 have just some summary statement that you wanted to make? I 19 mean, I think if they understand on Slide 3, clearly, that 17 NEI cc:me in with a different view. But do you have some 18 summary statement that you want to make on AOC and then move 19 on?
20 MR. FELD: Well, I think that in summary what I 21 would say is that the industry has consistently maintained 22- that this is not an appropriate policy. And I think that
-23 they provided two essential arguments.
24 One is that it's allowing the Agency to impose 25 regulations that do not contribute to the_public health and ANN RILEY & ASSOCIATES, LTD.
O- Court Re,. rters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
1
304 1 ' safety, but it's involving the NRC in issues that are 2 internal and concern their own personal investment and i.
s 3 operational-decisions, and it's clearly beyond the NRC's 4 purview.
5 I think, reading the paper and perhaps even this 6 slide would suggest that the Staff has problems with both of 7 those arguments for a number of reasons that I have tried to 8 identify. So in balance, we don't find any compelling 9 reason to change our policy in response to the industry's 10 concerns. That would be my conclusion, I guess,.
11 At this point, I'll turn to the discussion of 12 voluntary initiatives. Here, too, the NRC has been asked to 13 prepare a Commission paper in response to a Commission SRM, 14 which essentially directed the Staff to reconsider its (A) 15 position with respect to the treatment of voluntary 16 initiatives in regulatory analyses, and to identify options 17 or alternative policies for the Commission's consideration.
18 A couple of weeks ago, we provided the Committee 19 with a draft of this Commission paper and I just want to 20 indicate to you that that paper has undergone a number of 21 revisions. There may be some inconsistencies between what 22 that paper says and what this discussion may contain, so I 23 just want to alert you to that.
24 Once again, it's appropriate to start with a 25 definition. Basically, voluntary initiatives --
.['T ANN RILEY & ASSOCIATES, LTD.
Asl. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i i
l 305 I 1 DR..KRESS: Excuse me.
fN 2 MR. FELD: Sure.
d-3 DR. KRESS: If you hit on one of those 4 inconsistencies, you might want to flag it for us to be sure i
5 we recognize it.
6 MR. FELD: One of those inconsistencies relates to l- 7~ the.- well, first of all, we've --
i 8 DR. KRESS: You can wait until you get to it if 1
l 9 it's in your slides.
10 MR. FELD: All right. Definitionally, I think 11 basically, voluntary initiatives are actions that are l
l 12 performed by licensees that, although not required by NRC 13 regulation, clearly complement the NRC's regulatory 14 responsibility.
() 15 16 The current policy on voluntary initiatives also appears in the regulatory analysis guidelines in Revision 2.
l 17 Essentially, what it states is that for base case j -18 calculations, no credit should be given for voluntary 19 -initiatives. However, for sensitivity analysis purposes, l :20 full credit should be provided for voluntary initiatives.
i
! 21 That way, the decision maker, again, is afforded the full l
~22. sensitivity of these cost benefit results with respect to 23 this particular attribute.
24 DR. WALLIS: So credit is in the cost benefit 25 sense.
O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 m
306 1 MR.'FELD: Credit is in a cost benefit sense and jN 2 in the calculahion of risk.
3' DR. KRESS: The implications of sensitivity 4 analysis in these is that the decision maker can use that as input and make judgments as to whether or not, or now much
~
5 6 credit to give.
7 MR. FELD: The decision maker essentially is being 8 told-that as a result of our assumption regarding the future 9 role of voluntary initiatives, here's what the cost benefit 10 results can be,.what the range of results can be. And the li decision maker can --
12 DR. KRESS: Does he have --
13 MR. FELD: -- decide, you know, how much weight he 14 thinks it's appropriate to give to those, in effect.
() 15 DR. KRESS: Does he have any guidance on --
16 MR. FELD: Currently, he does not.
17 DR. KRESS: When we talk about the decision-maker 18 --
19 MR. FELD: I think we're talking here about the 20 Commission.
21 DR. KRESS: The Commission itself?
l 22 DR. POWERS: Well, I mean, there are different 23 kinds of decisions, some of which can be made by NRR. I l 24 mean, they have to acknowledge that other people can make i
25 decisions here i
O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW,' Suite 1014 I
i Washington, D.C. 20036 (202) 842-0034
r i
307 1 DR. KRESS: They would be either the EDO or the I
(')
(m) 2 . Commission. '
3 DR. POWERS: Well, actually the director of NRR 4 has certain decision-making capacity.
5 MR. FELD: In this description of our policy, I've j
6 included - although this does not-appear in our current l 7 policy -'I've included the words "to the extent ,
8 practicable." And this is a change that we made in the paper j 1
9 itself.
10 There was concern expressed that although we say i
11 that we should not give credit to voluntary initiatives in )
12 our base case calculations, we recognize that in certain 13 instances, it may not be practical to actually not give 14 credit. And those instances would be, for example, where
() 15 the risk calculations and cost and benefit calculations are 16 based on PRA results.
i 17 The PRA, which is looking at the as-is state, 18 effectively includes voluntary initiatives when it 19 calculates the risk. Therefore, in many instances it may l
20 not be possible to modify those PRA results; in fact, it may 21 be very hard or impossible. And as a result, we may be !
1 22 unable to show what the risks would be without those 23' voluntary actions.
24 So.although we're saying we're providing the '
25 results with no credit, in certain instances we may not be l
(~N ANN RILEY & ASSOCIATES, LTD.
(s-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ,
Washington,.D.C. 20036 (202) 842-0034
308 1 able to actually do so, and one should be aware of that.
2 DR. WALLIS: I don't understand this voluntary 3 bit. If there's a limit that you're not allowed to go above 4 here, if the licensee deliberately maintains a margin by 5 staying here, that's voluntary.
6 MR. FELD: Maybe it would be helpful to try and 7 explain how voluntary initiatives are important'in bur 8 calculation of risk in cost and benefits. When we calculate 9 the costs and benefits of a regulatory action, what we're 10 really looking at is the differential in costs and benefits 11 between two cases.
12 The first case is, what are the costs and benefits 13 to the utility? What are the costs and benefits if the 14 regulatory action is adopted? What are the costs and
() 15 16 benefits in the future going to be? All right?
The second state we'd look at is, what would the 17 cost and benefits be in the future if the regulatory action
-l 18 were not' adopted? And it's the differential between those 19 two states that is the incremental, or delta, cost and 20 benefit that we're trying to capture in our in our 21 regulatory analysis. Therefore, what we characterize as 22 that baseline state, what the cost and benefits would be 23 without that action, becomes critical in our determination 24 of what the risks are, what risk benefits are in adopting 25 this action, and what the cost and benefits are of adopting ll ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
v 309 1 that action.
2 So, for example, if we say we're not going to give b(~~T 3 any credit to the voluntary initiative, what that 4 effectively means is that in the base case, in the baseline,-
5 the risks are greater and the risks of adopting the 6 requirement would be greater and the benefits would be 7 greater, because the baseline has been reduced. We're 8 saying, we're not assuming they're going to have those --
9 DR. WALLIS: You're saying - I mean, suppose that 10 all the licensees have adopted some initiative, which then 11 becomes required by a regulation. According to you, the 12 regulation benefit is zero because it's already been 13 adopted. Is that right? Or it is huge - you give great 14 credit for a regulation which has absolutely no effect
(~m i
) 15 whatsoever?
16 MR. FELD: Is we're saying we're not going to give 17 credit to the voluntary initiative, then the benefit of 18 adopting the regulation is large.
19 DR. WALLIS: Although it has no effect whatsoever?
20 MR. FELD: Well, we're saying it does have an 21 effect because we don't have an assurance that that 22 voluntary initiative will be in place in the future.
23 DR. WALLIS: Ah hah.
24 MR. FELD: It may be in place right now, but what 25 we're looking at is the cost and benefits in the future.
i l
! :(~'i ANN RILEY & ASSOCIATES, LTD.
(_,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
l l 310 1 DR. WALLIS: Okay.
t 2 MR. FELD:
i ()\
i '\.
And if we don't have an assurance that i l 3 those actions are going to be available in the future, we're ;
4 saying we shouldn't give credit to them.
! 5 DR. KRESS: And there may be some inconsistencies l
6 in how it's, a voluntary action is - the scope and 1 l 7 effectiveness across the --
8 MR. FELD: Right, and there are a number of 9 problems that we've identified with voluntary initiatives 10 that we feel make it compelling to not give credit to them. 1 11 DR. POWERS: Do you explicitly or implicitly give 12 a value to the ability to enforce?
13 MR. FELD: Enforcement is clearly a consideration 14 in our determination that voluntary initiatives may not be
/^T i j 15 of equal weight to regulatory action. And if we can't 16 enforce them, we would argue that that suggests that maybe 17 it's not appropriate to assume that those programs will be i
18 available in the future.
19 DR. POWERS: So it's really an on and off 20 situation.
21 MR. FELD: Right.
22 DR. POWERS: There's --
23 DR. KRESS: Normally, what you're looking at is -
24 pardon me.
25 MR. FELD: Sure.
l l
/~N ANN RILEY & ASSOCIATES, LTD.
(s,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
L
n 311 1 DR. KRESS: You're making a difference. You're
)
2 calculating. benefits'and costs and you're subtracting one j 3 from the other to see if you get a net benefit.
4 MR. FELD: Right.
3 DR. KRESS: Do you do an uncertainty analysis on 6 each of.these, or sensitivity at least?
- 7. MR. FELD: Yes. As in the case of averted on-site 8 costs, and as in the case.of;our treatment of voluntary 9 initiatives, when we an assumption that we feel that there's 10 a great deal of uncertainty to --
11 DR. KRESS: You do limit the uncertainties 12 depending on questionable parts of it.
13 MR. FELD: Right.
14 DR. KRESS: Is there a danger of subtracting (G) 15 too-big numbers to get a small one here, getting that net?
16 The benefits are big; the costs are-big; the difference is ;
i 17 maybe small?
18 'DR. POWERS: It's not that they're big; it's that !
19 they're big and uncertain.
20 DR. KRESS: Yeah, big and uncertain is my point.
21 MR. ROSENTHAL: We are recommending a change, j 22 somewhat of a change in current policy, which I think you'll i 23 find more satisfying. So if you could get to that, I think 24 you'll be pleased.
25 MR. FELD: I'll cover this one very quickly.
.- ANN RILEY & ASSOCIATES, LTD.
s_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014.
Washington, D.C. 20036 (202) 842-0034
1 312 l' When we adop4ed the policy we acknowledged that it '
(
2 was. controversial. We went to the ACRS. We went to the 3 CRGR~.
We discussed it with the Commission. And these 4 discussions took place in 1992 to 1995 timeframe, when we 5 were developing draft guidelines and a final guidelines.
6 Imd we found that in each case, we found that the 7 Committees and the Commission supported the position that we 8 were taking with respect to voluntary initiatives.
9 DR. KRESS: I recognize those words,_the first 10 quote.
11 DR. APOSTOLAKIS: And there is a comma that's l 12 missing there.
13 DR. KRESS: The word on the first bullet obviously 14 were poor.
15 DR. WALLIS: That's such a strange word to me. IT
[N,)\-- !
16 seems to me if the risk to society of CDF is so much that a 17 utility can voluntarily reduce that CDF by a factor of 10, 18 then there ought to be a way of getting credit for that.
19- Something has happened which has reduced the risk to 20 society.
21 DR. KRESS: Wait for his bottom line.
22 DR. WALLIS: There ought to be a charge for a CDF, 23 which he can avert by doing better.
24 [ Laughter.)
25 MR. SIEBER: The utility could make it a part of ANN RILEY & ASSOCIATES, LTD.
O, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 )
313-
- l the design basis of the plant, and under those circumstances
()
2 I think credit would be appropriate.
3 MR. FELD: Clearly, I think there are different 4 degrees of voluntary. initiatives -- different.
5- characteristics and traite to these voluntary initiativec 6- .that could influence our decision as to whether or not to
~
/ 7 give credit or not.
8 MR. SIEBER: Right.
9 MR. FELD: And that, in fact, is the thrust of the 10 new position, or policy that were recommending to the 11 Commission at this-point in time.
12 This slide indicates that we made this decision to 13 give greater weight to this scenario where we weren't going 14 to give credit to the voluntary initiatives. We did so I I 15' because we recognize that there were a number of issues'or V
'16 problems. associated with a large number of voluntary 17 ~ initiatives.
18 Basically, they all came down to the fact that we 19 didn't feel that we could have confidence or a great q
.20 : assurance that these voluntary programs would necessarily be i 21 available in the future. We felt that we needed assurance j 22 regarding the scope, the duration, the level of ethic, that i 23 these voluntary programs.were. going.to have in the future, i 24 before.we could really assume that'they were of equal 25 . . . footing to regulation itself. ;
I 1
"SJ ANN RILEY & ASSOCIATES, LTD. l 1 (q,,I' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 L
314 1 This basically identifies a number of those 2 concerns with voluntary initiatives.
(~')
V They're highly 3 discretionary. The natu're of the program can be very vague.
4 There's clearly non-uniformity across licensees.
5 Some can be very aggressive in a voluntary program; others 6 can be very lax. Some licensees miglit not even be a party 7 to a voluntary initiatives. They lack enforcement, which 8 was an issue that was an issue that was identified by one of 9 the Committee members just a moment ago. The fact that they 10 could be dissipated by the licensee, even without the NRC's 11 knowledge, was of concern to many.
12 And then there's the issue of backsliding, which I 13 believe in the environment of deregulation that's coming 14 upon the electric utilities, a concern which should be of
[J N
) 15 16 increasing importance. As cost competition becomes a more critical consideration, licensees may give much greater 17 consideration to reducing their commitments to voluntary I 18 actions in order to save money.
19 Well, then what are the concerns that we have with 1
20 the current policy? The first concern is that it appears to l 21 run counter to our direction-setting issue, DSI-13, which !
22 the Commission has basically adopted a policy to promote and 23 encourage the use of voluntary initiatives in lieu of 24 regulation.
25 And there's also a concern that it doesn't provide ANN RILEY & ASSOCIATES, LTD.
(~})
(, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 315 1 sufficient incentive to the licensees to adopt voluntary 2 initiatives. If we're not going to give any credit for them
[
3 in the regulatory analysis, why should a licensee even
~
4 ' bother to propose or utilize a voluntary program?
5 A second concern that exists is with respect to 6 the risk calculation itself. The NRC calculates risks in a 7 wide number of venues. It calculates risks in PRAs. When 8 it looks at GSIs and USIs. When it prioritizes generic 9 issues. In all of these venues, we are effectively giving 10 credit to voluntary initiatives. These programs are 11 basically looking at the risks in an.as-is state.
12 In a regulatory analysis, we're arguing that we 13 don't want -- for base-case calculations, we're not going to 14 give credit to these issues. And therefore, there's an
() 15 inconsistency in how we're calculating risk. For some, this 16 is a concern.
)
17 The third concern, which I think is a change in '
18 the paper-from what you saw, is a recognition that - just i
19 recently, in fact on May 27 - the Commission issued a new 1 20 SRM to.the Staff concerning the use by industry of voluntary 21 initiatives in the regulatory process.
~22 This SRM is basically a direction to the Staff to 23 begin to implement and put in place the objectives of 24 .DSI-13. It calls upon the Staff to develop processes and 25 guidelines to enable.the Staff, the NRC to have greater "T ANN RILEY & ASSOCIATES, LTD.
(Q Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.'20036
-(202) 842-0034
t:
316 1 assurance in relying on voluntary initiatives as a
/' \ 2 substitute'for regulations.
Ns!
3 Clearly, to the extent that these guidelines are 4 -implemented and'put in place in the future, the position 5 that we currently have where we're not giving credit to 6 voluntary initiatives becomes a much more untenable policy. j 7 If, in fact, we have guidelines that are going to give the 8 assurance that these programs are going to be available in 9 the future, and we can have that greater assurance, then it 10 doesn't make sense that on the other hand we're not going to 11 give credit for these programs.
12 As a result of this review, the Staff has 13 identified three operations, three alternative policies to 14 the current policy.
() 15 DR. KRESS: Of papers --
16 MR. FELD: Yes, and this is a change.
l l
17 DR. KRESS: You've subsumed two of them into B?
18 MR. FELD: Actually, the first option that was 19 identified before has been dropped completely !
20 DR. KRESS: The A option before has been dropped. I 21 MR. FELD: Dropped. And B, C, and D of before, 22 have been moved up to A, B, and C.
23 DR. KRESS: I see.
- 24. MR. FELD: The first option basically says that !
l 25 we're going to continue to calculate the costs and benefits ANN RILEY & ASSOCIATES, LTD.
Os m, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
317 1 based on a no-credit and full-credit scenario. And 2 effectively then, we're going to try to capture the full b(\
3 level of uncertainty associated with our assumption 4 regarding the future role of voluntary initiatives.
5 But in addition to that, we're going to attempt to 6 develop a best-estimate scenario. We're going to look at 7 the voluntary initiatives in question, we're going to look 8 at the specific voluntary initiatives, and based on their 9- characteristics and traits, we're going to make a reasoned 10 judgment as to how much weight we should give to those 11 programs being available in.the future.
12 DR. KRESS: Will there be guidance?
l 13 MR. FELD: There will be guidance available.
14 We've identified, for example, in the paper a number of
() 15 features that we think are relevant in this decision. For 16 example, if the cost of that voluntary initiative are 17 primarily up-front costs that have already been incurred, 18 and the operating or to-go. costs are very small, it stands 19- to reason that there's a greater likelihood that those )
20 voluntary-programs will continue.
21 If the voluntary program is relatively 22 non-controversial and is standard pr.sctice on the part of j 23 industry - and by that, we mean thr.t it's been in place for 24 a very long period of time and it's fully supported by all 25- of the licensees - again, we think there's a greater
(~'t ANN RILEY & ASSOCIATES, LTD.
(m,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
318 1 likelihood-of that program continuing in the future.
2 If there are written commitments attached to the 3 voluntary program, we feel that we may have some leverage to 4' provide enforcement control over that voluntary initiative.
5 Again, we might give greater credit to it being available in 6 the future.
7 Finally, we believe that in the future when the 8 Agency has developed these guidelines that the Commission 9 has asked for, to'give it the assurance that these programs 10 will be effective and available, to the extent that the 11 voluntary initiative in question has guidelines that are 12 applicable to it, again we feel that that would provide the 13 assurance for us to give the consideration to it being 14 available in the future.
() 15 DR. KRESS: Do you see this' guidance having a 16 quantitative nature in the sense you want to give anywhere i 17 from zero to one credit, and you have a matrix or a decision 18 chart that has these attributes in it? j 19 MR. FELD: I'm not sure how quantitative we can i 20- be, but I think the intent clearly is that based on the 21 characteristics of that voluntary initiative, based on l 22 guidelines-that may be developed in the future, our feeling l
23 is that this best estimate will either be very close to the 24 zero credit scenario, or very close to the, you know, the 25 100%' credit scenario, or be somewhere exactly in the middle.
i O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
[ -1 DR. KRESS: It's more like a none-or-all.
t .
! [~N 2 MR. FELD: Right.
l 3 MR. ROSENTHAL: I'm sorry - again, this is very L
4 important, at least in my mind. That is, you're not just 5 simply providing three numbers, you know, the two bounds and I
6 the best estimate, but that the words that will go with that 7 to the decision maker will likely be more important than the 8 numbers. That's the attributes that Sid was just talking 9 about. You know, is a capital expense? Is it ASME, is it 10 an NEI commitment? Etc., and that in fact, at least in my 11 mind, it's the text that will carry the day for the decision 12 maker in terms of how much credit to give.
l 13 DR. POWERS: Option B is a-little more than what I 14 it says there is.
l
() 15 16 As a decision maker, I would have in front of me a no-credit case, a full-credit case, and a best-estivaate case 17 with a text on where this best estimate came from.
l 18 MR. FELD: Right.
19 MR. ROSENTHAL: Right.
20 DR. POWERS: So option B a little richer than it 1
21 says on there.
l 22 MR. ROSENTHAL: Right. j 23 MR. FELD: And that the zero- and full-credit I 24 cases are not really options that the Staff is proposing as 25 likely. I think it's just a way of bracketing or enveloping
s . ANN RILEY & ASSOCIATES, LTD.
-Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 c_
320 )
I 1 the full range of uncertainty that's reflective of this 2 consideration.
3 DR. WALLIS: This credit's a one-shot thing. I 4 mean, you make a decision and give credit, and then if they 5_ take the voluntary initiative away, you don't have any way 6 of taking the credit away with it.
7 MR. ROSENTHAL: Actually I do, and that is for 8 example,Lif there's a generic issue on air-operated valves, j
9 and we.come to some decision, and sometime later there is '
10 operational experience to change our view. We could reopen 11 that generic issue, go back through the loop of saying, is 12 'there a substantial improvement in safety? Is it an 13 adequate safety issue or a safety enhancement?
14 Go right back through the loop, re-do the cost h 15
[O benefit analysis, and then re-emerge out. That would be 16 driven by operating experience.
17 DR. WALLIS- w ell, the credit could be' condition i
18 on the voluntary initiative maintained.
l 19 MR. ROSENTHAL: Yes. i 20
- DR. WALLIS: So you do have some leverage to see l 21 is'not just put in,-in order to get some credit and then 22 removed afterward.
23 MR. ROSENTHAL: Uh huh.
24 DR. SHACK: But he still has to go through a full 25 regulatory process.
(]; ANN RILEY & ASSOCIATES, LTD.
(_) Court Reporters 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)~842-0034
321 1 DR. KRESS: That's right.
2 DR. SHACK: If you haven't passed a new rule and 3 you decide you need a new rule, you still have to go through 4 everything you need to do to get the rule._ I mean, it's not 5 as though the credit goes away pops into place.
- 6 DR. KRESS': That's right. You either have a rule 7 or you don't.
8 'DR._ SHACK: Right.
9 DR, WALLIS: But these are bureaucratic details 10' which are tiresome if all you're looking at is the overall 11 effect. If there's a voluntary initiative which is good, 12 then; you know, it should happen.
13 DR. KRESS: I need to look at it. If you're.a 14 regulatory agency, you really want to be sure that
() 15 16 everything is in place and controllable.
DR. SHACK: I mean, the good thing is that many of 17 these voluntary initiatives.are clearly in everybody's best 18 interests.
H19 - DR. KRESS: Yeah, it seems to be.
l 20 DR. SHACK: I mean, the NRC has almost given up i 21 regulating water: chemistry because the industry standards ;
22_ are so stringent because it's obviously in their best 23 interests. l l
24 DR. KRESS: Yeah, that's the nice thing about j l
25 that. It's in.everybody's interest. They've got the right
)
i l
/~ ANN RILEY & ASSOCIATES, LTD. l
(,,T) Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
l
322 1 idea - if they can assure themselves that it's always
!2' consistent --
3 DR. SHACK: I mean, that's a case where clearly 4' the full credit is --
5 DR. KRESS: Yeah, is probably what you would give 6- a full credit for the assessment.
7 DR. APOSTOLAKIS: I'm still not clear what 8 " selectively" means. What - between A and B. Selectively l
l 9 including scenario.
10 MR. FELD: Option B, then, is basically, for all 11 practical purposes, very similar to Option A. But it states 12 that, effectively, if we find that by doing the zero-percent l
13 and hundred-percent scenarios that the bottom-line cost 14 . benefit conclusion is not changed between that wide range of
() 15 uncertainty, then there's no need to do the best-estimate 16 case because it's obviously not going to effect the 17 bottom-line conclusion.
.18 DR. APOSTOLAKIS: It's not cost-beneficial.to do 19 it.
20 MR. FELD: So what we're saying is, basically, 21 Option B appears to be a more efficient way of using NRC's 22_ resources in doing these regulatory analyses.
23 DR. APOSTOLAKIS: And what is measured credit?
24 MR. FELD: I think what I mean by measured credit 25' isLthat we're looking at the specific voluntary actions that ANN RILEY & ASSOCIATES, LTD.
Os Court Reporters 1025. Connecticut Avenue,ENW, Suite 1014 2 84 - b34 1
i 323 1 are in question here, and we're trying to decide how much
[)
v 2 credit to give to them. And it's a measured credit. It's 3 based on our understanding of the characteristics and traits 4 of those specific voluntary actions that are under 5 consideration. So it's a measured credit; some conscious 6 thought has been given to how much credit to give to it.
7 MR. ROSENTHAL: Yeah, apparently at one time 8 people didn't want to do this because it gives a lot of 9 judgment to the analyst in terms of how much credit or not 10 to give, although intellectually the best estimate just 11 seems the best way to go. And that's why I got back to the 12 question of, what would the text be that accompanied the 13 numbers.
14 And it's not just a question of the upper and (m.) 15 lower bound, and if the cost benefit changes, then you do a ;
16 best estimate. But you need all this text about, is an ASME 17 standard? Is it a capital expenditure? Etc., to remove the 18 subjectivity from the analyst and give the decision maker, 19 then, some hard facts to drive the decision.
20 DR. APOSTOLAKIS: So the decision maker is, as you 21 said, the commission most of the time?
22 MR. ROSENTHAL: Uh hmm.
23 MR. FELD: I'm thinking in terms of rule making 24 and so forth, yes.
25 DR. APOSTOLAKIS: So they will have, then, to (3 ANN RILEY & ASSOCIATES, LTD.
( ,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p i-324
.1~ weigh the three different calculations as to what extent 2- they should - decision making.
3 MR. FELD: Although the Staff's recommendation 4
would be'that'which'is' consistent with the best estimate. I 5 mean,~the best estimate means to the Staff that it's the 6 .most'likely result-.
7 MR. ROSENTHAL: Just to be perfectly clear, I mean 8 we.think it's the Staff's obligation to make a 9 recommendation to~the Commission. We just wouldn't' simply
~ 10 pass the numbers out.
11 DR. APOSTOLAKIS: Right. Now, what you said 12- though, Jack, regarding the voluntary measures, does it come 13' from a commitment to a society code - isn't that part of the 14 measured credit? Or the words were simply elaborated on?
() 15 'It would give credit to a. commitment that comes from the 16 cytomechanical engineers, then-say something that the 17 utility's'doing to encourage, you know,.to improve the
- 18. morality ploys, which may disappear tomorrow.
- 19. By the way, speaking of that, Southern 20' California's use of the risk monitor has improved the safety 21- culture of the plant. Is that something that you can 22 include somewhere here?
23 .MR. ROSENTHAL: No.
24 DR. APOSTOLAKIS: I don't think so, and yet that 25 mayLhave more significant impact --
i
()
N ,/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 325 1 DR. POWERS: Understand that this is --
'~) 2 DR. KRESS: -- evaluate safety culture.
'us/
3 DR. POWERS: Understand that these things - as I I I
4 understand it - are very much for generic issues. So '
5 specific plant capabilities are not --
6 DR. APOSTOLAKIS: So, if the whole industry 7 installed these monitors, that probably would --
I 8 DR. POWERS: Then you might want to start thinking 9 about it.
10 DR. APOSTOLAKIS: It sounds good to me.
11 DR. WALLIS: In a way it's experimental. Try 12 something and see if it works out. And then you can be less 13 or more selective, depending on your experience. That seems 14 a reasonable step to take. If it doesn't work out, you can
() 15 16 always go back to the old policy.
DR. POWERS: Are you ready to move on?
17 DR. KRESS: I think we have expired our time. So, 18 you know, I thank the speaker - you could tell, we're very 19 interested in this subject and it was a very good 20 presentation. We appreciate that.
21 With that, I think I'll turn it back to you, Mr.
I 22- Chairman. !
23 DR ., POWERS: I think you have something from NEI?
24 DR. KRESS: Oh, I'm sorry. Did you wish to -- !
25 DR. SEALE: Marion.
O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 o
~
l 326 1 DR. KRESS: Marion. Thanks for pointing that out 2 to me.
3 MR. MARION: Good morning. My name is Alex 4 Marion. I'm the director of programs department. I
- 5. appreciate the opportunity to chat with you briefly about 6 the industry's concerns with this longstanding, 1
7 controversial issue.
8 The industry and the NRC has been interacting on ;
9 this for about the last fifteen, sixteen years. Someone 10 -made the comment earlier about the controversy involved in 11 this and NEI's position and Sid Feld's position. I never 12 met Sid until today; he seems to be a very nice, decent man.
13 [ Laughter.)
14 MR. MARION: He is an economist; I am engineer.
() 15 16 So there ere obviously going to be some things that we disagree on. But anyway, be.that as it may, I'd like to l 17 make just a couple points on both topics. !
18 In terms of regulatory decision making that's 19 called for by the backfitting rule, 10 C.F.R. 50.109, the 20 costs, the evaluation of the costs, should focus on the 21 implementation of that regulatory requirement. And the 22 costs are the direct and indirect costs associated with 23 licensees implementing the regulatory requirement.
24 The reason that the NRC has gotten into the more 25 comprehensive cost benefit analysis, stems from an executive
(g ANN RILEY & ASSOCIATES, LTD.
(,,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
327 1 order that was issued in 1993 calling for all regulatory 2 agencies to do a more comprehensive economic analysis of 3 their regulations.
4 NRC'as an independent Federal agency was excluded 5 from that Executive Order. However, there was some 6- communication later on from the Office of Management and 7 Budget that recommended Federal agencies - I'm sorry, 8 independent Federal agencies to - I'm thinking of complying, 9 because I represent a regulated industry --
10 DR. SEALE: Comply is all right.
11 MR. MARION: -- to meet the intent, or something.
12 DR. POWERS: That's an NRC policy that --
13 MR. MARION: Do something consistent with the 14 direction provided in the executive order. 1
'15 DR. POWERS: The Commission has always had a 16 policy that says that, unless there's a compelling reason 17 not to comply with these administrative' directives, that 18 they will do so. I mean, they do pretty routinely..
19 MR. MARION: Yes, I know they do. I just wanted 20 to give you that background.
21 I mentioned that it's been a long-standing 22 controversy. We fundamentally believe that the NRC 23 regulatory decision making associated with rulemaking or '
24 other_ regulatory actions should be primarily based on public 25 health and safety considerations, not financial investments i i
ANN RILEY &. ASSOCIATES, LTD.
V('"3 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
328 1 of utilities or its investors, or the associated economic
() 2 risks for operating and maintaining a nuclear power plant.
3 DR. POWERS: Now, since the first test that they 4 use on any backfit that they propose is a substantial 5 improvement of safety, it would seem that they do exactly 6 what you ask for.
7 MR. MARION: Then why are we even bothering to 8 talk about a comprehensive cost benefit analysis?
9 DR. POWERS: Because they have a second test.
10 MR. MARION: Well, I was interested during Mr.
11 Feld's to find out if he would identify any specific 12 examples that have been done recently where the cost benefit 13 analysis has been conducted to support a regulatory action 14 by the NRC. I'd like to post that question, if I can.
() 15 MR. FELD: We've gone back and looked at the 16 effectiveness of rules.
17 One that I was involved with most recently 18 concerned the station blackout rule. One of the 19 commissioners asked us to go back and see what the licensees 20 had done, what the actual. costs were, how they compared to 21 what we had estimated, and to try and look at what the 22 benefits of that action were.
23 The Commission in that instance was very helpful, 24 in that they identified what they felt was the change in 25 risk associated with station blackout. Utilizing our.$2,000 ANN RILEY & ASSOCIATES, LTD.
Court' Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036.
(202) 842-0034
329 1 person rem value, when we went back and looked at the cost
( }' 2 and benefits that were actually, what we expected to be 3 resulting from that rule we found that, in effect, it was
.4 cost effective. It did pass that cost benefit test in most i 5 instances.
6 MR. MARION: What would have happened if it didn't 7 make'the test?
8 MR. FELD: What?
9 MR. MARION: I'm just posing a rhetorical 10 question.
11 Okay, fundamentally, regulatory decision making 12 should not consider economic risk factors associated with 13 the postulated transient at a plant, or an accident at a 14 . plant. That's fundamentally our bottom line, and I guess we
() 15 will continue to disagree.
16 We feel that the Commission should reconsider
. 17 their policy on this, and we've glad to hear, very pleased 18 to hear that there's a Staff paper before the Commission on j 19 this. And we're hoping that the Commission continues to 20 . focus on the first criteria, or the first threshold, which 21 is adequate protection of public health and safety.
22 One other aspect of this.that I kind of feel
)
23_ compelled to identify is, in light of the utility licensee's 24 use of'probabilistic safety assessment, it seems to me that 25 there's going to.be greater concentration on that first I
/')
(m-ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p 330 1 ' threshold of quantifying the impact of a regulatory action,
( ) 2 whether it be through rulemaking or the imposition of some 3 regulatory requirement and a generic communication.
4 -But there is a methodology for quantifying the 5 impact in terms of core damage frequency. If you make that 15 test, then I.would say, why are we continuing to argue and 7 create all this hate and discontent about comprehensive cost 8 benefit. analysis.
9 Now I would like to move on briefly to the other
- 10. topic of voluntary initiatives credited or not credited --
11 DR. WALLIS: Well, now wait a minute - this 12 probabilistic safety analysis. My claim all along is that 13 everything is cost benefit, and if you do a public PRA, get 14 a CDF, really there should be some cost associated with
( '15 that. I mean, there should be some benefit with changing 16 CDF. There obviously is a benefit to sum up, and that 17 should sum into the cost benefit. Everything --
18 'MR. MARION: Right.
19 DR. WALLIS: Safety is not an independent thing.
20 Safety is really is cost benefit and really should be 21 interpreted in that way, somehow. That's my personal view.
22 MR. MARION: I'm not disagreeing with what you're 23 saying. I'm just suggesting that there's a better tool
~
l 24 available to everybody to really quantify the relationship 2 5.. of actions to core damage frequency. And the issue of what i
'I ANN RILEY & ASSOCIATES, LTD. i O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l'
Washington, D.C. 20036 (202) 842-0034 Ir
~
c-331 1 cost you put on that is a separate question.
, 2' DR. WALLIS: The reason sometimes the cost benefit 3 comparisons look silly is because one hasn't properly 4 evaluated the costs.
5 MR. MARION: Right, and, you know, our basic point 6 is that it's not the NRC's statutory responsibility to look 7 at economic risk factors.
8 DR. POWERS: I continue to disagree on that. If I 9 understand your words, you're saying, you'want to use PRA 10 and decide whether something needs to be done or not. And 11 if it does, we'll do so regardless of cost. Is that what 12 you're saying?
13 MR. MARION: If it reduces core damage frequency 14 and advances public health and safety.
( ). 15 DR. POWERS: So you, so you would have absolutely 16 no difficulty at all with the NRC coming in and saying, ;
17 we're going to regulate shutdown activities that we have not 18 regulated in the past because we know that by doing so and 19 ensuring that safety systems are available, we're going to 20 reduce the core damage frequency by a bunch?
21 MR. MARION: I'm not familiar with what action the
'22 NRC is proposing in that particular area so I hesitate to l
23 give you a yes or no answer, 24 DR. POWERS: Oh, the:' wrote a shutdown rule - they 25 wrote a proposed shutdown rule a couple years ago that was
('S ANN RILEY & ASSOCIATES, LTD.
(m.) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
332 1 pretty extensive.
2 DR. SEALE: At-random was pretty good too.
3 DR. POWERS: I think you mean, regret a position 4 that's just use the PRA.
ti MR. MARION: No , I'm just saying there's a tool 6 that helps the NRC make a regulatory decision on that first 7 threshold of demonstrating adequate protection of public 8 health and safety. We didn't have that tool ten, fifteen 9 years ago in wide use, as we have it today.
10 Voluntary industry initiatives. We think NRC 11 should encourage licensee actions that enhance safety.
12 Again, we maintain our firm belief that NRC's primary 13 responsibility's ensuring adequate protection.
14 Safety enhancements, just as a term, essentially 15 go beyond the level of protection provided by the current 16 body of regulations. You need to maintain that distinction.
17 Utility licensees need the flexibility to make a 18 determination of where they're going to apply their 19 resources to improve plant operations, etc. When they do 20 so, and the NRC decides that they want to pursue a 21 regulatory action that-achieves the same objective that's 22 already been accomplished by the utility licensee, 23 fundamentally we think credit should be given for that.
24~ Fundamentally, if it's already in - if a program, 25 if you will,.is already in place and the results of that ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
c.. .
333 1 program is being-successfully implemented to the point that j } 2' the objectives are the same, then why do you have to 3 regulate to it?
4 What we heard during the discussion is, the answer 5 to'the "why" deals with control, deals with enforcement, 6 deals with backsliding - I was surprised cherrypicking 7 didn't come up today because that always occurs when we talk 8 about voluntary industry. initiatives, whether NRC takes 9 credit or whether the' industry wants to implement it.
10 But fundamentally, it's kind of troubling that 11 we're looking at these decision making processing and trying 12 -to come up with some kind of calculus that captures every
- 13. element of that decision making so that everybody knows what 14 everyone is doing and why everyone is doing it. As I'm sure
( f 15 all of you can recognize, there is no such calculus that 16 would help in dealing with some of the decisions that i
17 licensees have to come to grips with in operating nuclear 18 power plants safely. And there is no calculus that's going 19 to capture decision making of NRC to support their role of 20 regulating, inspecting, and enforcing.
21 But one thing that does help bring the two
-22 together is communication to develop a common understanding !
l H23 uof what people are doing,.why they're doing it, and 24 fundamentally what the benefit, what the objective, what the 25 result is from that action that's being pursued, either by i
ANN RILEY & ASSOCIATES, LTD.
Os Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)- 842-0034 l
l
I i 334
'l the utility or by the NRC. And we need to talk about these es
/
2 more and more.
3- I was kind of surprised to hear that there's an 4 SRM from the Commission on the DSI-13 SECY paper. We were 5' asked by the Staff to review that SECY and meet with the 6 NRC. 'And that had not occurred.
7 I'm really troubled about that, especially since 8 NEI is,.I think, the organization in the industry that deals
, 9 with voluntary initiatives more so than anyone else, any 10 other entity that I'm aware of. That's a topic that we're 11 going to have to discuss with the Staff in further detail, 12 and probably have some discussions with the Commission. I 13 don't know.
14 It's troubling that we keep finding this cookbook
() 15 process, this effort to continually find a calculus, a 16 methodology that captures the complexity of decision making.
17 And I submit, you'll never get there.
I 18 Anyway, that completes my comments. Does anyone 19 have any questions about the two topics I discussed? Okay. j 20 Thank you.
21 DR. KRESS: Thank you.
22 DR. POWERS: We have covered this topic?
23 DR. KRESS: I think we've completed it.
24 DR. POWERS: I thank all the speakers. And I will 25 recess until 20 after the hour.
l ANN RILEY & ASSOCIATES, LTD.
C>\) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i
(202) 842-0034
- I
335
-1 [ Recess.]
() 2 DR. POWERS: Let's come back into session.
3 The particular topic we're looking at now is one 4 near and dear to the hearts of the Committee, that is, the 5 assessment of risk associated with low-power and shutdown 6 programs. The Committee has written to the Commission a
.7 couple of times on this subject.
8 Dr. Kress, you are our cognizant Member in this 9 particular area?
10 DR. KRESS: Yes.
11 DR. POWERS: And so I'll turn the meeting to you.
12 DR. KRESS: Okay. Thank you.
13 Well, it turns out that -- I don't know if we had 14' anything to do with it or not, but they are undertaking a
() 15 program to look at the low-power and shutdown risk, and I 16 think what we're going to hear today is merely a status 17 report on the plans for that program and what they've done l 18 so far in the way of a workshop and getting together some 19 information.
20 Is that right, Mark?
21 MR. CUNNINGHAM: That's correct.
22 DR. KRESS: Okay. I'll turn it over to you, Mark.
23 MR. CUNNINGHAM: Okay.
24 Good morning. I'm Mark Cunningham from the Office i 25 of Research at NRC. As Dr. Kress indicated, I'm going to )
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 e
r 336 1 make a presentation, kind of a status report on the program i i (s) 2 that we're working into now on low-power and shutdown 3 research. I should note that I've got some help from people 4 over here to the left of me: Tom King, the director of our 5 division; Gareth Parry from NRR; and Erasmia Lois from the 6 Research staff, who ard more familiar with some of the 7 details of some of the -- in particular the workshop that l
8 went on.
9 Two of the other key players in this are Mary 10 Drouin and Nathan Siu. Mary is on vacation this week, and l 11 Nathan is on travel, so unfortunately they couldn't be here 12 to help me out for the tough questions.
13 DR. POWERS: Now Mary is off in the South of 14 France; Nathan drew a shorter straw.
O) s 15 MR. CUNNINGHAM: Yes. Well, he's in I believe 16 Diablo Canyon, so that's not necessarily --
17 DR. POWERS: A very much shorter straw.
18 MR. CUNNINGHAM: Talking about fire standards, 19 fire PRA standards.
20 DR. SEALE: Gee, I wonder why.
21 DR. POWERS: Interesting stuff.
22 MR. CUNNINGHAM: Anyway, the presentation we've 23 got today has some background historical information, and 24 then try to give you an idea of what's in the staff shutdown 25 program, at least in its initial stages now, summarize some
{
/ ANN RILEY & ASSOCIATES, LTD.
5- - Court Reporters l
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
i
337 i
g 1 aof our current understanding on shutdown risk, summarize the
/~'% 2 results of a workshop that we held last I guess in late
(-s/
1 3 April, a public workshop about trying to gather information )
-4 on what's going on in shutdown risk assessment, give you an i 5 idea then of what we plan to do over the next six months or 6 .so in terms of following up on that.
7 As many of you are quite aware, previous NRC l 1
8 studies, previous studies from around the world have 9 indicated that under some circumstances low-power and 10 shutdown risk can be comparable to full-power risk. We had 11 sponsored some studies a number of years ago looking at 12 Surry and Grand Gulf. I think they showed these results, 13- and many of the results we've seen since that time would 14 tend to provide the same message.
() 15 DR. KRESS: If the CDF risk were 1 or 2 times 10 16- to the 4, then it's likely when you included shutdown in 17 that also it.would be 4 times 10 to the 4? l l
18 MR. CUNNINGHAM: We'll come back with some ,
4 19 examples, but that's the type of thing we're talking about; j 20 yes. It could be of the same order, so it would tend to 21 have the effect of doubling, if you will, in some cases.
22 DR. WALLIS: You meant 10 to the minus 4?
23 MR. CUNNINGHAM: Yes, I did.
24 DR. KRESS: The minus has to be there.
- 25. MR. CUNNINGHAM: Yes.
ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,'D.C. 20036 (202) 842-0034
338 1 DR. POWERS: I don't know. On some of the
( )' .2: localized things we've got numbers up to 1.
3 DR. KRESS: You know,-I've heard George
-4 Apostolakis'say there's no difference between 2 times 10 to 1
5' the minus 4 and 4 times 10 to the minus 4. Is that right, 6: George?
' '7 DR. POWERS: Well, I've certainly heard Professor 8 'Apostolakis argue that there is a certain amount of 9 uncertainty in these numbers, but I think we make an error 10: in looking at the issues of shutdown risk strictly in terms 11' of the' bottom-line number.
12' I'think that our regulatory implementation of the 13 ' risk-informed approach has up till now focused very heavily 14 on evaluating systems and their importance to risk, and I
() 15 think that you're much better off thinking in terms of how 16 does the. inclusion of quantitative assessments of risk 17 during low-power and shutdown operations affect your 18 classification of systems as either risk-significant -- high 19 risk. significance or low risk significance than simply 12 0 .asking does it double or -- where does it move you on the 21 horizontal scale on that marvelous fuzzy line to plot that
'22' appeared in 1.174. -
23 DR. APOSTOLAKIS: Have you heard Professor
-24 Apostolakis say anything you want to say, Mark?
25 MR. CUNNINGHAM: Not right now.
O* ANN RILEY & ASSOCIATES, LTD.
(_, Court Reporters
.1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
339 1 However, the Committee in general has made at
- 7s i
2 (J least one recommendation if not several to the Commission 3 that there's a substantial research program needed to have a 4 better understanding of shutdown risk. In response, we have 5 a what I would call at the moment an approved budget that's l 6 of what I call moderate size. The Commission approved that 7 as part of the FY '99, and we're now looking at the future I 8 years to have such a budget.
9
'The Commission introduced one constraint on that.
10 Back in the days of the policy issues of Reg Guide 1.174, we 11 raised the issue that there may be additional guidelines, 12 acceptance guidelines, the fuzzy lines and things, for 13 shutdown conditions. The Commission told us that that 14 should not be part of this program, but otherwise did not
() 15 particularly constrain the program. They also asked, j 16 however, for a status report on what we're doing in the 17 program. There's a paper that's going up in parallel with 18 'this meeting that provides a similar perspective in written 19 form to what we're going to talk about today. So that'll be 20 going up to the Commission here in the next few weeks.
21 So at any' rate, as Dr. Kress noted, we have a 22 beginning or are developing a low-power and shutdown i 1
23 research program. The overall objective is to develop an I J
24 understanding of shutdown risk sufficient to support the 25 risk-informed decision making that the Agency is making. I i
l l
ANN RILEY & ASSOCIATES, LTD.
- s. Court Reporters 1025 Connecticut Avenue, NW, Su$te 1014 i Washington, D.C. 20036 (202) 842-0034
340 l' Another way to put it is, if you will, is what's needed to
-s^).
V 2 make at the very least an incremental step in terms of 3 guidance and methods.that could help us take a step-forward 4 in the context of 1.174 or other contexts.
5 DR. POWERS:
When I look at an objective like 6 that,.I have mixed feelings about it, because I say on the 7 one hand if I had to do the job I love objectives like that, 8 because it looks'to me like anything I do meets the 9 objective. On the other hand, I'm a bit frustrated in that 10 it does not give me any design-to' guidance.
11 MR. CUNNINGHAM: Yes.
12 DR. POWERS: And it does not say, for instance, 13 develop an understanding of LPSD sufficient to find out 14 where you are on the horizontal axis of the marvelous
() 15_ fuzzy-lined plot in 1.174, which would be something I could 16_ design to.
17 DR. KRESS: That is the way I would interpret that 18 sentence.
19 DR. SEALE: It's easy to score, but it's hard to 20 win.
21 DR. POWERS: Well, yes, I mean, it seems to me 22 that the day before my performance review I could sit down 23 and do something and come in and say I satisfy this one.
24 DR. SEALE: Yes.
25 DR.~ POWERS: I may not have done it well, but I've
'\ ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 341 l
1 certainly met the requirements. i i
() 2 3 to?'
Why don't we have objectives that we can design l
4 DR. SEALE: Again, I think implicit in this are j 5 some of the things that you've been talking about. The 6- sufficiency issue is, as you say, it could be -- if we did 7 six months' worth of work, we could make an incremental i
8 improvement over what's in 1.174. If we did six years' i 9 worth, it would be a much larger step beyond 1.174.
10 What we're struggling with now is our 11 understanding of shutdown risk is a little out of date, the 12- staff's understanding, and we're struggling now to see what i 13 improvements have been made in the rest of the world, 14 including the U.S., to give us a better tiea of how far we f~
t 15 can reasonably go.
16 DR. POWERS: Certainly one of the ACRS' comments 17 in their letter to the Commission was to complain that the 18 scoping studies that have been done in the past were now a !
19 bit out of date.
20 MR. CUNNINGHAM: Yes.
l 21 DR. POWERS: And that the plants were doing l 22 different things. l 23 '
MR. CUNNINGHAM: Yes. And in a fair measure '
24 that's what we're trying to do now is to sort out what !
25 advances have been made elsewhere'in the time since those Oh ! ANN RILEY & ASSOCIATES, LTD.
(s f I Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014
- Washington, D.C. 20036 I
(202) 842-0034 I
I
1 342 1 studies were completed. So that's why at this point we're a
~
'little fuzzy, because we don't know how much may have been
~
2-(Q, '\ -
3 done someplace else that we can take advantage of.
4 DR. WALLIS: By understanding you mean' measures 5 and data, you don't mean a fuzzy understanding, you mean 6 actually coming up with numbers that describe this worst -- I 7 so we can see what it is and we can make comparisons with 8 other risks.
9 MR. CUNNINGHAM: Yes, that's correct.
10 DR. WALLIS: Scale and so on.
11 MR. CUNNINGHAM: That's right. I think of this 12 again in the context of 1.174, where you have a ,
l 13 horizontal-axis question.and a vertical-axis question that's 14 . fairly quantitative. As we talk about the -- when we get I) 15 into the workshop results there's people have suggested 16 there may be more qualitative ways that we can handle this, 17 but that remains to be seen --
18 DR. KRESS: An objective I think this Committee 19 might be more pleased would be one like to develop the 20 capability to routinely include low-power and shutdown in 21 the risk assessments for individual plants and the 22 uncertainty analysis, which would include calculating 23 importance factors, LERF, CDF, delta CDF, delta LERF. But, 24 you know, that would be a design-to objective.
25 MR. CUNNINGHAM: Yes. That's certainly not
/~'l- ANN RILEY & ASSOCIATES, LTD.
(m) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
343 L1 different than what we're talking about here, but it is much b)%
.2 more crisp.
3 'In order to work towards this objective, we've got 4 a number of things we have under way. One is that we're 5 trying to assess, as I said a little bit earlier, both
,6 domestic andLinternational information on what's been done 7 in low-power and shutdown risk analysis and what the 8 concerns are today. Given that, we intend to perform 9 research activities, methods development, additional
- 10 analyses, that sort of thing, to get at these concerns.
11 DR. POWERS: In what part of the NRC's activities 12 does someone come in and say now what is the technology that 13 -NRC needs to do its job the way we want it to do its job?
14 With respect'to low-power shutdown.
() 15 MR. CUNNINGHAM: I'm sorry, I missed the first of 16 what you said.
17 DR. POWERS: I mean, this program seems to be 18 saying okay, what is the current state of the art out in the 19 world, the state of understanding --
1 20 MR. CUNNINGHAM: Um-hum. '
21 DR. POWERS: And is that different than the 1 22 understanding that we have now? Better, worse, or something i
23 like that?
j 24 What I am looking for is who is it that goes out 25 .and says, now, if I want NRC to do its risk-informed !
[~~
ANN RILEY &_ ASSOCIATES, LTD. l l
Court Reporters
'1025 Connecticut Avenue, NW, Suite 1014 Washington,.D.C. 20036 (202) 842-0034
i I
344 1 regulatory job the way I would like it to do its job with
]
[1
%f 2 -respect to low power and shutdown, what is it that it needs 3 '
to do it?
4 MR. CUNNINGHAM: Okay.
5 DR. POWERS: Where is that said,,or is that the
]
6 next step that I am just'not seeing?
7 MR. CUNNINGHAM: Well, I think that is kind of 8 what would come out of the second bullet here in terms of 9 the research work. Part of what you have to do is -- well, 10 what do we have?, is one question, and then another question 11 is, what do we need?
12 DR. POWERS: Yes.
13 MR. CUNNINGHAM: Okay. And I think part of what l 14 we are intending to do here is the needs statement of what 15 is needed, and I guess, again, we would put it in the 16 context of, what do we need'to go into the next step or the 17 next update, or supplement to 1.174 and say this is how you l
,18 can better address the issues of shutdown risk.
19 DR. POWERS: Okay. So it is just coming.
20 MR. CUNNINGHAM: Yes.
21 DR. POWERS: I have just got to be patient here.
22 MR. CUNNINGHAM: Okay. One of the things we are
'23 doing as'part of our research and information gathering 24- phase of this is we have an international cooperative 25 research group called COOPRA, whatever that stands for. It O ANN RILEY & ASSOCIATES, LTD.
bl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
345 1 is intended to NRC's mechanism for cooperating throughout
,I')
G-2 the world with people doing PRA research.
3 There are four working groups to COOPRA. One of 4 them is focused on shutdown risk. We have a program that 5 Mary is chairing, an effort -- back up. Mary chairs a 6 working group. It has membership, from what count was, of 7 like.14 countries trying to look at what have each of these 8 countries done, what are their plans for using shutdown risk 9 and doing research.
10 The idea is that we can go through an identify 11 collaborative research, if you will, or -- either in the 12 sense of, you know, if country X does this piece, then we 13 will do one other piece, or more jointly funded programs or 14 that sort of thing.
() 15 But this working group had its first real meeting 16 in January and they have got another one coming up in the 17 fall. But I expect that will be a good mechanism for us to 18 have a very good understanding from the international set of 19 what is going on and what research they are performing.
20 DR. POWERS: Is the technology for PRA 21 internationalized, that is, does a Japanese PRA and a 22 Finnir.h look kind of the same?
23 MR. CUNNINGHAM: At first glance, yes. Yes.
24 Again, as we proceed with the program, our idea is that --
25 DR. APOSTOLAKIS: Mark, isn't it also true, l ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 '
i l
'346 1 though, that we tend to pay more attention to uncertainty
( 2 analysis than some of our international colleagues?
3 MR. CUNNINGHAM: We, --
4 DR. APOSTOLAKIS: In the United States.
5 MR. CUNNINGHAM: People in this room, I think yes.
6 (Laughter.]
7 DR. POWERS: Deftly said, sir.
8 DR. SEALE: Very, very perceptive.
9 MR. CUNNINGHAM: I am not sure we are consistent 10 throughout the United States.
DR. SEALE: Very perceptive.
12 MR. CUNNINGHAM: Internationally, it depends.
13 Individual countries do things very differently. Certainly, 14 you see in a number of countries more of a consideration of
( 15 the parameter uncertainty and that sort of thing without 16 pursuing very far the modeling unc~ertainty, and that sort of 17 issue.
- 18. DR. APOSTOLAKIS: Now, that is going a little 19 beyond the topic, but are they receptive to risk-informed 20 regulation? I mean how is 1.174 received by these groups?
21 MR. CUNNINGHAM: Again, it varies. You see 22 countries that are developing similar types of approaches.
1 23 I believe Canada, for example, has a similar type of process 24 underway. Others are not so interested in being 25 quantitative and very explicit about it, they are more ANN RILEY & ASSOCIATES, LTD.
[' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 4
347 1 qualitative. Some of it is driven by the internal
') 2 mechanisms of the country as of how the regulator and the
[~J L
3 licensee interact with each other. In many countries it is 4 not as formalized, if you will, as it is in the U.S. So 5 that to some degree also drives how they see these things.
6 DR. APOSTOLAKIS: Right.
7 MR. CUNNINGHAM: But, certainly, the work we have 8 been doing over the last few years on 1.174 has been a 9 subject that they have shown a great -- internationally, 10 they have shown a great deal of interest in.
i 11 At any rate, so we see it towards the end of this 12 program that one of the goals, if you will, would be to 13 develop guidance or see an update to 1.174 where we can say 14 better how we should treat shutdown, and maybe the right way
() 15 to say it is a routine type of thing, routinely you we would 16 --
you could incorporate shutdown risk by these acceptable 17 methods.
18 Also, in parallel, we are considering development 19 of a consensus standard on shutdown risk.
20 DR. SEALE: That is sort of phase B or C of the 21 present effort.
22 MR. CUNNINGHAM: Yes. Yes, that's correct.
23 DR. POWERS: How do you decide when an aspect of 24 PRA technology has reached sufficient maturity that it is 25 appropriate to ossify it by creating a standard?
[^')
w_/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
348 1 MR. CUNNINGHAM: Well, ossify is the intriguing
(')
V 2 word in there, obviously. One of the things that we --
3 DR. POWERS: It was deliberate, by the way.
4 MR. CUNNINGHAM: Yes, I am quite sure. One of the 5 concerns that we have had in development of the ASME 6 standard is that if you become very prescriptive, you do 7 just that, that you prevent or preclude -- you show -- there 8 is no incentive at that point for inrovation.
9 DR. SEALE: Discriminating against it.
10 MR. CUNNINGHAM: Yes, you almost -- you have a-11 bias against it. Certainly the people working on the ASME 12 standard were aware of that and were trying to write it not 1
13 at such a prescriptive level that it would preclude those l
14 things. You know, how you can preclude that other than
<x
( ) 15 trying to set out, if you will, functional requirements for l
16 an analysis and not be very prescriptive is perhaps a good 17 step.
18 DR. POWERS: I mean the question comes up without 19 the pejorative " ossify," because I think you did a very good 20 job and the people doing this standard on operational PRA 21 did a good job in trying to skirt that ossification, while 22 at the same time setting down what are minimum standards.
23 One of the dangers, it seems to me, in cooperative 24 groups a la your COOPRA, is that groups like that are 25 usually more effective at writing standards than they are at CN ANN RILEY & ASSOCIATES, LTD.
(_s) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 m
r 349 1 doing research itself. Research is best done in individual l
)
2 institutions where people work on things. And so there is a I 3
drive to write a standard in an area where I think there is 4 a limited amount of experience and insight, at least in 5 looking at the literature in this field. So things haven't 6 -- the pot hasn't been stirred and inspected to the extent 1
7 that maybe merits even that limited kind of standard writing 8 that you have done to date at this point, I think.
9 MR. CUNNINGHAM: Yes. Yes.
10 DR. POWERS: But I don't know what point. It does 11 get to the point that you say, okay, we are really confident 12 that these few things you absolutely have to do and we will 13 set those. I don't know when you can say that.
14 MR. CUNNINGHAM: You know, we will come back to a
() 15 little bit in terms of the discussion from the workshop, l
16 because that was a topic of the workshop, of the need for a j 17 standard. So it might be a better place to talk about this. 1 1
18 But just to be clear, by the way, COOPRA is a 19 research organization, an organization of researchers, so it ,
20 is not writing standards at this point. It is more looking 21 at trying to develop collaborative, international l
22 collaborative research efforts. l 23 DR. APOSTOLAKIS: It is way of exchanging 24 information.
25 MR. CUNNINGHAM: That's correct, yes. And that is
(~ ANN RILEY & ASSOCIATES, LTD.
(_}-- Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034
350 1 being worked, and one of the goals of the COOPRA effort is
/"'\ 2 to get the people talking who were the researchers, as b 3 opposed to the managers and other things. You get it down 4 to the technical level to get. people to communicate at that 5 level and plan at that level.
6 The next few slides talk about our understanding 7 based on.the Grand Gulf and Surry PRAs a few years ago, and 8 our initial literature search on shutdown risk to see where 9 we think things are today. And again a fair amount of the 10 information we've'got here is from our COOPRA partners.
11 Basically you see a pattern that's emerged time 12 and time again that core damage frequency is comparable to 13 full-power operation for some operating states and shutdown
-14 conditions.
() 15 DR. APOSTOLAKIS: Mark, do you have a mechanism 16 through which you can get the LPSD PRAs that the industry 17 has done in this country? This international group doesn't 18 help you with that.
15 MR. CUNNINGHAM: It doesn't help. That's correct, 20 it doesn't. Yes, we have mechanisms. Again, I come back to 21 that a little bit later. We have some plans over the next 22 few months to sit down with utilities who have done PRAs, 23 shutdown PRAs, and sit down and understand what they've 24 done, that sort of thing. That's --
25 DR. APOSTOLAKIS: Okay.
ANN RILEY & ASSOCIATES, LTD.
O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
g 351 1 :MR. CUNNINGHAM: A future activity as opposed to a l
l [~}
%J 2 past, if you will.
3 DR. UHRIG: What do you mean by operating states?
4 The containment is open versus closed?
i i
5 MR. CUNNINGHAM: Operating state in this context j i
6 can be low-power conditions --
7 DR. UHRIG: Mode 5, Mode 6, Mode 4?
8 MR. CUNNINGHAM: Yes, that's right, except in PRAs ]
l 9 what we've found to do is a Mode 5 designation isn't ]
10 necessarily precise enough because things change even within l 11 Mode 5, so instead of, you know, Modes 1 through 6, you l 12 might have low power and shutdown ten or 15 operating 13 states. You know, it varies going down in power, coming up 14 in power, cold shutdown. Mid-loop operation would be an
() 15 operating state, that sort of thing.
16 DR. UHRIG: Containment open. ;
i 17 MR. CUNNINGHAM: Yes. Well, in each of those you '
18 have -- I think the operating states are more defined, at 19 least.in our PRAs in the past by system configurations on 20 core cooling and inventory control. Then with each of those 21_ you have the question of well, what's the status of the 22 containment given that, in that mode,-and what you see, and 23 I'm. going to talk about some of the results, is the ones 24 that tend to be the most important operating states from our 25 studies have been ones where the containment has been open f
/)
(_/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p 352 1 during those modes. I'll come back to that in a minute.
() 2 3
So at any rate, we have seen that the, if you lwill, the annual average core damage frequency is comparable 4 for some parts of shutdown conditions, as with full power.
5 However,-the core damage frequency varies considerably 6 across operating states, so that mid-loop operation'in PWRs 7 tends to be a fairly high CDF state. Refueling operations 8 tend to be a very much lower -- have a very much lower CDF 9 estimate.
10 And then the contributors, what's causing the core 11 damage event, the initiators and that sort of thing, can be 12 quite different, You see different types of human 13 performance at shutdown, because there's far fewer 14 procedures, if you will. The redundancy at full power is r\
(j 15 lost in many cases in a number of situations in other 16 operating states, so single failures can be much more 17 important in shutdown condition than in power operations.
18 The next two slides show some of the results, just 19 to elaborate on this point a little bit, from our Grand Gulf 20 and Surry studies. I'm going to focus on a few of the 21 points in this basically.
22 What I show here are core damage frequency results 23 and risk results for early fatality risk and latent cancer 24 fatality risk. This one is Grand Gulf, and the next one 25 will be Surry. The values in here are from internal events ANN RILEY & ASSOCIATES, LTD.
O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
353 1 that are shown on the slide. I want to focus more on the l 2 mean values, which'is over'here, and make again a couple of 3 points.
4 Just focusing on those things for the moment,
{
5 basically.you see in this case the core damage frequency, 6 the mean core damage frequency from Grand Gulf for POS 5, o 7 which is cold shutdown, is similar to the core damage 8 frequency estimated in 1150 for full-power operations. It's 9 .a fairly small number for a lot of reasons at Grand Gulf, 10 but again they're similar numbers. The early fatality and 11' latent fatality risks actually -- they're all small numbers 12 at Grand Gulf again for a variety of reasons that are kind 13 of unique to Grand Gulf, but the POS 5 risk can be somewhat 14 ' higher than the full-power risk.
15 Basically this deals with the issues that we were 16 just talking about on containment status. As POS 5 was 17 analyzed in the Grand Gulf study a few years ago, when they 18 were'in this mode, the suppression pool was drained and the 19 containment was open. So at least two of the barriers that I 20 you would normally expect at least in full-power operation 21 to be there to mitigate releases are not there. So you 22 could have greater consequences, if you will, from.a core 23 damage accident.
24 I'll skip over now to Surry, a similar plot.
25 Again this is for internal events. I should note that --
jQ sj
- ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ,
(202) 842-0034 l
r - ,
354 1 let me do this again. )
(~')
V 2 The core damage frequency that I've circled up 3 here, in this case it shows that for the internal events the I 4 core damage frequency is a good bit lower. I I should note 5 that for fire, though, these numbers don't show fire. The 6 core damage frequency for mid-loop from fire was about 2 7 times 10 to the minus 5. So that brings it up to be --
8 again it would be comparable, if you will, to full-power 9 operations. Again, you also tend to see in some cases the 10 somewhat higher risks from mid-loop operations.
11 Again in this case Surry was analyzed four or five 12 years ago. The containment in mid-loop operations was not 13 necessarily buttoned up. So you didn't necessarily have the 14 -- I believe it was the equipment hatch was the issue. It (d \
15 wasn't i cessarily in place during mid-loop operation. So 16 you had a potential there for having a bypass, if you will, 17 of the containment.
18 Again, based on what we've seen from international i
19 studies and other reviews, you see a similar type of pattern '
20 for shutdown risk studies.
21 To turn now to the public workshop that we held to 22 basically gather information to help us understand where l 23 people were in terms of assessing shutdown risk, what tools i
24 they have, what results they have. So we had three points l i
25 that we wanted to cover in that workshop that we held -- it i
/~ ANN RILEY & ASSOCIATES, LTD. !
k_N) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
355 1 was a public workshop held on April 27.
2 One is share results on what's been going on in 3 terms of risk analyses, what information and methods. What 4
information and methods do we need in order to be able to 5 use this in decisian making? And again, what's an 6 acceptable approach or structure for a standard in shutdown 7 risk?
8 DR. KRESS: What's a reasonable estimate for 9 fraction of a year that you're in shutdown?
10 MR. CUNNINGHAM: I'm sorry, what's a --
11 DR. KRESS: A reasonable estimate of the time, 12 fraction of a year, that you're in shutdown mode.
13 MR. CUNNINGHAM: It varies a good bit, I think, 14 especially going to shorter outages and. things, you people
() 15 16 strive for 30-day outages and things like that.
don't --
So I 17 DR. KRESS: Ceuld be on the order of one-tenth?
18 MR. CUNNINGHAM: My first answer would probably be 19 like 10 percent or something like that, and that's planned 20 outages. You also have unplanned outages and that sort of 21 thing.
22 DR. KRESS: Do you reduce the CDF full power by 23 one-tenth when you add in the --
24 MR. CUNNINGHAM: We should. I don't think we ever 25 do.
I ANN RILEY & ASSOCIATES, LTD.
Os Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 i
F 356 1 DR. KRESS: It's not. worth it. It's not that 2 significant.
(~')g 3- MR. CUNNINGHAM: Professor Apostolakis has noted-4 that 2 and 4 times 10 to the minus 6 are the same number, so j 5 we'll - in that same vein --
6~ DR. BONACA: Just one point. I mean, typically 7 the highest risk is in mid-loop operations, so you are 8 looking for refueling-outages -- I 9 MR. CUNNINGHAM: Yes.
10 DR. BONACA: As the one of concern.
11 MR. CUNNINGHAM: That's correct. l 12 DR. BONACA: And second, typically you don't 13 refuel every year, you refuel every --
14 MR. CUNNINGHAM: Yes.
() 15 16 DR. BONACA: Eighteen months or even 24 months, MR. CUNNINGHAM: Yes.
17 DR. BONACA: So I would say it might be 5, 6 18 percent at the most.
19 MR. CUNNINGHAM: Certainly for the pes where you 20 see'mid-loop is the thing that sticks out.
21 DR. KRESS: Well within the uncertainty, though.
22 DR. POWERS: But also understand that the numbers 23 that Mark showed on those previous charts are all 24 annualized.
25 MR. CUNNINGHAM: Those are annual averages; that's
/'S ANN RILEY & ASSOCIATES, LTD.
(,,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
357 l 1 1 right. i
/"N'
.Q 2 DR. KRESS: So if I want to know what the risk is 3 during the period >that I'm actually shut down, multiply the 4' numbers.
5 .Yes. I'was just saying you're double-counting, 6: though. When you add shutdown in with the full power, 7- you're' double-counting. full power -- -
8 DR. POWERS: Not very much. l
.9 DR. KRESS: I know. It wasn't really a serious .
(
10' comment.
11 DR. APOSTOLAKIS: Gareth wants to say'something, i
- 12. MR.-PARRY: Actually I don't -- this is Gareth 13 Parry from the staff. You don't in fact double-count,
- 14. because the initiating event frequencies that you calculate j) 15 are on.a per-calendar-year basis and you can't, for example, 16 scram a reactor if it's not at power. So you get the right 17 numbers. I 18 DR. WALLIS: 'You showed us these CDF early
~
19 fatality risk tables and so on.
20 MR. CUNNINGHAM: Yes. I
- 21. DR. WALLIS: Do you need to do a lot more work !
=22 .before actually making some preliminary decisions about what 23 to do about these sorts of numbers? You sort of imply that i
24' you need to do more research to gather more information and ;
25 so on, make better PRAs. But you've already used some O ANN RILEY &. ASSOCIATES, LTD.
Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
i~
E
l 358 1 information.in generating these tables.
() 2 3
MR. CUNNINGHAM: That's correct.
is -- I guess there are several questions.
And the_ question There was a 4 particular approach that was used that -- in those shutdown 5 PRAs that was screened out had a first filter, if you will, 6 to screen out a large -- the vast majority of the sequences !
7 and plant operating states and things like that. One of the 8 issues raised is is that process sufficient, that screening 9 process sufficiently robust --
10 DR. WALLIS: Aha, so --
11 MR. CUNNINGHAM: That you're not missing 12 something.
13 DR, WALLIS: Right. So you're just suspicious the 14 numbers will not be good enough --
15 MR. CUNNINGHAM: Yes.
16 DR. WALLIS: To guide decisions.
17 MR. CUNNINGHAM: That's correct. And another 18 point is the process that was used, even with this 19 screening, at least for the NRC studies, it was a very ;
1 20 resource-intensive piece of work to get to those numbers.
21 Another question is, are there more practical ways 22 today to provide robust estimates without having to do 23 several years' worth of analysis.
24 DR. SEALE: All of the completeness arguments 25 apply in spades, it seems to me.
/~' ANN RILEY & ASSOCIATES, LTD. I Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
359 !
1 MR. CUNNINGHAM: Yes, that's right.
2 DR. POWERS: Just to remind Members, the screening
("2)
%)
3 process took out the mode of operation which the Wolf Creek 4 shutdown event was in.
5 MR. CUNNINGHAM: Yes, that's correct. And that l 6 was going to get -- kind of related to the point I was going 7 to make that we had human performance as an issue in 8 shutdown conditions that is more variable and more of a 9 concern'than in full power because of the Wolf Creek 10 example, if you will. There are more opportunities to do 11 things, if you will, without procedures and without the 12' redundancy of the safeguards equipment.
13 DR. POWERS: Mark, I might just suggest that you
.14 move on to the workshop --
15 MR. CUNNINGHAM: Okay.
16 DR. POWERS: In order to not do too much damage to 17 our schedule.
18 Well, we're doing the damage but we blame you.
19 MR. CUNNINGHAM: That's quite all right.
20 DR. POWERS: That's kind of the rules here.
21 DR. WALLIS: Well, we could shorten our shutdown 22 periods and catch up.
23 MR. CUNNINGHAM: The workshop was a one day l 24 workshop. The morning was spent having -- we opened it up 25 offered outside folks to make presentations on what they I
ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
l
360 1
have done, so we had a fairly large number of industry
)' 2 presentations, be it from vendors or from consulting 3 engineering groups or from individual utilities.
4- The afternoon was spent trying to glean from what 5 we heard in the morning and from our own knowledge of 6 shutdown risk what we could learn about the four topics 7 -there at the bottom.-- what do we see about results, the 8 scope, present methods, and the need for a standard.
9 MR. CUNNINGHAM: The title of this slide is Views 10 Expressed by Workshop Attendees.
11 Again, this is a snapshot -- the workshop was a 12 snapshot of remarks and things like that from a number of 13 attendees, a number of them from the industry but different 14 segments of the industry, if you will. It doesn't mean that (f 15 the Staff necessarily agrees with all these positions, but 16 again this is just a characterization of what was said at 17 the meeting.
18 We also don't have at this point a lot of_ backup 19 to say, well, you have the question, well, why did they say 20 that LERF was not a useful metric, for example, we don't f21 have a lot of background as to -- there wasn't a lot of 22 discussion in this meeting as to the details of that.
23 DR. SEALE: I have a lot of prejudice about the 24 value of the falseness of that conclusion though.
25 MR. CUNNINGHAM: Okay.
' ANN RILEY & ASSOCIATES, LTD.
O, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 361 1 DR. SEALE: Well, for one thing, there are all s these questions of the containment being open, so that the D) 2 3 ratio of LERF to CDF is not just the characteristic of the 4- closed containment, whatever kind it might be, butomore than 5 .that, the driving' term for release, namely the energetics if 6 a release occurred, are quite different for a shut-down 7 system. You don't have necessarily or you may depending on 8 what.the shutdown mode is, you don't have the pool of 9 pressurized hot water to act as a driver or anything else, 10 or those. things, so it seems to me the CDF to LERF 1
11 transition is one of the most uncertain aspects of the whole 12 process.
'13 MR. CUNNINGHAM: Yes. I think that was what was 14 intended here as a point, that the 1.174 concept of LERF
() 15 16 doesn't fit well in this circumstance at all.
DR. SEALE: Well, except that it still is a risk.
17 MR. CUNNINGHAM: Yes, it is. The question comes 18- back to is there a better metric you could use --
19 DR. SEALE: Yes.
I 20 MR. CUNNINGHAM: -- instead of LERF, which is '
21 based on an early containment failure, as you say -- !
22 DR. SEALE: And it is our risk metric, really. i 23 DR. KRESS: I think the concept applies. You just i I
24 may have to define how you determine what an early failure j 25 is, i
/~ ANN RILEY & ASSOCIATES, LTD.
(T) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i
Washington, D.C. 20036 (202) 842-0034 i
362 l' -DR. SEALE: That's right.
2 DR. KRESS: You know, if the containment is 3- already open, that's an automatic early failure.
4 DR. SEALE: Yes.
5 DR. KRESS: And the point about the. driving forces
'6 is not'necesrarily the case. You-boil down the core and 7 strike off the steam zirc reaction, you have got just about 8 equivalent driving forces there with equivalent energies 9 that you have in normal full power.
10 The timing may be different.
11 DR. SEALE: Yes, the timing would --
12 MR. CUNNINGHAM: That's right.
13 DR. WALLIS: Would it be true to say that if CDF 14 is comparable, LERF is probably bigger?
() 15 16 DR. SEALE:
DR. KRESS:
Oh, yes.
More than likely.
17 DR. WALLIS: So it becomes a more useful metric, 18 important metric.
19 MR. CUNNINGHAM: It just may be not a very -- the 20 definition that we use for LERF --
21 DR. WALLIS: The way it's defined --
22 MR. CUNNINGHAM: The way it is defined is not 23 particularly --
24 DR. WALLIS: The actual release is a more --
25 MR. CUNNINGHAM: Yes, the conditional risk if you ANN RILEY & ASSOCIATES, LTD.
f)g
(, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i l
363 1 will may be, can be for some POS's higher than what we see
~
3 .DR. BONACA: One thing that I just wanted to point 4 out is that again we were talking about 5 percent of the 5 time, whatever. In reality, I mean the risk in the true 6 time where you are at risk, which is really mid-loop 7 operation, is extremely high, I mean because the time is 8 extremely short.
9 MR. CUNNINGHAM: Yes.
10 DR. KRESS: It's got to be factored in, j 11 DR. BONACA: Yes, so it is much shorter than 5 12 percent. I mean -- ,
13 MR. CUNNINGHAM: Yes.
14 DR. BONACA: -- the time in which you are at risk, 15 -you know?
16 MR. CUNNINGHAM: That's right, and --
17 DR. BONACA: To the point where that should l 18 provoke a number of questions, like, you know, can you 19 really avert -- avoid that risk?
.l 20 MR. CUNNINGHAM: Yes. '
21 DR. SEALE: Not only is the containment open but i I
22 the primary loop is open. !
23 DR. BONACA: I mean we used to do this refueling 24 in mid-loop operation but there are other ways to do it.
25 It's_just I wanted to throw in just a little, so --
i ANN RILEY & ASSOCIATES, LTD.
p(_j : Court Reporters
'1025 Connecticut. Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
364 1 MR. CUNNINGHAM: That's right. We are touching on
() 2 3
a nunber of points on this slide, as you say, that the instantaneous CDF.can be higher for some of the POS's like 4 mid-loop for a short amount of time.
5 DR. BONACA: Short amount of time.
6 MR. CUNNINGHAM: That's right, so again -- maybe I 7 will just skip this. slide and go on to the next on, where it 8 talks -- perhaps what you can do about some of these things.
9 Again, some of the views from the workshop is in a 10 sense focused on Dr. Bonaca's point of go in and if mid-loop 11 is the real issue, then focus your risk analysis and your 12 work on risk significant configurations and not go spend the 13 resources to go across all POS's.
l 14 Other views offered at the workshop is the p j g 15 transition risk which has always been an unknown in shutdown -
16 risk analysis. Arguments were made that because during 17 transitions there are more controls put on, that maybe that 18 is not as much of an issue as while you are in certadn 19 modes.
20 No real agreement on whether or not fires and 21 floods and seismic should be included, at least from our 22 perspective we did see place in Surry where the fire CDF was 23 a fairly -- was the dominant contributor to mid-loop 24 operation CDF.
25 Fuel handling, fuel pool cooling didn't seem to be
(~% ANN RILEY & ASSOCIATES, LTD.
(_-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 365 1 big issues. The issue raised of whether or not unplanned
~
2 ' outages had been adequately assessed in risk analyses.
}
.3 MR. MARKLEY: Mark, I guess I have a question on 4 the transition and why they feel like there is no need for i
5 stuff. Because most of the human errors, I mean at least in I 6 my experience,. a large nunter of them come during the l 7 transition periods.when you are moving stuff around and 8 changing, and human error would seem to be larger.
9 MR. CUNNINGHAM: Again, I am in a situation where 10 I don't know much of the details of why people said these 11 things. But it is something we can pursue, if you will.
12 DR. WALLIS: This isn't really the basis of 13 research, this is all just hearsay.
14 MR. CUNNINGHAM: This is, yeah, anecdotal 15 information at this point, yes.
16 DR. SEALE: Yeah, but the fact that people had the j i
- 17. perception that the refueling risk was the shutdown risk, ;
i 18- and that seemed to be the case for a while, --
19 MR. CUNNINGHAM: Yes.
20 DR. SEALE: -- and that is no longer apparent once 21 you have looked at this, tells you something about the 22 quality of that earlier judgment.
23 MR. CUNNINGHAM: Yeah, that's right. Early on I 24' don't think there was a recognition by anybody of the 25 occurrences during mid-loop operation, for example,.
(~h. ANN RILEY & ASSOCIATES, LTD.
V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)- 842-0034
l 1 l 366 l
.1 DR. SEALE: 'Yes. !
2 MR. CUNNINGHAM: They are just not recognized.
3= And today I think'there is a very general recognition of the 4 importance of controlling configuration and managing your 5 risk during.mid-loop.
.6 , Talking about methods that would be needed to 7 ' supplement 1.174, if you will, there was some discussion j
8 within the workshop that the qualitative arguments may be 9~ . adequate to supplement 1.174, and it doesn't necessarily 10 need a quantitative PRA approach.
11 DR. KRESS: Let me ask you a question about that 12 one, Mark. It seems to me like there are two basic 13 applications for shutdown risk assessments. One of them is 14 what I would call risk management, to control your outage,
() 15 16 to plan your outage and to be sure you don ( <g ; into too risky a configuration. That takes one kind of PRA and it 17 may very well be you could do this with defense-in-depth and 18 that sort of stuff.
19 But the other need is the regulatory need, where 20 you need to include risk' assessments not for a specific
- 21. outage, but for all future outages that go into your risk 22- assessment to assess the risk status of a plant now and in 23 the' future for regulatory decision purposes, for 24 risk-informing regulations. Now, that is a different kind 25 of PRA. And defense-in-depth doesn't even help you, I mean i
ANN RILEY & ASSOCIATES, LTD.
.O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
367 1 doesn't -- I mean it influences the numbers because you have
, 2 defense-in-depth, but it doesn't help you control or do
(
3 'anything.
4 .So it seems te me like_there is basically two 5 -types of PIUi issue needed, and you need one type, the.
6 utilities need another type.
7 MR. CUNNINGHAM: That is a good point, and it may 8 just -- in a sense, I suspect the people making these 9 arguments, and there have been people who, by and large, the 10 industry has been focused on.
11 DR. KRESS: Focusing on risk management.
12 MR. CUNNINGHAM: . Risk management, that is correct.
13 And even within that, you will see within the industry some 14 that are much more qualitative and some that are very 15 quantitative.
16 DR. KRESS: Which I think is all right.
17 MR. CUNNINGHAM: Yes. Yes.
'18 DR. KRESS: That i, good, and that is needed. But
'19- I think you have a different need.
20 MR. CUNNINGHAM: Yes, that's'right. That is a 21 different need than'1.174.
22 DR. APOSTOLAKIS: I am not even sure that this 23 statement is correct.
,24 DR. WALLIS: Oh, I think it is wrong.
25 DR. APOSTOLAKIS: The qualitative defense-in-depth l
i r~ ANN RILEY & ASSOCIATES, LTD. !
(N,)_' Court Reporters j 1025 Connecticut Avenue, NW, Suite 1014 '
Washington, D.C. 20036 (202) 842-0034 i
p-368 1 concepts are adequate for RG 1.174. The whole idea there is 2 --
(:) -3 DR. KRESS: I think it is adequate for risk 4 . management. I think 1.174 is more of the regulatory need, 5 and I would agree with you.
6 DR. WALLIS: Isn't it. wrong when you have lost 7 much of your defense-in-depth --
8- DR. SHACK: If you are Grand Gulf and you can 9 bound it, then it is adequate for 1.174. You know, it may 10 be it is adequate for some people and not for others.
11 DR. KRESS: Well, you know, you would always make 12 the bounding argument.
13 DR. SHACK: Yeah.
14 DR. APOSTOLAKIS: Well, but you don't know. If
() 15 you don't have a detailed PRA somewhere, you really don't 16 know whether you are missing something.
17 DR. KRESS: That'is my opinion.
18 DR. APOSTOLAKIS: Even for risk management.
19 DR. WALLIS: It seems to me this is the wrong 20 statement. It is the wrong statement.
21 MR. KING: This is Tom King. What South Texas 22 told us at the workshop was they used detailed PRA to 23 identify those states where they needed to do risk 24 management.
25 DR. APOSTOLAKIS: Yes.
ANN RILEY & ASSOCIATES, LTD.
O Court Reporters
-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
369 1 MR. KING: Where they stop, when they get into
/~N 2 those high risk configurations, they stop other activities b 3 and they put dedicated people to watch RHR, watch inventory 4 and so forth. So they were doing both, in effect.
5 DR. KRESS: Even there, that is a different kind b 6 of PRA than what you need.
7 DR. APOSTOLAKIS: Yeah, that is very different.
8 MR. CUNNINGHAM: And part of that, too, is getting 9 at the barriers that we talked about, is you see some of the 10 risky operations come, then you make sure the containment is 11 buttoned up and that sort of thing, too.
12 DR. APOSTOLAKIS: But I disagree with the first 13 bullet, though, I mean make it clear, even for regulatory 14 purposes, I am not sure that -- I mean you are undermining
()
t 15 16 1.174, I think if you do much of it qualitatively.
DR. POWERS: Let's make it clear that the speaker 17 doesn't vouch for this.
j 18 DR. APOSTOLAKIS: No, I understand. I 19 MR. CUNNINGHAM: I am not an advocate of this 20 position. l 21 DR. SEALE: You are a reporter.
22 MR. CUNNINGHAM: Yes, that's right. i 23 DR. APOSTOLAKIS: I understand that.
24 MR. CUNNINGHAM: That's correct.
25 DR. APOSTOLAKIS: It also amazes me, though --
("'g ANN RILEY & ASSOCIATES, LTD.
(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
370 1 DR. WALLIS: You mention the importance of human
() 12' factors. Isn't this a case where you say you dedicated 3 people to watch the RHR and all sorts -- this depends very 4 much on those people assessing probably what is. going on, 5 and'most of the events seem to be based on human
.6 misunderstanding or omission.
7 MR. CUNNINGHAM: That's right. Yeah, you can't --
8' one of the issues that you see is poor instrumentation or 9 lack of instrumentation, so in that sense --
10 DR. WALLIS: Interpreting instrumentation they 11 have got.
12 MR. CUNNINGHAM: Yes. Yes, that's right.
13 Two or three topics that were mentioned as being 14 quite different for. shutdown, that may require additional
() 15 research,. are the success criteria, how much flow, how much 16 injection do you really need, failure data for equipment, ,
I 17 and then the source term issue. !
I 18 DR. KRESS: The source terms wouldn't be very much
-19 different, mostly just in the timing of the approach.
20 MR. CUNNINGHAM: That's right.
21 DR. POWERS: I think in my limited thinking on 22 this subject, I think that if you talk about things that go 23 completely into core degradation -- you are right, I mean 24 there is this problem of higher oxygen potentials and like j
'25 that that complicate things and can have some fairly i
/ ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
371
- 1. ' dramatic effects on the elemental distribution of your 2' source term to consume air, high oxidation potentials exist.
3- And those kinds of things we can handle with 4 . existing kinds of models, but I think there's a difference 5 that you have to recognize for shutdown and it comes about 6 because of how you define what are success criteria.
7 If we uncover a core during power operation and 8 subsequently flood it, we say we.have be3n successful. I' 9 think when you are open in a shutdown situation you uncover 10 a core, discover that you have done so, flood it, shatter 11 the fuel, then you have not ended the accident there, 12 because water will leach iodine out of the fuel and iodine 13 can partition into the atmosphere, and you have sort of 14 thing, and that is not different than iodine leaching,
.15 partitioning out of containment sumps and what-not like 16 that, but-it is something that we have not considered that 17 kind of a source term in our power operations and yet it 18 coul,d. leave you in a situation where you can't do anything 19 about the plant. It is too radioactive to approach, so you 20 can't seal it up.
'21 DR. KRESS: And I presume higher ingress by being
' 2 2' a higher probability shutdown. I am not sure.
23 DR. POWERS: Well, in whatever limited work has 24 been'done largely in connection with the PHEBUS program, I
-25 think-it is an open issue and I think it is an open issue O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW,_ Suite 1014 Washington,-D.C. 20036 (202) 842-0034 m
372 1 because people have a hard. time dealing with one of your 2
I~'}
G
. favorite subjects, which is parallel flow instabilities.
3 So I don't think we know whether it is more
'4 probable. Clearly it is probable to put air into the system 51 if you go-into a full core melt, but is it more probable at 6 part way through and things like that? I think it rests 7 upon, like I say, your favorite topic, which is parallel 8 flow instability -- and we're using.up your time.
9 MR. CUNNINGHAM: That's okay. The last topic of 10 the workshop was the need for a standard in shutdown risk.
11 I think there was general agreement that there was a need 12 for a standard, but it broke in a sense into two camps. One 13 was -- in the sense of timing relative to the present work 14 and one opinion was that we should wait on this to better O j 15
( understand the implications of what is -- if you will, the 16 lessons learned from the present ASME standards work, and 17 try not to avoid perhaps some of the dead ends that were hit 18_ in that activity. i i
19 Another side of the coin was that there's so much 20 work going out by individual licensees out there that the i
21 sooner that we get some sort of a standardization of this, 22 the better it would be for individual licensees. It would
'23 reduce the variation or the variance of the cost to 24 licensees.
25' The second point there is that we shouldn't assume
/~
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
373 1 that the shutdown risk analysis would be kind of a cookie t 2 cutter of the full power risk analysis. The standard then 3 may have to be shaped quite differently because of the way 4- risk would be assessed in shutdown.
5 Basically, our overall goal is that over the next 6 about six months we need to come up with a statement that is 7 a perspectives report, if you will, on shutdown risk 8 summarizing what our undorstanding is and what we believe is 9 needed in terms of future research.
10 In order to get there, we have had a couple of 11 things already We are going to continue with work over the 12 next few months. We are going to go out and become more 13 familiar with some of the industry shutdown PRAs including 14 South Texas, Grand Gulf and some others.
O) f y 15 We want to better understand the more commonly 16 used risk management methods like ORAM and EOOS and that 17 sort of thing so we are going to be on the, some of the 18 Staff is going to be on a travel circuit, if you will, to 19 get a better understanding of these things.
20 DR. POWERS: We know what ORAM is, but what is --
21 MR. CUNNINGHAM: Pardon me?
22 DR, POWERS: ORAM I am familiar with. I can find 23 it on the web. Can I find EOOS on the web if I can't find 24 anything else about it? EOOS -- I just don't know what it 25 is.
ANN RILEY & ASSOCIATES, LTD.
O\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
374 1 MR. CUNNINGHAM: I am not sure -- I am looking at
)
2 Gareth or Erasmia. Do you know?
3 MR. PARRY: Yes. It's either'EPRI or SAIC and I 4 think they would -- it's EPRI, okay. Then you would be able 5 to find it from them.
6 MR. CUNNINGHAM: We are going to continue a review 7 of what we can learn about domestic studies and through 8 COOPRA and just continue the work looking internationally.
9 DR. SEALE: Mark, you had a list of three or four 10 utilities and then SAI and'other people who were involved 11 directly in your workshop.
12 MR. CUNNINGHAM: Yes.
13 DR. SEALE: How long is the list of utilities who 14 have shutdown PRAs that would be appropriate candidates for
() 15 16 inclusion in this review?
MR. CUNNINGHAM: The list -- we are going to see 17 four at this point.
18 -DR. SEALE: -Yes.
19 MR. CUNNINGHAM: I don't have a sense of how many 20 others there are. The four were kind of -- you know, we got 21 one that's very detailed, one pretty simple and two in the 22 middle. I have heard, again anecdotally, that at least half 23 the utilities have shutdown PRAs. I have heard that.
24 -_
W hether that is again how sophisticated they are, whether 25 they are being used more'for qualitative risk management
'/ ANN RILEY & ASSOCIATES, LTD. I I,, ') - Court Reporters
-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ;
(202) 842-0034
375
-1 purposes and things I don'tiknow.
] 2 DR. WALLIS: That final report, that perspectives 3 report --
4' MR. CUNNINGHAM: Yes?
5 DR. WALLIS: I would like to go back to what Dana 6 .said earlier. I think that it would be good'if you spelled.
7 out more clearly'what'it is specifically that: is needed'by 8 the NRC.
- 9 MR. CUNNINGHAM
- 'Yes.
11 0 DR. WALLIS: Right now, so that you -- what we-are 11 going to wind up with at the end is a measure of A,'B, C, D.
12 We need those to make sudden decisions, whatever they are --
13 X, Y,'Z - and focus on those things. Do we have enough 14 information to give them that, so that.they can then decide
.15 what to~do.
16 DR. KRESS: Are you. thinking about, Mark, the 17 'needs for'an additional database for shutdown risk? I have 18- .in mind, you know, you need-to -- there's probably a need to 19 survey the whole industry to. find'out what frequency 2 0.-- different systems and components are at, what is the 21 durations they are out, an average type' thing, and then - '
22 and the average tine of shutdowns:for the industry. ~ These 23 are data that you are going to need --
'24 MR. CUNNINGHAM: Yes.
25- DR. KRESS: When you make a risk assessment and D ANN RILEY & ASSOCIATES, LTD.
h Court' Reporters 1025 Connecticut Avenue, NW, Suite 1014
-Washington, D.C. 20036 (202) 842-0034 L
~ . .
376 1 then I don't know if it has all been collected very well, s
( 2 because they are not normally in a PRA database.
')
\_/
3 MR. CUNNINGHAM: That's correct. You could see 4 that evolving, that we are starting to do a better job of 5 collecting power operation data on equipment failure rates 6 and that sort of thing.
7 DR. KRESS: That's not going to -- it's a 8 different database.
9 MR. CUNNINGHAM: That's right.
10 DR. SEALE: You need to know about refueling 11 machines and cranes and things like that.
12 MR. CUNNINGHAM: And you need to know times of, 13 durations of different configurations and that sort of 14 thing.
rN
( ,) 15 DR. KRESS: They're different and whether there's 16 correlations. You know, you take this one out but you won't
{
17 take this one out.
18 MR. CUNNINGHAM: Yes.
19 DR. KRESS: Or these two will come out at the same 20 time or something like that.
21 MR. CUNNINGHAM: That's right.
22 DR. KRESS: So you need to worry about !
23 correlations.
l i
24 DR. BONACA: The other thing about it, I think i Q
25 there is a lot of information available because I believe ANN RILEY & ASSOCIATES, LTD.
[~')h
'\- Court Reporters ,
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
377 1 all utilities must have --
2 DR. KRESS:
]) I think it is available. You just 3 have to go get it and you have to figure out what you want 4 and what --
5 DR. BONACA: They have the. shutdown management 6 programs in place.
7 MR. CUNNINGHAM: Yes.
8 DR. BONACA: Whereby they have procedures and also 9 they have very clearly identified whether or not they are 10 developing either quantitative or qualitative PRA profiles, 11 okay? It qualitatively means that it is not fully 12- quantified but you have clear identification of the delta 13 between certain conditions you are addressing, so through 14 that information I think there is a lot of information
(/ 15 available to see where the status of the industry is just by 16 those programs.
17 DR. KRESS: I don't know how you retrieve that 18 data. That's the only -- put in the form you need it.
19 MR. CUNNINGHAM: That's right, and we have talked 20 mostly today about the issue of how you would treat it in 21 the context of license amendments and that sort of thing, ,
22 considering it in the 1.174 space. ;
23 You get into the new risk-informed oversight 24 program, the inspectors are going to be faced with the 25- ~ question of how do you -- what, if anything, do you need to O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (2023 842-0034
378 L1 inspect in terms of shutdown, the programs, the results or f 2 that sort of thing, so there is another interest here, if 3 you will.
4 Last slide, basically over the next few months we 5 are. going to be visiting the sites and other engineering 6 firms and that sort-of thing. As it's laid out now, we 7 would' envision having a draft report in the October time 8 frame and coming to the ACRS perhaps for a subcommittee in 9 November to talk to them -- talk to you some more. If you 10 like, we can perhaps add a subcommittee in before that where 11 once we've gone on the plant visits and the reviews, and 12 perhaps in the September time frame or something if you're 13 interested we could give you more of a perspective at that 14 point of'what we've seen out in the industry. That's a
() 15 decision for obviously --
16 DR. WALLIS: Well, I have a sense of urgency about 17 this that I don't see reflected. What your numbers told us 18 was that the CDF is comparable to power operation, that the 19 actual cancer fatality risks are higher because the things 20 are open and so on. So it would seem that the risk to the 21 public of shutdown is maybe greater than the power operation 22 on which NRC's been focusing so much attention. It would l 23 seem that-this would be a really high-priority item to deal' 24 with' .
25 MR. CUNNINGHAM: I think it is a high-priority --
l ANN RILEY & ASSOCIATES, LTD.
C')/
s- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
379 1 one st the things that's not reflected very well in the O
%J 2 results I showed was again those are about five years old, 3 and there's been a lot of work in the industry that's been 4 done since then to manage their outages better, to reduce 5 the duration, to -- someone talked about the idea of iust 6 ' avoiding mid-loop operation. Now after this work we did for 7 Surry, that's one of the things they went back to do. They 8 said we're just going to do everything we can to not go --
9 DR. WALLIS: So it looks like a place where the 10 NRC could have a great influence on public safety, and we 11 get a lot of stuff to look at where the payoff to public 12 safety may be small. I mean, it's just detail stuff. But 13 this looks like an item where you have a chance to make a 14 real contribution.
15 MR. CUNNINGHAM: Yes.
16 DR. WALLIS: This is quite measurable.
17 DR. KRESS: Let me ask you another question about 18 planning and research. As I said earlier, I think a PRA for 19 shutdown looks a lot different than a PRA for full power, l 20 and it looks a lot different for your needs than it does for l 21 risk management. It seems to me like there's going to be a )
22 need to develop approved PRA methodology. Actually you're 23 not going to be able to take your standard full-power PRA in 24 and wedge shutdown into it. So there's a need to develop 25 PRA methodology for doing shutdown risk. Now whose job is 4 G ANN RILEY & ASSOCIATES, LTD.
h Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l
Washington, D.C. 20036 (202) 842-0034
380
-1 that? Are you guys going to do that in Research or is 2 that --
3 MR. CUNNINGHAM: That's one of the --
4 DR. KRESS: I can't see industry doing that, 5 .because it's your need. You need this kind of PRA to do 6 your risk-informed regulation.
'7 MR. CUNNINGHAM: Yes.
8 DR. KRESS: So it's a need you have.
9 MR. CUNNINGHAM: Yes. In that sense --
10 DR. KRESS: Do you c4 vision this leading to a 11 research proposal --
12 MR. CUNNINGHAM: Yes.
13 DR. KRESS: Perhaps --
14 MR. CUNNINGHAM: Yes, that's correct. You know,
.() 15 one of the things we have to deal with, is the real need 16 methods development or is it more applications of existing 17 methods or what. But all of that would be in the scope of 18 this program, if you will.
19 DR. KRESS: That's part of the scope.
20 DR. POWERS: Let me make sure you understand, 21 Graham, those numbers Mark put up there are part of a 22 scoping study that they did with the ground rules that are 23 fairly typical of PRAs. That is, actions that are 24 proceduralized were allowed; unproceduralized or heroic 25 actions were not considered in getting those risk numbers.
(~'
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
381 1
1 Well -- and that's a well-founded process in power operation
/ '2' PRA. But it kind of flies in the face of sensibilities when 3 it comes to shutdown PRAs, the idea that you could have a 4 core merrily boiling its coolant off and -- I don't have a
- 5. procedure, so I just can't do anything about that darn 6 . thing.
7 That's a little bit unfair, in that there are lots 8
of accidents that can occur in shutdown where there isn't i
9 time to respond.
4 10 MR. CUNNINGHAM: Yes.
11 DR. POWERS: But the fact is that the recovery 12 options available to the operations staff are richer than 13 probably are reflected in those numbers.
14 DR. SEALE: That's right.
f 15 DR. POWERS: And that's why some, including 16 Members of the Commission, have questioned the accuracy of 17 those things. .And I think that's the kind of information
.18 _you need to go out and ferret out because you presume that a
~19 plant is not so rigid in its rules on how it does its own 20 evaluation.
21 So those scoping numbers, you know, they always {
22 excite me, and I rant and rave. On the other hand, I also I l
23 try to temper my comments by saying I also know where those j 24 numbers'came from, and so that's one of the reasons the ACRS 25 .in its letter to the Commission didn't say do something ANN RILEY & ASSOCIATES, LTD.
- (~)'
(_ Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)'842-0034
382 1 about shutdown risk. Now we said go find out about shutdown
() 2 3
risk, because there's more to it than I think the scoping
. studies have said.
4 DR. WALLIS: Well, not only are there 5 opportunities for heroic action that solves the problems,
~
6 probably for heroic action that makes it worse.
7 DR. POWERS: Yes. Right now what -- I mean, what 8 you have is an empirical data base that says something like 9 58 percent of the augmented inspection teams that the NRC 10 sends out are associated with shutdown or low-power events.
11 That's one data point.
12 The other data point I get is Mr. Pietrangelo 13 comes in front of me and says yes, that's all true, but it's l 14 ancient _ history. But if you look at the modern day, and O
( ,/ 15 someday he's promised me he's going to show me this plot 16 that.shows that so many improvements have been made in the 17 way we do outage management nowadays that those numbers are 18 way down. Okay. So it's a dynamic period.
19 DR. WALLIS: That may be true.
20 I have another question for you. We talk about 21 PRA methodology, and we sort of think about probabilistic 22 things, but I wonder how much we really understand these
'23 sort of technical, physical, chemical scenarios of l 24 uncovering the core or failing to cool it properly or the l
25 various things that can happen when the top's off. But you i O
N-ANN'RILEY_& ASSOCIATES, LTD.
Court Reporters ;
1025 Connecticut Avenue, NW, Suite 1014 '
Washington, D.C. 20036 (202) 842-0034
I l 383 l 1 spend hundreds of millions on LOCAs and things which are l IY
, LI 2 very much less likely. Do you'have the basic technical
-3 research to know what happens in the event of --
4 MR. CUNNINGHAM: No, I think that's -- within the 5 context of the research program we could be talking about I 6 here in six months that's fair game as well.as the 7 probabilistic parts.
8 'DR. WALLIS: Do you have any idea of how much that 9 might amount to?
10 MR..CUNNINGHAM: In terms of?
11 DR. WALLIS: Of the needs for research in that 12 sort of area and the technical details.
13 MR. CUNNINGHAM: I don't have a good sense now.
1 14 The part --
) 15 DR. WALLIS: What is the basis now? Are there 16 calculations made of all kinds of scenarios that could occur 17 in event of shutdown -- a failure to cool the core during 18 shutdown? *
.19 MR. CUNNINGHAM: Yes, there are thermohydraulic 20- calculations done, there are source term calculations done 21 that would --
22 DR. WALLIS: Are they of the quality that we've j i
23 seen for LOCAs and things like that? l 24 MR. CUNNINGHAM: I suspect --
25 DR. POWERS: The source term calculations of ANN RILEY & ASSOCIATES, LTD.
/~')N
(_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
384 1 course are superb and without fault. But the
~T
[d 2 3
thermohydraulics --
DR. KRESS: Pretty superficial.
4 DR. POWERS: Well, there's been --
5 DR. WALLIS: Can we answer that without, you know 6 -- in a more professional way?
7 MR. KING: I don't know of any experimental work 8 that we've funded that's looked at the shutdown condition 9 with the head off the vessel and thermohydraulically run a 10 calculation and compared it to expe.imental results. '
11 DR. WALLIS: Well, what happens?
12 DR. POWERS: Well, what I know is that in 13 connection with PHEBUS feasibility -- there's a PHEBUS test 14 in France planned to look at the issue of air intrusion on
() 15 the behavior of the fuel. And in connection with the 16 development of the feasibility for that, calculations of a 17 variety of natures were run, and they varied from lump node 18 codes trying to jury rig the air intrusion accident to -
I 19 fairly sophisticated codes that Mr. Patankar I believe 2 .. ' develops on natural circulation kinds of phenomena and what 21 not, but they ran into the problem that this -- when you've 22 got the head off, literally the head off, that you've got 23 this huge big-diameter vessel with steam coming up.
24 'Well, that sounds all very good, and you're very 25 confident that the steam keeps the air out, except Dr. Kress I
ANN RILEY & ASSOCIATES,.LTD.
[)h
\_ . Court' Reporters 1025 Connecticut Avenue, NW,. Suite 1014 '
Washington, D.C. 20036 i (202) 842-0034 i
I m .-. .]
[-
385
,1 1 points out accurately that this is inherently unstable, and
,. 2 you get these instabilities. And the problem is it's !
3 . irreversible. Once air starts going down into the core, it 4 reacts, and the oxygen's removed out of that, and so it i
5 creates a vacuum, and you never get out of that instability, i 6 and so you can get air intrusion. And that seems to be a 7 very difficult thing to handle computationally right now.
8 DR. WALLIS: So,'you see, there are lots of i 9 lacunae in the computational abilities.
10 DR. POWERS: Yes. Now, the source term itself, l
11 there is some confidence that if we knew exactly what 12 happened to the clad, we would know how to calculate it, i 13 because the only thing that really changes is the oxygen l 14 potential, and we think we know what oxygen potentials are.
() 15 DR. KRESS: I don't think we really handle heatup 16 rates very well either.
17 DR. POWERS: Well, the real --
18 DR. KRESS: The heatup' rates around the change.
19 DR. POWERS: The real challenge comes up'is if you R20 heat very vigorously, you drive the~ clad to melting and now 21 it can drain away and leave the fuel exposed, and that is 22 all the difference in the world, If you expose the fuel to 23' oxygen, there have been tests now done at the esteemed 24 institution in the southeast of the United States on air u
-25 affects fuel and a really extensive set of experiments --
(~')
\ ,/
ANN RILEY & ASSOCIATES, LTD.
% Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l 1
l
7 386 1 DR. KRESS: Is that Savannah River?
/ 2 DR. POWERS: No. No, much more esteemed than 3 Savannah River. You may have heard of it, it is very near 4 where you live. And there has been some work in Canada that 5 pretty clearly shows that if you expose this fuel to air, 6 you are going to get a ruthenium source that you had not i 7 anticipated.
8 Now, you say, well,. ruthenium has been more a 9 fission product. Ruthenium is the element that I 10' characterize as being a disaster that they make movies out 11 of, because it has the prompt fatality consequences of 12 iodine and the latent fatality consequences of cesium. You 13 do not want to_get large releases of ruthenium.
14 DR. WALLIS: Well, there is also a possibility of
() 15 16-this reactor gone' critical with the head off. I believe that has happened in at least one case.
18 DR. WALLIS: So I guess that you might find out in 19 your studies that there is a great need for research on what 20 actually happens during the'--
21 MR. CUNNINGHAM: The physical process.
22 DR. WALLIS: Within something the Commission would 23 have to face up to.
24 MR. CUNNINGHAM: Yes. I have run well over my 25 time.
I l
/"') .
(s,/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
387 1 DR. APOSTOLAKIS: Do you think we should have a 2 _ subcommittee meeting?
3 DR.' POWERS: I think it is essential. But'I think 4 it is essential in the November.timeframe. I am not sure 5 that Mark's offer to have an interim briefing in there is so 6 crucial to us. That is my opinion.
7 DR. APOSTOLAKIS: HNo , I think that is --
8 DR. SEALE: If you find some surprises, --
'9 MR. CUNNINGHAM: Yeah, maybe that is it.
10 DR. SEALE: -- that may be appropriate. But you 11 are probably a better judge of whether that is opportune.
12 -' MR. CUNNINGHAM: Okay. What we can do is we can 13 go back and after_we get through the next few months, we can 14 see if there would be something that we could -- that would C)
( 15 merit a few hours or half a day or something like that.
16 DR. SEALE: This does look like a candidate for 17 having some surprises.
18' DR. WALLIS: Well, is this final report going to 19 be of the form "more work is needed," or is it going to be 20 of the form "there isn't a problem," or is it going -- or 21 you have a great problem here and you have got face up to 22i .it? I_ hope it is going to really face up to the problem and 23 not end up saying, well, work is needed and action, 24 something will come --
25 MR. CUNNINGHAM: I think this is a planning O
ANN RILEY & ASSOCIATES, LTD.
Court. Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
388 1 effort, so one of the outcomes of the report will be this is
() ~
2 3
-- specifically, this is what we need to do over the next few years to -- given the money we have for low power and 4 shutdown research.
5 DR. WALLIS: I.think what the Commission probably 6 needs to know is it looks as if, from some of the 7 indications, this might turn out to be a real sort of I 8- significant problem that would shake the agency, in which 9 case they need to know.
10 MR. CUNNINGHAM: Well,'again, we are seeing the 11 confirmation over and over again that the shutdown rieks are 12 similar. The Commission is aware of that, but perhaps this 13 will just reinforce, but I don't know.
14 DR. KRESS: Well, lest you put too much weight on
() 15 your workshop opinions, I suggest you start from top level 16 principles which might include stuff like we want a 17 realistic estimate of the risk. We want to include most of 18 the POSs because they will add some in there and we need it 19 even though I wouldn't --
I wouldn't say we don't want 20 scoping analysis that are bounding in this case, because we 21 are talking about the needs for risk-informed regulation.
22 MR. CUNNINGHAM: Yes.
23 DR. KRESS: So, you know, I wouldn't put too much 24 - weight on those workshop things.
25 MR. CUNNINGHAM: Yeah.
O ANN RILEY & ASSOCIATES, LTD.
i Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034
I i 389 1 DR. KRESS: And I think you need to start thinking
/' 2 about this database I mentioned, and you need to start
(
3 thinking about how -- what is a PRA going to look like that 4 will do.a shutdown risk? And it is not an ordinary PRA. I 5 think your problem there is going to be, for -- you have got )
6 to deal with the individual plants, PRAs for individual 7 I plants,.and individual plants' future shutdown
{
i 8 configurations are unknown to you. But you have got an 9 industry-wide database that tells you what shutdowns 10 generally might look like on a probabilistic sense.
11 So you are going to have to think about likely 12 about probabilistic sense, future configurations for a given 13 plant, and how you deal with that in a PRA. How do I 14 incorporate likely future configurations in a PRA? And you
() 15 will have to use this database for industry-wide, because 16 you don't have a database for an individual plant. You will 17 have to use a database industry-wide to get likely future L 18 conditions and have the PRA configured in such a way that it 19 can select internally those likely conditions.
20 MR. CUNNINGHAM: Yeah.
21 DR. KRESS: That is a different -- that is why I 4 22 am saying it is a different PRA. l 23 MR. CUNNINGHAM: Yes. !
24 DR. POWERS: I am going to have to intercede 25 -because I have got -- I am going to run into a scheduling i ANN RILEY & ASSOCIATES, LTD.
(]_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
e l '
390
! I problem here, j.
2 DR. KRESS: I think we are basically finished.
3 DR. BONACA: I have,just one comment if I could, 4 just one simple comment I had. The observation I made 5 before, clearly, I am not -- I understand the impact on the 6 industry, but cutoff load, which some plants do, eliminates 7 much of the risk, which is really mid-loop oftentimes. I am 8 only saying that there may be even an analysis done at some 9 point to understand, okay, what -- in the aggregate, by 10 using the number of plants you have got, the number of 11 refuelings you have per year, and so on and so forth, to 12 look at the individual issue of mid-loop operation versus 13 full offload, just to get an understanding.
14 DR. KRESS: I think Graham would say there ought
() 15 16 to.be a cost-benefit assessment of that, because that is going to cost you a lot of full core offload.
17 DR. BONACA: I understand that, and I am not 18 proposing it right now. I am only saying that one should 19 understand the dimension of that issue alone, because there 20 is one action there that certainly may not be desirable but 21 is feasible. That's all.
22 MR. MARKLEY: There certainly won't be 17 day 23 outages.
24 DR. KRESS: Yes.
25 DR. BONACA: Yeah, I understand that. I am not i
i ANN RILEY & ASSOCIATES, LTD.
l I
O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l
i l
Washington, D.C. 20036 (202) 842-0034
i 391 1 proposing it either.
2 DR. KRESS: Thank you, Mark.
3 MR. CUNNINGHAM: Thank you for the comments.
4 DR. KRESS: It was-very, very interesting. We 5 will.look forward to continuing our interactions on this 6 issue.
7 I MR. CUNNINGHAM: Thank you, all. '
8 DR. KRESS: I will turn the floor back to you, Mr.
9 Chairman.
10 DR. POWERS: Okay. At this point I want to go off 11 the record.
12 [Whereupon, at 11:40 p.m., the meeting was 13 recessed, to reconvane at 12:47 p.m., this same day.)
14 16 17 18 19 20 21 1
22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
O' Court Reportern 1025 Connecticut Avenue, FiW , Suite 1014 Washington, D.C. 20036
, (202) 842-0034
392 i
1 AFTERNOON SESSION l 2 (12:47 p.m.]
3 DR. POWERS: Let's come back into session. We are 4 moving now to the topic of options for crediting existing 5 programs for license rrenewal.
6 Bob, I think you're in charge of it.
7 DR. SEALE: Yes. I'm working sort of as a 8' vice-chairman, along with Mario, on this particular 9 Subcommittee on License Renewal. And the question of credit 10 for existing programs is going to be looked at as a specific 11 issue as we go forward.
12 You remember the last time we talked about license 13 renewal, among other things we were exposed to the 14 statistics that there are about 400-odd programs of one sort
() 15 or another in the existing license basis for BGE that have 16 been judged to be sufficient unto themselves to provide the l
17 kind of monitoring and oversight of those activities to 18 carry forth'into the renewed license. There are between ten 19 and 20 of those programs that'were found to be slightly 20 deficient in a few areas, and there were only 25 new 21 programs -- or about 25 new programs that were identified as 22 being required in order to meet at least the first cut at 23 the full requirements of license renewal.
24 Clearly this affords an opportunity to use 25 considerable -- or to realize considerable resource i
,O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
393 1 conservation if we are able to carry these programs forward 2 without serious change.
[
3 This is an issue that has been the subject of 4 discussions between people from the Nuclear Energy Institute
~
5~ and the Commissioners,'and we understand that the staff is 6 in the process of preparing a draft Commission paper on the 7 subject. That paper is not fixed yet or not finished, so 8 we're not able to get the full story at this point.
9 Mr. Grimes has offered to give us an update and a 10 status report and so on, and so this is a good time for us 11 to get a heads-up on what we can look forward to, 12 Chris, I'd like you to go ahead and do that, but 13 I'd also want you to -- or would appreciate it if you could 14 tell.us when do you need something from us, and what that r
( ), 15 something might be, 16 MR. GRIMES: Yes, Dr. Seale, I'd be happy to. !
i 17 My name is Chris Grimes. I'm chief of the License {
18 Renewal and Standardization Branch.
l 19 As Dr. Seale mentioned, there's an issue that has 20 existed since the license renewal rule, Part 54, was amended j 21 in 1995, and it concerns how existing programs are credited 22 for the purpose of a license renewal application.
23 Recognizing that the vast majority of aging management l 24 programs that utilities would refer to in order to address ,
25 the finding that we would need to make for a renewed license ANN RILEY & ASSOCIATES, LTD.
) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
394 1 are existing programs, and then, as Dr. Powers pointed out,
() 2.
3 but it gets back to a basic question about what mission did the Commission intend to send us on when they said to go 4 review aging management programs for passive, long-lived 5 systems, structures, and components, in order to determine 6 that those programs are effective at managing aging effects, 7
what does!" demonstrate the effectiveness of" mean in a 8 regulatory review context?
9 We have a Commission paper that we had hoped to 10 have completed by now. We had targeted completion for May 11- 28. I apologize. It was probably too optimistic to think 12 that after we'd met all our milestones for the first two 13 applications that we meet the milestone for that Commission 14 paper.
() 15 But I can tell you that it has been a very 16 difficult issue for the NRC and the industry to come to 17 grips with in terms of what is it that we're arguing about.
18 And that has led us to have the Commission paper go through i 19 a series of evolutions including feedback from the License 20 Renewal Steering Committee and the EDO's office. And so we 21 have shared with the Committee the latest draft, which does 22 include changes that --
the feedback that we got from the 4 l
23 Steering Committee and our management and the EDO's office, 24 but because the EDO has not yet signed the paper out, we've 25 shared it with you as predecisional information because l
1
(~)
(j ANN RILEY & ASSOCIATES, LTD. I Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
f- 395 1 there's still a. chance that the nature of the options, the
/\ 2 characterization of the impact of those options, might b 3 change. So we've given it to you in draft form.
4 We are hopeful that the Commission paper will be 5 completed shortly. As a matter of fact, they are so hopeful 6 in the EDO's office that there is a Commission briefing 7 tentatively scheduled on the subject for the week of July 8 12. And we're going to talk specifically in that briefing ;
9 that the staff is_ going to present its views about what the 10 Commission intended, referring to language in the statements 11 of consideration, for the 1995 amendment to Part 54.
I 12 NEI will be there to present their views about how 13 they read that same language from the statements of 14 consideration and what they had thought the nature of the
() 15-16
' license renewal would consist of. And I think that we may find that after all of our effort to try and characterize 17 the nature of this controversy and what its real impact is i 18 relative to a license renewal application, that we'll find 19 that we're not so different, but that it geta back to and 20 how is stability and predictability ensured in a license 21' renewal review process.
22 And so we will continue to Keep the Committee 23 posted on this issue. It is a fundamental policy issue, the 24 question about what mission did the Commission intend for us i
25 to do. 'And so it's very important for us to get that
(~s ANN RILEY & ASSOCIATES, LTD.
t
( -
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 1
i
i i
396 l 1 mission statement clarified and to resolve any differences.
2 about what the nature of the job is.
) ;
3 DR. POWERS: When you look at the statements of 4 consideration and the language that was bandied around 5 during the development of the license renewal rule, do you 6 find suggestions that the word "to demonstrate" was in any 7 way different than its engineering interpretation?
8 MR. GRIMES: No, we don't feel that -- we feel '
9 that " demonstrate" means something substantial. We also i l
10 felt that the language in the statements of consideration -
11 challenges us to challenge the existing programs and to l
12 determine what additional requirements should be imposed to I i
13 manage aging effects for the period of extended operation. l 14 The difficulty comes about in the language in the
() 15 statements of consideration that says but the current 16 licensing basis is still adequate and will carry forward.
17 And using, you know, referring to that language, we also 11 8 understand the industry's views that the threshold for 19 challenging the adequacy of existing programs should meet 20 some threshold. I 21 And then it gets down to a very practical and 22 pragmatic question about well, what's the appropriate 23- threshold vis-a-vis this question about adequate protection.
l 24 If the program is adequate for the first 40 years, why isn't l
l 25 it adequate for the next 20? That, you know, I think that's
/~'g ANN RILEY & ASSOCIATES, LTD. I tj Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
397 1 a fair question. And we view " demonstrate" to mean well, it j
)
2 may be okay for the first 40, but we have a higher 3- expectation to manage aging effects through a period of 4 extended operation.
5 DR. POWERS: I guess it was not my impression that 6- the -- I had gotten the impression, rightly or wrongly, that 7 things that were adequate for the.first 40 years did not 8 have embedded in them the concept of aging that went beyond 9 that, and that what you were looking for was equivalency, 10 but that it was not ipso facto true that because it was good 11 for 40 that it was good for 60.
12 DR. SEALE: Or fully sufficient.
13 DR. POWERS: Fully-sufficient.
14 The particular issue'used as an example for
() 15 16 challenging you is one that intrigues me, because -- the smaller-than-four-inch-pipe issue, where it seems that it's 17 argued that it's adequate to infer rather than to 18 demonstrate, it seems to me that's contrary to the language.
19 MR. GRIMES: We would agree, but NEI would l L20 disagree. And I think that trying to capture the nature of 21 that disagreement has been a challenge for us for this 22 Commission paper. We also fully expect to address that l
( 23' . example along with others.
24 The first example that we exposed you to was this 25 question about is the equipment qualification process under I'
ANN RILEY & ASSOCIATES, LTD.
g Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
~i Washington, D.C. 20036 (202) 842-0034 i
L 1
i 398 .,
1 50.49 adequate to manage aging effects. And we went probing 2 and poking and stumbling through how 50.49 is managed today.
)
3 And the industry press reported the staff's efforts as being 4 rereviewing compliance with those regulatory requirements, 5 while we tried to characterize the nature of our inquiry as 6 a review of the adequacy of the aging management aspects of 7 50 8 And so thare is, you know, we're set up in a 9 situation where asking questions about the adequacy of 10 programs to manage aging effects infers a challenge to the 11 Current licensing basis. And I think that the Commission '
12 intended that we should, you know, challenge these existing !
l 13 programs. But then you can also read the language in the 14 statements and consideration about the adequacy of the COB
[J i 15 and its ability to carry forward as one about not 16 duplicating compliance reviews, not challenging existing 17 programs.
18 And at the risk of --
I don't want to contradict 19 Dr. Seale, but the numbers that BG&E reported are counts of 20 individual procedures, activities, and programs. So they 21 get a very large number. l l
22 DR. SEALE: Yes, that's right.
23 MR. GRIMES: For statistical purposes. Three 24 hundred twenty-nine procedures that are relied upon for 25 aging management were deemed adequate as is; 101 procedures
('"3 ANN RILEY & ASSOCIATES, LTD.
s ,)
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
399 1 or programs were modified in some shape, way, or form, in
(y 2 order to address aging effects for all of the applicable V-3 passive long-lived systems, structures, and components. And 4 16 programs were new. And so if the intent of our 5 mission --
6 DR. SEALE: Something was incorrect. That's easy.
7 MR. GRIMES: For me the dialogue has now gone on j
8 for four months, and they're burned into my brain.
9 [ Laughter.)-
10 DR. SEALE: I bet they are.
11 MR. GRIMES: There is a different set of
.12 statistics for oconee, which counts things in program l 13 measures that get up into the couple dozen. But we're still 14 talking about an impact to the license renewal that affects
() 15 16 25 to 30 percent of activities, whatever those things are, and trying to characterize that in terms of what should the
- 17. threshold be in order to effect a change, and to what extent 18 should the NRC staff review challenge those decisions is the 19 fundamental policy issue that we need to rectify.
20 At the same time, as Dr. Apostolakis points out, 21 there is this concern about if we push too hard, if we say 22 that the '95 amendment to the rule was a mistake in some 23 way, if we are not careful how we characterize the nature of
-24 the resolution of this controversy, then there is a real 25 fear that there are utilities out there who are sitting on I
s ANN RILEY & ASSOCIATES, LTD.
c Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
400 1 the fence that might not pursue license renewal because of a 2 concern about lack of stability and regulatory control that 3 might otherwise continued to operate their plants, and that
.4 is.a real: concern, so we are not trying to overblow this 5 issue. At the same time, we are not trying to underestimate 6 its importance.
7 My view is that we will continue to keep the 8 committee informed, but I think that the Staff and NEI first 9 need to present the issue to the Commission and let the 10 Commission help us sort out what is the fundamental question 11 and the policy issue that needs to be addressed and then 12 thereafter we will come back and ask the ACRS to review the 13 case as it was presented by the Staff and NEI, and then you 14 can present your views to the Commission and we will let
() 15 them know that you are doing that in such a way that their 16 decision is timed to consider your input.
17 DR. SEALE: Okay. You are talking about this 18 being on the 12th of. July?
19 MR. GRIMES: The week of the 12th of July.
20 DR. SEALE: In your schedule --
21 MR. GRIMES: That's correct.
22 DR. SEALE: Well, it turns out that is the week of 23 our July meeting and then we don't have a meeting in August, 24 so if you wanted to come to see us in the latter part of 25 July, then it would be the first of September, roughly, when f^)
(m/
ANN'RILEY & ASSOCIATES, LTD.
Court Reporters ,
1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 j (202) 842-0034 '
l
I 401 1 we could give you some feedback.
- 2 Is that sequence doable?
}
3 MR. GRIMES: It seems doable to me. We would 4 probably argue before the Commission that this is a moot 5 issue for Calvert Cliffs and Oconee because we did the job 6 we felt'we needed to do and we exercised that term 7 " demonstrate" to its fullest extent, and we hope that you 8 will agree with us after you have reviewed the Oconee safety ,
l 9 evaluation, unless this is an issue that really applies to '
10 the next two applicants in terms of both the scope and depth 11 of the material that they would cover in their application 12 and the scope and depth of our review, but we will -- you j 13 know, we will relay the scheduling aspects to the Office of 14 the Secretary and then let them sort out the schedule with
,em i
( ) 15 the Commissioners.
- 16. DR. SEALE: Well, I would assume that -- well, let 17 me ask.you. !
18 Do you believe that it would be appropriate for us 19 to try to have a subcommittee meeting to get the overall 20 full and fruity feedback review on, the story on what you 21 have presented to the Commissioners and any at least initial 22 feedback as to what their comments might have been, and then 23 plan to have a presentation to the committee in the 24 September meeting?
25 MR. GRIMES: I think that would be a useful thing
,O ANN RILEY & ASSOCIATES, LTD.
\ ,/
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
402 l' to do.
2 As I said, it would depend in part on how the i
3 meeting with the Commission goes, because it could be that l 4 we -- that that dialogue may end up fully reviewing what the t 1
5 nature of this disagreement is and we find we are not as we 1
) 6 thought we were, but on the other hand, it would have been i
7 nice for me -- my druther would have been wish we could have 8 practiced on you first before we go to the Commission.
9 (Laughter.)
l 10 MR. GRIMES: But it doesn't look like it is going i
11 to work out that way, but I think it would be useful to l 12 schedule the subcommittee and if it turns out we don't have 13 as much to talk about on this particular issue then we could i 14 carry it forward and talk about the ramifications to II V
15 improvements in the Standard Review Plan. You have lots of j i
16 opportunity here.
I 17 DR. POWERS: You don't want to try to do something 18 actually in the July meeting then?
19 DR. SEALE: It doesn't appear that you are going
-20 to be in a position to give us much to do. If they came up 21 with-something that would give us a July meeting goal that 22 could really satisfy their needs, I think we could certainly 23 work towards that.
24 DR. POWERS: Yes. I was just going to say that as 25 you move forward, then you find that it would be convenient l ANN RILEY & ASSOCIATES, LTD.
i /)s A, Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
1
403
( 1 for-you to do something in July rather than waiting for
,q 2 September, we.will maintain schedule flexibility on this
) 3 issue to meet your needs as well.
4 DR. SEALE: Yes.
5 MR. GRIMES: I appreciate that.
6 DR. POWERS: It is a thorny issue and it has -- we 7 have a little different charter in this regard than maybe 8- the Commission does, charged for looking at technical 9 adequacy on this, in our statutory response. We have 10 another charter to advise the Commission, and we have to 11 address both of them in regard to this issue because I think
-12 it is intriguing.
13 MR. GRIMES: We agree. We appreciate that, and we 14 think that the ACRS views on this controversy are important ;
/~~
(Tj. 15' and can assist us. Obviously, we think you will agree with I
16 us, but at the same time you have pointed out that there are
~
I 17 probably areas of the Staff review that are not worth the 18 effort and there are areas of the Staff review that probably 19 aren't deep enough, and so this gets right to the heart of H2 O that question because it is basically a question about the 21 scope and depth of the Staff evaluation.
22 DR. POWERS: Sure.
23 MR. GRIMES: At least now I finally came to 24 -understand how Corbin McNeil could figure six months to 25 complete a licence renewal review after I read the March
("N- ANN RILEY & ASSOCIATES, LTD.
() Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
404 l 1 letter from NEI -- because if you take NEI's explanation j'") 2 about carrying the current licensing basis forward to an V
-3 extreme, then using the statistics from BG&E we only look at 4 16 things out of 436, which makes the review very simple.
5_ But in fairness, I think NEI needs an opportunity 6 to clarify what they meant in their letters, because we find 7 some inconsistencies in their explanation about what they 8 viewed as the issue and it's hard for us to understand.
9 Before I forget again, Doug Walters expressed his 10 regrets. There is an NEI workshop on design basis that is 11 being held right now, and they weren't able to attend this 12 session and they fully expect that there would be more 13- dialogue on this topic, and so I am trying to represent 14- NEI's perspective as best I can.
b)
[' 15 DR. POWERS: That just adds fuel to your idea of a 16 subcommittee, it seems to me, because we're certainly going
)
1 17 to understand all the nuances, and that takes more time. ~
18 DR. SEALE: Yes. We certainly need to offer them 19 the opportunity to bring their own soapbox.
20 Any other comments? Mario, would you have any 21 comments?
22 DR. BONACA: I just had a question regarding the 23 March 24th letter from Bill Travers on this issue.
24 There is an example there being provided regarding i 25 the-Staff found that the ASME Section 11 Code doesn't i
i p
.q,)
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034
~
405
- 1. address certain areas such as cracking of less than four 2 inch diameter reactor coolant system piping and so on.
3- Okay.
4 Well, that is important data to cover but wouldn't 5' that consideration be applied also for operating plants 6 irrespective of the license renewal process?
7 MR. GRIMES: And in fact there is an explanation 8 about how that matter is being pursued for operating plants 9 and_it gets bach to an interesting regulatory process 10 concern, and t. hat is for these issues, these questions that 11 have been raised that have aging management implications for 12 which we have no fully developed generic safety issue or 13- task action plan that plots a future course, if there is a 14 question that is lingering out there that has an aging 15
{) management implication, is it fair for the NRC Staff to 16 raise that question as an adequacy of aging management for 17 the purpose of license renewal when we still haven't decided 18 how we are going to proceed to address the issue for the 19 current plants.
20 That is the small bore piping issue that we refer 21 to as here is an example of where First Forty hasn't even 22 gotten the issue off the ground yet for which there is an l 23 aging management' issue. You have heard the other extreme of 24 that. example, which is the fully-developed generic safety-25 issue 190 on fatigue, where we manage to come up with a j i
j' ' ANN RILEY & ASSOCIATES, LTD. ;
J\
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 I (202) 842-0034 i
6 i
I 406 L 1 plant-specific way to address the issue pending a generic
{} 2 resolution of the GSI and then we have a series of examples 3 of everything in between and beyond.
4 EQ is an_ example of one that is beyond. We found 5 .nothing needed to be added to the program. But then there 6 are other questions about things like monitoring buried 7 piping for which it's not even an issue for current 8 operating plants, but it is an aging management question.
9 So we fully expect that at both the Commission 10 briefing and the ACRS Subcommittee meeting both the staff 11 and NEI.would be prepared with their examples to illustrate 12 the two sides.
13 DR. SEALE: And I can certainly anticipate a lot 14 of questions from the committee on exactly these issues.
(m) 15 Any other comments? Bill, do you have any?
16 DR. SHACK: No. Thank you.
17 DR. SEALE: George.
18 DR. APOSTOLAKIS: No, I have some crazy thoughts.
19 Could one use -- this is an entirely different subject.
20 Could one, in the name of regulatory stability, if you don't 21 'want to touch 54, I wonder whether one could use 1.174, 22 before the 40 years expire, to change the licensing basis 23 and them demonstrate according to 54 that you meet it for i 24 the next -- 1 25 MR. GRIMES: Sure. )
i l
l
,/~] ANN RILEY & ASSOCIATES, LTD. j
\m/ Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 i
407 1 DR. POWERS: I don't see why not.
I \ 2 MR. GRIMES: We fully --
d 3 DR. APOSTOLAKIS: But how would you do that? I 4 mean --
5 MR. GRIMES: Well, wo fully expect that plants --
6 the later plants, as a matter of fact, Arkansas, which will 7 be in the next license renewal application, is going to 8 refer to their ISI program for a lot of the aging 9 management.
10 DR. SEALE: It is a pilot, 11 MR. GRIMES: And they will have --
12 DR. APOSTOLAKIS: Components though. No , IS1, I'm 13 sorry.
14 MR. GRIMES: ISI applies -- ISI is relied on
() 13 extensively for aging management and piping and pressure l 16 boundary. And they will have a risk-informed ISI program, 17 and then we will be asked to judge the adequacy of aging 18 management for all of the -- for the whole scope of pressure 19 boundary that is covered by ISI.
20 DR. APOSTOLAKIS: So risk information can be l 21 injected.
22 MR. GRIMES: Sure.
23 DR. KRESS: But your idea was to fix all the 24 current plants before they get to license renewal and just 25 keep the license renewal stay _ rule as it is.
(O ANN RILEY & ASSOCIATES, LTD.
(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r-408 1 DR. APOSTOLAKIS: Well, yeah, 54 refers to the
( ) 2 current licensing basis.
3 DR, KRESS: That is an intriguing thought, yeah.
4 Right. Let's make them change the current --
5 DR. APOSTOLAKIS: Change the current licensing 6 basis.
7 DR. KRESS: That is an intriguing thought.
8 DR. APOSTOLAKIS: In other words, it comes back to 9 something that is similar to the 50.59 debate.
10 MR. GRIMES: Sure.
11 DR. KRESS: We would still have to --
12 DR. APOSTOLAKIS: Can you go and argue on the 13' basis of 1.174 that you can reduce your safety margin, you 14 know, some components, passive components and so on, by some I 15 delta X?
16 DR. SEALE: Small delta.
17 DR. APOSTOLAKIS: Even though you have not reduced 18 it yet. And then come the license renewal and say, look, 19 this aging mechanism will deteriorate this thing and at it 20 the end of 20 years, it will still be within the delta X you 21 have already approved.
22 DR. KRESS: The problem is 1.174 does not give you 23 title to do that. It is strictly written for licensees 24 coming in with requested changes to their licensing basis.
25 It doesn't give an RC the power to make any requested ANN RILEY & ASSOCIATES, LTD.
v) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Wachington, D C. 20036 (202) 842-0034
l' l
409 1 changes.
' /~') 2 DR. SEALE: You don't get a blank check.
V 3 DR. KRESS: You don't get a blank check with it.
4 But the idea --
5 DR. APOSTOLAKIS: But it will be specific. ;
6 DR. KRESS: Yeah, but it is not --
there is no 7 licensee who is going to come in with this request. It is 8 going to' originate from the NRC and they can't originate it.
9 DR. SEALE: Obviously, we need a subcommittee 10 meeting.
11 DR. KRESS: Yes.
12 DR. SEALE.: I am sure you have heard most of these 13 arguments before.
14 DR. APOSTOLAKIS: I was hoping they were original.
() 15 DR. SEALE: But thank you very much. Is there 16 anything else you want to tell us at this point?
17 MR. GRIMES: I can tell you that amongst our ;
18' inventory of generic renewal issues, which you can certainly 19 contribute to, because everybody gets to give us their good 20 ideas, one of those issues is how to do risk-informed 21 license renewal, you know, with a vision towards how does --
22 what role does the PRA play in identifying either scoping, 23 the plausibility of aging effects, or the effectiveness of 24- aging management.
25 DR. APOSTOLAKIS: Is there room, though, in the O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L 410 1 current regulation for this? And I will tell you why I am
() 2' 3
asking. I have been talking for the last maybe couple of years to people, you know, it was not a systematic survey, 4 but around the world about -- and also in this country, 5 about probabilistic methods for aging mechanisms and 6 including them aging assessments and so on, PRA, including 7 them in PRA. I would say that all, most if not all of the 8 people I talked to said, yeah, but there is no reason to do 9 that because the license renewal rule is not going to use 10 any of that.
11 So that, the existence of the present rule has 12 discouraged the development of methods of the thinking as to I 13 how risk information could be used in that, because right 14 now people'are not spending money on research just to (n; 15 advance the state of the art, they want to see a goal. So 16 perhaps we are creating a chicken and an egg here, you know.
17 The rule says don't use PRA, or it does not exclude -- it 18 doesn't say that, but, you know, it does not encourage it.
19 Therefore, there is no work on PRA and how it could be used 20 for these kinds of issues.
21 Then we come back to the rule and say, well, gee, 22 how can we use risk information? We look at the state of 23 the art, it is not.very good. And, you know, that is not a 24 healthy situation.
25 MR. GRIMES: I am sure that if I am not -- if I O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
411 1 don't do'this correctly, I am going to get hit in the back 2 of the head with a shoe.
3' DR. POWERS: I am kind of hoping you do it poorly, 4 I would like to see this. .
5 MR. GRIMES: I noticed Mark was sitting behind me.
6 In fact, at the same time the Commission acknowledged that 7- the license renewal rule is predominantly deterministic and 8 is founded on the concepts of defense-in-depth, there is 9 language in the Statements of Consideration that says risk 10 insights can be useful to making determinations about the 11 effectiveness of aging management. So it contemplated it.
12 I would assume from the relative timing of the 13 construction of the Statements of Consideration in 1995 14 relative to the struggle that we were going through at that 15 point to try and develop Reg. Guide 1.174, its predecessors, 16 and at that I was working on risk-informed tech specs, I 17 imagine that we didn't want to go too far in speculating 18 about how that would be done until we had a better about 19 integrated risk control, which is still an issue, you know, 20 in Reg. Guide 1.174 space as to how many little bites can 21 you take-before you have gone too far.
22 And so I think that we have not tried to 23' discourage the use of risk insights, we have just been 24L reluctant'to extend them too far into the design basis. And 25 I think that we can envision a rule change, after we have j i
[~N ANN RILEY'& ASSOCIATES, LTD.
\ Court Reporters ;
1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034
412 1 gotten through a few of the license renewals, when both the (
1
() 2~
aging management aspects and research in that area, along 3 with the potential for developing PRAs in the future can 4 actually measure risk of aging.
5 You are correct, there is a reluctance to try and !
6 spend money on developing those tools if'there isn't i 7 somebody that says how they are going to get a benefit from 8 that, i
1 9 DR. SEALE: But your perception is that the 10 existing rule is permissive rather than prohibitive?
11 MR. GRIMES: That's correct. Because when we look 12 at the language that says demonstrated effectiveness, and 13 you look in the Statements of Consideration, and it says 14 risk insights can be used to make those judgments, we view
() 15 that as an area that could be explored on an 16 effect-specific, component-specific basis, not, as the 17 language in the Statements of Consideration points out, not 18 on wholesale change considerations.
19 DR. APOSTOLAKIS: So you may not even then have to 1
20 change the rule, because if the rule is permissive, you can 2
.1 issue a Regulatory Guide that says, well, here is a way to ;
22 do it.
23 MR. GRIMES: That's correct.
24 DR. APOSTOLAKIS: And that is much easier.
25 DR. POWERS: I am willing to bet that after you O
ANN RILEY & ASSOCIATES, LTD.
(~/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
c 413 i
L 1 have gone through a few of these and get a feeling on how
(
2 license renewal input, that you will indeed get as many 3 applications as some of the upper estimates. But if you 4 don't go risk-informed, the agency won't be able to respond 5' quite as fast.
6 DR. SEALE: 'It will drive you out of your mind.
7 DR. POWERS: Well, it will just swamp the system.
8 DR. SEALE: Sure, that is what I mean.
9 DR. POWERS: That, in fact, if the agency doesn't 10 . focus its attention in some way, and the only rational way I 11 know of is based on risk, they won't be able to process all 12 of them. And I think it is inevitable that we go 13 risk-informed here, just because the workload is excessive.
14 MR. GRIMES: No, we agree because we see (O,/ 15 tremendous efficiencies that can be gained by making smart 16 samples in the review process. And at the same time we 17 cxpect that you are going to be challenging us to have a 18 fully developed technical basis to defend the findings and 19 that is where we will have an interchange that I think will 20 be very constructive in terms of where do you think the 21 staff should be focusing its efforts, and where can we be 22- using more generic findings relative to the adequacy of 23 aging management programs.
24' DR. POWERS: I think you certainly saw in the 25 before lunch session that our lists are going in that l-s ANN RILEY & ASSOCIATES, LTD. l Ts Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034 1
I
V: \
L l I- l l
414 l' direction, but I think, in contrast to what I thought going
() 2 3
into this, it is going to be as a result of the initial applications rather than prior to them. We are learning as 4 .much from the initial applications as you are, as the 5 licensees are,.as the public is. I think it is going to be 6 coming out of that. We had all better learn some lessons or 7 we will drown in this.
8 MR. GRIMES: That's correct.
9 DR. SEALE: Well, I must say that while I am sorry 10 you weren't necessarily able to give us the full story, we 11 certainly appreciate your update. I think we are in a lot 12 better position to understand exactly where you stand, and 13 also to anticipate what it is that we are going to have to 14 do in order to be responsive. We agree that this is a
() 15 ' critical item and we don't want to be on the critical path.
16 So anything you can do to give us a hi-sign to get 17 up into'the process earlier than otherwise thought, let us 18 know. Of course, Noel is your contact on that.
19 And with that, Mr. Chairman, I'll hand it back to 20 you and we saved some time.
21 Thanks, Chris.
22 DR. POWERS: I'll just remind Chris that we are 23 committed to this process and that you can count on us for 24 flexibility in accommodating your needs. So don't feel like l
25 you're imposing on us.
l
/O- ANN RILEY & ASSOCIATES, L'ID .
(_) Court Reporters 7
1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 I
l u
415 1 MR. GRIMES: And I appreciate that. And as soon
/~'N 2 as we get. feedback from -- we're also asking the Commission U
3 to approve immediate release of the paper so that whatever 4 other constructive dialogue we can accomplish before the 5 Commission meet'ing, we'll try to --
6 DR. POWERS: Very good.
7 MR. GRIMES: We'll try to do that, and we'll work 8 through Noel ~to make sure that we make the most effective 9 use of your time and schedule.
10 DR. POWERS: That's very good, and we'll be as 11 flexible as we can.
12 I want to go off the record now.
13 [ Discussion off the record.]
14 DR. POWERS: Let's get come back into session and
() 15 continue with the Mario Bonaca show. What we have now is 16 .the proposed resolution of Generic Safety Issue 165 that has j 17 to do with the spring-actuated safety and relief valve 18 reliability, and Mario, you are the cognizant member of the 19 committee, and I guess if your voice holds out, you will 20 lead us.in this discussion.
21 DR. BONACA: I think my voice will do.
22 We have now the Staff here to -- you may remember !
I 23 the last meeting a question was raised regarding the j l
24 applicability of the sample used in the INEL study to all j 25 the other plants in the U.S. and the Staff went back and
\ ANN RILEY & ASSOCIATES, LTD.
Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 841-0034
p I
I 416 l.
1 performed a significant review of a large number of units,
/"'% 2- and they are ready here to report on that specific question.
- -V 3 I believe that was the main question that the ACRS raised at 4 that time, so I will let the Staff go to their presentation.
5 ,DR. POWERS: Well, I certainly hope we will l
l 6 . discuss the whole resolution. The sampling was simply the h
{
7 Achilles heel that I saw in the draft proposed resolution, 1
8 so there's more. j l
9 DR. BONACA: That's right, and I understand the j 10 presentation is covering the whole issue.
11 MR. GORMLEY: Okay. We have the viewgraph package 12 assembled to discuss the whole issue, so if that's all 13 right, we can proceed in that thing, and Mr. Cherny will --
14 MR. CRAIG: Before we get started -- John Craig, l
I) 15 the Director of the Division of Engineering Technology.
16 Owen has been the Project Manager on this issue for awhile.
17 Frank Cherny has some expertise in the A'3ME code and we have i
18 a number of support help here from NRR also that we have 19 been warking with on this issue that involves four-inch 20 spring-operated valves.
21 When the issue was identifled as a result of an 22? event at Shearon-Harris, and we will talk about that a 23 little bit, the Staff did a prioritization and the 24 resolution of the issue at that time was going to be some 25 changes in surveillance, and what you will hear in a few
/}
v-ANN RILEY & ASSOCIATES, LTD.
Court Repcrters 1025 Connecticut Avenue, NW, Suite 1014
' Washington, D C. 20036 (202) 842-0034
417 1 minutes are that the surveillance that the Staff thought
] 2 sould be appropriate to address this issue has been 3 incorporated in the ASME code and it has been implemented in 4- all but, I believe, seven plants, and it will be implemented 5 in the remaining seven plants in I believe the next 6 refueling outage, and you will hear a little bit more about 7 that.
8 Had the ASME not revised the code and the plants 9 not implemented those changes, the Staff would have gone to 10 _ great lengths to, I assume, support a cost beneficial safety 11 enhancement that would have in fact gone forward to require 12 exactly or in large part what the ASME code has already 13 done.
14 In addition to that, we will have part of the '
() 15 presentation,.and Owen will give some insights that we got I 16 from looking at different plant types, et cetera, to look at I
17 the valves, some LER searches and other things, to talk a )
18' little bit about the performance of the spring-operated 19 valves.
20 With that, I will turn it over to Frank Cherny, 21- who will start the presentation. Thank you.
22 DR. POWERS: The bottom line is we essentially --
23 this issue-is basically resolved through an ASME 24 modification.
25 MR. CRAIG: Yes.
1
("'s ANN RILEY-& ASSOCIATES, LTD.
(s,_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
418 1 DR. POWERS: Okay. Good.
!/~~T 2 MR. CHERNY: Good afternoon. I am going to talk a
\_/
3 little bit about the scope of GSI-165, why we got into 4 prioritizing it in the first place, a little bit of 5 background on the so-called Shearon-Harris event, which I 6 guess was the primary motivator for prioritizing the issue, 7
talk a little bit about the ASME code surveillance 8 requirements which are gradually being implemented on all 9 the plants in the country, which we have finally concluded 10 are adequate resolution for this issue.
11 With that brief introduction, before we ever heard 12 of GSI-165 the Staff had known that there had been numerous 13 problems over the years with set point drift on safety 14 relief valves leakage problems, occasionally a stuck-open
\
( ,/ 15 valve, and there had been a number of generic activities and 16 generic issues over the years that have addressed those 17 types of concerns on the large primary system safety and 18 safety relief valves and the main steam safety valves on 19 PWRs, so this issue does not have within its scope any of 20 those.
21 John mentioned the four inch size. That is kind 22 of a nominal cut-off size. What we are saying is four 23 inches and less, and those are, generally speaking, the 24 relief valves that are installed primarily for overpressure 25 protection purposes on safety-related support systems.
l l ANN RILEY & ASSOCIATES, LTD.
\s /)
i Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
419 1 The reason we got involved in prioritizing GSI-165
~'\ 2 in the first place, the so-called Shearon-Harris event was
[V 3 kind of'the catalyst for that, I guess. We completed the 4 prioritization of this issue in November of 1993 but the 5 Shearon-Harris event took place around April of 1991 and 6 involved severely degraded pressure relief valves which if 7 they had been asked to perform their function at the wrong 8 point in time a significant amount of high-pressure 9 injection flow would have bypassed the reactor vessel and 10 gone out these relief' valves.
11 I guess we have a viewgraph here of the 12 Shearon-Harris configuration. Let me put that up.
13 I'm not going to try and pretend to be an expert 14 on the safety 1 injection system at Shearon Harris, but just
() 15 to set the stage for how we got into this situation in terms 16 of the prioritization.
17 The Shearon Harris folks and a few other plants 18 installed what is termed this configuration down here, which I 19 is an ultimate minimum flow configuration, which was 20 installed to prevent the three convection problems, which 21 are the same as the charging problems at most Westinghouse 22_ three-loop plants, from going into a deadhead operation i
23 situation on certain kinds of small-break LOCA situations. j 24 During normal plant operation this valve and this valve are 25 open and provide mini-flow function for the pumps during O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 420 1 ' normal charging service. When you have a safety injection
., 2- system, those two valves isolate, and these two valves down 3 here open and provide access to these two relief valves.
4 Now I should say that that's the way the Shearon 5 Harris configuration used to be. In April of 1991 there was 6 a failure ~of a leakoff line right next to one of those two 7 . relief valves, the three-quarter-inch line. Subsequent
'8 plant inspections found that not only was there a failure in 9 that line, but that these two relief alves were seriously 10 degraded, so much so that if the syste.m had been called upon 11 for a certain type of event, the system would not have been 12 able to provide anywhere near its FSAR required design --
13 DR. WALLIS: You mean it was stuck? What does 14 l " degraded" mean?
'15 MR. CHERNY: One valve had a severely cracked 16 . spring in it'and was -- both valves had been obviously 17' subjected to --
18 DR. WALLIS: So they would have opened at too low 19 a pressure or something?
20 MR. CHERNY: They both would have opened at too 21 low a pressure, and they would have, you know, the pump flow ;
22 would have gone up the valves rather than into the core. '
23 That's the basic message.
24 NRR subsequently investigated and found that there
-25 were about six other plants in the country that had similar
/7 ANN RILEY & ASSOCIATES, LTD.
b Court Reporters l
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 421 1 configurations. I 2 DR. WALLIS: There's no way the operators would f~'.)\
3 know that and close those other valves in series? ICS 752.
4 MR. CHERNY: Well, I guess there are certain l
5 indications it the control room that would give you an 6 indication. The two relief valves in question relieved to 7 the refueling vater storage tank, okay? That's where the 8 flow would go out.
9 DR. WALLIS: I think there should be some 10 indication.
11 MR. CRAIG: There's certainly level indication and 12 alarms in the reactor water storage tank, and as it got l
13 high, they would certainly get that. There are also some 14 charging flow lines that give you charging flow rates, and I (O 15
~
j think it's pretty straightforward that they would be able to 16 tell the water was being diverted.
17 MR. CHERNY: Subsequently what happened at'Shearon 18 Harris was the two relief valves that are shown here were 19 replaced with flow orifice limiting devices rather than 20 valves. The other plants that had similar configurations 21 for one thing had much smaller relief valves than what were 22 being used on Shearon Harris, and through a combination of J
23 increased surveillance and inspections, they were able to 24 resolve any remaining concerns on those. So this particular 25 configuration that started the concerns for GSI-165 really l
['
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
IT l 422 1- has been eliminated, is not a concern specifically on any of
'(9
%)
' 2' .the plants.
3 However, the concern about diversion of flow 4 through these auxiliary-type relief valves motivated the 5 prioritization of GSI 165 in the first place. As far as the 6 -- I can put-this up. I think we've talked about most of 7 this'already. That's the wrong viewgraph; this one.
8 MR. GORMLEY: Which one? This one?
9 MR. CHERNY: No, where's the Shearon Harris 10~ viewgraph?
11 MR. GORMLEY: That's the first one.
12 MR. CHERNY: .There was an information notice that 13 was sent out in August of 1992, Information Notice 92-61, 14 and subsequently there was a supplement to that information
() 15 notice which was sent out in November of 1992. The 16 supplement did in fact show the modified configuration with 17 flow orifice devices on it. And as I said before, the 18 plants that had similar. configurations have implemented 19 various kinds of changes to correct those concerns. #
2 0_~ That's all I really intend to say about Shearon i 21 Harris per se.
22 Just repeating slightly, the relief valves thus 23 that are in the scope of GSI 165 are the small J
24 spring-operated relief valves less than four inches in size. I 25 When we prioritized this issue, there were two key i
l i,
('}
v ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)-842-0034
l 423 1 assumptions that resulted in this issue coming out as a
( _2 high-priority issue. There was one assumption that was made l 3 that the relief valves -- that 10 percent of the relief 1 i
4 valves installed on safety-related support systems had the 5 relief capability to fail their trans. That's a fairly high
-6 number. That's what was assumed. That was a judgment call.
7 A fair. number of, systems and PRA people were involved in-8 those discussions, but at the time of the prioritization, a 9 lot of resources weren't spent on studying P& ids and FSARs 10 .and things like that. So we made that 10 percent 11- assumption. I 12 The other thing that was done was we made an j 13 assumption that an increased testing frequency somewhat in 14 excess of what was about to be implemented in 10 CFR ,
A Q 15- 50.55(a), that slightly increased testing frequency for 16 testing that could be easily and economically performed at 17 the plant sites could be performed on a small set of 18 high-safety-significant relief valves to resolve this issue.
i 19 Now just about at the time that we were sitt'ing 20 down to prioritize the issue, there was a revision made to 21 10 CFR 50.55(a). I think it became effective in September ;
22 of 1992. And it for the first time required through the 23 120-month update process, something.that you all are rather 24 familiar with from a' briefing not too long ago, required 25 that gradually the plants implement new ASME code testing O ANN RILEY & ASSOCIATES, LTD.
b Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 424 l' requirements for these types of valves. That revision of
/mT 2
- 50. 55 (a) endorsed for the first time in the 1989 edition of QJ 3 ASME section 11, that revision of section 11 endorsed an 4 ASME O&M testing standard, Part 1 of ANSI ASME OM 1987, 5 which for the first time has testing requirements in it for 6 these. types of valves.
7 And just to describe briefly what they involve, it 8 requires you to test as a minimum set pressure test, leakage 9 tests, and good visual inspection a minimum of once every 10 ten years, which isn't a fairly high frequency, but there's 11 an additional requirement. You're supposed to group these 12 valves in accordance with manufacturer and model number 13 types, and you're supposed to test a minimum of 20 percent 14 of valves in such a grouping every four years. So if you
() 15 have -- what really happens is if you have small numbers of 16 valves in the groups, they really get tested more often than 17 once every ten years when you actually try and apply the I 18 code.
19 What we had assumed when we did the prioritization 20 was we said well, they've got this once-every-ten-year test 21 requirement that's just coming into play. Supposing we have 22 a couple really risk-significant relief valves that we find 23 as we go about doing our study, what would be a good testing 24 frequency. And I think what we used at that time was we 25 said well, we'll go from once every ten years to once a I)
(/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
425 1 year. So that's sort of what was used as the model for the 2 prioritization.
3 DR. WALLIS: Well, the original -- excuse me, the 4 original problem at-Shearon Harris was thought to be the 5 result of ECCS testing.
6 MR. CHERNY: That's correct.
7 DR. WALLIS: Testing actually was the cause of 8 degrading the valve.
9 MR. CHERNY: In a sense. They had a very strange 10 configuration there, though, too. They had a situation 11 where they had -- they were subject to a lot of water 12 hammers when those valves actuated, they had trapped air 13 pockets in downstream and upstream piping.
14 DR. WALLIS: So it was --
/~~
15 MR. CHERNY: But you're right, the testing 16 actually instigated those failures, but so did the design.
17 "R. WAIX 7S : So this is another case of water 18 hammer.
19 MR. CHERNY: That was -- at Shearon Harris it was 20 a water hammer, severe water hammer problem.
21 The ASME code requirements --
22 DR. WALLIS: So the real cure is to prevent the 23 water hammers. The first action would be if you're going to 24 have valves like this, make sure that there aren't any 25 _ potentials for water hammer in the line.
t ANN RILEY & ASSOCIATES, LTD.
( L Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t .l
i 426 1 MR. CHERNY:
Um-hum. There are other valves that
() , 2, 3'
over the years have -- relief valves that have been prone to water hammer problems. I think the most famous-one is the 4 case of some of-the PWR pressurizer safety valves that have 5 purposely installed water slugs in the inlet piping to the 6 valves. And as a result of a TMI action plan item, the 7 design of all of those configurations was revisited right 8 after the'TMI 2 accident, and additional piping supports I 9 were put in, valve qualifications were performed, and those 10 were'-- believe me, those were fixed for a lot of money, but 11 they're fixed.
12 With regard to the ASME code requirements that 13 became effective in that rulemaking in September of 1992, we 14 have gone through a number of years now and, as it turns
() 15 out, those code requirements have been implemented in most 16 of the plants in the country. There are about seven plants 17 left that are due to implement those new -- those 18 requirements at.their next refueling outages. After --
19 DR. WALLIS: I am still puzzled, I'm sorry. Why 20 do you test the valves when the cause of the problem is'the 21 waterhammer?
22 MR. CHERNY: Well, we are testing -- we'are 23 testing the whole population of valves, not just the Shearon 24 Harris.
25 DR. WALLIS: The cause of the problem at Shearon
,O) ANN RILEY & ASSOCIATES, LTD.
(m) Court Reporters 1025' Connecticut. Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
427 1 Harris was the waterhammer.
/~N 2- MR. CHERNY: Right. And they did a design change.
3 DR. WALLIS: Why did this lead to paying attention 4 to the valves? The valves could have been 100 percent 5 perfect in every way.
6 MR. CHERNY: Most of the valves are not installed 7 in those kind of configurations. That was a very strange 8 configuration that they had there. In addition, that was 9 not --
10 DR. WALLIS: It would seem to me the generic 11 safety issue is waterhammer, not valves.
12 MR. CHERNY: Now, as I said before, the Shearon 13 Harris problem was fixed before we ever really started doing 14 anything on the GSI. The concern about the GSI was whether
() 15 the failure of other relief valves and support systems could 16 defeat something like ECCS functions.
17 DR. WALLIS: Okay. So it is not just the valve, 18 it is the whole system and the way it behaves that you are 19 worried about .
20 MR. CHERNY: Right. Right. But the focus was on 21 the contribution from the relief valves, for this issue, 22 that is the scope of this issue. Okay.
23 DR. WALLIS: So there wasn't an issue on the 24 waterhammer?
25 MR. CHERNY: There was a separate waterhammer ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 m.
i l
428 1 issue some years ago, but that was not the scope of this
(%
2 issue.
'wI 3 DR. WALLIS: I am still not quite clear why this l 4 became a GSI at all, apart from the waterhammer.
5 MR. CHERNY: Shearon Harris did not become a GSI.
6 Shearon Harris was just a motivator to take a look at relief 7 valves and support systems, okay.
8 DR. WALLIS: Why?
9 MR. CHERNY: We do not need generic issue for 10 Shearon Harris. Shearon Harris was --
11 DR. WALLIS: So there was some other reason why 12 the valves became a generic safety issue? I 13 MR. CHERNY: People were concerned about the 14 number of LERs reporting all kinds of different kinds of
(,,) 15 valve problems.
16 DR. WALLIS: Other problems with valves.
17 MR. CHERNY: Release valves, ring adjustment 18 problems, set point drift problems, leakage problems.
19 DR. WALLIS: Other problems with valves. l 20 MR. CHERNY: Premature actuations of valves that 21 had nothing to do with waterhammers.
22 DR. WALLIS: Okay.
23 MR. CHERNY: And that is why the focus, too, was 24 on the ASME code testing for these kind of valves. Before 25 the September 1992 rulemaking, there was no requirements to
/~'; ANN RILEY & ASSOCIATES, LTD.
(_.) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 1
I 429 1 test these kind of valves at all, nobody had to do any. tests
'I'N 2- on them. With the putting in place of that rulemaking,
(, l l
3 surveillance. requirements for the first time on these kinds 4 of valves were put into place.
5 And as I was saying before, there are seven plants 6 left.in the. country that at their next refueling outages 7 will be implementing these requirements for the first time.
8 After those seven plants implement those requirements,-all 9 the plants in the country will be doing regular code 10 required surveillance testing on those types of valves.
11 What we have done as part of the resolution 12 process we have done some PRA work and some additional 13 deterministic work which has led to the conclusion that the 14 additional increase in frequency of testing that we
() 15 1 postulated when we did the original prioritization is no 16- longer necessary, and we have concluded that the 17 surveillance tests that are already in place with the l 18 September 1992 rulemaking are' adequate to address the GSI )
-19 165 concern.
20- And Owen is going to talk now a little bit about 21 some of.that additional work that was done to al' low us to 22 reach that: conclusion.
23 MR. GORMLEY: Okay. Thank you, Frank.
24' DR WALLIS: Well, one way is to fix the valves 25 and'make sure they are reliable. The other way is to make i
ANN RILEY & ASSOCIATES, LTD. {
/ . Court Reporters 1025. Connecticut-Avenue, NW, Suite 1014 Washington, D C. 20036 ,
(202) 842-0034 i I
l l
c 2N
430 1 sure that if they do fail, the operators know it and they
() 3 2 -have an action-which they can take to close some other valve or something.
4 MR. CHERNY: He is going to talk about some ot 5 that.
6 DR. WALLIS: About some of that.
7 MR.'GORMLEY: I am not going to talk about that.
8 I.think most of the systems have some kind of a flow i
l 9 measuring device, an orifice or have a tailpipe temperature 10 that tells them that the valve is passing flow. Now, my 11- recollection is that the tailpipe temperatures are not 12 alarmed, but we are relying on the operator to --
13 DR. WALLIS: Believe it. Was it TMI it had been !
14 leaking? j
. ,- 1 i 15 s j. MR. GORMLEY: Yeah, believe it or look for it.
16 DR. WALLIS: Believe it.
17- MR. GORMLEY: Yeah. Let's see, a bad thing
'18 happened here.
19 As you recall from our discussion last month, we 20 initially looked at five plants and found that in most of 21 the plants there were no valves that were of any concern at 22 all. We looked at one of the Combustion Engineering plants 23 and found a valve in it that seemed to be bigger than what 24 would b'e required for' simple thermal relief -- thermal 25 relief valves which are in there to comply with ASME code
[i
\s /
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
'431 1 requirements to protect dead legs of the plant, by far the
[)
\_/
2 majority of the valves that are used for this purpose, and 3 so we analyzed that additionally.
4
.What we found is that the valve has the capability 5- to directisomewhere between 30 and 50 percent of the l 6 available flow,' depending on what kind of assumptions you 7 make about how far the valve opens, what degree of 8 overpressure or accumulation you allow.
{
9 It isn't clear that that does not actually fail 10 the train and that is something that we need to keep in mind 11 as we go through this. In PRA space you only have the 12 option of it is failed or it isn't failed, but in fact in a 13 case that we just examined today if two valves fail, one.in 14 each train, the combined trains still provide enough flow to
- (D 15 keep the clad temperatures within acceptable limits.
(_j 16 DR. WALLIS: These are high pressure injection?
17- MR. GORMLEY: Yes. .Yes, so having the valve fail 18 completelyLopen is not -- doesn't actually constitute
.)
19 failure'of the train. We examined that train or we examined 20 -that' plant with a Sapphire analysis, and we found that ,
.21 having that valve. fail with an 8.6 percent failure rate 22- produces an acceptable CDF. I 23 DR. WALLIS: That is 8.6 percent of the times when 12 4- it is called upon to open --
25 MR. GORMLEY: No.
'T ANN RILEY & ASSOCIATES, LTD.
k'%.) Court Reporters:
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
432 1 DR. WALLIS: -- or it is challenged --
(}
V 2 MR. GORMLEY: That it fails -- prematurely opens 3 8.6 percent of the time after the pumps start.
4 DR. WALLIS: You took that calculation from the 5 acceptable increase to get 8.6?
6 MR. GORMLEY: No. This is a failure rate 7 calculated from the NPRDS.
8 DR. WALLIS: You had reasons to believe that 8.6 9 was the right number to use?
10 MR. GORMLEY: No, 8.6 is a number that we can 11 support technically. It is wildly over-conservative.
12 For these valves to have any effect on the 13 diversion of flow, they have to fail wide open. The failure 14 rate data contains results of all of these ASME tests where n
( ) 15 all you do is approach the set point and see if the valve
%J I
16 cracks open. '
17 Where we looked at the LER data, we'll come to l
18 that but when we looked at the LER data, we didn't find any 19 circumstances where the valve springs broke -- also valve 20 springs would have to break in order for the valve to fly 21 wide open.
22 MR. CHERNY: Except for Shearon-Harris.
23 MR. GORMLEY: Well, yes, that's right.
24 DR. WALLIS: Was there a water hammer in these 25 lines in this CE plant?
[~' ANN RILEY & ASSOCIATES, LTD.
'(-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
433 1 MR. GORMLEY: Well, we didn't find any examples
/~\ 2 when we looked at the LERs.
3 DR. BONACA: So that CDF, really it is --
4 MR. GORMLEY: Probably two orders of magnitude too 5- high.
6 DR. BONACA: Well, that means that typically you 7 do a PRA to look at best estimate or as realistic as you 8 can, but this is really -- there is an assumption there that 9 is far from realistic.
10- MR. GORMLEY: And that is the problem. It is not
{
11 an assumption. (
It's a calculated value. l 12 DR. BONACA: That's because you haven't set a rate 13 for frequency of failure wide-open, therefore you assume the 14 very conservative number.
[)
V 15 MR. GORMLEY: It's the calculated rate that we 16 have data to support and unfortunately the data contains all 17 of these minor failures to meet or set-point drift failures.
18 DR. WALLIS: What_is the acceptable increase in !
19 CDF?
20 MR. GORMLEY: We have been going with 1.5 times 10 !
21- to the minus 5 -- sorry, one times 10 to the minus 5. I 22 DR. WALLIS: So if one had a price on this 23 increase in'CDF instead of just saying it is acceptable, it 24 might well be that we were spending the money to prevent it 25 happening.
O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
434 ;
1 MR. GORMLEY: We believe that the money is being 2 spent to prevent it from happening.
/~~]
LJ \
3 DR. WALLIS: Though it's acceptable, you are still j 4 spending the money?
5 MR. GORMLEY: Because ASME has invoked the 6 testing.
7 DR. BONACA: Still it gives me concern with using, 8 you know, that kind of failure rate when it is not really 9 applicable to the condition you are examining, because ;
10 assume that rather than getting six in 10 to the minur 6 you i
11 calculated two in 10 to the minus 5, and you may conclude l
12 that you have a generic issue while you don't have it.
13 MR. GORMLEY: Yes. Yes. Except in this case we i
14 concluded even though we were using the high rate, we
( ). 15 concluded we did not have a generic issue. If we had 16 concluded that we had a generic issue, then we would go back 17 to work. Probably the first place would be to go to work on 18 the failure data. I-_think that is the most productive area, 19 but it.is an. intangible that I wanted to bring to your 12 0 attention.
21- DR. BONACA: How far does the NPRDS database go?
22 I am trying to understand this.
I 23 MR. GORMLEY: Oh, we went back to, I believe, 1990 24 or 1989 when the additional testing requirements began to be 25 imposed and the data in the database improved.
/g1 ANN RILEY & ASSOCIATES, LTD.
'Q. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
435 1 DR. BONACA: Is there a case you may remember when 2 one of these failures occurred?
3 MR. GORMLEY: Well, that is the problem. You 4 can't find out. What we wanted to do was weed out all of 5 these minor set-point or seat leakage problems. There is 6 not enough information in there that allowed us to do that, 7 so --
8 OR. BONACA: So you are telling me that you cannot 9 find -- you cannot really quantify a failure rate for the 10 wide-open failure of these, so the failure rate is low as a 11 minimum --
12 MR. GORMLEY: It is very high. It is a very high 1
13 failure rate that we have used.
14 MR. CHERNY: Yes, but the failure rate he is
() 15 asking about is what is the failure rate for a seriously 16 failed condition --
17 DR. BONACA: Yes.
1G MR. CHERNY: And that is a number we don't have.
i 19 MR. GORMLEY: We have gone about that in a 20' different way. We tried to find valve spring failures and l 21 we didn't find any. I asked the manufacturer, a fellow who l 22 told me he worked there for 20 years and had not seen any 23' valve spring failures.
24 DR. BONACA: Okay.
25 MR. GORMLEY: There was a Braidwood LER that came T ANN RILEY & ASSOCIATES, LTD.
- s. ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
436 1 in after we had done this work. The incident occurred I
[)
V 2 think last year where they had an air cushioned water hammer 3 and the valve was only a 20 gallon a minute valve, but the 4 incident'was of interest to me because there was a
~5 deformation of the spring that took place. In that 6 particular instance, it lowered the set-point pressure by 7 about 10 percent, 5 to 10 percent actually.
8 In the case of these Conbustion Engineering 9 plants, the valves are set for about 2500 psi, and the pump 10 shutoff head for the HPSI is down in the 1200 to 1400 psi 11 range, so there would have to be a really significant 12 failure of the spring in order for the valve to fail open 13 prematurely.
14 DR. NALLIS: How do we get assurance that there
() 15 isn't goi.ng to be a waterhammer?
16 MR. GORMLEY: I don't know what the answer to that 17 question is. You ce.n be sure that it won't happen again at 18 Braidwood. They expended a great deal of energy, the whole 19 thing was.very mysterious to them. I 20' MR. IMBRO: Let me try and a little bit. I think I 21 that this is -- my understanding with the Shearon Harris, 22 the waterhammer was really a result of the valve chattering.
23 And as-Frank Cherny pointed out, the design at Shearon 24 . Harris was very unusual, where they actually use these l 26 relief valves in place of orifices, which most plants use ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 f
Washington, D.C. 20036 (202) 842-0034
~ __
437 1 for the mini-flow, for the pump mini-flow. So these valves
] 2 -basically were always called upon when the pump started to 3 lift somehow.
4 So, but what happened at Shearon Harris, as I 5 understand, is that they kind of set up a cyclical problem,
.6 where as the pressure increased, the valves opened up, and 7 then as soon as the pressure dropped, valves would close 8 again, and that was within the operating range of the pump.
9 So you set up kind of a chattering effect on this valve,.and 10 you had the fluid column moving back and forth which caused 11 the waterhammer.
12 So, again, the Shearon Harris is a very special, 13 special case because of the somewhat unusual design of the 14 system. So we would not really expect waterhammers to f
- 15 occur. Most of these valves we are talking about here are N. i 1
16 relief valves for overpressure protection from thermal 17 expansion and that type of thing, so,_really -- and they set !
18 usually 110 percent of the design pressure of the piping to '
19 protect the piping, and you never really see a situation j 20 with pump operation where you would lift these valves, or 1 21- very infrequently anyway, I will say that.
22 MR. SIEBER: Isn't it true, though, that when you j 23: have a configuration with a motor-operating valve followed 24 by a relief valve, that while,the motor-operated valve is 25 opening, you. create an orifice effect which makes the relief ANN RILEY & ASSOCIATES, LTD.
_ \]s -
Court Reporters
.1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
.(202) 842-0034
f 438 1 valve chatter? I know of applications --
/~'\ 2 MR. IMBRO: It is possible, I am sure.
D 3' MR. SIEBER: -- at some plants where it actually 4 will bend the stem, and then the valve with stick because 5 the stem is bent. And that is a design problem in 6 configuration.
7 MR. IMBRO: Right.
8 MR. SIEBER: The way the pipe is laid out. And 9 that sounds like what this is.
10 MR. IMBRO: Yeah. Again, you know, the Shearon 11 Harris thing was very unusual. I have never really seen any 12 other examples of that type of situation, although they say 13 there are a few others out there like that. But, again, 14 that was the focus of the generic issue was not so much the
() 15 16
-issue as to Shearon. Harris, but basically, given that we had a valve -- a failure of a relief valve, was to look more 17 broadly at relief valves used in systems to determine 1
18 whether or not a failure, any type -- you know, caused by !
19 anything, waterhammer or whatever, would really result in 20 the ECCS system or a system not being able to perform a 21 safety function.
- 22. That was really -- the focus wasn't on the 23- waterhammer or the specific event that Shearon Harris, but 24 was really on the focus of let's look at the safety valves 25 less than four inches and see whether or not -- if one of
(g ANN RILEY & ASSOCIATES, LTD.
\J Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r l
439 l
1 those would fail or could be somehow degraded, would this i
! /~'\ 2 create a situation where the ECCS, or whatever system it is b
3 in, would not perform its safety function. So that is
! 4 really the focus on the GSI.
5 MR. SIEBER: Well, the only reason why I mentioned 6' .that is that if the root cause is really configuration 7 related causing valve chatter, then testing will never solve l 8 it.
9 MR. IMBRO: Yeah, I agree, certainly.
l 10 DR. WALLIS: How about orifices,~just a hole, i
11 instead of a valve, you have a whole?
12 MR. GORMLEY: Yes.
l l 13 DR. WALLIS: So what happens when there is no --
14 when they are not functioning? What is.there, just air or
) 15 something? What is in the hole?
L 16 MR. GORMLEY: Water, it is still filled with 17 water. Yeah.
18 DR. WALLIS: Going.nowhere, just sitting there?
f 19 MR. GORMLEY: Yeah.
20 DR. WALLIS: Into the atmosphere?
i 21 MR. GORMLEY: Yes.
22 MR. SIEBER: Well, no, it goes to the RWST.
23 MR. IMBRO: It goes to the RWST. Right.
24 MR. SIEBER: Comes from and goes to, so there is 25 no change at all.
ANN RILEY & ASSOCIATES, LTD.
\. .
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
440 1 IMt. WALLIS: You have got to keep that orifice ,
I covered with. water, or.otherwise water backs back down the b}
[' 2
.3 pipe, and you turn on the pump, --
4 MR. GORMLEY: I see, yes.
5 DR.'WALLIS: -- it will blow out the orifice with 6 a waterhammer.
7' MR '. SIEBER: -If the levels are high.
8 DR. WALLIS: It seems to be very critical.
. 9' MR. GORMLEY: Yes. You are' talking about flow 10 . measurement orifice?
11 DR. WALLIS: I am talking about keeping the 12 orifice full of water, q
.13 MR. GORMLEY: In which orifice? At Shearon 14 Harris?-
fs.
/ 15 DR. WALLIS:
V). If you replace the safety valve with 16 'an orifice, right to the outside world, you have got to be 17 sure that it is covered with water, otherwise when you turn 18 the pump on, you get waterhammer -- the orifice.
.19 MR. GORMLEY: I believe that the whole system is
- 20. filled with water at all times, and when it goes back'to the 21 reactor -- refueling water storage tank.
22' DR. WALLIS: It's all full, all the way down.
12 3 . MR. GORMLEY: Yeah.
24 MR. SIEBER: Right.
25 MR. IMBRO: Yes.
ANN RILEY & ASSOCIATES,'LTD.
(O ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 1 (202)-842-0034' l
441 1 DR. WALLISi Okay.
2 MR. GORMLEY: The problem at Braidwood was that
)
3 .they weren't.getting the air out of the valve when they 4 replaced it, and so they immediately found it during 5 post-maintenance testing. And then they put on another 6 valve,zwhich they also didn't get the~ air out of, and they 7~ did'that about five times before they found it, and it was 8 'very mysterious to them,.which is why I say it is not going 9 to happen'there again.
10 DR. WALLIS: They really know now.
11 MR. GORMLEY: Yes, they do.
112 DR. POWERS: Replicate testing, replicate testing.
13 I keep telling you, this is very important. Sometimes it's 14 carried to extremes, but --
() 15 MR. GORMLEY: And now the' question of the day.
~16 The last time you said gee, only five plants, so I went back 17 and I-looked at a number of others. I went to the, you 18- know, those charts in the contractor's report where it said 19 which.the more important systems were, and I picked out 20 -first of all the plants that had high numbers, and also from 21 inspection I concluded that.the HPSI, LPSI, and in the GE 22 plants the core spray were the important systems, even 23 though there seemed to be no systems in the GE plants that 24 really were as important as in the other plants.
25 So-I looked at -- the other thing I noted was that
/~N JJ24.RILEY & ASSOCIATES, LTD.
$s,)- Court Reporters
'1025 Connecticut. Avenue, NW, Suite'1014 Washington,-D.C. 20036 (202)' 842-0034
442 1 the LPSI in the B&W plant seemed to be quite important. So
( 2 I looked at almost all of the B&W plants. I looked at a l
3 large fraction of the CE plants, and four other plants. And j 4 what I found was that there are no valves in those plants 5 that.will cause the system to bypass a significant amount of 6 flow.
l 7 In the process I did find one plant that had a
- 8. large, oversize relief valve on each HPSI loop, but that's 9 only a single plant, and really doesn't factor into the l
10 generic -- into the generic issue resolution. Even in that 11 plant,._you remember I was saying earlier, in that plant even 12 if both valves do fail, you still get enough flow into the 13 core, you get enough partial flow from each loop into the 14 core.to meet the clad temperature restrictions.
() 15 I'm hoping that that's going to be enough --
16 looking at enough plants to --
17 DR. POWERS: I think the most important thing in 18 your sampling here is that you, by doing 24, that you have 19 gotten away from those plants that have been so thoroughly 20 examined --
21' MR-. GORMLEY: Yes.
22 DR. POWERS: That it never seems to happen, but 23 they scrub out so many things, and we're always worried 24 about the ones that haven't had that intensive examination.
25 I congratulate you on 24. That wasn't as necessary as
[~'\ , ANN RILEY & ASSOCIATES, LTD.
\ms/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
443 1 getting away from those five representative plants, or at
(} 2 least arguing why they were indeed representative. I think 3 moving off those constitutes better sampling than that. )
4- Just because everybody and his dog has done Surry.
5 MR. GORMLEY: Well, the thing that drives you 6 thereHis if you're going to have -- l 7
k DR. POWERS: Got the information. l 8 MR. GORMLEY: PRA. Yes.
9 DR. POWERS: Yes. You've got the information 10- there. And that's a real good indicator, except it's not 11 representative of all the plants.
12 MR. GORMLEY: Yes.
l 13 DR. POWERS: And now you've taken -- it seems to 14 me you've solved this problem six ways from Sunday now.
() 15 MR. GORMLEY: Great.
16 DR. POWERS: Looked at a bunch of plants, you've 17 got an ASME code testing requirement. I mean, this has 18 really solved it. But for the sampling issue, when it comes 19 up elsewhere, I think the issue is how representative are 20 those plants that we called representative back in '86 when 21 we did 1150. They aren't anymore, because they've been I 22 looked at.
i 23 In the case of Surry, they were looked at in 24 WASH-1400. They were looked at in NUREG-1150. They were 25 looked.at in the IPEs. They've been looked at so many times i
1
/~% ANN RILEY & ASSOCIATES, LTD. !
Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
444 l 1 and so scrubbed that they just really aren't representative
' () 2 of the plant population anymore.
'u J 3 DR. WALLIS: So 24 is enough. It always puzzles 4 me, what's an adequate sample size when you're resolving 5 these issues?
I 6 DR. KRLSS: Twenty-three is not.
7 DR. PC WERS : Well, you can actually -- you can 8 actually sit dewn and come up with some rational view on 9 that if you believe that these things are random. And I 10 think sampling roughly a fifth of the plants gives you a 11 t'airly high probability, especially when it's more than a 12 fifth of the plants, because he left out the sister plants.
13 He didn't need to look at them again.
14 DR. WALLIS: As long as the sisters had the same G
i
) 15 . architect-engineers or something, because, you know, the j 10 details of each plant are different. l 17 DR. POWERS: Well, the sisters are going to be 18 fairly close on these issues.
I 19 I mean, in the case of this issue, it didn't 20 matter. All of them are doing the testing. And the only 21 question you're addressing here is is that testing in the 22 SME sufficient for regulatory purposes.
~
23 DR. WALLIS: I guess what we're saying is you 24 don't need assurance that there's no plant out there, all 25 - you need is assurance that this is not a generic issue.
/\-
ANN RILEY & ASSOCIATES, LTD.
-(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
445 1 MR. GORMLEY: Yes.
2 DR. WALLIS: For the generic issue, this is
)
3 probably a perfectly good sample size.
4 MR. GORMLEY: And we talked last time we looked at 5 the LER data base and didn't come up with anything. We also 6 touched on the question of the always meeting the 7 single-failure criterion no matter what the situation is 8 with the valve.
9 DR. POWERS: It seems to me your second bullet 10 there is yet more information, that is an inferential test.
11 MR. GORMLEY: Yes.
12 DR. . POWERS: So you have got this explicit testing 13 at fairly infrequent intervals, and then you have this very 14 frequent inferential test.
() 15 MR. GORMLEY: And there is also an annual -- no, a 16 once a' refueling test of the ECCS system as a whole.
17 DR. POWERS: Sure.
18 MR. GORMLEY: Let's see, I don't know, do we want 19 to go over again the -- go back over the details of the 20 examination of the five plants. We ran the PRA, looked for 21 the important systems, got that -- found that large valve on 22 the CE plant and calculated an acceptable CDF. Was there 23 anything else we needed to talk about or not?
24 And the last viewgraph in your package is just 25 what it'was that I did to select the 24 plants, the p)
(,
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
446 1 additions to the 24 plants. If you don't have any questions
/T 2 on that, it is sort of irrelevant at this point.
b 3 DR. POWERS: Not on this particular GSI, but as a 4 generic question? I hesitate to use the word -- you come up, 5 with a delta CDF of 6 times 10 to the minus 6th and you are 6 looking at a threshold of 1 times 10 to the minus 5th, and 7 both numbers are uncertain by factors of 3. Have you set 8 that threshold of 1 times 10 to the minus 5th through some 9 recognition of the uncertainties in the numbers?
10 MR. GORMLEY: Harold. Harold Vander Molen.
11 MR. VANDER MOLEN: I would like to find the person 12 that put these TV sets here. Can I have that question 13 repeated once again? The TV distracted me.
14 DR. POWERS: He looked at his analysis and he
() 15 said, gee, the delta CDF is 6 times 10 to the minus 6th. I 16 am looking for a threshold of 1 times 10 to the minus 5th.
17 Those CDF numbers when they are calculated have 18 uncertainties that are arguably are perhaps a factor of 2.
19 MR. VANDER MOLEN: Probably larger than that.
20 DR. POWERS: Maybe larger than that. And so I am 21 looking at a delta and I see it is below my threshold, and
-22 that's fine if you have chosen the threshold such that you 23 have recognized the large uncertainties in the numbers in 24 this bracket.
25 MR. VANDER MOLEN: This is a discussion that goes
("N ANN RILEY & ASSOCIATES, LTD.
(j, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
o
^
447 l 1
1 all the way back in the safety goal days, and I can't say 2
()
v that I remember all of it off the top of my head, but the 3 goals and these criteria were set on the mean of the 4 distribution intentionally. And the reasons for it, we 5 would have to go back into some of the studies that have 6 gone on in decision theory. But, yes, the uncertainties 7 were consciously taken into consideration when these things 8 were set up.
9 In the case of generic issues, the thresholds were 10 adjusted a number of years ago, but even the thresholds we 11 used, even in the prioritization case, consciously included 12 some allowance for the uncertainty in the numbers.
13 DR. POWERS: But it seems to me, if I subtract two 14 means and I get a number of -- that are uncertain by a r~
(%) 15 factor of 2, I get a number that the uncertainty, the 16 difference of those two means is roughly a factor of -- 5?
17 Okay. So, and then that is fine. So what you are saying is 18 that delta in the mean, I have to know to a confidence level 19 that is very small, in the sense of I am only 50 percent 20 confident that the mean is that small. ;
21 MR. VANDER MOLEN: Well, if I am understanding 22 your statement correctly, you are really saying that you are 23 taking the difference between two fairly large numbers, each 24 with an uncertainty, and of course the delta between them is 25 going to be fairly small, but the uncertainties are going to
/"'N ANN RILEY & ASSOCIATES, LTD,
(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 k
e 448 1 be just as large as they ever were, so that the relative t '2 uncertainty of the difference is going to be fairly high, am 3 I characterizing it correctly?
4 DR.-POWERS: That's right. That's right.
5 MR. VANDER MOLEN: It is a little bit more
'6 complicated than that. We can -- and are looking into ways 7 actually of calculating an uncertainty distribution for the 8 delta. Now, it is not easy to do with our codes. What you 9 really have to do is -- it is not built into our current PRA 10 codes at all. The closest thing we can come to is to
.11 generate a series of calculations for the base case and 12 another one for the adjusted case, with and without your 13 proposed fix for the issue, and save each calculation, 14 starting them both with the same random number seed and then
(/b
~
15 form a distribution for the delta. Hopefully, and, mind 16 you, we are still looking into this, --
this is not an easy 17 thing to do, -- hopefully, we will be able to form an 18 . uncertainty analysis directly for the difference.
19 DR. POWERS: And what you end up saying in this 20 particular case is at some confidence level, you are -- you 21 can assure that the delta CDF was less than the 1 times 10 22 to the minus 5th threshold, and that confidence level is not 23 very high, because the uncertainties are high.
24 MR. VANDER MOLEN: Yes, but they are always are in 25 .PIU4. I wish they were not, but that's the best of what we
-[\,s/] ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
449 1 'have.
/ 3-b 2 DR. POWERS: But we are stuck with that. l 3- MR. VANDER MOLEN: Yes.
4 DR. POWERS: My question, when you find the delta 5
CDF is close but not above the 1 times 10 to the minus 5th !
6 threshold, how close does it have to be before you say, 7 well, it really probably is, there is a high probability l 8 that the delta exceeds my threshold?
9 MR. VANDER MOLEN: We don't have strict guidelines 10 for that. We do'-- if you will look at our policy papers, 11 we do leave.ourselves a little bit of judgmental wiggle 12 room. If we really think, based on our engineering 13 judgment, that there is a real possibility of a safety 1 14 problem and that things might be a little higher, we will
() 15 continue to take action or investigate further trying to 16 bring the uncertainty bounds down a little bit. Short of 17 doing vast improvements of PRA, I don't think we can do too 18 much more.
19 DR. POWERS: It is just merely having a confidence 20 level that you command.
21 MR. VANDER MOLEN: Yes. In many cases we look at 1 22 a lot of these issues,- and we have been through over 400 of 23 them so far. In many cases, it is not near the threshold, 24 it is fairly -- yes, exactly. And that is pretty clear cut.
25 But we do have the occasional issue where it is
[] ANN RILEY & ASSOCIATES, LTD.
Court Reporters
\s /
1025 Connecticut Avenue, NW, Suite 1014
. Washington, D.C. 20036 (202) '842-0034
I 450 i i close,.there is no question about that.
2 MR. GORMLEY: Well, the other thing is that the 3L calculations are done in a fairly consistent and routinized 4' manner. And you can make the argument that while the 5 results.themselves aren't very good, perhaps the difference 6 between them might be better.
7 MR. VANDER MOLEN: Actually they often are.
8 DR. POWERS: I have heard people make that --
9 MR. VANDER MOLEN: If you have an issue -- I'm 10 sorry.
11 DR. POWERS: And I have never yet seen a case 12 .where that is true.
13 [ Laughter. ]
14 DR. POWERS: Where it is verified. I mean I have rw i j f 15 heard the argument that changes in a PRA are more accurately
%)
16 known than in one single one, but every time I do an 17 uncertainty analysis, the deltas alway.i. have bigger relative 18 errors than --
19 MR. GORMLEY: It sounds to me like a correlation-20 of the -- if you can't be right, be consistent theory.
21 DR. POWERS: Yeah. That was just strictly for my 22 understanding,'it didn't have anything to do with this I 23 issue. This issue is, to my mind at.least, effectively and 24 very thoroughly resolved here.
25 DR. WALLIS: Well, I am trying to follow the logic
(~'
A ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 451 1 here and this CDF' change is less than some criterion for one
[ (~'s 2 plant, therefore, there isn't a generic issue. And even if O
3 it were one plant, that still doesn't make it a generic 4 . issue. It just means you have got to fix that one plant.
5 DR. BONACA: In fact, it is the case here.
6 Imagine'that there would be communication to the CE plant
-7 that they.have this configuration, or is there? What action 8 -- you mentioned at some point two valves.
9 MR. GORMLEY: Yes. We will be consulting with NRR 10 and they will be deciding what action to take relative to 11 theplantwith~tIetwovalves. With the plant with the one 12 -valve,~we just used as the model for the calculation, it was 13 a surrogate for all plants, it was like the worst case. So 14 the fact -- our approach was if we can show that this plant j 15 with the large valve in it meets the CDF criteria, then.we 16 can be sure that all the rest do. 1 17 DR. POWERS: Ted, suppose that calculation had 18 come out 1.6 times 10 to the minus fifth, suppose it had !
19 come out 5 times 10 to the minus fifth, what conceivable 2
.0. 'else could you have done?
'21 MR. GORMLEY: Oh, I would have gone right after 22 the failure rates.
23 DR. POWERS: Well, you would have refined the CDF 24- calculation, but suppose that after you had done that it i 25 _still didn't work? Then I seems to me that you have I
ANN RILEY & ASSOCIATES, LTD.
f ,(y,)g Court Reporters 1 l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202).842-0034
452 1 resolved the issue because you are testing it directly. You
(Y O
2 are testing it inferentially and there is not much else you
'3 can do on that thing.
4 MR. GORMLEY: Right. Well, that's right. First 5- of all, the testing improves the failure rate for_you, but 6 we would be trying to find some way to beg the issue on the 7- ' failure rates.
8 For example, we calculated 8.6 times 10 to the 9 minus 2. The overall failure rate in the San Onofre plant 10 for relief valves is 8.5 times 10 to the minus 3. There is 11 an order of magnitude right there.
12 The difference between premature opening and 13 failure to close is the difference between 8.6 times 10 to 14 the minus 2 and 1.5 times 10 to the minus 2, so there are
\ 15 things that we could have done to sharpen the pencil on
[/
x-16 failure rates but the more we deviate from the hard data the 17 .more difficult it is to sell the result.
18, MR. CRAIG: But the point is for this issue, even 19 .if we had come up with a large enough CDF and a low enough 20 cost, the action that we would have put forward is the 21 ' action that has already been addressed by the ASME and it 22 has already been implemented in the plants, so I am sure the 23 ASME will find some satisfaction that we have done -- we 24 would:have donetsome analysis that might support from a cost 25 benefit standpoint changes they have made, but the changes p
s ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
453 1 have been made and put in, so it saves us from going 1
[~N 2 forward. '
L) 3 DR. POWERS: All the probabilistic analysis did 4 was give you comfort that you didn't need any additional i' 5 testing --
'6 MR. CRAIG: Right.
7 DR. POWERS: But in fact you already have 8 additional testing in an inferential nature.
9 MR. CRAIG: That's right.
10 DR. POWERS: Instead of a direct nature, so you 11 have belt-and-suspenders resolution to this issue, it seems 12 to me.
13 MR. CRAIG: At least, yes, 14 DR. POWERS: A belt, suspenders and whatever I
) 15 else -- maybe a rope.
16 MR. CHERNY: I might just add as far as the code 17 testing is concerned that when we first started working on 18 this issue I did talk to the chairman of the ASME committee 19 that has written the code requirements that we have been i 20 talking about, and I told him that there was a possibility 21 that as we went through the resolution of this issue that we 22 might identify a couple risk-significant relief valves that 23 may be, you know, we might be able to provide some 24 justification for more frequent surveillance testing than 25 the once every'10 year thing that we had already put in the
/% ANN RILEY & ASSOCIATES, LTD.
( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ,
(202) 842-0034 l i
E i
454 1 code, and he was very receptive to receiving that kind of J
2 information and to adjusting the code requirements l 3 accordingly if we could provide some basis for so doing.
4 Well, as it turns out, we haven't been able to 5 find any basis for that.
6 DR. WALLIS: So this happened in -- when was this 7 called a GSI, in '92?
8 MR. CHERNY: We finished the prioritization I j 9 think in November of '93 if I have the date right.
1 10 DR. WALLIS: So there were six years where no one l quite knew whether this was important or not?
l 11- !
12 [ Laughter.)
13 MR. GORMLEY: No. We have been working on it for l 14 three years and everything that we look at comes up as not
() 15 being meaningful in any way, so there was -- you know, when 16 you discover that, there's no rush to completion, and ;
17 frankly, we thought that since there's some uncertainty 18 about it we thought that it would be a good idea to do all 19 of these other investigations.
20 We started out we were only going to do two 21 plants, and we ended up, you see, with 24, 22 DR. WALLIS: So an external perception, it looks 23 good to dispose of these GSIs as soon as possible? i 24 MR. GORMLEY: Yes, indeed.
25 DR. WALLIS: Avoid even hanging around -- the more
, O, ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 455 1 there's the suspicion there might be something to them and
() 2 3
that early resolution does have a benefit.
MR. IMBRO: Let me just add -- this is Gene Imbro 4 again with the Staff -- with regard to the issue on the 5 relief valves for the CE plants, I just want to point out, 6 you know, our management meets periodically with the CE I 7 Owners Group, and this certainly is an issue that we can 1
8 converse with them and try to achieve some kind of -- get d 9 some industry action on this.
10 DR. WALLIS: This Slide 9 says testing of most 11 pumps. Do you mean testing of the valves or --
l 12 MR. GORMLEY: No, actually pump testing --
13 DR. WALLIS: System testing, isn't it?
14 MR. GORMLEY: Well, yes, it basically is system 15 testing.
.16 DR. WALLIS: No way of testing a pump as -- )
17 MR. CHERNY: No, there is a quarterly ASME code 18 pump test that is performed and you have to measure the pump 19 flow when you do that test and it is confusing.
20 DR. WALLIS: With the valve test at the same time?
21 MR. CHERNY: In the sense that if the valve lifts 22 and you don't get your full pump flow, you are going to 23 start looking why don't you have it.
24 DR. WALLIS: So everything is fine?
25 MR. GORMLEY: Yes, sir. i 3O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L 456 1 DR. BONACA: Any additional questions?
/
- ~ -
2 MR. CHERNY: No. As I said earlier, we have had 3 other generic activities that have looked hard at those 4' bigger valves over the years.
5 DR. UHRIG: Not a problem?
6' MR. CHERNY: There were problems. There aren't 7 anymore. There were a lot of problems in the early '80s 8 'with some of those valves which have since been fixed.
9 There were ring adjustment problems, there were chattering 10 problems, there were materials problems. There was a whole 11 flock of problems with pressurizer safety valves right after 12 the TMI-2 accident that were fixed.
13 DR. WALLIS: Let's go back to what came up in the 14 discussion though. It seems as if the failures or the
() 15 16-events that concern people had something to do with water hammer rather than just a valve and the water hammer does 17 come up an awful. lot of the time.
18 MR. CHERNY: Could I try that one? I have been 19 involved in ASME code activities for a number of years and 20 the practice -- two comments on that.
21 The practice that all the engineering firms follow 22 for water hammer is as much as possible to design not to 23 have water hammers, okay? That is the first thing.
24 The other thing is we did have a USI, an 25 Unresolved Safety; Issue, back in the early to mid-eighties.
l
/G
(,,/
- ANN RIL':Y & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 4
457 1 I have forgotten the number of it. I think it was A40 2 something-or-other, which we studied water hammer on these h(~%
3 plants extensively, and we finally, even though it was 4 classified as a USI we came out, as I recall, not being able 5 to justify any new requirements, and that was extensive 6 studies of that all over the place on that issue.
7 DR. WALLIS: So there isn't a requirement then? We 8 have this other case of the fire system had a water hammer 9 and it seemed that all the fire codes had to do with fires 10 and didn't say anything about designing the system so it 11 doesn't have a water hammer, which is an omission.
12 MR. CHERNY: If a system has a water hammer 13 problem, the water hammer problem should be fixed.
11 It is like anything else. You try your best to
(~h (d" 15 design those things out of the system. Every now and then l
16 one slips through, like the Shearon-Harris example we were 17 talking about a few minutes ago.
18 DR. BONACA: Does anybody else have any other 19 comments?
20 [No response.]
21 DR. BONACA: If none, I will turn it over to you, 22 Mr. Chairman.
23 DR. POWERS: Thank you very much. I certainly 24 thank you for the presentation. It was again, to my mind, 25 it sounds like a belt-and-suspenders type of resolution to
(~'g ANN RILEY & ASSOCIATES, LTD.
'ws/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
F I 458 o- 1 me.
] 2 MR. CRAIG: Good. Thanks. We hope everybody 3 agrees'with that. Thank you.
4 DR. POWERS: At this point I think we can go off 5 the transcript.
l 6 [Whereupon, at 3:35 p.m., the meeting was I 7 ' recessed, to reconvene at 8:30 a.m., Friday, June 4, 1999.] ;
8 9
10 11 12
- 13. i 14 15 16 17 18 19 20 21 22 23 24 25
/"*s- ANN RILEY & ASSOCIATES, LTD.
(,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L..
p.
i i
REPORTER'S CERTIFICATE This.is to certify.that the attached. proceedings
~
4 before the United States Nuclear Regulatory Commission in the matter-of: l NAME OF PROCEEDING: MEETING: 463RD ADVISORY COMMITTEE i ON REACTOR SAFEGUARDS (ACRS) l i
i l
i I
CASE NUMBER: ,
l PLACE OF' PROCEEDING: Rockville, MD i
() were held as herein appears, and that this is the original i
transcript thereof for the file of the United States Nuclear i I
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.
Mark Mahoney i
Official Reporter Juul Riley & Associates, Ltd. i
'f%
O
O S
E D .
5V R 6L A 1 A U -
EV G UF E SE F h SI L A yc gr I
S o ae YE R l
TR os ne ED O hR FN T yer cy A AY C yeTo S T A nl r mgat 9 9
C YI I TL I E
R er nl hoiu r CGeg 9
1 REB N .e e 3 O EFA O CPnR .E N AI knga i
r N
E S EL E n en e U GD R E awElc r
FOf u J
F E I o N OA T i l
n f M i oo NR M se OE i
vc i TP I
O i Df f UO C O LG Y O R SI N O ER S RP I V
S D A
O 4
S 2 O U O
9
/
I 8
H V D E E T R U O1 P S Y B9/ E S T N 4 H I
I L
I S T 1 6-I DN T B NR 2 A
I UE A 9 L OC G E E FN N C 5 R 6 )O I T
I T S 1 E VsC S E
O N
E EV RE T G UL (S N N SA D SU S O A SV N EA C I T
H I
F U VC C A C YE O L E D TI L R AN F M E E VO R 2 O FE AR G
K F M O O T N
C EM T F E SD LO I L N CNA A U I M
I B EC S N E R RG E I L
EY EN R D P NE T RIS E M E F UI EE S 2 I GA SA H T G S 9
/ S S SR A E 1 T EI ET R 1 N D RS BU D D A E S PH D E L T
I R H OO F P A D TG A E R R EF TN M I D E A DO HI L E R E _
H B T P
N AS GE L B C O- RP UU S E G O GO OF O R F N R EO HE R C F I A DL TR P A A R E P H O S S
- e e e e
,: l
O l l A B S
"y S I
A 1
6 1
X e- X H
H R
H rv' -
g= R H
R
}N #
S
/
3 (
R M5 l I
S I
A S,S A S
/r)t S- /r 6u-6uA HpC HP C 1 8 _
C 1T S91 _
/ 4 _
'2!* , [:
CH GrU-8 C P1 2 :ij!-
- 1!i } ..' i.
!* 1!: !- [I!i:i* !..
8 1 -
- lii
,:is .
iis i!ii.
h.!Ii .is *- -
S. 0 i !ii.
.[4.+Ai !
O C. 1 6 9
. . 6 y" rgS I
@M g 2 V,* s
- 1
- y" . 4 g -
r- : j i '- i::
S
% C I
! i i' S
,: i :.
.C
. 1 S
3 S 54 C 7 5
- h. 7-S6 C5 1
7-4 5
.I
. - 4 .
q S 7 S
@a
'D-C Q 2 1
S 7
S@ip C
I C
1 S$
C i
C 1
I . 4 _
S 4 Y, :*
ih7 i .
x S _
E 7
H , - .
S,
- -- S R
T s m4M D" i C l C I
S I T -
W S _
w gs2$vV l
A g R E
S
$>v I (
( -
-~
.I T.
t HS AH O
O T
L A
I F T E N I
L E E T Y R O T P I L
D E I N H B A T A I
Y E L T V E ER S A R FE H E AT N S SE O s A DM I
T V E EA I P R R TD M F C A U O N RE P S %
I EI S 0 O 3 PP A 1 T OT N T S E GE L O A T S C N N D H N I
T E RI E T A P "4 S S L L S A A A N L
B W I EN S C O E RA H NN I
M I
T V AHT R G OIA I
O U U S
I D
I _
H T R N L S
G E S O DS S P T O S L .
S E A M C A I
H U L L D UI R E E R N T CS E SE ,
O F NE Z SH E D I V I AT L E T O I sL T I Yl P S I
D
~
M I
O D P RV O KF S P A O I R O C P R S e 9 O P O c ! : . .
O N I
D E
T A L R A O N P O R S E I T
O E G I C G A D N N T D I A U A E H O F C E C G O N D E N A H I
L N O T E O L C I L D U T I
E E F I E H T E S V T N R O S R E T P U U Y M X M T S B E E I O A T G D E
L P
N T
E H
4 S N I S M I A T D S Y T T R E D N U -
A R A E D E M O G S R E H E D U L L T R A T A P I S Y A E M I
W E L T V L D G 2 E S A L E N9 T H I V
A N W L A/1 U O S H1 I T 7 OS Q T N G S T CG E A A N EN EN D T L P
I N RE DIK A N I S M O E T A E C A S I I
M S M 5R M E E O E 6I U EE U L M R 1 ML S P I Q SU SE O AR S I
M I 9 e GR L
E S O. R E
E C
W l D U l
E D S A I A F D O R T U R P A HT P H H TS I
E C T WS N T
A I
S H T TO NI R
W N AIT %
R A LD 6 L
S O F P PN 8 E E EO T I
T E T CC A I C A EN V V ,
G TG R I
T W O AI E C & R GE S S A B R A S , O R D C E T E U S N G S RA T T A U S A L P W SW R O H P P O O
B EO HL OF 5
E D TF WD N T L
N GC _
N%
O 4
A I
D A I 0 NN _
T G N E D5 I I NE U O A G E -
0 I
AS L R ,
I F 3 TA O P I R O W TT NE S U N NR OR E S O I EE CC R L N 5 3 D DV I I NI E
F E I F
VD I AE O S I RO R L U TS NN ET TB A W O E EI A SY AT F T E H L D R CIL R OP EE I
V GB I E NA sT TIBHE RC VR S AT I
RI E R PR LA L EV OH O AU I
AN A
I WA NT WCF FA T
O I
N I 9 G 9 9
O s E-
+
3 3
, , A S S 5 R E ,
E T S T A E S D T S I S A T G D N G N T A N I
S G N L I s N s A P D E- N I S E- L U E P R L A C N A ~
E .
C 2 I
L E 4 E N T X , C , C O S .
E S F I L S A E O E I
I S N T F T N T S O A A G O A R I
S M N I T D A S D I
T A G E R G G R N L Y A N N O Us N E I
U I 7
I S D F O PE -
S 1 Y N N ON I C T
OA P 2 N
E C
S T
3 1 E C
I F
S 6
G O E , I N S I U
N N HS L A T L O
T E F I
T S T F L N I R FA O P A O V T L E O N OD S L P S
R R P A TG R 3- P P L S A 2 L A U P OIN E Y E 4
E E
Y O
T S 4 MS S S 2-
-N 5 U U 3 N E S E 1 1 O
TC S O O S
, I T
Z I NL I
T H H T P S A F N G G N E L A N N A C E PO L I
T I
T L X L
P W SR P S E s S
E P
E E
M &A E E A BE C WE W G N S 5Y 6 4A 5 4 O Y
D e e e e e e U
O T
S
! 4._
4 6
O _
D m
N U F _
O O -
m F N m_
E O E R I S
S E R A W E L B S VA A I I
DIT _
T R 7 _
E H S H N NY T G N EL N U I
O TN M R E
V O
R A A OO P
X H N E H E S DE E T E EE 0 R O V R 9 E T L B U 9 OL AI 1
M W
s R
A L
W E
I D
E T
OE VV NH A 7
F O V I V R I
R R M E TD V F I
S R O N L R G P EU D N S D E R E I V N E L R V E O E H L O S S W i
L C O I
T A E R E I
T R
V A R R R F A N E -
O D D U U _
E S
I S A D
L I A HI L
W R R A A S G E F NF _
E A E E R 2
I L I N O N .
V W D U I RI E E Q A AA m R E N G R ER S I N E N R T HT A I R O S -
B Y P N N A T R S 5 YW m T V LO A O O E N L D F N S e OF O e
- e e e
i i 4 O .
N E
I A S E I F Y S BO O F O DS I L LI E T R N T UE U E A OR L D H WE I I T H A D H ET R -
F L C R . E E U U UE T L O S LM A G I I AT W N W T I
S G N
E FE D EL E A N I C HB L -
TA I
T I L -
H F ,N I
S T F H I
E U SO C W T S NS C A P E OA I
A I
R M R TE V U S AR H O E P D A RA 8
T I T E I
Y U PN R R N I C LE L A O D I
A 6 RM EI F L LE G 4 TT S O AT N 0 RE C O MC I T
N 5 AL C C E RE R O
I T UB E DL OR A T R QA EB NR T A N D S A P G O E RIG OI N O C M N S R T L I
G R T I DD P D S E DA O SGE E O EM UE T EN U F
SA E I
S F
Y M TE LR C N S O N U DK T
S I
,S Es S TVR I
N N GE EE C I
A AY L T NR N O
I T TV E N V T
E PE I T L U NM SOI C R LF SI I
T AO Y CL -
O R LA EA E UR SSN P U AS TF L QF NIDO I e P L I P E
O U S
A F e e D e e
, < i e a
S O Y R R Y E S
/ O R C -
S T / E U E Y U S P A B Y H D -
Y D I A T E N T 5 R D M R O T T D I
N 6
3 N 5 O L T O 6 R A A ,
C M 3 F U N
L % E ,
6- O _
P 0 T T %
I C C 0 N S 6 E W M I 1
A Y 8 6 S A SR F T S F F P X A N O R I O O M E B E O S U 5 O T P P E E P R T A H T S E GE M A A T H NL R I T S E N R E T
A O L T C M U VI M P A N F OA O I
F Y E CV E C I
S N R L H A G O N A L A P N O F OS I
I A
U T
F N H
T 5-I T
9 S TA D O I E S _
N E
AR I Y V -
M E NP V I
L R. A L 6.
3 E T LY F R Y I
MD D " P T N AR/ E U L AE OL S XL I
US S E R Y I M DY A C FI A E S EA E VA I
OE S D5 S T A O FD Y N6 WR U N SA S I 3
R O
F O EO Q% 5 O TH S N ,
NN F7 N C I
A % W N AH OY AIC "
I T 0 I C R0 A A DT NB C LH E T1 R E I
OE E PW H HT D T TW T U I
L E
5 R C CA E I E AS P AL TO A AF F N LT S C F E ED I
T O UL M V E LC N CU U LD l l I E
L I LS SI S EN A AO D A AE SH SA F FT I F CR AT O e e e e e e e
a D
O H C
N A O I
H S T
T L W N A I
S A T E L N-V P E L L T A L O V A P R E R O H O F T F I E
N s S V O D P A I l
~
L H T & & E A P I D
M S R
D F P s I
S N D H E- E O A C S A G F s O ES /
N Y R R T TT H A O I G A S
N O
UN TA I L P
A H
C 0
1 N F I T T P R S I
T S G I
T U NE E D R N B OG O P O I M E P
A R CR I T G M L T RO U P P N N E F F F P U LI O VY O O E N S S AA A C EA E E HI NR I
R E TR G G TA OT E R AP N N NR T U HS A A O T TI R I
I E
I R L I WE R R sI R D H C A TR A A VE D T N F AO R R RH A l O N I
KC E E Y T Fl I
T A OD V V Ll l OA C R OD O O NA F E T LA C C OF WD EL L
E I S e e e e e VU O EO RC e
O .
s .
s -
e .
n _.
S e _
v -
E i t
SV c _
TI e ST fh f
OA S I Ecr CTEI ya r e EN S os TIY YL t n I
S aR N RA l
7 4 #
uy O ATAN gr q eo a & dRt a 9 E DNY l 9
R
- EUR ed F ngu l
9 B TLO y ya e 1
Op g 4 ROT B 3 g& # EVA V
esR ni e F L dsr ya n
- A F
OUG i
Slale J u
O TN E nc AuN m
TE R s m
NMC E TR mfo MAN te e m TE N sc yf i m_
T D o m
N n A i o _
s i
i v
D O
L
O ~
l l
y t st r
e a ut l i
c b i
nys a) p ,
e y sel t n t
i h ni s
ywal e
r l ce s t
a aCfid i s
) t nSiun o C a A O gG C S h t Ai( e O
t i f s n t s et r u oi o i
s A ee e n o n
(
S c
n s e h e s u O T e n Bt sl d swe r c e i
S ue t n t O
qc ei s
l r
os Cl t e vrC o r e
v C ne e u A E oht w n i n sl dit r -
f o o o 1 O T I
c y Pi Creue on f -
S db t Sywe m te y t a Oa N
al t nn ei Ap n B l y
n O -
o l
e ce mm eisis ot r D
E t r
i r ea ct nis r
ddso u ol uC c
a T nd a oa l ce n R e l pcp cs a E
de in eee nl iaet xh s cr RDR a V co d A ab -
y e
s i
c u l
s o i n P C o t S i
t n O i
i n e r A '
f r e u O D C
r e e d t i
s r u n o b oe ct on t e
i t
t r
ei t ol pc a v A s Y e dm da t i r s x C p u i I
L eo e o f O
ec n s g n
g o t y
P -
so i l se ap n a t f u
sa l
T - r n N
yep h or r e c A ee s _
E r -
rk n f v _
o e o o R -
l i R e ah c t at c ne _
h mtf e n e i U Tno c gv C t o s n m oer a
i l i t R f eic se d a
e l
ip O
F nc ee ne i
u T r ed c n 2-L Bdu-G s d u a A t oq s B s '
A o r e N o se s Mi t A pit v
O Ct sn Ofe F n a I
h co h n h ai t g
T t if ec t e t ci A
e i wb i
nm R t wfeh l t t d t w
o e S naf ne n i s r
' et eo eiz e u ap C t siec r t
sa l t s l R i so u ins i
s cm x
N nst n er n eo -
ol c Cap l i ot Ci n C o
t sC .
i -
e e e e
1 k
O w dl o l o eao l
t a
l srl n o
pve an l
a e e ee eh rt o oc u sm o
o r pheC s h e r Y f g en et R i
s wc,n C
I ri et c h nN t y l a s i
e t er e h e t i L t t f
a o ce s O d or ha af so s no P n ap t ee c op T ed erb dc ny i
l b
ym N u so n ui t e u l
e r g i
E l p
sy cl f yi n R ie niaa e l ns yb ot s v l ar e R t eo c nad l o cub nc U f g a
t t n ss a v i p
C st a ub i n yd e muh t t naqu G dh nt sl t
a a l l
e Ca i
h N as R e t w n,ns -
n 3-O I D h t o Ni nhc t s
n yio o gt ac R
i l
at a ,t el ubs i
l e r el et ry A h u l
usui t m n ot e pf e G cg r e pf e e E i e t r en l
e t sa l
b r i f l l n e ad ns R u pse kih e cwt f b s
e r mt n S bat odn d N ap o n u e ,a cg R
t oi m e eno a h mis l
c n l ant h i
n o t pna l E r et t r c s i
C eie C et eie Rmh N
r aC dut nqoco S O
O C S Nl Rci Ur e pa rt A -
C Oe b u
At hp e
O
~
_ t a a O h t
t m n t o
s o o i s
n n f r
e t n
i o e s g ss s r a
t c n oi i
c a a c )t n
e t s p h c
a e d s m sd l
a o I f
o i i c s c n c l
n e p a s i
o i t U-t n
t c o a t
a s n e e in t
aa r n a m f
f c g e o esn e i p
e f
n Cnr o l l t i
- ) o a h di t T
' d i
c - ei v t ore N n a w n
a t
n yE mn n o
mv e n ea r a O t t oy mPdn i
n i
C nv f sB er n r e e
e a u t e r(
(
mp ae m i
ae S t h s e v sh t pm -
secn t
N ss o nl t a 4-O R e v 'n t Gceeay g e
r ei rt n
E no i si el eLiHre t
t ke w n
i s gy t ao C l as gb t al l c n e md N n i m uy S Aie t
s r
oof l
sl O d subt n i
em e s C
t no e ci v n e n t
e e?
ns aerP o mn? c?
n C i
m c eu ie il l
amlae r r c n iait t
Cht r c ex eto ea ie ndf R d pe dsnl e uepe t om wie on Nn x e en FCGr st i
ove
's d n dab eyo I r aw veb Mo eo l
Tb Ld o
ve n r ia e
O
~
a O r o
e t h i f
t n e i
i s n e d sb e a d b a l
u t e c f b i
Y n e d i
nl C e bo eu I
b L .
d t h es O l u n C P h o aS C
s nO S d t oA e i s sr O t a e t
l e e v uh A r e st e
rh e t i F e e n l
b bm yit w O C t i t u i l
cf f eo W S s ul b o on pen - _
O OEI A
e i n
o d
n e i w
e Cs St s c
t bo nt t ess i
5- _
V d t u s m V Oo r oe -
E n u rl m s Ac r cuq u
R o l
c oc o C ct i
s x e
pn e i c G f e oh seh ne L snl u e nt Rt s t
'o r O p st _
A oc i t oto or e e -
in t
n s u s i sn t C t i a
s od b e2 u d dpu a
r ts de s0 st om i
I t n r l cn R eisied a u e n_
o o1- na e ne s O bso ce l a m i
d9 i n ivo s s n i
t p n8 vm l
T er d ut -
i l
Dop pon Eo ie ncs f EY t r m et a d a e S l apsi o l c onf nC ou pl idl I
aer ii o oE pco u n yt H o uis o n ist i
sS u gel e G 's y s l
ri Gy l pes ins ss dmifas ySs m t y g t n Orsoc mo Sf t
i emtno s oet f
t eRum fCdo f eo Coda mM Ren i vcss at r Gn oR Ce eeso SaAInC s
SS OEa CS Ab RREc 2 5 7 0 2 5 8 8 8 9 9 9 O 9 1
9 1
9 1
9 1
9 1 1 9
t o s O n 's i hCgR y
r d t
i uN t a nt e r
h ot n
en t u l c
t e xl e ov l
l u
am t,e e r f
s al h o e t
h p f s t
m t o ne o pes S so ec sv r
E e ng i ui v V sn o s pt a
I T n ei o i t i si t A
ii ctayt l at i sn I i ud yi T
I l
y ul l
i i c er l ayr na l
N a c c b gb ei I
at -
OYR dRse n e o yun 6-mCo s n t i l A rRp a e ,
vo T s cl iv N f oNe -
e b s t
i s r U
r yr eb y s aciev nf e
o L p r btait sr ne s etdo cia O r V nr a or ait oi v i
oil uu F pi n F g t
cqg Ar eer -
y i
c l
o n P o t i
t n -
i i
n e r
f r -
e u _
O D C _
e o yry -
O h t s i t
t t r
ao t o i nht ,h nla t -
sg uu f st nu f 5 na ao l
og a .
9 oh i t es v er ysd r
t ti 9
1 t
cdme b t in di aee tnth c r ae e e s u t
yn r r ml d rt cc l dg n e
t a cSo2eou topa oen vki m _
Y nn uo .hs 19 9 f si d e _
C t oi m oav r o csns l i -
I t s o u L
O ve r os".
nd en nr e ep r q e
nat es i ta a ns r P
F o
nw e caoo ypt cn ri isr pe t
m od as ir a
i s
s e ,r c olu es y -
O kaetr asa r a t ri mo w l a
tnevn i
sh pv s t n
W u.lyc u p a f o
f f
m oye a E owl oa n s a y I i s n t Ce t V t o v ae iHs i
t o s on i v -
e OE g dwa 7-ii o
i y a R p s. ao gr r t
al a t
8 v rt et h t
i s
E e ert u h u 2 o n h nuao t c r ei pvw e D i ol c sl a4 0- s p e e t
ec u n l
l h dsge e c9 5 e W. t ii i e e r e9 9 awu
- os h t
Y wudrdgoen gh 1 Ynh s e at Ci o ,
i d
e C ed t ht a e R n "s. Esse d N r ed gsn et Gs i
e Ssehvt i d E aoedo Rn s y mitt i a G ept sm i Col a Nmii as f f
l ol t o i
Ooiv t a A Wri
" pwop ur " aa
.t
. cn SCirne I
S t
- - S I
S R M R G M C R O A C C e e e O
~
I o t u
o h
t i
y w r
a n Y t e n v C
I l u e L o n O v o P n i t
T i
a c t s a N r e e E e e e R c s s R
f n n o e e U s e c c C c u i l i -
g oRO l
i 8-t a s y s v s b i
r o F e d r c
t n deeg t
c n a e E a a t ade L r y m m pl A a r r e N h a o c r iws g c n f o so n O
i o
i I c i n f n dnk i d
T i
t t e U e e i l
A as r - b 's s R me ei v c
s n k c nC k c
l t i o a aR a ba i D N L CN B ot ri Pi n - - - - -
e o
ln
r O f a oe l t ync o r o ne t taias Y set a i nui s C ulcs on i
l I
L di oxn veo O t ot i P
i eet t
as h a -
mTu l
T h e u N t e s .
c n s l
E R i n sa na ac l
3 e yoe R 1 c l is U
i l t C
l r aca Sf o I
i cn c-G puf e De y s e N ov t dai c -
9-OID t t r n i
)
s nbt a r a c R eec A A t n ns Rcfeor p G Pas ei s E
R uim ot cna
( l s pvh it niger nnt S uc o i oiam i N i rf r ta ri et o R o f p usy l u
a nr i f E t c sye r a mr s r C r ea l au N adt c ratn tr O ein pvu k gu a C prolo sol p Apv ir oe Rpvd
- e O
i o
O r a
n s e
e yv c i -
ser l e t eo i v tai dm i
t u c n l
ca l e i y
n , e r i
sa
- e. ,t e nu ei l
- l b bl i
ca esv i ao cv t i t r -
co ct -
aia rt af rt pi pi n d -
nre t i t _
ny er ec xt a t t S xd en eer N eu l eu e y O h t o v h t st aa c 0 OIT i
t o r oem l
o 1 P ,f o t
,mi t p
y y O id l
ci t i l
c se se t n
e oe vt r pr ois pge r cet u t t t b c nda na e eem r r eh rt t r
c i
s r
r ui u t u ois c ss i l e N _
ae cra a e v
e O oet to nr r I t
mse T n ecr e y n l A ieo sb oso t e D e
i ivic t
iem t N dgs i t dd l
p E A d t i
B du a C m M B n a aa l n
al c ,
o M o it nh e r o nn e.
iii n
o C O n
o i
t p
i t
p i
t p
C i t
p E
O e O e O e R O O
~
5 1
K f
' o 1
e g
' a S
P o N I O RS h I U c NT S r a 4 S e I
M WAT d s
r R
s e
M O a y r
O C DS T f u
g e
a l
t o
a u
Y S g R U M r R e
O T HA t o c o
ya r
9 o
A L
U SRG t d R e n a
e b
d e
tn N l
e c
u 9
9 1
D O t
n o 3 G e s e ef e E s o R
R NR A P P e
r t t
i e
m P
e r e i
f f
c J n
u A m O E R H C o ,
L S. C u E C y r
m a
WRA h
o g s n U. N i v i n
OE d A
n u
%, y P S E C
k r
a o"
e wR M o
n * -
O~4E L'
5 1
f o
. 2 e
g a
P O
k i
s R
s D e S i t
P i L i v
f t O o c ._
A s g e n f v m i
f -
i t a d
n t a .
c r a e g t p S ._
p s o r
s r o e r _
r P e h u e s P D d k t n r u l
a S U o F e
E c P L t W /
t l
N i r n n u o f e c e d I t f r i r e L s a r l
b r h T i H
t S C u
P u
c u
S c
U O O 0 O O O O O
- ! !;! ii l ! i!; !
5 1
f o
' 3 e
g a
P O
k D _
s S i
r P s L r h t
n w e cf r o e a g v po e e -
si n l l ed r
al n u n
o f n ta i
o o s S t a t i
s r s e E r e _
V I
el pb o r a id mn mu i
d a o r O c n p C e E a m ot t
P s o t e n S e c db o -
R i
d k e a i t
E u s d c _
i n n e P t s r e ai r
L C D mg i d
A R P S mo ot n C N L c s i o
I s e e e s R ut ri t
s o a i O i v c Si v Rikt m
T ed~
r n i
C cis m
o S P i A a r C I
O H O O O i, j ;l;!
5 1
f o
4 e
g P
a
. J o
k p i
s u r t o t n r r a g o c f g -
p i f i,s n k p ) nis M
i n t u
s g n rki)d e r r 4 r
A i s e c ot7a o mnwr1 d R t k po) p1 o n G t n
e i
s r l ocApet eeR
- a O i y vsp si ud s c
R i f
f i
t dheeOoGuA tO t R P f u n e d s
eC t nr s yP s d oz( eo us D k s
i d
h t
l yh i t a cic a n S
l i
r n e nafrfgsue a ma P D n .rssR
, euen o o L P L
S i t
o a
goe ee
( t e i rk s gD
,c A f o m r s av gi eitD(P r eS o gL G gg nn f n
it t
isr eeP a S nf N ii dk na i
D i
t v v nor pL k o i
at I omn tam ci o P S a r cf e e nm s
r n P h el O ei o L ch rt n a ci op L d s t n ar o nso E ailce i
n c e eui V ue r r
sf e
td aiev e
- nd u r tonud E e a d csnm,tepet r gd d _
vpe D
s r rd r iom tler : s eo I e cfd enlomo er p C cvo es nr e s oee vop ef u eef n pAcP n R jDi b co neDiS o N OO SO O O O
5 1
f o
5
~ e g
a P
t a
O e K s S)h I h o
R c e t r m n a o a De s r
h t
Ss o t n
P e r
f e
L u n s r o e e F ta i t
t a f f
Or e a r
t s i e d g
Git p o n l y
N l
i t t l
r a n I a e r a c
O Dit w o
e p
i Nin p o f
i n
Ai l t g -
Td n l u n a
i s -
S a f l p e _
R s t o
g b
E n Di de e se n a l
o c bt Nu aa rt m
a s r
Ut s as p g s
e o r u e t
TC mn i r b w NR EN coit a
a v i r po F r F t -
R Dp e nl m D ou l
R o C o C Cf U r O C
~
(f 0 O O l i !
il
5 1
f o
6 e
g a
S P E f 6 9 o
4 I l u n 0 0
0 0 D k G a e 1 x
1 x
1 x
1 x
U sd )
r M 1 2 8 5 T
i a
r n e 4 8 3 9 a
S t e
aG r y r
a -
D gr e o d
n e -
S rf g
gn l
a c
5 8 k
s 2 3 P
- - i - -
R L a oi r
e h
t y 0
1
_ 0 1 y 0
1 0
1 p 5 x x x x d ta e 9 c
- n. 4 6 i t
2 3 D n r r e k s
l a -
a e a u 1 i 2 t a
1 2 N yp c o s e
q r
e R.
ty-F A n r l u
a F- l i_ a r
e e e v e g
c n
0 u q w a.
t a- a e po l
l m F c 5 r (
A l
s e a D
6
- l y ' t n
3 4
1 f l s
i t ht 0 r a 0 e 0 0 e c n e t o
l 1
1 u i e 0 r x E 1 a 1 x
1 x
gf t s c o x L
- a r 5 C 1 1 9 4 i
e . l a
G md t 1 1 2 aP 6 a n t
t - - o S
E d )a e
- T R re nw i t
v U o cd o i p
r N c 7 2 4 5 r tu s ._ -
2 o e 0 0 0 0 fh b h 1 1 1 1 t x x x M s s 5 8 5 x
3 4 nd O ol o 1 2 4 1 R i t c F u(
b 5 S
i T tr S - r - r r L i sO ' e w
- e w 5 e
w DP ,N o o o U r '
P P O
S P S o l l
l l
u P l
l u
o E R
f F
u .
F F 1 !! . l! j ' : . ' ,
5 1
f e
7 e
g S -
- P a
E 5 6 O I n
_8- - - -
D a 0 1
0 1 1 0._ 0 1
0 1 -
k e U s )
r M 1 x
9 x
0 x
]
2 x
T i r a e 4
-4 2 1 5 S t e
y y
r -
a r a D g r e
d n
e S r u l gS a c 4
- 6 k
s 2 P g r a o r h 0
-. 10 0
- i R 0 0
L e
p t y. 1 .
1 y 1 1 -
d f 5 c x _x x t x x n n e 9 n- 0 k_6 4 i 5 9 D a o r a
e u 1 i s_1 5 l
t a
5 1 N yt c a i
s e
q-e r
R y F a
A n r l u F- i t
- e r
e pe a l
e- ta_
c v n 0 u q o g
a- a a F- c l
5 l
e r r A
( s e
m a 5 y ' 8 t 1 f e l i D 0
- l r
n e
w s tn ht e a0 0 0 0 O 1 e c e 1 E1 1 t a 1 1 g po i
0 r_ x x x x x t
s c o L
- a i r 5 C 5 -
.6 0 3 2 e l a
G ml u a
l t
t aP 2
- 3 7 t o
5 2 E S d f - T e
R ed r n i v
U o a t .
p -
i c p r N r o o ol b
c s
e h
6 0
1
. 2 0
2 0
4 0
1 4
0 f -
x 1 1 x
1 M sd t
5 8 - 3 x
6 x
0 1 x
O n mi 9 7 8 3 o 1 R
i t r F u o b f S i r -
L T t i
s '
r e
w _ oo p r e
w p
o r
e w
D ,N o . o o o U
P .L P L P S ^
" l l
u-d i
M l
l u k di l
l u
O E - F F F R -
, t : :i! .l
2 1
f o
8 e
g P
a o 7 D 2 S f P L f k L I t a s r i
s o R
P s r d f t D e e A r S e r o P n g u p L s n t p i c g do k u D u s i n h a t r
S o o
g t
e n m
s P t n mo d n .
L n o d i
s a io d ni c h N t n a
a e c a
o O a s nd o y o m u i r P r o t r pd a o p r O fo a a i
v mt a e e dn H in r rl p o u l a
S r f n
g e
b at s K e f o
i r t p s R ht s D r e u O am S o -
t c s ga l
u P f c n _
a e W drg no s
e r se L
f t
yn e f
ys n o
C arp es r y i
t i
i c i t
n c
I t nf eA L i cD hala n d ef u d R B S a s ;
P U liS I 1 oP SL o P O O O
. ;! ! j i ;i
5 1
f e
~
9 e
g a
P a
O s
i c
p o
T r
j o
a M
r u
o F
n l i
s o a n s t e
O i t
o i
n o d s n
a s f o t
n s oi
) u t e
s y c l
e p g s v m e
r r i
D e u P e l s
t l a d s ye n r n a r s E
( s e s ad t u s a nl t e n P u ho h dn x ek o e u p a s o sd O d g c G e cd r n n e BeT o :
r s a -
H I gs i
t t
e e h
n r t b Ir n oDDh od n S n ei civ u aR o eP o
nSS t et a K i nWSRSSE rP P ELL MS R r o f t
O Ma = = = a = A = a e a --
O W O O -
- !!tt j! '
5 1
f o
0 1
e g
a P
m.
l es O o r nn no f
S t t
n oi si t E f o a a rd E r h l p en po D e t n r ac _
N d a r a l trde E o h u _
t c x r _
i e r i
t ei
,s m e i r e de a a h
A s e i h
g p y
l pn mu P h t e b ae xh O
t b d f e et S -
H o n s r P oge S d a u L .
n c a fa r K
a F c ;n o R
da D F n f tem t
O n Do C c a Ci t no i _
O c D r _
W i
a et y t f
iF S Dr msi t e Y nD g
P L
Su Pd l en r og m B iCs r ) L d
pi e e s
r u oe mtt ian a D ee o tt ci e E bw h sm i
s nl otn l
e no r r ol r S ap i cl e t ol ia tcincm e l S Duf l
(
p u b o f
at f u
E i e
s r s yria i
R S s S Ps u t n rct n u P La o nio o T e t too a X L md e n r ae ot car a c E U S o u t w tsgu sdn n eia t
o n
s E fi rt n
n apo ei e ng t p F R Fg t gf rn min R w
E D Da Cm If sl nu l
Lc ao ossia Cam E
L I S P
O V L O O O O O l :
, 3 1
f e
s 1 1
n e g
o s P a
i t g e r
a n o r u
g i
r u
f d
i i
d n S f n s a E o l o s E c r d o t D t n
t n o n d N a o l f
a c e r
c c e E i l
a i
f f t e n i
n d gm i i n h i s
r g i
g i t t i
e i s
n o
A i
s t ef n i n c k v o i
g y P s e had o l
i d n e O r e i u i
l o
t a
H t n r l
c o u S
h t a pe n c q K n l
p i
l e o t d o d R e c o r l u o p
a s
O u nh o n e
0 c i s s h
s l
e e W f o
y k
s r a
o D
S f
d u b t
Y i
l rf P n o B n L a n o nt o s e
, r g v D S i i t x e i n a E s e h i
O n t l
d h S P aly e n a
s e
S l l
a t r n o
h w h g E e l a R d d ed n t n e t u
P u u e c u o a f X l c
n l
c n n mi em m d e
E i i i
o es ri o
r n n
t t t e s o n
o n
i s
n g
a s f
k l
a p
w E o o a r o dn i s n E P D Dt Na R U I O 0 V C S O O O. O O
. l ;i I ..
3l
5 1
f e
2 1
e g
a P
~
ek O i v si r
S t d E taD n a
E i l S D aP uL D N q s S E d s P e re i L i r d d o A ed e f P n a t n
o :
O et ek r H
b t
e t mo S o a t
a w K n u el a y q r n R a e t o O mda t nit i
O W h ct s ed rd a p e a Y o e f f e -
B r p n c i r a d i t D p o u a E a c d q d e e e S Ah t e r a r u
S R p n i yeirl P e s a s E at R ed 4 v -
e u mif n mre
,ct r
P s i t n71 s es et X b i
a e1 - i s r se me E O H i t
t sG i n f o c p c c u u i r T- n eR n a eu q o S t a t r e rS e s w- M u fe r o eh E D Qd f C t = e a I S P
O V L O O i! :, i ; !
fj ' '
5 1
f e
3 1
e g
a P
O k i
s r
S E Dd S e E
D P m r
L N fo fo E s i n
i -
tc k i
ei s A p r s
P a (n e g O k r u ni H o w
i qk n a S E u m K e n -
R M h o O S t i A si s O s c W d t d
e n e s e d e e rd .
Y e e d tr B n r a o s p o pp D i o t u
E d t r e d
e s S a di v p o S nt l ot E a a ed v e R
l D
t s e r ed P R d es n e ne o t
X A n ein g
E D b i N mm st _
A di s a s T ei eT r
l u yi l c
w S g h olap n p D A u S a a E
S I _
O P V
L O 0 _
- .: ! : liij j L
. . 1
5 1
f o
4
~ 1 e
g
~
a P
~
O t) l g
nr a e
eo n (
mit i o
k sn t a s so n i e r sM r e D sk k
a i s i t
n P S
s R L S A s i rr
, d n f E R Dt o a o I P c g Si n T n i
t I D P L
o s i
d) s S M e nsd V P d ey m )p m ade I L st o u a t oe i y uef d o r t rt shn r fr g re ek O c t s
ya og o od m,wor pn A
l nS wgn r e
r u s u o p d ,
ei E n mS ikv h t
s 's S er R
i mO e r g efOu w
e oO c r o i s
vf iaPt U f E l w r tt t u a e cs nf T t c
t sM o
nA oR v e p gag U e mA iP t t o si n c ni i
F l e eR iO d n rzfz ei prnr i
i
/ s a
hO dO l a aga T e t(
es a (C p amim s N n nd o ms t r pmk m E-i m
i mh rt or o p
l o usu i f o eSrS R a x
at xe rp p u
v e
R E Em ee P r S D= =
U O C O 0 O 0 O ii;ii li 1 : l
= 5 1
f o
5 1
y P
d 9
9 9 9 9 9 1
9 9 9 9 ,
9 9 9 9 5 1 1 1 1 y y 9 1 r r l
u l
u r e e e b b J J b m m
/ /
e e e o e e t n n t v c a u u c o e D J J O N D O
w i
e n o _
v t i e
r s _
r o i s -
p e
r e m .
u r m t t o E a f C r a o L e r g n t U s i
l t d y
i f t r
D t i
l a
n r
a i e
r o
p E t y i s
v o n b e H
i i
i m r -
v t i t S l C a i
i t n d l e R c a C n O. S A l
P d
A P r
A F i
, l . '
!; !l 4
!jl
, -